Item 8 Appendix 2: HRA 20250104DET River Tromie v3

Cairngorms Nation­al Park Author­ity Ugh­dar­ras Pairc Nàiseanta a’ Mhon­aidh Ruaidh Item 8 Appendix 2 29 August 2025 Page 1 of 33

Agenda item 8

Appendix 2

2025/0104/DET

Hab­it­ats reg­u­la­tions appraisal

HAB­IT­ATS REG­U­LA­TIONS APPRAIS­AL Plan­ning ref­er­ence and pro­pos­al inform­a­tion Appraised by Date Checked by Date 2025/0104/DET, Realign­ment of 400m of River Tromie Scott Shanks, Eco­lo­gic­al Advice Officer (Plan­ning) 03 June 2025 (ori­gin­al) Ver­sion 2 updated 06 August 2025 fol­low­ing dis­cus­sion with NatureScot Ver­sion 3 updated 15 August 2025 to include River Spey — Insh Marshes Ram­sar fea­tures Ver­sion 2 & 3 checked by Anne Elli­ott, NatureScot Oper­a­tions Officer – Cent­ral High­land Ver­sion 2: 07/08/2025 Ver­sion 3: 18/08/2025

INFORM­A­TION European site details Name of European site(s) poten­tially affected 1) River Spey SAC 2) Insh Marshes SAC 3) River Spey — Insh Marshes SPA Qual­i­fy­ing interest(s) 1) River Spey SAC Otter Fresh­wa­ter pearl mus­sel Sea lamprey Atlantic sal­mon 2) Insh Marshes SAC Alder wood­land on flood­plains Clear-water lakes or lochs with aquat­ic veget­a­tion and poor to mod­er­ate nutri­ent levels Very wet mires often iden­ti­fied by an unstable quaking sur­face 3) River Spey — Insh Marshes SPA Hen har­ri­er (non-breed­ing) Osprey Spot­ted crake Whoop­er swan (non-breed­ing) Wigeon Wood sand­piper 4) River Spey – Insh Marshes Ram­sar Meso­troph­ic loch Flood plain mire Alder Wood­land String sedge Scand­inavi­an small reed grass Least water lily

Cow­bane Shady hor­se­tail Pill­wort Inver­teb­rate Assemblage Otter Osprey Spot­ted crake Whoop­er Swan Wigeon Wood Sand­piper Con­ser­va­tion object­ives for qual­i­fy­ing interests 1) River Spey SAC Con­ser­va­tion Object­ive 2. To ensure that the integ­rity of the River Spey SAC is restored by meet­ing object­ives 2a, 2b, 2c for each qual­i­fy­ing fea­ture (and 2^d for fresh­wa­ter pearl mus­sel): 2b. Restore the dis­tri­bu­tion of fresh­wa­ter pearl mus­sel through­out the site 2c. Restore the hab­it­ats sup­port­ing fresh­wa­ter pearl mus­sel with­in the site and avail­ab­il­ity of food 2^d. Restore the dis­tri­bu­tion and viab­il­ity of fresh­wa­ter pearl mus­sel host spe­cies and their sup­port­ing hab­it­ats 2a. Restore the pop­u­la­tion of fresh­wa­ter pearl mus­sel as a viable com­pon­ent of the site 2b. Main­tain the dis­tri­bu­tion of sea lamprey through­out the site 2c. Main­tain the hab­it­ats sup­port­ing sea lamprey with­in the site and avail­ab­il­ity of food 2a. Main­tain the pop­u­la­tion of sea lamprey as a viable com­pon­ent of the site 2b. Restore the dis­tri­bu­tion of Atlantic sal­mon through­out the site 2c. Restore the hab­it­ats sup­port­ing Atlantic sal­mon with­in the site and avail­ab­il­ity of food 2a. Restore the pop­u­la­tion of Atlantic sal­mon, includ­ing range of genet­ic types, as a viable com­pon­ent of the site 2b. Main­tain the dis­tri­bu­tion of otter through­out the site 2c. Main­tain the hab­it­ats sup­port­ing otter with­in the site and avail­ab­il­ity of food

2a. Main­tain the pop­u­la­tion of otter as a viable com­pon­ent of the site Con­ser­va­tion Object­ive I. To ensure that the qual­i­fy­ing fea­tures of the River Spey SAC are in favour­able con­di­tion and make an appro­pri­ate con­tri­bu­tion to achiev­ing favour­able con­ser­va­tion status. 2) River Spey — Insh Marshes SPA To avoid deteri­or­a­tion of the hab­it­ats of the qual­i­fy­ing spe­cies (Hen har­ri­er, Osprey, Spot­ted crake, Whoop­er swan, Wigeon and Wood sand­piper) or sig­ni­fic­ant dis­turb­ance to the qual­i­fy­ing spe­cies, thus ensur­ing that the integ­rity of the site is main­tained; and To ensure for the qual­i­fy­ing spe­cies that the fol­low­ing are main­tained in the long term: Pop­u­la­tion of the spe­cies as a viable com­pon­ent of the site Dis­tri­bu­tion of the spe­cies with­in site Dis­tri­bu­tion and extent of hab­it­ats sup­port­ing the spe­cies Struc­ture, func­tion and sup­port­ing pro­cesses of hab­it­ats sup­port­ing the spe­cies No sig­ni­fic­ant dis­turb­ance of the spe­cies 3) Insh Marshes SAC Con­ser­va­tion Object­ive 2. To ensure that the integ­rity of Insh Marshes is restored by meet­ing object­ives 2a, 2b and 2c for each qual­i­fy­ing fea­ture. 2a. Main­tain the extent and dis­tri­bu­tion of clear-water lakes or lochs with aquat­ic veget­a­tion and poor to mod­er­ate nutri­ent levels with­in the site 2b. Main­tain the struc­ture, func­tion and sup­port­ing pro­cesses of clear-water lakes or lochs with aquat­ic veget­a­tion and poor to mod­er­ate nutri­ent levels 2c. Main­tain the dis­tri­bu­tion and viab­il­ity of typ­ic­al spe­cies of clear-water lakes or lochs with aquat­ic veget­a­tion and poor to mod­er­ate nutri­ent levels 2a. Main­tain the extent and dis­tri­bu­tion of very wet mires often iden­ti­fied by an unstable ​‘quak­ing’ sur­face with­in the site 2b. Main­tain the struc­ture, func­tion and sup­port­ing pro­cesses of very wet mires often iden­ti­fied by an unstable ​‘quak­ing’ sur­face 2c. Main­tain the dis­tri­bu­tion and viab­il­ity of typ­ic­al spe­cies of very wet mires often iden­ti­fied by an unstable ​‘quak­ing’ sur­face 2a. Main­tain the extent and dis­tri­bu­tion of alder wood­land on flood­plains with­in the site

