Item6Appendix4Objections20190247DET

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 6 Appendix 4 13/12/2019

AGENDA ITEM 6

APPENDIX 4

2019/0347/DET

REP­RES­ENT­A­TIONS — OBJECTION

Com­ments for Plan­ning Applic­a­tion 2019/0347/DET

Applic­a­tion Sum­mary Applic­a­tion Num­ber: 2019/0347/DET Address: Bal­avil House Kin­gussie High­land PH21 1LU Pro­pos­al: Form­a­tion of forest/​woodland access track (in ret­ro­spect) Case Officer: Edward Swales

Cus­tom­er Details Name: Mr Nick Kempe Address: 23 Queen Square Glasgow

Com­ment Details Com­menter Type: Mem­ber of Pub­lic Stance: Cus­tom­er objects to the Plan­ning Applic­a­tion Com­ment Reas­ons: Comment:My objec­tion is not to the prin­ciple of a track in this loc­a­tion to assist with forest oper­a­tions but to one ele­ment of the design/​route and the spur off the main track to access pheas­ant feed­ers. A short sec­tion of the track is too steep and con­trary to SNH’s best prac­tice guid­ance. It will erode. The eco­logy report is right to recom­mend that no fine mater­i­al be used to sur­face this sec­tion of the track as it will be quickly washed away but the aggreg­ate below this will be sub­ject to con­tin­ued erosion­al pres­sure. As this sec­tion of track is short, rerout­ing it along a gentler but longer line would prob­ably have a much great­er impact, but ways need to be found to pre­vent it erod­ing. These could include water bars and a dif­fer­ent type of sur­face, eg cobbles rather than com­pacted aggreg­ate. The spur off the track to access pheas­ant feed­ers which has already been con­struc­ted should be restored. The CNPA should not be encouraging/​facilitating estates to release ali­en game spe­cies. I accept that the CNPA does not con­trol the release of game birds at the cur­rent time but it should not be assist­ing infra­struc­ture related to this. If the estate wants to place pheas­ant feed­ers in wooded areas it could do so by the sec­tion of track which is now to be dir­ec­ted through the wood. Its very wel­come that since the applic­a­tion was sub­mit­ted CNPA staff have got the estate to agree that the line of the track which had not been con­struc­tion pri­or to this plan­ning applic­a­tion might be dir­ec­ted through the wood rather than around the top of it. That is an improve­ment on the ori­gin­al proposal.

BSCG info From:BSCG info Sent:Mon, 2 Dec 2019 23:48:16 +0000 To:Planning Subject:2019 – 0347-DET Objection

Badenoch & Strath­spey Con­ser­va­tion Group Fiod­hag, Nethy­bridge, Inverness-shire PH25 3DJ

Scot­tish Char­ity No. SC003846 Email Web­site bscg​.org​.uk/

2 Decem­ber 2019

Dear Ed Swales 2019/0347/DET | Form­a­tion of forest/​woodland access track (in ret­ro­spect) | Bal­avil House Kin­gussie High­land PH21 1LU

BSCG wishes to object to the above applic­a­tion. We request the oppor­tun­ity to address the plan­ning com­mit­tee when this applic­a­tion is considered.

It is dis­ap­point­ing that this is a ret­ro­spect­ive applic­a­tion and that major con­struc­tion works have already been under­taken. Bal­avil Estate engaged with the CNPA plan­ning team over a con­tro­ver­sial track to the River Dul­nain (2018/0400/DET) a year ago and it is hard to under­stand why the estate has sub­sequently made a ret­ro­spect­ive application.

Part of the pur­pose of the track is to facil­it­ate pheas­ant rear­ing for sport. Pheas­ants can have sig­ni­fic­ant eco­lo­gic­al impacts, includ­ing on slow worms, com­mon liz­ards andad­ders, all of which pheas­ants are known to pred­ate. These three spe­cies are on the Scot­tish Biod­iversity List and are UKBAP spe­cies and have the poten­tial to be present in the vicin­ity of the pro­pos­al. Pheas­ant rear­ing can also have implic­a­tions for loc­al pop­u­la­tions of oppor­tun­ist­ic pred­at­ors of ground nest­ing birds such as wood­cock. There are also cumu­lat­ive impacts with oth­er devel­op­ments, that have been approved, such as the hous­ing on the former saw­mill site on Rothiemurchus and An Camas Mor. We are con­cerned that these spe­cies were not included in the eco­lo­gic­al sur­vey relat­ing to this proposal.

We are con­cerned at the impact of the pro­pos­al on wood­land on the Ancient Wood­land Invent­ory of semi nat­ur­al ori­gin. In this con­text all aspects of the wood­land hab­it­at are

import­ant and mer­it pro­tec­tion and appro­pri­ate man­age­ment, includ­ing soils,ground veget­a­tion and drain­age and hydro­logy. Some of the hab­it­ats in the vicin­ity of the pro­pos­al are of par­tic­u­larly out­stand­ing qual­ity in our view.

We are con­cerned that the spur track does not appear to have been included in the eco­lo­gic­al survey.

In the con­text of the cli­mate and eco­lo­gic­al emer­gency, the impact of pheas­ants on biod­iversity is of par­tic­u­lar concern.

We are con­cerned about the eco­lo­gic­al impacts of this new track. A major plank in the CNPA’s Caper­cail­lie Frame­work is the expan­sion of suit­able hab­it­at for caper­cail­lie that will enable the Scot­tish pop­u­la­tion to increase in num­bers and expand in dis­tri­bu­tion and achieve favour­able status in the future. A cru­cial aspect of the suc­cess of this is human dis­turb­ance. The new track con­nects with oth­er routes and is likely to pro­mote a range of recre­ation­al activ­it­ies and asso­ci­ated dis­turb­ance pressures.

Croft­car­noch plant­a­tion is dom­in­ated by Scots pine and provides poten­tially suit­able hab­it­at for caper­cail­lie. The com­bin­a­tion of the new track and oth­er tracks cre­ates a cir­cu­lar route all the way around Croft­car­noch plantation.

In rela­tion to caper­cail­lie and poten­tial Sched­ule 1 breed­ers, there has been no assess­ment of poten­tial impacts asso­ci­ated with increased recre­ation­al pressure.

We query the con­clu­sion that a HRA is not needed.

It is not clear wheth­er eco­lo­gic­al sur­vey work has been under­taken to cov­er the route in the updated site plan.

We are con­cerned at the land­scape impacts of the track in this excep­tion­ally scen­ic area. In addi­tion, we are con­cerned at the irre­vers­ible alter­a­tions to nat­ur­al land­forms and geomorphology.

Yours sin­cerely Gus Jones Convener