Scheme Objective 1: To improve the operation of the A96 and inter-urban connectivity through:

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1 FAADAG (the Forres Area A96 Dualling Action Group) offers the following feedback to Transport Scotland (and in copy to SWECO), as invited pursuant to the most recent Route options design update issued on 17 th August We have questions about the Red Route as revealed in the design update issued in August We have based our questions and observations around the A96 Dualling Hardmuir to Fochabers scheme objectives. [We quote these objectives in italics] Scheme Objective 1: To improve the operation of the A96 and inter-urban connectivity through: Reduced journey times The Red Route appears approximately 4 km longer than a route through the transport/industrial corridor of Forres. Therefore, we cannot see that the choice of the Red Route will help to reduce journey times on this stretch of the road. Furthermore, choosing a longer route in the Forres area would create a lifetime of additional vehicle emissions, with adverse consequences for the environment in general and the health of the local community. Improved journey time reliability Increased overtaking opportunities Improved efficiency of freight movements along the transport corridor Reduced conflicts between local traffic and other traffic in urban areas and strategic journeys. Do you agree that more heavy freight vehicles may still travel up and down a congested A940 to get to the industrial areas of Forres if they go via the R3 junction? How does this help journey reliability? Scheme Objective 2: To improve safety for motorised and Non-Motorised Users through: Reduced accident rates and severity Reduced driver stress Reduced Non-Motorised User conflicts with strategic traffic in urban areas. Do you agree that increased heavy traffic down the A940 towards Forres, [via the R3 junction] would put school children, other pedestrians and cyclists at risk in an already busy and growing residential area? Why have a huge very expensive R3 junction at all? 1

2 Scheme Objective 3: To provide opportunities to grow the regional economies on the corridor through: Improved access to the wider strategic transport network Enhanced access to jobs and services. We note from your letter of 17 August 2018, in response to Enquiry 231 from FAADAG that: Route Option P1 at Hardmuir has been de-selected based on the potential impact on the Planning Application for mobile camping holiday pods in the area south and adjacent to Macbeth s Hillock. Route Option B1 at Burgie has been de-selected based on the potential impact on Burgie Eventing Centre and proximity of Category B listed Burgie Castle. Also, its potential impact on agricultural holdings in the area. These de-selections are particularly relevant to Marcassie Farm in Rafford (Grid Ref NJ ). Enquiry 231 gave information regarding Marcassie organic farm, farm business and Category B Listed Farmhouse which formed part of FAADAG s Feedback to Transport Scotland and SWECO re A96 Dualling Options dated 13 April 2018 (see pp under the heading People and Communities and p. 35 under Cultural Heritage ). FAADAG was delighted to note that Marcassie was granted EU LEADER Funding on 23 April 2018 and Planning Consent (18/00071/APP) on 10 May 2018 for the Retreat Centre already outlined in the FAADAG Feedback (Enquiry 231). This development represents a substantial capital investment in Marcassie Farm and work is already underway. To fulfil the terms of the grant award, Marcassie are under contract now to the EU and Scottish Government to complete this development by the end of June Give the de-selection of Options P1 and B1 for the reasons above that you have given in your 17 th August letter, the case for de-selection of Option R4 seems overwhelming based on the following: 1) Marcassie has Planning Consent for guest accommodation for a farm and naturebased heritage craft retreat centre business which has strong local backing evidenced in the award of EU LEADER funding 2) Marcassie runs an organically certified agricultural smallholding 3) Marcassie has a Category B listed building of historic interest on the farm To adopt the Red Route would be wholly inconsistent with your Scheme Objectives 2c, 3b, 6a and 6b. It would irreparably damage this unique innovative local business. Failure to deselect the Red route option appears discriminatory based on the decisions described above relating to route options P1 and B1. Would you agree? And if you do not agree, please explain why you disagree? Tourism is a major industry in Northern Scotland, but the Red Route will take away opportunities for tourists and prospective business folk to see Forres from the A96. The Red Route will generally hem in and restrict the growth of Forres to the South, and new housing 2

