NEMT COMMENTS ON FLS ANGUS GLENS MANAGEMENT PLAN MAY 2024

Ken Thomson

Submitted on behalf of NEMT by Ken Thomson and Dave Windle, 1 July 2024.

The Forestry Land Scotland (FLS) Angus Glens Management Plan can be found at https://forestryandland.gov.scot/what-we-do/planning/consultations/angus-glens

The North East Mountain Trust (NEMT, Scottish Charity SCIO 008783) represents the interests of hill-goers and those who enjoy visiting remoter areas. NEMT membership, comprising twelve hillwalking and climbing clubs along with individual members, totals around 1000 people. NEMT is based in the Grampian area, but represents its members´ interests across the whole of Scotland.

We are pleased to take up the opportunity to comment on the FLS "concept" Land Management Plan for the Angus Glens, and would make the following points:

1. Given the very different histories and natures of Glens Doll, Prosen, Isla (actually Finlet) and Markie (actually the hill ground around Hare Cairn, not the glen), the Objectives have little practical meaning unless differentiated by "glen". Moreover, the Plan (which seems spread over several documents, making it difficult to absorb) makes no or little mention of timescale, e.g. in reaching its "Objectives".
2. In broad terms, we think that the Plan is a positive step forward. We note that many of the objectives would be improved by specifying quantitative targets, enabling progress to be measured.
3. We note that much of the Plan involves considerable stretches of deer fencing, even though this is nowadays considered a "last resort", as well as being expensive and involving short-term and ground-disturbing activity, usually by non-resident contractors. We should be happier to see more explicit mention of active deer culling, which would involve much longer-term local employment and venison production.
4. We support the proposal to apply for carbon offsetting credits, and note that this plan should be superior to private sector schemes also aimed at carbon credits.
5. We are pleased to see the expansion of montane scrub in the objectives. However, we are concerned that any planting / regeneration will be eaten by the very high deer population in the area. How is it proposed to protect these plants from grazing by deer?
6. Objective 10 - "Maintain an element of timber production and wood products where sympathetic to environmental objectives and economically viable" - is very vague, especially as "environmental objectives" are here undefined, and might be used to justify widespread quick-growing conifers to promote carbon capture.
7. Objective 11 ("Plan for resilience") refers to "strategic access to mitigate against and limit the spread of notifiable diseases ...". The meaning of this is not entirely clear, nor are sites and locations (of tracks?) specified. If it is a "method" within the "Plan" to achieve the "resilience" Objective, this should be made clearer.
8. We agree that the proposed herbivore management plan is appropriate for establishing forest in this area, where deer numbers are excessive. We are particularly glad to see explicit mention of a target deer density of 0 - 2/km². We think that FLS need to take a robust approach to discussions with surrounding landowners. This is particularly important in this area where there are very high numbers of deer on surrounding landholdings. FLS will need to be clear about acceptable deer densities and, if "habitat or grazing damage" surveys are to be used to guide policy, how such measurements will be undertaken. The public purse should not be used to subsidise poor land management practices by others.
9. We note the phrase "sweeping compartments for herbivores before planting". Is it intended to sweep out voles, rabbits, etc., or will (biodegradable) tree guards be used?
10. Has enough care been taken to ensure that trees will not be planted on deep peat? Not only will such plantings do poorly and probably die, but the net effect on carbon emissions is likely to be negative. It is becoming increasingly well established that trees planted on peat release more carbon than they absorb for a long time. Even without taking account of the carbon cost of obtaining and transporting seedlings, and disturbing the soil, the tree roots dry out the soil, allowing the trapped carbon to oxidise and hence enter the atmosphere.
11. We suggest that FLS should be adopting the "precautionary principle" and only planting trees where the peat depth is significantly less than the current standard of 50cm.
12. We are pleased to see that 155 ha of land at Craigie Thieves has been allocated for natural regeneration. However, this is a small fraction of the total plan area. Is it not possible to either find another similarly sized area, say in Glen Doll? Alternatively, when planting native species, leave areas in the middle to regenerate once the outer surrounding trees have started producing seed. Either way, there will have to be regular visits to remove invasive trees, e.g. Sitka spruce, both from natural regeneration areas and the middle of native species areas.

    Glen Prosen, with shelter belt conifers... © Mike Duguid

13. We should like to see more detail on facilitating public recreational access (primarily by walkers and bikers, but also perhaps by horse or pony) in the Glens, e.g. encouragement to complete "circuits", accommodation possibilities, etc. This would not include much signage, which seems only desirable at the entry point to the FLS Glen Prosen holding.
14. We are pleased to see that FLS is working in partnership with the River South Esk Catchment Partnership. Improving river quality and ability to mitigate floods will deliver many benefits in the years to come.
15. There is no mention in the consultation Plan documentation of the Land Management Plans proposed in the Land Reform (Scotland) Bill currently before the Scottish Parliament, and which is likely to come into force within the next 5 years or so. The Bill provides that statutory Plans must include information on:
    • the long-term vision and objectives for the management of the land, including high level management proposals and potential for future sale,
    • how the landowner is demonstrating compliance with existing obligations relating to land (such as those in the Outdoor Access Code and Deer Code) as applicable, and how the landowner is managing or intends to manage the land in a way that contributes towards achieving net-zero emissions targets, adapting to climate change and increasing or sustaining biodiversity"

Moreover, "the Land Commission recommended that the requirement for land management plans would address risks identified in their work on large scale and concentrated landholdings", and Ministers are expected to issue regulations further defining requirements for such statutory plans (paras 76 et seq. in the Bill´s "Policy Memorandum", https://www.parliament.scot/-/media/files/legislation/bills/s6-bills/land-reform-scotland-bill/introduced/policy-memorandum-accessible.pdf).

Not all these items are mentioned in the consultation Plan. Attention is drawn to discussion of these statutory Plans in the Net Zero, Energy and Transport Committee session of 11 June 2024, including explicit mention by the Chairman of a Plan for Glen Prosen: see about 9:53 a.m. within that session ((https://www.scottishparliament.tv/meeting/net-zero-energy-and-transport-committee-june-11-2024)

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