National Parks Advice to Ministers - Annex B - Online Consultation – List of respondents and analysis of responses

Key points:

There was significant support for the overarching purpose of Scotland’s National Parks to incorporate these additional elements.

The case was also made that the existing four statutory aims continue to be highly relevant.

Many commented on the need for the purpose to refer to nature positive (as well as net zero). A number of respondents also felt further emphasis was needed on climate change mitigation and adaption; cultural heritage; landscape and recreational qualities; and support for local communities and rural economies.  

Issues of clarity and definition were raised including what both a recovered nature and a just Transition to net-zero meant in practice - does it describe an end-point, such as a ‘nature-based economy’?

Selected quotations:

Yes….. the primary goal of new and existing National Parks should be to lead nature recovery, and act as exemplary models of progressive land management for the whole of Scotland. This in turn will make vital contribution towards our net zero target by 2040. (JMT)

…. the overarching purpose does provide a clear direction to National Parks and ties in with the direction in the recently approved Cairngorms National Park Partnership Plan. (CNPA)

The wording of this purpose could be strengthened further to state “a just transition to net zero and nature positive”.  Becoming Nature Positive means halting and starting to reverse the nature loss by 2030 and recovering nature by 2045. (Buglife)

While we fully support the aspiration for a new national park to lead on nature recovery and a just transition to net zero, we do not support this as an overarching purpose; because it does not sufficiently recognise the important and wide-ranging role that cultural heritage plays. (HES)

No, we recommend that the statutory aims of Scotland’s National Parks should continue to be the conservation of natural and cultural heritage; sustainable use of the area’s natural resources; access and education; and sustainable economic and social development of the area’s communities (BASC).

Achieve environmental, economic and therefore social objectives. (Dunecht Estates)

Wish to see some clarity as to what the connection of the proposed overarching purpose is with the existing four collective aims set out in the National Parks (Scotland) Act 2000.  (RTPI Scotland)

There are other important purposes of National Parks, including conservation of cultural heritage; facilitating social and community engagement; landscape protection; to engage visitors with our heritage; and potentially to manage visitor pressures. (NTS)

Key points:

Majority of respondents supported all the elements.

Most additional elements of leadership and action suggested fell into the following categories:

• ensure that economic impacts are just;
• innovate and pilot;
• provide outreach and visitor engagement;
• adequate emphasis on nature protection;
• thriving rural economies and communities;
• enhance benefits for people; and engage communities

Selected quotations:

Need Government policy on how National Park leadership is intended to provide a best practice approach to influence wider spatial policies in other areas (CIfA)   

A recurring concern [is] that existing national parks have failed to retain local people or protect rural businesses, and that increased tourism and visitor access has driven up the price of property, thereby pricing out locals and resulting in an influx of wealthy, second homeowners. (NFUS)

A key ingredient has been omitted – education. A National Park has a uniquely important role to play in educating the public about the “why” and “how to” of the proposed actions. It can provide a wide range of effective learning experiences for visitors, local people, and schools. (Campaign for a Scottish Borders National Park) 

We would also recommend adding Demonstrating and facilitating increased understanding and development of the vital inter-relationships between the environment, economy and communities; ensuring that National Parks embrace diversities of environment, economics and society; National Parks consider the long term, outwith short term political cycles. (Invercauld Estate) 

Achieving large-scale regeneration will require a substantial number of businesses with a capable workforce.  The regulatory constraints should be reviewed (Galloway National Park Association)

The references to the potential role of National Parks in securing green investment are welcome. National Parks are already pioneering in this area through the Revere project facilitated by UK National Parks Partnerships.  (LLTNPA)

There is an opportunity … to think about positioning visitors as an integral part of a positive, vibrant place, where responsible tourism can contribute positively to thriving communities, vibrant businesses, and a well-managed environment, working together to support the transition to net zero. (VisitScotland)

New forms of sustainable development and related housing solutions should be viewed as a criticality. (Comhairle nan Eilean Siar)

Of respondents to this question, most suggested some opportunities.

Key points:

General points included the need for careful implementation and links with related initiatives. Specific opportunities included:

• carbon offsetting, carbon credit, woodland and peatland carbon codes;
• habitat creation, ecological restoration;
• payment for ecosystem services;
• sustainable local products/produce, including tourism;
• renewables; and
• planning gain, Biodiversity Net Gain, Marine Net Gain.

Several respondents were opposed to private investment in natural capital in National Parks.

Selected quotations:

The Scottish Government should seek to promote creditable standards and metrics for a natural capital approach in general to generate confidence for investment. National Park Authorities can play an important role in encouraging this development. (Dunecht Estates) 

Opportunities with nature investment, such as carbon credits - such income schemes should provide financial benefit and employment to communities. (Strathglass Community Council)

[There is an] opportunity presented by Biodiversity Net Gain (BNG) and Marine Net Gain (MNG) for developments, such as renewable energy projects, to generate private investment in nature enhancement. (Scottish Renewables)    

… the fifth element on the list should be strengthened to specify “responsible private investment in natural capital” and should refer to the Scottish Government’s Interim Principles for Responsible Investment in Natural Capital. (RSPB)  

We see an opportunity for National Park Authorities to work with the Scottish Government to further refine the Scottish Government’s Principles for Responsible Investment in Natural Capital to generate a more detailed set of principles for investing in natural capital within National Parks. (SE LINK)

… nature-based tourism and the provision of outdoor learning opportunities are possible ways for securing additional private investment.  (Mountaineering Scotland)

Appropriate woodland planting and peatland restoration for carbon management. (South Lanarkshire Council)

Key points:

Local communities have an important role to play.  Most responses focused on actions led by the National Park authority rather than by communities; the focus was mostly on how best to ‘work with’ communities rather than ‘work for’ them. 

Other points included:

• the National Park should employ best practice in working with communities;
• the National Park should help to build capacity and skills for community engagement and support this with resources;
• the National Park must recognise the diversity of communities and wider population;
• communities should be represented at all levels in the National Park;
• communities have important perspectives to bring to the National Park;
• the National Park should pay attention to existing community structures; and local communities should play a role in securing a Just Transition

Select quotations:

Communities in National Parks should be involved in decision making that shapes their places to the same extent as in other parts of Scotland, in line with the Place Principle.  (A&DS)

Engagement, from consultation through to participative action, needs to be adequately resourced to be effective. (Berwickshire Marine Reserve) 

Clearly local communities are fundamental …… and we would flag that other communities of interest will have a role also, including those who value the area and visit it. (SportScotland)

Communities should be an integral part of all decision-making, particularly in regard to the provision of affordable housing and control of second-home ownership. (Heart of Argyll Wildlife Organisation)  

National park authorities must do better at making local representation more accessible and inclusive. Local communities are rarely a cohesive and unified voice. (NFUS)

There must be a balance of local interest with national interest within the National Park. (Buglife)  

A truly just transition to “net zero” must take account of inequalities of health, opportunity and access to public services at community level, not just national and regional. The educational role of the NPA will be important … and its ability to facilitate public/private partnerships in order to achieve a just transition. (Campaign for Scottish Borders National Park)   

We would like to see National Parks being more proactive in promoting opportunities for re-skilling and training in a broad spectrum of subjects relating to the high quality environment of National Parks. (Badenoch and Strathspey Conservation Group)  

Local communities should be represented on the National Park Board. (South Lanarkshire Council)

It will be vital to ensure there are real and tangible community benefits. (Trees for Life)

Key points:

Strong support for a National ‘vision and mission’. This would: give all selected areas the same stature; help coordinate ambition and action; give a cohesive, clear and overarching purpose (i.e. nature/culture versus social and economic development), goal and future vision for everyone to aim for; highlight priorities; provide for public understanding; develop a similar culture; and link to the global family of National Parks.

Recognition that the statement needs to provide clarity and direction for National Parks with regard to the climate and nature emergencies.

Strong calls in many responses seeking local setting of vision and priorities tailored to local circumstances and issues etc.  Some respondents seeking a balance – a statement with an overarching national purpose yet enabling local vision setting.

