New National Parks - appraisal framework: consultation analysis

3. Criterion 1: Outstanding national importance

This chapter examines respondents’ views on Criterion 1 and its two components. Respondents were asked whether outstanding national importance should be considered when assessing new National Parks, and specifically whether natural and cultural heritage should be considered.

Views on the criterion

Q1. Do you agree that ‘outstanding national importance’ 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	88	9	3
Individuals	129	86	10	4
Organisations	28	96	4	0
- Interest organisations / Stakeholders	14	93	7	0
- Public sector bodies	10	100	0	0
- Built Environment / Land management	3	100	0	0
- Energy	1	100	0	0

Almost nine in ten (88%) of those answering Q1 agreed that outstanding national importance should be a criterion for assessing nominations. The vast majority of individuals (86%) and organisations (96%) agreed with the criterion. Only one organisation – NFU Scotland – disagreed.

Q1 received 30 open text comments. As noted in the introduction, although respondents were asked to comment if they disagreed, a range of views were expressed; some were supportive of Criterion 1, while others were more critical.

Supportive comments

Some respondents made supportive comments, expressing their approval of using outstanding national importance as an assessment criterion for new National Parks.

“National Parks should represent areas of outstanding national importance due to their natural and cultural environment.” – South of Scotland Enterprise

“We agree that outstanding national importance should be a selection criterion for the new National Park.” – RSPB Scotland

One respondent described the proposed criterion as consistent with the requirements of the National Parks (Scotland) Act 2000.

Prioritising environmental considerations

However, some concerns were raised about the proposed criterion. 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 assessment framework to focus more closely on nature conservation, restoration and recovery. Others disagreed with the introduction of a new National Park, instead advocating for environmental protection and restoration to be implemented across all of Scotland’s land, rather than in a specific area.

“Designating areas of outstanding national importance could also lead to ‘winners’ and ‘losers’ throughout Scotland, by drawing arbitrary lines on a map. This is contradictory to Government commitments around just transition and fairness. NFUS [National Farmers Union Scotland] strongly believes that it is better the whole of Scotland is improved, rather than select parts." – NFU Scotland

While these comments were prevalent in response to Q1, the importance of prioritising environmental considerations when assessing applications was a recurring theme raised by some respondents across multiple consultation questions. However, as little additional detail was provided by the respondents making this request, only brief references are made to this theme in the remainder of the report to avoid repetition.

Debate over location qualifier

The use of the term 'national' as a qualifier for importance was challenged by a few respondents. Two were concerned that if a location is deemed to have outstanding national importance it could overshadow the interests of the local community. Another contested that the National Parks (Scotland) Act 2000 does not specify that outstanding 'national' importance should be a criterion.

There were calls for the ‘regional’ significance of National Park candidates to be considered in conjunction with national importance.

“To ensure support and effective engagement of local communities it is also important that the area reflects regional significance.” – Dumfries and Galloway Council

Galloway and Southern Ayrshire UNESCO Biosphere called for ‘international’ importance to be included in the criterion.

Calls for more detail

Several called for greater clarity and a more detailed definition of the proposed criterion; it was described as unclear, open to interpretation and difficult to assess.

“The definition of ‘outstanding national importance’ should be clearly defined as not to undermine the credibility of this designation.” – Scottish Power Renewables

“It's a nebulous and subjective criterion.” – Individual

"Who is to say whether a particular area is or should be of outstanding 'national' importance? On what basis can such a claim be made?” – Individual

“I agree in principle, but I don't think this term has been defined well enough within the framework, leaving too much ambiguity and room for dispute.” – Individual

The term ‘outstanding’ was seen as particularly ambiguous and subjective. A few described the outstanding national importance criterion as unnecessary and potentially restrictive, with one individual arguing that a National Park “merely needs to be somewhere special; an area of natural beauty or significance that we want to protect for future generations”.

“I disagree with the word "outstanding" as I fear it could be used to block worthy candidates for park status.” – Individual

However, the John Muir Trust welcomed keeping this interpretation open “so that nominees can explain what makes an area outstanding”.

Different approaches to identifying the site of Scotland’s new National Park were proposed by respondents. For example, a few suggested that rather than selecting an area of outstanding national importance, an undeveloped site, such as brown space or an ash lagoon, could be transformed into a National Park.

“The ability to seek enhancement of degraded areas or areas that do not meet the national importance test, should also be considered, in order to enhance and complement the core of the potential Park.” – Scottish Borders Council

“There is an argument that there could be more benefit in areas which are not already outstanding for biodiversity... Therefore more benefit could be accrued.” – Scottish Land and Estates

Criticism of existing park management

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. This small number of respondents repeatedly raised their concerns throughout the consultation; to avoid repetition they are acknowledged here. For example, at Q16 – do you have any other comments? – a few respondents raised concerns about the proposed development of a theme park at Loch Lomond.

In Q1, one individual called for National Parks to be replaced by publicly owned nature reserves; another described the process of establishing a new National Park as too complicated and called for less regulation and bureaucracy. In Q16, one individual called for reforms to the national parks system, highlighting the importance of protecting all land, not just the areas designated as National Parks.

Other comments

A few called for existing UNESCO sites to be considered for National Park status.

