Item6appendix3ObjectionsGlenRoadTrack20220421DET

Cairngorms Item 6 Appendix 3 28 April 2023 Nation­al Park Author­ity Ügh­dar­ras Pàirc Nàiseanta a’ Mhon­aidh Ruaidh

Agenda item 6

Appendix 3

2022/0421/DET

Rep­res­ent­a­tions Objections

Com­ments for Plan­ning Applic­a­tion 2022/0421/DET

Applic­a­tion Sum­mary Applic­a­tion Num­ber: 2022/0421/DET Address: Land 760M NW Of Rise­ley Cot­tage Glen Road New­ton­more Pro­pos­al: Con­struc­tion of 4.83km forestry track, form­a­tion of passing places, renew­al of bridge Case Officer: Edward Swales

Cus­tom­er Details Name: Address: 

Com­ment Details Com­menter Type: Mem­ber of Pub­lic Stance: Cus­tom­er objects to the Plan­ning Applic­a­tion Com­ment Reas­ons: Comment:I am writ­ing on behalf of the North East Moun­tain Trust (NEMT). NEMT rep­res­ents the interests of hill-goers and those who enjoy vis­it­ing wild land. NEMT mem­ber­ship, com­pris­ing twelve hill­walk­ing and climb­ing clubs along with indi­vidu­al mem­bers, totals around 1000 people. NEMT is pleased that the Nation­al Park has called this applic­a­tion in as it needs to be tested against the Park’s hill tracks policy. This applic­a­tion is the resub­mis­sion of a pre­vi­ous applic­a­tion with minor changes to the line of the track and fuller inform­a­tion about poten­tial tree plant­ing in the area. NEMT objects to the sec­tion of track which heads north from the Glen Ban­chor pub­lic road and crosses open moor­land. NEMT’s over­rid­ing con­cern is the ques­tion of the need for the track and its pur­pose along with the neg­at­ive land­scape impact. The stated pur­pose of this track is to remove tim­ber from four rel­at­ively small plant­a­tions affect by wind blow. The applic­a­tion is based on the like­li­hood that nor­mal tim­ber lor­ries will be unable to nego­ti­ate the pub­lic road down the glen. The applic­a­tion does not say why small vehicles could not be used to remove the rel­at­ive low volumes of tim­ber involved, per­haps with some tem­por­ary alter­a­tions to Glen­ban­chor Road, as sug­ges­ted for the upper sec­tion of the road. NEMT under­stands that Wild­land Ltd is using small vehicles on nar­row tracks to remove cut tim­ber else­where in the Cairngorms Nation­al Park. NEMT raised this in respect of the pre­vi­ous applic­a­tion and it is not addressed in the cur­rent applic­a­tion. NEMT strongly sup­ports the pro­posed increase in wood­land cov­er on both estates; how­ever the areas iden­ti­fied are adja­cent to the pub­lic road and plant­ing work should not need large vehicles. NEMT is also con­cerned about the fol­low­ing: It is unclear why the pro­posed track crosses the Strone track and goes fur­ther east when pre­sum­ably the Strone track would be used for extract­ing the tim­ber. The Design State­ment says that the pro­posed new track does not provide access to shoot­ing butts but the Ord­nance Sur­vey map marks butts just north of one sec­tion of it. This track will have a very sig­ni­fic­ant det­ri­ment­al impact in land­scape terms where it traverses

open moor­land. The sheer width of the track (log­ging width), the numer­ous unsightly passing places and fact that, at its south­ern end, it will run beside the exist­ing ​‘dog track’, thus cre­at­ing two par­al­lel roads, com­bine to cre­ate a very neg­at­ive visu­al impact. The design state­ment says that the new track will improve community/​public access and gen­er­al amen­ity. How­ever this is not the case as the area is well served by paths and tracks already. It is not clear what ​‘gen­er­al amen­ity’ means. It is stated that one exist­ing bor­row pit will be used as neces­sary. It appears likely con­sid­er­able amount of mater­i­al will need to be taken from this and there is no inform­a­tion in the applic­a­tion about where this is and how it will be rein­stated. The CNPA’s hill tracks policy con­tains a pre­sump­tion against new tracks in open moor­land (much of this track is new) except where there are no altern­at­ives for car­ry­ing out essen­tial estate man­age­ment tasks. NEMT thinks that the remov­al of the tim­ber from the exist­ing smallish stands and the pro­posed new plant­ing can be car­ried out without this track and so it should not be approved. In addi­tion the policy sig­nals that, when there are no altern­at­ives to a new track, there is an expect­a­tion of com­pens­at­ory meas­ures such as the remov­al of tracks else­where. No com­pens­at­ory meas­ures are pro­posed. If the Park Author­ity con­siders that, even with small vehicles, the tim­ber can­not be extrac­ted using the Glen­ba­chor Road, then NEMT sug­gests that a con­di­tion of con­sent be the com­plete remov­al of the new sec­tion of track, along with rein­state­ment of the ground, once tim­ber extrac­tion is com­plete. Cre­ation of the new plant­a­tions is very unlikely to require the pro­posed track.

