Tag: hunting

October 23, 2017 Nick Kempe 3 comments

Just when it appeared that the Cairngorms National Park Authority was starting to get a grip on the proliferation of hill tracks which has blighted the Cairngorms landscape, they have blown it.  Faced with a proposal by WildLand Ltd, the company controlled by Anders Povlsen, the Danish billionaire to create almost 15 miles of new hill tracks between Glens Feshie and Tromie, they have decided these can go ahead without any planning approvals.   This is an astonishing decision which undermines the planning system as well and the National Park Partnership Plan approved earlier this year.  (You can view all the documentation that has been made public on the Highland Council Planning portal here)

Photo/photomontage from the landscape assessment

The purpose of this post is not to consider the details of the proposed tracks, which form part of a wider plan to reforest a large area between the Feshie and Tromie with native woodland and which I will consider in a further post (there are I think many positive aspects to the proposals), but to look at this decision from a policy and planning perspective.   What is important here is not just the size of the proposed developments – 15 miles of track in a National Park – but that 7.3km of the track are within the Cairngorms National Scenic Area and 9 km in the Cairngorms Wild Land Area.


The policy position of the Cairngorms National Park Authority and this decision

Many conservation and recreation organisations welcomed the statement in the National Park Partnership Plan approved earlier this year that there would be a presumption against new constructed tracks in open moorland areas.


This commitment was developed further in the Main Issues Report, which set out the main areas for public consultation in the forthcoming Local Development Plan, which was considered by the CNPA Board on 6th October:


Preferred Option

The existing Local Development Plan includes a specific policy on landscape. It outlines a presumption against any development that does not conserve the landscape character and special qualities of the National Park. This has been used effectively to control and mitigate the impacts of new hill tracks in cases where they require planning permission. We think the existing policy will continue to provide an appropriate means for controlling these forms of development in the future. However, we also think that we could give more clarity on the issue of hill tracks by amending the policy to reflect the National Park Partnership Plan’s specific presumption against new tracks in areas of open moorland.


“Do you agree that the new Local Development Plan should include an amended policy to reflect the National Park Partnership Plan’s presumption against new hill tracks in open moorland areas?”


It is somewhat ironic that just the day before (see here), on 5th October, CNPA staff had emailed Highland Council that despite the potentially significant landscape impact, they were content for the proposed tracks to be dealt with by Highland Council under the Prior Notification System.

The track proposals, the green area on the right marks the National Scenic Area while the tracks in the bottom half of the map are in the Cairngorms Wild Land area. Some of the proposed tracks including U-V, A-B and B to the green which marks the edge of the forestry plantation, run across open moorland. W-X is an upgraded ATV track which runs along the ridge of the Corbett Carn Dearg Mor.

What is even more extraordinary about the CNPA decision is that back in the Spring, in their response to the Government planning consultation on People, Places and Planning they had argued (rightly in my opinion) that the whole Prior Notification system for hill tracks was flawed and that tracks should require full planning permission:


We also consider that the review should consider whether some development that can
be undertaken through prior notification or approval as agricultural and private roads
and ways should simply require planning permission. Many tracks on open moorland
and hills have some link to an agricultural purpose, even where the primary use is for
sporting activities. These tracks can be contentious, but the public may never know of
their approval nor have an opportunity to make representation on them. We suggest
that new tracks on open ground that are not in enclosed farmland should simply require
planning permission, irrespective of the purpose of the track.


The Feshie track proposal was, one might have thought, an ideal opportunity for the CNPA to consider properly the implications of a large development of hill tracks under the planning system and allow the public to comment.  Instead, the CNPA have totally contravened their own policy position.

The brown shading marks the Cairngorms Wild Land areas where there is supposed to be a presumption against new developments. Most of the proposed tracks in the application which fall into this area are in what is currently open moorland.

The situation is much worse than that however.   By allowing the proposal to be decided under the Prior Notification system – which was introduced for agricultural and forestry tracks which are treated as permitted developments under our planning system – even if significant parts of the development were justifiable, the CNPA has lost any ability to control what happens under what the planning development and left the entire development to trust.


Where a track is agreed through the planning system, a planning authority will always attach conditions, for example about how it should be constructed.   Wildland Ltd has produced far more documentation than would normally be submitted for Prior Notifications, for which it is to be commended, and many of these look good.  However, not only is the public being given no chance to comment – representations from the North East Mountain Trust who were consulted privately that the visual impact of the tracks would be reduced by a vegetated central strip have been ignored –  the CNPA and Highland Council now have no means of ensuring what has been proposed happens in practice.  Without planning conditions, there can be no enforcement.  This development is being left to trust.


What is going on?

I do not think responsibility for this mess lies with the Feshie Estate/WildLand Ltd but with our public authorities.  These include Forestry Commission Scotland, SNH, Highland Council as well as the Cairngorms National Park Authority.  Its clear from references in the planning documentation that Wildland Ltd consulted with our public authorities as early as last December.  Its also appears that initially the CNPA did the right thing and asked for a full landscape assessment, as is evidenced by his extract from a communication quoted in the landscape assessment produced by Wildland Ltd:

What then happened is also revealed by the WildLand Ltd documentation:

So, just as the CNPA were telling the Scottish Government that the Prior Notification system was not fit for the purpose and before they had received any detailed information about whether the tracks could be said to be forestry or not, they had agreed that the proposals should be dealt with under the Prior Notification system.    This effectively pre-judged the decision and ruled out any public engagement and consultation.  I had been feeling a bit guilty that it has taken me three weeks, since I first heard about the proposals, to consider them on parkswatch but its clear the decision was effectively made well before then.


There is nothing to indicate that WildLand Ltd would have objected if they had been asked to submit a full planning application which could have been considered by the public.  While there are legal complexities about when a forestry track is a forestry track, the Wildland Ltd documentation makes it clear that these tracks are also to assist with deer management and have been designed to improve recreational access by walkers and cyclists.   In other words they are not pretending, as many estates do, that these tracks are solely for forestry purposes and therefore don’t require planning permission.   And while there might have been complexities in considering in one application tracks that did not require planning permission with those that should have required it, it is clear from the fact that WildLand Ltd submitted this as one proposal – rather than the normal track creep which is so evident in places like Drumochter – that they are trying to be open and transparent.  Its our public authorities which are the issue.


I can think of several possible explanations for the CNPA’s stance, none of which in my view are appropriate for a National Park:

  • A full planning application – which would have required Board visits etc – was too much work.
  • The CNPA trust WildLand Ltd, in a way that they don’t trust other estates – hence they don’t see the need for planning conditions.
  • That because Glen Feshie has been successfully reducing deer numbers and enabling native woodland to regenerate, its crucial to the National Park achieving its landscape scale restoration targets, and the CNPA therefore did not want to risk this being disrupted in any way through a planning application.

