Insh Marshes is an internationally important 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.
Since 2015 we have had numerous meetings with Transport Scotland, their consultants and other public bodies including Scottish Natural Heritage (now NatureScot) 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 Transport Scotland published their detailed design for this section of the dualling works (Crubenmore to Kincraig). RSPB Scotland lodged a formal letter of objection on a number of grounds. RSPB Scotland has continued to try to work with Transport Scotland since submitted our objection and hope to resolve our concerns without the need to take part in a costly inquiry process. Disappointingly, in January 2020 Transport Scotland formally requested that the unresolved issued are considered by Scottish Ministers at a Public Inquiry. This is expected to take place in Winter 2020 or Spring 2021. Until then RSPB Scotland will continue to try to work with Transport Scotland to find a resolution.
Transport Scotland proposes to compulsory purchase around 12.98 ha of land which RSPB Scotland owns or occupies at Insh Marshes. Of this, about five hectares will be permanently lost to construct the new road. Further areas of the reserve would be temporarily lost during construction, covered by temporary tracks, the machinery and structures required for the roadworks. This land will not be available for the wading birds such as curlew, oystercatcher and redshank 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 construction activities. These types of wading birds need large areas of undisturbed, open and relatively flat wetland, so that they can watch out for predators such as foxes which might be hiding nearby. All of the noise and human activity associated with the road construction will cause these birds to keep well away from the construction site. Once the roadworks are complete and the dual carriageway opens for traffic, the imposing road structure will deter many waders, such as curlew, snipe, oystercatcher, snipe and lawing, which will avoid nesting and feeding within a much larger 'zone of avoidance'. Many of these birds would not be able to simply move to other parts of the reserve, as the parts that are suitable habitat are likely to be already occupied by others.
Transport Scotland has bought an area of land (the 'Dellmore site') near Insh Marshes. It proposes to convert a large part of this land to wet and marshy grassland habitat to rehome the birds 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 these wading birds and maintain it as such over the long-term. Therefore, it is far from guaranteed that it will provide suitable habitat, and even if it does, the new habitat will not be big enough to rehome the numbers of the different types of birds that are predicted to be displaced as a result of the dualling.
Transport Scotland are mostly relying on their proposals for the Dellmore site to provide new habitat to rehome the wildlife affected by the dualling. 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. Therefore, we believe Transport Scotland needs to commit to additional habitat improvement measures and mitigation, above and beyond what they currently propose, to guarantee that nature does not lose out in the long term. We have identified several ways in which Transport Scotland could do this, within the existing reserve and elsewhere.
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 commit to additional habitat improvement measures, above and beyond what they currently propose, to guarantee that nature does not lose out in the long term.
- 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 reserve at Insh Marshes. Without adequate access the reserve cannot be effectively managed for nature 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 incorporating a bridge much longer than the existing bridge. This option would have affected less important wading bird habitat, reconnected floodplain habitats and have multiple benefits for the river and its wildlife, whilst reducing upstream flooding in Kingussie. Whilst we still believe that the Spey crossing bridge would be better for environmental reasons if it was 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.