2b. Restore the struc­ture, func­tion and sup­port­ing pro­cesses of alder wood­land on flood­plains 2c. Main­tain the dis­tri­bu­tion and viab­il­ity of typ­ic­al spe­cies of alder wood­land on flood­plains Con­ser­va­tion Object­ive I. To ensure that the qual­i­fy­ing fea­tures of Insh Marshes SAC are in favour­able con­di­tion and make an appro­pri­ate con­tri­bu­tion to achiev­ing favour­able con­ser­va­tion status. 4) River Spey – Insh Marshes Ram­sar 2a. Main­tain the extent and dis­tri­bu­tion of Meso­troph­ic loch with­in the site 2b. Main­tain the struc­ture, func­tion and sup­port­ing pro­cesses of Meso­troph­ic loch 2c. Main­tain the dis­tri­bu­tion and viab­il­ity of typ­ic­al spe­cies of Meso­troph­ic loch 2a. Main­tain the extent and dis­tri­bu­tion of Flood-plain mire with­in the site 2b. Main­tain the struc­ture, func­tion and sup­port­ing pro­cesses of Flood-plain mire 2c. Main­tain the dis­tri­bu­tion and viab­il­ity of typ­ic­al spe­cies of Flood-plain mire 2a. Main­tain the extent and dis­tri­bu­tion of Alder wood­land 2b. Main­tain the struc­ture, func­tion and sup­port­ing pro­cesses of Alder wood­land 2c. Main­tain the dis­tri­bu­tion and viab­il­ity of typ­ic­al spe­cies of Alder wood­land 2b. Main­tain the dis­tri­bu­tion of Otter through­out the site 2c. Main­tain the hab­it­ats sup­port­ing Otter with­in the site and avail­ab­il­ity of food 2a. Main­tain the pop­u­la­tion of Otter as a viable com­pon­ent of the site To ensure that except where due to nat­ur­al envir­on­ment­al change the fol­low­ing are main­tained in the long term: Pop­u­la­tion of the Inver­teb­rate Assemblage as a viable com­pon­ent of the site Dis­tri­bu­tion of the Inver­teb­rate Assemblage with­in site Dis­tri­bu­tion and extent of hab­it­ats sup­port­ing the Inver­teb­rate Assemblage Struc­ture, func­tion and sup­port­ing pro­cesses of hab­it­ats sup­port­ing the Inver­teb­rate Assemblage No sig­ni­fic­ant dis­turb­ance of the Inver­teb­rate Assemblage To avoid deteri­or­a­tion of the hab­it­ats of the qual­i­fy­ing spe­cies (Hen har­ri­er, Osprey,

Spot­ted crake, Whoop­er swan, Wigeon and Wood sand­piper) or sig­ni­fic­ant dis­turb­ance to the qual­i­fy­ing spe­cies, thus ensur­ing that the integ­rity of the site is main­tained; and To ensure for the qual­i­fy­ing spe­cies that the fol­low­ing are main­tained in the long term: Pop­u­la­tion of the spe­cies as a viable com­pon­ent of the site Dis­tri­bu­tion of the spe­cies with­in site Dis­tri­bu­tion and extent of hab­it­ats sup­port­ing the spe­cies Struc­ture, func­tion and sup­port­ing pro­cesses of hab­it­ats sup­port­ing the spe­cies No sig­ni­fic­ant dis­turb­ance of the spe­cies Note: The pro­tec­tion of String sedge, Scand­inavi­an Small reed grass (Cala­magrostis pur­purea), Least water lily, Cow­bane, Shady hor­se­tail and Pill­wort is delivered by the over­lap­ping Insh Marshes SAC Con­ser­va­tion Object­ives for Clear-water lakes or lochs with aquat­ic veget­a­tion and poor to mod­er­ate nutri­ent levels, Very wet mires often iden­ti­fied by an unstable quaking sur­face and Alder wood­land on flood­plains. Con­ser­va­tion Object­ive I. To ensure that the qual­i­fy­ing fea­tures of River Spey- Insh Marshes Ram­sar are in favour­able con­di­tion and make an appro­pri­ate con­tri­bu­tion to achiev­ing favour­able con­ser­va­tion status.

