To: Debbie Greene
Sent: 4 May 2015
Subject: RSPB Scotland’s planting plans for Abernethy
I am very concerned about the impact that RSPB Scotland’s planting plans for Abernethy will have on the authenticity and naturalness of the Caledonian Pinewood there. By (1) requiring RSPB Scotland to conduct an EIA, and (2) subsequently granting consent – FCS and SNH implicitly acknowledged their authority to withhold that consent.
The case for planting is weak, relying on RSPB Scotland’s misrepresentations about the condition of the Caledonian Pinewood – which FCS and SNH appear to have accepted at face-value. Both Stuart Housden and Jeremy Roberts have (rightly) boasted about how well the pinewood is regenerating while claiming full responsibility for 800 hectares of regeneration. And, in my superficial survey of 2013 I saw that Birch, Willow, Rowan, Juniper, and Scots Pine seedlings of all ages are well represented across the consent area.
In your letter to Adam Watson of 17 July 2014 (as it appears on the Caledonian Foresters website) you wrote :
Our advice to FCS on this case reflected our assessment that the plan will benefit the Caledonian Pinewood qualifying interest of the Cairngorms SAC, the native pinewood notified interest of the SSSI, and delivery of the SSSI management objectives
Can you explain (1) how the Caledonian Pinewood at Abernethy ‘will benefit’ from planting – when by definition – planting will reduce the designation of the pinewood from Caledonian to merely Native ?
I assume that you are aware of the ‘precautionary principle’ – the following is a direct quote from the SNH website :
SNH interprets the precautionary principle to mean that where there is uncertainty over the consequences of an activity ‘full scientific proof of a possible environmental impact is not required before action is taken to prevent that impact’.
SNH’s view is that where there is a risk that proposed activities might have a significant and irreversible impact on important natural heritage resources, a precautionary approach should be applied.
Can you explain (2) how you overcame the presumption of the ‘precautionary principle’ to ‘prevent the impact’ that RSPB Scotland’s planting plans for Abernethy will have on the authenticity and naturalness of the Caledonian Pinewood there ?
Joe Dorward
Bracknell
Letters, etc. 