Selected quotations:

National ‘vision and mission’ would give all selected areas the same stature and clarity of purpose. (Dumfries and Galloway Council)  

The creation of a vision and mission will also aid new parks as they develop organisational cultures and future plans. (Rewilding Britain)

Setting out a clear ‘vision and mission’ seems a sensible way to coordinate ambition and action across our existing and any new National Parks. (SE LINK)

A vision and mission statement for National Parks would provide an ideal opportunity to explain how the imperative to do much more on nature recovery and a just transition fits with the existing National Park aims. (SCNP/APRS)  

The delivery of the vision and mission should be flexible to allow for appropriate governance and structures adapted to the circumstances of the selected areas. (SOSE)

Park administrations, in tandem with local stakeholders, such as Local Authorities, should develop locally appropriate vision and mission. (Comhairle nan Eilean Siar)

The two existing National Parks are very different and future National Parks could be more different still so there needs to be flexibility within each to meet specific challenges and opportunities- a more prescriptive national vision and mission could prejudice the ability to achieve this. (Invercauld Estate)  

Key points:

Strong support for the statement to emphasise the role of National Parks in addressing the climate and nature emergencies through action to restore nature at the landscape scale and by managing  ecological networks within and across Park boundaries.

Significant amount of responses around the theme of making wider policy and practice links: consideration of co-working between Parks and other designated sites/landscapes; 30 x 30; Scotland’s National Performance Framework, Scotland’s Biodiversity Strategy; and wider national commitments at an international level, such as the UN Sustainable Development Goals and targets of the Convention on Biological Diversity.

Significant amount of responses around the theme of National Parks delivering benefits for people and active, resilient, engaged and knowledgeable local communities.  In addition, that National Parks should be accessible for all.

Select quotations:

The National Statement should address how National Parks will contribute fundamentally to addressing the twin crises of climate change and biodiversity. (CIEEM)  

The national statement should express clearly that the primary purpose of national parks is rewilding (or nature restoration) to tackle the biodiversity and nature emergencies, but that nature recovery will be delivered in such a way that it will enable communities to thrive and nature-based businesses to succeed. (Trees for life)

It should also recognise that virtually all of Scotland’s landscapes are the product of millennia of interaction between people and nature and that much that we value in them reflects this longstanding and ongoing relationship. (SCNP/APRS) 

Although there is likely to be a new focus on nature restoration and the move to net zero, the need to preserve and restore designated landscapes primarily for their natural heritage and landscape quality will still underpin the role of national parks and as such should be covered in the national statement.   (Landscape Institute) 

The National statement should demonstrate commitment to those communities within and adjacent to the National Park. (Dumfries and Galloway Council)

Whether it is a place known nationally, and around the world, a place known to be a great place to live, work, or visit; a place known for exemplary Biodiversity with a forever vision of suitably advancing Nature; or a place displaying world leading landscape, it is most importantly, a place we are all 'Proud of'; and as a community are 'Proud to belong with'. (Strathglass Community Council)  

Key points:

Overall, most respondents agreed that National Parks should be about the future potential of an area for nature restoration as well as what’s currently in place, as there is a significant need to address the climate and nature emergencies.

The theme of rewilding featured in a number of responses.

The theme of not leaving people out of the nature restoration picture also featured throughout.

Selected quotations:

If ‘leadership of nature recovery and a just transition to net zero’ becomes the overarching purpose of Scotland’s National Parks, which we believe it should, then nature restoration and protecting existing areas of high biodiversity value should be a key consideration in all decisions that are made. (BES)

There is a clear role for all National Parks in identifying and demonstrating the future potential of areas for nature as well as improving existing areas that are important for nature. National parks should be at the forefront of nature recovery effort and make significant contributions to national targets. (SE LINK)

Any new National Park designation needs to firmly take into account what is currently in place alongside capturing the future potential of the area. This includes ensuring the protection of economic growth, communities and the livelihoods and operations of those who manage the land in harmony with nature recovery and net zero objectives. (Confederation of Forest Industries)

Rewilding is the large-scale restoration of ecosystems to the point where nature is allowed to take care of itself. Rewilding aims to reinstate natural processes and, where appropriate, missing species – allowing them to engineer and restore habitats. Effective rewilding encourages a balance between people and nature. This approach is perfectly suited to our national parks, where large areas still require significant regeneration. (Scottish Rewilding Alliance).

A fundamentalist approach to nature restoration has the potential to alienate local communities and landowners whose stewardship has already resulted in generating a historic landscape with considerable nature conservation value. (SCRA).

Alongside existing nature restoration practices, we need to see ambitions to develop innovative approaches which drive nature recovery, we need to improve people’s connections with nature, and we need to fundamentally ensure that these landscapes go beyond visual appeal and provide places for living and working communities. (SL&E).

Communities and businesses expect National Parks to be about nature restoration – and not just about conserving what is already in place.  Visitors to National Parks also expect there to be nature restoration – it’s the main stated reason for visits to National Parks.  But it is important that communities are involved early on in discussions about what that nature restoration might mean. (Stirling Council)

*note - a number of individual respondents put in the same response from what appears to be a template.

Key points:

Of the respondents who felt that changes to the aims are required, many of them stated that nature recovery and net zero should be the focus. 

Other respondents were clear that they felt no changes are required; although a small number of those respondents did go on to suggest some possible changes if changes are going to be made anyway, with nature recovery and net zero being the focus.

The need to change the ‘conserving and enhancing natural and cultural heritage’ and ‘sustainable use of resources’ aims were highlighted by many respondents, though they was a wide range of views of what these changes should be.

Selected quotations:

The aims should more adequately reflect the urgency of the nature and climate crisis through updating the wording.  Adding an overarching purpose would help provide clarity about how the four aims should be interpreted and what they are ultimately trying to achieve (SELINK).

The current aims of the National Parks are broad, and this is a strength in that all the issues that Parks must face are interrelated e.g., to be able to undertake peatland restoration in the park you need good data, a skilled workforce and affordable housing for employees. (CNPA)

The required shift in priorities for addressing nature and climate change could happen under the existing Aims (Friends of Loch Lomond and the Trossachs)

[There] may be a tension between the potential additional aims “secure nature recovery” and “a just transition to net zero” – how these aims integrate and which has priority, if any, should be clear. (Argyll and Bute Council)

The areas are also a resource for people’s health and well-being and we’d seek that the original aim around promoting understanding and enjoyment isn’t lost. Looking at the barriers to people being able to access these areas is something we’d support. (SportScotland)

[Listening] to voices of young people who live in the Parks is critical too – and maybe should be reflected in the aims. (Stirling Council)

Sustainable use of the natural resources of the area should be promoted, but maybe a check in place if it adversely impacts the conservation and enhancement of the natural and cultural heritage of the same area. (Strathglass Community Council)

In our opinion, Section 1 (a) – (d) and Section 9 (6) are sufficient legislation to achieve the aim of nature recovery. It is national development planning, transport planning, forestry and agricultural policy and funding that will drive change, co-ordinated by the National Park Authority.  (Mountaineering Scotland)

Note - a number of individual respondents put in the same response to this question from what appears to be a template.

Key points:

There was a mix of views on the best option, with Option 2 (keeping the policy intention of each Aim unchanged but rewording them to better reflect the new vision and mission in the proposed national statement), Option 3 (keeping the four Aims but including a new overarching statutory purpose of National Parks to secure nature recovery and a just transition to net zero;) and Option 5 (reducing the Aims to the first one and changing the other three Aims to duties, thus giving the National Park a much stronger, single statutory focus on the protection and enhancement of the natural and cultural heritage) attracting the most support overall.

There was debate in some of the organisations responses about whether the options which did not require any, or any significant, legislative change would be better given the tight timescale for establishing a new National Park.