To me though none of these quite ring true.   I had started out by thinking perhaps the CNPA was under huge pressure from Glen Feshie estate but looking at the planning I don’t think that is the case.  Feshie appear to have been co-operative.  I am left with the suspicion that there is some hidden factor behind this terrible decision.   Perhaps the CNPA will disprove this and publicly explain their position and why they appear to have ignored their own and national policy?


Its time the CNPA started to put its money where its mouth is, trust public consultation processes and use them properly.   Had they done so, I am sure the end result could have been a new track network which achieved conservation purposes but with less impact on the landscape and wild land then the current proposals.  Examples of this will be considered in a future post.

October 18, 2016 Nick Kempe 2 comments




I am up in the north-west Highlands for a week, staying near Gairloch, and yesterday walked into Beinn an Eoin from Loch Bad Scalaig.   The first part of the track is through a native woodland scheme planted in 1998 and then leads on to the former bothy, Poca Buidhe, almost 12k in all.   Its  used by vehicles for stalking.  What struck me is how narrow it is, like a footpath, about 1.5m wide and as a consequence enjoyable to walk.  In many places the Poca Buidhe track just disappears from view although there are still places where there is a signficant impact on the landscape, as is in the photo above where the track runs above the Abhainn a Garbh Coire.


On my reading the Loch Lomond and Trossachs National Park Authority set out similar aspirations for hill tracks in the National Park in its Guidance on Renewables:


“It is expected that where possible, the type of vehicles that will require access after restoration of the tracks  will be light, low-pressure vehicles, such as quad bike or equivalent.

If access tracks are to be retained for light low-pressure vehicles, the visual impact of these tracks should be minimised by downsizing the width, green re-instatement track methods and local mitigation measures such as planting and rock/boulder placement”.

ALL of the hydro tracks in Glen Falloch, approved by LLTNPA officers are far wider than would be needed for a quad bike or similar, leaving aside there is no evidence that there was any “overwhelming need” for these tracks to be retained (see here).

Looking across Glen Falloch from the Eas Eonan track

The narrowest tracks are about 2m wide.   Gordon Watson, the Chief Executive of the LLTNPA, has subsequently stated in writing that planning conditions require construction tracks to be reduced to 2m (2.5m at bends).    While I believe this is simply his latest re-interpretation of the LLTNPA’s policy and, as the Torridon photo shows, is needlessly broad, in practice the LLTNPA was approving tracks in Glen Falloch while he was Director of Planning that are wider than his quoted maximum:


  • The Glen Falloch extension track is 2.5m wide (see here)
  • The Eas  Eonan and Allt a Chuillinn schemes 2.5m (see here)
  • Allt Fionn width not specified but the “minimum” necessary for use by a landrover (see here)


Only the Ben Glas track, approved at end of 2015, states the track should be reduced to 2m (and 2.5m at bends).


This shows that once again LLTNPA officers are ignoring their own policy, both the written policy which was good in intention if too vague, and Gordon Watson’s re-interpretation of this to mean tracks should be 2m wide.    I don’t believe there was an “overwhelming reason” to allow these hydro construction tracks to be retained but even if there was, if the Gairloch Estate can manage on 1.5m tracks so should estates within our National Parks.

Part of the West Highland Way in Glen Falloch which is also used by estate vehicles. Its closer to 1.5m in width than 2m.

Reducing the width of these hydro tracks would help them merge with the landscape over time (which is what the LLTNPA claims it wants).  The LLTNPA should be setting an example of best practice and I regret that so far it has conspicuously failed to do this.  It is not too late.  The Glen Falloch Estates will make a fortune from these hydro schemes over the next 10 years paid for by the public and the least they can do in return is reduce the impact of the destruction they have caused.

Hill track Dinnet


At least the LLTNPA appears to have a policy position on the width of tracks.  The Cairngorms National Park Authority produced an 18 page report on the Dinnet Hill Tracks without mentioning the width of tracks once item8aadinnettracks20160004det.   More on that in a future post.


September 24, 2016 Nick Kempe 1 comment

raptorsRaptor Persecution Scotland picked up  (see here) on a Cairngorms blog piece and article in the Strathspey and Badenoch Herald by Peter Argyle, Convener of the the Cairngorms National Park Authority.


I believe Peter’s contribution is very welcome and its very refreshing that as Convener of the National Park he seems prepared to engage in public debate, unlike his counterpart, Linda McKay, at the Loch Lomond and Trossachs Park Authority where everything is sorted out with preferred partners in secrecy and behind closed doors.


I thought it interesting that Peter has not referenced any of the powers the CNPA has to address the widespread raptor persecution that takes place in the National Park.   I have argued how these could be used before (see here) but there is now a very interesting precedent just to the North in Moray where the creation of bye-laws and permits for shooting geese at Findhorn has been supported by none less than the British Association for Shooting and Conservation and Richard Lochhead, the Scottish Government Cabinet Secretary who was responsible for National Parks until earlier this year:


“Following his meeting with Basc, Mr Lochhead argued it was “absolutely clear” the existing regulations weren’t working properly.

And he has now encouraged councillors to impose a permit system with certain by-laws to satisfy parties on either side of the debate.

Mr Lochhead said: “There’s been a backlash in the local community due to some visitors not respecting the local environment, and it’s absolutely clear the status quo is not an option.

“My meeting with Basc was positive and they made it clear they support a permit system with by-laws.

“We need the council to adopt a can-do attitude and calculate the costs of a permit system to inform the debate.

“The shooting season is under way and I don’t think anyone wants to see another season go by without a solution being put in place.”

Basc Scotland’s Donald Muir added: “We explained that a permit system should be put in place at Findhorn Bay, which should eliminate any bad practice taking place.”

(from Press and Journal ((see here))


So why doesn’t the CNPA adopt a similar type of can-do attitude as Richard Lochhead is calling on Moray to adopt?



I also think Peter and the CNPA have got the economic contribution that moorland management makes to the National Park wrong.   It is now very profitable, in part because the financiers are enamoured with grouse shooting (Fred Goodwin when running the Royal Bank of Scotland as his personal fiefdom loved to put on his plus fours and go shooting as told by Ian Fraser in “Shredded: Inside RBS the bank that broke Britain)  and have both invested in estates and pay large amounts for a day’s shooting (£9,943 per day compared to £729 per day of stag shooting according to the Cairngorms Estates survey in £2014).   This has resulted in a shift from deer management to grouse shooting as shown by Andy Wightman and Ruth Tangay in “Research into the Intensification of Grouse Moor Management”.   Unfortunately the CNPA have completely failed to provide a similar overall analysis for the Partnership Plan and I think if they did, it would show that most of the alleged benefits grouse moor management brings to the National Park are myths.


