Transport Scotland Biodiversity Strategy consultation response

Cairngorms Nation­al Park Author­ity 14 The Square Grant­own on Spey PH26 3HG

T: 01479 873 535

27 Novem­ber 2025

Maria Klimek Trans­port Scot­land Biod­iversity Strategy Doc­u­ment Devel­op­ment Team Email: TSBS@​jacobs.​com

Response: Trans­port Scot­land Biod­iversity Strategy Consultation

Many thanks for giv­ing the Cairngorms Nation­al Park Author­ity the oppor­tun­ity to com­ment on the emer­ging Trans­port Scot­land Biod­iversity Strategy and Deliv­ery Plan. We note that the trans­port net­work with­in the Park that falls under Trans­port Scotland’s remit is lim­ited to the A9, A93, A95, the Perth-Inverness rail­way line, and asso­ci­ated act­ive travel links.

Link­ing the Strategy with the Cairngorms Nation­al Park Part­ner­ship Plan is a key con­sid­er­a­tion for the Park Author­ity, par­tic­u­larly regard­ing stra­tegic invest­ment at scale, work­ing in part­ner­ships, safe­guard­ing and deliv­er­ing nature net­works, pri­or­it­ising nature-based solu­tions and green infra­struc­ture, and sup­port­ing a sys­tems-based approach.

We note that Nation­al Park Plans are ref­er­enced in Annex 1. How­ever, there appears to be no expli­cit acknow­ledge­ment of the exist­ing stat­utory duty for pub­lic bod­ies to have regard to the Park Part­ner­ship Plan when exer­cising their func­tions in the Nation­al Park. There also doesn’t seem to be any ref­er­ence to the pro­posed new stat­utory duty for pub­lic bod­ies to facil­it­ate imple­ment­a­tion of Nation­al Park Plans as set out in the Nat­ur­al Envir­on­ment (Scot­land) Bill 2025.

Sec­tion 7 acknow­ledges Nation­al Plan­ning Frame­work 4 policy 3 b) require­ments for nation­al and major devel­op­ments to con­serve, restore and enhance biod­iversity such that they are in a demon­strably bet­ter state than without inter­ven­tion, and to deliv­er sig­ni­fic­ant biod­iversity enhance­ments in addi­tion to any pro­posed mit­ig­a­tion. The text notes that Scot­tish Gov­ern­ment has com­mis­sioned work to devel­op a Scot­tish biod­iversity met­ric to sup­port deliv­ery of this policy. Fur­ther­more, it acknow­ledges the poten­tial bene­fits of met­rics, when used appro­pri­ately, but also recog­nises that they have lim­it­a­tions and do not con­sider spe­cies or eco­sys­tem func­tions. This is where a sys­tems-based approach may be more appro­pri­ate. We would wish any mit­ig­a­tion to be inves­ted stra­tegic­ally in the Park as a whole, not just where works are tak­ing place, as this is often where the biggest biod­iversity and eco­sys­tem ser­vice gains can be made.

We feel the Biod­iversity Strategy should refer more expli­citly to it facil­it­at­ing the deliv­ery of Nature Net­works. The Park Author­ity would wel­come the oppor­tun­ity to dis­cuss with Trans­port Scot­land the applic­a­tion of sev­er­al of the object­ives of the Biod­iversity Strategy in the Nation­al Park, espe­cially with­in the con­text of the emer­ging Cairngorms Nation­al Park Nature Net­work. This would include exploring:

• The remov­al of non-nat­ive trees that have the poten­tial to be invas­ive, such as Sitka spruce and lodge­pole pine, from land under Trans­port Scotland’s con­trol and their replace­ment with site-appro­pri­ate nat­ive trees. This is par­tic­u­larly per­tin­ent along the A9 between Dal­whin­nie and Dal­nas­pid­al, part of a poten­tial nat­ive wood­land cor­ridor iden­ti­fied in the Wood­land ele­ment of the CNP Nature Net­work that sits in a cur­rently largely tree­less land­scape and that would form a sig­ni­fic­ant link­age between the wooded land­scapes of the Tay and Spey catchments
• The enhance­ment of road­side veget­a­tion along the A9, A93 and A95 to con­trib­ute to the Man­aged Low­land Grass­land ele­ment of the CNP Nature Net­work and emer­ging CNP Pol­lin­at­or Plan
• Max­im­ising the per­meab­il­ity of the A9 cor­ridor to wild­life move­ments, par­tic­u­larly in the con­text of the road’s ongo­ing dualling
• Re-examin­ing the poten­tially envir­on­ment­ally harm­ful use of arti­fi­cial light­ing of fea­tures for aes­thet­ic reas­ons, such as rock cut­tings along the A9 and the A95 bridge over the River Spey SAC

We would be happy to expand on any­thing we have writ­ten, so please don’t hes­it­ate to get in touch if you require fur­ther detail.

Yours sin­cerely,

Dav­id Hetherington

Dr Dav­id Heth­er­ing­ton Nature Net­works Manager