The Situation

Local developers Allan Munro and David Cameron have applied for outline planning permission to build 120 houses in the woods to the south of Deshar Road, Boat of Garten.

Objections

Badenoch and Strathspey Conservation Group has strongly objected on behalf of its members.   The letter of objection is as follows:

Badenoch & Strathspey Conservation Group

Fiodhag    Nethybridge     PH25 3DJ

Robert Cameron

Area Planning and Building Control Manager

Badenoch and Strathspey

100 High Street

Kingussie

PH21 1HY

^5.9.02

Dear Mr Cameron

02/230/OUTBS Housing etc development south of Deshar Road, Boat of Garten

I am writing on behalf of the Badenoch & Strathspey Conservation Group to object to the above application for the following reasons.

Woodland Site

Descendants of the ancient Caledonian pine forest ?

The proposed development site is Scots pine woodland with a rich understorey of dwarf shrubs (cowberry, ling, blaeberry, crowberry and locally bearberry).

The Council will be aware that "Caledonian Forest (native pine) is listed as a priority habitat in the EC Habitats Directive. This designation is based on the view that this habitat, ‘is in danger of disappearing in the European Community and requires special and urgent protection measures to ensure its survival and subsequent enhancement’."(A Forest Habitat Network for the Cairngorms 1998 SNH Research & Monitoring Report). The Council will also be aware of the strategic objective identified by the Cairngorms Partnership (Managing the Cairngorms 1997) "to consolidate and encourage the regeneration of existing native woodland".

Almost the entire development site is classed as ‘self sown Scots pine’ (Native Woodlands of Strathspey BMS Dunlop 1994, map 10). The small area classed as ‘planted Scots pine woodland (>75% Scots pine)’ appears to include a major element of natural regeneration and lacks exotic conifers. The small area of ‘self sown Scots pine & birch mixtures’ is also of diverse age structure, of native species and with wild and natural qualities.

It is probable the Scots pine is all of local provenance. Dunlop (1994 p60 my emphasis) states that "Some of the areas in this category [Established Woodland] may be direct descendants of the Caledonian pine forests. The main areas of established Scots pine woodland, most likely self-sown from planted trees, include:- … Boat of Garten – Granish Moor". Whatever part of Granish Moor this refers to, it is reasonable to suppose that the seed source covering the proposed development site would be much the same. The proposed development site has habitat features typical of native Caledonian pinewood, in terms of for example animals and plants present in the wood, soils, and a rich dwarf shrub layer. Today there is fairly abundant natural regeneration of young trees, in particular Scots pine, with rowan. quite frequent in this category.

In the Ancient Woodland Inventory some two thirds of the proposed development site is listed as "long established woodland of plantation origin". Considering this classification and that of Dunlop an assumption can be made that the trees were self sown from parent trees of either natural, or possibly at some past stage, planted origin.

The importance for biodiversity and natural heritage of Caledonian pinewood and plantations on ancient woodland sites has been increasingly recognised in recent years. The importance of avoiding fragmentation and safeguarding connectivity between woodlands is also now much more fully recognised than when the Local Plan was passed (research related to metapopulation thinking has been an active area in wildlife biology in recent years). The Plan for example pre-dated the Cairngorms Forest Framework, A Forest Habitat Network for the Cairngorms, and the draft Cairngorms Local Biodiversity Action Plan (LBAP) as well as the River Spey Catchment Management Plan (CMP). We consider it appropriate for the planning authorities to have regard to documents such as the LBAP and CMP and assume that, regardless of formal status, their aims are accurately described as "a material consideration" in relation to planning decisions (as stated in the dCMP page 11)

Capercaillie interests

Capercaillie are frequently seen in Deshar Woods

There is abundant evidence of frequent use of this wood by capercaillie. Capercaillie are known to use the woodland for feeding and lekking.

Capercaillie is a UK and Local Priority and Annex 1 Species for which Britain has an international responsibility. It is a culturally and economically significant bird that is important to local tourism and to sustaining green tourism over a wider area. It is predicted that capercaillie will be effectively extinct in 10-15 years if the current decline in numbers continues, yet it is a candidate as an emblem for the proposed National Park (and its image adorns the cover of such publications as Managing the Cairngorms). Strathspey woods are currently (September 2002) described as "the key area in Scotland for this species" (Dr Peter Mayhew, Senior Conservation Manager with the RSPB).

