Item7Appendix3bAddendumObjections20210112DET

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 7 Appendix 3B 14/05/2021

AGENDA ITEM 7

APPENDIX 3B

2021/0112/DET

5889881 A HC 5DD9B8=”6” .. PUB­LIC COM­MENTS OBJECTIONS

Deirdre Straw

From: BSCG info info@​bscg.​org.​uk Sent: 10 May 2021 23:49 To: Stephanie Wade; Plan­ning Sub­ject: 2021/0112/DET BSCG Com­ment Cat­egor­ies: For Dee

Badenoch & Strath­spey Con­ser­va­tion Group

Fiod­hag, Nethy­bridge, Inverness-shire PH25 3DJ

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

Stephanie Wade CNPA Grant­own on Spey

10 May 2021

Dear Stephanie Wade

2021/0112/DET | Recon­fig­ur­a­tion of exist­ing car park and pro­vi­sion of infra­struc­ture for camper van overnight facil­ity | Cairngorm Moun­tain Ciste Car Park Glen­more Aviemore High­land PH22 1RB.

I am writ­ing to object to the above applic­a­tion, and BSCG would like to request the oppor­tun­ity to address the plan­ning com­mit­tee remotely when the applic­a­tion is determ­ined, which we under­stand will be on 14 May.

Impacts on Glen­more Forest

1

The Ciste car park is about 1/​2km from the south­ern edge of the east­ern part of Glen­more Forest. There is now estab­lished nat­ur­al regen­er­a­tion with self- sown trees, mostly Scots Pine, spread­ing to the south. Glen­more forest is there­fore nat­ur­ally expand­ing up the hill, by nat­ur­al regeneration.

It is import­ant to recog­nise that Glen­more is one of the most import­ant core areas for caper­cail­lie in Scotland,

is highly sig­ni­fic­ant in terms of caper­cail­lie con­ser­va­tion. this is to provide last­ing bene­fit to caper­cail­lie recre­ation­al dis­turb­ance are not too high.

If it is imper­at­ive that levels of

The crit­ic­ally low pop­u­la­tion of caper­cail­lie and their depend­ence on the forests of Strath­spey is well estab­lished, as is their sens­it­iv­ity to dis­turb­ance from people and dogs.

Caper­cail­lie have been declared effect­ively extinct at Loch Lomond and there are very ser­i­ous con­cerns over their viab­il­ity out­with the core Strath­spey meta­pop­u­la­tion. The Strath­spey forests are now vital for the future of caper­cail­lie in Scot­land and we must ensure that we do not impact the viab­il­ity of caper­cail­lie in any of the Strath­spey forests.

The CNPA Caper­cail­lie Frame­work states:

“With caper­cail­lie pop­u­la­tions at such vul­ner­able num­bers, any factors that could impact on the breed­ing suc­cess of indi­vidu­al birds could have sig­ni­fic­ant impacts for the pop­u­la­tion as a whole”.

We con­sider, there is every like­li­hood the pro­pos­al would affect breed­ing suc­cess and con­sequently the pop­u­la­tion as a whole. This area of Glen­more has long been known as key for caper­cail­lie, and this is reflec­ted in forest management.

There is a wor­ry­ing level of exist­ing recre­ation­al use The form­al­isa­tion of a 50-motorhome facil­ity at the Ciste car park, and the social media ​‘chat’ that would accom­pany this, is very likely to increase recre­ation­al dis­turb­ance to the sur­round­ing area by people and their pets, from walk­ing, run­ning and bik­ing. the Glen­more vis­it­or centre and café, links with many oth­er routes in Glen­more, and thereby offers a vari­ety of attract­ive cir­cu­lar round trips of a range of distances.

The CNPA’s Caper­cail­lie Frame­work states:

“The Strath­spey caper­cail­lie pop­u­la­tion is cru­cial to the long-term sur­viv­al of the spe­cies in the UK. This places a sig­ni­fic­ant respons­ib­il­ity on CNPA and our part­ners to take a stra­tegic approach to man­age­ment for this pop­u­la­tion and work at a land­scape scale if we are to save this spe­cies”. 2

There is a power­ful body of sci­entif­ic evid­ence that caper­cail­lie are sig­ni­fic­antly sens­it­ive to disturbance.

This is acknow­ledged in the CNPA’s Caper­cail­lie Frame­work which states that: ​“Caper­cail­lie are sens­it­ive to dis­turb­ance and pred­a­tion at all life stages espe­cially when attend­ing leks, incub­at­ing eggs or rear­ing broods”.

Vis­it­or Man­age­ment Plan.

The VMP makes no ref­er­ence to people walk­ing or bik­ing down the Allt na Ciste path into the forest.

Envir­on­ment­al Impact Assessment

The EIA provides no evid­ence or even a ration­al jus­ti­fic­a­tion for the con­clu­sion reached of ​“no sig­ni­fic­ant effects are anti­cip­ated”. This asser­tion does not fol­low a pre­cau­tion­ary approach and can be con­sidered extremely reckless.

We note that the ​“essen­tial actions” of the Cairngorms Caper­cail­lie Pro­ject include ​“Improv­ing and cre­at­ing more hab­it­at for capercailie…in key areas.” There appears to be a fail­ure to prop­erly recog­nise that the area set to be impacted by the pro­pos­al is a cru­cial key area of unpar­alleled import­ance in Scot­land to caper­cail­lie conservation.

Hab­it­at Reg­u­la­tions Assessment

Glen­more is of nation­al import­ance for caper­cail­lie. It is the respons­ib­il­ity of the CNPA to ensure there is no adverse affect on the viab­il­ity of caper­cail­lie There is reas­on­able sci­entif­ic doubt about the effects of the pro­pos­al We do not accept that motorhome users will not alter For example, people have mul­tiple reas­ons to seek new routes, such as to avoid paths being used by oth­er dogs, or slower recre­ation­al users.

Addi­tion­al use would increase dis­turb­ance. It is estab­lished that more use by people adds to dis­turb­ance and the dis­tance of avoid­ance by caper­cail­lie. This effect­ively dimin­ishes and frag­ments habitat.

We do not con­sider that the pro­posed mit­ig­a­tion is adequate to pre­vent addi­tion­al adverse dis­turb­ance to capercaillie.

Yours sin­cerely

Gus Jones Con­vener 3

4