Item7Appendix4AObjections20210090DETCampervanSiteNethy

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 7 Appendix 4a 25/02/2022

AGENDA ITEM 7

APPENDIX 4A

2021/0090/DET

PUB­LIC REP­RES­ENT­A­TIONS- OBJECTIONS

2021/0090/DET BSCG info From:BSCG info Sent:19 Apr 2021 23:28:08 +0100 To:Stephanie Wade; Plan­ning Subject:2021/0090/DET Comment

Badenoch & Strath­spey Con­ser­va­tion Group Fiod­hag, Nethy­bridge, Inverness-shire PH25 3DJ Tel Scot­tishChar­ity No. SC003846 Email Web­site bscg​.org​.uk/

Stephanie Wade CNPA Grant­own on Spey

19 April 2021

Dear Stephanie Wade

2021/0090/DET | Form­a­tion of camper­van site | Land 315M SW Of The Half House Nethy Bridge

BSCG wishes to object to the above applic­a­tion, and we request the oppor­tun­ity to address the plan­ning com­mit­tee, in per­son or remotely, when the applic­a­tion is determined.

Caper­cail­lie. The pro­pos­al is very close to Sliemore Wood and would increase dis­turb­ance to the wood through e.g. vehicle activ­ity and noise. This wood lies between the SPAs for caper­cail­lie of Aber­nethy Forest and Craigmore Wood and provides import­ant con­nect­ing pine wood­land of favour­able hab­it­at dir­ectly between the two SPAs. Sliemore Wood is owned and man­aged for con­ser­va­tion by the RSPB. It is well estab­lished that move­ment of caper­cail­lie between the Strath­spey wood­lands is neces­sary for the sur­viv­al of the Strath­spey meta­pop­u­la­tion. No single SPA can sup­port a viable pop­u­la­tion in isol­a­tion. The caper­cail­lie pop­u­la­tion in Scot­land remains at a crit­ic­ally low level. If they are to return to favour­able con­ser­va­tion status and have a sus­tain­able future in Scot­land, their num­bers need to increase, and their dis­tri­bu­tion expand very substantially.

At present Sliemore Wood is con­sidered to receive light use by caper­cail­lie. How­ever, by vir­tue of its good hab­it­at and con­nect­ing loc­a­tion it is in a prime pos­i­tion as a forest for caper­cail­lie to expand into. It is there­fore sig­ni­fic­ant that dis­turb­ance needs to be min­im­ised in order to avoid the situ­ation whereby suit­able hab­it­at for caper­cail­lie is rendered unused due to dis­turb­ance levels. Over 80% of the Scot­tish­pop­u­la­tion is in Strath­spey, mean­ing that the forests of Strath­spey are crit­ic­al to the sur­viv­al of caper­cail­lie in Scot­land. Caper­cail­lie are known to be very sens­it­ive to dis­turb­ance from people and their pets. The pro­pos­al would res­ult in a new source of dis­turb­ance to Sliemore Wood from the prox­im­ity of camper­vans and asso­ci­ated activ­ity and noise, includ­ing at what are com­monly quieter times of day such as in the even­ings and early morn­ings. The pro­pos­al would be likely to increase dis­turb­ance in Craigmore Wood SPA, which is a short and very attract­ive bike ride, run or walk from the pro­pos­al site. The pro­pos­al would also be likely to res­ult in increased recre­ation­al dis­turb­ance in Cul­stank Moss and School Wood. At present Cul­stank Moss receives rel­at­ively little recre­ation­al dis­turb­ance and caper do still use this wood­land. Caper­cail­lie is on the Scot­tish Biod­iversity List and the Scot­tish Biod­iversity Duty of the Nature Con­ser­va­tion (Scot­land) Act 2004 applies.

