Thursday 16 December 2021


Please find below, in full, the Scottish Gamekeepers Association's response to the Cairngorms National Park Authority's consultation on the draft Park Partnership Plan for the next 5 years.

Please note: only sections directly relevant to our membership were submitted.

The draft plan can be found, here:

A2: Increasing woodland cover, where it is the right thing to do, in full discussion with those directly impacted and in consideration of their aspirations, is a worthy enough aim for a Planning and Access authority. However, the Park’s explanations for why woodland expansion is an objective, in itself, requires more detail, given potential implications.

The ‘trees for climate’ argument, for example, is an over-simplification of a multi-faceted process. 

The right tree, right place reasoning is good but, on the ground, what assessments are actually being made by the Park to establish what is right in each circumstance? Insufficient work has been carried out in Scotland as a whole to identify where tree planting/regeneration will have definitive carbon benefits. This James Hutton Institute mapping system of woodland expansion would suggest the carbon benefits of increasing tree cover in the National Park in recent times, for example, is moderate

Nationwide, not enough work has been done on soil carbon or identifying which part of the habitat is sequestering the carbon. Is it always the trees or is it the ground vegetation, in many cases, heather, which is sequestering the carbon? There are many unanswered questions.

The work by Nina Friggens et al, 2020: ‘Tree Planting in Organic Soils does not result in net carbon sequestration on decadal timescales’ should represent a ‘foot on the ball’ moment for upland researchers, in order to avoid hurtling down a blind alley.

Given the implications, the Park must be honest about the rationale, science and data driving this aim, including how it is able to judge that trees are the right option on a given piece of land. All land is different, even if the Park, itself, is large.

Biodiversity can be enhanced by tree regeneration/planting but not in all cases. Generally, woodland species are faring better in Scotland, in line with increasing tree cover nationally. In contrast, open habitat species in the uplands are declining. 

Choosing more woodland over more open habitat is a choice, therefore. The choice being to provide greater habitat extent for those species currently faring better, while fragmenting habitats acknowledged as necessary for species in decline in upland areas. 

The mountain hare, now fully protected, has been proven to decline upon tree canopy closure and red-listed wading birds avoid habitats close to areas of afforestation. This is due to the impacts of predators (‘edge effects’) which have extended cover from which to emerge and hunt prey. It is a choice, therefore, to shrink the habitats of birds and mammals who require open upland habitats. The Park must be honest about these trade-offs, what will be achieved and why it is promoting changing the present habitat make-up of the park to deliver that choice.

Mountain hare on managed moorland in snow.
Mountain hare by Freck Fraser

While the Park’s woodland expansion aspiration will benefit some, it will negatively impact others, directly. The promotion of more woodland, without fences, for example will continue to reduce the income of businesses who rely on providing deer stalking experiences for visitors because the sporting quarry, deer, will continue to reduce in number. It should be noted that there are already areas across the Park with much lower deer numbers due to unprecedented heavy culling in un-fenced forests.

Deer stalking brings economic, community and environmental benefits. The Park must think carefully about promoting an aim which will directly impact estate/shoot income at a time when some poor shooting years and Covid 19 have impacted these businesses financially. The Economic factsheet accompanying the consultation also makes clear the economic impacts of the pandemic on the Park (14.8% shrinkage in 2020).

The recent Scottish Government report into grouse shooting socio-economics (2020) described deer stalking as a highly marginal activity in terms of income which nonetheless provided many wider community benefits. It should also be noted that, elsewhere in this consultation document, the Park is considering funding deer management training. Perhaps money could be saved by keeping the existing experienced deer managers, within the Park, in employment?

Like Scottish Government, the Park must quickly grasp how close the increasing burden of regulation/policy is to eroding confidence and investment in the Scottish game shooting sector. 

Jobs are increasingly dependent upon policies which will sensibly balance peoples’ need to make a living with the wider benefits accrued from that employment. SGA members have managed more deer in the last decade than any other representative organisation in Scotland (over 1 million deer). The biodiversity benefits of this should not be forgotten by those shaping policies which could further undermine their economic viability. Deer managers and their jobs (and game managers) make up an interwoven element of the Park’s cultural heritage which cannot be readily sacrificed. Indeed, their contribution outlasts, by more than a century, the very formation of the Cairngorms National Park itself. This is relevant, given the Park’s over-riding founding aim: to enhance the natural and cultural heritage.

A3: Agree, although the Park should gather relevant science/data on carbon/methane budgets on restoration sites, before and after work is carried out. While peatland restoration can assist a site’s ability to sequester carbon, not all restored sites become carbon sinks. Whether they do or not is regulated by several site-dependent factors, so relevant data should be gathered. 

