This is the text of the response sent to Scottish Forestry on 27th November following community consultation.

This summary of responses was collated from the documented views of residents at very well-attended meetings (indicating the level of interest and concern in the proposal) as well as individual representations made directly to BC Councillors. Those responses have been divided into key issues.

 

Farmland

  • Two very different points of view; the majority believe that loss of farmland capable of growing arable crops is unacceptable. EJD pre-consultation document (paragraphs 3.2 and 5.1) states some of the land is “capable of use as improved grassland with few problems with pasture establishment” and is “capable of average production though high yields of barley, oats and grass can be obtained”. Whether or not the arable argument is a good one, there would be loss of grazing land with the Knocktall proposal.

  • A minority believe this is ground only suitable for grazing (supported by usage in the recent past, and its classification in the national soil survey), and planting for woodland would provide a net positive effect.

  • Foresight’s philosophy, according to their website, is that they will target land in the “poor livestock” category. Responses note that ground at Knocktall does not fall into that category.

  • Planting with predominantly conifers will result in permanent loss of farmland. The proposals are in conflict with its classification as “broadleaf preferred” and “sensitive” in the Dumfries & Galloway Council Forest & Woodland Strategy.

  • Damage to soil will occur both during planting and during clear-felling due to use of ploughing/heavy machinery.

  • Concerns have been raised about how decisions are made regarding change of use from farm to woodland and the lack of input from local communities in making these decisions given the effect they will have on the amenity/ landscape (and see under Employment).

 

Employment

  • Concern that the forestry proposal will result in no additional local employment and, following that point, that it will not bring additional families in the area and also support the local school. EJD Forestry have stated that the contractors who establish and maintain the woodland are likely to come from Cumbria so substantial mileage is also involved.

  • EJD had previously indicated the establishment of a number of forestry apprenticeships. There is no formal confirmation of this, the number or that these would be restricted to young people in the D&G area, and lead to permanent jobs in the area.

  • These concerns were balanced by support for employment in the (relatively) local sawmill/wood processing industries.

 

Fire Risk

  • Concerns that there is no published assessment of/ provision for increased fire risk, given this adds to the existing area of Upper Senwick Wood - an area accredited as Ancient Semi-Natural Woodland which won Scotland’s Finest Wood award in 2018. The assumption is the risk will increase with climate change, as we now have longer dry spells in the spring/summer months.

  • EJD recently proposed that additional water bodies within the development could be created. BCC would welcome these, and their careful design would improve wildlife potential on the site.

  • Access gates should have contact details for woodland management personnel in case of issues arising.

 

Tourism / Public Access

  • A number of responses consider that a large plantation of Sitka Spruce is unattractive and will discourage tourists, and felled areas of Sitka Spruce will remain an eyesore for years.

  • It would be of greater benefit for tourism if there was a bigger proportion of broadleaf/native tree planting.

  • Recognition by some respondents that the site is, in part, already bordered by high hedges and existing woodland, and will not be very visible to passing tourists. The hedges must be maintained in the future to retain this screening effect.

  • Support for footpaths. If implemented, they would benefit both local people and visitors to the area. They should, however, join up with footpath networks in the Borgue area – see Community Gain. BCC therefore supports multiple access points, as shown on the Capital Items Plan, dated 16th November 2023, plus parking for several cars at a minimum of two locations. 1 entry should be located close to the Brighouse / Borgue to Kirkcudbright junction to reduce traffic dangers to pedestrians on the latter. Any changes to locations should be negotiated with BCC and relevant residents adjoining the site.

Drainage and Pollution

  • Some responses consider that Sitka Spruce will acidify soil and watercourses.

  • Runoff from the woodland could affect the marine environment and local fishing businesses.

  • The site drains into Kirkcudbright Bay and Brighouse Bay. During timber extraction, there could be run-off of soil into these areas with negative effects on recreational use of the beaches and inshore shell-fishing.

  • Residents seek confirmation that if the scheme is implemented such negative effects will be avoided, and clarity on how this will be monitored.

Flora and Fauna

  • The mammals and birds reports provided are somewhat limited, and also take little account of local knowledge. For example, great crested newts have been seen on the site, but no record is in the report. Flora and fauna in surrounding areas will be impacted by the proposal but the reports are limited in recognising this and how this can be addressed.

  • Respondents, including an experienced ecologist, consider that the recorded data provided on flora is very limited and more work should be undertaken.

  • Whilst the sensitivity of parts of the reports are understood, the extent of redaction is so great we cannot fully assess the impact of the proposals on those species.

