This document is our response to the CNPA Draft Cairngorms National Park Plan. Members can see the full [huge!] consultation documentation at www.cairngorms.co.uk. The consultation is in two parts "Looking to 2030" and "Priorities for Action 2007 - 2012" and the response date was 30th June,

Introduction – who we are

The Mountaineering Council of Scotland is the representative body for hillwalkers, climbers and mountaineers in Scotland. We are a membership organisation with well over 2,000 individual members plus over 8,000 affiliated members via about 140 associated clubs, representing almost all Scottish mountaineering clubs. We have a longstanding concern to conserve and enhance the natural heritage of our mountain areas, demonstrated in our Access and Conservation Policies. These are available on our website under www.mountaineeringscotland.org.uk/council/policies.

OVERVIEW

The MCoS welcomes the opportunity to comment on the Draft Plan. Our concerns are with the landscape and access issues and whilst we are pleased with the overall commitment to conservation and restoration we do have a number of concerns.

In general we feel that although in Looking to 2030 the Montane Area is described as “a national asset at the heart of the park” not enough attention is given to the conservation and restoration of the montane landscape and this does not receive enough emphasis in the Draft Plan. Similarly we feel that the value of wild land and the need to protect and increase this is not prominent enough. The statement in Looking to 2030 headed “Conserve and enhance the wild characteristics of areas within the Park” should be a key statement rather than a subsection of a subsection (5.2.1 c).

FORESTS

The MCoS is in favour of the restoration of a natural forest and a natural tree line and supports the statement in Looking to 2030 5.4.2 d “encourage a gradation of tree and scrub cover from valley floor to tree-line in targeted areas”. We would like the “targeted areas” to be extensive and apply to all montane and wild areas.

VEHICLE TRACKS

Recent years have seen an increase in the number of bulldozed vehicle roads and ATV tracks in mountain areas and these have become one of the main causes of the degradation of the landscape and the loss of wild land qualities. Whilst the Draft Plan documents mention such tracks we do not think enough emphasis is given to the importance of preventing further construction and removing existing tracks. In Priorities for Action 2007-2012 it says there will be “restoration of the more unsightly landscape scars such as redundant vehicle tracks and eroded footpaths”. Which vehicle tracks will be determined to be redundant and what will happen to other “non-redundant” vehicle tracks? The MCoS would like to see a presumption against new vehicle tracks in the hills and a presumption for the removal of all high level tracks.

DEER

There are several references to deer management in the Draft Plan and the MCoS is pleased to see that the CNP recognises that excessive deer numbers can damage the landscape. We support the approach given in Looking to 2030 5.4.4 a & b. Again however we do not feel that enough emphasis is put on this or the need for a big reduction in deer numbers to counter the large increase that took place in the second half of the 20th century. This reduction should be with the aim not just of preventing further damage but also to allow habitat recovery both above and below the tree line.

LAND MANAGEMENT

There is much in the Draft Plan about land management and we are concerned that in mountain and wild areas too much “management” could damage the very qualities we wish to preserve. In these areas “management” should have as light a touch as possible, the main activities being reducing grazing pressures and removing bulldozed roads.

ACCESS

The MCoS supports open access to mountains and wild land. However the MCoS does not wish to see access made easier through the building and “improvement” of paths, other than repair and relocation where necessary, or the provision of signage in mountain areas as these detract from the wild and remote qualities of these areas. In Priorities for Action 2007-2012 4.2.7 the Outline Action Programme proposes there should be “steps towards an integrated system of outdoor signage”. This should not include signs in wild and mountain areas.

The MCoS does not favour the use of fencing to control deer (Looking to 2030 5.4.4 e). However if fencing is used frequent access points should be provided. This is not mentioned in the Draft Plan.

On behalf of the Mountaineering Council of Scotland
Chris Townsend
Member, Access & Conservation Committee
16 July 2006