022 Main Issue 10 - Sites of Local Nature Conservation Interest

Response ID Respondent 4 Community Council 24 Ms Dawn Gibbs 76 Dr. Edward Hugh Morel 111 Echt & Skene Community Council 415 & District Community Council 571 Cruden Community Council 668 Mr and Mrs Ian & Rosemary Nicol 741 Mr Peter Rowbotham 809 Mrs Lucy Morel 860 , & Community Council 928 Gourdon Community Council 956 , & 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 Community Council 1434 Crathes, & Durris Community Council 1443 North Kincardine Rural Community Council 1445 Ms Christine Mechie 1467 Development Trust 1477 Community Council 1478 Ms Judith Smit-Haffmans 1520 Ryden LLP on behalf of 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 . 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).

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• 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 Coast (860). • LNCS 72 (415). • LNCS 73 -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 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:

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• 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 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 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

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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. This panel of academics, agencies and interest groups has access to a wide community of expert and amateur opinion on the value of sites. As stated in Position Paper 5 Renewable Energy, Local Nature Conservation Sites are included in the level of the Spatial Framework for Wind turbines where planning constraints are less significant in response to specific instruction contained within draft Scottish Planning Policy 2013. In response to the comments raised within the MIR it should be noted that it is stated that while wind turbines may be technically feasible in such areas, it is difficult at this time to identify what the mitigation could be to allow our responsibilities for biodiversity to be maintained as well as allowing the land take and disturbance associated with a wind turbine. Reasonable Alternative Although one respondent showed support for the reasonable alternative (not to identify the sites in the development plan) there was more support received for the preferred option. The comment raised in relation to the preferred option, was regarding sites being protected through the policy SG NE 2: Protection of the wider biodiversity and geodiversity. This policy gives strong protection to habitats, species, and geological feature which do not have any statutory protection in order to fulfil the Council’s biodiversity duty as required under the Nature Conservation () act

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2004. This means that the sites which are thought to fulfil this criteria in Gourdon will still be protected even though they are not formally designated. The comment regarding the grouping together of the policies relating to Green Networks, Local Conservations Sites and Valued Views is acknowledged. It is not thought currently that these policies will be grouped together within the Plan. However, it should be noted that all the policies within the Plan work together to meeting the aims of the Plan. Additional Sites The sites which have been requested to be added to the Local Nature Conservation Sites have been assessed by the LNCS panel and the decisions are outlined below. Consideration has been given to the addition of the waterway between the Loch of Skene (LNCS 61) and Leuchar Moss (LNCS 57). Much of the burn between these sites passes through intensively managed agricultural land with almost no semi- natural vegetation along its banks. This section would therefore not meet the criteria for inclusion within a LNCS. The gap between LNCS 34 and LNCS 53 has been reviewed. This section of the coastline is very inaccessible making detailed botanical survey difficult. It has been agreed that the LNCS 34 should be extended southwards to just south of Todhead Point. The coastal vegetation within this section is a UK Biodiversity Action Plan (BAP) priority habitat which supports a good variety of coastal plants and diversity of invertebrates. It is also proposed that LNCS 53 is extended northwards to just north of the bay at Little as again this area is a UK BAP priority habitat with the locally uncommon purple milk-vetch recorded in this area. As there has been a new area added to the LNCS site this area will be required to be renamed accordingly. The two additional sites proposed, Daugh of Invermarkie and Bisset Moss, had be considered by the LNCS panel who have agreed that these sites meet the criteria for selection as Local Nature Conservation Sites and they have therefore been recommended for inclusion. Extending the St Cyrus site to include the land at the furthest point of The Den of Fenella has been considered and it is agreed that the LNCS should be extended to include other areas of valuable habitat. A Habitat Survey will be carried out in summer 2014 to inform the extent of the area that should be included. The current gap in the Local Nature Conservation Sites at Brown Jewel has been considered. This area of land is difficult to survey but from what can be seen from accessible locations the area supports undisturbed coastal grassland. Although not much information is available on the species present it seems reasonable to identify this area as a LNCS as the coastal grassland/maritime cliff is a UK BAP priority habitat. It is therefore proposed that the LNCS 68 is extended northwards to the burn at Ritchie Shore and that LNCS 73 is extended southwards to this point. As there has been a new area added to the LNCS site this area will be required to be renamed accordingly. The Caldhame Plantation in Luthermuir has been considered but this is a small area of predominantly regenerating wet birch woodland which, together with the surrounding network of woodlands, is known to be used by red squirrel. No other species of note have been recorded. It is therefore not considered to meet the criteria for selection as a LNCS. However, consideration should be given to extend the Local Development Plan 2012 protected area (P2) to include this plantation. The area at Sunset Seat in Banchory is a small area of poor neutral grassland and regenerating woodland, which is well connected to other areas of woodland. The site