APPRAIS­AL STAGE 1: What is the plan or pro­ject? Rel­ev­ant sum­mary details of pro­pos­al (includ­ing loc­a­tion, tim­ing, meth­ods, etc) The pro­posed realign­ment of 400m of the River Tromie will cre­ate a new chan­nel to realign the his­tor­ic­ally straightened lower reach of the River Tromie, which will con­nect with the Inver­tromie Drain as the main con­flu­ence with the River Spey. The new chan­nel starts at NH 78095 00791 and fin­ishes at NH 77814 00953 where it will join the Inver­tromie Drain. The river will flow along the final 200m of the drain before join­ing the Spey at NH 77931 01110. The new chan­nel will recon­nect the river with its flood­plain after hav­ing been con­strained by stone embank­ments for the last 150 – 200 years and will reduce the risk of an uncon­trolled avul­sion over the right-hand bank onto the Dell of Kil­liehuntly farm. Fish pas­sage and hab­it­at will be main­tained through the cre­ation of riffles and pools, and rare inver­teb­rate pop­u­la­tions that are reli­ant upon banks of sands and gravels will be enhanced due to the new depos­itions of sands and gravels that will occur reg­u­larly due to the under­sized chan­nel. Reg­u­lar over­top­ping of the rivers banks will also main­tain the wet­land plant com­munit­ies includ­ing trans­ition mire. The realigned chan­nel will have great­er con­nectiv­ity with the flood­plain and enhance wet­land hab­it­at around the realigned sec­tion. The con­struc­tion peri­od is expec­ted to take 4 – 6 weeks, aim­ing to start in August to avoid the peak breed­ing bird sea­son (March to mid-August), and the Atlantic sal­mon spawn­ing sea­son (mid- Octo­ber to Feb­ru­ary). STAGE 2: Is the plan or pro­ject dir­ectly con­nec­ted with or neces­sary for the man­age­ment of the European site for nature con­ser­va­tion? 1) River Spey SAC Yes, this pro­ject is dir­ectly con­nec­ted with the man­age­ment of this site for nature con­ser­va­tion. i) Has the effect on all qual­i­fy­ing interests been con­sidered? Yes. Atlantic sal­mon, fresh­wa­ter pearl mus­sel (FWPM), sea lamprey and otter, the qual­i­fy­ing interests (Qls) of the River Spey SAC, have been con­sidered dur­ing the devel­op­ment of this river realign­ment pro­pos­al. Exist­ing hab­it­at con­di­tion, and the dis­tri­bu­tion and extents of the Qls, as well as their con­ser­va­tion object­ives were used to inform the res­tor­a­tion design and pro­posed con­struc­tion works (i.e. meth­od­o­logy and tim­ing) to mit­ig­ate against impacts on these spe­cies. The poten­tial impacts, design and mit­ig­a­tion meas­ures under­taken and resid­ual impacts on the Qls are fur­ther dis­cussed in Stage 4. ii) Is the pro­pos­al part of a fully assessed and agreed man­age­ment plan Yes, the pro­pos­al is being delivered as part of the Cairngorms Con­nect Flood­plains and River Res­tor­a­tion pro­gramme. Cairngorms Con­nect con­sists of a part­ner­ship of Wild­Land Lim­ited, NatureScot, Forestry and Land Scot­land, and RSPB Scot­land, with the

iii) iv) Cairngorms Nation­al Park as a sup­port­ing part­ner. The part­ner­ship has a 200-year vis­ion that aims to enhance hab­it­ats, spe­cies and eco­lo­gic­al pro­cesses across 600ha of con­nec­ted land with­in the Cairngorms Nation­al Park. Pre­vi­ous works to improve hab­it­at diversity in the River Tromie involved the install­a­tion of 9 large woody struc­tures in 2022, which was sup­por­ted by the Scot­tish Government’s Nature Res­tor­a­tion Fund. Is there a clear rationale to jus­ti­fy the con­nec­tion with the con­ser­va­tion object­ives? Yes. The Con­ser­va­tion Object­ives for Atlantic sal­mon, FWPM, sea lamprey and otter seek to improve the pop­u­la­tion, dis­tri­bu­tion, and avail­ab­il­ity of sup­port­ing hab­it­ats for these pro­tec­ted spe­cies. If there is a clear rationale to jus­ti­fy the con­nec­tion with the con­ser­va­tion object­ives, will any bene­fits arising from the pro­pos­al out­weigh any neg­at­ive impacts? Yes. Steps have been taken dur­ing the design devel­op­ment to mit­ig­ate against impacts to the SAC’s qual­i­fy­ing interests. As noted in the response at 2ii) the pro­posed river realign­ment works along the lower extent of the River Tromie have the poten­tial to improve hab­it­at pro­vi­sion and diversity for all Qls, con­trib­ut­ing towards improv­ing the con­di­tion of the des­ig­nated site. The design and con­struc­tion meth­od­o­logy have been developed with pro­posed mit­ig­a­tion meas­ures in place (see Tromie Option­eer­ing and Final Design FINAL Report and Tromie Res­tor­a­tion — Meth­od State­ment Advice to inform Con­tract­ors Con­struc­tion Man­age­ment Plan), and the con­tract­or will be tasked with the devel­op­ment of an Oper­a­tion­al Man­age­ment Plan with spe­cif­ic mit­ig­a­tions for sed­i­ment man­age­ment and pol­lu­tion con­trol, con­trol of invas­ive non-nat­ive spe­cies (INNS) and pro­tec­ted spe­cies plans, which will lim­it neg­at­ive impacts on the Qls. How­ever, dur­ing the con­struc­tion pro­cess resid­ual risks remain, such as best prac­tice con­struc­tion meth­od­o­lo­gies not being fol­lowed or imple­men­ted incor­rectly. These mit­ig­a­tion meas­ures and resid­ual risk will be dis­cussed fur­ther in Stage 4. v) Have any altern­at­ive meth­ods of imple­ment­ing the pro­pos­al been explored, includ­ing build­ing in any rel­ev­ant mit­ig­a­tion, to demon­strate that this is a the least dam­aging option? Yes. Dur­ing both the design devel­op­ment and con­struc­tion plan­ning stages. The ​‘Tromie Option­eer­ing and Final Design FINAL’ report out­lines 8 design options that were assessed against sev­er­al factors includ­ing impacts on veget­a­tion, fish pas­sage and water flows. The ​‘Tromie Res­tor­a­tion Mod­el­ling and Flood Risk Assess­ment FINAL Report’ has also con­sidered poten­tial increases to flood risk. The ​‘Tromie Res­tor­a­tion Meth­od State­ment Advice to inform Con­tract­ors Con­struc­tion Man­age­ment Plan’ report out­lines required mit­ig­a­tion meas­ures includ­ing sed­i­ment and pol­lu­tion man­age­ment meas­ures that area to be included in the contractor’s Oper­a­tion­al Man­age­ment Plan. These mit­ig­a­tion meas­ures must be employed dur­ing con­struc­tion to pre­vent this mater­i­al from being mobil­ised into the River Tromie or the Inver­tromie Burn, and from there into the River Spey.