Com­ments for Plan­ning Applic­a­tion 2022/0421/DET

Applic­a­tion Sum­mary Applic­a­tion Num­ber: 2022/0421/DET Address: Land 760M NW Of Rise­ley Cot­tage Glen Road New­ton­more Pro­pos­al: Con­struc­tion of 4.83km forestry track, form­a­tion of passing places, renew­al of bridge Case Officer: Edward Swales

Cus­tom­er Details Name: Address: 

Com­ment Details Com­menter Type: Mem­ber of Pub­lic Stance: Cus­tom­er objects to the Plan­ning Applic­a­tion Com­ment Reas­ons: Comment:I wish to register my objec­tion to this plan­ning pro­pos­al. This road will cre­ate an enorm­ous, ugly scar and will enable the driv­ing of mul­tiple, pol­lut­ing, large SUVs and ATVs over cur­rently rel­at­ively unspoiled land. It is appar­ent to me that the real reas­on for the estate wish­ing to build this road is not primar­ily for tim­ber extrac­tion, but to facil­it­ate estate man­age­ment for intens­ive grouse, part­ridge and pheas­ant shoot­ing. It will also be used for the estate own­er and his guests to drive over to Glen Ban­chor without driv­ing through Kin­gussie and New­ton­more. The size and scope of this plan shows it is clearly a road which will be con­struc­ted in open moor­land, and not a forest track. The exist­ing pub­lic roads com­bined with the already extens­ive net­work of tracks on the estate affords suf­fi­cient access to estate staff to get from Pit­main to Glen Ban­chor and per­form estate man­age­ment work. Even if a new track is deemed to be required for tim­ber extrac­tion, it should be on the con­di­tion that it is only for use until the tim­ber extraction/​woodland man­age­ment pro­ject is com­pleted. Once this is done, with­in a spe­cified time-lim­ited peri­od, the land should then be restored to it’s ori­gin­al con­di­tion. How­ever, even for this use it is hard to jus­ti­fy as the exist­ing pub­lic road could be used if atten­tion was paid to modi­fy­ing the way the tim­ber extrac­tion is man­aged. Smal­ler tim­ber lor­ries could nego­ti­ate the bends in Glen Road and the extra cost to the estate of using smal­ler vehicles would be minor com­pared to the costs of con­struct­ing a new 4.83 km road. There is no doubt that vil­la­gers in New­ton­more would be adversely impacted by the pas­sage of mul­tiple lor­ries but this would be for a lim­ited time, and, speak­ing as one of those impacted, I would prefer that tem­por­ary dis­rup­tion along the exist­ing Glen Road to a per­man­ent dis­fig­ur­ing of the open moor­land and the dis­turb­ance to wader breed­ing habitat.

Com­ments for Plan­ning Applic­a­tion 2022/0421/DET

Applic­a­tion Sum­mary Applic­a­tion Num­ber: 2022/0421/DET Address: Land 760M NW Of Rise­ley Cot­tage Glen Road New­ton­more Pro­pos­al: Con­struc­tion of 4.83km forestry track, form­a­tion of passing places, renew­al of bridge Case Officer: Edward Swales

Cus­tom­er Details Com­ment Details Com­menter Type: Mem­ber of Pub­lic Stance: Cus­tom­er objects to the Plan­ning Applic­a­tion Com­ment Reas­ons: Comment:I wish to object to this applic­a­tion for the reas­ons I set out in a blog post https://​park​swatch​scot​land​.co​.uk/​2​0​2​2​/​1​2​/​2​1​/​h​i​l​l​-​r​o​a​d​s​-​a​n​d​-​s​p​o​r​t​i​n​g​-​e​s​t​a​t​e​s​-​t​h​e​-​g​l​e​n​-​b​a​n​chor- pit­main-forestry-bypass-is-back/ which are, in sum­mary: 1) There is no jus­ti­fic­a­tion for this road. Much of the tim­ber it is claimed needs to be extrac­ted is value­less. The swept ana­lys­is, while identi­fy­ing poten­tial safety con­cerns about large lor­ries using the pub­lic road does not explain why these could not be addressed or why small vehicles could not be used. 2) The land­scape impact is sig­ni­fic­ant and the cre­ation of a road round the back of New­ton­more con­trary to the CNPA’s policy pre­sump­tion against new roads on moor­land. Among the land­scape impacts are: there would now be TWO roads by the esker, the dog track and the pro­posed road; the road will require sig­ni­fic­ant cut­tings which will be highly vis­ible; the width of the pro­posed road cor­ridor is double the width of the road itself and that should be used to assess the land­scape impact; the junc­tions etc are far wider than neces­sary adding to the land­scape impact. 3) The doc­u­ment­a­tion in the plan­ning applic­a­tion is intern­ally incon­sist­ent with a dif­fer­ent line for the road con­tained in the Wood­land Man­age­ment Plan which is not totally out of date and does not reflect the wood­land cre­ation in Glen Ban­chor 4) The road will release sig­ni­fic­ant amounts of car­bon in its con­struc­tion not least because part of it is con­struc­ted over/​through peat 5) Why the CNPA would even con­sider allow­ing Pit­main Estate to re-sub­mit a plan­ning applic­a­tion for a new road when they have so far failed to restore the dam­age cre­ated by the Gyn­ack over­flow is unclear

