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

Basil Dunlop to George Campbell (RSPB)

From: Basil Dunlop
To: George Campbell
Sent: 9 March 2014
Subject: Abernethy South planting

George,

Thank you for your response to my email and attachment. While I mentioned the SoC was outdated, that does not mean invalidated. It is over 8 months old, and concentrates on the previously agreed policies. Now the emphasis is on the responsibilities of the statutory authorities to safeguard the naturally regenerated boreal forest remnants, taking account of subsequent discussions with RSPB.

As for your promised comments on the Statement of Concern, yes, we would still like them, if only to understand the reported statement to the Sunday Herald by Stuart Housden that “the report is wildly inaccurate and makes many unsubstantiated claims in the absence of facts”, but no examples were given. Also your own “assumption and speculation”. Considering the SoC was based on and quoted official policy documents and published reports, we would like to know what RSPB considers wildly inaccurate and unsubstantiated.

In paragraph 2 you claim that the other authors and RS had no insight into what you were planning to do. On the contrary, I sent them copies of EIA maps J32 “PROPOSED LOCATIONS of PLANTING POLYGONS for ENRICHMENT PLANTING and J33 PROPOSED LOCATIONS of PLANTING POLYGONS for PIONEER PLANTING, and explained the basic concept. They felt that ANY planting was unjustified as it compromised the integrity of this hitherto naturally regenerated part of the Forest, and was contrary to all the previously stated and agreed principles and policies of the Caledonian pinewood remnants. The context of RSPB thinking was immaterial. Incidentally the Pioneer Planting of cells of pine to act as future seed sources mirrors the recommendations I made in my 1988 report* to the RSPB on the way to expand the forest, except that I advocated the protection of cells of existing natural regeneration, in view of the unnaturally heavy browsing of deer and sheep in the area at that time.

As to making contact with you, in 2011 the three statutory authorities were well aware of my concerns from my letters, before approving the EIA, but seemingly dismissed them. They did not even inform me when they had unexpectedly approved the EIA, despite knowing that I was a well known and respected authority on native pinewood issues and knowing that I was likely to react in an adverse way to their decision. Such secrecy of decision taking in the use of public funds is unacceptable.

I am pleased to note in para. 3 that natural regeneration remains your principal policy objective at Abernethy, but non-adherence now and again cannot be justified in any circumstance in such a rare and fragile part of our natural heritage, except perhaps in a last resort, which does not apply to the disputed area in Abernethy. It is the failure of the agencies to adhere to their own stated policies which is the issue. We accept that they are not able to rescind their approval, which is why we will continue in our efforts to persuade the RSPB to voluntarily refrain from implementation of the most contentious elements.

Your position as stated in para. 4 is difficult to understand, when you say you “do not recognise” OCP as a designation, or “what that actually means”. Paragraph 1 of the introduction in our paper clearly defines it. We assume you accept designations under the Caledonian Pinewood Inventory and many other FCS and other documents, so it must be the word “Old” which causes a problem. This is merely a descriptive adjective to emphasise its age, to avoid confusing it with “new” planted pinewoods. (It was used in my 1988 report* to the RSPB). We do not accept that you can claim it is in favourable condition when you seek to plant in it, and the domestic and European objectives indicate planting should only be a last resort, i.e. when there is no alternative. We are concerned for other remnants, but no other ancient pinewood site is as important as South Abernethy and its neighbours on the foothills of the Cairngorms.

In paragraph 5 you dismiss our case as opinion, but it is based on fully quoted facts, so interpretation would be a more appropriate description. We note you do not disagree with their advocacy for natural regeneration. As to your comments under Para. 7, you take this completely out of context. It is made abundantly clear in all our statements, especially the introduction to the paper under discussion, that the subject is confined to the enrichment and pioneer planting proposals in the most natural extremity of Abernethy South (i.e Ryvoan and Strath Nethy), and the anomalies in existing legislation. It has nothing whatsoever to do with the rest of Abernethy or its management and maintenance. Indeed, I am on record as praising RSPB in this respect.

Reference the other comments numbered

7 We understand that the funding was awarded because RSPB stated regeneration would be by natural means. This could be regarded as a condition, though it is agreed no formal conditions were stipulated..

11 We have evidence of extant non-pine potential seed trees and regeneration in the Ryvoan and Strath Nethy areas. Your own surveys record there is ample natural Scots pine regeneration..

12 Our reference is to planting in the far South of the pinewood, and the map I produced and tabled included the parts you mention elsewhere, coloured yellow.

16 We accept that this was the former title which has now changed, and apologise for the error.

Regarding your penultimate paragraph, we believe that RSPB is in fact in a position to help persuade the statutory authorities, especially FCS, that changes in policy and processes are necessary, especially regarding grants, definitions and protection. This would also influence other OCP owners of the need to adopt natural systems, and avoid interventions such as planting except as a very last resort.

Obviously we believe this is the most important conservation campaign in Scotland right now.

