Proposal for a National Park in Southwest Scotland: report

Section 2: The engagement and consultation process

20. Before we could prepare this reporter advice, NatureScot was required to consult widely with individuals and organisations with an interest in the proposed National Park. This section of our advice describes how we undertook this task, summarises the comments received about how we did this and presents an assessment of its effectiveness, drawing on the independent review of this work we commissioned from the Scottish Community Development Centre (SCDC).

Overall approach

21. The overall approach was set out in the Reporter Plan published in August 2024 outlining three phases of work:

Table 1: Phases of work

Pre-consultation Engagement (August 2024 – mid October 2024)

To raise awareness of the proposal and work with local interests and other stakeholders to design an effective consultation strategy and develop the draft proposals for consultation

Formal Consultation (November 2024 – February 2025)

To gauge opinion on detailed proposals and the support or opposition to the principle of the proposal through a formal 12-week consultation.

Analysis and Evidence (February 2025 – April 2025)

To analyse the responses received and finalise advice for Ministers taking account of the views expressed in the previous phases

22. As well as being developed to ensure we meet the requirements on us, our work was informed by Scottish Government good practice on consultations and the national standards of community engagement. Alongside this Reporter Plan we also developed an Equalities Impact Assessment to consider how to develop our work to be as inclusive as possible.

Pre-consultation Engagement

23. In the engagement phase we:

• wrote and provided briefing on the proposal and how we proposed to undertake the consultation process on it to the three local authorities, 52 community councils and 39 community organisations across the indicative area suggested by the bid;
• provided a range of information, such as details of the process and frequently asked questions, on the National Parks pages of our website;
• prepared and distributed through the post an information leaflet to 52,000 households and businesses within and close to the indicative area suggested in the bid (though we recognise that not all addresses have received them as we had anticipated);
• created a dedicated online Reporter hub to provide information and the opportunity for interested parties to share issues and concerns. In total, more than one thousand respondents contributed a total of 2,951 comments to the various surveys hosted on the information hub;
• held or inputted to over 30 meetings online and in person with circa 400 people from local and national groups and stakeholders to explain the process and discuss the issues it raises;
• scoped and developed bespoke engagement with young people and under-represented people and groups;
• issued press releases and social media content to raise the profile of the work and respond to widely held queries;
• responded to over 500 emails and letters; and
• developed more detailed thinking on the proposal to inform the formal consultation, both drawing on these discussions and our own field work and analysis.

24. We published a report summarising the main outputs from this engagement phase in December 2024. This concluded that nine of the proposed actions outlined above had been successfully completed or progressed. The report noted the significant engagement achieved overall in terms of the depth and range of issues raised for this stage of the reporting work. It also highlighted some issues encountered around engagement with community councils, the distribution of the information leaflet by Royal Mail and the postponing of the drop-in surgeries to enable these to be informed by the more specific proposals in the consultation.

Formal Consultation

25. For the consultation phase we developed a main consultation paper and used this as the basis for the following consultation methods:

a) An online technical survey allowing participants to respond in detail to all aspects of the proposal (hereafter ‘Technical survey’)

b) An online summary survey primarily intended for individuals and households (hereafter ‘Summary survey’)

c) A survey leaflet distributed to the 52,000 household and business addresses in or close to the area and containing the same questions as the summary survey (hereafter ‘Household survey’)

d) A programme of 30 independently facilitated public consultation events led by Outside the Box held across the area

e) Sector-led consultation meetings and events including land managers, tourism, renewables, conservation and local authorities

f) A range of bespoke engagement work with young people, black and ethnic minorities, disability groups, and other under-represented groups.

26. We received 5,387 responses to the three surveys, of which 5,230 were considered valid. A more detailed breakdown of the responses by businesses and organisations is provided in Annex C.

27. Between November 2024 and February 2025, the consultancy, Outside the Box, facilitated and hosted 30 community events across Southwest Scotland and three online events. In total 1,158 people signed in and participated in the activities. A number of additional people also attended these events but did not sign in. In addition, 4 drop-in surgeries organised and led by NatureScot attracted over 60 attendees.

28. During the consultation period, we also attended a series of 8 sector-led meetings with audiences ranging approximately from 5 to 50. We also provided briefing for councillors of the three local authorities and met regularly with the South of Scotland team of public sector bodies.

29. Map 1 shows the location and timing of all the public consultation events and drop-in meetings held as part of the consultation.