Peter Argyle acknowledges that driven grouse shooting has been banned in much of the rest of Europe but does not say why its a problem.  Driven grouse shooting is just like a glorified clay pigeon shoot the difference being the supply of targets is limited.   This might not matter to most people but grouse shooting is about conspicuous consumption and among the shooters part of the “fun” is downing more grouse than the person next door.  The numbers of grouse are extremely important and this is what has driven the intensification of grouse moor management including raptor persecution.  While the CNPA has been trying to talk to estates, the ground rules have been changing beneath their feet and as a result they are always on the back foot.     If the CNPA introduced a permit system and limited the numbers of grouse that could be shot in a day they could stop this completely and “de-intensify” grouse moor management.


Peter seems to fear that if grouse shooting was tackled there would be a loss of jobs.   The evidence suggests that while grouse shooting is now extremely profitable, most of the profit is not invested in the National Park but elsewhere.  There is a complete myth that grouse shooting is essential to maintain jobs in remote areas.  The pay of estate staff, often working in very difficult conditions, is lamentable (Andy Wightman found the average salary was £11401 and this would seem to accord with the CNPA’s own findings that wages in the National Park are 26% lower than elsewhere in Scotland).   The obvious question, which is not being asked by the CNPA, is whether alternative land-uses which depended on the natural rather than the highly managed qualities of the National Park could provide more and better paid jobs which kept money in the local area?     Surely this is the sort of question the CNPA should be considering under its mandate to promote sustainable economic development?


The CNPA has produced lots of information on economic development but what is conspicuous by its absence in the Partnership Plan is the absence of any analysis of the role of sporting estates.  Part of the reason for this that while previous economic surveys have identified “game management” as one of the most distinctive economic activities in the National Park, it has not been analysed as such but included partly under the tourism sector and partly under food and drink.  So, the dominant land-uses in the National Park simply disappear from the economic analysis as this graphic from the draft plan and the quote below illustrates:



Land Management related industry is of vital importance to the economy of the Cairngorms
National Park and activities to support this sector are a key priority. Land Management in itself,
however, has not been identified as a Priority Sector. This is because it is such a diverse
industry which cross-cuts wider sectors including tourism, forestry, agriculture, renewables etc.  (Cairngorms Economic Strategy 2015)


The result is the draft Plan, instead of looking at the economics of sporting estates and how this impacts on it priority issues of landscape scale conservation and deer and moorland management, comes up with this non-plan:


Deer and moorland management is a significant aspect of the local economy and culture for many people living in the National Park. The fact that estates invest heavily in deer and moorland management is clearly demonstrated in the landowners’ survey carried out in 2013. This currently supports jobs in sometimes remote locations. Investment in moorland management is a personal choice often driven by a range of external social and economic motivations. Changes to any model of land use carries risks and uncertainties about how alternatives are funded, particularly for individual businesses. Therefore the long term viability and continued employment opportunities must be integral to addressing any changes, to maintain viable land management with investment in public interest outcomes. There is a good opportunity in the National Park to explore new approaches to combining the value of sport with a high quality environment, maintaining employment and investment.


I welcome Peter Argyle’s call for a frank dialogue but I think that to take that forward requires a much more rigorous analysis to that presented in the draft Partnership Plan.  Peter says in his blog “There is much good work being done on heather moorlands within the Park, be it on peatland restoration, the spread of upland scrub species and more effective control of deer numbers.”   I would agree there is good work and also that some people are trying very very hard – I don’t want to belittle the efforts of those who are trying – but unfortunately the Park Plan does not explicitly put these efforts in context:


  • 350ha of peatland restoration underway in the National Park, with a target of 2,000 ha by 2018.   This is tiny in the context of the National Park and the 2m hectares of peatland in Scotland that is in poor condition.
  • 890 hectares of new woodland is tiny within the context that the National Park covers 4528 km2 or 452800 hectares


Is this really good enough for a National Park which should be setting an example to the rest of Scotland?


What the Partnership Plan needs is some much more ambitious targets if the CNPA is to deliver its statutory aims.   I hope Peter Argyle will take part in further public dialogue and debate about this.




July 24, 2016 Nick Kempe No comments exist

A week ago the National Trust for Scotland announced that four hen harrier chicks had fledged on their Mar Lodge estate, in the central Cairngorms.  Raptor Persecution Scotland commented in their blog last week time that the chances of the young harriers surviving were extremely low given the history of raptor persecution in the Cairngorms National Park.    Just a week later the truth of this comment was demonstrated by the announcement that an illegal trap had been discovered on the neighbouring Invercauld Estate along with evidence that a further 8 illegal traps that had been removed before the police were able to start their investigation.    While the trap that was found contained a common gull, it could just as well have caught a hen harrier – proof of Raptor Persecution Scotland’s comment that if the young harriers moved east they were likely done for.


It was good to see another quick response from the Cairngorms National Park Authority Chief Executive, Grant Moir, http://cairngorms.co.uk/illegal-trap-use-statement-from-ceo/  unequivocally condemning the use of the trap.   His request for a meeting with the Head Trustee and Sporting Partner at Invercauld however, though I am sure well intentioned,  simply illustrates the weakness of National Parks.   A strong National Park would have summoned the estate and all the trustees to explain themselves or risk losing their right to hunt (which as the blog has pointed out they could control through byelaws).  Instead, the CNPA has not even named the Head Trustee and Sporting Partner.   Do the CNPA  not know who the people are?   Or are they allowing the people ultimately responsible for management of the estate to hide their identity?   The Farquharson family, who control the Invercauld Estate, hide behind a trust structure that protects their assets but why should the National Park perpetuate this?  What about some openness?


Moreover, instead of calling on other public authorities to contribute resources for enforcement (resources that are unlikely to materialise under austerity), why does not the CNPA  simply use the powers it already has to license all hunting in the National Park and suspend or remove that license whenever evidence of wildlife crime such as this occurs as  previously suggested on this blog http://parkswatchscotland.co.uk/2016/03/25/stop-raptor-persecution-cairngorms-national-park/?   The deterrent effect of this would I believe be sufficient to solve the problem of wildlife persecution overnight and would NOT require other public authorities to contribute further resources.


Unfortunately, the CNPA in trying to work in partnership with landowners appears to have  got far too close to them.   The problem is illustrated by the CNPA’s new Partnership Plan, which is currently out for consultation, and which set the future direction of the National Park over the next five years.  It includes nine issues reports, the second of which is on Deer and Moorland Management 160621DeerMoorlandManagementFINAL1-1 (there is no conservation issues report as such despite the Park’s primary objective being conservation).