vi) Give a Yes/​No con­clu­sion in terms of wheth­er the plan or pro­ject is con­sidered to dir­ectly con­nect with or neces­sary to site man­age­ment for nature con­ser­va­tion. Yes. The pro­ject site is covered by the River Spey SAC des­ig­na­tion. There­fore, realign­ment works along this sec­tion of the River Tromie (a trib­u­tary of the River Spey) will dir­ectly impact the River Spey SAC. How­ever, the pro­pos­al aims to rein­state nat­ur­al dynam­ic pro­cesses along the water­course, enhance hab­it­at pro­vi­sion and diversity both in the river and the flood­plain, as well as con­trib­ut­ing to nat­ur­al flood risk man­age­ment and improv­ing cli­mate change resi­li­ence. There­fore, it is deemed that this river realign­ment work is neces­sary for nature con­ser­va­tion and should improve suit­able hab­it­at diversity and poten­tially increase dis­tri­bu­tion of Atlantic sal­mon, FWPM, sea lamprey and otter with­in the site. 2) River Spey — Insh Marshes SPA No, this pro­ject is not dir­ectly con­nec­ted with or neces­sary for the man­age­ment of the European site for nature con­ser­va­tion 3) Insh Marshes SAC No, this pro­ject is not dir­ectly con­nec­ted with or neces­sary for the man­age­ment of the European site for nature con­ser­va­tion 4) River Spey — Insh Marshes Ram­sar No, this pro­ject is not dir­ectly con­nec­ted with or neces­sary for the man­age­ment of the European site for nature con­ser­va­tion STAGE 3: Is the plan or pro­ject (either alone or in-com­bin­a­tion with oth­er plans or pro­jects) likely to have a sig­ni­fic­ant effect on the site(s)? 1) River Spey SAC Otter: Yes, LSE from short term effects arising dur­ing con­struc­tion activ­ity. There could be long term impacts through improved nat­ur­al­isa­tion of the riverb­anks and wet­land improve­ment works which could provide increased hab­it­at for otters and their prey. Fresh­wa­ter pearl mus­sel: YES, there will be a LSE from short term effects arising dur­ing con­struc­tion includ­ing fine sed­i­ment released dur­ing con­struc­tion activ­ity that could smoth­er FWPM pop­u­la­tions down­stream of the site, with­in the River Spey. Pol­lu­tion from con­struc­tion work such as fuel spillages could also enter the water­course and impact FWPM and host spe­cies in the River Spey SAC. Poor bio­se­c­ur­ity meas­ures could res­ult in the spread of dis­ease or invas­ive on-nat­ive spe­cies (INNS) that could impact FWPM pop­u­la­tions and host spe­cies. There could be post-con­struc­tion effects arising from expan­sion of suit­able FWPM hab­it­at, and host spe­cies hab­it­ats with poten­tial to increase FWPM abund­ance and improve dis­tri­bu­tion and

encour­age col­on­isa­tion of the res­tor­a­tion site. Sea lamprey: Yes, LSE from short term effects arising dur­ing con­struc­tion activ­ity includ­ing dis­turb­ance of exist­ing hab­it­at with­in the River Tromie through release of sed­i­ment mobil­ised from banks and river­bed dur­ing con­struc­tion works, or pol­lu­tion from con­struc­tion activ­ity such as fuel spills. There could be post-con­struc­tion impacts from improved nat­ur­al dynam­ism of the River Tromie and improved hab­it­at for Sea Lamprey Atlantic sal­mon: Yes, LSE from short term effects arising dur­ing con­struc­tion activ­ity includ­ing dis­turb­ance of exist­ing hab­it­at with­in the River Tromie through release of sed­i­ment mobil­ised from banks and river­bed dur­ing con­struc­tion works that could smoth­er Atlantic sal­mon spawn­ing gravels down­stream of the site, pol­lu­tion from con­struc­tion activ­ity such as fuel spills and dis­turb­ance dur­ing spawn­ing peri­ods. There could be post-con­struc­tion impacts from improved nat­ur­al dynam­ism of the River Tromie and improved hab­it­at for Atlantic sal­mon. 2) River Spey — Insh Marshes SPA Hen har­ri­er (non-breed­ing): Yes, LSE from short-term effects from dis­turb­ance arising dur­ing con­struc­tion activ­ity. Osprey: Yes, LSE from short-term effects ars­ing dur­ing con­struc­tion activ­ity. Poten­tial long- term effects from improve­ments to hab­it­at diversity with­in the River Tromie, and pos­sible pos­it­ive impacts on prey spe­cies includ­ing Atlantic sal­mon. Spot­ted crake: Yes, LSE from short-term effects arising con­struc­tion activ­ity. Spot­ted crake are sum­mer vis­it­ors to the UK, return­ing to win­ter­ing grounds in Octo­ber each year. Whoop­er swan (non-breed­ing): Yes, LSE from short-term effects arising dur­ing con­struc­tion activ­ity. Whoop­er swans are a win­ter­ing spe­cies in the UK. They gen­er­ally arrive back in the UK in Octo­ber. Wigeon: Yes, LSE from short-term effects arising dur­ing con­struc­tion activ­ity. The major­ity of wigeon in the UK are winter vis­it­ors from Scand­inavia, how­ever there are res­id­ent birds which breed in parts of Scot­land includ­ing at sites with­in the Cairngorms Nation­al Park. Wood sand­piper: Yes, LSE from short-term effects arriv­ing dur­ing con­struc­tion activ­ity. Wood Sand­piper are a spring and sum­mer migrant spe­cies, that gen­er­ally leave the UK for winter in grounds in Octo­ber. Poten­tial for long-term pos­it­ive effects from wet­land enhance­ment works. 3) Insh Marshes SAC Alder wood­land on flood­plains, No LSE as no tree works are pro­posed with­in the Insh Marshes SAC as part of the applic­a­tion, and there­fore no pri­or­ity alder wood­land will be impacted by the pro­posed river realign­ment on the flood plain. This QI has been scoped out of fur­ther con­sid­er­a­tion. Clear-water lakes or lochs with aquat­ic veget­a­tion and poor to mod­er­ate nutri­ent levels: No LSE. The pro­posed route of the River Tromie realign­ment will not dir­ectly impact any of the clear-water lakes or lochs with­in the Insh Marshes SAC. The loc­a­tion of the pro­posed con­flu­ence of the realigned River Tromie and the River Spey is over 7km upstream of Loch Insh, and so there will be neg­li­gible impacts from the poten­tial mobil­isa­tion of sed­i­ment or

