New National Parks - appraisal framework: consultation analysis

10. Scoring and other considerations

This chapter presents the analysis of responses to Q15 and Q16. These two questions had a broader scope than the rest of the consultation. Q15 asked respondents for their views on the overall scoring process, while Q16 provided an opportunity for respondents to provide any other comments on the draft Appraisal Framework.

Q15. Once finalised, the appraisal framework will include details of how each criterion will be scored. This will be published ahead of the nominations process being launched. Do you have any comments that you would like to make about how the selection criteria should be scored?

Environmental concerns are paramount

81 respondents answered Q15. In line with the recurring theme noted under Criterion 1, many respondents suggested that environmental considerations, such as ecological preservation, climate mitigation and biodiversity protection should be given priority in the scoring process. While some also called for cultural and social heritage to be prioritised, others thought that the benefits new National Parks would bring to the environment should be the top concern.

“Given the lack of land and sea area where non-human interests are prioritised, please weight selection criteria of the national park to non-human beneficiaries.” - Individual

Scoring process

Several respondents commented on the process of scoring applicants. A few respondents each suggested letting stakeholders decide or letting the public decide via a vote, for example. Others raised more specific concerns. A small number suggested that statisticians should be involved in the process, while a few others mentioned a distrust of quantitative scoring, instead proposing a more qualitative scoring process, such as: very good, good, fair, poor.

A small number requested clarity on how criteria that seemed to overlap would be assessed. Areas of overlap between Criterion 3: Meeting the special needs of the area and other criteria in the Appraisal Framework were highlighted by a few organisations, particularly between Criterion 3, Criterion 7: Strategic contribution and Criterion 5: Added value. Perth and Kinross Council suggested re-ordering the criterion to enable a direct comparison between similar fields, and Scottish Environment LINK questioned how the assessment framework will address the potential duplication or double scoring of overlapping criteria.

Perth and Kinross Council, Highland Council and Mineral Products Association Scotland provided specific requests for weighting the criteria. However, they expressed different priorities. Perth and Kinross Council and Mineral Products Association of Scotland believed Criterion 6: Local support should be the top priority. Highland Council believed that Criterion 1: Outstanding national importance was the top priority with Criterion 6: Local support the second most important.

Scottish Land & Estates emphasised the importance of balance:

“As with all of these issues there is a requirement for balance. There should be a minimum score required for each of the outcomes. e.g. Getting 100% in 5 areas and 10% in 2 should not be favoured over a more balanced score which meets all of the outcomes but to a lesser extent. The success of a new park will be reliant on it bringing a range of benefits, both locally and nationally.” - Scottish Land & Estates

Transparency in the application process

Transparency was highlighted by several as necessary for a fair assessment of applications. Some respondents mentioned that the criteria need to be clarified and the weighting and scoring structure available to applicants before they apply. Some others suggested publishing the criteria and scoring procedures publicly, while another individual requested the publication of all submissions.

“The scoring methodology should be clearly explained to ensure that it can be understood by all, and this should possibly be supported by further consultation. There is likely to be a high degree of cross over between the criteria identified in the Appraisal Framework (e.g., 3 and 7) and it will be important to ensure that any assessment methodology is able to be clearly applied to criteria where there may be a lack of transparency because of the similarity of the criteria and their components. It should be clear from the appraisal framework how the different components will be weighted in the decision-making process, particularly where there may be conflicts between components.” - Crown Estate Scotland

In Q16, respondents asked for clarity on the application itself, including information on what support will be provided by the Scottish government, word counts, and clear guidance notes to assist completion.

Local people and communities

In Q15 and Q16, some respondents reiterated the importance of including local people and local voices in the application process. Some requested that local concerns be prioritised over other factors in the scoring process. Others emphasised that this should reflect the views of local people and communities, rather than local government.

“While local government/third party support (businesses) is important, I would like to stress that this should not be taken as more important than the needs and wishes of the local community. They should be acting in the best interests of said local community and not for their own political/financial gain.” - Individual

When commenting on questions about Criterion 6: Local support, some respondents questioned the application process and asked for transparency about how data would be collected, how decisions would be made and how applications would be scored. A few wondered what would constitute evidence of support and how support should be captured to ensure competing views are represented.

