Dave Windle
I set out below a summarised version of our comments on the proposed update to the Nature Action Plan. The original document is available.
It is stated that an objective is 'more sustainably managed moorland'. This is unacceptably weak. The objective should be that 'all moorland should be sustainably managed'. It must be clearly stated that all moorland must be managed for both environmental and wild life diversity as well as for sporting purposes. This will not be achieved by collaboration and consultation but needs to stated. It is possible to manage grouse moors for more than just grouse and a stronger stance needs to be taken. This does not preclude driven grouse shooting; it just needs to come in line with current legislation.
The lack of achievement of the aims of this previous plan demonstrates the problems of a purely voluntary and consensual approach. Targets failed include the flagship 5000ha new woodland excused by an unknown amount of natural regeneration. It is essential that the extent and rate of natural regeneration is established in the current Plan so that the effectiveness of conservation interventions and reductions in grazing pressure can be properly assessed. River and floodplain restoration has seen only very few projects in the Park, instead of the major flagship demonstration programmes we should expect.
The Objectives and Vision Statements are all good - who could argue with them? However, in general the targets are very soft or non-existent. The Plan needs to contain baseline data, so that SMART targets can be seen in the appropriate context.
The three aims (Habitats, Species and Engagement) are welcome and appropriate. But in Protecting and enhancing species: "tackling species management conflicts by combining knowedge from all sectors to develop shared solutions to competing objectives" is pie-in-the-sky for some issues. The aim should reflect the introduction and state that diversification of habitats and species is the priority.
NEMT supports the Deer Management priority"...deer numbers and consequent impacts are reduced..." The overriding need to reduce deer numbers across all estates, not just the better-managed ones, has to be explicitly addressed with higher profile and more measurable actions.
NEMT does not support high altitude planting to achieve tree regeneration. Experience from Glenfeshie and Mar Lodge estates clearly shows that reducing deer numbers will stimulate regeneration very satisfactorily. Planting simply dodges the core issue, wasting public money that would be better spent in getting deer numbers down. Limited planting should only be in very specific cases where suitable seed stock is no longer present.
There needs to be a target for grazing densities. Such a target is sensitive with the estate owners but can't be avoided. SNH and FCS have material which would help with this.
The target of 5,000 ha of new woodland is too soft. Glenfeshie, Abernethy and Mar Lodge should achieve this. What about the contribution from some other estates and reserves, e.g. Invereshie?
A separate target should be set for new woodland by modifying muirburn in gullies, steep slopes and along the edges of grouse moors. It should include establishing much more riparian woodland along watercourses. Grouse moor owners need to start playing their part.
The 5000 ha peatland restoration is too soft. The Scottish Government target is to restore 40% of the 618,000ha restorable peatland by 2030, which equates to 247,000ha across Scotland. A target of 5,000ha in a 5 year plan will only get us to 10,000-12,000ha by 2030, which is too small a contribution from a National Park.
Similarly, the 150 km river/riparian restoration target is also too soft. We assume that the 150 km target refers to riparian tree planting. No mention is made of the physical need to allow river channels and flood plains to return to a more natural condition, thus improving flood resilience.
The most recent evidence on Mountain Hares (Centre for Ecology & Hydrology report August 2018) indicates huge declines in some areas and that the species is not likely to be under sustainable management. This part of the plan needs to be revised.
Wildlife tourism will be an important part of combatting illegal killing of raptors. This target needs to be more specific, e.g. an additional 20 people employed in wildlife tourism businesses.
As noted above, these engagement objectives are far too vague and mostly not measurable. The targets given have no current baseline (see earlier comment above) against which to evaluate the degree of success. We all agree that "involving people" is key to a successful plan and yet this section could be so much more positive if more details of what is proposed were given.
The delivery & monitoring actions are weak and unmeasurable with no clear baseline. The action to: "Build and retain constructive relationships with local and national partners...." is a good example. They need to be SMART
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