Otter have been known to use Cul­stank Moss, School Wood, the Caochan Fhuar­ain and the Allt Mor over many years, and are con­sidered to be part of the River Spey and Trib­u­tar­ies SAC pop­u­la­tion. The pro­pos­al would be likely to increase dis­turb­ance to otters in these areas, through increased recre­ation­al use by people and their pets walk­ing, run­ning etc from the pro­pos­al site. Otters in the SAC are con­sidered to be under grow­ing pres­sure, due to flood­ing issues asso­ci­ated with cli­mate change and declines in import­ant food sources such as sal­mon and eels. Use of these smal­ler water courses may have grow­ing import­ance for the Spey otter pop­u­la­tion due to cli­mate change lead­ing to more fre­quent floods when smal­ler water bod­ies may be safer for otters than the main stem of the Spey. Small water courses can have a high value for for­aging otters, and use by otters of the Caochan Fhuar­ain may be par­tic­u­larly asso­ci­ated with pres­ence of amphi­bi­ans, which coin­cideswith a time when oth­er food sources are scarce. There has been anec­dot­al evid­ence of a young cub otter by the Allt Mor near School Wood.

Badgers use the nearby wood­lands and the pro­pos­al would encroach into for­aging hab­it­at in the field.

Brown Hare are known to use the field and the pro­pos­al would encroach into their hab­it­at. In addi­tion, the pro­pos­al would be a source of increased dis­turb­ance from vehicles, people and their pets.

Land­scape. The pro­pos­al would be det­ri­ment­al to the land­scape qual­it­ies of what is a very scen­ic location.

Yours sin­cerely Gus Jones Convenor

2021/0090/DET

Megan Crook

From:Megan Crook Sent:2 Apr 2021 18:49:20 +0100 To:Planning Subject:2021/0090/DETI would like to com­ment on the plan­ning applic­a­tion for a camper­van site at Land 315m south­w­est of The Half House, Nethybridge.

As a cara­van­er and motor home own­er I am not against camper van sites. How­ever I believe they should be sens­it­ively placed. The pro­posed site is on land that until a few years ago was open farm­land. The land is out­side the vil­lage on a quiet rel­at­ively nar­row road as you leave Nethy­bridge and head out into open farm and moor­land. The road affords won­der­ful views of wild Scot­land at it’s best. The field has under­gone devel­op­ment in the last few years to accom­mod­ate a farm build­ing a large area of park­ing for industrial/​agricultural vehicles. There also exists plan­ning per­mis­sion for a farm­house. The fur­ther devel­op­ment of a camper / motor home site will do noth­ing to improve this won­der­ful location.

It will risk cre­at­ing both noise and light pol­lu­tion in an area eas­ily vis­ible from the road. The quiet nature of this road would be dis­turbed unne­ces­sar­ily by poten­tially large motor homes/​vans. When plan­ning per­mis­sion for the farm and build­ings was approved there was a stip­u­la­tion that screen­ing in the form of trees should be put in place. No such screen­ing has ever mater­i­al­ised. Nor if this were required for this devel­op­ment do I expec­ted that would hap­pen either.

Yours respect­fully,

Megan Crook

Roy Turn­bull Tornis­car Nethy Bridge Inverness-shire PH25 3ED Scot­land Tel Email:

Stephanie Wade, Case Officer, CNPA Dear Stephanie Wade, 18^th April 2021

2021/0090/DET | Form­a­tion of camper­van site | Land 315M SW Of The Half House Nethy Bridge

1. Dis­turb­ance

This applic­a­tion raises the con­cerns that are cor­rectly sum­mar­ised in the CNPA’s Noti­fic­a­tion of Call In let­ters to the applicant/​agent and to The High­land Coun­cil, namely:

“The applic­a­tion would cre­ate a site for vis­it­or accom­mod­a­tion in a loc­a­tion where there is little cur­rent pro­vi­sion and close to hab­it­ats that may con­tain spe­cies that are sens­it­ive to human dis­turb­ance and is there­fore con­sidered to raise issues of sig­ni­fic­ance to the aims of the Nation­al Park.”