  • Even though the reports identify degraded areas, overall, the proposals lack identification of opportunities for enhancing natural resources. The small proportion of native trees and species mix shown in the scheme and the lack of shrub planting/ valuable edge species both work against this. There is scope however. For example, the creation of new water bodies to address fire risk could be designed to provide new wildlife resources. Small and more natural open spaces with increased native species and varied storeys would also assist and provide an enhanced experience for public access.

  • Because timber production dominates, the scheme does not deliver the best possible outcome for the environment. This is not in line with current government thinking (UK and Scottish Governments) who stress that improving the environment should be a key outcome in any development.

 

Tree Planting

  • The proposals clearly conflict with the area’s classification as “broadleaf preferred” and “sensitive” in the Dumfries & Galloway Council Forest & Woodland Strategy. The proposed low numbers of / restricted mix of native tree species contrast with existing woodland in the Borgue area.

  • A key response was that the forestry mix proposed is dominated substantially by conifers, and in particular Sitka spruce. The latter is an alien species in the UK, with very low wildlife value and its visual characteristics are considered to contrast negatively with the adjacent existing woodland mix. Alternative ‘timber’ tree species offer better wildlife/ visual contributions.

  • Forestry experience has shown that reliance on one major tree species should be avoided in terms of the potential for disease.

  • A greater percentage of native trees (broadleaf and conifer) plus more varied vegetation levels would improve the proposals in many respects, not least helping to blend the scheme into the existing woodlands and landscape whilst providing increased wildlife value. A substantial number of respondents voted to support a scheme with more native planting and open spaces at a recent BCC meeting.

Landscape Appraisal

  • Respondents question the expertise used to undertake the submitted landscape and visual appraisal. No professional expertise is referenced in the assessment - the only reference being Nature Scot’s Landscape Character Type 157 ‘Peninsula with Gorsey Knolls’. Note: The Landscape Institute “considers that it should be suitably qualified and experienced landscape professionals that “carry out” landscape and visual impact assessments (LVIAs). However, provided they have had appropriate training and experience, other professionals may also do so.”

  • Respondents also understand that no landscape architect is currently employed at Scottish Forestry. Even with limited training of forestry staff, this suggests that they may not have the experience to evaluate such work. Note: The Landscape Institute states, “When it comes to reviewing assessments undertaken by others, however, in the absence of formal certification of specific competence, the appropriate ‘competent expert’ would normally be a Chartered Member of the Landscape Institute who has substantive experience.” Refs: https://www.landscapeinstitute.org/technical/glvia3-panel/ and Landscape Institute Technical Guidance Note 1/20 (10 Jan 2020)

  • The appraisal underestimates the change that the proposal will make to the landscape. A forestry mix dominated by conifers, in particular Sitka spruce - an alien species in the UK, and its characteristics contrast strongly with adjacent existing woodland mix. The low level of native tree species proposed is also at odds with existing woodland in the area.

  • A substantial percentage of native trees (broadleaf and conifer) would improve the proposals and help to blend the scheme into the existing landscape.

EIA

  • A number of respondents have expressed concerns that there is no EIA at this stage. The proposal will have major impacts on the area including landscape and agriculture. An EIA should be requested.

Traffic Management

  • Some concerns raised at future traffic generation at times of key operations such as removal of timber from site. BCC would wish to be involved in agreeing a management plan, in partnership with D&G Council, by agreeing times of operation, specific roads used, vehicle weights etc in order to limit negative impacts on tourists and residents.

Community Gain

  • It is difficult to see community gains with the loss of landscape and environment. However, respondents have identified potential benefits to the local community and tourists, if implemented:

  • A well-connected network of footpaths through the woodland to adjacent areas for use by residents at Senwick House, the local community and tourists. This should include connections to Core Path 220 through Senwick Woods.

  • Woodland footpaths could be more attractive than walking across farm pastures, particularly if through native woodland planting with varied edge species.

  • The development should provide education opportunities for local schoolchildren.

  • Donations of funds or resources, negotiated through the Community Council, to community and specialist local groups (such as red squirrel, bat, bird and moth groups who are involved in improving species records and enhancement in the Borgue area).

 The application process

 Finally, BCC has a concern regarding how local communities, and indeed the wider public, can comment on Forestry Grant applications. In relation to Knocktall, to understand and then comment on proposals, a number of individuals went to the SF Public Register to gain access to relevant information documents explaining the proposals. Given the name, one could expect to see and get easy access to supporting documents. But, clearly, they are not accessible from the Register. A respondent was informed by SF that “None of the documents supplied as part of the application are provided on the Public Register. You have to request access to these from the Conservancy direct. This is our approach across Scotland." How is the public meant to know this? For a scheme seeking public comments we do not believe that this is acceptable, and in the interest of transparency. You cannot be assured that we have received all relevant and up-to-date information if this is the case – as recent plans have shown.