Annex 6: Details of peat extraction in Scotland Information about peat extraction sites in Scotland is taken from Brooks (2003)1 and its accompanying spreadsheet. It does not distinguish between those sites cut for horticultural peat and those for other uses, but the footnote to Table 2.3 shows that, in 2009, the peat cut for energy was approximately 5% of the total volume; no figures are available for the volume of peat used by distilleries. Raised bog peat (made up of lowland raised bog and montane and sea-level blanket bog) is much more widely distributed in Scotland than in England, but no suitable sources were available to illustrate the position of each site within its wider peat deposit (as relevant to HAP Target 3) as is done for England and Northern Ireland in Annexes 4 & 7. Brooks (2003) reports on 72 sites in Scotland. Of these, 20 consents are thought to be active; 16 are known to have expired; there are 3 consents pending; and confirmation of status was awaited for 33 sites at the time the draft report was submitted. Of the 32 local authority areas in Scotland, 16 have no records of any consents for peat extraction (Brooks, 2003). The main concentrations of peat extraction sites are found in Argyll & Bute, Shetland, Highland, South Lanarkshire, Aberdeenshire and Dumfries and Galloway. As is required within the Review Of the Minerals Planning consent (ROMP) process2, the most recent consents appear to place more emphasis on restricting working practices and a requirement for restoration plans. Afteruse objectives for sites are varied, and include wetland creation, forestry and agriculture; none mentions raised bog restoration specifically. Further investigation is required to determine the effectiveness of the ROMP process in delivering biodiversity gain in 2011. Brooks’ results are summarised in Table A6.1. Consents have been granted on 2,237ha of peatland and the total area of peatland covered by a current active consent is 520ha. This does not indicate how much of a site is in production at any one time. It is of interest to note that there are no longer any known active consents on any Natura 2000 lowland raised bog (there are two on blanket mire), although confirmation of this from local authorities is still required. It means that the achievement of T1 on Natura 2000 sites is not being delayed by peat extraction, though the target does not deal exclusively with such sites. There appears to be very little consistency in restrictions on operating practices. Working conditions, such as the depth of peat to be left, are variable. When mentioned at all it is between 0.3m and 1m. More often than not this type of detail is left to a later date, by which time it may be too late to retain the ideal depth. Plans have been requested for most of the consents issued after 1995, but there are no records of restoration plans requested pre-1995. The operator is always charged with the responsibility for developing the plan and this must be agreed with the local authority and sometimes Scottish Natural Heritage (SNH). SNH is always cited as a reference point for advice. No information is available as to whether SNH have been consulted, or what their advice has been. In some cases operators are requested to complete extraction in designated zones before they can move on to other areas within the overall consent. It is not always clear why this is requested, as operators are not asked to restore sections before they move on. However, this requirement could be developed in conjunction with the restoration plan, so minimising the loss of species from the site altogether, assuming unworked areas can be maintained as functioning peatlands whilst extraction is going on nearby. Only one of the consents requires a strip to be left uncut, but it is not clear whether this is as a firebreak, for landscape reasons or as a refugium for bog species.

1 Brooks (2003) is held by Scottish Natural Heritage as a draft report and was made available for this

project. It is quoted with their permission. The draft has not been developed into a final version. 2 Required under the Environment Act, 1995.

