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.
- 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.
- 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.
- 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
- 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?
- We suggest that the wording should be strengthened to include a strong
presumption against any new tracks or footpaths.
- 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
- 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.
- 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
- 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.
- 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.
- 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.
- 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.
- 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?
- 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.
- 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.
- The target of 35,000 ha for peatland restoration is similarly
unambitious. However, the peatland skills training programme is a good
- 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.
- 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
- We fully support the proposal to reduce muirburn. However, this is an
example of the need to be clear that detailed plans are awaiting
- 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
- 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
- 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.
- 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
- 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.
- 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
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
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