A4: As a body whose statutory functions encompass Planning and Access, the ability of the Park to enact this aspiration will require legislative change. Further, Scottish Government has indicated that it intends to follow the recommendations of the Deer Working Group report which is for a density of 10 deer per sq km across Scotland. Advocating its own different deer density would mean the Park promoting population levels at odds with every other region of Scotland. This is confusing and unworkable in a practical sense. Please also see response to A2 and the trade-offs inherent in pursuing this, if the Park acquires the statutory powers to do so. 

A5: As a body whose statutory functions encompass Planning and Access, the ability of the Park to enact this aspiration will require legislative change. The consultation document states that the Park only has ‘patchy’ data regarding the extent of gamebird releases within the Park. The sustainability or otherwise of gamebird releasing, therefore, is not known. We would suggest this is an irresponsible rationale for adopting a strategic policy position which would involve the use of public funds and has implications for employment of residents which the Park serves.

Game shooting and farming represent highly significant income generation within the Park’s boundaries as well as other benefits. Subjective evaluations of certain activities founded on information gaps is not a foundation for policy, given the Park’s duties to its residents and businesses. If the Park wishes to evaluate its data (when it is acquired) against a benchmark, it should consult the Code of Good Shooting Practice which is well recognised throughout the industry as the barometer of standards. 

In terms of reducing the ‘intensity’ of grouse moor management and encouraging lower density grouse shooting, Scottish Government intends to introduce a licensing system. Upon gathering evidence, it regards this as a proportionate response to concerns voiced from outwith the sector.

While we share the Park’s aspiration for raptor persecution to reduce further than it has in recent years, the need to tackle ‘intensity’ of management did not feature as a prominent focus of Professor Werritty’s review of the sector, based on all the panel evidence and scientific research. The socio-economic and biodiversity reports which accompanied the Werritty inquiry, clearly indicated that some species benefit from grouse moor management while others don’t. This is similar for all other land uses. Indeed there were more benefits for the species of flora and fauna studied than there were negatives. 

Driven grouse moors were the biggest employers of all moorland land uses studied in that report, something which is relevant to the Park. Proposing a move towards walked-up grouse shooting (presumably the desire of the Park in this section?) means the Park would be promoting an activity which, according to the Government reports, sustains far less employment and investment; investment which also has a return for species conservation and habitat management on many of the Park’s designated sites.

A recent income/outgoings survey by Scotland’s regional moorland groups found record downstream spending by grouse estates in their communities in 2021, despite a very poor grouse breeding year (£600 000+ spending per estate, on average). Given that the Park has been hit substantially by the pandemic, and the aforementioned points, would it not be appropriate for the Park to follow Scottish Government’s line on grouse moor licensing rather than promote a divergent policy aim which could further destabilise local economies in parts of the Park where grouse shooting is important?

A6: The impact of fires in the upland landscape, and the damage they can cause, is determined principally by fire severity, regardless of whether they occur on deep peat, shallow peat or non- peaty soil. The peat is, therefore, not the key issue in fire behaviour. Severity of fire is determined by conditions (ie: prolonged dry conditions), ground moisture and fuel loads. 

High severity fires (wildfires) usually occur where surface vegetation (fuel load) is high and conditions and ground vegetation is dry. High severity fires can cause long lasting damage to habitat and important wildlife breeding sites. If high severity wildfires occur on peatlands, they can damage the functional ability of the peatland to sequester carbon and can burn down into the peat layers, releasing significant amounts of greenhouse gases. These fires can threaten property, they have resource implications for emergency services and can burn for extended periods over extended distances. Summer wildfires at Moray and the Flow Country in 2019, which exhibited all the above factors, released 1m tonnes of carbon and were the worst ever on record. Avoiding this scenario is important in future, particularly in a changing climate where fire seasons are longer.

Those at the heart of fire science acknowledge that well managed muirburn or prescription burning is very different to high severity fire or wildfire. It is carried out by skilled gamekeepers and farmers with knowledge, experience and the right equipment. It is a low severity fire, whether it is undertaken on deep peat, shallow peat or non-peat soils. Done properly, it removes surface vegetation, leaving mosses and understory plants either untouched or in a state where they recover quickly following fire. These fires do not burn down into the layer below the understory ie: where peat will be forming, if the habitat is a peatland. Again, peatland is not an issue in the behaviour of the fire itself. Also, muirburn is carried out at a time of year where the surface conditions enable lighting of fire, but the understory will be wet.

Well managed, the fires will break up monoculture vegetation, will provide nutritious food for sheep, deer and grouse (amber listed) and breeding cover for red-listed birds. Well managed, low severity, fires work well as a wildfire mitigation tool and is internationally recognised as such. Similarly, research undertaken by Climate XChange scientists in Scotland suggests the carbon released into the atmosphere in the process of muirburning is neutralised by the vigorous regrowth of vegetation. This is important.

