Joe Dorward to Debbie Greene (SNH)

From: Joe Dorward
To: Debbie Greene
Sent: 2 July 2015
Subject: RSPB Scotland’s planting plans for Abernethy

Debbie,

Thanks for your reply of 25 June 2015.

While the following may appear patronising or condescending – no nastiness of any kind is intended.

I am not alone in asserting that the decision to allow RSPB Scotland to plant trees within the de facto Caledonian Pinewood at Abernethy is a self-evident catastrophe for its authenticity and naturalness.

About 9,000 years ago, seedlings of the species we call Pinus sylvestris var. scotica began growing in the area that SNH designated Abernethy Forest SSSI. These seedlings grew to become part of (what, since ancient times, was known as) the Caledonian Forest. Various causes led to the fragmentation of that forest into primarily-deciduous and primarily-coniferous woodlands.

While Caledonian Pinewood may not be a statutory-designation, it must surely be a logical-designation, since it features in the title of the FC publication Caledonian Pinewood Inventory (1998) and since the Caledonian Forest is no-more, it makes sense to stop referring to it (except in a purely historical context) and – instead – refer to the remaining primarily-coniferous fragments as Caledonian Pinewoods.

There can be no doubt that the Caledonian Pinewood at Abernethy is authentic and natural and (to paraphrase the JNCC definition) it is relict Pinus sylvestris var. scotica, self-sown, naturally regenerating, genuinely native, local origin pinewood.

The existing trees of this pinewood are the latest links in an unbroken chain of natural evolution connecting them to the first seedlings to grow there 9,000 yeas ago. It is this Caledonianess that makes the pinewood scientifically valuable. It is this Caledonianess that makes Nature the only scientifically justifiable agent in the regeneration and expansion of the pinewood. It is neither the number of trees nor the extent of the pinewood that makes it scientifically valuable. Planting will increase the number of trees and extend the pinewood, but, by breaking the chain of natural evolution it will also diminish the authenticity and naturalness of it – it would become merely ‘Native’ rather than ‘Caledonian’ because ‘self-sown’ is an essential clause in its definition.

During their first decade at Abernethy, RSPB Scotland would have agreed with the foregoing. One need not be much of a researcher to find unequivocal, published statements by them referring to ‘purely natural regeneration’ and ‘no planting or fencing’. But sometime in the early 2000s they appear to have changed their mind – for whatever reason – they are prioritising increasing the number of trees and extent of the pinewood over authenticity and naturalness. Recently, as a direct result of RSPB Scotland’s own actions to reduce red deer numbers, 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. Elsewhere, RSPB Scotland make contradictory ‘struggling to survive’ claims about the condition of the pinewood.

Looking on the SNH website – I note that ‘It is an offence for any person to intentionally or recklessly damage the protected natural features of an SSSI’ and on Sitelink – I note that for Abernethy Forest SSSI that the ‘Coniferous woodland’ is a ‘Notified feature’.

1. How can it be that the RSPB Scotland’s planting within the Caledonian Pinewood at Abernethy is not causing ‘intentional or reckless damage’ to this ‘notified feature’ when planting is contrary to the essential clauses defining it ?

2. If the scientific value of the Caledonian Pinewood at Abernethy is its Caledonianess and not the number of trees nor the extent of the pinewood – then how can planting ‘benefit the statutory natural heritage designations’ when planting is contrary to the essential clauses defining it ?

In your answers please provide references to Policy and Procedure documentation that will enable me to understand the steps in the process by which SNH arrived at the decision that planting ‘will benefit the statutory natural heritage designations’ of the Caledonian Pinewood at Abernethy.

For the avoidance of doubt – please avoid justifying or defending the SNH decision. I merely want to know how and why SNH came to approve the planting-plan rather than reject it because it involves planting. I would not have guessed that RSPB Scotland could ever be permitted to plant within the Caledonian Pinewood at Abernethy.

It appears self-evident that the approval of the planting-plan was an error, that was either (a) an error of judgement / interpretation etc. within SNH, or (b) an error of policy / process – that given the process SNH is required to follow, that SNH could only have given approval, or (c) subversion – that (in spite of knowing and understanding the foregoing) that the SNH policy / process (that would have led to the rejection of the planting-plan) was subverted with intent, to enable RSPB Scotland to do what they want within the Caledonian Pinewood at Abernethy. Either way – the decision process should be repeatable – you should be able to show me how (given knowledge of SNH policy / procedure) I would reach the same conclusion.

