Am Bratach No. 318
SNH must heed the lessons of Assynt
by Ray Mackay and Victor Clements
June 29 last year, the board of Scottish Natural Heritage (SNH) agreed to
use their regulatory powers to force the Assynt Crofters Trust and other
landowners on the Assynt Peninsula to cull large numbers of deer. By August,
SNH officials had reversed that decision. Recently, the Assynt Peninsula
Deer Management Sub-Group (APSG) agreed with SNH a plan of operations for
bringing the woodlands at Ardvar back into favourable condition. The plan
involves a combination of deer control across Assynt, some fenced enclosures
to strengthen the habitat network and diversify tree species, and an agreed
monitoring programme. Agreed deer culls have been delivered for 2017-18,
fencing work is well underway and habitat monitoring will take place shortly
to inform on-going management.
So, after years of wrangling over the
nature of the woods at Ardvar — whether they were regenerating or being
devastated by the impact of deer and how many deer there actually were on
the Assynt Peninsula, the issue of deer in the Ardvar woodlands has been
settled. This draws a line under a seemingly intractable argument that has
dominated land-use debate in Scotland for a number of years, and which has
cost the public purse almost £1 million.
Now that the argument has
been won and common sense has prevailed, we feel we are in a position to
explain our own side of the story, aided by a knowledge of SNH
decision-making gained through Freedom of Information (FOI). We have not
been able to get SNH to explain their recent change in policy, far less
apologise for the years of disruption they have caused in Assynt, and so we
are publishing this account of what went wrong so that lessons can be
learned and situations like this cannot arise again in future.
It is important for us to do so because, in
addition to the huge public cost, the ability of the Assynt Crofters Trust
to manage their own land has been publicly questioned; relationships within
Assynt have been put under strain, and the time and effort required to deal
with all these issues has been immense. While salaried SNH staff have been,
for years, getting well paid to provide often misleading and inaccurate
information to their board and to Holyrood, we have had to fight our case in
our own time and at our own expense against a full array of public agencies
and politicians. All of this has been damaging and unnecessary.
The woods at Ardvar on the Assynt
Peninsula are designated both as a Site of Scientific Interest (SSSI) and a
Special Area of Conservation (SAC). Since 2004, SNH officials have been
monitoring the area, and had concluded that the woods were not regenerating
and were in an unfavourable condition. The woods were described as
“moribund” and “senescent” and the ground vegetation described as
“impoverished”. The site developed a symbolic significance in that it
supposedly embodied many of the problems associated with the impact of deer
on the natural heritage more widely in Scotland. Environmental NGOs were
campaigning to introduce statutory deer management planning, and Ardvar
became an important part of that campaign. Politicians became involved, and
their interest gave the area a profile well above its actual importance.
Senior SNH staff presented Ardvar to their board as a “case study” in
how voluntary deer control was not working. The issue became very complex
and heated, and it frequently spilled over into the press. Government
ministers had to be briefed, and questions were asked in the Scottish
Parliament. Everyone wanted to know what was happening at Ardvar, and the
impatience to see an example made of the people in Assynt was obvious.
Campaigners tried to steer the narrative towards a very simplistic view
of “big landowners putting deer before trees and the natural environment”,
all the while failing to grasp that the biggest landowners on the Assynt
Peninsula were actually the local crofters themselves. Throughout all this,
and for many decades beforehand, trees had been regenerating and growing in
Ardvar, and the woodland area had been gradually expanding and filling in.
All the available evidence points in this direction. Anyone driving through
Ardvar can see the regeneration. How then was it possible for such a
fundamental misrepresentation of the site to occur, and why did SNH
ultimately have to step back from taking statutory intervention, despite the
huge pressure on them to do so from environmental campaigners and the
Scottish Government itself?
The developing problem
With the benefit of hindsight, distance and FOI material, this is how
and why we think the situation at Ardvar developed as it did:
designated area at Ardvar is not a single woodland but a collection of ten
to twelve separate woods spread over several miles. They are diverse and
different, and the monitoring protocols used between 2004 and 2016 were not
capable of picking up on this diversity. The narrative that there was no
regeneration at Ardvar arose through inappropriate survey methodology, and
it was only recently (in 2016) that more reliable information was available.