The need to be clear about how the aims relate to each other and to be clear about how and when priority should be given to the first aim was also mentioned by several respondents

Selected quotations:

Keeping the four Aims but include a new overarching statutory purpose of National Parks to secure nature recovery and a just transition to net zero. (South Lanarkshire Council)

The overarching statutory purpose should be expanded to include “leadership on addressing climate change”. (Scottish Power Renewables)

The environment must remain the first key principle of any national park. (Marine Concern and Seal Scotland) 

The Park Authority think that any overarching purpose should be set in policy rather than legislation so that it can be adapted as times and issues change …..  The intent of the current aims should remain the same but that the language could be modernised and should include a reference to nature recovery and the climate crisis. (CNPA) 

Stronger focus needed on local communities, rural economy, agriculture, affordable housing. (NFUS) 

The four current Aims may need reworded so as avoid repetition or overlap. (RTPI Scotland)

Depends on what the overall vision is – need to think through the consequences of the changes. Statements like "to promote the just transition to net zero" or "to increase the accessibility of the areas for all" sound great but need definition. (Perth & Kinross Council)

Key points:

Rather than an additional option, the most frequent comment made was for clear definitions of the Aim to be provided and that these definitions should be updated to be in line with the vision and mission for Scotland’s national parks.  There were also calls for evidence to be used to inform the new Aims with monitoring and review of the Aims thereafter.

There was a wide range of comments made by individuals, though many of them were other elements to be incorporated rather than suggestions on alternative Options.  Priority for nature and priority for local people was frequently emphasised. 

It was suggested that the principle in section 9(6) of the Act (the Scottish version of the Sandford principle) should apply to all public bodies in the National Park not just the National Park Authority.  Clarification of the mearing in practice of “greater weight” was also needed.

Selected quotations:

We suggest that in addition to the options set out above, clear definitions should be provided for the terms in the aims and these definitions should be updated where needed in line with the vision and mission for Scotland’s national parks. (SE LINK)

Whilst nature recovery and net zero issues must have prominence, it is important that these are pursued with the health and economic well-being of local residents firmly in mind.  National Parks must take account of their interests and can serve to rejuvenate areas where there are social and economic challenges. (Galloway National Park Association) 

The need to provide “greater weight” to the first aim if the aims are in conflict should apply to all relevant public bodies operating in the Park and not just the Park Authority.  ‘Greater weight’ should be formally defined in the national policy statement and guidance given about how that approach should be applied within a Park. (CNPA)

Key points:

Responses to this question were evenly balanced. Various wordings for the duty were suggested but all on a similar vein.

A number of organisational respondents said that resources and budget would be required to help other organisations meet this requirement were it to be introduced.

Concern was raised about how organisations with particular duties and plans could be made to fit in with / contribute to a National Park Plan which could be contrary to their own plans.

Selected quotations:

Best drafted as a 'must do' duty with specific mention of key agencies and public bodies to whom this applies and in what context it should be followed. (CIEEM)

…could be improved to “act in accordance with” in order to increase the effectiveness of the plan. (SE LINK)

The wording should be strengthened to require public bodies to support the delivery of national parks, however that this should be backed up by increased resources and designated funded to enable public bodies to effectively deliver national aims. (Landscape Institute)

As public bodies already have a duty to support climate, carbon, and biodiversity outcomes, any additional duties are looked at in the context of how these existing duties may already support this, if they are effective, or whether they need to be strengthened. (Scottish Water)

No. If additional statutory duties are considered, then they need to be accompanied by additional budget to support this. (Aberdeenshire Council)

There should be active encouragement from all public bodies to engage and collaborate with all parties to ensure a balanced view of the requirements of both the communities living and working in National Parks and the needs to enhance / maintain the biodiversity of the land. (Openreach)

The duties should not be changed unless there is clear evidence… (Scottish Renewables)

Should a new NP be proposed in a part of Scotland that overlaps with the Scottish Crown Estate, it will be important for the NP plan to be cognisant of these exiting plans and polices and to align with them. It would be difficult for Crown Estate Scotland to accord with a plan that was contrary to the other plans we accord with. (Crown Estate Scotland)

Collaborative approaches [are important and] can be achieved through existing partnerships within a region.  These approaches are perhaps preferable to making this a statutory requirement which may impact on the existing functions of the public bodies and their ability to deliver against their existing core functions and may act against effective partnership working. (SOSE)

Key points:

Aligning the National Park Plan priorities with the priorities of local authorities and other stakeholders so that everyone is working towards the same priorities featured highly.

Using locals’ and communities, including land managers, detailed knowledge more meaningfully also featured in many responses.

Aligning agricultural support payments with the National Park aims, and ensuring that the management plans that large landholdings will soon have to write (under the Land Reform proposals) align with National Park aims, was suggested.

Selected quotations:

Preparation of overarching nature strategies for the parks will identify priority projects and guide partnership working, as it ensures that all partners understand the direction of travel and opportunities for involvement. These strategies must be measurable. (RSPB)

There should be a concordat agreed between each National Park Authority and the public sector partner authorities that can be independently assessed for compliance by Environmental Standards Scotland. (CIEEM)

There is a greater need to work with community groups, local estates and land managers to ensure that decision making around nature restoration is well-informed and ensures inclusivity of all involved. (BASC)

A Joint Accord was established between Openreach and the Cairngorms, Loch Lomond and the Trossachs National Parks to enable the proactive roll out of fibre broadband services and their associated benefits to communities, in ways that protect and enhance the special qualities of Scotland’s finest landscapes.  [An] Accord should lay out guidelines to establish an alliance of all public bodies, communities and Operators to provide a balanced approach to new development in the National Park and set standards on operating and maintenance requirements.  (Openreach)

There are many individuals/groups with detailed local knowledge of their area and expertise; these groups, some community groups are increasing rapidly and must be included with the National Park Plan and sit on the park management board. (Marine Concern & Seal Scotland)

Management plans for holdings within National Parks should be aligned with National Park aims and Park Plans, and the NPA should be given responsibility for assessing their acceptability, including their compliance. (SCNP/APRS)

Note - Individual responses tended to favour less regulation and more collaboration with local communities.

Key points:

National Park Authorities should be empowered and sufficiently funded to use the full range of their existing powers.  Examples: compulsory purchase and land acquisition powers could be used where needed to improve habitat connectivity, accelerate change or prevent negative impacts.

Planning: responses generally supported maintaining flexibility in how the planning function is delivered in each National Park.  Several consultees expressed the view that the planning function should remain with the local authority or that further consideration was needed of this issue to reflect the changes in planning system.  A case was made for the Park to be responsible for rights of way across its area to enable a more joined-up approach to access.

Visitor management: responses advocated strengthening the powers to deal with irresponsible and anti-social behaviour, with specific suggestions including more scope for National Park Authorities to use fixed penalties and management rules. Responses also advocated increased ranger provision with enhanced enforcement powers and a broad remit (including cultural heritage).

Selected quotations:

National Park Authorities should be empowered and sufficiently funded to use the full range of their powers. (Heart of Argyll Wildlife Organisation)

From protecting ancient woodland to fast-tracking ecosystem infrastructure to providing affordable housing - with nature and a just transition to a nature-based economy as overarching aims, our national park authorities should be confident in exercising their powers. (REVIVE coalition for grouse moor reform)

The transfer of functions to a Park body that enable better coordination and more efficient and speedy delivery of change should be actively promoted. (Trees for Life)

How the planning function is delivered should relate to the scale, nature and location of the National Park selected, as is the case currently with Cairngorms and LLTNP both exercising differing planning powers relevant to their situation. (Argyll and Bute Council)

The principle that the approach to conferring powers on National Park Authorities should be tailored to the needs of each area supported, however, it is suggested that as a minimum a National Park Authority should have some formal role in the planning system and managing access. (LLTNPA)

More effort is required in managing access-related issues and dealing with irresponsible visitors. (NFUS)

Key points:

Although some of the powers and functions have not been used to date, consultees mostly did not see that as a reason to remove them from the legislation.

Some respondent argued that the type and function of any new National Park will determine the range of powers required and how best to utilise these moving forward, for example to ensure integration of the planning and access powers and functions of local authorities and National Park Authorities. 

Specific suggestions of powers or functions that may be redundant, unnecessary or shared included the following:

• research & development and national ranger functions (consultee suggested these should be moved to a body overseeing the suite of National Parks in Scotland);
• compulsory purchase and land acquisition; and
• planning and access powers (several consultees suggested they should remain with the local authority, others suggested that local authorities should have reduced powers).

