Freedom of Information Request - Twinflower Population Creag Bheag
Date: 25 September 2025
Our ref: SIR181604/A5445730
Information Request – Twinflower Population Creag Bheag
Your Request
A stated aim of the Cairngorms Wild Plants project was "to provide advice and support to land managers at existing sites". The Creag Bheithe Bheag site is no more than 4 km from the CNPA offices in Grantown.
a. Question. What prior contacts did the CNPA, NatureScot and Plantlife (as Cairngorms Nature Action Plan partners for Twinflower) have with the owner / manager of Creag Bheithe Bheag?
b. Question. Did the CNPA, NatureScot or Plantlife alert the owner / manager of the wood that Twinflower was present? If not, why not?
c. Question. Did the CNPA, NatureScot or Plantlife respond to the consultation on the clear fell / restock proposal in autumn 2023? If not, why not?
d. Comment. NatureScot and Plantlife have access to all BSBI plant records. The occurrence of the Creag Bheithe Bheag Twinflower site was known to the first Cairngorms Rare Plant Project, and was included in 'The Flora of the Cairngorms National Park - A Rare Plant Register', published in May 2013, with support from the CNPA. A copy was supplied to the CNPA.
2. Question. Do the CNPA and NatureScot have GIS based systems that allow for plotting notable species occurrences, including Twinflower, against land management polygons, including clear felling operations? If not, why not? If they do, why was the occurrence of Twinflower not highlighted and communicated to Scottish Forestry and the landowner / manager? It should have taken relevant staff a matter of minutes to realise that a Twinflower patch occurred within a proposed clear fell. The solution to that potential conflict is obvious, as would apply to e.g. a badger sett.
3. Question. Twinflower is surviving (just) at Creag Bheithe Bheag. As an isolated population, possibly of a unique clone, what actions will CNPA, NatureScot and Plantlife (as Cairngorms Nature Action Plan partners for Twinflower) undertake to ensure the plant's survival at this site?
Our Response
We have discussed your request with the Operations Team, and we have responded to each question in turn.
Question. What prior contacts did the CNPA, NatureScot and Plantlife (as Cairngorms Nature Action Plan partners for Twinflower) have with the owner / manager of Creag Bheithe Bheag?
There was a consultation with the landowner’s agent (Premier Woodlands) on the long-term forest plan. But NatureScot staff were not aware of any consultation from Scottish Forestry about a felling licence.
Question. Did the CNPA, NatureScot or Plantlife alert the owner / manager of the wood that Twinflower was present? If not, why not?
The Operations Team did have a consultation but did not comment on twinflower. Our comments were restricted to the nearby designated site Anagach Woods and measures to protect any capercaillie interests. Our service level statement sets out what can be expected from NatureScot staff, and it does not include trawling for information on rare/scarce species or even usually protected species.
Question. Did the CNPA, NatureScot or Plantlife respond to the consultation on the clear fell / restock proposal in autumn 2023? If not, why not?
The Operations Team was consulted by the landowner’s agents, and our response was limited to the effects of the felling on capercaillie, as part of our Service Level Statement.
Question. Do the CNPA and NatureScot have GIS based systems that allow for plotting notable species occurrences, including Twinflower, against land management polygons, including clear felling operations? If not, why not? If they do, why was the occurrence of Twinflower not highlighted and communicated to Scottish Forestry and the land owner / manager? It should have taken relevant staff a matter of minutes to realise that a Twinflower patch occurred within a proposed clear fell. The solution to that potential conflict is obvious, as would apply to e.g. a badger sett.
NatureScot has a GIS based system that allows for the plotting of species occurrences from select datasets. The GIS system permits access to a dataset “Rare Plants Register – Cairngorms NP” which contains data on a vascular plants species including twinflower, but only up to 2010, and a second dataset covering the Central Highlands titled “Priority Vascular Plant Species”.
NatureScot staff do not search datasets for rare or scarce species every time there is a consultation. Our comments address the likely effects on national interest. In this case we considered the effects on capercaillie, from a proposal out with protected areas, but which might have an impact upon protected areas.
See our guidance on planning.
Question. Twinflower is surviving (just) at Creag Bheithe Bheag. As an isolated population, possibly of a unique clone, what actions will CNPA, NatureScot and Plantlife (as Cairngorms Nature Action Plan partners for Twinflower) undertake to ensure the plant's survival at this site?
We will recommend that as part of a project being led by Plantlife that clonal material is collected from the site and propagated ex-situ. We will also liaise with CNPA and Plantlife on how to proceed, for example liaising with the owner or land manager which might include advising the owner or land manager of the clear-felled site that twinflower is present, providing the location of the surviving twinflower and recommending that the twinflower be taped off during re-stocking to avoid damage. However, it would be up to the owner or land manager to decide whether to act upon this advice.
How We Handled Your Request
We believe you have asked for environmental information as defined in the Environmental Information (Scotland Regulations 2004 (‘the EIRs’), so we are dealing with your request under those regulations. To be able to use the EIRs, we must apply an exemption under section 39(2) of the Freedom of Information (Scotland) Act 2002 (‘FOISA’). The Scottish Information Commissioner’s guidance recommends that public authorities apply this exemption to environmental information and handle request under the EIRs.
If you would like to find out more about the access to information legislation, there is a guidance booklet available on the Scottish Information Commissioner’s website.
Review and Appeal
I hope this information meets your requirements, but if you are dissatisfied with how we have responded to your information request, please write to us within 40 working days explaining your concerns. You can contact us at Battleby, Redgorton, Perth, PH1 3EW or email us at [email protected]. We will carry out a review of our response and contact you with our findings within 20 working days.
If you are not satisfied following this, you can make an appeal to the Scottish Information Commissioner within 6 months. The Scottish Information Commissioner can be contacted at:
Scottish Information Commissioner
Kinburn Castle
Doubledykes Road
St Andrews
Fife
KY16 9DS
Telephone: 01334 464610
Yours sincerely
FOI Officer,
NatureScot