Analysis and Advice

30. In the advice phase we analysed all survey responses and information from the public meetings to develop the consultation reports that accompany this advice. Support in handling and analysing data from the three surveys was provided by the consultancy Progressive Partnership. The detailed methodology for this analysis is presented as a separate report.

31. Using this analysis, a small team developed the draft advice for discussion and review by a range of senior staff. The NatureScot Board discussed the advice at extraordinary online meetings held on 17 and 28 April and 2 May 2025. In preparation for this work, on 15 and 16 March 2025, the NatureScot Board also visited the proposal area to familiarise themselves with it and to meet and hear from a range of stakeholders who had participated in the consultation.

Commentary on the consultation

32. We consider that we have successfully delivered on all the outputs and milestones we set out to undertake in the Reporter Plan to meet the requirements of us from Scottish Government. We also received a range of formal and informal feedback on the work we have undertaken, most of it positive. Though we do not ask a direct question on this issue, calls for a referendum were mooted in responses to the consultation making up less than 3% of all responses.

33. At the same time, we recognise that a number of issues have been raised by members of the public and by groups who were opposed to the proposal, with the No Galloway Campaign Group in particular expressing significant concerns about both our capacity and capability to act as Reporter. Throughout the process, we have sought to address the key concerns raised by making changes to the programme of work. We also responded to 321 separate emails from 155 people (of which 30 people sent 173 emails and 3 people sent 50 emails) seeking further information on the process or challenging aspects of it.

34. A common theme raised concerned the survey approach which sought to gauge opinion on the proposal and alternatives to it while also seeking views on the detailed arrangements for the proposed National Park. While these elements of the analysis are presented separately in this report, we do know that responses to many of the questions was lower among strong opponents of the proposed National Park and that some people were concerned that offering a preference on an option area might be interpreted as support for the National Park itself.

35. We also heard claims that the consultation process was not fair and balanced in line with the national standards for community engagement. Equally, concerns were raised from both sides of the debate that the heated nature of the public and online discourse on the proposal was making it difficult for all to have their voices heard. In response, NatureScot and SOSE had to issue statements seeking to lower the temperature of the discourse and focus it on the substantive issues rather than personal ones.

36. In their report on the programme of public consultation events they organised and facilitated which will be published alongside this report, Outside the Box noted several lessons learned as well as improvements that could be made in further engagement exercises. Most of these result from the time and timing to prepare and run the events suggesting a longer run of more than 8 weeks to the consultation exercise may have been useful. They also provided the following feedback and commentary on the process.

Feedback from People at the Community Events

At the events, informal feedback was gathered at the welcome desk from people as they left the events. Feedback tended to fit into four areas. People said:

• it was useful and informative, and they felt they had a chance to have their say, leave comments and talk with NatureScot staff;
• the information was too vague, and the proposal was unclear making it hard to comment;
• the information boards were too wordy with too much to read and take in; and,• they didn’t like the dots and post-it notes approach because they felt they were being treated like children.

Most people said the events were useful. Outside the Box observation of people at the events was that many arrived looking tense and uncertain and left looking more relaxed after they had completed activities and had conversations with NatureScot and Outside the Box staff.

People also said they liked meeting and seeing their neighbours and friends and spending time chatting about the issues in an informal setting. At most of the events there was a friendly relaxed atmosphere and people stayed for an hour or so chatting with neighbours and friends.

37. While this feedback was generally positive, Outside the Box also made the following observations on the atmosphere of the events.

Atmosphere at the Community Events

The aim of the community drop-in events was that they were a safe enjoyable space and experience where people could easily share their views, participate in activities and get answers to their questions.

However, during at least five events, participants and Outside the Box staff experienced aggressive and intimidating behaviour by other people at the events.

At four events the venue was at capacity for the numbers of people who arrived and then stayed watching what was happening and what comments were being left. The lack of space and noise of many people talking added to the unpleasant atmosphere.

At other events, ‘no-campaign’ banners were installed outside the venue during the drop-in event, ‘no-campaign’ leaflets were handed out to people outside the venue before they came in (and inside at least two venues as well) and members of the ‘no-campaign’ wore clothing, fleeces and buffs, featuring ‘no-campaign’ logos.

At the end of every event people supporting the ‘no-campaign’ took photos of the completed feedback boards and in particular the completed H diagram board.

Outside the Box staff observed that people who were undecided or were positive towards the proposed Park were less likely to complete activities and write comments, and when they did complete activities would wait until a quiet time to do so.

