022 Main Issue 10 - Sites of Local Nature Conservation Interest Response ID Respondent 4 Kemnay Community Council 24 Ms Dawn Gibbs 76 Dr. Edward Hugh Morel 111 Echt & Skene Community Council 415 Portlethen & District Community Council 571 Cruden Community Council 668 Mr and Mrs Ian & Rosemary Nicol 741 Mr Peter Rowbotham 809 Mrs Lucy Morel 860 Newtonhill, Muchalls & Cammachmore Community Council 928 Gourdon Community Council 956 Catterline, Kinneff & Dunnotar Community Council 1118 RSPB 1122 Ms Anne Mansfield 1150 Kincardine Estate 1235 Ms Rachel Shanks 1251 Ms Judith Cox 1255 Mearns Community Council 1325 Mr Stephen Paterson 1340 Fred Olsen Renewables 1353 Land Owner within zoned area (identity withheld by request) 1360 Banchory Community Council 1434 Crathes, Drumoak & Durris Community Council 1443 North Kincardine Rural Community Council 1445 Ms Christine Mechie 1467 Laurencekirk Development Trust 1477 Inverurie Community Council 1478 Ms Judith Smit-Haffmans 1520 Ryden LLP on behalf of Dunecht Estates 1597 Mr Revor Hodgeson 1619 Mr James Herd 1663 SITA UK 1703 Scottish Natural Heritage 1814 Mearns Community Council 1. Issues Preferred Option General Support General support was received for the preferred option set out in the Main Issues Report (004, 741, 1118, 1360, 1443, 1520, 1597, 1703). It is seen that this will further the conservation of biodiversity in Aberdeenshire. Support was also noted for the 95 Local Nature Conservation Sites (LNCS) that are currently listed as there is potential to enhance these with the green networks (1703). However, it was also noted that landscape conservation may be a more appropriate way of describing the natural and historical heritage that we should preserve. (741) There was also specific local support for the following sites: • LNCS 17 Catterline Den (956). Page 1 of 9 • LNCS 34 Downie Point-Catterline Coast (956, 1520)). • LNCS 40 Findon (415). • LNCS 41 Forest of Birse (1520). • LNCS 55 Kingcausie (1433) • LNCS 59 Lochton of Leys (1360). • LNCS 68 Muchalls to Stonehaven Coast (860). • LNCS 72 Portlethen Moss (415). • LNCS 73 Portlethen Village-Newtonhill Coast (415, 860). • LNCS 77 Red Moss (1433) • LNCS 87 Strathfinella (024). • LNCS 80 The River Dee (1520). Support has also been received for the landscape around Fettercairn to be retained as it is (1255, 1814). Comment was also made in regards to LNCS 2 Annies Dam stating that the area is somewhat overgrown and needs attention (928). It has been requested that the reasons for designation are published along with the site name and map so that the public can be more informed about their environment (1122, 1235). The sites should be mapped but the ones in the MIR are too small a scale to allow people to identify whether their land is affected (1150). There is also need for better awareness of these sites (1467). Local Nature Conservation Sites and perceived linkages between them are important for wildlife transfer. These designations should be integrated with the green network plan to protect and enhance biodiversity (668). There could also be further research completed for the proposed Local Nature Conservation Sites in terms of archaeology (928). There was a call for a consultation process to identify further appropriate sites in conjunction with the outcome of the green networks and the biodiversity requirements of the EU2020 biodiversity strategy. We should take advantage of this and seek proposals that will provide further links (1477). Another respondent also commented that there will be a need to amend this list as the climate and microclimates change (1467). The position of the LNCS in group 3 of the Strategic Framework for wind turbines is appropriate and through appropriate design or mitigation, wind energy development could be accommodated in such areas. In line with SPP it should be ensured that there are no buffers around the LNCS (1340). Reasonable Alternative Support was received for the reasonable alternative option not to publish the location of the sites as it is felt that some sites in Gourdon could be protected through the application of SG Natural Environment 2: Protection of the wider biodiversity and geodiversity rather than designation (928). It is also felt that Green Networks, Local Nature Conservation Sites and Valued Views are linked and the respondent supported the grouping together of these concepts within the Plan. (1434) Additional Sites There have been several sites which have been requested to be added to the Local Nature Conservation Sites, these requests are outlined below: Page 2 of 9 • The waterway between the Loch of Skene (LNCS 61) and Leuchar Moss (LNCS 57) should be added as it would help to maintain the integrity of the existing sites and consideration could be given to merging the three sites into one (111). • The coastal area between LNCS 34 and LNCS 53 should be included as it is valuable coast with an excellent