To: Plan­ning Officer, Cairngorms Nation­al Park From 8 Jan 2023 Plan­ning applic­a­tion 2022/0421/DET Con­struc­tion of 4.83km forestry track, form­a­tion of passing places, renew­al of bridge Land 760M NW of Rise­ley Cot­tage, Glen Road, New­ton­more I wish to object to the above plan­ning applic­a­tion on the same grounds that I objec­ted to the ori­gin­al plan­ning applic­a­tion for this pro­posed devel­op­ment. My objec­tion let­ter of 15 Feb 2022 is provided below as annex 1. I now wish to make the fol­low­ing addi­tion­al points:

1. The ori­gin­al pro­pos­al has not been mod­i­fied sig­ni­fic­antly to dimin­ish in any way the grounds for my objec­tion in Feb 2022 and these objec­tions remain the basis for my objec­tions to the cur­rent plan­ning applic­a­tion. Although the align­ment of the road is lower across the hill­side it would have the same massive impact on an area of rel­at­ively unspoilt wild land char­ac­ter, both in terms of neg­at­ive effects on the land­scape and degrad­ing amen­ity value. The visu­al rep­res­ent­a­tions using com­puter sim­u­la­tion in the new plan­ning applic­a­tion are of neg­li­gible value but their replace­ment with actu­al pho­to­graphs, with the pro­posed road align­ment super­im­posed, would make no dif­fer­ence – any site inspec­tion would demon­strate that this pro­posed devel­op­ment would be highly intrus­ive in this type of land­scape, whatever align­ment was chosen.

2. The applic­ant has presen­ted no new evid­ence to sug­gest that there are over­rid­ing reas­ons, from an estate man­age­ment per­spect­ive, to over­ride the exist­ing CNPA policies which pre­sume against the con­struc­tion of new hill roads or any oth­er CNPA policies designed to pro­tect land­scape value and to mit­ig­ate impacts relat­ing to cli­mate change and biod­iversity pro­tec­tion needs.

3. The last 11 months have simply rein­forced the points that I made in Feb 2022 that, from a tim­ber extrac­tion per­spect­ive, trans­port­a­tion of such tim­ber down Glen Rd is per­fectly feas­ible using appro­pri­ately sized vehicles, with good turn­ing capa­city, plus minor modi­fic­a­tions such as pos­sible verge strength­en­ing in a few loc­a­tions. Any issues relat­ing to wires cross­ing the road, as noted in the latest plan­ning applic­a­tion, can be eas­ily dealt with by ensur­ing that load heights are not too great. As I have observed on occa­sions large vehicles of con­sid­er­able height use Glen Road, includ­ing the nor­mal Coun­cil refuse vehicles, so I can­not see why the applic­ant appears unable to source appro­pri­ate forestry vehicles if indeed there is a real inten­tion to extract tim­ber from exist­ing plant­a­tions in Glen Banchor.
4. I would also like to draw your atten­tion to this film which doc­u­ments recent riv­er­ine con­ser­va­tion work along the River Calder in Glen Ban­chor which involved the trans­port­a­tion of mature trees to the river bank and place­ment of root plates and sec­tions of trunk into the river: Ren­at­ur­al­ising the Calder — You­Tube. Note the com­ments made in this film at 1.2 min by Duncan Fer­guson, Oper­a­tions Man­ager for the Spey Fish­er­ies Board who describes these trees as com­ing from ​“plant­a­tions that are worth­less and are com­ing down any­way”. This rein­forces the view that the exist­ing forest plant­a­tions in Glen Ban­chor are of lim­ited com­mer­cial value whose extrac­tion on tim­ber vehicles would yield less fin­an­cial bene­fit than the costs of con­struct­ing this pro­posed hill road. Instead the main value of the plant­a­tions is prob­ably their reten­tion as winter feed and shel­ter areas for the large red deer pop­u­la­tions in this area, along with use of some of the tim­ber for loc­al fire­wood needs, fence posts etc.
5. The obvi­ous con­clu­sion remains — the primary pur­pose of this pro­posed hill road is for the trans­port­a­tion of shoot­ing cli­ents vis­it­ing the Glen Ban­chor and Pit­main estates and for estate man­age­ment pur­poses. All these needs can be met by using the exist­ing hill tracks plus the pub­lic road net­work in and around