pol­lu­tion this far upstream (Ref: wat-sg-90-sepa-con­ser­va­tion-pro­ced­ure-for-sacs-spas-and- sssis.pdf). There­fore, there will be no impacts on this Ql, and this QI has been scoped out of fur­ther con­sid­er­a­tion. Very wet mires often iden­ti­fied by an unstable quaking sur­face: Yes, LSE from short-term impacts from loss of trans­ition mire hab­it­at where the pro­posed realigned River Tromie chan­nel meets the Inver­tromie Burn before empty­ing into the Spey. How­ever, mod­el­ling indic­ates that there will be a long-term sig­ni­fic­ant increase in the extent of this hab­it­at as a res­ult of the River Tromie realign­ment works (Ref: Tromie Option­eer­ing and Final Design FINAL Report). River Spey — Insh Marshes Ram­sar Meso­troph­ic Loch: No LSE. The pro­posed route of the River Tromie realign­ment will not dir­ectly impact on Loch Insh, which is a meso­troph­ic Loch. The loc­a­tion of the pro­posed con­flu­ence of the realigned River Tromie and the River Spey is over 7km upstream of Loch Insh, and so there will be neg­li­gible impacts from the poten­tial mobil­isa­tion of sed­i­ment or pol­lu­tion this far upstream (Ref: wat-sg-90-sepa-con­ser­va­tion-pro­ced­ure-for-sacs-spas-and- sssis.pdf). There­fore, there will be no impacts on this Ql, and this QI has been scoped out of fur­ther con­sid­er­a­tion. Flood-plain mire: Yes, LSE from short-term impacts from loss of trans­ition mire hab­it­at where the pro­posed realigned River Tromie chan­nel meets the Inver­tromie Burn before empty­ing into the Spey. Insh Marshes is the largest trans­ition mire in the UK. This site is rep­res­ent­at­ive of the flood plain mire type. How­ever, mod­el­ling indic­ates that there will be a long-term sig­ni­fic­ant increase in the extent of this hab­it­at as a res­ult of the River Tromie realign­ment works (Ref: Tromie Option­eer­ing and Final Design FINAL Report). Alder wood­land, No LSE as no tree works are pro­posed with­in the River-Spey Insh Marsh Ram­sar bound­ary as part of the applic­a­tion, and there­fore no pri­or­ity alder wood­land will be impacted by the pro­posed river realign­ment on the flood plain. This QI has been scoped out of fur­ther con­sid­er­a­tion. Inver­teb­rate Assemblage: Yes, LSE from short term effects arising from loss of exposed riv­er­ine hab­it­at along the exist­ing chan­nel. How­ever there will be long term This site has a rich diversity of inver­teb­rate spe­cies util­ising a range of dif­fer­ent hab­it­ats with­in the Ram­sar bound­ary includ­ing alder wood­land, birch wood­land, fen and wet­land hab­it­ats, and exposed riv­er­ine shingle (ERS) at the edges of water­courses. The ERS hab­it­at along the exist­ing chan­nel is likely to be lost Otter: Yes, LSE from short term effects arising dur­ing con­struc­tion activ­ity. There could be long term impacts through improved nat­ur­al­isa­tion of the riverb­anks and wet­land improve­ment works which could provide increased hab­it­at for otters and their prey. String sedge (Carex chor­dor­rhiza), Scand­inavi­an small-reed (Cala­magrostis pur­purea), least water lily (Nuphar pum­ila), cow­bane (Cicuta virosa), shady hor­se­tail (Equis­etum pratense) and pill­wort (Pil­u­laria globulifera). No LSE. This is not an import­ant loc­a­tion with­in the Ram­sar for any of these plant spe­cies. RSPB Scot­land mon­it­or­ing indic­ates that no

