New National Parks - appraisal framework: consultation analysis

Consultation analysis report on the draft appraisal framework criteria for new National Parks.

8. Criterion 6: Local support

Criterion 6 examines the importance of considering local support in assessing a new National Park. There are two components of this criterion that clarify that interest in local support includes local interests, such as community bodies, landowners, businesses, public bodies and third-sector organisations, as well as support from local authorities.

Views on the criterion

Q11. Do you agree that ‘local support’ should be a criterion for assessing nominations for new National Parks? If you disagree, please give reasons for your answer.

n= % Agree % Disagree % Don’t know
All answering (%) 157 77 14 9
Individuals 128 73 17 9
Organisations 29 93 0 7
- Interest organisations / Stakeholders 15 87 0 13
- Public sector bodies 10 100 0 0
- Built Environment / Land management 3 100 0 0
- Energy 1 100 0 0

A criterion assessing local support was supported by three quarters (77%) of those answering Q11, making this the second lowest rated of the seven criteria. Support was lowest among individuals; 73% agreed, 17% disagreed and 9% were unsure. Among organisations, however, 93% agreed and no organisations disagreed. Two were unsure – James Hutton Institute and Scottish Rewilding Alliance.

Supportive comments

42 respondents commented at Q11; many agreed, but only some gave detailed reasons why. These respondents noted that people living and working in or around the proposed area need to agree with the plan and benefit from creating the new National Park.

“Local communities, landowners, local authorities and a wide range of stakeholders all play an essential role in the conservation and promotion of the historic environment and cultural heritage more widely. Local support is essential in ensuring the success of a National Park.” – Historic Environment Scotland

NFU Scotland noted the importance of considering “cross-sectoral and cross-community views and not just the view of those who put forward the nomination” to ensure that, whatever the outcome, parts of the community are not left feeling left out or ignored. Scottish Borders Council agreed it was important to also solicit opinions from those in opposition, and at Q16 – Do you have any other comments? - another individual requested there be a specific place for people who are against a proposed National Park to register their concerns.

Reasons for disagreement

All those who provided further detail about their opposition to the criterion were individuals. A few highlighted a worry that local opinions could be swayed by lobbyists or interest groups. A few others disagreed because they believed a National Park is in the national interest and therefore creating one should not be based entirely on local opinion.

“There's the danger that this puts the decision into the hands of lobby-groups, giving the illusion of consensus when only a tiny proportion of the population have been informed or consulted.” – Individual

“I am concerned about how to achieve a balance between doing what we must to safeguard the future of all life and the needs of locals. A big worry is the vested interests of planet-wrecking, wealthy landowners who have already decimated their vast areas of land. They must not be permitted to place their greed and lack of proper stewardship over the needs of ordinary people and the need to restore biodiversity.” - Individual

Views on the components

Q12. Do you agree with the components of criterion 6 (local support)? If you disagree, please give reasons for your answer.

All answering for each component: n= % Agree % Disagree % Don’t know
Component 1: What level of local support (with evidence) is there from local interests (community bodies, landowners and managers, businesses, third sector organisations, public bodies etc). 157 73 17 10
Component 2: What level of support (with evidence) is there from the local authority/authorities in the area? 157 72 15 13

The two components of Criterion 6 recorded the lowest levels of support across the framework, with 73% agreeing with Component 1 and 72% agreeing with Component 2. In both cases, agreement was lower among individuals than organisations; 69% and 93% respectively for Component 1 and 69% compared to 86% for Component 2.

It should also be noted that no organisations disagreed with either component. All those who did not agree indicated they were unsure.

There were 47 open comments in response to Q12.

Component 1: What level of local support (with evidence) is there from local interests (community bodies, landowners and managers, businesses, third sector organisations, public bodies etc).

Some respondents provided feedback on Component 1. A few asked for a clearer understanding of who would be classified as local under this component. For example, would landowners or business owners who lived remotely or in another country be considered? Another individual asked for clarity about what support meant.

“Guidance could be given as to what would constitute evidence of local support - e.g. online surveys, village hall meetings, opportunities to comment in local libraries, etc.” - The National Trust for Scotland

A request for robust local representation, capturing a multitude of views, both positive and negative, was requested by a few respondents. The National Trust for Scotland pointed out that this aspect of the submission would be the most costly as it required wide community consultation, e.g. publicity, engagement, and collation and analysis of responses, and questioned whether the Scottish Government would provide financial support for this. One individual stressed that business interests should not dictate environmental or biodiversity concerns.

Component 2: What level of support (with evidence) is there from the local authority/authorities in the area?

There were mixed views from several respondents in response to Component 2.

Of those who agreed, a few wanted further clarification on what information councils should supply in support of their application and how they would make it clear whether they support the nomination for all or only part of their area. Scottish Campaign for National Parks (SCNP) and Action to Protect Rural Scotland (APRS) noted that there could be competing or conflicting interests within local authorities. For example, it is possible that local authority may be the site of several, competing nominations. While these respondents supported the consideration of local authority positions, there was concern that putting too much weight on local authorities' opinions may stop the development of otherwise well-supported nominees.

“We feel that unequivocal Local Authority support at the nominations stage should not be required for a nomination to succeed, as reluctance to provide such whole-hearted backing may be motivated by a whole range of factors, some of which may have little to do with the long-term best interests of the area.” - Scottish Campaign for National Parks (SCNP) and Action to Protect Rural Scotland (APRS)

Among those who disagreed or were unsure about the component, the main concern was that local authorities could take a different position than the people or organisations in their area. They argued that a local authority’s view was superfluous as councils should represent the same opinions as those sought in Component 1.

“We have selected ‘don’t know’ in response to Component 2 because whilst we recognise that Local Authorities are democratically elected, and in most areas we would expect Local Authority support for a bid, there could be cases where the Local Authority might not support a bid but there is local community support for a bid. In those instances, we don’t think Local Authority opinion should sway an outcome for a designation. There are examples where this has happened in the past. In 2013, a North Harris National Park proposal didn’t proceed because the Local Authority objected. The Local Authority will have a view on a designation, so it would always be beneficial as part of the process, to consult the Local Authority, but not for the Local Authority view to sway the final decision.” - John Muir Trust

Balancing interests

There were concerns from several about how to balance the different interests of people involved. For example, a few posed questions around how national importance should be measured against local importance, how a loud minority opposition could be considered against a quieter supporting majority, and how business interests could be weighed against individual perspectives.

“This support is highly desirable and should be sought by applicants. However, there is inevitably a mix of views regarding designation of an area as National Parks, and, not infrequently, those opposed are vehement in their opposition, perceiving adverse consequences for their livelihoods or property or privacy. Consequently, my view is that this support should be sought, but that the weight given to it in the assessment process should be flexible; it should not be a factor that, if absent or incomplete, reduces the chances of being considered.” - Individual

“However, there is the need to balance the range of views to a national park designation to come to a determination against the wider national aspirations in term of the delivery of national outcomes designation would potentially bring.” – Scottish Borders Council

Less commonly mentioned themes

As with most criteria, some respondents highlighted that environmental protection should be prioritised over local support.

The Royal Town Planning Institute Scotland mentioned that evidence should include “policies set out in emerging Regional Spatial Strategies and community-led plans or policies, including emerging Local Place Plans.”

One individual suggested that the government should work with local communities to help build the National Park vision.



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