We are concerned that the Council should have regard to the substantial sums of public money that are being invested to help this species, and that the benefits from such investment would be undermined through direct habitat destruction and increased disturbance, especially from people and their dogs.

Since woodland south of Deshar Road was identified for built development in the Local Plan the conservation status of capercaillie has become markedly more precarious. In our view this matter is an important material planning consideration.

Moreover, the Council has obligations under the Habitats and Birds Directive to assess areas outwith Natura 2000 sites. The Habitats and Birds Directives, Implementation in Scotland, June 2000, page 3 states "As the Directive requires the protection of the interests for which the area has been designated, the need for appropriate assessment extends to proposed developments outwith the boundary of the designated area.". It is acknowledged that capercaillie in Scotland "regularly moves many kilometres between forests" (Dr Mayhew September 2002). It is also considered by the top authorities on this species that the network of Special Protection Areas for capercaillie, although greater than when the Local Plan was passed, are currently insufficient to meet their purpose.

The Wild Birds Directive (79/409/EEC) states that the maintenance of habitats shall include "upkeep and management in accordance with the ecological needs of habitats inside and outside the protected zones" (Article 3). The Directive also states that Annex 1 species (like capercaillie) "must be subject to particularly stringent scrutiny" and require "special conservation measures concerning their habitat in order to ensure their survival and reproduction in their area of distribution" (Article 4).

Capercaillie numbers need to increase to ensure their survival. The Directive requires that capercaillie habitat (including outwith Natura 2000 sites) is managed so as to allow a population increase to a level where they are no longer in danger of extinction. The proposed development would do the opposite, causing loss of capercaillie habitat, leading to increased disturbance by people and dogs, and increased risk of egg predation by crows (which tend to be associated with edges and openings of forests).

Biodiversity

This rare crested tit was photographed recently in Deshar Woods,

This woodland provides habitat for red squirrel, crested tit, Scottish crossbill, and wood ants. The proposed development would reduce the habitat for these species, as well as increase disturbance, predation and other risks (road traffic is for example a common cause of accidental red squirrel deaths in our district). 

Red Squirrel.   Status - endangered

Red squirrels are one of the UK’s most endangered mammals and a Priority Species in National and Local Biodiversity Action Plans. Strathspey’s pinewoods are certainly one of their main UK strongholds and the studies (such as those presented to the Scottish Squirrel Group) identifying this special importance post-date the production of the Local Plan.

It has also been suggested that the importance has even been underestimated by such studies owing to the high component of Scots pine (rather than exotic conifers like Sitka spruce) in Strathspey, not allowed for in models based simply on forest area. This is because it is well known that Scots pine woodland is capable of supporting particularly high population densities compared to more widely planted species, such as Sitka spruce, that are dominant in commercial plantations over most of Scotland.

In this context, if Highland Council is serious in supporting red squirrel conservation, it must recognise that it is particularly important to take squirrels into account in Strathspey’s Scots pine woodland.

What is described as "Habitat fragmentation and islandisation" are identified in the draft Cairngorms LBAP as locally important issues relating to red squirrels.

Squirrels are known to be vulnerable to predation from domestic cats in Strathspey as elsewhere. They may be extra vulnerable in the vicinity of garden feeding stations. There have been major fluctuations in squirrel populations in the District in the past, with strong circumstantial evidence of disease having played a part in some population crashes. Garden feeding stations increase the chances of spread of contagious diseases such as parapox virus. This disease to which red squirrels are particularly susceptible has recently been found in this species in Scotland. It is often suggested that habitat loss can lead to displacement and stress, increasing vulnerability to disease. This may be more disastrous in smaller and thus usually genetically more uniform and less resilient populations.

Crested tits have a restricted range in the UK and there is evidence to suggest they are not good at dispersing. Loss of woodland will reduce and fragment crested tit habitat. Crested tit is a UK Species of Conservation Concern and a Locally important species, that attracts visitors to the area being in the UK associated with Strathspey and Speyside.