Selected quotations:

The powers and functions are not redundant but it may not be necessary to adopt them in all instances. (Scottish Borders Council)

We appreciate that some of the powers and functions have thus far never been used but see no reason to remove any from the legislation.( SCNP/APRS)

Planning and Access authority functions of local authorities should be unnecessary as these would be a duplication and additional cost as they are already provided by Local Authorities and could be implemented through special planning conditions and a better integration of services locally. (Dumfries and Galloway Council)

Research and development could be jointly held nationally and at park level, given the local varying conditions yet need for national monitoring. (Europarc Federation)

Key points:

Consider designation of nature recovery zones within National Parks to enable landscape-scale restoration.  Differing views as to whether such zones should be areas not currently designated or to replace existing piecemeal habitat designations.  Such zones could contribute to 30x30 and 10% highly protected targets.  

Various additional powers and functions proposed to better align land management within the National Park to the Park aims, including land management standards and incentives; greater powers with respect to deer management and INNS; and direct ownership or management of public land within the Park area.

Echoing responses to Q11, there were calls for strengthening the duty of public bodies to further the aims of the National Park in all the functions they undertake (land management, funding, licensing, etc.). In addition, it was argued that that a dispute mechanism was needed in cases where this duty was not being followed and that the Park Plan should have a stronger influence in on funding priorities.

If a new coastal and/or marine National Park is proposed, consideration should be given to how to best integrate the coastal and marine planning functions.

Selected quotations:

Large nature recovery zones could replace piecemeal habitat designations, where nature is prioritised and can be restored at scale. This should include bans on muirburn, driven grouse shooting and other intensive land uses. (Scottish Rewilding Alliance) 

Scotland has world leading access legislation, and we would be concerned about proposals which would erode this. (SportScotland)

As part of … designating 30% … for protecting nature, consider whether parts of the National Park core areas not currently under designation should be protected for nature recovery. (LLTNPA)

Park authorities may need new powers and/or funding to e.g. acquire and manage land, ban destructive practices or fund restoration. Where functions currently rest with other bodies it should be considered on an individual basis whether that function would be better moved to the Park or … [stay] with the existing body with a duty to support the aim of the Park. (Reforesting Scotland)  

The Park owning and/or managing any public land within park boundaries. (Trees for Life)

Local Authorities planning functions stop at the coast, but with new marine planning functions and pressures on our coastal space, it would be appropriate to integrate the two systems better. Marine planning is currently under the jurisdiction of Marine Scotland. Further devolution/regionalisation of these functions could be supported by National Park Boards who have stronger knowledge and closer connections to local coastal communities. (Blue Marine Foundation) 

Key points:

Marine: A National Park with a marine area will introduce a new suite of criteria, interests and legislative context, which will need to be reflected in any new or amended powers.

Land management: Consider providing National Park Authorities with greater control or influence over the delivery and prioritisation of funding, including SG agricultural and forestry grants, also powers in relation to the management of deer and grouse moors, to enable closer alignment with the delivery of National Park plans.

Visitor management: Calls for the National Park authority to have the necessary powers and functions to be able to manage visitor pressures, including traffic and parking management, provision of bins and toilets, and have a range of enforcement options.  There may be a case for visitor taxes to be collected by National Park Authorities, or a mechanism ensuring that visitor services benefit from the visitor levy. 

Community development: community well-being development powers should be broadened to align with and support wider goals to create sustainable, resilient and thriving communities.

Selected quotations:

The potential for a park with a marine area will introduce a new suite of criteria, interests and legislative context. Any new or amended powers will need to take this into account, beyond just the stated ‘Better management of land or sea’. The marine environment is complex and has many competing interests. (Comhairle nan Eilean Siar)

Other powers that might be worth considering are more emphasis on NPAs taking ownership of land within the National Park boundary, particularly where it currently lies with other public bodies. This would be with a view to the National Park delivering the integrated management that National Park aims require both faster and more effectively. The argument for such a change would of course be weaker if the duty to further the aims of the National Park were strengthened to include all public bodies as well as the NPA. (SCNP/APRS) 

Sustaining of local character or community…. Development within National Parks, particularly housing, should support the conservation of beauty and a required function of National Parks should be to prohibit inappropriate and insensitive development that does not enhance the environment in which it sits. (NTS)

The National Park authority should have adequate powers and functions to be able to manage associated pressures such as high road congestion at busy times, litter and camping. (SE LINK)

It may be better for a new National Park to take on the full responsibilities of a local authority to guarantee more agile …. [Traffic and parking management]. (NTS)

Key points:

There was a mix of views on this question.  Most responses seem to be in favour of all powers and functions applying to all National Parks and not on a Park by Park basis, This was most commonly referred to for natural heritage functions and – to a lesser extent (and in contrast to responses to earlier questions)– planning.

Echoing responses to previous questions, a sizeable minority of responses leaned towards powers and functions being decided on a Park by Park basis, as this would enable consideration of; local socio-economic and environmental circumstances, needs and opportunities; different requirements, potential and ambitions for each area; and different local aspirations, constraints and conflicts.

Some responses suggested a balanced approach could be achieved, recognising that all National Parks will be different although they could all be guided by similar overarching principles.

Selected quotations:

The powers and functions of National Park Authorities should be universal across all National Parks in Scotland. To do otherwise could limit flexibility, confuse the public and potentially create different tiers of Park, watering down their ‘National’ status. (Invercauld Estate)

Given the scope for discretionary and varying priorities in new Parks it should follow those mechanisms (i.e., functions and powers) to deliver these should be bespoke to individual Park boards.

The context (e.g. community empowerment, community land ownership etc.) has so changed in the intervening period since that last Parks were designated that there is definitely scope for different approaches to management and governance.  (Comhairle nan Eilean Siar)

It would probably be more useful if there was consistency between the National Parks – even if this was a menu-based approach where the different parks could, in consultation with their communities, select the powers and functions most appropriate to them. (Stirling Council)

A roughly similar model for all National Parks in Scotland as the ‘brand’ is well understood, but agree that powers and functions should be decided on a park by park basis and be adjusted as appropriate to the area via the individual Designation Orders. (SCNP/APRS)

All national parks should have the same range of powers and functions, and all national parks should have nature and wild animal welfare as their priority. (Scottish Badgers)

Key points:

Most respondents felt that there should be changes to the governance and management arrangements of all National Park Authorities, with the most common themes emerging being around inclusion, diversity, and skills of park boards.

There was little commentary on the balance of representation on Park Boards, though the need to maintain local presentation was mentioned. 

A number of responses suggested a National Park Service (or similar) where National Parks could work together to save costs and duplication and benefit from an economy of scale, joint national promotion and the sharing of best practice.

Local authority responses did not highlight any specific concerns, though the scope to have one Park board for more than one national park in a local authority area was raised.

Selected quotations:

The main theme being changes to the Boards e.g. reduction in their size; more training for members; members to have ecological skills; the ability to drive the formation of policy; and better balanced representation, with individuals who live within National Park areas and more youth, gender, and ethnic diversity, as the current processes “is not delivering the equality, diversity and inclusion outcomes that are being aspired to in Scottish public life”. (LLTNPA)

A current failing in governance is the lack of diversity on Authority Boards. Youth, gender, and ethnic diversity are all real challenges - and we are failing to improve this situation. (CIEEM)

The National Parks (Scotland) Act could be “strengthened to more explicitly require Board members to have significant skills, expertise and commitment to the purposes of National Parks”. (RSPB)

Young people are the future of Europe’s protected areas and we care about sustaining our rural landscapes but we are under-represented in the decision making process. (Stirling Council)

No, but if a local authority area contains more than one National Park it would make sense to, for example, have a single National Park board. (Highland Council)

Now is the obvious time to consider the merits or otherwise of establishing a single National Park Service while retaining NDPB to ensure there is some accountability at both national and local levels. (Friends of Loch Lomond and the Trossachs)

More parity with neighbouring areas beyond the boundaries – activities and impacts are similar to many areas beyond the boundaries but resources are significantly less. (Perth & Kinross Council)

Key points:

Organisations are predominantly strongly supportive of the proposed elements of an effective nomination process for National Parks in Scotland. 

Individuals were predominantly supportive of the listed elements for an effective nomination process for National Parks in Scotland, though they articulated much more explicit concerns over the ‘competitive’ nature of the process which will end up judging the best nomination rather than the best area.