New­ton­more. Whilst it might be a little more con­veni­ent for cli­ents and estate staff to drive back and forth along the pro­posed new hill road this is in no way a good enough reas­on to over­ride exist­ing CNPA policies relat­ing to envir­on­ment­al pro­tec­tion and enjoy­ment and to set a pre­ced­ent that would com­prom­ise CNPA action on hill tracks in the rest of the nation­al park. If this plan­ning applic­a­tion pro­ceeds fur­ther to plan­ning com­mit­tee con­sid­er­a­tion I would like to address the com­mit­tee in sup­port of my objec­tions. Many thanks Annex 1 Plan­ning objec­tion sub­mit­ted in Feb 2022 To: Plan­ning Officer, Cairngorms Nation­al Park 15 Feb 2022 Plan­ning applic­a­tion 2022/0010/DET. Con­struc­tion of 4.83 Km of forestry track; upgrade of exist­ing sheep dog tri­al track; and alter­a­tions to Glen­ban­chor Road, New­ton­more I wish to object to the above plan­ning applic­a­tion on the grounds that the pro­pos­als are con­trary to policies con­tained with­in the Cairngorms Nation­al Park’s Loc­al Devel­op­ment Plan. My spe­cif­ic objec­tions are as follows:

The pro­posed devel­op­ment is inap­pro­pri­ate for an area with such high land­scape and nat­ur­al her­it­age val­ues. These are import­ant for the res­id­ents of Badenoch and Strath­spey, par­tic­u­larly those liv­ing in or near the set­tle­ments of Kin­gussie and New­ton­more and for per­sons vis­it­ing from fur­ther afield. Such val­ues under­pin the exper­i­ence of all who enjoy out­door recre­ation, study and exer­cise in wild and rel­at­ively nat­ur­al places. The land­scape char­ac­ter and spe­cial qual­it­ies of this tract of land on the Pit­main and Glen Ban­chor estates would be degraded by the pro­posed hill road con­struc­tion, impact­ing as it would on both land­scape value and pub­lic enjoy­ment. The pro­posed devel­op­ment is there­fore con­trary to Policy 5.1, Spe­cial Land­scape Qual­it­ies which states: ​“There will be a pre­sump­tion against any devel­op­ment that does not con­serve or enhance the land­scape char­ac­ter and spe­cial land­scape qual­it­ies of the Cairngorms Nation­al Park includ­ing wild­ness and the set­ting of the pro­posed devel­op­ment”. The pro­posed new road would be a per­man­ent fea­ture and have a neg­at­ive impact on the land­scape. This can­not be jus­ti­fied giv­en that there is an obvi­ous altern­at­ive option for extract­ing tim­ber from Glen Ban­chor, using all of Glen Road, along with minor modi­fic­a­tion of that road as well as the use of appro­pri­ate vehicles to trans­port the tim­ber. This would cause only tem­por­ary incon­veni­ence to res­id­ents and oth­er users of Glen Rd. The pro­posed devel­op­ment is also con­trary to Policy 5.2, Private roads and ways, which states: ​“There will be a pre­sump­tion against new private ways in open moor­land areas”. The pro­posed new hill road is entirely loc­ated on open moor­land and does not meet any of the three con­di­tions that could over­ride this policy require­ment: The pro­posed road is not ​“essen­tial” for land man­age­ment pur­poses; it would do noth­ing to ​“con­serve and enhance the land­scape char­ac­ter and spe­cial land­scape qual­it­ies of the Nation­al Park includ­ing wild­ness”; it is not part of a ​“pro­gramme of works includ­ing the remov­al of oth­er exist­ing private roads and ways to deliv­er a net bene­fit for the spe­cial land­scape qual­it­ies of the Nation­al Park includ­ing wild­ness”. The pro­posed devel­op­ment would involve no remov­al of any oth­er road or track. The pro­posed devel­op­ment is also con­trary to Policy 10.7, Car­bon sinks and stores, which states: ​“Devel­op­ment affect­ing car­bon sinks, par­tic­u­larly soil and peat, should: a) pro­tect all soil and peat from com­mer­cial extrac­tion; and