Basil Dunlop
Grantown-on-Spey

* Reference: “Report on the Future Management of the Abernethy Forest Estate as a Nature Reserve” for RSPB by Forest Conservation Services, 1988.

Drennan Watson to Dave Morris

From : Drennan Watson
To : Dave Morris, Basil Dunlop, Adam Watson, Dick Balharry
Sent : 9 April 2013
Subject : Restoring the Caledonian Forest

The problem Dave has highlighted is a general one with the Cairngorm National Park Authority staff. They seem to have no knowledge of all that has gone before in the Cairngorms and what has been learned. They also show a remarkable lack of practical experience. Getting planted trees established on the open hill – or in fact almost anywhere – without protection from browsing / and or weed competition is very difficult. I have lost count of the failed plantings of broadleaves I have seen in Forestry Commission schemes. Also, they need to learn from other key bodies of information elsewhere – e.g. on Mountain Management, Lessons on Sustainable Tourism from the Alps etc., and other bodies of knowledge. Not only have they not done this but they show no awareness of the need to do so. There seems to be no proper staff training programme recognising that they are asking staff to do a job that has never been done before in Scotland.

I think a good idea would be a report with multiple authors that explores the concept of a Caledonian Forest, (that is as a habitat, as ecological processes and as an assemblage of species). Some history of the attempts to restore OCP in Scotland and also input from people like Basil with their expertise on Scots Pine management, would make the kind of document with some impact. There is an educational job to be done with people like CNPA staff before you can persuade them of the correctness of restoration principles.

Drennan Watson
Alford

Basil Dunlop to Dave Morris

From : Basil Dunlop
To : Dave Morris, Adam Watson, Dick Balharry
Sent : 3 April 2013
Subject : Restoring the Caledonian Forest

When the Strathie first revealed the schemes for planting on Cairngorm to the public (November 2010), I wrote a letter (published 8/12/10) to express my disbelief, and then SNH, and corresponded with Keith Duncan. Unable to persuade SNH this was ill-conceived, in March 2011 I wrote to Andrew Thin (Chairman SNH), John Risby (Conservator, Forestry Commission Scotland), and Jane Hope (CEO CNPA) in similar vein. John Risby met me and we discussed the problem. He understood my concerns, but he felt FCS should support the various proposals as there was a need to expand and enrich the pinewoods and improve their condition now. He revealed there were other schemes in Glenfeshie and Abernethy involving EIA’s. Andrew Thin stated SNH staff were satisfied some planting was justified because it was not “within existing ancient woodland”. Jane Hope mentioned the proposals were consistent with pinewood policy and largely outwith the current native woodland areas. Statements apparently from an adviser showed ignorance of the importance of previous policies for the boreal forest remnants and expansion zones in forest ecology terms.

As I stated in a previous email, I inspected the RSPB plans regarding Ryvoan, but did not take further action as I felt I was getting nowhere, and they seemed to be put on the back-burner.

Basil Dunlop
Grantown-on-Spey

Dave Morris to Basil Dunlop

From: Dave Morris
To: Basil Dunlop, Adam Watson, Dick Balharry
Sent: 2 April 2013
Subject: Restoring the Caledonian Forest

The principles behind the Abernethy and Cairngorms National Nature Reserves were established many years ago (late 1970s) and those were based on the fact that the stretch of forest from Abernethy around to Glenfeshie is the largest tract of semi natural forest in the UK. Those principles were founded on the Steven and Carlisle approach – these forests’ key characteristic is that they have survived by natural regeneration from generation to generation. As far as I know those principles have not been changed, by SNH, RSPB Scotland or any other body (Mar Lodge is an aberration forced upon the NTS by the pressure of neighbouring landowners).

I think we need to make a firm stand here and insist that the original principles are stuck to. There should be no planting of any species, apart from in the immediate vicinity of Glenmore village and the intensively managed skiing areas of Coire Cas and Coire na Ciste. We all know what the problem is – overgrazing. The forest should be allowed to evolve naturally simply by controlling the numbers of grazing animals. No planting, no fences – we need to stick to that simple approach as we challenge RSPB Scotland, etc.

Dave Morris
Milnathort

David Bale (SNH) to Jim Dewar (FCS)

From: David Bale
To: Jim Dewar
Sent: 13 November 2012
Subject: RE: Glen Tanar

Jim

Thanks for getting back. I fully understand your reaction but could we have a quick chat about this tomorrow when I think you are back in the office? I can relate the conversation I had with Adam which will give you more context.

David

David Bale (SNH) to Bruce Luffman (CNPA)

From: David Bale
To: Bruce Luffman
Sent: 6 November 2012
Subject: RE: Glen Tanar

Dear Bruce

Thank you for your contact. One of my staff is looking at things this morning to see just what the issue is. From my understanding of what Adam Watson tells me, it sounds as though it is tracking from forestry machinery rather than the construction of tracks. Accordingly I do not think that planning consent is likely to be an issue here. I will be able to confirm one way or another once I hear how this morning’s site visit went.

David