Consultations

Dave Windle

Mar Lodge Estate Management Plan 2022-2027

Most of the points that we made were detailed and difficult to understand without the full draft management plan. They are not repeated below. We made nine more general, key points.

1. We endorse continuing the principle of the “long walk in” and look forward to progress on how the growing use of mountain bikes can be fitted in with this policy.
2. We suggest that you add local community groups to the list of five named organisations. They are an important stakeholder and, in the past, a cause of problems.
3. We are concerned to see planting mentioned in the section on woodland expansion and regeneration without the necessary caveat. We remind you of the quote from Shaila Rao, “Thank heavens we didn’t rush in and plant”. On something as important as this, the plan needs to be very cautious.
4. We thought that NTS had stopped muirburn on the estate. Clearly, that is not case. Is it possible to define areas where you won’t be burning?
5. We suggest that the wording should be strengthened to include a strong presumption against any new tracks or footpaths.
6. A target of 5.5 deer/km² seems too high for the whole estate when you have a large area of zero tolerance. This would seem to be a suitable upper limit for the area not including the zero tolerance zone.
7. Volunteering is proposed for “management and monitoring”, but more purposes and more partners could be suggested, e.g., couldn’t better use be made of OATS for pathwork? NEMT could play a role here in reaching local walking and climbing clubs in the northeast.
8. Mountain biking needs more urgency. Trailforks and Strava are already advertising mountain biking routes across the estate, including the sensitive plateau. If NTS isn’t careful, it will be left behind, having to adopt policies chosen by others.




Suggested cycle routes in the Cairngorms on the Trailforks website

9. Mountain rescue should not be used as a reason to maintain tracks. It is mostly used to “trump” other arguments.

Cairngorm National Park Partnership Plan 4

As above, I have omitted the specific detailed comments and only included the more general, key points.

1. The document is too vague and lacks detail. The targets should be specific and measurable. At the end of the planning period, it will be very difficult to assess how much of the plan has been delivered.
2.  The high priorities need to be clarified. For example, the climate emergency deserves emergency actions. Similarly, with biodiversity loss. There is a danger that the difficult actions required to deal with these issues will get lost in a smokescreen of well-intentioned, but easier, actions.
3. In some cases, the targets can’t be too specific because they depend on legislation which has yet to be passed. It would be helpful if this was made clear.
4. Getting to net zero by 2045 is a national target. Surely, the Park with its wealth of natural assets should be able to be an exemplar or leader and aim to get to net zero before the rest of the country?
5. Your own data shows that the average GHG emissions per capita in the Park is double the UK national average. Surely, this should feature in the plan with the necessary actions to, at least, bring the Park into line with the UK national average.
6. The target of 35,000 ha of new woodland by 2045 is described as ambitious. This is less than 8% of the total park area. Given the climate emergency, this is unambitious in the context of both the large amount of ongoing natural regeneration, e.g. Cairngorms Connect, and woodland expansion targets for the whole of Scotland.
7. The target of 35,000 ha for peatland restoration is similarly unambitious. However, the peatland skills training programme is a good idea.
8. Reducing red deer densities to 5 – 8/km² is far too weak. While we fully agree that the use of a deer density number is too simplistic and that we need to move to measures such as occupancy and browsing impact, we believe that this target deserves comment. It is an average figure across the Park, which includes conservation estates such as Abernethy, Glenfeshie and Mar Lodge and also grouse moors fenced to keep the deer out where deer densities are much lower. This target should be replaced by a maximum of 5 – 8/km² on any estate.
9. We fully support the need to reduce the intensity of game bird management in the Park but would like to see much more specific proposals. The word “Encourage” reveals that there are no firm plans in place.
10. We fully support the proposal to reduce muirburn. However, this is an example of the need to be clear that detailed plans are awaiting legislation.
11. Restoration of the rivers in the Park is fully supported. However, this needs to be accompanied by some definitions of what this actually means. Planting a few trees doesn’t mean that the river is restored. There are still many km of moderate, poor and bad quality rivers in the park, much of which is due to physical modification. The plan should provide an annual and longer term target for restoration of these rivers.
12. Restoring ecosystems is highly desirable, but the plan needs to be much more specific about what is intended. The proposed Cairngorms Nature Index is a good example. At present, it is undefined and meaningless.
13. We note that wildlife crime, as an issue, is buried. It needs to be a much higher profile issue. This gives the impression that things are OK and that progress is being made.
14. Leveraging in private investment for carbon offsetting looks good when the sums of money are displayed against public finance figures. However, many people already see through these sort of corporate greenwashing attempts. You need to be very sure that the carbon benefits are clear and real, that nature is benefitting and that the correct solution isn’t to tackle the emissions at source rather than offsetting by growing trees.
15. We fully agree that improved public transport is necessary. However, progress won’t be possible without a more detailed plan. Solutions will potentially require significant public subsidy, which will probably not be available. Innovative thinking is required and getting this going requires a more detailed plan.
16. Affordable housing is so important that it needs a higher profile. This is buried amidst footpaths and cultural experience. It needs to be prioritised. There is no indication of how the targets will be even approached, let alone, met. On the positive side, there is a clear target of 200 new affordable rental houses and the proposal to extend the greater than 25% affordable housing quota to other villages is very welcome. The Actions section refers to a Short Term Let Control Area. What is this and how will it work?

As part of their reply, Scottish Environmental LINK, with NEMT’s and other NGO’s support, sent an open letter to the Board, part of which generated some press coverage.

The landowners and their gamekeepers have reacted, Protest against new Cairngorms National Park plan - BBC News. They have sent a leaflet to every resident in the park forecasting all sorts of doom and destruction if the plan goes ahead.

National Planning Framework 4

We made the following comment.

North East Mountain Trust believes that this Policy gives insufficient protection to wild land. We strongly suggest that wild land status becomes a statutory designation. In addition, protection needs to be strengthened by requiring all Local Development Plans to identify any areas of wild land, and to restate that any development, other than for small-scale agricultural operations relating to crofting, is prohibited. The existing wording allows developments provided that “use of siting, design or other mitigation measures minimises adverse impacts”. This is insufficient as, once wild land has been developed, it will never be wild again.

Wild land is an important part of Scotland’s attraction for foreign tourists. Industrialising our landscape will have a negative impact on an important part of our economy, particularly in the more fragile rural areas.

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