There was recurrent reference made regarding the approach to the nomination and evaluation process rather than the specific elements themselves around the need to have a balance between a bottom-up approach and contributions of appropriate expertise from both organisations and individuals. A critique levied on the bottom-up approach was that the decisions would still be made at the top.

Selected quotations:

Yes, although community engagement needs to be included. (Newton Stewart Initiative)

The only issue is that the timescale appears optimistic in terms of identification, designation and then a national park becoming operational within the current Parliamentary period to 2026. (Scottish Borders Council) 

The bottom-up approach will need to be clearly set out and also resourced to enable participation. The role of local authorities, as locally elected and representative bodies, will be important and should be noted within this process. (Argyll and Bute Council) 

It will be important to have sufficient information to allow a decision to be made in favour of one or more areas. (Galloway National Park Association)

There should be a role for expertise as well as a ‘bottom up’ nomination process, as there is significant prestige and value which comes with the accolade signalling national significance. (SE LINK)

Key points:

A higher proportion of organisations felt there were improvements to be made on specific elements of the nomination and evaluation process than those who did not. The most popular areas for improvement were:

1. making the provision of advice and other support for potential areas to prepare nominations more widely promoted and available to inform who is able to nominate areas;
2. dealing with potential/proposed development or other changes;
3. communication and engagement (of communities, land owners, farmers etc.);
4. expert panel membership as part of an open and transparent evaluation of nominations based on the agreed framework; and
5. the use of a template in the nomination process.  

The suggestions from individuals tended to focus on communication and engagement of communities, and on the need to require consent from local communities for establishing a national park and a call for it to be a democratic process. It was suggested that the proposed panel for the evaluation of nominations should involve local community representatives as well as experts and practitioners. Two respondents explicitly stated that “politicians” should not be the ones who decide.

Selected quotations:

It is important that the guidance is produced timeously and is clear and well set out in terms of the assessment criteria and how bids will be supported. (Scottish Borders Council)

Community support is one of the most important aspects when deciding a future national park in Scotland and that this should be clearly outlined in the nomination process. (NFUS)

The strength of interest and support from the local community for the area to be designated [should also be] based on an appreciation of the added visitor numbers and associated economic opportunities that the designation would bring. (Paths for All)

An independent panel of experts should be involved. Stakeholders should have some recourse to redress for any unforeseen omission or bias which becomes apparent when the evaluation framework is published. (Campaign for a Scottish Borders National Park)

Needs to be cognisant of the impact beyond boundaries e.g. onshore windfarms being directed to areas and communities that aren’t in a national park. (Perth & Kinross Council)

Alongside the provision of advice, it would be useful to provide a template for the nomination process, to ensure consistency in approach which will make the evaluation process easier to manage at both application and evaluation stage. (SL&E)

Key points:

Of those organisations who responded to this question, the majority wanted to see additional elements included in the nomination and evaluation process. Some of the most popular suggestions were around community engagement/consultation, followed by transparency, accountability via support, monitoring, analysis, and good management, and inclusion of the nomination impact and potential (ecological impact, food security impacts, rural economy, and fiscal implications). One organisation wished to include an element of community voting which was not echoed among other organisations but was echoed by more individual respondents.

Of those individuals who responded to this question, the majority wanted to see additional elements included in the nomination and evaluation process. A significant number wanted to see enhanced community engagement and communication and the addition of accountability, including transparency and monitoring of change. Other popular responses included incorporating community voting and veto power, additional funding, including expert opinion, and ensuring that National Parks contributed to SBS delivery, nature networks and the 30x30 targets.

One individual respondent raised the point of incorporating more-than-human representation, by making the natural world itself a stakeholder in the process.

Selected quotations:

Do nominations require Local Authority support and if so what level of support (local member, area committee or full Council support)? Can a Local Authority support and endorse multiple nominations from across its area? Should nominations be endorsed by all communities across the nominated area – what if some communities strongly oppose or object to the nomination? Is there (or should there be) a process to appeal the creation of (or the refusal to create) a new National Park?. (Highland Council)

Include representation from Scottish Youth Parliament. (Adventurous Activities Industry Advisory Committee)

The process should be subject to Island Communities Impact Assessment. (Comhairle nan Eilean Siar).

It is absolutely vital that any changes to National Parks in Scotland, or proposals to create new ones, only happens following extensive and thorough consultation with the farming communities often directly impacted by many of these decisions. (National Sheep Association)

[We] would welcome greater clarity and transparency on the decision-making process and why any potential new National Park sites are proposed over others. (Scottish Renewables/EDF Renewables UK)

Key points:

A significant majority of respondents agreed with this as a criterion, with few opposed to it.

“Outstanding” needs to be defined for both land and marine environments. Some think this should be just about nature, especially individual respondents. Others considered that it should be about social/cultural as well.

It was suggested that individual applicants should be given the space to make the case for national importance, rather than pre-defining it too tightly.

Selected quotations:

‘Outstanding national value’ should be clearly defined and clarity should be provided as to whether ‘special qualities’ are the same as ‘values’. (RSPB)

Yes, it would support a case if at least some part of the area is already designated for its national importance.  It is unclear if the values listed above make up ‘outstanding national importance’ or if this is a separate criterion. More information is needed about how ‘value’ would be defined and assessed. (SE LINK)

Yes. However, it depends how outstanding national importance is defined. We need to protect areas with the most potential to deliver the aims. (Aberdeenshire Council)

Individual proposals should be encouraged to present their own ideas about why their area is of national importance. (JMT)

Key points:

A significant majority agreed with the proposed components though many comments also suggested the need to improve their clarity.

The main themes in the responses included:

• biodiversity restoration potential; and
• climate mitigation potential, though there were differing views on how this should be interpreted.

Various responses touched on a wide range of aspects relating to the social and economic development of local communities.

Selected quotations:

They need to be areas where nature restoration and protection will be most effective due to existing or future conditions, with effective guidance and sufficient support and input from local communities. (SWT)

Potential for biodiversity restoration, protection, monitoring, as well as for climate mitigation should be a key component. In fact, this is what would give the most long-term environmental benefits to the area. (BES)

(…) the presence of significant numbers of wind turbines in some areas should not detract from the proposal based on its outstanding national significance and natural and cultural heritage.  Their presence may affect the boundary that could be drawn but their presence does not mean that the Scottish Government should rule out an area at a time of climate crisis. (Galloway National Park Association)

(…) we request that consideration is given to planned future transmission infrastructure upgrade requirements to ensure that any potential corridors/areas of transmission network development will be accommodated within any designation or policies. (SSE Networks)

Marine areas and islands should only be included where they demonstrate the other components listed above. Being a marine area in itself doesn't necessarily bestow particular qualities; it is only where they add significantly to e.g. biodiversity, culture, landscape, enjoyment etc. that their value is indicated. This should be clarified. (Crown Estate Scotland)

Key points:

A significant majority of respondents agreed with this as a criterion, with few opposed to it.

Nature Networks and ecological connectivity should be included. Many said the larger the better to secure landscape-scale conservation.

Consider administrative boundaries and resources to secure efficient implementation.

Some respondents see large-scale infrastructure and development as counter-productive to the aims of a National Park.  Other respondents felt some development could contribute to net zero ambitions of a National Park.

Consider boundary effects and impacts on nearby communities.

Selected quotations:

Within National Parks consideration should be given to potentially identifying core areas of land for nature recovery that could be given additional protection that contributes to the 30x30 targets and the 10% highly protected targets. (CNPA)

One indicator of coherence would be whether there is an obvious name for the National Park whose geographical spread would be widely understood both locally and nationally. (Friends of Loch Lomond & the Trossachs)

It should not always be considered that development is not compatible with national park designation and would detract from its special qualities. This is a problem of the current thinking and application of such policy within the existing national parks. (SSE Renewables)

We would draw attention to the impact caused by drawing hard boundaries, boundaries that can bring benefits and restrictions and affect the livelihoods of farmers on different sides of boundaries.  From experience we know this can be divisive and lead to unintended consequences such as infrastructure problems such as transport and parking issues as well as economic activities and enterprise, and succession due to planning constraints. (National Sheep Association)

Connectivity needs to be an over-arching purpose so that any and all National Parks contribute to the cumulative size of the 'bank of functioning ecosystems' across Scotland. (Scottish Badgers)

 Key points:

A significant majority agreed with the proposed components though many comments also suggested the need to improve their clarity.