Scand­inavi­an small-reed is present. Cow­bane and String Sedge are present fur­ther north of the devel­op­ment, but not with the res­tor­a­tion site, and the increased wet­ness is not likely to reach them. Least water lily is not present in the lower part of the ditch. The long-term pre­dicted changes are not likely to affect any of these spe­cies. These QI have been scoped out of fur­ther con­sid­er­a­tion. Hen har­ri­er (non-breed­ing): Yes, LSE from short-term effects from dis­turb­ance arising dur­ing con­struc­tion activ­ity. Osprey: Yes, LSE from short-term effects ars­ing dur­ing con­struc­tion activ­ity. Poten­tial long- term effects from improve­ments to hab­it­at diversity with­in the River Tromie, and pos­sible pos­it­ive impacts on prey spe­cies includ­ing Atlantic sal­mon. Spot­ted crake: Yes, LSE from short-term effects arising con­struc­tion activ­ity. Spot­ted crake are sum­mer vis­it­ors to the UK, return­ing to win­ter­ing grounds in Octo­ber each year. Whoop­er swan (non-breed­ing): Yes, LSE from short-term effects arising dur­ing con­struc­tion activ­ity. Whoop­er swans are a win­ter­ing spe­cies in the UK. They gen­er­ally arrive back in the UK in Octo­ber. Wigeon: Yes, LSE from short-term effects arising dur­ing con­struc­tion activ­ity. The major­ity of wigeon in the UK are winter vis­it­ors from Scand­inavia, how­ever there are res­id­ent birds which breed in parts of Scot­land includ­ing at sites with­in the Cairngorms Nation­al Park. Wood sand­piper: Yes, LSE from short-term effects arriv­ing dur­ing con­struc­tion activ­ity. Wood Sand­piper are a spring and sum­mer migrant spe­cies, that gen­er­ally leave the UK for winter in grounds in Octo­ber. Poten­tial for long-term pos­it­ive effects from wet­land enhance­ment works. STAGE 4: Under­take an Appro­pri­ate Assess­ment of the implic­a­tions for the site(s) in view of the(ir) con­ser­va­tion object­ives 1) River Spey SAC Con­ser­va­tion Object­ive 2. To ensure that the integ­rity of the River Spey SAC is restored by meet­ing object­ives 2a, 2b, 2c for each qual­i­fy­ing fea­ture (and 2^d for fresh­wa­ter pearl mus­sel): 2b. Restore the dis­tri­bu­tion of fresh­wa­ter pearl mus­sel through­out the site The pro­posed river realign­ment works will con­trib­ute towards achiev­ing this Con­ser­va­tion Object­ive. A Pro­tec­ted Spe­cies sur­vey under­taken in Novem­ber 2024 found no evid­ence of FWPM with­in the lower stretches of the River Tromie and a 500m buf­fer down­stream of the site with­in the River Spey (350m of which was eas­ily sur­vey­able dur­ing the sur­vey). This was a repeat of a sur­vey under­taken in 2022, which also found no evid­ence of FWPM. The lower River Tromie sur­vey reach was con­sidered mostly unsuit­able for pearl mus­sels due to unstable pebble and cobble dom­in­ated hab­it­at, with only small mar­gin­al patches of partly stable, sub-optim­al hab­it­ats present. There was no evid­ence of pearl mus­sels with­in the 350m reach of the River Spey, where again

sub­strates were classed as unstable and the hab­it­ats were con­sidered unsuit­able. The River Tromie realign­ment pro­pos­al aims to cre­ate a diversity of hab­it­ats suit­able for FWPM and it’s host spe­cies with­in the realigned chan­nel. The improved hab­it­at diversity will improve suit­ab­il­ity for FWPM and host spe­cies such as Atlantic sal­mon. This could increase suit­ab­il­ity for FWPM and improve the prob­ab­il­ity of fur­ther col­on­isa­tion of FWPM across the site. Pro­posed mit­ig­a­tion meas­ures included in the design pro­cess includ­ing avoid­ing dis­turb­ance dur­ing Atlantic sal­mon spawn­ing, and mit­ig­a­tion meas­ures pro­posed for the con­tract­or Oper­a­tion­al Man­age­ment Plan (Ref: Tromie Res­tor­a­tion — Meth­od State­ment Advice to inform Con­tract­ors Con­struc­tion Man­age­ment Plan) as part of the pro­pos­al will min­im­ise the con­struc­tion phase risks of mobil­isa­tion of sed­i­ments, pol­lu­tion or dis­ease that could poten­tially impact FWPM fur­ther down­stream of the pro­ject site with­in the River Spey. 2c. Restore the hab­it­ats sup­port­ing fresh­wa­ter pearl mus­sel with­in the site and avail­ab­il­ity of food. The pro­posed river realign­ment works will con­trib­ute towards achiev­ing this Con­ser­va­tion Object­ive. The pro­posed works will improve hab­it­at diversity for host spe­cies of FWPM (such as Atlantic sal­mon) through the cre­ation of a series of pools, lat­er­al bars and riffles, that will res­ult in the loc­al­ised depos­ition of a range of sed­i­ments. This will pro­mote the expan­sion of suit­able FWPM hab­it­ats and improve the chances of fur­ther col­on­isa­tion of this sec­tion of the SAC. The pro­pos­al will improve water­course to flood plain con­nectiv­ity. The works aim to improve hab­it­at for FWPM host spe­cies and mod­el­ling of sal­monid fish pas­sage have been con­sidered in the design pro­cess. The pro­pos­als should res­ult in improved nutri­ent exchange with the flood­plain, which will provide organ­ic mat­ter for feed­ing FWPMs that might col­on­ise through increased use of the lower reaches of the River Tromie by host sal­monid spe­cies. 2^d. Restore the dis­tri­bu­tion and viab­il­ity of fresh­wa­ter pearl mus­sel host spe­cies and their sup­port­ing hab­it­ats. The pro­posed river realign­ment works will con­trib­ute towards achiev­ing this Con­ser­va­tion Object­ive. The pro­tec­ted spe­cies sur­vey work under­taken in Novem­ber 2024 did not find any FWPM with­in the lower reach of the River Tromie, or with­in 350m down­stream of the site with­in the River Spey. The works have been designed to improve hab­it­at diversity with­in the lower River Tromie chan­nel which should bene­fit sal­monids, the host spe­cies of FWPM. Encour­aging increased use of the site by breed­ing sal­monids will increase the prob­ab­il­ity of col­on­isa­tion of the site by FWPM via glochida attached to young sal­monids. This could help restore the dis­tri­bu­tion and viab­il­ity of fresh­wa­ter pearl mus­sel in this sec­tion of the River Spey SAC. 2a. Restore the pop­u­la­tion of fresh­wa­ter pearl mus­sel as a viable com­pon­ent of the site The pro­posed River Tromie realign­ment works will con­trib­ute towards achiev­ing this Con­ser­va­tion Object­ive. As noted pre­vi­ously, there were no FWPM found with­in the sur­veyed stretches of the River Tromie or with­in a 350m of the River Spey down­stream of the pro­ject site, and exist­ing hab­it­at with­in the cur­rent lower River Tromie and stretch of the River Spey was assessed to be mainly unsuit­able for FWPM due to the dom­in­ance of unstable pebble and cobble