b) min­im­ise dis­turb­ance of soils, peat and any asso­ci­ated veget­a­tion; and c) include an assess­ment of the likely effects of devel­op­ment on green­house gas emis­sions and identi­fy appro­pri­ate mit­ig­a­tion meas­ures to min­im­ise the release of stored car­bon as a res­ult of dis­turb­ance”. The applic­ant appears to have made no attempt to address this policy require­ment and clearly fails to com­ply with points b) and c). The pro­posed con­struc­tion of 4.83 kms of new road across moor­land is not in any way ​“min­im­ising” dis­turb­ance to veget­a­tion, soils and peat, while green­house gas emis­sions would also far exceed the altern­at­ive use of Glen Rd, when minor amend­ments to the road peri­phery, com­bined with bet­ter vehicle trans­port, is a prac­tic­al altern­at­ive. Addi­tion­al Points: The pro­posed devel­op­ment is in an area of undu­lat­ing moor­land which lies above New­ton­more and sep­ar­ates the vil­lage from the steep­er slopes of the Mon­adh­liath moun­tain range. It is close to the peri­phery of New­ton­more but is visu­ally isol­ated from this vil­lage and nearby Kin­gussie through being at a high­er elev­a­tion. This con­trib­utes sig­ni­fic­antly to the feel­ings of wild­ness and remote­ness when tra­vers­ing the area. These val­ues are rein­forced by the absence of motor­ised vehicles, except occa­sion­ally on exist­ing tracks, and the lack of any traffic noise from the vil­lages or pub­lic road net­work. The sur­round­ing veget­a­tion is mainly an extens­ive com­plex of bog, moor­land and nat­ive birch­wood. These semi nat­ur­al hab­it­ats cov­er moraines, ridges, lochans and asso­ci­ated land­forms which have exis­ted here for thou­sands of years, since the last Ice Age. Bey­ond the moor are the crags, cliffs, and high mont­ane slopes of the Mon­ah­liath. All provide a strong con­nec­tion to the nat­ur­al land­scape along­side wild­life rich hab­it­ats. These exper­i­ences are avail­able to all sec­tors of the pop­u­la­tion, of all ages, and includ­ing those with lim­ited mobil­ity. With the exist­ing pub­lic road sys­tem close by, this wild land­scape is avail­able to every­one, from those who want to explore its inner heart to those who simply want to observe from the edge. An import­ant fea­ture of the pro­posed devel­op­ment area is a rel­at­ive lack of arti­fi­cial fea­tures asso­ci­ated with human hab­it­a­tion. There are no houses, no power­lines, masts or oth­er struc­tures either with­in or eas­ily vis­ible from the area. From with­in the area there are extens­ive views towards all points of the com­pass, from Cre­ag Dubh and fur­ther hills to the west, from Drumochter in

the south and round to the main Cairngorms mas­sif in the east and finally to the hill slopes above Kin­gussie as they merge into the main back­bone of the Mon­adh­liath to the north. The views down onto the area from nearby hill slopes illus­trate a rel­at­ively wild land­scape dis­tinct from the intens­ively farmed and settled areas close by the River Spey to the east. It is dif­fi­cult to think of any oth­er set­tle­ment in the Nation­al Park which has such a high qual­ity wild land­scape vir­tu­ally on the door­step and one which is so access­ible. This is a sig­ni­fic­ant con­trib­ut­ing factor to the high levels of pub­lic use of this area, par­tic­u­larly from Glen Road and the Strone Road above New­ton­more and from the trail net­work adja­cent to Kin­gussie. Equally import­ant is pub­lic use of the Wild­cat Trail which encircles New­ton­more and is a major tour­ism facil­ity. The north­ern side of this trail looks across the wild, undu­lat­ing moor­land towards the pro­posed new road, with extens­ive views to the moun­tains bey­ond. A vast net­work of anim­al tracks, cre­ated by sheep and deer, tra­verses the pro­posed devel­op­ment area, provid­ing ample oppor­tun­ity for those who want to explore off the main trails with­in the moor­land, or to ascend to the high­er slopes. With­in the moor­land the inform­al trails fol­low the main gravel ter­races, up and around the moraines and along the ridges (eskers), giv­ing very attract­ive views over the sur­round­ing ter­rain. In winter, with suf­fi­cient alti­tude to hold snow, there are usu­ally good ski tour­ing oppor­tun­it­ies across the whole of the moor­land area, includ­ing the extens­ive boggy ground, if this is frozen. A new road in this loc­a­tion would dimin­ish the qual­ity of these views and activ­it­ies, in the near and far dis­tance. Some deer and stock fences cross the area, primar­ily asso­ci­ated with croft­ing oper­a­tions, along with some rem­nants of ancient inhab­it­a­tion, along with a num­ber of exist­ing vehicu­lar tracks that tra­verse the area, mostly going from high to low ground. These fea­tures provide an his­tor­ic­al and cul­tur­al back­ground to the tra­di­tion­al croft­ing enter­prises and man­age­ment of the hill ground for the shoot­ing of deer and grouse. The exist­ing tracks accom­mod­ate small vehicles with the over­all impact con­sid­er­ably less than that asso­ci­ated with the large vehicles and wide roads com­monly used in many mod­ern day, indus­tri­al scale forestry oper­a­tions. The exist­ing forestry plant­a­tions are all out­with the moor­land area which the pro­posed new road would cross. Those plant­a­tions to the west of the pro­posed devel­op­ment area are relatively

