Insh Marshes is an internationally important example of a near-natural floodplain with exceptional wildlife. Given the area's conservation importance, we have major concerns about the potential environmental harm that the dualling project through Insh Marshes could cause.
We have had several meetings with Transport Scotland, their consultants and other public bodies including Scottish Natural Heritage and the Cairngorms National Park Authority to try to minimise negative impacts on the reserve, and maximise potential environmental benefits of the dualling project.
In October 2018 RSPB lodged a formal letter of objection to Transport Scotland on a number of grounds. Although RSPB Scotland is not objecting to the principle of the A9 dualling it has a number of concerns with the implementation of the scheme and the associated impacts on Insh Marshes and the species that rely on them. Unfortunately the overall picture and response from Transport Scotland has so far been disappointing and resolution is yet to be had with respect to a number of important points of objection.
According to Transport Scotland’s calculations, the proposed road scheme would result in the permanent loss of the equivalent of five professional football pitches of habitat from the National Nature Reserve, or 143 tennis courts, lost mainly underneath the footprint of the new road and its embankments. Added to this, a further 4 football pitches worth of the reserve would be temporarily lost – covered by temporary tracks and the massive machinery required for the roadworks. This land would not be available for the waders to nest and feed on for a long period.
However, the effects of the dualling scheme will extend far beyond the footprint of the new road and the roadworks activities. Waders need large areas of undisturbed, open and relatively flat wetland, so that they know that predators such as foxes are not hiding nearby, ready to pounce on their vulnerable eggs or chicks. All of the noise and human activity associated with the road construction will cause the waders to keep well away from the construction site. Once the roadworks are complete and the dual carriageway opens for traffic, the increased traffic flows and the imposing road structure will deter many waders, which will avoid nesting and feeding within a much larger 'zone of avoidance' equivalent to the area of more than 50 football pitches. Many of the waders would not be able to simply move to other parts of the reserve, as the parts that are suitable habitat are already occupied by others.
Overall therefore, the dualling across Insh Marshes will significantly reduce the number of waders and other wildlife on the reserve and on other nearby areas of wetland.
The road construction may well affect a lot of other wildlife on the reserve and local area, including osprey, otters, whooper swan, water voles, wigeon, goldeneye and various rare invertebrates, and will cause loss of wetland plants such as ragged robin, greater butterfly orchid and marsh marigold. It would also be very noticeable to visitors to the reserve, from two of our hides.
We have continually made the case for protecting the exceptional wildlife of Insh Marshes and the surrounding area, minimising harmful impacts, and maximising environmental benefits (such as enhancing or providing new habitat nearby) that the dualling project brings with it. We have identified several ways in which Transport Scotland could do this, within the existing reserve and elsewhere. These include creating new nesting 'islands' on the reserve where the ground is currently too wet for ground nesting waders (the birds need just the right balance of wet and dry areas, for nesting and feeding); reprofiling old defunct embankments to create a more natural landform and open landscape favoured by the waders; and excavating 'scrapes' (shallow ponds with muddy edges) to provide extra feeding habitat. These measures would all create extra wildlife habitat, and study work that we have commissioned shows that they would not cause flood risk issues off the reserve, in fact they are expected to reduce flood risk upstream of the River Spey bridge. We have been encouraging Transport Scotland to explore these and other measures, but so far our suggestions have largely been disregarded.
Transport Scotland has bought an area of land (the 'Dellmore site') near Insh Marshes. It proposes to convert a large part of this land (plus a few small areas of nearby land elsewhere) to wet and marshy grassland habitat to rehome the waders that will be 'displaced' from Insh Marshes. Whilst we welcome this intention, it will be challenging to successfully convert this land to suitable wetland habitat for the waders, and maintain it as such over the long-term. It is therefore far from guaranteed that it will provide suitable habitat, and even if it does, the new habitat will not be big enough to rehome all of the birds that are predicted to be displaced as a result of the dualling. Transport Scotland also proposes to remove some of the existing A9 embankment and restore this land to wetland, but its closeness to the new dual carriageway severely limits its suitability as new bird habitat.
Transport Scotland are mostly relying on their proposals for the Dellmore site to provide new habitat to rehome the wildlife affected by the dualling. In doing so they are basically 'placing all their eggs in one basket' which is inappropriate given the challenges they will face to make this site suitable habitat. We believe that Transport Scotland’s proposals for replacement wildlife habitat are insufficient, and there is a real risk that the road scheme will result in long-term harm to a variety of wildlife. Transport Scotland should propose and fund additional habitat improvement measures, above and beyond what they currently propose, to guarantee that nature does not lose out in the long term.
In summary our key outstanding points of objection are:
- Transport Scotland’s proposals for creating new areas of wildlife habitat (including at Dellmore of Kingussie) are insufficient to make up for the losses of habitat and wildlife caused by the dualling. Transport Scotland should propose and fund additional habitat improvement measures, above and beyond what they currently propose, to guarantee that nature does not lose out in the long term.
- Errors and inconsistencies within the Environmental Statement that mean we have a lack of confidence that the true impact on species has been recorded. This may mean that the environmental statement underestimates the numbers of birds that will be affected by the dualling both during construction and once the dual carriageway is open for traffic.
- Lack of appropriate mitigation measures to minimise the impact on visitor experience at Insh Marshes.
- Lack of assurance and detail regarding access to the remaining RSPB Scotland landholding at Insh Marshes. Without adequate access the reserve cannot be effectively managed which could lead to further species loss.
We had previously proposed that Transport Scotland should use the opportunity to create a ‘green and blue underpass’, which would involve widening to the immediate west of the existing single carriageway and incorporating a bridge much longer than the existing bridge. This option would have affected less important wader habitat, reconnected floodplain habitats and have multiple benefits for the river and its wildlife, whilst reducing upstream flooding in Kingussie.
Whilst for environmental reasons we still believe that the Spey crossing bridge should be longer than currently proposed, we have withdrawn this element of our objection as a result of further information provided by Transport Scotland. The removal of this element of our objection was partly driven by the fact that modelling had indicated that a longer bridge may increase flooding downstream. It would also add substantially to the costs of the project, which perhaps would be money better spent on providing more offsetting, and additional mitigation measures to provide a better deal for the wildlife impacted.
It is RSPB Scotland’s intention to try to resolve the outstanding objection points in series of upcoming meetings, however the response from Transport Scotland has so far fallen far short of the mark.