New National Parks - appraisal framework: consultation analysis

Executive Summary

The Scottish Government committed to establish at least one new National Park in Scotland by the end of this Parliamentary session in 2026. The New National Parks - appraisal framework: consultation was open between 11 May and 4 August 2023. The consultation aimed to gather a broad range of public and stakeholder views on the draft criteria included in the Appraisal Framework which will be used to assess nominations. In total, 165 consultation responses were received from 132 individuals and 33 organisations.

Overall, there is a high level of support for the seven criteria. The table below shows that all criteria were supported by at least 70% of respondents, with three supported by more than 90%. Similarly, each of the 22 components were supported by between 72% and 94%, with most organisations in agreement.

Although respondents were asked to comment if they disagreed with any aspect of the Framework, a range of views were expressed including comments supporting the criteria and components.

Criterion 1: Outstanding national importance

Some respondents made supportive comments about Criterion 1, expressing their approval of using outstanding national importance as an assessment criterion for new National Parks. However, some concerns were raised. Several respondents argued that the primary criterion for assessing national park candidates should be the potential benefit that they can generate for the environment, with calls for the framework to focus more closely on nature conservation, restoration and recovery. While not directly related to Criterion 1, a few respondents were critical of the management of existing National Parks, suggesting that this has resulted in excessive development and exploitation of the land.

Several called for greater clarity and a more detailed definition of the proposed criterion. In particular, the terms ‘national’ and ‘outstanding’ were described as unclear, open to interpretation and difficult to assess.

Several respondents viewed Component 1 as a higher priority than Component 2, describing natural heritage as more important than cultural heritage when assessing bids for potential National Park status. A few respondents felt that deep cultural heritage should not be an essential feature of a National Park, and such a requirement may exclude otherwise adequate candidates. A small number of organisations felt that separating Component 1 and Component 2 was unhelpful and called for them to be combined.

Criterion 2: Size, character and coherence

A few made broadly supportive comments about the criterion, agreeing that it is important to consider the size, character and coherence of potential National Park candidates. Others called for a degree of flexibility within this criterion to allow for a variety of models or landscapes to be considered for National Park status.

While most who commented agreed that distinctive character is an important quality, a few challenged including coherent identity under Component 1. Concerns were raised that very few candidates of sufficient size would be able to demonstrate coherent identity across the span of an entire area.

Regarding Component 2, a few described the phrase ‘sufficient size’ as vague and called for more information about this component. Some disagreed with including size as a qualifying factor in the assessment framework, fearing this may restrict the consideration of smaller potential sites.

Criterion 3: Meeting the special needs of the area

Some respondents agreed that the special needs of the area must be considered when assessing nominations for a new National Park. Several respondents cautioned that meeting the special needs of an area may be a difficult criterion for candidates to adhere to, advising that a site may have conflicting or opposing needs across different parts. A few respondents emphasised the importance of balancing the needs of local communities with national needs and the wider aims of the National Park.

There was widespread support for all five components of Criteria 3, with open comments focusing on the perceived order of importance of the components. For example a few respondents described Component 2 as the most important component under Criterion 3, emphasising the crucial role of National Parks in promoting and delivering nature recovery and restoration.

Criterion 4: Visitor management and experience

Respondents agreed that visitor management and experience should be a criterion for assessing nominations for new National Parks. They stressed that this should consider how the area would manage increased visitor numbers, but also how a park will ensure visitors enjoy the spaces and understand the area's history and cultural heritage. Respondents who disagreed with the criterion and provided a reason suggested that visitor management had not been effective in the other National Parks in Scotland.

Many respondents had comments about Component 3 about future transport infrastructure. While most agreed with the component, some suggested clarifications or additions, such as an emphasis on green or eco-transport infrastructure and education for all visitors on how to safely and sustainably enjoy and engage with the natural environment.

Some respondents agreed with Component 1 about enhancing opportunities for enjoyment, recreation and understanding of the area’s natural and cultural heritage, but suggested further considerations or amendments to the wording. These included consideration of an area’s contribution to a just transition to net zero, commitment to nature recovery, the value a place has in changing perceptions or challenging behaviours to support future sustainability, and how a new national park will encourage visitors to understand the interaction between the built and natural landscapes.

Criterion 5: Added value

While still recording a high level of agreement (72%), Criterion 5 recorded the lowest level of agreement of the seven criteria. Many who disagreed highlighted their dislike of the term ‘added value’, often due to their interpretation of this as monetary value or financial gain. Many respondents, whether they agreed, disagreed or were unsure about the criterion, suggested that a clearer definition of added value was necessary. Respondents noted that value, even financial value, could speak to a number of different outcomes. They asked for clarity about whether it was intended to be financial – and if so, for whom – or whether value could also speak to environmental, social, or cultural heritage concerns.

Open comments in response to the components of Criterion 5 typically reflected on the clarity of the wording of both the criterion and the components, specifically the ‘added value’ rather than the individual components. A small number of respondents made specific suggestions for further consideration.

Criterion 6: Local support

Many agreed with this criterion, but only some gave detailed reasons why, noting 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. 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 were concerns from several about how to balance the different interests of the 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.

Some respondents provided feedback on Component 1 about local support. A few asked for a clearer understanding of who would be classified as local under this component. A request for robust local representation, capturing a multitude of views, both positive and negative, was requested by a few respondents.

There were mixed views from several respondents in response to Component 2 about support from local authorities. A few of those who agreed requested further clarification on what information councils should supply in support of an application and how they would make it clear whether they support the nomination for all or only part of their area. Among those who disagreed or were unsure about the component, the main concern was that local authorities’ position could differ from that of the people or organisations in their area.

Criterion 7: Strategic contribution

While many agreed with the proposed criterion, only a few noted the importance of using National Parks to show how natural landscapes can be preserved and protected, increase biodiversity and be used to help mitigate climate change. A few were critical of how the creation of the two existing National Parks had been managed, as well as their current management. Individuals cited increased development of the areas and negative impacts on local populations, such as decreased wages, as their reasons for disagreeing. A few others disagreed because they thought National Park status would not effectively help environmental issues.

Support for the five components of Criterion 7 varied from 84% for Component 3 to 91% for Component 5. Of the respondents who provided further comment on Component 3 about sustainable investment in an area’s natural capital, most disagreed due to concerns over the concepts of natural capital and sustainable development, which they distrusted.

A few respondents noted concern about prioritising economic benefits from new National Parks. A few respondents suggested that the goals and aims of a wellbeing economy should be included, such as health and happiness.

Other considerations

Two further questions asked respondents for their views on the overall scoring process, and to provide any other comments on the draft Appraisal Framework.

Many respondents suggested that environmental considerations, such as ecological preservation, climate mitigation and biodiversity protection, should be given priority in the scoring process. Several respondents commented on the process of scoring applicants, with a small number requesting clarity on how criteria that seemed to overlap would be assessed.

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.

Conclusions

Overall, the key message was that, with some refinement, there is widespread support for the draft Appraisal Framework. The findings from the analysis will be used by the Scottish Government to revise and finalise the Appraisal Framework which will then be published ahead of the nominations phase of the selection process.