3 and businesses will be affected by the increased road noise, pollution and the significantly impaired view. Do you agree that a route through the present transport corridor in Forres will give tourists a better view and feel for Forres and permit organic growth of the town of Forres to the South of the town? Scheme objective 4: To facilitate active travel in the corridor. The Red Route will negatively affect cycle and walking routes. This will be caused by noise and air pollution, visual impact, particularly the height of the embankments, traffic noise and pollution. The woodlands and river-scape south of Forres are the relaxation and leisure area for many Forres folk and would be irreparably damaged by routes R3, R4 and R5. Would you not agree that the present transport/brown field corridor of Forres is already busy and for these reasons would be a far more suitable location for a new dual carriageway? If you disagree could you please explain why you disagree? Scheme objective 5: To facilitate integration with public transport facilities. The existing transport corridor in Forres is close to the new railway station. It is not clear how the Red Route will facilitate integration with public transport facilities. Integration with existing public transport facilities would be much easier and less expensive to achieve if any dualling of the A96 in the Forres area were placed closer to the new train station. Scheme objective 6: To avoid significant environmental impacts and, where this is not possible, to minimise the environmental effect on: The communities and people in the corridor Natural and cultural heritage assets. This scheme objective reflects the Scottish Government s Environmental Policy The Scottish Government has a longstanding commitment to reducing our impact on the environment. We do this through effective sustainable management of our operations and estate and by engaging with all staff to embed the principles of sustainable development into our day-today working practices. Our actions are directly contributing towards delivery of the Scottish Government's National Outcomes: We value and enjoy our built and natural environment and protect it and enhance it for future generations. We reduce the local and global environmental impact of our consumption and production. We live in well-designed, sustainable places where we are able to access the amenities and services we need. 3

4 Our public services are high quality, continually improving, efficient and responsive to local people's needs. By severing the existing wildlife corridors South of Forres by a four-lane dual carriageway to the South of the town, to mirror the rail link and old A96 to the North, thus encircling the town with impenetrable swathes of tarmac and railway both to North and South, and in particular its Community Woodlands in Sanquhar, the people of Forres will be cut off from woodland and river walks which are vital to their health and wellbeing. Most recent housing development in Forres is built to the south of the town. The people buying these houses have made this decision partly because of their proximity to these natural assets. This is particularly important for young people in the age group, who frequently use the path through Limekilns Woods to access the River Findhorn, which is not accessible from other nearby sites because of giant hogweed. In addition, the area will be starved of all wildlife diversity and re-supply. Forres residents are very fortunate that the iconic red squirrel is frequently seen in the gardens of town houses on Leonard s Road. This is a rare and precious asset and a great source of delight to the residents. The squirrel corridor runs from Limekilns Woods to St Leonard s Road in the path of the proposed Red Route. The latest Design Update reveals how the Red Route will impact local communities and individual homes and farms. The height of embankments required across Chapelton Moss and elsewhere and the enormous disproportionate junctions are a shock to all we have spoken to. This is exacerbated by some local roads being taken over the already towering embankments. Do you agree/understand that these revealed details totally change the landscape in such a way that scores of homes along the Red Route will look out onto a dominating noisy dual carriageway, where there was previously quiet, rural, beautiful scenery? Natural and cultural heritage assets [Continued]. The status and nature of the woodland at Altyre on the line of the proposed Red Route (R3, R4 and R5), along with the policy context is summarised below: Ancient woodland The Altyre and Darnaway woodlands are recorded on the Scottish Ancient Woodland Inventory (AWI) as being of Long Established Plantation Origin (LEPO). The Woodland Trust for Scotland believe that there is sufficient evidence to conclude that they should be more accurately classified as Planted Ancient Woodland Sites (PAWS). The current route drawings would require removal of c35 hectares of ecologically rich woodland on this ancient woodland site (not including area for construction). The proposed woodland removal would not only remove trees but would also entail the loss of undisturbed woodland soil, with its associated fungal and microbial diversity, the disturbance of hydrological function, the loss of ground flora, lichens, bryophytes, and the loss of breeding and foraging habitat for wildlife. The loss of ancient woodland cannot be mitigated for by compensatory planting. 4