Need to develop the components of this criterion for the marine extent of coastal and marine National Parks

Need to clarify whether large-scale infrastructure (e.g. wind farms, electricity transmission) and intensive land uses would be excluded

There is a range of views on the extent to which cultural heritage should be a component of this criterion and if so what it should include.

Selected quotations:

Perhaps some details of potential marine limits for a coastal and marine National Park could usefully be set out. (SCNP/APRS)

… an area needs to be large enough to allow meaningful overnight adventures - “parks” are inherently about recreation, and national parks are in part for recreation on a larger scale. (Blue Marine Foundation)

Suggested revised wording: “An area where more intensive land or sea uses, including current or planned large-scale infrastructure, would not undermine the special qualities of the Park”. (Aberdeenshire Council)

(…) it is implied here that a National Park would not be considered in areas where there are existing wind farms, wind farms which will require repowering and other large infrastructure present. If this is the case then The Scottish Government needs to be clear, as they are otherwise causing great concern to the renewables industry and investors. (Scottish Renewables)

Cultural associations and traditions can be highly mobile and in many cases it will be difficult to geographically define an area based in whole or in part on a shared heritage, cultural associations and traditions – at least away from discrete and well-defined island communities for example. Care will be required if this component is to be used to justify a boundary. (Highland Council)

 Key points:

A significant majority of respondents agreed with this as a criterion, some passionately so.  However, there is some division on whether net zero should be prioritised or included alongside nature recovery.

The small number of organisations who did not support this criterion considered it to be unnecessary given the existing ambitions for nature recovery and net zero.

Clarity could be improved around the definitions of nature recovery, net zero and just transition, how these would be achieved and at what landscape scale and time scale.  What essential infrastructure will be required and supported in practice, in order to reach net zero, also needs to be made more explicit.  Some are concerned that this would open the door to renewable energy infrastructure within the National Park.

Consideration needs to be given to landscape, cultural and community needs, and potential conflicts of interest over land use and development. Some individuals suggest that human activity is incompatible with nature recovery within a National Park boundary. Others are concerned that the local economy, jobs and development needs support, so there are opposing views here, both among organisations and individuals.

Selected quotations:

The potential contribution to net zero needs to be considered against specific criteria. (Galloway National Park Association)

Further clarity [is] required on exactly how this would be achieved and supported and there needs to be careful consideration when it comes to land use and any future changes to that … in a holistic sense covering economic, social and environment drivers for change. (Dumfries and Galloway Council)

It is unclear whether “transforming land or sea use to contribute to net zero?” includes commercial energy infrastructure projects. We would welcome this being explicit. (EDF Renewables UK)

The clarity of ‘just transition’ could be improved by spelling out more clearly what it might look like in practice. (JMT)

Building on the lessons and experiences from Scotland’s existing national parks, visitor and tourism activities and the management of such must align with nature recovery and net-zero … (RSPB)

…. add cultural heritage to the criterion as well. This may be particularly relevant to the proposed criterion for better visitor and tourism management. It may also be a more relevant issue in the case of considerations of urban or semi-urban national park areas. (CIfA)

Key points:

A significant majority of respondents agreed with the components or slightly modified components.

The need to align tourism and visitor management with net zero ambitions was highlighted. Transport options need to include active travel routes, with connections beyond park boundaries.

Several organisations argued for safe access and inclusion for all (including disadvantaged groups) to ensure full diversity and community cohesion, in tandem with public education on the National Park role and values.

Many responses noted the need for sustainable economic development for local communities and nature based jobs in National Parks. This contrasted with some individuals who feel that the inclusion of tourism development, intensive land-use and large- scale infrastructure compromises nature restoration goals.

Selected quotations:

Key to better visitor and tourism management is the concept of Responsible Tourism and we would suggest that this phrase is used. (HES)

We support this component of the new parks, and we strongly encourage these future parks to include active travel routes as well as other affordable transport options. These routes need to be included in new or existing active travel networks, integrated with other transport networks, and connect beyond park boundaries. (Sustrans Scotland)

…..health and wellbeing are strongly interlinked with the nature and climate crises too and must also be an important consideration.  (GAT)

The pandemic increased inequalities in access to greenspace and the creation of new national parks could help reduce them. Access to green space can increase mental health and wellbeing for all. (Sustrans Scotland)

Throughout the proposals made, there has been a lack of consideration for women and minority groups. (Scottish Women’s Convention)

There has to be a clear additional benefit for businesses, communities, and people for a national park to be worthwhile. These benefits must outweigh the threats, perceived or otherwise. (NFUS)

Remote areas with fragile local communities with significant needs for sustainable social and economic development are often areas with opportunities for this to be based upon natural resources and visitor economy. (SE LINK)

Note: Some respondents suggested the need to give more significant consideration to alternatives to National Parks. 

Key points:

A significant majority of respondents agreed with this as a criterion, though many comments also suggested the need to improve its clarity.

Assessment against other national/international designations, mechanisms or land management is needed to see whether a new National Park would add value or not.  This should include some consideration of how existing National Parks are being managed in practice.

Support for developing a cost and benefits approach encompassing both financial and non-financial aspects This would include functions that may be better supported by other mechanisms.

There is potential given the refreshed purpose of National Parks, to include additional or new and innovative benefits including investment in natural capital and local socio-economic impacts.

Selected quotations:

We strongly support this comparison so that the costs and benefits of different approaches can be compared. (RYA Scotland)

We strongly agree that any National Park designation must demonstrate that it is providing additional benefit, rather than just clarifying current benefits. (SGA)

Where an area already has a selection of statuses, Park status could bring these together and give it maximum protection to develop further and protect the long term nature and biodiversity of those statused areas and beyond, thereby safeguarding, improving, expanding and enhancing the benefits geographically further afield. (Strathglass Community Council)

Note - Some respondents suggested the need to give more significant consideration to alternatives to National Parks. 

Key points:

A significant majority agreed with the proposed components though many comments also suggested the need to improve their clarity.

A number of comments were made on the need for the evaluation to be based on cost benefit with clear accounting, adequate resourcing and a financially sustainable model of National Parks. This was also reflected in individual responses, and included comments about the importance of the local economy and businesses.

It was considered important to consider the longer-term impacts and benefits including the ‘joint delivery of multiple and integrated benefits for people, nature and climate’. This should include social and community benefits for health and wellbeing, ‘cultural capital’, and better public awareness.

Interactions with other designations / approaches, including functions across all national parks, using an evidence-based approach should also be assessed.

Selected quotations:

A component could be added looking at the estimated cost of proposed measures and an appraisal of financial sustainability. (RTPI Scotland)

We would like to highlight the need for a new National Park authority to be adequately skilled and resourced to fulfil its functions, including as a statutory consultee to ensure planning delays are avoided. The significant costs of establishing, resourcing and managing a new National Park effectively must also be taken into consideration. We also take this opportunity to highlight the existing significant lack of resources within planning authorities across Scotland … (EDF Renewables UK)

We would suggest a more positive component, which allows an understanding of the range of positive impacts associated with national park status. How would this specific designation deliver a range of long-term benefits? (HES)

Link to wider long term impacts beyond just costs of establishment. (Europarc Atlantic Isles)

A missing third component is the assessment of the likely benefits and costs of an area as an NP. It is not possible to properly assess the merits of a proposed designation if only the costs and benefits of the status quo are examined. These must be compared with the realistic benefits and costs that would/could arise from designation. (Campaign for a Scottish Borders National Park)

Take into consideration other designations in the area … i.e. UNESCO sites to ensure consistency with objectives and that a new National Park does not impact on the status of what exists already….neighbouring boundaries with existing National Parks, or other designated sites and also other initiatives such as RLUPs, Nature Networks, etc. (SL&E) 

Key points:

A significant majority of respondents agreed with this as a criterion, though many comments also suggested the need to show specific evidence of local support.