“There may be some designations, e.g. UNESCO Biospheres, that already meet the aims of a National Park and deliver across the criteria making up the framework so there will be value in looking at the connections between existing designations." – Dumfries and Galloway Council

Two advised against considering new candidates in isolation, suggesting that a new National Park should offer something unique or different from the two existing National Parks in Scotland. One respondent suggested that Scotland’s National Parks should be connected by corridors of land to enable safe dispersal and movement of wildlife and ecosystems within them.

Views on the components

Q2. Do you agree with the components of criterion 1 (outstanding national importance)? If you disagree, please give reasons for your answer.

All answering for each component:	n=	% Agree	% Disagree	% Don’t know
Component 1: Is the proposed area of outstanding national importance due its natural heritage, including biodiversity, geodiversity and landscapes?	156	89	8	3
Component 2: Is the proposed area of outstanding national importance due to the area’s cultural heritage, including the historic environment?	149	77	14	9

The table above details the results for each component among all respondents who answered each question. Tables with a full breakdown of results by respondent type are provided in Appendix A.

Most respondents agreed with Component 1 of the criterion – 89% of those who answered agreed, as did 88% of individuals and 93% of organisations.

While agreement with Component 2 about considering cultural heritage was comparatively lower, over three quarters (77%) of those answering agreed with its inclusion. Agreement was lower among individuals, with 73% agreeing compared to 93% of organisations.

Q2 received 38 open text comments. Broadly, the two components were well received. However, as with the overarching criterion, there were calls for more detail about each component.

Component 1: Is the proposed area of outstanding national importance due its natural heritage, including biodiversity, geodiversity and landscapes?

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. This aligns with the recurring theme of prioritising environmental considerations.

“While cultural heritage is important it should be secondary in consideration to the natural heritage.” – Individual

“I think Criterion 1 is more important given we are in a situation where Climate Change is impacting on us. Biodiversity, geodiversity and landscapes are more important than historic & cultural heritage.” – Individual

Two highlighted that cultural and historic sites have other bodies which oversee their preservation, such as Historic Environment Scotland, and therefore natural heritage should be the priority for National Park candidates.

While most were supportive of Component 1, a few expressed concern that a requirement for outstanding natural heritage may exclude urban areas from National Park candidacy.

“There are many urban areas that could be defined as having outstanding national importance, and indeed cultural heritage. But the lack of ‘natural heritage’ may preclude them from becoming a national park. We believe that component one restricts the potential of urban areas, while at the same time placing extra burdens onto rural areas.” – NFU Scotland

“I would like to propose a national park in the central belt, which component 1 might prevent.” - Individual

A few organisations, including RSPB Scotland and Scottish Environment LINK, requested more detail about the ecological criteria that would be used to determine whether a candidate’s natural heritage is of national importance.

Component 2: Is the proposed area of outstanding national importance due to the area’s cultural heritage, including the historic environment?

As noted above, Component 2 was viewed as less significant and less relevant than Component 1 by most who commented. 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.

“I think an area such as the flow country should have as much right to be a contender for reasons of its natural heritage alone (I don't know how much of a cultural heritage, if any, it has) as, say, Rannoch moor, which has both natural and cultural heritage.” – Individual

“Many major cities have a deep cultural heritage, yet that seems hardly fitting for a national park.” – Individual

However, others welcomed Component 2 and agreed that preserving and celebrating Scotland’s cultural heritage should be a priority for a new National Park. Some reiterated these calls at Q16 – Do you have any other comments? A few called for Component 2 to be considered very broadly so as not to exclude less obvious areas of cultural importance. It was proposed that industrial and agricultural heritage should be included under the definition of cultural heritage. Also at Q16, Bòrd na Gàidhlig emphasised the importance of the cultural history of the Gaelic language and culture, which they suggested should be included in any National Park proposal.

Suggestions for additional components

Some additional components were proposed for inclusion under Criterion 1, such as:

• Biological health and diversity of the landscape.
• Recreational and educational capacity.
• Capacity for nature recovery and community regeneration.
• Resilience of the landscape (i.e. ability to absorb substantial visitor numbers without having a negative impact on the area).
• Public transport links.
• Renewable energy infrastructure.
• Wildness.

Other comments

Cultural and natural heritage were described as highly integrated, with a few highlighting that historic features and processes can shape landscapes and natural assets. A small number of organisations, including Historic Scotland and Built Environment Forum Scotland (BEFS) felt that separating Component 1 and Component 2 was unhelpful and called for them to be combined into one category.

“BEFS welcomes the inclusion of cultural heritage and the historic environment as components for Criterion 1, however would suggest that the presenting cultural heritage and natural heritage as separate criterion could undermine the fundamentally interconnected nature of the two.” – Built Environment Forum Scotland (BEFS)

Some respondents anticipated difficulty assessing candidates based on their natural and cultural heritage, describing them as contested or subjective constructs.

“While this is laudable, there will need to be more guidance available on this. Every area of Scotland could lay claim to being nationally important both for natural and cultural heritage.” – Scottish Land & Estates

“I imagine this would not be a functioning discriminator… isn't all of Scotland suffused with cultural significance?” – Individual