On page 5 of this report CNPA quotes from the Game and Wildlife Conservation Trust, treating them apparently as an authoritative source:



No mention here of the impact of raptor persecution on grouse numbers.   It was the very same GWCT which on Friday issued a press release on behalf of the Invercauld estate (see here) first denying the crime and then alleging that if the illegal traps had been set this must have been done by people trying to discredit the grouse shooting industry.  Why is the CNPA giving the GWCT credence by quoting them uncritically?


While later in the Deer and Moorland Management Issues Report the CNPA does question some of the statements of the grouse lobby, the report contains is no fundamental questioning of the impact of current grouse moor management on wildlife or whether this is compatible with the conservation objective of the National Park.   It is worth stating loudly and clearly that in the case of conflict – and the CNPA does acknowledge some of the conflict  – the Scottish Parliament intended the conservation objective to override all the other objectives and this is enshrined in law in the National Parks Act.    This should be the basis of the Partnership Plan.


Instead of giving a firm lead based on its legal obligations, however, at the end of the Issues Report 2 on Deer and Moorland Management the CNPA asks two 2 questions, the first on deer numbers (which I will cover in another post) and the second on grouse moor management:




I believe this is the wrong question.   The right question, based on the CNPA’s founding legislation, would be to ask HOW can grouse moor management be made compatible with the National Park’s conservation objectives?  The answer to both that and the Park’s own question is “not by voluntary means”.  The CNPA has been trying to prevent raptor persecution by persuasion for over ten years without any significant success.   It is time to admit defeat and the interests of grouse moor managers are such that the system will never change voluntarily.


It is the CNPA’s reliance on voluntary means, which its staff must know by now will not work, which I believe accounts for the Issues Report proposing the following targets/direction of travel for the new Partnership Plan:





The first is totally wrong as well as being so vague as to be meaningless.  What the National Park’s overriding conservation objective should mean is that the economic and cultural interests of shooting estates should not be at the expense of wildlife or habitats.   I would suggest the following should flow from this as a start:

  • All hunting in the CNPA should be licensed.  I appreciate there is now a campaign to license all gamebird hunting nationally but there is nothing to stop the CNPA starting a consultation on new hunting bye-laws now which should be broader than just gamebirds and include hunting of mammals from deer to mountain hares.
  • The use of ALL traps should be banned within the National Park except in limited cases under license. The CNPA should not be prioritising one species over another in terms of conservation objectives (in contrast to grouse moor management priorities grouse over everything from mountain hares to stoats to golden eagles) and there is no general justification for trapping in our National Parks.   I would suggest the only trapping that could be justified in the National Park would be for introduced species such as mink.


The second “target”, to “improve raptor population conservation” as phrased does not even mean the CNPA is committed to increase numbers of raptors in the National Park.   To give this bite the CNPA should:

  • Consult with RSPB and the raptor study groups and come up with a (conservative estimate) for the minimum number of nesting pairs of each species of raptor the National Park could be expected to support at present (given current state of habitats without any wildlife persecution). For example, 30 pairs of hen harrier, 20 pairs of golden eagle etc.   The target should then be to reach this number before the end of the Partnership Plan.   This should not be difficult to achieve.  Raptor populations would expand quickly if they were not illegally killed and their primary food sources apart from red grouse, such as mountain hare, ceased to be systematically cleared from the moors.
  • Make a commitment to satellite tag all species of raptors where persecution has had a serious impact on populations.  The National Park used to be involved in a satellite tagging project and its very sad that this now depends on the efforts of others.  According to the reports on the young NTS hen harriers only one of the four is to be tagged.  Tagging appears the best deterrent against persecution because it provides evidence of where birds were last seen alive (and this evidence could play an important role in the CNPA being able to revoke  hunting licenses because of illegal persecution).  Every reason then for our National Parks to fund satellite tagging.
June 7, 2016 Nick Kempe No comments exist

Raptor Persecution Scotland published a piece today  about the BBC Countryfile programme at the weekend on the Invermark Estate and the recent history of persecution in the Angus glens.  The list of crimes, most never “solved” or brought to justice is horrific.   In the interests of accuracy though its worth stating the vast majority of incidents that have been recorded took place on other estates and outwith the National Park boundary.    The BBC presenter however did not even ask Invermark how raptor persecution by these other estates affected the wildlife part of its business.


By chance earlier this week I came across these photos of estate signs from Invermark taken in 2005.

Invermark Estate sign 2005.  Two years after the Land Reform Act granted us access rights the estate still had signs up stating “Estate Path.  Access at discretion of estate”.
Invermark Estate sign 2005. There has never been any significant evidence that walkers or other visitors disturb raptors

In support of Raptor Persecution Scotland’s case, I would suggest the only reason for such signs is that greater visitor numbers increases the likelihood that the public will come across evidence of illegal activities.   Evidence from the past that the Invermark Estate is perhaps not as pro-wildlife as portrayed by the BBC and a very strong reason to preserve access rights.  Note how the estate was anti-camping  (just like the Loch Lomond and Trossachs National Park Authority, which is strongly supported by Scottish Land and Estates).  I suggest a major reason for this is that  campers are out in the field for far longer than walkers and therefore far more likely to come across evidence of raptor persecution.


The BBC missed another angle on Invermark.   All the estates within the Cairngorms National Park have been asked to produce estate management statements and Invermark was one of the estates that did so (many did not).   The Invermark Estate Management Statement  makes interesting reading, not for what it says, but what is left out:

  • There is no mention that much of the Invermark Estate is part of the Cairngorms Special Protection Area designated for its golden eagles (the BBC should have asked, if hare numbers had increased on the estate as claimed in Countryfile, whether eagle numbers had too and if not why not)
  • There is no mention of predator or vermin control.  So, which species do the estate regard as vermin and control as such?
  • There is no mention of red deer numbers, what the estate believes as a sustainable number and how these will be controlled (not surprising perhaps because the estate factor, Richard Cooke was long the secretary of the Association of Deer Management Groups which has done such an effective job lobbying politicians in Scotland to prevent any effective controls on deer numbers).
  • There is no mention of how the grouse moors will be managed, such as the extent of burning and medication of grouse
  • Or, one might add, from the two events that Raptor Persecution Scotland’s have listed as taking place on the estate, what it might do to prevent destruction of peregrine’s nests (as happened in 2004) and to protect trees where raptor are or have nested (January 2013 White Tailed Eagle nest tree felled).    Evidence of estate determination to stamp out such practice could include contracts of employment that clearly describe such actions as gross misconduct which would lead to instant dismissal.