2) The site became politicised. Members of the Scottish Parliament came
to accept the view that the Ardvar situation was symptomatic of the wider
problem of deer impacting on the natural environment. But they did this
without any critical analysis or real understanding of the site or the wider
3) Because of the supposed remoteness of Assynt, few people
chose to come and check up on information for themselves. They simply
repeated the arguments of others.
4) The high profile of the site
meant that many SNH personnel were engaged with the issue. These should have
been people with the necessary knowledge who could have commanded the
respect of the local players by listening, before coming to a decision.
Instead, most of the officials we dealt with had neither a background in
deer management nor an in-depth knowledge of woodland management. What they
attempted to do was to manage the problem rather than solve it. And this
wish to “manage” rather than analyse and decide on a course of action led to
local knowledge being disregarded.
5) A narrative based on poor
information was therefore developed, and once accepted, it proved very
difficult for SNH to move from this position. The management structure and
lines of communication within SNH now seemed very much more complex, and it
became almost impossible for any staff member to deviate from the
established, but flawed, line of thinking. The pertinent image is that of a
huge ship heading for the rocks, unable to change direction despite various
warnings from different sources.
6) SNH’s focus on managing the argument
rather than analysing the situation led to an unhelpful focus on
personalities rather than issues — “Ardvar” came to represent differing
vested interests (the John Muir Trust, the Ardvar Estate and the Assynt
Crofters Trust) and SNH officials spent a lot of time and effort in trying
to “play off” one group against another. This approach threatened to tear
the deer management group apart. Ultimately, however, it was a strategy that
back-fired badly on SNH as the group cohered in opposition to SNH’s
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7) SNH’s managerialism came to a head when our deer
management plan was heavily criticised for not adopting an “adaptive
management” approach. When asked for an explanation of this term, SNH
responded as follows: “Adaptive management is an iterative process for
continually improving management by learning from how current management
affects the system. AM is therefore based on monitoring and evaluating past
management and devising alternative actions that can be tested against
desired objectives.” To show how facile and empty this jargon is, ask
yourselves whether you’ve ever come across a non-adaptive approach to
management. (As in, “My success as a manager stems from the fact that I
never, ever adapt. I insist on not learning from how current management
affects the system”.) But this jargon became a managerial weapon which SNH
officials tried to use against us. And the greater irony, of course, is that
it was SNH itself that seemed incapable of “devising alternative actions” —
theirs really did seem an organisation incapable of adapting to a changing
8) When the APSG began developing a deer management plan
in 2016/17, SNH would not allow for any proper analysis or discussion of the
habitat monitoring procedures or deer count information available.
Fundamental issues were ignored, tree regeneration was only grudgingly
acknowledged and downplayed, and community input was disregarded. SNH had
previously used the media to question the ability of group members to manage
their own land, and their overbearing and patronizing approach now angered
9) The SNH board decision to intervene in Assynt was
therefore based on deeply flawed information. When that decision was
challenged, the case quickly fell apart and SNH withdrew from their
position. While this may well have been in part due to the political
difficulties in taking on a group like the Assynt Crofters Trust, with their
profile and history, the fundamental issue was that, despite assurances to
their board, SNH staff had not prepared their case properly, and they were
simply not ready for a challenge of the kind mounted.
10) When SNH
finally agreed to simplify communications by providing a single point of
contact and concentrate on the actual evidence, the situation very quickly
resolved itself, and we now have a situation that all APSG members, SNH and
the Forestry Commission are happy to sign up to.
It is important that the above criticisms
are not made without recommendations for how things should be done
differently in future.
1) Issues with deer management in Scotland
are not going to go away any time soon. SNH needs to be re-structured to
provide for a small problem-solving unit, concentrating mostly on
deer-related issues, but potentially taking on other difficult issues as
well. It must have a short chain of command, and have an ethos of looking
properly at evidence and finding solutions. Removing the Deer Commission and
then the Wildlife Operations Unit from within SNH has been a mistake, and
such a unit needs to be re-instated. Deer-related work requires a particular
skill set which involves empathy, an ability to deal with conflict and a
working knowledge of both sides of the deer-natural environment debate.