The hab­it­ats referred to include Sliemore Wood, Garlyne Moss and the wood­land of Cul­stank Moss, all of which are char­ac­ter­ised as i) cur­rently hav­ing very little human dis­turb­ance and, as a con­sequence, ii) provide suit­able hab­it­at for ground nest­ing birds, includ­ing wood­cock, black grouse, caper­cail­lie and oth­er wild­life. These are not the only spe­cies of con­cern on 22^nd April 2013, I coun­ted around 20 cur­lew feed­ing in the applicant’s fields to the south of the road and adja­cent to Cul­stank Moss.

Human dis­turb­ance of such hab­it­ats is increas­ingly being recog­nised as hav­ing a neg­at­ive impact on the sur­viv­al of such spe­cies. For example, the recent (14^th April 2021) art­icle by the CNPA Con­ser­va­tion Engage­ment Officer entitled ​“Our Brave Ground-Nest­ing Birds”, viz: https://​cairngorms​.co​.uk/​o​u​r​-​b​r​a​v​e​-​g​r​o​u​n​d​-​n​e​s​t​i​n​g​-​b​irds/ states, ​“Our wood­lands offer a more pro­tect­ive sheltered envir­on­ment with the most icon­ic ground- nest­ing giant being the caper­cail­lie, who is also joined by wood­cock and black grouse on our wood­land edges. Being in wood­land can give shel­ter to the worst of the ele­ments but can con­ceal canny pred­at­ors sneak­ing amongst the tower­ing pines or with­in the thick under­story. Young fledglings of all birds are vul­ner­able at the best of times but life on the ground can be per­il­ous and unfor­giv­ing for these spe­cies. The main dangers are tramp­ling or nests, dis­turb­ance of adults leav­ing eggs or vul­ner­able young to the cold, or to pred­at­ors. These events of cause can be caused nat­ur­ally by a passing red deer or fox but con­tinu­ous dis­turb­ance caused by people stray­ing from main tracks, with or without dogs are an addi­tion­al and more fre­quent dis­turb­ance event, height­en­ing the risk to vul­ner­able help­less, flight­less chicks.” Like­wise, the CNPA Caper­cail­lie Framework:states,

“Caper­cail­lie pop­u­la­tions in Scot­land have declined sig­ni­fic­antly from an estim­ated 20,000 birds in 1970 to 1,114 at the most recent nation­al winter sur­vey in ²⁰¹⁵⁄₁₆. […] 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. 27

The Frame­work iden­ti­fies ​‘dis­turb­ance’ as one of the reas­ons for the caper­cail­lie decline and 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.” Con­sequently, the CNPA issued the fol­low­ing appeal to the pub­lic on 8^th April 2021, entitled, ​“Keep­ing caper­cail­lie safe this spring: How you can help”, https://​cairngorms​.co​.uk/​k​e​e​p​i​n​g​-​c​a​p​e​r​c​a​i​l​l​i​e​-​s​a​f​e​-​t​h​i​s​-​s​p​r​i​n​g​-​h​o​w​-​y​o​u​-​c​a​n​-​help/ that refers to a num­ber of ground nest­ing bird spe­cies in the Cairngorms and again par­tic­u­larly emphas­ises the situ­ation with caper­cail­lie: ​“At least 80% of the small remain­ing UK caper­cail­lie pop­u­la­tion now live in the Cairngorms Nation­al Park. This makes us extremely lucky — but it also means we must take extra care to pro­tect this strik­ing bird, as it is again threatened with extinc­tion and is espe­cially sens­it­ive to dis­turb­ance.” […] Like all ground nest­ing birds, caper­cail­lie need peace and safety while rear­ing their chicks. If dis­turbed even slightly, they might aban­don their lek, nest or young and these scattered fam­il­ies may not regroup — chicks sadly will not sur­vive without their moth­ers. Causes of dis­turb­ance to caper­cail­lie include vis­it­a­tion by humans — inten­tion­ally or not — and acci­dent­al encoun­ters with dogs who range off-path. Caper­cail­lie are a pro­tec­ted spe­cies — mean­ing it’s a leg­al offence to inten­tion­ally or reck­lessly dis­turb them while they’re lekking, nest­ing or rear­ing young. 77 This appeal res­ul­ted in media art­icles, for example in the Scots­man news­pa­per (16^th April 2021) with the head­line, ​“Caper­cail­lie: Cairngorms Nation­al Park asks vis­it­ors to keep their dogs under con­trol and away from the caper­cail­lie as lock­down travel restric­tions ease,” and also on the BBC ​“Park plea to vis­it­ors to stay away from caper­cail­lie”, https://​www​.bbc​.co​.uk/​n​e​w​s​/​u​k​-​s​c​o​t​l​a​n​d​-​h​i​g​h​l​ands- islands-56731675