5 Legally Protected Species and UK Biodiversity Action Plan (UK BAP) species The woodland along the line of the proposed routes contains species protected by European and UK legislation. The North East Biological Records Centre (NEBReC) contains records for the following protected species being present along the line of the proposed Red route; o Red squirrel o Otter o Badger o Pine marten o Crested tit There are badger setts, an otter holt and squirrel dreys on the line of the proposed Red route. Please see the attached Appendix 1, Table 1, which contains individual protected species records on the path of the proposed route, and Table 2, which contains details of the Protection Species Legislation. It is an offence under the listed legislation to damage or destroy breeding sites, setts, holts, dens, sheltering and resting places of these animals. UK BAP priority species are those that are identified as being the most threatened and requiring conservation action under the UK Biodiversity Action Plan (UK BAP). Otter, pine marten and red squirrel are listed as UK BAP priority species. Furthermore, formally approved Regional Red List assessments were conducted for native species in Great Britain according to the International Union for Conservation of Nature (IUCN) criteria. Under the IUCN Red List criteria, the red squirrel is classified as Near Threatened in Scotland, which indicates that the species is close to qualifying as Threatened or is likely to qualify as such in the near future. The assessments of Regional Red List status for Great Britain have been formally approved by the Inter-Agency IUCN Red Listing Group. If we fail to protect those areas where there is least threat to the red squirrel in the north of Scotland, such as the woods on route options R3, R4 and R5 near Forres, we will be unable to save the red squirrel. Would you agree that the Red routes R3, R4 and R5 will damage or destroy breeding sites and habitats of protected species, BAP priority species and, furthermore, in the case of the red squirrel a Near Threatened native species in Scotland? If you do not agree, why not? Scottish Government Policy on Woodland Removal The Scottish Government has developed a policy for the control of woodland removal to help direct decision making and support the Scottish Forestry Strategy and Climate Change Scotland Act. Within this policy there is a strong presumption in favour of protecting Scotland woodland resources and woodland removal should be allowed only where it would achieve significant and clearly defined additional public benefits. 5

6 In addition, the policy states that there will be a strong presumption against removing the woodland that support priority species listed in the UK BAP and woodlands listed as plantations on Ancient Woodland Sites (PAWS). With relevance to the Altyre woodlands, the guidance on the use of this policy for Forestry Commission Scotland staff states that a woodland requiring a particularly strong presumption against removal should apply to the following; o Sites designated for their woodland features (habitats) or woodland-related species under EU or national designations. o UK BAP priority woodland types in areas mainly composed of ancient, semi-natural woodland (ASNW), ancient woodlands planted with native species, long-established woodlands of plantation origin (LEPO) with significant biodiversity interest, or wellestablished semi-natural priority woodland types. There is also a strong presumption against woodland removal where it would lead to fragmentation or disconnection of important forest habitat networks. The guidance states that for woodlands with a strong presumption against removal, only in exceptional circumstances should the strong presumption against woodland removal be overridden. It also states; To further the policy s strong presumption in favour of protecting Scotland s woodland resources, options that avoid or reduce the need for compensatory planting (CP) should always be fully considered as part of the decisionmaking process. CP should be seen as the final option once all other solutions have been exhausted. Would you agree that the strong presumption against woodland removal guidance requires de-selection of Red routes R3, R4 and R5? If you do not agree, why not? For all the reasons stated in this document we believe you should deselect the Red Route and choose a route as near to the present A96 as possible. We look forward to your replies to the points made and the questions posed above. Yours sincerely, Howard Stollar Chair, Forres Area A96 Dualling Action Group (FAADAG) 14 September