Historical decline and habitat loss of Caledonian pinewoods has been identified as a key issue for crossbills in the draft Cairngorms LBAP. The Scottish crossbill is a UK Priority and Locally important species, that is a draw for birdwatchers to the district. Woodcock and bullfinch a UK Priority and locally important species are also of interest to visiting birdwatchers.

Wood ants (e.g. Formica aquilonia and F. lugubris) are Priority Species at UK and Local Biodiversity Action Plan level. Loss of semi-natural habitats like native pinewoods has been identified as a locally important issue for both of these species and the narrow-headed ant (see Draft Cairngorms LBAP page 121). The proposal would cause loss of woodland, which would reduce the habitat and increase the possibility of destruction of remaining nests. The status of the Red Data Book 1 species, the narrow headed ant, is presently unknown in this wood and requires careful and detailed investigation. This is especially so given the recent discovery at Glencharnoch (near Carr-bridge) of a colony of this species in an area already surveyed for wood ants.

The proposal would fragment the remaining habitat in the wood and would particularly isolate the woodland east of the development site. In addition this part of the woodland would receive very much higher levels of use by people, dogs and cats as a result of the development. 

One of our precious otters

Otters are recognized of particular importance in relation to the River Spey Special area of Conservation. They are known to use Loch Vaa, where the proposed development would cause increased disturbance by people and dogs, and they also can use secluded sites in woodlands as natal holts. Otters may use the wetland area close to the site boundary for seasonally feeding on amphibians. These are an important food source at a time of year of food shortage for this species.

There is limited up to date information on use of the proposed site by badgers which have special legal protection. Information has apparently similarly not been collected on any species of bat for example of summer or hibernation roosts. The Pine marten a UK species of conservation concern is present in the wood and may be vulnerable to increased traffic, as suggested by one recent road fatality on the outskirts of the village. The wildcat, a locally important species at risk from hybridisation with domestic cats, may use the wood (which supports some rabbit prey). A road-killed individual was found a few years ago not far outside the woodland.

The fungi of the site, while evidently prolific and to the non specialist diverse, merit survey especially as in pinewood habitat in the Cairngorms area in recent years rare species have come to light.

We also know of no botanical survey of the site but our own limited observations (in September) have revealed the presence of juniper, a UK Priority and locally important species and the nationally scarce species of orchid Creeping lady’s-tresses (Goodyera repens). This orchid is associated with woodlands "with in almost every case" a considerable proportion of Scots pine and often some birch (see Scarce Plants in Britain p.198). Ostrich plume moss (Ptilium crista-castrensis) is also present within the proposed development site and is often considered as a good indicator of long established woodland.

An invertebrate present on the proposed development site (in September 2002) the ashy-grey slug Limax cinereoniger is a "widespread but local" woodland species associated with dead wood that is described as "intolerant of human disturbance". There has been no survey to look for its smaller "very local" old woodland relative the lemon slug which exploits fungi and lichens which are well represented on the proposed development site.

National Park and duties to protect woodland

This woodland would be lost for the sake of unnecessary housing

The proposed development is within the proposed National Park boundary so the highest standards of planning are needed. National Planning Policy Guideline 14 states "planning authorities should take particular care to safeguard the landscape, flora and fauna of … the [future] Cairngorms [National Park]" (para 33.), and also "Planning authorities should seek to protect … areas of woodland where they have natural heritage value or contribute to the character or amenity of a particular locality. (para 51). Old aerial photographs (for example one taken on 26 August 1946) provide evidence that trees have long been an important part of the amenity and character of the proposed development site which it would be perverse to fail to protect now with a National Park only a few months away.

The Cairngorms Forest and Woodland Framework

The Aims and Objectives of the Cairngorms Partnership’s "Cairngorms Forest and Woodland Framework" (1999) includes "To conserve and enhance the natural heritage, biodiversity and cultural interest of the area by: Enhancing the conservation value of the existing woodlands by developing effective habitat networks". This emphasises the need to increase connectivity between woodland areas around the Cairngorms.

