Item5Appendix3AGeneralComment20200201DETHutsCrathie

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 5 Appendix 3A 27/08/2021

AGENDA ITEM 5

APPENDIX ЗА

2020/0201/DET

REP­RES­ENT­A­TIONS GENERAL

Emma Bryce Plan­ning Man­ager (Devel­op­ment Man­age­ment) Cairngorms Nation­al Park Author­ity 14 The Square Grant­own-on-Spey PH26 3HG

Dear Emma

APP/2020/1566 Land To The North And North East Of Tom­idhu, Crath­ie, Bal­later, Aber­deen­shire Erec­tion of 18 Hut, 4 Com­post Toi­lets and Asso­ci­ated Access, Car Park­ing and Landscaping

I am writ­ing on behalf of But­ter­fly Con­ser­va­tion Scot­land to high­light our con­cerns over the above applic­a­tion due to the pres­ence of an import­ant assemblage of rare and threatened Lepidoptera.

The north-west­ern half of the devel­op­ment site lies with­in the Crath­ie Wood SSSI (Site of Spe­cial Sci­entif­ic Interest). The SSSI is des­ig­nated in part due to the import­ance of its inver­teb­rate assemblage which is iden­ti­fied as a Noti­fi­able Fea­ture. It is there­fore import­ant that the pro­pos­als do not com­prom­ise the object­ives of the SSSI designation.

We have recently reviewed our con­ser­va­tion pri­or­it­ies in Scot­land with the pro­duc­tion of our Scot­tish Con­ser­va­tion Strategy (SCS) which iden­ti­fies the country’s most threatened spe­cies and thus those most in need of con­ser­va­tion action. The pro­posed devel­op­ment falls with­in But­ter­fly Con­ser­va­tion Scotland’s Deeside Pri­or­ity Land­scape one of eight­een land­scapes across Scot­land that identi­fy the country’s key areas for threatened Lepid­op­tera. The bound­ar­ies of these Pri­or­ity Land­scapes are drawn up to encom­pass net­works of sites sup­port­ing one or more linked colon­ies, or sub-pop­u­la­tions, of threatened species.

It is vital that sub-pop­u­la­tions are linked, act­ing as step­ping stones across the land­scape, thus pre­vent­ing genet­ic isol­a­tion and greatly redu­cing the pos­sib­il­ity loc­al extinc­tion. If any of the sub- pop­u­la­tion loc­a­tions are lost, then the oth­ers become more isol­ated and the over­all set of sub- pop­u­la­tions becomes frag­men­ted, with the risk that even­tu­ally even lar­ger sub-pop­u­la­tions may become extinct and the whole pop­u­la­tion may fail. This high­lights that sub-pop­u­la­tions both on and off the SSSI are of equal significance.

The fol­low­ing SCS spe­cies have been iden­ti­fied as occur­ring on the site or close by with­in the SSSI and are there­fore poten­tially det­ri­ment­ally impacted by the pro­pos­al. • Dark Bordered Beauty — Epi­one ves­per­tar­ia (HA) • North­ern Brown Argus — Aricia artax­er­xes (HB) • Pearl-bordered Fritil­lary — Bol­or­ia euphro­syne (HA) • Cous­in Ger­man — Pro­tolampra sobrina (M) • Exaere­tia cini­fl­on­ella (HB) • Dicho­mer­is juni­per­ella (HB) HA = High Pri­or­ity Spe­cies Action urgent across all occu­pied landscapes/​sites HB = High Pri­or­ity Spe­cies Action neces­sary in some occu­pied landscapes/​sites M = Medi­um Pri­or­ity Spe­cies Spe­cies in bold are also Scot­tish Biod­iversity List Species

In addi­tion, the fol­low­ing scarce spe­cies, that have no form­al des­ig­na­tion, also occur • Cydia con­ifer­ana • Bryotropha gal­ban­ella • Roesler­stam­mia erxle­bella • Phiar­is metallicana

The site’s two most import­ant spe­cies are Dark Bordered Beauty and North­ern Brown Argus. There are only three pop­u­la­tions of Dark Bordered Beauty in Scot­land, all with­in the Cairngorms, and one in Eng­land. In Scot­land the moth is solely asso­ci­ated with aspen, the lar­vae feed­ing on their short suck­ers. The moth was first found on the site in 2013 and annu­al sur­veys have proved it still to be present this year both in the east and west of the site. It is very pleas­ing, there­fore, to note that there are meas­ures in the Wood­land Man­age­ment Plan to enhance the hab­it­at for Dark Bordered Beauty, includ­ing the erec­tion of four small exclos­ures to allow the aspen suck­ers that are cur­rently being kept in check by rab­bits and sheep to get away. How­ever, it should be borne in mind that the erec­tion of exclos­ures to enhance suck­er growth will only be suc­cess­ful in the short-term and sub­sequent man­age­ment, includ­ing cyc­lic­al clear­ance and/​or erec­tion of addi­tion­al exclos­ures, will be required to ensure there is always suit­able hab­it­at for the moth. In addi­tion, a pro­por­tion of suck­ers should be allowed to mature to become the next cohort of adult trees to improve the age struc­ture of the aspen in the wood­land and be the source of future suck­ers. Sim­il­ar exclos­ures are cur­rently being used suc­cess­fully to enhance Dark Bordered Beauty hab­it­at at some of its oth­er extant sites in the Cairngorms.

North­ern Brown Argus is asso­ci­ated with Com­mon Rock­rose, its sole lar­val food­plant. It appears that the but­ter­fly was formerly more wide­spread and numer­ous at the site, espe­cially in the late 1970’s, and has sub­sequently declined. The exact reas­ons for this are unclear but it prob­ably cor­res­ponds with a reduc­tion in Rock­rose and where it con­tin­ues to per­sists the plants are prob­ably too short, as the but­ter­fly pref­er­en­tially selects plants grow­ing in a medi­um to tall sward to lay their eggs. The reduc­tion in Rock­rose height and occur­rence may be due to excess­ive graz­ing by deer, sheep and or rab­bits as well as tramp­ling and com­pac­tion by ped­es­tri­ans and vehicles.

The oth­er lis­ted lepid­op­tera are pre­dom­in­antly wood­land or wood­land edge spe­cies mostly reli­ant on birch, juni­per and blae­berry. It is there­fore imper­at­ive that the cur­rent wood­land remains intact and felling, e.g. for fire­wood etc, prevented.

Giv­en the import­ance of the site and spe­cies BCS is will­ing to work closely with the landown­er, and/​or their agent(s), and oth­ers to provide the neces­sary expert­ise to ensure that the pro­pos­als min­im­ise the impact on the pri­or­ity spe­cies and ideally, par­tic­u­larly in the case of Dark Bordered Beauty and North­ern Brown Argus, grasp the oppor­tun­ity to enhance their hab­it­at and thus populations.

Please do not hes­it­ate to con­tact me if you require any fur­ther inform­a­tion. Yours sincerely

Tom Prescott Seni­or Con­ser­va­tion Officer But­ter­fly Con­ser­va­tion Scotland