CIEEM Response – The Future for National Parks in Scotland

Here you will find our response to the Future for National Parks in Scotland consultation. This response was developed by our Scotland Policy Group. 30/11/2022.

This consultation response builds on the outcomes from the Scottish National Parks policy event hosted by CIEEM and the BES Scottish Policy Group. The report and blog from the event can be found here.

CIEEM’s Key Comments:

  • The future of our national parks should be focused on the simple adage of the 2010 Lawton Report Making Space for Nature – More, Bigger, Better and Joined Up. National Parks need to be the foci for nature restoration at a faster and larger scale than what may be possible elsewhere. National Parks need to be exemplars of best practice.
  • The “Duty to have regard to the National Park Plan” is too weak. It needs to be removed and a stronger duty and direct policy instruction placed on all public authorities to work and act differently within National Parks. Change to the Sandford principle to extend it to all public bodies operating in the parks, not just the National Park Authorities.
  • The new National Parks should be about the future potential of an area for nature conservation and restoration. What could the area become, not just what it is currently. Therefore, any designation needs to meet changing conditions, creating resilience to a shifting baseline and realised future potential.
  • National Parks can contribute to the delivery of 30 x 30, however not in their entirety due to the many often conflicting objectives. There is a great opportunity for National Parks to expand their role in delivering nature recovery and restoration at-scale. With additional support to build on the existing positive measures that the National Parks are taking, more and more areas within the parks should meet the criteria and, over time, count towards the 30% target.
  • A review of existing planning powers and the differing arrangements between Cairngorms National Park Authority and  Loch Lomond and Trossachs National Park Authority should be conducted to evaluate how planning operates and how this could be modified or strengthened. This is particularly in light of the requirement of the Planning (Scotland) Act 2019 that all development should, amongst other key outcomes, secure positive effects for biodiversity.
  • Ideally, the boundaries of future National Parks should align with the boundaries of other designations (e.g. Ramsar and SPA boundaries) that may be present in an area to facilitate ease of management for landowners and practitioners.
  • It is important to consider communities and their complexities. Who are the local communities? How are they engaged or served by the National Park? It is imperative that governance structures allow for community voice and representation at all stages including proper representation of local communities on the governing body of the National Park Authority. A current failing in governance is the lack of diversity on Authority Boards.