landscape. As it is relatively inaccessible it ensures that it is home to a variety of wildlife (956). • Two additional sites are proposed: Daugh of Invermarkie, which is an area of fen and wet heathland with some base rich flushes which contain several locally rare plants such as globe flower and frog orchid; the second is Bisset Moss, a lowland bog/valley mire which is still very wet, in good condition and supports a very good diversity of plants (1251). • The St Cyrus site should be extended to include the furthest point of The Den of Fenella from the A92 (1619). • There is a gap between two Local Nature Conservation Sites and this is questioned as to why it is there. It has been recommended by the respondent that the sites should be extended to include the area in the middle. • The Caldhame Plantation in Luthermuir should be listed as a Local Nature Conservation Site (1255, 1814). • Sunset Seat , Banchory (within the Ma058 bid site) is an area of natural beauty and should be added as a Local Nature Conservation Site (1325). • Scolty woodlands and the surrounding area in Banchory should be added as a Local Nature Conservation Site (1445). • The River Deveron and its river valley should be added as a Local Nature Conservation Site as it is of historic, scenic and environmental importance (1478). • The LNCS 37 site should be extended to include the whole greenbelt around Stonehaven which is appreciated by a large number of people for its biodiversity, it is known to have many animal and bird species (76, 809). • Moss of Cruden and the Blackhills Quarry SSSI are cited as missing (571). Removal of Sites There have been comments received which have asked for either proposed sites to be completely removed or areas of the sites removed. The requests which have been received are outlined below. Another comment was also received stating that they would oppose removal of sites from the current list (1118). • There is concern with part of the LNCS, Site 6 Barmekin Hill and Site 61 Loch of Skene boundaries and as such there areas which have been requested to be removed (1520). • A request that Site 66 Mergie either has the southern part of the designation removed or if this is not viable then for the complete removal of the site from the LNCS list (1353). • The inclusion of the Stoneyhill landfill site at the edge of the proposed designation Stirling Hill Site 85 is contended as it is seen that this does not add value to the designation (1663). 2. Actions Page 3 of 9 General Support The general support for the preferred option and the individual sites is welcomed. The comments requesting that the reason for designation to be published alongside the map of the boundary of the site and the scale of the map are acknowledged. Position Paper 8: Local Nature Conservation Sites (LNCS) had additional information than what was published in the Main Issues Report, including more detailed maps of the individual sites as well as information regarding the reason for designation. This information should be transferred to supplementary guidance so there will be better awareness of the areas designated. The Local Nature Conservation Sites will be linked and integrated with the green networks objective of the plan through supplementary guidance Natural Environment 1: Protection of nature conservation sites. It is under this policy that the Local Nature Conservation Sites will be listed, and this policy along with other policies will have links to the green network objective. Archaeology is not considered as part of the selection criteria for the Local Nature Conservation Sites There is still a very rigorous set of criteria to be met before the site is included as an LNCS site. There are two sub categories within the LNCS. These are local biodiversity sites and local geodiversity sites. Both of these categories have criteria which need to be met in order for the sites to be classified as a LNCS. For the biodiversity sites the criteria includes; species diversity and rarity, important populations of species, habitat rarity and naturalness, habitat or site extent, connectivity and other factors. The geodiversity sites criteria includes; assessment of features present, rarity of geology type, extent of feature/exposure, educational value, access and other factors. Although a list of Local Nature Conservation Sites was located within the Main Issues Report there has been an opportunity for respondents to identify areas of land that had not already been classified as an LNCS. This was encouraged in the MIR text itself. Within the comments received relating to LNCS there were eleven sites that respondents have requested to be included and these have been further examined by the independent LNCS panel. The list of the Local Nature Conservation Sites will remain under review and the supplementary guidance updated as required as qualifying sites are identified by the LNCS panel.