isol­ated and with much of their wood­land con­tent sub­ject to wind­throw over many years and with most of the deer fen­cing now per­meable and derel­ict. The applic­ant has stressed the sig­ni­fic­ance of the pro­posed new road for forestry pur­poses, espe­cially for the extrac­tion of tim­ber and remov­al to the pub­lic high­way. Expert advice, how­ever, indic­ates that the cost of con­struc­tion of the new road would likely out­weigh the com­mer­cial value of the tim­ber extrac­ted. The exist­ing com­mer­cial value of the stand­ing tim­ber is unlikely to exceed £300,000 while the cost of the new road con­struc­tion would be expec­ted to be in the region of £400,000. It there­fore appears that the applic­ant has oth­er, unspe­cified pur­poses in mind, for want­ing to con­struct this new road. The obvi­ous con­clu­sion is there­fore that the new road is desired for oth­er estate man­age­ment pur­poses, not­ably sport shoot­ing and asso­ci­ated activ­it­ies, and might indeed be the primary object­ive for con­struct­ing such a road. While there is no obvi­ous objec­tion to the extrac­tion of tim­ber from these plant­a­tions it is unclear why Glen Rd can­not be used for this pur­pose along its whole length. I first came to reside in Glen Rd in 1980 and my house is very close to the road so I am well aware of traffic con­straints on this road. This does not pre­vent large vehicles, usu­ally asso­ci­ated with agri­cul­tur­al activ­it­ies, road main­ten­ance or loc­al deliv­ery of sup­plies, from the use of Glen Rd. Else­where it is known that smal­ler vehicles are used to extract tim­ber from sens­it­ive loc­a­tions and along nar­row roads. I can see no reas­on why a sim­il­ar approach can­not be used in regard to Glen Rd, obvi­at­ing the need to con­struct a new road across the moor. I accept some modi­fic­a­tion might be needed to Glen Rd to accom­mod­ate tem­por­ary or per­man­ent passing places along with some edge strength­en­ing. Last year I was in Glen Tilt on Atholl estate when it was being used as the film set for a major glob­al pro­duc­tion. This involved the trans­port­a­tion of huge amounts of mater­i­al by large vehicles, from mar­quees and oth­er struc­tures, board­ing and fen­cing to food stuffs and all the oth­er paraphernalia that accom­pan­ies such an oper­a­tion. The main film base was a long way up a nar­row road, com­par­able in width, bends and slope to Glen Rd. To meet this require­ment in Glen Tilt vari­ous passing places had been con­struc­ted, with rel­at­ively little impact on the land­scape. If such an arrange­ment can be made

in the Perth and Kinross sec­tion of the Nation­al Park, it should cer­tainly be pos­sible to facil­it­ate tim­ber extrac­tion in the High­land Coun­cil part of the Park with Glen Rd used as the obvi­ous extrac­tion route from Glen Ban­chor. The applic­ant does not appear to have con­sidered the use of Glen Rd, along its full length, with tim­ber extrac­tion vehicles appro­pri­ate to small roads in the High­lands. The use of wag­on plus drag com­bin­a­tion vehicles (ie a short lorry with small trail­er), along with reduced tyre pres­sures, con­trolled from the cab, is stand­ard prac­tice else­where in sens­it­ive loc­a­tions. This extrac­tion meth­od, plus minor adjust­ments to the road peri­phery, needs to be explored fur­ther if sig­ni­fic­ant tim­ber extrac­tion is to be under­taken in Glen Ban­chor. Glen Ban­chor and Pit­main estates were recently amal­gam­ated under a single own­er­ship. I do not recall any of the pre­vi­ous own­ers ever sug­gest­ing that a new road across the moor would be required to extract tim­ber from any of the long stand­ing plant­a­tions on these estates. It seems to have been accep­ted that any tim­ber extrac­tion would be down the exist­ing tar­mac roads which access these estates from Kin­gussie and New­ton­more. But single own­er­ship means that the employ­ees of both estates now work with­in the same man­age­ment unit. It might be con­veni­ent for these employ­ees to be able to drive across the moor from one estate to anoth­er, but this is not a neces­sity, giv­en the exist­ing pub­lic road con­nec­tion between the two vil­lages. Employ­ees have lived in both New­ton­more and Kin­gussie for many years and appear to have had no dif­fi­culty in car­ry­ing out their man­age­ment activ­it­ies in the moor and moun­tain areas by using the exist­ing pub­lic road net­work plus exist­ing hill track net­work. I accept, how­ever, from the per­spect­ive of guests par­ti­cip­at­ing in shoot­ing activ­it­ies on the single own­er­ship of Pitmain/​Glen Ban­chor estates, it might well be con­veni­ent if they could drive them­selves, or be trans­por­ted along, a new road across the moor which con­nec­ted the two estates. Such con­veni­ence for estate guests is not a suf­fi­ciently good reas­on to over­ride the land­scape policies of the Nation­al Park and cer­tainly does not rep­res­ent, in any way, a nation­al interest that should take pre­ced­ence over CNPA policies. Finally, I wish to com­ment on future forestry policy. The applic­ant is very vague in stat­ing any inten­tions regard­ing forestry that might be linked to this