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is small and no species of particular note have been recorded and it does not therefore meet the criteria for selection as a LNCS. Scolty woodlands and the surrounding area supports a variety of habitats including forestry managed for timber production, together with open heathland. The open heathland and forest habitats present within this site are typical of many areas within Aberdeenshire. Although some patches of semi-natural vegetation are present, much of the forest area is plantation which does not support a particularly high diversity of species. Apart from red squirrel, which is widespread within the wider area, notable species within the site are very localised. The site is therefore not considered to meet the criteria for selection to be an LNCS. The River Deveron and its river valley have been considered and the woodlands along the river have recently been survey by the Forestry Commission as part of their Native Woodland Survey. Other than this information no comprehensive data is available and consideration of the river and its valley as a potential LNCS will be given at a future date when habitat data is available. The request for the Fetteresso LNCS 37 to be extended to include the greenbelt around Stonehaven has been considered. However, it should be noted that sites identified as LNCS are those which contain important habitats and/or support populations of key species within the area. It would not, therefore be appropriate to apply this to large swathes of land of which include extensive areas of improved pasture and land used for crop production. The Local Development Plan contains policies which aim to protect biodiversity within the wider countryside. Independent of the Main Issues Report Consultation it has been requested that the western boundary of the Forest of Birse, LNCS 41 be reviewed to include the FCS Caledonian Pinewood buffer zone. On further examination, this buffer zone and the area beyond contains planted and regenerating pine woodland. It is concluded that that there would be merit in extending the boundary of the site beyond the buffer zone to include additional areas of open pine woodland with a good ground flora. The southern boundary of the site, which was also questioned, was drawn based on the use of these areas by moorland birds and it is recommended that this is retained. Removal of Sites There have been some sites where there has been a request to either remove part of the site or the whole site, these requests have been assessed by the LNCS panel and the decisions are outlined below: The request for the removal of part of the site at LNCS 6 Barmekin Hill has been considered. The areas proposed for removal are a predominantly birch woodland to the north and an area of mixed oak/beech woodland along the north-eastern edge. Both areas of woodland are good examples of semi-natural with a diverse woodland vegetation. These woodlands clearly meet the criteria for inclusion within the LNCS and there is no justification for their removal. LNCS 61 Loch of Skene has been re-considered and it has been decided that all the varied woodland and heathland habitats surrounding the Loch of Skene form an important part of the wider biodiversity value of this site, supporting a variety of plant, invertebrate and bird species. The request to remove the southern part of the LNCS 66 designation has been considered. The area in question is a small disused quarry and a small area of species poor coniferous woodland. Following re-assessment of the habitat survey and a site visit it is agreed that this small area could be removed from the LNCS without any overall loss of semi-natural habitat and no impact on the overall

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biodiversity interest of the site. The LNCS boundary will be redrawn to exclude this area. The geological feature of interest on LNCS 85 Stirling Hill is the presence of deposits known as the Gravel Formation, which form a cap along the hills in this area. The request to remove the landfill site at the edge of the proposed designation has been looked at. It is felt that the gravels remain present in this area and will not be affected by this land use. A site visit by members of the LNCS panel to the quarry is being arranged. In response to the comment received opposing the removal of sites, it should be noted that no sites are being removed from the current list, although some small modifications to boundaries are being proposed as a result of the consultation process. Additional sites which meet the criteria for LNCS have been identified.

