For details of your nearest Halcrow office, visit our website halcrow.com

Appendix C

Stakeholder Consultation

Scottish Natural Heritage, Battleby, Redgorton, Perth, PH1 3EW Tel 01738 444177 Fax 01738 45 8611 www.snh.gov.uk

Dr Kathryn Dennis Senior Environmental Consultant Halcrow Group Limited 16 Abercrombie Place EDINBURGH EH3 6LB 15 June 2011 Our ref: NAT/FWA/RIV/RR Your ref: WBA/WPP/SNH/001 Dear Kathryn Allan Water Natural Flood Management Scoping Study Screening for Appropriate Assessment Thank you for your letter of 31 May requesting our advice on the requirement for an “appropriate assessment” under the Conservation (Natural Habitats, &c.) Regulations 1994 (as amended), for the proposed natural flood management measures in the Allan Water catchment. This letter constitutes our informal advice. A formal stage will follow once the competent authority has been identified. Although in this situation it is our view that SEPA will almost certainly have this role as an application will, in all likelihood, be needed under the Controlled Activities Regulations. Is the operation likely to have a significant effect on the qualifying interest?

We consider there will be significant effects on the qualifying features for the following European sites and therefore the competent authority (SEPA or Perth and Kinross Council) will need to undertake an appropriate assessment:

- Shelforkie Moss Special Area of Conservation (SAC)

- South Tayside Goose Roosts Special Protection Area (SPA) We consider the significant effects could be as follows: Shelforkie Moss SAC

- Degraded raised bog – possible significant direct effect as an area of this feature is within the potential “assisted naturalisation” area as marked on the plan you sent to us. The effects would include loss of deep peat habitat and characteristic species and peripheral wetland areas. The effects is likely to be permanent if it occurs.

- Active raised bog - possible significant indirect effect if degraded raised bog is directly affected e.g. through changes in hydrology and water tables.

South Tayside Goose Roosts SPA

- Non-breeding birds: Greylag goose, Pink-footed goose

Likely significant effect through:

1. Disturbance of geese when work is carried out; and

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2. Undercutting of Carsebreck Loch dam by natural river change over time. Effect likely to be permanent, although it may be possible to reverse (at great cost). May be prevented by intervention.

The appropriate assessment will need to address these effects. We have already undertaken our own initial appraisal based on the information provided – see appendix 1. We have concluded that there will be no significant effect on the River Teith SAC. Carsebreck and Rhynd Lochs SSSI – Hydromorphological mire range feature.

We have also assessed the impact of the proposed management of the Allan Water on this feature. Small areas of this feature overlap with the area of “assisted naturalisation”; these are small sump wetlands at the eastern end of the site. We are happy to accept allowing natural processes to work in these areas (reasoning similar to that for the raised bog - see appendix 1). There should be gains as well as possible small losses and therefore the habitat should balance out over time. SNH Appraisal of the Proposals

Our appraisal concludes the following for the respective designations:

South Tayside Goose Roosts SPA

Given the small scale nature of the in-river works, it is not thought likely that channel evolution will be of a scale to re-meander and undermine the dam of Carsebreck Loch, and will not therefore adversely affect the integrity of the SPA as a suitable roosting site for geese. However, during construction there is the potential for significant levels of disturbance and this needs to be addressed with appropriate conditions on the CAR licence. Suggested condition – “Any works related to assisted naturalisation or tree planting adjacent to Carsebreck Loch carried out in the Allan Water between September and mid April should be timed to start after 9am and work should cease by 4.30pm. No restrictions apply outside these months” Shelforkie Moss SAC

Site integrity would not be adversely affected and would be positively impacted if ditch blocking and tree clearance was undertaken on the raised bog. We are keen for the project to include peat bog restoration and we have already made this comment on 18 May in an email to Andrea Johnstonova at SEPA when we commented on the list of options. If you would like to discuss the contents of this letter, please do not hesitate to contact me. Yours sincerely Peter McPhail Area Officer Tayside & Grampian peter.mcphail@snh.gov.uk

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Appendix 1 Allan Water Natural Flood Management Scoping Study Screening for Appropriate Assessment SNH Initial appraisal of the implications for the following European site designations in view of the site’s conservation objectives