Local community opinion should be central and their ‘well-being’ should be over-arching. But what is and who represents ‘the community’ needs to be carefully considered and clearly defined, including the role of local authorities. Expectations should not be raised by accepting nominations from areas where support is absent or unclear.

Must consider wider ‘communities of interest’ as well as local communities e.g. those who benefit from the area – hillwalkers, businesses (including farming, power generation) and ensure consultees are as informed as possible.  

National interests including energy infrastructure needs should also be taken into account.

Selected quotations:

We must be careful that a vocal or influential minority are not able to unduly and unfairly influence the decision, either for or against. (Highland Council)

It is absolutely vital that any changes to National Parks in Scotland, or proposals to create new ones, only happens following extensive and thorough consultation with the farming communities often directly impacted by many of these decisions.  (National Sheep Association) 

Consideration must also be taken from a tourism perspective, if local infrastructure is ready for a potential tourism boost and how the designation could have impact (both positive and negative) on local business… (Intelligent Health)

It is important that community of interest support is also considered i.e. groups who may not live locally but have a particular interest in an area e.g. hill walkers who come to particular area to enjoy their activity and have huge interest in how the area is used and managed. (Crown Estate Scotland)

This support needs to be wider than any local groups promoting a particular proposal [and including] … Local Authority, Regional Economic Partners, RLUP, as well as a range of community and business interest …. support from all these sectors is important. (Scottish Borders Council)

Greater emphasis is needed on the ‘national’ element. Given the climate emergency and nature crisis, it is critical that decisions on how to use our limited land are made strategically. There should therefore be an opportunity for all stakeholders to demonstrate informed support or objection to any new National Park.  (Scottish Power Renewables)

Key points:

A significant majority agreed with the proposed components though many comments also suggested the need to improve their clarity.

There needs to be a clear definition of local community and community groups, and awareness of vested interests. Balance should be weighted towards local components. There needs to be greater clarity on how much support would counts as sufficient (e.g. compared to community land buy-outs threshold).

Definition of communities needs to include communities of interest as well as of place.

How and where land owners and businesses (the private sector) fit in needs to be clear. Landowners need to be more explicitly mentioned and their role in land use change recognised. Expertise such as scientific and economic knowledge needs to be additional components taken into consideration. Consider also the areas adjacent to the park.

Selected quotations:

The proposed the component on community support needs to provide a clearer idea of how much support within a community counts as sufficient. Community organisations do not necessarily reflect the views of the wider community on every issue. Community land buy-outs, for example, require a threshold to be met in a public ballot of permanent local residents before they can apply to the Scottish Land Fund for significant funding. (JMT)

In terms of other components, there is no reference to private sector in terms of the business community, landowners and land managers, who are a critical grouping both in terms of being affected by the proposals but in terms of delivering the outcomes of a National Park such as native woodland creation and peatland restoration targets. (Scottish Borders Council)

The assessment of support should take account of the views of individuals in business as well as those of the local and national organisations which represent them.  (Galloway National Park Association)

Key points:

A significant majority of respondents agreed with this as a criterion, though many comments also suggested the need to improve its clarity.

Areas should qualify in terms of national (strategic) importance. This might be specific designations or reflective of national priorities – social, economic and environmental. Importance of cultural heritage should be recognised, as should best practice – National Parks should ‘lead’ but not be exclusive.

National Parks should deliver the 30x30 commitment but designation should not automatically count towards that 30%. Language should be modernised to include nature recovery and the climate crisis. Nature conservation and recovery should be of prime importance. Consideration should be given to marine/coastal.

More information is required to enable people to understand and use this criterion. For example, what role are National Parks expected to play in contributing to 30x30? Or, how does National Park make a strategic contribution to the sustainable development of local communities?

Selected quotations:

National Parks should be national level assets and therefore the assessment of the strategic contribution a proposed area can make would be a useful criterion. (Argyll and Bute Council)

We suggest our National Parks should be transparently demonstrating ‘best practice’ in nature recovery and transition to net zero as an overarching purpose. (Badenoch and Strathspey Conservation Group)

National Parks can contribute to the delivery of 30 x 30, however not in their entirety due to the many often-conflicting objectives. (CIEEM)

Clarity could possibly be improved by stating explicitly that any proposed new National Parks will be assessed to measure its potential contribution to the Scottish Government’s target of protecting 30 per cent of Scotland’s land area for nature by 2030 (30 by 30). (JMT)

The strategic contribution should be included as part of the criterion, specifically in relation to the delivery of the 30X30 commitment, to test approaches to nature recovery and net zero and to contribute towards sustainable social and economic development.  (Landscape Institute)

Key points:

A significant majority agreed with the proposed components though many comments also suggested the need to improve their clarity.

Restoration and protection need to be explicitly included. The connections between components were highlighted, e.g. that nature restoration and land management go hand-in-hand, and that nature recovery and 30x30 overlap and should not be separated. Coastal and marine aspects should be considered.

There was a call for clarity for land managers in particular. The issue of support for renewables needs to be considered within and adjacent to the park, and this needs clarification. Just Transition needs clarification.

Designation should be seen as a catalyst for ambition and innovation, including opportunities for good land management practice and responsible tourism.

Selected quotations:

We have reservations over the proposed components, and specifically the 30x30 commitment. We believe that nature restoration and land management go hand-in-hand. Therefore, this component could have been further expanded on, in order to give clarity to land managers. (BASC)

To some extent we support the consideration of the potential contribution of a National Park in delivering nature recovery and a Just Transition to net zero as criterion. However, we believe this requires further clarification. It is unclear whether the second bullet, “transforming land or sea use to contribute to net zero? includes commercial energy infrastructure projects. We would welcome this being explicit. (EDF Renewables UK)

… if one or more new National Parks are designated there does seem to be growing emphasis on the collective national impact and contribution that these areas can make together. If the proposed national vision and mission for all National Parks is to be realised then it would appear that criteria 6 (Strategic Contribution) will be an important consideration. (LLTNPA)

There will be a need to make sure that the area being designated will also deliver an additional benefit for nature, people and climate due to its designation. What extra benefits the designation will bring to the area need to be considered and should be an important factor. It should be noted that it is not just the coverage but the effectiveness that matters. (BES)

We largely agree with the proposed components but feel that they could be strengthened ….. designation should be seen as a catalyst for ambition and innovation as presented the components do not stand out as being anything different to what we are aspiring to deliver across the wider countryside. (SL&E)

Key points:

Community empowerment and the necessity of high levels of community engagement were again highlighted as being very important in this process. The key role that National Parks could play in supporting social and economic renewal was also noted.

Some renewables industry respondents suggested that a National Park designation in an area that does not already have a designation that precludes wind farms e.g. National Scenic Areas could limit the amount of land available for renewable energy generation, and therefore have a negative impact on Scotland’s journey to net-zero.

The current criteria are focussed on the potential benefits that a National Park could bring to an area, without any criteria that allow for analysis or discussion of potential negative impacts.

Greater clarity around weighting of components is needed.  There should also be an appropriate balance between the components while maintaining a strong focus on nature recovery and net-zero.

Possible financial benefits and/or negatives, and where funding is coming from should be a component.

Selected quotations:

Any new designation needs to be an all-encompassing package where priorities for nature sit alongside the well-being of the people that live and work within the park ensuring a sustainable future for all. (SL&E)

…accessibility and the potential for building relationships with urban communities, particularly in areas of multiple deprivation, should be at least a strong consideration. (JMT)

Attracting people who use or are interested in Gaelic will produce a more diverse visitor profile - and increase visitor numbers with attendant economic benefits. (Bord na Gaidhlig)

Creating a new National Park…. that would preclude a wind farm or other renewable energy technology development, will have significant ramifications for meeting Scotland’s renewable energy target, and pose a direct conflict with the priority given to the Climate Emergency, as set out in the recently published revised draft NPF4. (EDF Renewables UK)

The criteria are currently orientated around benefits only, with no opportunity to discuss the problematic implications, for example for the renewables industry, local communities and businesses. (Scottish Renewables)

…adequate funding was essential for a national park to be successful, however, there is no detail as to how they will be paid for. (NFUS)

Key points:

Most respondents thought some criteria were more important than others.

Of these, many saw nature recovery and a just transition to net-zero as the most important given the climate and nature crisis we face.  