While the Cairngorms National Park Authority was no doubt well intentioned when it asked the estates within the National Park to produce management statements, by publishing statements such as that from Invermark,  it has in effect endorsed them.   This, I suggest,  undermines the statutory conservation purpose of the National Park because there is complete avoidance of almost all the things that matter from a conservation perspective – and the Invermark Estate Statement is typical in this respect.


The solution is for the CNPA  to lead by example and require  management statements from ALL estates within the National Park setting out how they will meet the Park’s conservation objectives and putting in place sanctions for those that fail to do so.  Part of every statement should include what the estate will do to prevent raptor persecution.   Such statements should form part of a much wider plan of action to address raptor persecution and other conservation failures which I have outlined in previous posts http://parkswatchscotland.co.uk/2016/03/25/stop-raptor-persecution-cairngorms-national-park/























May 29, 2016 Nick Kempe 16 comments

The Cairngorms National Park Authority has, with Scottish Natural Heritage,  issued a short educational video on dog walking in the National Park https://t.co/ZsYpjNosWL   This is to be welcomed.  The Land Reform Review Group, which reported to the last Scottish Parliament, concluded that access rights were working well but there were a number of areas where further education was needed.   Dog walking was the priority area for further work (camping was not seen as a major issue at all and the Review Group rejected representations from the Loch Lomond and Trossachs National Park Authority that the legislation needed to be amended to remove the right to camp by roads).   The CNPA video should be seen as a positive initiative by a public authority to implement the recommendations of the Land Reform Review Group.


SNH also, to its credit, engaged with commercial dog walkers to draw up a new code of practice.  An exemplary way to do things in contrast to the LLTNPA who failed to engage seriously with recreational organisations about how to educate people about reducing the impacts of wild camping.


The dog video, which is aimed at visitors, includes information on the impacts of dogs on wildlife.   Good stuff and something that I think Dick Balharry, the great Scottish ecologist who died last year, would have approved of – I remember him saying to me how he thought there should be NO dogs in National Nature Reserves.    This, however,  begs the question about landowners dogs.   Anyone who has walked by estate buildings in the National Park will have experienced the howling of dogs in kennels and earlier this year I came across a very nice keeper (he kept his most dangerous looking dog by his side as we passed!)  running six or seven dogs at Dalnaspidal.    The purpose of these dogs of course is to assist with hunting and what is not said publicly at present is that this includes anything that the estates perceive as vermin or might prey on red grouse.  For estate dogs helps keepers track down ground nesting raptors, mountain hares and stoats all of which are persecuted in the National Park.    I suspect estate dogs are responsible for far more damage to wildlife on grouse moors than visitors dogs but let’s not wait for a three year scientific study before anyone acts on this.


So, my question is when will the National Park and SNH be producing a video on good practice for local estates?    Indeed, should they not go further and introduce licensing of dogs on estates and set conditions about what they can be used for?   Or follow Dick Balharry and ban dogs completely from National Nature Reserves or indeed the National Park and make legitimate hunting a bit more challenging?.    I suspect if any of this were to happen the number of dogs in estate kennels would drop dramatically.

April 2, 2016 Nick Kempe No comments exist

There is an interesting thread on mountain hare persecution and National Parks on Raptor Persecution Scotland https://raptorpersecutionscotland.wordpress.com/2016/03/30/sustainable-mountain-hare-culls-wheres-the-evidence/    Its very good that people are beginning to question not just why mountain hare persecution is  happening but also why, of all places, its being allowed in our National Parks.


Mike, my climbing partner on Thursday, contributed this comment about why mountain hares are being massacred:

“Interesting to read that Invermark (which is in the CNPA at the head of Glen Esk) no longer culls hares – or does Adam Watson think it never did? I remember massive culls there during my time working as a ghillie in the mid 80’s. There would be a “keepers’ day” when men from local estates would arrive early in the morning, form a line across the hill (the beat to the south of Loch Lee was a favourite starting point) and the day would be spent walking in a line and shooting hundreds of hares. Done in spring, the still white hares stood out against the heather and had little chance. The reason given was that the hares eat the tender heather shoots that the grouse need. Contrast that memory with another of standing with the pony by the Unich burn and watching an eagle take a hare on the slopes east of Muckle Cairn – the eagle landing on the hare in a tumble to wings as it struggled to avoid rolling down the hill.”

Mike put me right on Thursday about my speculative questions about whether hunting culture had changed  http://parkswatchscotland.co.uk/2016/03/27/landowners-defence-massacre-hares/    Mountain Hare massacres have been going on for a long time, even if this has now stopped at Invermark.


What the long history suggests is:


  • the current claims by landowners that hare “culls” are needed to stop Louping Ill virus spreading from hares to grouse should be taken with a large pinch of salt.  Its not so long ago that the culls used to be justified on the grounds that mountain hares deprived grouse of young heather shoots to eat.
  •  the massacres are mainly being conducted by estate staff, gamekeepers.    Their job, particularly in the Cairngorms where grouse moors are the dominant land-use,  is about and dependent on maximising grouse  numbers for others to shoot.   Hare shoots are a chance for keepers, who often work alone in tough conditions, to have a sociable day out with their peers from neighbouring estates.   Whatever the overt justification, it could be seen in part as a reward for a job well done, the extermination of predators.   Mike incidentally told me on Thursday about the numbers of foxes shot each year on the Dalhousie estates – 100s.    All that has changed is that instead of shooting hares by walking across the moors – which gave the hares some the chance to get away – estates are are now using All Terrain Vehicles to round them up.
March 27, 2016 Nick Kempe No comments exist

Douglas McAdam, Chief Executive of Scottish Land and Estates had an article in the Sunday Herald today http://www.heraldscotland.com/opinion/14386203.A_landowner_s_defence_of_culling_mountain_hares/ defending the killing of hares in which he referred to the Cairngorms at the end.  He was obviously trying to persuade our politicians, who I have heard read the Sunday Herald, and the CNPA that everything is just fine.


McAdam’s argument is basically that landowners need to cull hares for the same reasons that red deer need to be culled, to prevent grazing pressure.    Ignoring the obvious provocation,  that landowners aren’t culling red deer nearly enough and haven’t been for as long as I can remember, the argument is completely untenable:

  • It implies mountain hare are doing similar damage to vegetation as red deer.  They don’t.  I have checked  three of the management statements for large Sites of Special Scientific Interest in the Cairngorms (the eastern Cairngorms, Beinn a Ghlo and Caenlochan)  – you can see them for yourself at http://gateway.snh.gov.uk/sitelink/searchmap.jsp    They all mention grazing pressure from deer, not one even refers to grazing by mountain hare
  • More importantly, the mountain hare has a number of natural predators in Scotland, ranging from the fox to the eagle, unlike adult red deer.  So, whatever arguments there are for humans to cull red deer simply don’t apply to hares because there are other creatures which could control their numbers or would if estates hadn’t persecuted predators to extinction on grouse moors.   Agreeing with the landowner’s rationale for culling hares is simply to condone this persecution, which is unacceptable anywhere but should be off the radar in our National Parks.

