Ken Thomson & Dave Windle

Q1: the vision and opportunities for forestry over the next 20 to 100 years?
Comparisons with Scotland as a whole (e.g. relative shares of forest cover), while interesting, are not a good basis for planning within the Park, which should be setting more ambitious standards.

We feel that the biodiversity of commercial plantations is often over-stated, as are their employment prospects, especially when worker mobility and machinery advances are taken into account.

There is a mismatch in timescales with a 20- and 100-year strategy stated to help deliver elements of a 5-year plan. The strategy needs to stand in its own right, perhaps with a short-term implementation plan going beyond the overall five-year woodland creation target of 1000 ha per year.

The vision needs to emphasise the role that forests can play in natural flood management both within and beyond the Park boundaries. In addition, it should promote a clear preference for natural regeneration rather than by planting. This can be achieved by e.g. eliminating muirburn in specific areas, allowing existing forests to expand.

Deer are mentioned in the 2118 vision (as "Cooperative deer management has enabled deer numbers to increase again") but not in the 2038 one; this leaves it unclear how they should be managed in the medium-term future, when new plantings and natural regeneration are hoped for. Why does the vision for 2118 talk of increased deer numbers? - Surely the objective is to get the numbers down and then maintain a lower stable population with balanced deer stalking removing the right number of animals every year?

Q2: the 10 strategic objectives and their rationale?
These objectives are weak, very general and could apply to many areas. The special qualities of the Park need to be explicitly recognised. For example, almost no special mention is made of the remnants of the Old Caledonian Pine Forest. The Cairngorms are particularly important as these fragments are essentially untouched by man and have regenerated naturally since the last Ice Age. They are a key feature of the many protected area designations covering the area, are of international importance, and should receive special mention.

Only one of the objectives is dated and quantified, i.e. to increase forest cover by 1000 ha per year for five years. This seems to be arbitrarily based on a proportion (10%) of the national target of 10000 ha, when the Park occupies only 6% of the national land area. In any case, an area objective depends very much on its composition between planted forests intended mainly for commercial timber, and others - whether planted or naturally regenerated - intended largely for environmental purposes, e.g. landscape, recreation, wildlife and/or carbon storage.

The strategy should recognise more explicitly the Park Authority's limited powers in this area, than simply by its frequent use of "encourage" or "promote".

Q3: the above policy guidances on integrating woodland creation with other land use?
As is pointed out, moorland managed for grouse shooting covers approximately 40% of the Park, a major proportion. It is a disgrace that the best that current grouse moor management practice can do is to "achieve some regeneration along roadsides". Elsewhere, as noted (page 25), "In some locations isolated native trees have been deliberately and systematically removed to expand moorland habitat." Targets should be set for all moors to stop muirburn over, say, 5 - 10% of their area, the areas least suitable for rearing grouse, in order to allow trees to regenerate. Increasingly, such management involves the establishment or "improvement" of unsightly hill tracks and roads. In general, replacement of grouse moor by tree plantations hinders access and reduces long-distance views but could be encouraged where these disadvantages are reduced or offset by careful design of any new plantations. We endorse the stated guidance (in 4.1) that "Natural regeneration of native tree species should be encouraged on the forest-moorland margins to provide an increase in habitat diversity and woodland connectivity to benefit a wide variety of species."

The Park should work with developers and the Forestry Commission to ensure that all tracks and borrow pits needed for proposed new forests are included in initial forestry plans, rather than being introduced on an incremental basis at later stages.

We regard the guidance on forest felling to be relatively weak; such work too often results in many years of almost complete inaccessibility on foot of previously felled areas now covered by brash and/or crossed by deep ruts caused by heavy machinery, with minimal attention to restoring churned-up tracks or removing metal, plastics, etc. abandoned during felling operations.

As far as deer are concerned, we are very doubtful that "Collaboration between neighbouring deer managers to achieve deer densities compatible with woodland regeneration is encouraged" will be sufficient as "guidance" and believe that much stronger regulation of deer management will be necessary. The existing system of Deer Management Groups has failed, as acknowledged recently in Holyrood, where the Secretary made very clear her dissatisfaction with the current situation. Status quo is clearly no longer an option. The document needs to align itself with the modern need to really manage deer numbers and be ready to take on board the recommendations of the Deer Working Group, which should be mentioned. We are disappointed that the guidance on fencing for woodland creation (page 21) makes no mention of recreational access into these areas.

We strongly support the guidance (page 21) that "Early and thorough consideration should be given to the positive and negative landscape impact of new woodland, especially in wild land and other sensitive areas"; and that "New woodland should be designed to enhance perceptions of naturalness and wildness in the landscape in the long term and to keep short term negative visual impacts to a minimum."

Q4: the above policy guidances on habitat enhancement?
We strongly support the "corridor/network" strategy, though we are more doubtful of riparian planting except where part of large-scale schemes.

We are also in favour of identifying and protecting/enhancing remnant and semi-natural ancient woodlands, which often have cultural as well as wildlife importance.

Q5: the above policy guidances on rural development?
We are doubtful that "There is huge (sic) potential in the National Park to invest in a forest resource that will provide local employment and increase opportunities for future enterprise from marketing and refining local forest products" (page 29).

Q6: the above policy statements on forests and people?
We are strongly supportive of the guidance in this area, though some separation of walking and cycle access should be considered as part of any forest plan, with cycling (and horse-riding, where appropriate) banned by reference to "responsible usage" where this might cause unwelcome damage to footpaths and surrounding surfaces. It is also important to provide and maintain views, since the "tunnel" experience is generally unwelcome.

There is a need for long-term forward planning of recreational access, including paths, fence crossings (accepting that fencing is inevitable with inadequate deer control) and viewpoints/lookouts, especially where large areas of dense forest are envisaged. It may be useful to examine experience in SE Queensland, New Zealand and the USA, where trail-walking rather than roaming freely has resulted in a different type of recreational use.


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