Only one consent (part of a section 75 planning agreement) makes reference to a financial bond. One operator (name and site withheld because of confidentiality) were required to deposit £10,000 in an interest earning account to be used during the restoration phase. Afteruse objectives refer to nature conservation, forestry, agriculture and in one case a windfarm. Effectiveness of the ROMP3 in Scotland In Brook’s report only one of the questionnaire returns stated that a ROMP had been undertaken. This was for Tillinamolt SAC/SSSI, Aberdeenshire which falls into the Phase 1 list (footnote to Table A6.2). It is interesting to note that only 8 peat extraction sites were identified in the Scottish Executive 2002 review (Table A6.3) as requiring a ROMP. It is not clear whether these sites have now received ROMPs. From the list of 8 sites the Lower Camster consent has now expired (2001). Brooks was still awaiting confirmation of details from the other relevant local authorities when the draft report was written. It would appear from records collected by Brooks that Dale Moss (Highlands, consent 1981), Springfield Moss (Midlothian, consent 1978) and Hillhouse Farm (South Lanarkshire, consent 1963) should also have received ROMPs. In the case of Highlands and South Lanarkshire no reference was made to this on their questionnaire returns to Brooks and it remains to be investigated further. Midlothian did not return its questionnaire. The information collated by Brooks is so far incomplete in determining the effectiveness of ROMPs where they have been applied in Scotland. However, simple colour-coding for the biodiversity prospects for each site has been applied to Tables A6.1 and A6.2, though the information on which to base judgements is poor compared to England. Only Flanders Moss has good prospects on those parts of the site where permission existed for peat extraction; much of the past threat to Flanders Moss has been from commercial forestry. The amber category has been given to sites in Table A6.2 where permissions have expired, taking the optimistic view that no further damage will arise from peat extraction, even though the restoration prospects are unclear. A similar category is given to Tillinamolt Moss, an SSSI/SAC on which the permission is described as pending. All other sites have been placed in the ‘poor prospect’ red category. Brooks allegedly encountered significant difficulties in soliciting relevant information from some local authorities. Information from six local authorities was still outstanding at the time of publication; these were: Argyll & Bute, East Renfrewshire, Falkirk, North Lanarkshire, Shetland and Moray. Limited verbal reports were received from Midlothian and Dumfries and Galloway councils and Scottish Borders had stated they had insufficient staff resources to respond to requests. These omissions are significant and leave many gaps in the Brooks study. Extraction companies and the use of the peat Brooks (2003) does not distinguish between the uses of the extracted peat, and it is expected that many, probably extracting over relatively small areas, are for use in whisky production, particularly in the Western and Northern Isles. This, together with the ‘unknown’ status of the planning consents on about 65% of those listed in this Annex, as taken from Brooks (2003), makes it difficult to form an accurate picture of how extraction for horticulture (as linked into the effect of the HAP replacement target) affects biodiversity, other than the obvious effect of destroying what was originally present.

3 Although the amount of detail included here may seem excessive, it shows the degree to which the

ROMP, one of the most important mechanisms for updating working and afteruse conditions on bogs, has been implemented.

Some of the peat extractors listed in Table A6.1 are active nationally, and as such provide company policy information on their websites. National and multinational companies involved in the provision of growing media and undertaking peat extraction in Scotland include: The Scotts Company (UK) Ltd; Richardson’s Moss Litter Company (now part of Scotts); William Sinclair Horticulture and The Boothby & Penicuik Peat Company Ltd.

Table A6.1 Active or unknown consents in Scotland (from Brooks, 2003, database). Expired permissions are excluded.

Site Name Registered Operator Working Status Period yr ROMP

restoration plan Afteruse

Conservation area ha

Extraction area ha

Site area ha

Consent Status

Auchencorth Moss Boothby & Penicuik Peat Company Ltd active 35 unknown 162 334 active

Baltersan G Dunlop dormant 20 unknown active

Causeymire Dale & Achkeepster Farms Ltd intermittent unknown agriculture active

Cladance Moss William Sinclair Horticulture Ltd active 20 unknown 70 active

Creca Moss Richardson Moss Litter unknown 9 unknown 40 0 45 active

Dale Moss Dale & Achkeepster Farms Ltd intermittent unknown unknown active

Hillhouse Farm The Scotts Co Ltd active unknown unknown 40 active

Hobbister, Orphir Highland Malt Distilling active 10 Yes nature active

Knockishee Holker Estate intermittent 30 unknown active

Langass, North Uist Donald. A. Currie active 5 agriculture active

Lochwood Moss RGL Peat Producers dormant 19 unknown active

Middlemuir George Watson dormant unknown unknown 21 0 0 active

Ryeflat Moss William Sinclair Horticulture Ltd unknown 20 unknown 55 active

Springfield Moss Boothby & Penicuik Peat Company Ltd active 27 unknown 65 0 130 active