new road applic­a­tion. It is, how­ever, very unlikely that future forestry devel­op­ments are likely to lead to the type of tim­ber extrac­tion dif­fi­culties that are of cur­rent con­cern. Indeed there is pos­sibly a need to ques­tion wheth­er any tim­ber extrac­tion should take place from the exist­ing plant­a­tions. These exist­ing stands of mature wood­land provide import­ant areas of shel­ter and browse, espe­cially in winter, for the large herds of red deer which roam this part of the Mon­adh­liaths. These refuges have become increas­ingly sig­ni­fic­ant in recent years as more and more of the lower land has been deer fenced to pre­vent deer enter­ing croft land, houses and gar­dens and new forestry plant­a­tions. Much of the wood­land in the exist­ing plant­a­tions is wind blown and it may be worth­while to leave the remainder to over mature and devel­op a nat­ur­al pat­tern of death and decay, depend­ent on cli­mat­ic and soil con­di­tions. Such an out­come could be bene­fi­cial to the over­all rela­tion­ship between deer and trees in this area, espe­cially if the old plant­a­tions are care­fully integ­rated with new wood­land estab­lish­ment through plant­ing or nat­ur­al regen­er­a­tion. Recent forestry plant­ing along the River Calder in Glen Ban­chor has not required any change to the exist­ing road/​track net­work and, as this is pro­moted as a con­ser­va­tion pro­ject to restore riv­er­ine hab­it­ats, it is not expec­ted that this will provide a resource for future tim­ber extrac­tion. Else­where on the moor and mont­ane ground on these estates future forestry policy is much more likely to be dir­ec­ted towards eco­lo­gic­al res­tor­a­tion for cli­mate change mit­ig­a­tion, biod­iversity recov­ery and to min­im­ise down­stream flood­ing. This means that future wood­land estab­lished in these parts of these estates is expec­ted to pro­duce per­man­ent tree or shrub cov­er, with tim­ber extrac­tion a minor ele­ment. Plant­ing to meet tim­ber pro­duc­tion object­ives, both loc­ally and nation­ally, is likely to be focussed on land else­where where grow­ing con­di­tions and extrac­tion tech­niques are more straight­for­ward. There is there­fore no long term need, from a forestry per­spect­ive, for the con­struc­tion of this new road across the moor.

Emma Green­lees From: Sent: 09 Janu­ary 2023 23:48 To: Plan­ning; Edward Swales Sub­ject: Com­ments 2022/0421/DET Cat­egor­ies: Emma G, Comments

CNPA Grant­own on Spey planning@​cairngorms.​co.​uk EdwardSwales@​cairngorms.​co.​uk 9^th Janu­ary 2023 Dear Ed Swales 2022/0421/DET Con­struc­tion of 4.83km forestry track, form­a­tion of passing places, renew­al of bridge at Land 760M NW of Rise­ley Cot­tage, Glen Road, New­ton­more. BSCG objects to the above applic­a­tion and we would like to request the oppor­tun­ity to address the com­mit­tee when the applic­a­tion is determ­ined. Com­pli­ance with CNPA LDP policy The pro­pos­al would have major det­ri­ment­al impacts on the land­scape char­ac­ter and spe­cial land­scape qual­it­ies of the area. The track would be wide, large and intrus­ive, with large passing places and turn­ing areas. The pro­pos­al fails to com­ply with Policy 5.1 on Land­scape. The pro­posed track would reduce the sense of wild­ness that is exper­i­enced in this area of very scen­ic, var­ied and open hill ground, with inspir­ing views to the hills. The track would not deliv­er social or eco­nom­ic bene­fits of nation­al import­ance; and the neg­at­ive impacts of the devel­op­ment have not been sig­ni­fic­antly min­im­ised or mit­ig­ated, and we can­not see any way that this could be achieved. The pro­pos­al also fails to com­ply with Policy 5.2 on Private Roads & Ways. The pre­sump­tion against new private roads and ways in open moor­land should be applied to this pro­pos­al. We do not con­sider that the pro­posed track is essen­tial for land man­age­ment. We con­sider that the forestry oper­a­tions referred to can be con­duc­ted, using dif­fer­ent meth­ods, without con­struct­ing the pro­posed new track. 1