3. Committee Recommendations 1. To adopt the preferred option as identified in the Main Issues Report, to include site boundary information on the proposals maps in the forthcoming Local Development Plan, and to include a schedule of sites with detailed maps as part of policy SG Natural Environment 1: Protection of nature conservation sites.

2. To add the following additional or extensions to sites to the list of Local Nature Conservation Sites: • Site LNCS 34 should be extended southwards to just south of Todhead Point and site LNCS 53 should be extended northwards to just north of the bay at Little Johnshaven. • Daugh of Invermarkie and Bisset Moss should be included as Local Nature Conservation Sites. • LNCS 84 should be extended to include additional land at The Den of Fenella. • LNCS 68 should be extended northwards to the burn at Ritchie Shore and LNCS 73 should be extended southwards to this point. • LNCS 41 should be extended westwards to include additioal pine woodland.

3. The following site boundaries should be changed with the appropriate sections of the LNCS removed: • The area of the small disused quarry and small area of coniferous woodland should be removed from LNCS 66.

4. All of the other Local Nature Conservation Sites should remain as they are outlined in the Main Issues Report.

4. Committee Decisions 1. Area Committee approved recommendations 1, 3 and 4 at their meeting on 6 May 2014. It was also agreed that recommendation 2 should read; To add the following additional or extensions to sites to the list of Local Nature Conservation Sites as presented in the report but, in the instance of the Den of Fenella only to progress once survey work had been completed and with the approval of the landowner: • Site LNCS 34 should be extended southwards to just south of Todhead Point and site LNCS 53 should be extended northwards to just north of

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the bay at Little Johnshaven. • Daugh of Invermarkie and Bisset Moss should be included as Local Nature Conservation Sites. • LNCS 84 should be extended to include additional land at The Den of Fenella. • LNCS 68 should be extended northwards to the burn at Ritchie Shore and LNCS 73 should be extended southwards to this point. • LNCS 41 should be extended westwards to include additioal pine woodland. 2. Area Committee agreed recommendations 1 and 4 at their meeting on 13 May 2014. The committee also agreed that recommendation 2 and 3 should read; 2. To add the following additional or extensions to sites to the list of Local Nature Conservation Sites: • Site LNCS 34 should be extended southwards to just south of Todhead Point and site LNCS 53 should be extended northwards to just north of the bay at Little Johnshaven. • Daugh of Invermarkie and Bisset Moss should be included as Local Nature Conservation Sites. • LNCS 84 should be extended to include additional land at The Den of Fenella. • LNCS 68 should be extended northwards to the burn at Ritchie Shore and LNCS 73 should be extended southwards to this point. • LNCS 41 should be extended westwards to include additioal pine woodland. • 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 (subject to consultation with the landowner, survey and gaining the necessary evidence).

3. The following site boundaries should be changed with the approporiate sections of the LNCS removed:

• The area of the small disused quarry and small area of coniferous woodland should be removed from LNCS 66. • Bay, LNCS 43 should be removed from the list of Local Nature Conservation Sites. 3. Area Committee agreed the above recommendations at their meeting on 27 May 2014. 4. 4. Area Committee agreed the above recommendations at their meeting on 3 June 2014. 5. 5. Buchan Area Committee agreed the above recommendations at their meeting on 10 June 2014. 6. 6. Area Committee agreed the above recommendations at their meeting on 17 June 2014. 7. Infrastructure Services Committee noted the recommendations of the Area

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Committees and agreed them at their meeting of the 3 July 2014.

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