What some of the debate on persecution of mountain hares is perhaps missing is that estates have hunted the creatures of the high tops, mountain hare and ptarmigan, for many years.   McAdam’s article was silent about this and has tried to turn the debate onto a supposed need for culls.   What this hides perhaps is a shift in the way hares are being killed, from hunting for pleasure (where landowners and their guests might have shot a few hares in a day) to mass extermination by estate staff using machines on the utilitarian grounds that this increases grouse numbers .  What this suggests  is that  hunting of hares as such has become less socially acceptable – maybe its difficult now for estates to attract paying guests – whereas there is still high demand for grouse shooting.


It will be interesting to see how the Cairngorms National Park answers the argument of the landowners.

March 25, 2016 Nick Kempe 1 comment

On Tuesday the RSPB reported the death of a Hen Harrier on a moor near Newtonmore last September  http://www.rspb.org.uk/community/ourwork/skydancer/b/skydancer/archive/2016/03/22/hen-harrier-lad-found-dead-on-speyside.aspxhe  It was good to hear Grant Moir, the Chief Executive of the Cairngorms National Park, condemn the probable killing outright – a more upfront response than the Park’s reaction to the Mountain Hare massacres last week.  The commitment he made though was rather vague and  I doubt will have anyone who persecutes raptors trembling in their boots  “The National Park Authority will work with all our partners to try and ensure that raptor crime is a thing of the past and that populations and ranges recover in the Park.


How hunting byelaws could stop raptor persecution


The CNPA needs to start thinking about how it can use its powers to make persecution of wildlife by estates much harder if not impossible.  As I pointed out last week, http://parkswatchscotland.co.uk/2016/03/20/mountain-hare-massacres-balmoral-cairngorms-national-park/ the Park could use its powers to create byelaws to to protect species like the mountain hare and to control hunting in the National Park.    It is interesting that while the Loch Lomond and Trossachs National Park has been so keen, encouraged by the Minister, to try and ban camping for spurious conservation purposes, when it comes to the deliberate destruction of wildlife, the Cairngorms National Park  and the Minister have so far been silent about the need for more controls.


Here are some ways in which the CNPA could use hunting permits  to protect wildlife::

    • permits could be removed if  an estate or anyone connected to it committed a wildlife crime  (this would be a huge deterrent for estates whose main purpose is hunting)
    • permits could be issued on condition the landowner waived any right they might have to require RSPB and other wildlife organisations to seek permission before ringing or tagging wildlife on their land (or indeed set up monitoring cameras).   The RSPB had had to ask permission to tag the Hen Harrier which was found dead – it was given which was great but how many other estates refuse or fail to cooperate?.
    • permits could put a limit on the size of grouse “bags” shot by any one person or on any one day.   One of the drivers behind grouse moor intensification is that the size of the bag is very important to the people who shoot grouse.  Put simply the more grouse  the better the day and the more the people shooting the grouse are willing to pay for it.  Putting a limit on bags would help challenge this mindset which results in pressure on estate staff to increase grouse numbers in whatever way they can.
    • permits could be required for any wildlife trapping in the Park which would stop the proliferation of traps on grouse moors which has been directed at eradicating stoats

      Stoat trap, Dalnaspidal (close to the National Park Boundary)
      Stoat trap, Dalnaspidal (close to the National Park Boundary)









How development planning powers could help prevent raptor persecution


I visit Newtonmore regularly and the moors around it and along the A9 corridor all provide good habitats for Hen Harrier.   Over the last twenty years  there have been significant developments on most of the private  estates in the area which are linked to the intensification of grouse moor management:  new luxury estate housing for the shooters;  the creation and upgrade of hilltracks to make it easy for shooters to get up the hill and for gamekeepers to pursue their business;   the upgrading of bothies to provide places for the shooters luncheon.   As Planning Authority, the Park has had a role in facilitating these developments.  Its time that it had a re-think.  As a National Park it needs to set an example to other Planning Authorities about how to use existing and potential planning powers to prevent and influence developments that are associated with the intensification of grouse moor management and the destruction of wildlife.

Among the things the CNPA could do are:

  •  call on the Government to give National Parks full planning powers over the creation of hill tracks not just on landscape grounds but because of their role in wildlife persecution  (I now think of tracks as persecution corridors because they give easy access to gamekeepers to set traps or monitor anything they regard as vermin).  At present the CNPA can only control hill tracks in the National Scenic Areas which cover the central Cairngorms and Deeside.  Moreover because they are not a full planning authority they do not have to be notified of proposals under the Scottish Government’s new prior notification scheme where estate owners have to tell planning authorities what they are intending to do before doing it anyway.

    This hilltrack on Dalnaspidal estate just inside the CNPA boundary was created 2-3 years ago
    This hilltrack on Dalnaspidal estate just inside the CNPA boundary was created 2-3 years ago
  • the Park should make it clear it opposes the creation of all new hill tracks on moorland in the National Park (the main  purpose of which is the intensification of grouse management)
  • the Park should then start challenging estates about their claims that tracks on moorland have been constructed for agricultural or forestry purposes (which are permitted developments and are the loophole by which estates create tracks without planning permission).  It should consider taking legal action to require such tracks to be removed.  One case would be sufficient to get landowners to think twice………….
  • the Park should use its development planning powers creatively to influence the large-scale investments that are being made on some estate properties at present to ensure that the investment does not lead to even greater grouse moor management.  Investments such as those at Dalnaspidal,  http://www.lochericht.co.uk/dalnaspidal-lodge.html
     to which the Park granted planning permission a couple of years ago, are aimed at people with a lot of money who want to shoot a lot of grouse.   Once constructed the pressure is then on estate staff to ensure they attract enough paying guests to pay for the investment.  The main way they do this is by increasing grouse numbers and the temptation must be to do this by whatever means they can, particularly if their accommodation is owned by the estate.  I have walked over the Dalnaspidal estate several times in the last year  (both inside and outside the Park boundary) and there are grouse everywhere but not a lot else.   A pre-condition for planning permission on estates should be that they can show that a proposed development is  contributing to the conservation purpose of the National Park and that the investment will not lead to further destruction of wildlife.