St Fergus Moss Herbst Peat & Energy Scotland intermittent 10 Yes unknown 0 0 726 active

Westerdale Dale & Achkeepster Farms Ltd unknown 20 other active

Whitehills George Watson dormant unknown unknown 0 0 0 active

Woodend Farm A The Scotts Company Ltd (Carnwarth) unknown 20 unknown active

Woodend Farm B The Scotts Company Limited (Carnwarth) active 20 unknown 67 active

Greenloch Moss George Watson active unknown Yes nature 0 50 50 pending

Nutberry Moss Richardson Moss Litter completed 47 unknown 21 339 pending

Tillinamolt Moss George Watson intermittent 20 Yes Yes nature 0 0 0 pending

Arden Moss Arden Peat Ltd unknown 20 unknown 129 0 0 unknown

Ardshealach D Cameron unknown 20 unknown 0 0 0 unknown

Aros Moss Duke of Argyll unknown unknown unknown 0 0 0 unknown

Ballivicar Farm J A McTaggarts unknown 6 unknown 112 0 0 unknown

Birkhill Farm unknown 20 unknown 23 0 0 unknown

Braehour Caithness Peat Ltd unknown 30 unknown 0 0 0 unknown

Bunnahabhain The Highland Distillery Company unknown unknown unknown 0 0 0 unknown

Site Name Registered Operator Working Period yr ROMP restoration Afteruse Conservation Extraction Site area Consent

Status plan area ha area ha ha Status

Camster (B) EJ Darmady unknown 25 unknown 0 0 0 unknown

Camster (C) Peat Charcoal Ind unknown 22 unknown 0 0 0 unknown

Caol Iia Scottish Malt Distillers unknown unknown unknown 0 0 0 unknown

Castle Hill Moss Scottish Malt Distillers unknown unknown unknown 400 unknown

Creeside Farm Creeside Farming Company unknown 20 unknown 16 0 0 unknown

Cunningsburgh W Malcolmson unknown 5 unknown 5 0 0 unknown

Duich Moss B unknown unknown unknown 70 0 0 unknown

Eilean An Muice Dubh McIntyre & Brown unknown unknown unknown 0 0 0 unknown

Fannyside Muir Richardson Moss Litter unknown unknown unknown 0 0 0 unknown

Gardrum Moss William Sinclair Horticulture Ltd working* unknown unknown 160 unknown

Gremista B Peterson unknown 3 unknown 5 unknown

Gutcher HA Dickie unknown 10 unknown 10 0 0 unknown

Hill of Borno L Garson unknown unknown unknown 0 0 0 unknown

Kintour Moss Hiram Walker & Sons unknown 30 unknown 14 unknown

Lagavullin unknown unknown unknown 0 0 0 unknown

Laggan Moss Morrison Bowmore Distillers unknown unknown unknown 3 0 0 unknown

Letham Moss Richardson Moss Litter unknown unknown unknown 160 0 176 unknown

Machrie unknown unknown unknown 0 0 0 unknown

Mid Yell AJ Johnson Peat unknown 5 unknown 20 0 0 unknown

Moodiesburn Krikken Brothers unknown unknown unknown 15 0 0 unknown

Moss of Achnacree J Neilson unknown 60 unknown 3 0 220 unknown

Park Hall Bixter RB Eunson unknown 2 unknown 2 0 0 unknown

Scatsta W Malcolmson Peat unknown 5 unknown 1 0 0 unknown

Shiel Farm T Hamilton unknown unknown unknown 28 0 0 unknown

Vaila RH Anderson unknown 5 unknown 23 0 0 unknown

Westerhillhouse Farm Mr Dow unknown 60 unknown 0 0 0 unknown

Whim Moss Boothby & Penicuik Peat Company unknown unknown unknown 75 224 unknown

Woolfords Messrs Hamilton unknown 22 unknown 77 0 0 unknown

It is not known why Site Area is missing or cited as 0 ha where other areas are given. The meaning of ‘pending’ as a consent status is unknown, though could refer to ROMP status. *Gardrum Moss was not being worked in 2010 (R Meade pers. obs. June 2010). See Table A6.3 for colour shading code.