1. Loc­a­tion The above men­tioned areas of Sliemore Wood, Garlyne Moss and Cul­stank Moss, all of which are with­in a few minutes walk of the pro­posed camper­van site, are of intrins­ic value for caper­cail­lie. Sliemore Wood is owned by the RSPB, and Dr Robert Moss, one of the UK’s fore­most author­it­ies on caper­cail­lie, put in a joint bid with myself to pur­chase Cul­stank Moss in 2008 because of that value, (though that wood was sub­sequently pur­chased solely by myself in 2011). How­ever, this area is also of value because it forms a con­nec­tion between the Spe­cial Pro­tec­tion Areas of Craigmore Wood to the north and Aber­nethy Forest to the south, both of which form part of the extens­ive and import­ant Cairngorms Con­nect area, which is ​“com­mit­ted to a bold and ambi­tious 200-year vis­ion to enhance hab­it­ats, spe­cies and eco­lo­gic­al pro­cesses across a vast area with­in the Cairngorms Nation­al Park.” Main­tain­ing con­nectiv­ity and avoid­ing frag­ment­a­tion for wild­life pop­u­la­tions, par­tic­u­larly those such as caper­cail­lie with small pop­u­la­tions in danger of extinc­tion, is con­sidered to be of con­sid­er­able import­ance. Dam­aging that intrins­ic value and that con­nectiv­ity by increas­ing dis­turb­ance by humans and their dogs, as would inev­it­ably occur were the camper­van site be estab­lished, should, I sub­mit, be avoided. This pro­pos­al should also be con­sidered in the light of the Scot­tish Government’s ​‘Scot­tish Biod­iversity Strategy Post-2020’, which includes the com­mit­ment: ​“We will extend the area pro­tec­ted for nature in Scot­land to at least 30% of our land area by 2030, and are com­mis­sion­ing advice on wheth­er we could go even fur­ther than this” Pro­tect­ing areas of nat­ive wood­lands that provide hab­it­at import­ant for pro­tec­ted spe­cies should clearly be included in the areas ​“pro­tec­ted for nature” in the above Strategy. Indeed the only area spe­cific­ally men­tioned in the above Scot­tish Gov­ern­ment Strategy is the Cairngorms Con­nect area, and, as out­lined above, the present applic­a­tion site lies in the zone of con­nectiv­ity between parts of that Cairngorms Con­nect area. This is thus a prime area that should be ​“pro­tec­ted for nature” with­in the above Scot­tish Gov­ern­ment Strategy.