I have not seen a letter by you to Adam Watson dated 14 July 2014 and would very much appreciate seeing it, but if you mean the one dated 17 July 2014 – I have seen that. I referred to it and quoted from it in my first email to you.

Joe Dorward
Bracknell

Debbie Greene (SNH)

Joe Dorward to Debbie Greene (SNH)

From: Joe Dorward
To: Debbie Greene
Sent: 31 May 2015
Subject: RSPB Scotland’s planting plans for Abernethy

Debbie,

Thanks for your reply (of 4 May 2015), but you did not answer my questions. I should have realised that my use of ‘definition’ and ‘designation’ was ambiguous and was likely to lead you to incorrectly infer that my questions were about SNH’s statutory / official definitions, designations, policies, and processes.

In fact, my question :

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 ?

was entirely a question of logic, and based on the fact that the Caledonian Pinewood at Abernethy is both ancient and natural (not planted) and by logical-definition Caledonian by the definition to which you referred : ‘Relict, indigenous pine forests of Pinus sylvestris var. scotica‘.

The existing Scots pines of the Caledonian Pinewood at Abernethy are directly descended from the first Scots pines to arrive in the area after the last Ice Age. It should go without saying, but often does not, that the other tree species in this ancient and natural pinewood are also directly descended from the first of their species to arrive in the area after the last Ice Age.

Until SNH and FCS colluded to permit RSPB Scotland to plant there, the Caledonian Pinewood at Abernethy was both ancient and natural (not planted). No matter the provenance of any nursery grown seedling – the planting of any seedling of any tree species within the de facto expansion zone of the Caledonian Pinewood at Abernethy, by logical-definition, for ever reduces the logical-designation from Caledonian Pinewood to merely Native Pinewood.

I accept that SNH’s statutory / official definitions, designations, policies, and processes do not recognise the harm of planting in the Caledonian Pinewood at Abernethy, but (in the context of the foregoing) (1) can you explain how the Caledonian Pinewood at Abernethy ‘will benefit’ from planting given that (a) it was already regenerating and expanding (naturally), and (b) its logical-designation will, by logical-definition, be reduced from Caledonian Pinewood to merely Native Pinewood ?

Joe Dorward
Bracknell

Debbie Greene (SNH)

Joe Dorward to Debbie Greene (SNH)

From: Joe Dorward
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

Debbie Greene (SNH)

Adam Watson to Debbie Greene (SNH)

From: Adam Watson
To: Debbie Greene
Sent: 17 July 2014
Subject: SNH approval of RSPB application to plant trees in South Abernethy

Dear Debbie

Many thanks for your letter and for sending the attachments.

I should explain that although I have publicly criticised the decisions of SNH and FCS to approve the RSPB’s application to plant many trees in Abernethy south, and shall continue to oppose this planting and the decisions, I am not the main critic involved. I wrote to Des Thompson about this matter last August, and was surprised to learn that he had not heard of the SNH approval until I told him. He replied that he would look into this matter, and this is why I wrote to him recently asking for clarification of SNH’s role and his role within SNH on this issue.

You have sent useful information, but I still believe strongly that the RSPB should not have done this U-turn and that SNH and FCS have made a serious error of judgement in approving large-scale planting. You should of course know the obvious point that any planting is bound to change the genotype, which has evolved naturally for millennia, in unpredictable and unnatural ways. This alone, as well as other reasons, was a clear warning to avoid large-scale landscape gardening, irrespective of any human political rather than scientific new policies on pinewood expansion, and irrespective of any support for these by governments.

However, as I said earlier I am not the main person involved in criticising this case, and therefore I will not be taking up your offer of a meeting. Likewise I will not be continuing further with this correspondence and hearing any further inadequate excuses from SNH for deserting long-established policies on natural regeneration in favour of planting that has not been justified and flies in the face of the RSPB’s own findings on natural regeneration. I shall therefore forward your letter and attachments to others. I remain a scientific adviser to them.

Adam Watson
Crathes

Jeremy Roberts (RSPB) to Keith Duncan (SNH)

From: Jeremy Roberts
To: Keith Duncan
Sent: 5 September 2008
Subject: Tuesday’s mtg

We are seeing the latest draft from Dietrich next Wednesday, and meeting with him on 15 Sept. I’d like to say we’d turn around the final draft by end of Sept, but I think that’s being optimistic. We want to lodge a statement of intent (RDC) for forest expansion by the spring, so we need to have it through the consultation process by then.

Jeremy Roberts
Abernethy Nature Reserve

Jeremy Roberts (RSPB)