hab­it­at. The pro­posed sed­i­ment man­age­ment and pol­lu­tion pre­ven­tion con­trols, if cor­rectly imple­men­ted should min­im­ise the risk of neg­at­ive impacts to any undis­covered FWPM with­in the River Spey fur­ther down­stream of the sur­vey site. The realign­ment has been designed to improve hab­it­at diversity to bene­fit sal­monids (FWPM host spe­cies) and FWPM, and there­fore the res­tor­a­tion work could help restore/​expand the FWPM pop­u­la­tion into the realigned stretch of the River Tromie (which is part of the River Spey SAC). 2b. Main­tain the dis­tri­bu­tion of sea lamprey through­out the site The pro­posed River Tromie realign­ment works will con­trib­ute towards achiev­ing this Con­ser­va­tion Object­ive. There are cur­rently no records of sea lamprey using the River Tromie, or it’s con­flu­ence with the River Spey. Reg­u­lar elec­tro-fish­ing data from the River Tromie (most recently from 28/08/2022) has not recor­ded this spe­cies as present with­in the River Tromie trib­u­tary of the River Spey SAC. The pro­posed sed­i­ment man­age­ment and pol­lu­tion pre­ven­tion con­trols, if cor­rectly imple­men­ted should min­im­ise the risk of neg­at­ive impacts to poten­tial lamprey spawn­ing areas or nurs­ery areas for juven­ile sea lamprey fur­ther down­stream of the applic­a­tion site. The tim­ing of the pro­posed works will avoid the sea lamprey spawn­ing months (April-May), which will also mit­ig­ate against mobil­ised sed­i­ment smoth­er­ing spawn­ing areas. There­fore, the pro­posed realign­ment of the River Tromie chan­nel will not neg­at­ively impact the dis­tri­bu­tion of sea lamprey through­out the site. The pro­ject aims to increase hab­it­at diversity with­in the River Tromie chan­nel and improve suit­ab­il­ity for Atlantic sal­mon (a poten­tial host/​prey spe­cies of sea lamprey). The improved hab­it­at diversity may also bene­fit sea lamprey and encour­age spawn­ing with­in the River Tromie. 2c. Main­tain the hab­it­ats sup­port­ing sea lamprey with­in the site and avail­ab­il­ity of food The pro­posed river realign­ment works will con­trib­ute towards achiev­ing this Con­ser­va­tion Object­ive. There are cur­rently no records of sea lamprey with­in the River Tromie. The cur­rent lower stretches of the River Tromie have been straightened and can­al­ised in the past, which has res­ul­ted in the loss of typ­ic­al riffle and pool sequences with­in the river, and low hab­it­at diversity. The pro­pos­al has been designed to increase hab­it­at diversity with­in the realigned chan­nel and improve con­nectiv­ity with the flood­plain. This should increase hab­it­at suit­ab­il­ity for spawn­ing adults and poten­tially slower flow­ing sec­tions suit­able as nurs­ery areas for juven­ile sea lamprey. The pro­pos­al will increase hab­it­at suit­ab­il­ity for poten­tial prey spe­cies such as Atlantic sal­mon. 2a. Main­tain the pop­u­la­tion of sea lamprey as a viable com­pon­ent of the site The pro­posed river realign­ment works will con­trib­ute towards achiev­ing this Con­ser­va­tion Object­ive. As no sea lamprey have been recor­ded from the lower stretches of the River Tromie, this pro­pos­al will not have a dir­ect impact on the pop­u­la­tion of sea lamprey as a viable com­pon­ent of the River Spey SAC. The pro­posed res­tor­a­tion works may increase the extent of suit­able habitat

suit­ab­il­ity for spawn­ing sea lamprey with­in the River Tromie. 2b. Restore the dis­tri­bu­tion of Atlantic sal­mon through­out the site The pro­posed river realign­ment works will con­trib­ute towards achiev­ing this Con­ser­va­tion Object­ive. The works have been designed with a key aim of improv­ing hab­it­at diversity for Atlantic sal­mon, and to ensure that fish pas­sage from the main chan­nel of the Spey is main­tained into the Tromie. Sur­veys for Atlantic sal­mon hab­it­at with­in the lower stretches of the River Tromie (Ref: Tromie Option­eer­ing and Final Design Report, and Aer­i­al Imagery of River Tromie Fish Hab­it­at) have found that suit­able spawn­ing hab­it­ats are mainly focused in upstream areas and at the con­flu­ence of the River Tromie with the River Spey where there is high­er hab­it­at diversity com­pared to the straightened sec­tions. There are few­er areas suit­able for fry and parr with­in the cur­rent lower stretch of the Tromie. The pro­pos­al will res­ult in the loss of some spawn­ing areas near the cur­rent con­flu­ence of the River Spey how­ever these will be replaced by new areas suit­able for spawn­ing formed in the new chan­nel. Hab­it­ats suit­able for fry and parr are pre­dicted to be enhanced in the new chan­nel, and pas­sage will also be main­tained to high­er qual­ity hab­it­ats upstream. There­fore, realign­ment of the lower River Tromie will increase hab­it­at avail­ab­il­ity and diversity for Atlantic sal­mon with­in this sec­tion of the SAC. This increase in hab­it­ats suit­able for sal­mon in the new sec­tion of the river may facil­it­ate an increase in the pop­u­la­tion of Atlantic Sal­mon with­in the SAC. Mit­ig­a­tion Meas­ures included in the pro­pos­al will min­im­ise the con­struc­tion phase risks of dis­turb­ance dur­ing spawn­ing time, mobil­isa­tion of sed­i­ments that could smoth­er redds, and the release of pol­lu­tion or spread of dis­ease that could impact Atlantic sal­mon with­in the River Spey SAC. 2c. Restore the hab­it­ats sup­port­ing Atlantic sal­mon with­in the site and avail­ab­il­ity of food The pro­posed river realign­ment works will con­trib­ute towards achiev­ing this Con­ser­va­tion Object­ive. The pro­posed works will increase mor­pho­lo­gic­al diversity with­in this sec­tion of the River Tromie, cre­at­ing a diversity of hab­it­ats suit­able for a range of life stages of Atlantic Sal­mon. The cur­rent lower stretch of the River Tromie has embank­ments that lim­it con­nectiv­ity with the sur­round­ing flood­plain. The pro­posed realign­ment work will improve con­nectiv­ity between the river and the sur­round­ing flood­plain which should also provide a source of nutri­ents and food for sal­mon. The pro­ject design intends that the new chan­nel would be dynam­ic and there would be post- con­struc­tion changes. Nat­ur­al pro­cesses would oper­ate, includ­ing trans­port of sed­i­ment from the Tromie, and depos­ition and erosion of sed­i­ment. The design intends that a chan­nel pass­able to sal­mon would be main­tained for the long term. This is essen­tial to the sal­mon pop­u­la­tion of the river. The new chan­nel was designed to have a winter and sum­mer winter depth of at least 25cm, which would be deep enough for sal­mon pas­sage up and down stream in most con­di­tions apart from severe droughts. The deep­er the water, the easi­er it is for sal­mon to move. The design with