2. Mit­ig­a­tion Mit­ig­a­tion (in the form of issu­ing leaf­lets or not allow­ing guests accom­pan­ied by pets, includ­ing dogs etc.) may reduce the impact of dis­turb­ance some­what, but it can­not elim­in­ate it, since access legis­la­tion guar­an­tees ped­es­tri­an access, and the simple pres­ence of humans causes that dis­turb­ance. Humans and their dogs, hav­ing been con­fined to their camper­van dur­ing their jour­ney, will inev­it­ably wish to stretch their legs in the areas sur­round­ing their camper­van site. It is surely the job of the CNPA then to ensure that they can do so safely in loc­a­tions where such recre­ation does not cause dam­age to that envir­on­ment. That can only be done by ensur­ing that such camper­van sites are situ­ated in areas that are not sens­it­ive. This is not such a place. Sir Dav­id Atten­bor­ough dis­cuss­ing his latest doc­u­ment­ary, ​‘The Year Earth Changed’, (see https://​www​.bbc​.co​.uk/​n​e​w​s​/​a​v​/​s​c​i​e​n​c​e​-​e​n​v​i​r​o​n​m​e​n​t​-​5​6​7​52541 ) makes this point force­fully as the main mes­sage he would like view­ers to take away from the pro­gramme: ​“Human beings, even with the best will in the world, can­not but restrict the nat­ur­al world. That’s what we are doing. We’re push­ing it aside, even the most con­sid­er­ate of us. That’s almost inev­it­able to some degree, but let us real­ise that we are intruders, that we are late comers, and that the nat­ur­al world by-and-large would do much bet­ter if we weren’t there at all.” It is surely the job of the Cairngorms Nation­al Park Author­ity to avoid allow­ing the cre­ation of a devel­op­ment that restricts the nat­ur­al world in the way Sir Dav­id explains. That strongly implies not allow­ing the form­a­tion of a per­man­ent devel­op­ment that will cre­ate human and can­ine dis­turb­ance, such as that in this application.

3. Con­clu­sion Con­sequently, I have no altern­at­ive but to object to this applic­a­tion since the pro­posed devel­op­ment: i) does not con­serve and enhance the nat­ur­al her­it­age of the area, and is thus con­trary to the First Aim of the Cairngorms Nation­al Park, and ii) would have a sig­ni­fic­ant adverse effect on a spe­cies, caper­cail­lie, pro­tec­ted under Sched­ule 1 of the Wild­life and Coun­tryside Act 1981, and is thus con­trary to Policy 4 of the CNPA Loc­al Devel­op­ment Plan, 2021. Yours sincerely,

Stephanie Wade, Case Officer, and Rebecca Watts Con­ser­va­tion Officer CNPA Roy Turn­bull Tornis­car Nethy Bridge Inverness-shire PH25 3ED Scot­land Tel 01479 821668 Email: roytorniscar@​onetel.​com

Dear Stephanie Wade and Rebecca Watts, 11^th Octo­ber 2021 2021/0090/DET | Form­a­tion of camper­van site | Land 315M SW Of The Half House Nethy Bridge

I have noticed that the ​“Exten­ded Phase 1 Hab­it­at Sur­vey” for the above applic­a­tion is now pub­lished on the CNPA wens­ite, dated 30^th Septem­ber, folow­ing the ​“Eco­logy Response”, dated 29^th July. The Eco­logy Response men­tioned a num­ber of spe­cies for which fur­ther sur­vey work would be required to estab­lish if they occurred and were likely to be impacted by pat­rons of the pro­posed camper­van site. How­ever, the above Hab­it­at Sur­vey has a very restric­ted areal reach and does not cov­er large areas where such spe­cies would be expec­ted to be found. I am par­tic­u­larly con­cerned about the absence of any sur­vey of my own wood­land of Cul­stank Moss, an ancient wood­land man­aged for nature con­ser­va­tion which lies approx­im­ately 400 metres to the west of the pro­posed site, and adja­cent to the road along which any vis­it­or to the site approach­ing from the west would pass. The east­ern part of Cul­stank Moss, includ­ing areas closest to the pro­posed site, adja­cent to the road and to the fields to the east of Cul­stank Moss in which the camper­van site is pro­posed have evid­ence of the pres­ence of badgers, red squir­rels, otter (at the wet­land), pine marten, bats, brown hare, pos­sible wild­cat, numer­ous wood ant nests, includ­ing some of the largest nests in Strath­spey, copi­ous quant­it­ies of dead wood (par­tic­u­larly, but not restric­ted to, adja­cent to the road), and 12 colon­ies of twin­flower that were estab­lished by Andy Scoby, Rare Plants Officer about ten years ago that are presently thriv­ing. Cul­stank Moss also has occa­sion­al records of caper­cail­lie and one of sea eagle. Cul­stank Moss is cur­rently very rarely vis­ited by walkers.