In our view, therefore, policy makers should be prioritising how we reduce high severity fire and ensuring that those who are licensed to undertake managed muirburn (low severity fire) can do so safely, effectively and beneficially. For this, we would recommend training and the SGA is more than happy to help Scottish Fire and Rescue Service to lead on this and deliver. Our members possess centuries of accumulated knowledge in this and are a resource Scotland is lucky to have.

Rather than fixate on depth of peat, which fails to focus on how fires actually behave, focus should be on vegetation structure/ fuel load, conditions under which fires are set and the provision of training to ensure practitioners can deliver the many benefits which good muirburn can bring, in terms of biodiversity, creating fire breaks across the landscape and, something which is increasingly recognised: helping to retain stored carbon for longer in peatlands. See:

In our view, the Park should follow what Scottish Government produces in terms of a new muirburn licensing scheme. However, it is encouraging to see the Park recognise that it must also have a wildfire prevention plan in place. For the reasons above, the SGA believes that well managed muirburn, by trained and licensed professionals, should form a key plank of that future planning. 

The Park contains many contiguous areas where fuel loads are high. It also welcomes many visitors. An analysis of Scottish Fire and Rescue Service data logs, between 2009 and 2019, showed that accidental fires which the service attended were caused by members of the public (nine tenths of all Scottish fires attended) and were not related to land management activity. These factors, and lengthening fire seasons due to changing weather patterns, makes it essential for the Park to carry out wildfire mitigation.

Following the Moray fire, Park officials were told by the Scottish Fire and Rescue Service that such mitigation must include access to water, good access across land for fire crews and fuel load management. We welcome that the Park are taking the threat of wildfire seriously and hope that the input of practitioners, with long experience of how fire reacts in upland landscapes, will be sought when these plans are formulated.

Should the Park seek to introduce heightened restrictions on muirburn which will prevent gamekeepers and farmers from being able to carry out the work they rely on for a living, it should do so in the full knowledge that it will be reducing its own resilience to wildfire.

Not only will it lose the provision of firebreaks and active fuel load management, it will remove the incentive for shoots and farms to continue to hold expensive equipment and invest in training. Many estates within the Park are registered with Scottish Fire and Rescue Service to provide help during wildfires and this voluntary service will be compromised or lost.

A9: We agree on river restoration work but feel there is a need, in the interests of salmon conservation, for the Park to take an active role in addressing water abstraction from the Spey system which has risen at a rate which is no longer sustainable. The two elements should go hand in hand if the Park is serious about wild salmon conservation.

A10: Connecting habitats is commendable but, in pursuing this, the Park must be realistic with the public and residents about what it is attempting to achieve from it. Connecting habitats will not always produce nature restoration, for example. Other elements must be considered in tandem rather than this being an outcome in itself. Habitat connection provides corridors for wildlife but also for the predators of wildlife (and corridors for visitors). Without active predation management to keep that inter-relationship in some form of balance (in a landscape shaped by humans), this can have negative impacts upon prey species found at much lower densities than the predators which eat them. The failing attempts to save the Capercaillie in the remaining core forests of the Park is a costly case in point.

The Park must also do more to research the impacts of un-managed human (and pets) access on sensitive wildlife habitats. The strides taken in promoting the park must be commended. However, this does not always produce the right results for wildlife, whether large sums of public money are being used for connecting habitats or not. There are longer-running National Parks across the world which have recognised that high visitor numbers, while opening up wild attractions to humans, have negative impacts on wildlife and that interventions are necessary to restore a relationship which has gone too far one way. Everyone recognises the physical and mental health benefits of outdoor recreation but there must also be a recognition that wildlife may suffer as a result of increased human presence. 

A14: See answer to A10.

A15: Private green investment, where it meets a strategic target and its impacts can be measured, can be positive. Analysts suggest this market is currently suffering from lack of proper regulation and that many schemes will ultimately fail to provide the benefits promised for land, climate or local communities. 

If the park is to chase green finance for climate mitigation reasons, and wants to protect the Park and its residents, it must acquire, firstly, a detailed understanding very quickly of the soil carbon potential it currently has across the park’s landscapes, to ensure new schemes will deliver benefit. This will limit the risk of the removal of benefits which are currently there. If this cannot be measured or tested in any way, the Park is effectively at the mercy of companies or agencies speculating in the carbon market.

The Park must consider its responsibilities to its inhabitants when promoting green investment programmes. Poor programmes can displace current land managers and businesses and reinforce inequality if there is not a suitability test which can help protect peoples’ interests.