This objective recognises that fragmentation of existing habitats can be an important cause of local extinctions and that the establishment and enhancement of woodland corridors to facilitate movement should be a major priority within the Cairngorms area.

Amenity and Infrastructure               

The approach to the village from the west

The proposed development site provides an important amenity for residents of Boat of Garten and visitors, and is also valuable for ‘eco-tourism’ over a wider area. Species that are pinewood specialists, such as crested tits, crossbills, red squirrel, capercaillie, all of which occur in this wood, are important reasons why people visit and spend longer in the district. The proximity and accessibility of these species to the communities is also important in this respect. There is a need to cater for increasing demand for peaceful outdoor recreation for example within the context of the proposed national park. We note "the furtherance of outdoor recreational opportunities" is referred to under strategic objectives for woodland in the Cairngorms Partnership publication Managing the Cairngorms and that erosion of woodland of high amenity close to a settlement runs counter to this objective.

Boat of Garten, the ‘Osprey village’, has recently developed a popular network of community paths. A major path (part of Route 4) cuts across the proposed development site, and appears not to be retained within the development. There are also several very attractive smaller paths on the site which are not part of the waymarked network but which link into the network very well and provide excellent short, circular routes that are well suited for dog walking and short walks.

In addition the proposals would reduce the attractive surrounding landscape of some of the other waymarked and informal paths as well as a stretch of the Sustrans national cycle route.

The community has also provided a popular viewing point for wildlife visiting the lochan north of the Deshar road. More traffic on this road will detract from the quality of experience for people looking across the road from the wildlife viewing point, and makes this facility less safe.

Land surrounding Boat of Garten is well known for its high archaeological interest. There is a bank at the north of the site (possibly an old boundary) that may be of historical interest. We do not know of any archaeological survey that has been carried out on the site although we would urge that prior to any decision on planning permission a thorough survey should be undertaken. The interest of such survey may be high given the proximity to areas of already known archaeological interest (including features listed on the Sites and Monuments Register). Archaeologists and historians now often consider that it is the overall extent, scale, context and variety of features that makes the archaeological heritage of our district so special. In the context of a historic landscape with notable archaeological interest, semi natural native woodland on relatively undisturbed soil can be viewed as an asset.

The proposed development has infrastructure implications, for example for sewage treatment and water supply, which could impact adversely for example on wildland, designated sites and special features of general interest.

Scale and timing of development and recent findings of EC project and community initiatives

The proposal represents proportionally an excessive increase in the number of houses in Boat of Garten. This greatly exceeds natural growth of the village. We consider that to release so much land at once for housing would be premature and amount to planning driven by short term interests of the developer and land owner rather than the genuine interest of the community and natural heritage for controlled and sustainable development.  

The entrance to the proposed development will be near this point on the forest edge

Work that the Council has itself supported (in the Highlands) since the local plan was adopted serves to underline that serious consideration should be given to the sustainability profile of developments impacting on economically fragile rural communities and sensitive habitats and species of national importance.(see reports of the Duthchas EC life project 1998-2001). Such work in addition indicates, within a proposed National Park, community engagement in major decisions with enduring implications for future generations is fundamental to good practice.

Status of Local Plan

We note that the Local Plan is acknowledged as being out of date, and that SNH and RSPB objected to the zonation of this woodland for housing in the Local Plan.

When the Local Plan was drawn up the capercaillie in Scotland was considerably less threatened, the importance of our district for this species was less fully apparent, and the prospect of a national park was remote. Then there was also no draft Local Biodiversity Action Plan, millions of pounds of public money was not being invested in capercaillie conservation, the thinking embodied in for example the Cairngorms Forest Framework had limited currency, and support for community land purchase was less available.

Ministers have emphasised the need for change in the pursuit of high standards in the proposed Cairngorms National Park making it clear that this should not be at the expense of biodiversity conservation. In this context we consider it would be retrograde to do other than recommend rejection of the current apparently hastily conceived proposals that appear to be completely out of line with community wishes.

We strongly urge rejection of this application.

Yours sincerely

Dr A M Jones

Convenor

Email us