I am unable at present to provide fur­ther inform­a­tion as I am about to leave Nethy Bridge for a few days and am writ­ing in haste, but I would be grate­ful for your con­firm­a­tion that a Phase 1 Hab­it­ats Sur­vey that would cov­er the east­ern parts of Cul­stank Moss will be required and that the inev­it­able dele­ter­i­ous impacts on the spe­cies and hab­it­ats of increased vis­it­or pres­sure will be taken fully into account in assess­ing this proposal.

Yours sin­cerely,

2021/0090/DET giv­ing nature rspb a home Scot­land FAO. Stephanie Wade Plan­ning and Devel­op­ment Cairngorms Nation­al Park Author­ity By email: planning@​cairngorms.​co.​uk 23 April 2021 Dear Stephanie, 2021/0090/DET | Form­a­tion of camper­van site | Land 315M SW Of The Half House Nethy Bridge RSPB Scot­land wel­comes the oppor­tun­ity to com­ment on the above applic­a­tion and appre­ci­ates the exten­sion of time giv­en to sub­mit our response. RSPB Scot­land is not opposed to the devel­op­ment of facil­it­ies for camper­vans in sus­tain­able loc­a­tions and recog­nises that there is likely to be demand for such sites in the Cairngorms Nation­al Park. How­ever, devel­op­ment must be in the right place and must not res­ult in unac­cept­able impacts on hab­it­ats and spe­cies. We have care­fully con­sidered the above applic­a­tion, and object to the pro­pos­al on the fol­low­ing grounds: Insuf­fi­cient inform­a­tion has been provided to allow the assess­ment of poten­tial adverse effects on caper­cail­lie as a qual­i­fy­ing fea­ture of Craigmore Wood Spe­cial Pro­tec­tion Area (SPA) We believe that this applic­a­tion site may be an inap­pro­pri­ate loc­a­tion for a camper­van site due to the poten­tial to increase dis­turb­ance to nearby SPA caper­cail­lie. We will review our pos­i­tion in the light of any fur­ther inform­a­tion sub­mit­ted. Fur­ther detail on our objec­tion and addi­tion­al com­ment on the pro­pos­al is provided in the attached Annex. We would be happy to provide fur­ther inform­a­tion, com­ments or advice on this case as required Yours sin­cerely Alis­on Phil­lip Con­ser­va­tion Officer — South High­land North Scot­land Tel 01463 715000 Office Etive House Beech­wood Park Fax 01408 715315 Inverness IV2 3BW rspb​.org​.uk Bird­Life INTER­NA­TION­AL The RSPB is part of Bird­Life Intematon­al, a part­ner­ship of con­ser­va­tion organ­isa­tions work­ing to give nature a home around the world. Pat­ron: Her Majesty the Queen Chair­man of Coun­cil: Pro­fess­or Steve Ormerod, FIEEM Pres­id­ent: Mir­anda Krestovnikoff Chair­man, Com­mit­tee for Scot­land: Pro­fess­or Colin Gal­braith Dir­ect­or, RSPB Scot­land: Anne McCall Region­al Dir­ect­or: George Camp­bell The RSPB is a registered char­ity in Eng­land and Wales 207076, in Scot­land SCO37654

Annex 1 – RSPB Scot­land Objec­tion 2021/0090/DET

Craigmore Wood Spe­cial Pro­tec­tion Area

Caper­cail­lie is the qual­i­fy­ing fea­ture of Craigmore Wood SPA and one of the SPA’s con­ser­va­tion obect­ives is ​“No sig­ni­fic­ant dis­turb­ance of the spe­cies”. Insuf­fi­cient inform­a­tion has been provided to enable adequate assess­ment of the poten­tial impacts on Craigmore Wood SPA (which forms part of RSPB Scotland’s Aber­nethy Reserve). Caper­cail­lie are now largely con­fined to Strath­spey, and as a res­ult of severe nation­al declines the spe­cies is afforded the highest level of pro­tec­tion under UK and European law. Caper­cail­lie is also iden­ti­fied as pri­or­ity spe­cies in the Cairngorms Nature Action Plan, UK Biod­iversity Action Plan and Scot­tish Biod­iversity List species.