Table A6.2 Consents for all peat extraction permissions on or within 1km of an SSSI/SAC (Brooks, 2003)

Local Authority Site Name Bog type Within 1km of a

Designation

On Designated

Site Consent Status

Aberdeenshire Council Tillinamolt Moss Intermediate SSSI, SAC pending

Argyll & Bute Council Duich Moss A blanket SSSI, SAC expired

Argyll & Bute Council Eilean An Muice Dubh blanket SSSI, SAC SSSI, SAC unknown

Argyll & Bute Council Lagavullin blanket SSSI, SAC unknown

Argyll & Bute Council Laggan Moss blanket SSSI, SAC SSSI, SAC unknown

Argyll & Bute Council Kintour Moss unknown SSSI unknown

Dumfries and Galloway Baltersan raised SSSI active

Dumfries and Galloway Knockishee unknown SSSI active

Dumfries and Galloway Larbrax Moor blanket SSSI expired

Highland Council Ardshealach blanket SSSI, SAC unknown

Highland Council Camster (B) blanket SSSI, SAC unknown

Highland Council Drimnatorran blanket SSSI, SAC expired

Midlothian Council Auchencorth Moss blanket SSSI active

Orkney Islands Council Hill of Borno unknown SSSI unknown

Scottish Borders Council Whim Moss raised SSSI unknown

Shetland Islands Council Gutcher blanket SSSI unknown

South Lanarkshire Council Birkhill Farm raised SSSI SSSI unknown

South Lanarkshire Council Ryeflat Moss raised SSSI active

South Lanarkshire Council Woodend Farm A raised SSSI active

South Lanarkshire Council Woodend Farm B raised SSSI active

Stirling Council Flanders Moss raised SSSI, SAC SSSI, SAC expired

Stirling Council Offerance Moss raised SSSI, SAC SSSI, SAC expired

The statutory requirements for the review of old mineral permissions are established in S.74 and schedules 9 & 10 of the Town and Country Planning (Scotland) Act 1997. In general terms: 1. A Phase 1 site is defined as one where the predominant permission was granted after 30th June 1948 and before 8th December 1969. 2. A Phase 2 site is defined as one where the predominant permission was granted after 7th December 1969 and before 22nd February 1982. 3. A Dormant site is one where no substantial minerals extraction was carried out since 22nd February 1982. Colour codes for Tables A6.2 and A6.3: colour shading indicates the authors’ opinion of outcome for bog biodiversity: green = good because of a commitment to raised bog restoration. For the remainder, there is no commitment to a raised bog afteruse; amber = unclear or partial, red = poor or none.

Table A6.3: Peat extraction sites identified by the Scottish Executive 2002 review (Source: Brooks, 2003) as requiring ROMPs

Site name Local Authority Lower Camster Highland Bunnahabhain Argyll & Bute Lagavulin1 Argyll & Bute Kintour Moss1 Argyll & Bute Caol Ila Distillery Argyll & Bute Gardrum Moss Falkirk Peat Moss2 Tillnamolt

Aberdeenshire Whim Moss1 Scottish Borders

1 cited as SAC and/or SSSI in Table A6.2 2 not listed under this name in Brooks’s table or by Corporate Watch (undated)

Figure A6.1 Maps of peatland nature conservation sites and extraction sites in Scotland A map of the distribution of peat deposits Scotland was beyond the scope of the project.