38. In their broader review of our consultation work against the National Standards For Community Engagement which will be published alongside this advice, the Scottish Community Development Centre (SCDC), interviewed a wide cross section of people who participated in the consultation. Overall, they noted that “this consultation compares very favourably with others and has demonstrated elements of very good practice in the use of the National Standards in Scotland”. Key conclusions from the final report included the following.

Levels of involvement: NatureScot have made very significant progress in involving local people in the decision making about designation which compares very favourably with other park designations and large-scale public consultations. We should say that reliable figures for levels of engagement in public policy are not routinely gathered, analysed and published however comparisons we did identity point to significantly lower rates of involvement in these consultations.

Making use of the Standards: Our dialogue with those planning and delivering the work confirms that the design of the engagement used a systematic approach guided by the National Standards for Community Engagement in terms of who needed to be engaged, the contact strategy, methods and how to reach population groups whose voices are often not heard.

Methods used: We feel that the methods used were fundamentally sound and it is clear that the NatureScot Reporter Team sought to maximise opportunities to enable people to participate, particularly geographically, but also in communities of identity. In our experience the numbers of people who did take part was much higher than other activity we have supported or observed in other areas, and we imagine the analysis of engagement data will confirm this. The spread of promotional work, numbers of well attended local meetings and the work to raise awareness of the survey were evidence of this.

Role of NatureScot: Despite some local views to the contrary, we think it is clear that as a government agency operating on environmental issues that Nature Scot are a perfectly acceptable choice for government to appoint to the role of Reporter in a similar way that the Agriculture and Rural Economy Directorate regularly runs consultations on relevant policy, or that Councils and the NHS consult local people about funding priorities and service planning. This is a legitimate role of Government agencies and has value for money implications when compared to some suggestions about possible roles of independent enquiries

39. Like the Outside the Box observations on the atmosphere at some of the public consultation meetings, SCDC also noted:

Our experience suggests that it can be difficult for people to separate how they feel about the substantive issues in engagement from their feelings about the process by which their views have been sought gathered and analysed. This is particularly the case in issues where there are directly opposing views being expressed vociferously on different sides of an argument and/or where people are very motivated to advocate for specific positions and see little room for compromise. It seems clear that this has been an issue in this case with significant and effectively expressed criticisms of the process obscuring positive aspects of the work to engage local people and gather their views…

40. In its report, SCDC identified several areas for improvement and related recommendations for future engagement, with the key ones including the use of the National Standards for Community Engagement (NSfCE) planning tool VOICE; greater consistency in data gathering and use of both more inclusive and deliberative methods of engagement; and the establishment of a wider local advisory group. These improvements and the others they suggested should be implemented during any future engagement and consultation work on this proposal with the timetable planned accordingly.

41. Building on what we have done during the reporting work, further efforts should also be made to engage young people and individuals with protected characteristics while work is also needed explore how best to involve people on low incomes in these discussions. Investment in these engagement strategies will be important whatever happens next, but it would also help lay the foundations for a future National Park if Ministers decided to proceed with designation.

Consultation outcomes

42. This consultation has been the largest and most challenging one NatureScot has undertaken. We have made every effort to raise awareness of the proposal and to provide everyone with an interest in it with opportunities to express their views. It has also followed good practice in public consultation and has sought to be as inclusive, participatory and equality focused as possible in the time frame available. Public consultation and engagement has included meetings and events with local communities, interest groups, businesses and landowners and managers, using a variety of formats and approaches.

43. At times the debate has become heated, with strong and emotive language used especially online but also at some public meetings and events. Both misunderstandings and misinformation have also been evident, while attendance at public meetings and the use of negative posters and leaflets containing misleading information may also have shaped the public discourse and put off some from making their voices heard. From this perspective, the differences in the balance of opinion between the surveys and the public meetings is instructive.

44. We are aware the consultation work has been criticised by some parties as inadequate. NatureScot’s ability to act as Reporter has also been called into question. The open process of developing the detail of a National Park set out in the National Park legislation has been frustrating to those wanting more detail of how a National Park would operate and what its priorities would be. These views may have been unavoidable given the legislative process requires a stepwise development of proposals, and any organisation acting as Reporter may have been perceived as taking forward a formal Government commitment.

45. Overall, we consider that our work has met the Reporter requirements set us by Scottish Ministers. There are clearly important lessons to learn from the consultation process we have undertaken and the polarisation of the debate that has happened since the proposal was published. Nevertheless, we do not think the issues raised have significantly impacted on the outcomes of the consultation in terms of the arguments made for and against the proposed National Park, nor the conclusions we can reach from them.