Fur­ther, we do not con­sider the devel­op­ment has been designed to min­im­ise land­scape and envir­on­ment­al impacts; and the pro­pos­als would under­mine the land­scape char­ac­ter and spe­cial land­scape qual­it­ies of the Nation­al Park, includ­ing wild­ness, that char­ac­ter­ise this area. Impacts on Peat The route of the pro­posed track crosses through fairly lengthy stretches of wet heath (shown as M15 on the sup­port­ing NVC maps). This is a hab­it­at that is char­ac­ter­ised by peat or peaty min­er­al soil that is com­monly from around 15cms deep and usu­ally less than 2m deep. The track also crosses through short stretches of mire (shown as M18 on NVC map), that is char­ac­ter­ised by deep peat of typ­ic­ally more than 2m depth and some­times up to 10m deep or more. The dis­rup­tion of these areas of peat due to con­struc­tion of the track would inev­it­ably release car­bon; it may also cause dry­ing of sur­round­ing peat, hav­ing fur­ther longer term neg­at­ive impacts. Such con­sequences would exacer­bate cli­mate change and under­mine the pos­it­ive car­bon sequest­ra­tion that is hope­fully to be delivered through peat res­tor­a­tion pro­jects. Impacts on Biod­iversity Due to dis­turb­ance caused by track con­struc­tion and through use of the new track, the pro­posed tracks may impact on breed­ing waders, such as cur­lew (on the UK red list of birds of con­ser­va­tion con­cern, and Near Threatened in Europe and Near Threatened glob­ally); lap­wing (UK red list and Vul­ner­able in Europe and Near Threatened glob­ally); red­shank (UK amber list and Vul­ner­able in Europe); snipe (UK amber list and Vul­ner­able in Europe); oyster­catch­er (UK amber list, Vul­ner­able in Europe and Near Threatened glob­ally). We are con­cerned that there has been no assess­ment of fungi, a spe­cies rich group that is gen­er­ally poorly known in the Cairngorms and that plays vital eco­lo­gic­al roles. We are fur­ther con­cerned that there has been no assess­ment of inver­teb­rates, which are anoth­er diverse group that plays vital eco­lo­gic­al roles, includ­ing pol­lin­a­tion. Impacts on access and amen­ity The area that the track passes through is pop­u­lar for walk­ing, run­ning, cyc­ling, dog walk­ing, etc and has the advant­age of being eas­ily accessed from New­ton­more. The small scale of the pub­lic road in Glen Ban­chor and the stun­ning land­scape set­ting that it enjoys, makes this pub­lic road a very spe­cial and unique route. The pro­pos­als would have a det­ri­ment­al impact on this road, through the intro­duc­tion of large passing places and the sev­er­al new tracks that join the road or are close to it. The large and intrus­ive tracks that are pro­posed would sig­ni­fic­antly reduce the qual­ity of exper­i­ence for the pub­lic using the Glen Ban­chor area, in terms of land­scape and set­ting, as well as dam­age to the ground dur­ing track con­struc­tion, and noise and intru­sion of machinery also dur­ing track con­struc­tion. For people using the exist­ing track that runs approx­im­ately north east from the Glen­ban­chor road, the intrus­ive and unat­tract­ive new track would be run­ning approx­im­ately par­al­lel and close by. There would also be an unat­tract­ive large track and turn­ing point near this exist­ing track. The qual­ity of exper­i­ence for people using the track to the west, the Glen Road, would be impacted through widen­ing, includ­ing for passing places and turn­ing areas, as well as dur­ing con­struc­tion through noise, dis­turb­ance and use of the exist­ing track by con­struc­tion machinery. This area to the west, that is bey­ond the pub­lic tar­mac road provides an inspir­ing set­ting that should be kept as free of human arte­facts as pos­sible. Altern­at­ive options We strongly recom­mend that the present applic­a­tion should be rejec­ted. For the forestry oper­a­tions, smal­ler vehicles could be used, which are able to use exist­ing roads and tracks; and work­ing meth­ods could be put in place that obvi­ate the need for large and intrus­ive passing places. 2

Yours sin­cerely 3