Caper­cail­lie are par­tic­u­larly sus­cept­ible to recre­ation­al dis­turb­ance. Loc­at­ing a camper­van site with­in 1km of Craigmore wood would have the poten­tial to increase dis­turb­ance of this Annex 1 pri­or­ity spe­cies. There are tracks with­in Craigmore Wood that are cur­rently used for recre­ation­al pur­poses, how­ever, in com­par­i­sion to oth­er wood­land sites in the Cairngorms it is a rel­at­ively quiet. Way­mark­ing of routes and leaf­lets for loc­al walks have attemp­ted to dir­ect recre­ation to the least sens­it­ive parts of the forest in the east, fur­thest away from the caper­cail­lie leks.

Tracks lead­ing into more sens­it­ive areas of Craigmore Wood, close to cur­rent caper­cail­lie leks, are loc­ated approx­im­ately 500m from the entrance of the pro­posed devel­op­ment. RSPB Scot­land is con­cerned that sit­ing the pro­posed camper­van devel­op­ment so close to these access tracks could lead to increased dis­turb­ance in these areas as vis­it­ors to the camper­van site may seek out nearby loc­al walks to explore/​walk dogs etc. There appears to be lim­ited oth­er walk­ing route options in this area so vis­it­ors may access more sens­it­ive areas of the wood.

Due to poten­tial for increased dis­turb­ance of caper­cail­lie, there would be likely sig­ni­fic­ant effects on Craigmore Wood SPA. Con­sequently, CNPA is required by the Con­ser­va­tion (Nat­ur­al Hab­it­ats, &c.) Reg­u­la­tions 1994 to under­take an Appro­pri­ate Assess­ment of the effects of the pro­pos­al on the SPAs and its spe­cies in light of the site’s con­ser­va­tion object­ives. The applic­ant must provide suf­fi­cient inform­a­tion to inform this Appro­pri­ate Assess­ment. If the poten­tial impacts of the pro­pos­al can­not be suf­fi­ciently mit­ig­ated and there could be adverse impacts on the integ­rity of the site, then it is unlikely that the CNPA would be able to grant con­sent in accord­ance with the Hab­it­at Reg­u­la­tions requirements.

Suf­fi­cient inform­a­tion must be provided to allow the assess­ment of poten­tial adverse effects on caper­cail­lie as a qual­i­fy­ing fea­ture of Craigmore Wood Spe­cial Pro­tec­tion Area (SPA).

Addi­tion­al Com­ments Loc­al Devel­op­ment Plan Allocation

We note that there is no alloc­a­tion with­in the newly adop­ted LDP for a devel­op­ment of this type at this loc­a­tion. Although this applic­a­tion must be con­sidered on its own mer­its, we are con­cerned that this site may be an inap­pro­pri­ate loc­a­tion for a camper­van site due to the poten­tial to increase dis­turb­ance to nearby SPA caper­cail­lie. There may be altern­at­ive loc­a­tions for a devel­op­ment of this type that are less likely to increase impacts on caper­cail­lie, or oth­er hab­it­ats and spe­cies of highest con­ser­va­tion concern.

Sliemore Wood – RSPB Aber­nethy Reserve

The pro­posed devel­op­ment is dir­ectly adja­cent to Sliemore Wood, which forms part of RSPB Scotland’s Aber­nethy Reserve and is on the ancient wood­land invent­ory as a plant­a­tion of long-estab­lished ori­gin. Whilst this woodland

does not cur­rently hold caper­cail­lie, it may be used as dis­pers­al route between Craigmore Wood and Aber­nethy Wood. RSPB Scotland’s aim in the long-term would be to make this wood­land more suit­able for caper­cail­lie (and oth­er spe­cies) and encour­age them to use the wood­land as breed­ing hab­it­at. Any poten­tial for increase in recre­ation­al use of this area should be care­fully con­sidered and planned to avoid redu­cing the poten­tial for caper­cail­lie to expand into this wood in the future and to avoid dis­turb­ance to spe­cies and habitats