fea­tures means that pools would be present for rest­ing places for sal­mon mov­ing upstream. If the sal­mon con­nectiv­ity is com­prom­ised, for example with gravel depos­ition lead­ing to very shal­low flows in most con­di­tions, and this is per­sist­ent, for example over six months, it will be import­ant to take remedi­al action to reopen a usable chan­nel. Mit­ig­a­tion Meas­ures included in the pro­pos­al will min­im­ise the con­struc­tion phase risks of dis­turb­ance dur­ing spawn­ing time, mobil­isa­tion of sed­i­ments that could smoth­er spawn­ing sites, tem­por­ary loss of parr hab­it­at, and release of pol­lu­tion or spread of dis­ease that could impact Atlantic sal­mon with­in the River Spey SAC. Mon­it­or­ing of sed­i­ment erosion/​deposition with­in the new chan­nel should be under­taken post-con­struc­tion to ensure that flow depths are suf­fi­cient for fish pas­sage through the realigned chan­nel. If mon­it­or­ing iden­ti­fies restric­ted fish-pas­sage (both up and down the water­course) in aver­age flows for a peri­od last­ing more than 6 months, then adjust­ments should be under­taken in con­sulta­tion with a geo­mor­pho­lo­gist to restore fish pas­sage. 2a. Restore the pop­u­la­tion of Atlantic sal­mon, includ­ing range of genet­ic types, as a viable com­pon­ent of the site The pro­posed river realign­ment works will partly con­trib­ute towards achiev­ing this Con­ser­va­tion Object­ive. The res­tor­a­tion of this stretch of the River Tromie will increase hab­it­at diversity suit­able for Atlantic sal­mon. This increase in suit­able hab­it­at may in turn pro­mote an increase in the pop­u­la­tion of Atlantic sal­mon with­in this stretch of the River Spey SAC. How­ever, the pro­posed works will not influ­ence the range of genet­ic types with­in the SAC. Mit­ig­a­tion Meas­ures included in the pro­pos­al will min­im­ise the con­struc­tion phase risks of dis­turb­ance dur­ing spawn­ing time, mobil­isa­tion of sed­i­ments that could smoth­er spawn­ing sites, dis­turb­ance and tem­por­ary loss of parr hab­it­at, and release of pol­lu­tion or spread of dis­ease that could impact Atlantic sal­mon with­in the Rive Spey SAC. 2b. Main­tain the dis­tri­bu­tion of otter through­out the site The pro­posed river realign­ment works will con­trib­ute towards achiev­ing this Con­ser­va­tion Object­ive. Pro­tec­ted Spe­cies sur­veys under­taken in Novem­ber 2024 did not find any otter holts or couches, or any oth­er evid­ence of otter using the pro­ject site, how­ever it is likely that hab­it­ats in and sur­round­ing the pro­ject site are suit­able for use by for­aging otter. A fur­ther pre-con­struc­tion sur­vey for pro­tec­ted spe­cies is planned for the sum­mer of 2025. Dur­ing the con­struc­tion phase, otter may be a tem­por­ary inhib­ited from for­aging across the site. Otters can have very large home ranges of around 32km for males and 20km for females (Otter | NatureScot), and there­fore tem­por­ary con­struc­tion work at this loc­a­tion is unlikely to res­ult in sig­ni­fic­ant impact on for­aging otter. The pro­posed works will replace the straightened lower sec­tion of the Tromie with a more diverse chan­nel. The design of the new chan­nel has been mod­elled to increase hab­it­at diversity with­in the chan­nel and improve con­nec­tions with the flood­plain. The pro­posed works aim to increase the extent and diversity of wet­land hab­it­ats with­in and sur­round­ing the pro­ject site that would be suit­able for otter and there­fore will help main­tain the dis­tri­bu­tion of otter with­in the

River Spey SAC. 2c. Main­tain the hab­it­ats sup­port­ing otter with­in the site and avail­ab­il­ity of food The pro­posed river realign­ment works will con­trib­ute towards achiev­ing this Con­ser­va­tion Object­ive. The pro­posed river res­tor­a­tion works should improve the diversity of hab­it­ats with­in the River Tromie that sup­port prey spe­cies such as Atlantic salmon,