2) Where necessary, SNH should use their powers to convene Deer Panels
if they need external expertise to look at a particular site and devise
solutions. In the case of Assynt, Forestry Commission expertise proved to be
3) In June 2017, the chairman and board of SNH were put
in a very exposed situation. Rather than having been presented with
considered information and analyses on which to form a judgment, they were,
at best, ill-informed and, arguably, mis-informed by their officials.
Withdrawing from that position and endorsing a very different approach makes
them appear weak, easily led, lacking initiative and “rubber-stamp fodder”.
This is not sustainable. The SNH board needs to be protected from the
consequences of misleading analyses and ill-judged recommendations. The
warning lights were clearly visible at Ardvar, but these were not heeded by
officials, and the result has been considerable damage to SNH’s reputation.
4) There is an institutional problem within SNH whereby conformity to
established thinking is encouraged and rewarded. SNH needs to open up its
recruitment practices to other agencies and the private sector to ensure
that fresh thinking and skill sets can come forward on a more regular basis.
There is an obvious career path which involves SNH and environmental NGOs,
with senior people moving from one to the other. While the reasons for this
are obvious, it does tend to result in a kind of tunnel vision which places
environmental issues above the needs and welfare of the local people who
live in those environments and disparages the contribution that local people
can make to the environmental debate, even where that contribution is
5) Closely connected to the point above is the fact
that SNH officials often seemed to lack any understanding of how to work
with ordinary people, consistently showing a lack of empathy or any real
understanding of the situation in Assynt. From the moment when the Ardvar
woods were adjudged to be worthy of designation as a Special Area of
Conservation, the prevailing attitude within SNH has been one of
condescension — the natives are not to be relied upon. They know nothing.
Look at the damage they are allowing to happen in these very important
woods. At the time of the publication of the report into the Hillsborough
disaster, a phrase was used to describe the attitude of the authorities to
those affected by the tragedy — “the patronising disposition of
unaccountable power”. To us, that is exactly how SNH behaved in Assynt. This
mindset has to change.
6) The SAC designation at Ardvar has been
inappropriately applied, and this is likely to be the case with some other
sites in Scotland. We want to see this designation removed and believe there
are very strong grounds for doing so. There is a tendency for SNH to hide
behind EU regulations to defend their actions when, in reality, they
themselves define the status of these sites and can decide on appropriate
timescales for their restoration. Many sites in Scotland will take decades
or indeed centuries to fully restore, and consideration needs to be given to
this when discussions are taking place with land managers. Politicians in
particular need to understand this.
7) The cost of SNH’s involvement
in Assynt runs close to £1 million in total. This is the price of
inappropriate analysis and indecisive leadership stretching back years.
Politicians contributed to the situation by becoming involved in the detail
of an argument without fully understanding it. Their job is to provide
overall strategic and political direction to land management in Scotland,
but it is not appropriate for them to get involved in individual sites such
as happened here without, at the very least, gaining first-hand experience.
To our knowledge, only one politician has visited and that was to look
around the very small area owned by the John Muir Trust. It is significant
that no member of the Scottish Parliament has yet seen fit to accept our
invitation to visit the Ardvar woods. To that extent, the people of Assynt
have been let down by their elected representatives.
We have articulated our view of what has happened
here, because others appear unwilling or unable to do so. The local deer
management group has been very sorely tested, but it has survived and has
grown stronger, and we will ultimately be the better for that. In the
future, we hope that SNH as an organisation can change along the lines we
have suggested above. If it can, then land managers will find it easier to
arrive at working solutions, local communities will have more faith in what
SNH is trying to achieve and Scotland’s natural heritage will ultimately
benefit. That should be what we are all striving for.
Mackay is vice-chairman of the Assynt Crofters Trust and chairman of the
Assynt Peninsula Deer Management Sub-Group. Victor Clements is a woodland
advisor and author of the Assynt Peninsula Deer Management Sub-Group’s deer