The degree of support and strategic contribution were also considered to be a high priority when selecting which area to designate as a new National Park.  

At least some of a potential area, although not necessarily the entire area, should be of outstanding national value in terms of nature and (but not only) culture.

All of the criteria listed are important, and they will be of differing importance in different areas. Local stakeholder engagement should be used to guide which criteria will be more important in each area.

Selected quotations:

[Nature recovery and a just transition to net zero] is the most important because we are in an ecological and climate crisis which is threatening our health, quality of life and survival. (Friends of Denmarkfield)

National Parks must play a key role in implementing nature networks across Scotland, acting as nodes for the wider restoration and protection of nature across Scotland. (SWT)

[All] these criteria would be more important, given their wide-reaching impact on land management, shooting and conservation. (BASC)

Adopting best practice in visitor management is good, and this is best pursued through partnership working by all National Parks so that experience and successes can be shared. (Galloway National Park Association)

All are important considerations but if an area cannot demonstrate outstanding national value (Criteria 1) then it should not be considered as a National Park; Criteria 1 (in alignment with Criteria 2) underpin the other criteria and should be the most important for decision-making. (Highland Council)

…..the most important criteria relate to the provision of sustainable and low environmental impact recreation and tourism. (RYA Scotland)

…prioritisation should be aligned with a local approach and engagement with stakeholders to define what criteria are locally significant and should be prioritised. (Dumfries and Galloway Council)

Key points:

Most of those who answered this question thought the right balance was proposed.

Keeping the process simple, while ensuring key issues are covered, is very important, and the current format achieves that. This is key for the success of establishing the Park, without being too immersed with technicalities and bureaucracy.

As this process will involve lots of engagement with non-specialists and people without expert knowledge, some clarity on definitions would be beneficial

Several respondents suggested some definitions for technical terms.

Selected quotations:

The selection criteria and proposed components are well balanced. It is important not to overcomplicate the evaluation process, but also to ensure that key issues are covered and the proposed format does that. (Landscape Institute)

Yes. Also, all of these criteria should be satisfied for an area to be worthy of NP designation, not just some of them. The current requirement that NPs must be of national importance either for natural heritage or for a combination of natural and cultural heritage has worked well and should be kept. (SCNP/APRS)

Some explanations might be required on technical terms when engaging with non-sector individuals. (Europarc Atlantic Isles)

…seek clarity within these definitions around the use of ‘cultural heritage’ vs ‘historic environment’. (BEFS)

It is important that as the process develops local communities are communicated in full and with clarity. When technical language is used it is minimised and where it cannot be, explained as simply as possible, to ensure all understand. (LLTNPA)

Key points:

There was a spread of opinion on this question. 

Quantifiable criteria were seen as desirable because they can be used to ensure transparency in the decision-making stage, and they can be measured later in the evaluation stage. This can increase trust and confidence in the decision-making process.

Less quantifiable criteria also had their place. It was noted that quantification of components can over-complicate and can have a negative impact.  As quantifiable criteria are easier to integrate into statistical analysis, rather than qualitative or anecdotal data, it can be tempting to give them more weight. This should be avoided, as it will result in an unbalanced approach.

Selected quotations:

Yes, the components where possible should be quantifiable and measurable, this will be important in ensuring transparency in the decision-making process and aiding people to understand the outcome of decisions. Without quantifiable and measurable components, it will be difficult for people to have confidence in the process. Making components quantifiable will also be important in ensuring that an evidence-based assessment is made during the evaluation stage. (SL&E)

Yes, e.g. economic benefits to local communities through investment in natural capital. Percentage of land within a Park given over to nature recovery against that which retains intensive uses or other practices. (Heart of Argyll Wildlife Organisation)

It is unclear which proposed components are intended to be quantifiable. However, we support the components being quantifiable where possible. (Scottish Power)

Where practicable some degree of quantification is clearly desirable. But it is widely recognised that what can be counted is very often not what truly counts. This warning is particularly salient where the values being assessed are to a significant degree intangible. The imposition of spurious metrics should be avoided.  (SCNP/APRS)

It is often tempting to give more weight to criteria that are quantifiable as these are amenable to statistical analysis. However, the most important components are often difficult to quantify. (RYA Scotland)

Key points:

A range of comments was made, some reinforcing responses to earlier questions.

Some responses raised concerns about the approach to national parks. This largely covered: issues around role and location, connectivity and size; how and who ran it; the level of funding needed and need for innovation.

Other issues raised included raised concerns about visitor management/ sustainable tourism. This included concerns over access/camping, negative tourism developments, and the positive role that ranger services can play. Both positive and negative comments on ‘shooting tourism’ were also made.

The renewables sector again raised concerns surrounding national parks and their impacts on the renewable industry. These were largely said to be avoidable if new National Parks were only designated within existing National Scenic Areas.  

Further points were also made to reinforce the case for coastal and marine National Parks.

Selected quotations:

Developing new approaches

The two existing National Parks should not necessarily be a guide to size. While there may be case for one (or even two) large National Parks on similar lines, there may also be an option for several smaller scale National Parks if the right proposals were to come forward. (JMT)

Scotland is a coastal nation. Our inshore and offshore waters combined comprise 13% of all European seas and support a staggering 8,000 or more complex species. We have a deep rooted cultural connection with the ocean, which is part of our heritage and a source of inspiration, wellbeing, recreation and restoration for many. Given our coastal heritage, the Scottish Government should consider a Coastal and Marine National Park for Scotland to recognise the cultural role of our seas, and a new way for people to engage and value them. (Scottish Environment Link)

Lessons learned from the Land Use Strategy and Regional Land Use Partnership pilots should be considered as well as learning from landscape scale people and ecosystem restoration projects. (SWT)

There is little here that assesses the innovation or potential of a location to develop. It seems to be describe the status quo. We need people to thing smarter and look to new mechanism of delivery. There are many models in Europe, including privately run (Netherlands for example)…so different models, but all coherent with a national strategy and plan, overseen by and with responsibility by an overarching independent body. (Europarc Federation)

Education and training are key benefits of any national park and especially so for those children and young people living in the National Park. (Adventurous Activities Industry Advisory Committee)

Funding

The single most important issue of all. Existing and any new National Parks need to be properly resourced. Money is necessary both to take action as required (e.g. resolving access issues, publicising the Scottish Outdoor Access Code, maintaining paths and infrastructure etc.) and to employ enabling staff. (ScotWays)

Whether there is sufficient funding for the creation of a new national park or indeed an appetite from the public at large, in the current economic climate, and with other policy and legislative levers to achieve similar goals, to do so. We believe that the mechanisms to achieve the proposed aims of the new national park already exist through other means. (NFUS)

Investment in the development of nature networks will be crucial to delivering the aims … (NTS)

Tourism and visitor management

The role Rangers can have in ensuring visitor management issues are addressed. Likewise, community engagement and support requires a local focus and a dedicated point of contact, one which is on the ground, can react promptly and secure the desired outcomes.  Any successful bid will address in full how their Ranger Service will operate. The bid should demonstrate how the expectations the applicant has for the remit given to the Ranger Service will assist in many of the headline aspirations in their bid. (SCRA)

Shooting tourism represents an important boost for rural and remote areas, which is especially important in the tourism ‘off season’ months. (BASC)

Our National Parks should be providing vast areas of natural habitats for natural recovery, nature connection and environmental education. We should not tolerate the use of large swathes of land for unsustainable sporting activities which only benefit a very small fraction of the Scottish population. (Friends of Denmarkfield)

We would like to see water safety as a key consideration in the visitor management of any new National Park, as well as consideration given to areas of risk (in and around water) throughout the designation process. (Water Safety Scotland)

Renewables

[We] have major concerns that that a new National Park could be brought forward in an area of active onshore wind development and generation…developers will face uncertainty … and potential loss of the project and all time and costs invested. We suggest that a new National Park should be considered in areas already designated as National Scenic Areas. (RWE renewables UK)

Should a new coastal / marine National Park location be considered, we request that this does not add additional bureaucracy and complexity in powers and functions as we deliver our essential offshore networks infrastructure. (Scottish and Southern Electricity Networks)