Shelforkie Moss SAC

Active and Degraded bog – one small area of degraded raised bog is within the assisted naturalisation area and could be adversely affected by increased river meanders. Vegetation in the area has all the species one would expect for degraded raised bog. There would be no direct impact on the Active bog which does not overlap with the area for naturalisation. It is not thought that there would be any implications for the hydrology of the core active bog area through the naturalisation of the Allan Water. Any lowering of the water table adjacent to newly created meanders is likely to be extremely local and not impact on the wider bog. The main impact on the bog is therefore predicted to be on the degraded bog and only in the long term i.e. many decades should river meanders form. This could remove areas of peat and alter the local form of the habitat. However, these are natural processes and the habitat should adapt over time. If this management work was combined with ditch blocking on the wider bog (active and degraded) and clearance of trees there would be a net positive gain through re-wetting of the bog and growth of bog moss.

South Tayside Goose Roosts

Possible effect outlined in my letter:-

� Disturbance of geese – any adverse impact can be removed by conditions

� Undercutting of dam by creation of river meanders: Carsebreck Loch is part of the South Tayside Goose Roosts SPA. Current information shows that Carsebreck Loch is now the main goose roosting site in the SPA. Maintaining the integrity of the loch (which is wholly artificial) is essential to the SPA. It appears there is little room to allow a tolerance for the river to meander in the circa 600 metre section of river immediately adjacent to the dam. The Allan Water is already constrained by the railway line on one side and the field width from the river to the dam varies according to map measurements from approximately 56m to 90m. Halcrow state that due to the low energy of the Allan Water in this area it is anticipated that channel evolution will be gradual, probably a matter of decades. The works proposed are small scale and in the bed of the river. The risk to the site by possible river meanders cutting into the dam and loch is perceived to be low and no likely adverse impact on the habitat used by roosting grey geese.

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4.2 Land managed by interviewees

Figure 4.2.1 Map showing the areas of land owned and managed by the

participants of the stakeholder consultation

Map showing the areas of land managed by the participants of the stakeholder consultation

Allan Water Natural Flood Management Scoping Study

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4.3 Sample letter

APPENDIX C: Stakeholder Interviews – CRESS Report 04256.2

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4.4 Factsheet

What is meant by Natural Flood Management?

Scotland is adopting a new approach to help reduce the problems that can present to land

and properties. By working with nature it is possible to reduce the reliance on hard defences

such as and The more natural approach manages through the

r.

Opportunities for working with nature exist in both rural and urban settings. In rural areas

possibilities include reconnecting rivers to which provides temporary storage, and

planting woodland to increase the time that rainfall takes to reach the river. Equivalent options in

urban areas include permeable paving, green roofs and habitat restoration around urban streams.

Natural approaches can provide a ffective and long term mitigation measure to a

problem. Additional value can come from enhancements to biodiversity and recreation, opening

opportunities for land managers to claim grants, such as the Scottish Rural Development

Programme (SRDP) funding.

Removal of embankments and restoration of

retained in the upper catchment

Recreation of meandering channelNatural channel forms help slow the

Restoration of wetlands and bogs Wetlands in the upper catchment may be able to absorb

rainfall and release it to the river slowly

Fencing off the river bank and marginsRecovery of riparian vegetation can

Reduction of stocking densities Reducing ground compaction can reduce the

amount of water that runs off the surface

Reducing drainage from the upper catchment usually

reduces the speed at which river levels rise

Planting native woodland Rainfall tends to soak into the ground more in woodland

areas reducing the amount of water that reaches the river

Introducing large woody debris

Natural Flood Management factsheet produced for the Allan Water Natural Flood Management Scoping study

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M

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CM

MY

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Factsheet Rev2.pdf 1 16/03/2011 11:07

Allan Water Natural Flood Management Scoping Study

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4.5 Leaflet

4.5.1 Front

Front side of the leaflet printed 1/ 3 A4 and distributed to

stakeholders.

APPENDIX C: Stakeholder Interviews – CRESS Report 04256.2

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4.5.2 Back

Reverse side of the leaflet printed 1/3 A4 and distributed to

stakeholders