It was not by chance that the dead Hen Harrier  had been born and ringed on land owned by Wildland Ltd, better known as the Glen Feshie Estate, and owned by Anders Holch Povlsen.   He has been committed to conservation and is doing the opposite to most other private landowners in the area, reducing red deer numbers and enabling other wildlife to increase.   He has also bought up and invested a lot of money in Killiehuntly farm, just like Dalnaspidal, but by all appearances the land round about is being managed in a very different way.



March 14, 2016 Nick Kempe No comments exist

The CNPA have responded to the media coverage of the mountain hare cull  http://cairngorms.co.uk/mountain-hare-cull-statement/    The response is quite predictable – as a member of staff the Director of Conservation was not in a position to launch the CNPA in new directions – but very sad.  It demonstrates some of what is wrong with so-called conservation in the National Park:

  • there can be no “balance of moorland species” when everything centres on grouse shooting; a balance of moorland species would see golden eagles everywhere in the Cairngorms.
  • there is no need for better data; what difference does knowing the numbers of hares make except when they are being exterminated from grouse moors?  Data in this case is a trap which has sent the conservation agencies off on years of research which feeds into the hunting narrative that large numbers of hares are a problem.   They are not, but the lack of eagles and other predators is.  Instead of requiring better data on hares before banning culls, we should be requiring numbers of eagles to rise to predicted levels before allowing any shooting.
  • and just what does a “management cull” have to do with nature conservation in this case?   The Park has allowed management speak from the red deer world to be used to justify killing other species which unlike deer have a number of natural predators.


March 13, 2016 Nick Kempe 1 comment

There has been some excellent coverage today of the mass killing of hares in the Cairngorms National Park by Rob Edwards http://www.heraldscotland.com/news/14340402.Outrage_of_landowners_mass_killing_of_mountain_hares/

Raptor Persecution Scotland https://raptorpersecutionscotland.wordpress.com/2016/03/13/more-mountain-hares-massacred-in-cairngorms-national-park/ and Mark Avery http://markavery.info/2016/03/13/mountain-mountain-hares/

I am delighted that some of the commentators are now asking why this practice is taking place in a National Park which was set up to protect the environment.


The landowners excuse for destroying the mountain hares, is that they carry a tick which can harm red grouse and sheep.  While of all the species our National Parks should protect, there is a strong case that sheep and red grouse should be at the bottom of the list, I think there is another reason for the persecution.  Mountain hare is a favourite food for eagles.     The persecution of golden eagles in the eastern Cairngorms is well documented but the risks to estates of doing so are increasing because most birds are now monitored through tracking devices and penalties for wildlife crimes have increased.   Allow the grouse moors to provide plentiful food for eagles and they will keep coming back and might take a few red grouse, too, so better just to exterminate their food source.


As Mark Avery, former Director of Conservation at RSPB, argued in his book Inglorious, as long as the production of grouse for shooting is the primary purpose of owning land, almost every other species will suffer.  He argues for an end to intensive grouse shooting – what better place to start than the Cairngorms National Park?


SNH meanwhile is still talking about what evidence might be required to impose a temporary ban.   I believe this is the wrong way of looking at things.   The more hares, the more food for golden eagles.  The way to get eagle numbers back to what they should be in the Cairngorms and further afield is to ban  ALL culling of hares and  other species persecuted by the estates.  Let the food for eagles flourish.


There are two ways that I can see to do this quickly.  One is simply for SNH to use its powers to issue a temporary ban on mountain hare shooting.  The second is for the National Park to introduce byelaws to ban mountain hare culling.   To ensure enforcement of this National Parks could require estates to apply for permits for all shooting under the byelaws.   (There is a precedent for this in the permits for hunting SNH issues under National Nature Reserve byelaws).    Both options could happen with a little encouragement from the Minister of the Environment, Aileen McLeod.


Having backed byelaws to ban camping in LLTNP, on the  grounds that these were needed to protect the environment, one might have thought Aileen McLeod  would be only too keen to support the introduction of byelaws to stop  landowners and managers destroying Scotland’s wildllife.   I personally believe the photos of rows of massacred hares are far more compelling evidence of the need for action than the photos of a few abandoned campsites.    Unfortunately, I suspect that evidence, let alone consistency  won’t come into it.


If Aileen McLeod doesn’t give a lead, I hope others will:

  • The Cairngorm National Park Authority should announce its intention to introduce byelaws to control hunting in the National Park, including a ban on hare culls, as soon as possible.
  • Our MSPs should press Aileen McLeod to add Mountain Hares to our list of protected mammals – there is no need ever for human to control mountain hare numbers, our predators can do this job quite effectively – and by supporting the introduction of hunting licenses to ensure this is observed.  Any estate found breaking the law, whether killing hares or raptors, should lose their right to hunt.
  • SNH should stop trying to evaluate whether the population of the mountain hare is in danger or not and instead focus on the impact that the persecution of these and other animals has on the population of other species



March 8, 2016 Dave Morris No comments exist

I welcome the creation of parkswatchscotland because our National Parks are so important for outdoor recreation and they are not always getting matters right.  Every item in this briefing  on outdoor recreation issues for the Scottish Parliament elections is relevant to National Parks and some concern them directly.


Briefing by Dave Morris


This is a contribution to the forthcoming elections to the Scottish Parliament on 5 May. It provides a briefing on key issues which are of concern to participants in outdoor recreation. It may help in challenging those who seek election on 5 May to explain what they will do for outdoor recreation if elected. It also provides an indication to the next Scottish Government of ways in which they can enhance the Scottish outdoor recreation experience.


Camping byelaws.
The present Scottish Government made a serious mistake in early 2016 by approving the expansion of camping byelaws to curtail informal camping in areas close to loch shores in the Loch Lomond and Trossachs National Park. This will seriously undermine the principles embedded within the rights of public access to our land and water that were secured by the Land Reform (Scotland) Act 2003. It opens the door to landowners everywhere to press for the removal of any of our access rights through byelaw establishment and replacing those rights by regulation through permit systems. These camping byelaws, which are due to become operational in 2017, need to be abandoned. Instead a ten year programme of education, improved law enforcement and new camp site provision, both formal and informal, needs to be established, linked to an expanded path network. In support of this a change in forestry budget priorities is needed. It is difficult to understand how in 2015 Forestry Commission Scotland, the largest landowner in the Park through its agency, Forest Enterprise, claimed to have no funds available for camp site development in this national park. Nevertheless, in the Cairngorms National Park in 2014, this same organisation had £7.4 million available to purchase a large area of Old Caledonian Pinewood from a private landowner, in a secret deal, when there was no obvious threat to the woodland. In addition to FCS budget alterations in the national parks there is a need for entirely new funding arrangements to support developments such as new paths and camping areas. Such funding could come from infrastructure levies applied to new housing developments or through tourist taxes applied to all accommodation providers in the parks, as found in other European countries. Furthermore, most of the existing litter problems in our parks and elsewhere would disappear if the Scottish Government introduced a nationwide deposit and return system for bottles and other food and drink containers.