“It is not clear from the criterion or components how support can be sought and demonstrated equitably. There will be many competing views on whether there should be a national park in a particular area, what such a designation ought to mean and how the park should operate. National parks, by their nature, have to operate in a context of local and national interest, so while it is right that local stakeholders should be empowered through this process, consideration should be given to how views are sought and coordinated.” - Scottish Rewilding Alliance

There was an interest in understanding how support would be considered, and if, for example, local authorities' opinions would carry greater weight.

Additional suggestions

The following considerations were mentioned by one participant each:

• There should be greater inclusion of charities in the scoring and assessment process, specifically wildlife or ecologically focused organisations.
• Natural environments located within cities should also be considered.
• Distinctiveness of the landscape should be prioritised.
• Whether a place can cater for and include everyone.

Q16. Do you have any other comments that you would like to make about the draft appraisal framework and nominations process for new National Parks?

A total of 79 respondents answered Q16. However, many took the opportunity to reiterate points which have been described earlier in this report. For example, the most prevalent theme, mentioned by several respondents, again stressed that environmental concerns should be a top priority in the assessment process. Specifically at Q16, a few suggested that existing National Parks have not sufficiently protected the environment and were therefore opposed to new parks.

To avoid repetition, the analysis below focuses on points or themes that have not already been covered.

Supportive comments

Broad, positive comments were submitted by some respondents, reflecting their support for new National Parks and expressing gratitude for the chance to comment on the framework. One individual supported the consultation on a draft framework and emphasised the importance of engaging younger populations in Scotland.

“This is a fantastic long overdue opportunity to invest in the natural and cultural heritage of Scotland in a way that will bring about meaningful benefits to rural communities, businesses and the wider environment. We need to ensure that the approach taken is modern and forward-thinking, recognising the interdependencies between people and nature that will ensure future generations look back on this as a turning point that resulted in a rebalancing of the ecosphere.” - Galloway and Southern Ayrshire UNESCO Biosphere

Negative comments

Concerns about, and objections to, the creation of new National Parks were noted by some. These comments typically reiterated the sentiments noted throughout this report, though two respondents were critical of the consultation and the wording of the framework.

“Please consider very carefully why you are doing this. Remember, small is beautiful and thinking big like this while passing control to institutions like this is one of the causes of the problem. It should not be regarded as a good idea. Where I live we are surrounded by 'designations' policed by Quangos [quasi-autonomous NGO].” – Individual

Windfarms

At various points throughout the consultation, including at Q16, the small number of energy organisations who responded highlighted issues that could arise if a new National Park as a wind farm within its boundaries. These responses described the need for renewable energy infrastructure in Scotland and called for further clarity about the acceptability of existing wind farm infrastructure and land use within a new National Park. They cautioned that if wind farms are not permitted within a new National Park, there needs to be clarity about whether existing turbines would need to be dismantled, and consideration given to potentially losing a significant portion of Scotland’s renewable energy generation.

“New National Parks will potentially contain wind farms, whether going through the planning system, under construction or at some stage through their operational lifetime. It is still unclear what approach will be taken to wind farms within or adjacent to new National Parks. SPR understand that the approach may depend on what nominations come forward, and whether these proposed parks contain any renewables, however, there needs to be thinking put into how this will be handled to ensure that Scottish Government can adequately engage the renewables industry to find acceptable policy solutions.” - ScottishPower Renewables

“At present, the Appraisal Framework encourages consideration of the positive gains that a National Park nomination could bring. We suggest that a criteria is added that offers a clear opportunity for consideration of the negative implications of a National Park nomination to allow for balanced approach. We also suggest that a criteria is added that requires consideration of any resulting conflict with NPF4 policies.” - RWE Renewables

Additional suggestions

The John Muir Trust offered a simplified framework where applications are measured against two criteria: “a) The potential for the land to be managed in an exemplary way to protect and restore our finest wild places. The park must be based on a thriving natural ecosystem; and b) The strength of interest and support from the local community for the area to be designated based on an appreciation of the added visitor numbers and associated economic opportunities that the designation would bring.”

Collaboration was emphasised as an important criterion for measuring applications against by a few, including Architecture and Design Scotland.