Old Caledonian Pinewood.
Our native pinewood remnants, descended by natural regeneration from the native forests established as the last glaciers retreated nearly 10,000 years ago, are under threat. Excessive grazing by red deer or sheep continues to prevent regeneration in many OCP areas. Elsewhere too many landowners are planting too close to the old remnants, creating an artificial character, eroding the natural qualities of the native woodland. In some native pinewoods inappropriate use of large timber harvesting machines is damaging soil and vegetation profiles and causing excessive damage to old trees. These are some of the finest old growth forests left in Europe – elsewhere such mistreatment would not be permitted. Complaints to the European Commission are likely to lead to pressure on the Scottish Government to alter regulatory regimes and financial incentives in Scotland to ensure better compliance with the Habitats and Water Framework Directives and EC guidance on wild land protection.


Management of hunting
Successive governments, both in Holyrood and Westminster, have failed to provide a proper regulatory framework for hunting. This has led to excessive populations of red deer in many areas and the intensification of grouse moor management. Too much control remains in the hands of private landowners – no other country in Europe or North America has such a system where private interests prevail over the wider public interest in the management of our woodlands, moorlands and mountains. The direct result is massive overgrazing and excessive muirburn in too much of our uplands, with consequent soil erosion and vegetation damage, all leading to the possibilities of increased run off and downstream flooding. The indirect consequences include wildlife persecution on grouse moors and the loss of the economic opportunities that are associated with native woodland development. The next Scottish Government needs to legislate to establish a licensing system for all red deer and grouse moor managers so that permission to cull red deer is dependent on meeting targets set by a publicly accountable organisation and raptor persecution results in loss of hunting rights.


Electric fencing
Electrified deer fencing and stock fencing has been spreading across moorland Scotland in recent years, bringing with it massive constraints on public access and risk to those crossing electrified fences. Such fences should be prohibited, except in very restricted circumstances, such as within enclosed fields where horses and cattle need additional constraints.


Hill tracks
The widespread use of all terrain vehicles and the construction of new hill tracks are continuing, with no effective constraints in place. It was a serious error of the present Scottish Government when it failed to take the opportunity to bring such tracks under full planning control, opting instead for a system of prior notification. Landowners and planners say this creates just as much work as a full planning application, but with less clarity and no public scrutiny. This must be rectified in the next Parliament.


The UK Government decision to cut the subsidy for wind turbine development has been a welcome measure that has helped to curtail the proliferation of industrial scale windfarms in much of upland Scotland. Further constraints on such developments are needed, along with increased incentives to promote less energy use in the home, workplace and vehicle. The future for large scale wind turbines lies offshore.


Paths, trails and physical activity
In recent years the Scottish Government made substantial progress in the development of better paths and trails and the promotion of physical activity, partly as legacy benefits from the 2012 Olympic and 2014 Commonwealth Games. These achievements must be built on by the next Scottish Government, recognising not only the health and environmental benefits of improved walking and cycling routes, but also the economic value brought to all parts of the country through new trail construction work and its role in providing a key part of the infrastructure that underpins Scottish tourism. To achieve this there needs to be a national target to increase path expenditure relative to road expenditure on an annual incremental basis.


Field margins
The Common Agricultural Policy continues to deliver very little environmental benefit. Too much of the subsidy provided to lowland farmland is devoted to delivering increased production, leaving a biological desert across much of our land. Much more effort is needed by the next Scottish Government, in partnership with others, to drive CAP reforms in the direction where the majority of public money paid to farmers and crofters is to deliver public benefit not production profit. One of the most effective means of achieving this would be through expanded field margin management schemes to deliver biodiversity, public access and pollution control benefits on all farms. Securing funding for such margin schemes should be a key objective of Scottish Government rural policy in future CAP negotiations.


National Parks
The last two SNP Governments, in post since 2007, have achieved very little in the development of Scotland’s national park system, apart from the southern extension of the Cairngorms Park to Blair Atholl. They have allowed the governance of the Loch Lomond and Trossachs National Park to degenerate to a level not usually seen in other public bodies. Manifesto promises on developing the national parks system have come to nothing. In the next Parliament lessons need to be learnt from the establishment of the first two parks, including their current failings, so that the associated environmental and economic benefits that the parks are capable of can also be brought to other areas of Scotland which are worthy of national parks status. A priority should be the establishment of a national park on Harris in the Western Isles, where the economic case for providing a tourism boost here through national park designation outweighs any other location in Scotland.


Wild land protection
A major achievement of the Scottish Government has been the establishment of a wild land mapping programme by Scottish Natural Heritage which has classified all parts of Scotland according to degrees of wildness. This was in part a response to a European Parliament resolution in 2009 which called on all governments to do more to protect wild land and wilderness values. By building wild land evaluation into land use decisions Scotland is now at the forefront of European efforts to protect these values. This should be recognised by the next Scottish Government and further progress made to extend wild land understanding and to incorporate rewilding principles into government policy.


Government agency reorganisation
The structure of Scottish Government departments that deal with environmental and outdoor recreational interests has remained fairly static for many years. There is a case for refreshing the present system and dealing with some endemic problems embedded within the present structure. A priority should be the splitting up of Forestry Commission Scotland so that its land ownership and management functions, as carried out by Forest Enterprise, are clearly separated from the regulatory and grant aid functions of the FCS. A better arrangement might be to combine these functions with the parallel regulatory and grant aid functions of Scottish Natural Heritage. Indeed a case can be made for combining all these functions plus SNH’s habitat protection roles with similar functions for the water environment carried out by the Scottish Environment Protection Agency. This would create a single body better equipped to deal with the challenges of wildlife and habitat management, including woodland and peatland development, in a world where the impacts of changing climates and needs of outdoor recreation require a much more integrated approach by rural agencies. In parallel to this is the need to strengthen understanding and provision for outdoor recreation so that, at the highest levels of government, there is clear recognition of the role of outdoor recreation in delivering health, environmental and economic benefits. At present the promotion of outdoor recreation falls between too many stools, being a part of SNH and FCS functions, as well as those of sportscotland and visitscotland. Learning from other parts of the world, a better arrangement might be to bring these functions together into, for example, a department or agency for outdoor recreation and sport. This would give outdoor recreation the profile and resource priority that it needs in order to play an enhanced role in the lives of every one of our citizens as well as all visitors to Scotland.

(Dave Morris is former Director of Ramblers Scotland and is an adviser to the UIAA)