New National Parks - appraisal framework: consultation analysis

4. Criterion 2: Size, character and coherence

Respondents’ views on Criterion 2 and its two components are presented in this chapter. Q3 and Q4 asked if proposed new National Parks should be assessed for a distinctive character, coherent identity and be of a sufficient size to warrant integrated management.

Views on the criterion

Q3. Do you agree that ‘size, character and coherence’ should be a criterion for assessing nominations for new National Parks? If you disagree, please give reasons for your answer.

Among those answering Q3, 85% agreed that size, character and coherence should be a criterion. Over four fifths of individuals (83%) and most organisations (96%) agreed with the criterion; only one anonymous organisation disagreed.

Q3 received 31 open text comments. Few commented on the overarching criterion; most comments related to one of the components and as such were considered under Q4.

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. For example, some encouraged the Scottish Government to consider a range of approaches to drawing park boundaries.

“We favour different and creative ways of looking at a boundary for a National Park. For example, we suggest a National Park could encompass a series of distinct, but linked, areas across a region – that would collectively be of sufficient size, character and identity to form a National Park.” – South of Scotland Enterprise

“There should be flexibility in size, character and coherence to allow a variety of models that is relevant for the nature of the locality and qualifying criteria… we would argue in favour of considering a range of innovative approaches to National Park boundaries, including the possibility of designating different types of parks such as linear parks (say a river catchment) or a network of a collection of smaller park areas (multi-locational) with one central administration.” – Scottish Borders Council

“I disagree with the notion that 'size, character, and coherence' should be a criterion for assessing nominations for new National Park. My concern lies in the potential limitations imposed on prospective national park areas that are smaller and geographically separated from other areas of natural importance. I believe it would be more advantageous to consider creating multiple smaller areas that collectively constitute a national park. By adopting a more flexible approach, we can recognize and preserve the numerous small pockets of natural beauty scattered throughout the central belt of Scotland. These areas might not meet the requirements for a single large and continuous national park, but they still hold significant value and should not be excluded from this important categorization.” - Individual

A small number did not consider the features listed under Criterion 2 to be important, with some repeating their view that environmental benefits, biodiversity and nature recovery are the sole or most important considerations for National Park candidates.

Views on the components

Q4. Do you agree with the components of criterion 2 (size, character and coherence)? If you disagree, please give reasons for your answer.

Respondents were mostly positive about Component 1; 88% of those answering, including 86% of individuals and 96% of organisations supported the consideration of an area’s character and identity.

There was also support for Component 2 and the consideration of size, though at 77% this was lower than for Component 1. While agreement was relatively similar among individuals (77%) and organisations (79%), opinions varied among organisations. Most interest organisations / stakeholders (93%) agreed, as did 80% of public sector bodies, while other organisations held expressed more mixed views.

Q4 received 35 open text comments.

Component 1: Does the proposed area have a distinctive character and coherent identity?

While most who commented agreed that distinctive character is an important quality, a few challenged the inclusion of 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. Some warned that this criterion may exclude otherwise worthy candidates and called for flexibility when assessing candidates against this component. A few claimed that a site’s coherence can change or be nurtured or developed over time.

“Would areas that have multiple identities due to recent or historical migration then not have a coherent identity - and if so, why exclude them from being able to become a national park?” – Individual

“Coherence is also important to enable consistent approaches. However any area of scale will require nuance and understanding of localised issues and constraints/opportunities. Coherence in terms of landscape may not be reflected in coherence on land use, which will be equally important as it will require an integrated approach to deliver the multiple benefits sought.” – Scottish Land & Estates

Distinctive character was considered a subjective term, with a few cautioning that this could be difficult or contentious to assess as a criterion.

“Who decides what "character" is of value?” – Individual

Component 2: Is the proposed area of a sufficient size to warrant integrated management as a National Park?

A few described the phrase sufficient size as vague and called for more information about this component; for example, whether there would be parameters placed around this i.e. a maximum or minimum size.

“We agree but not clear what would be considered "a sufficient size" by [the Scottish Government] in this context.” – Campaign for a Scottish Borders National Park

“It would be helpful to have more information in the appraisal criteria about Component 2 as there is a lack of detail about what is meant by the reference to an area being of sufficient size to be a National Park.” – Crown Estate Scotland

“Further guidance may be required on the sufficient size criteria to ensure informed applications.” – Perth & Kinross Council

Some respondents disagreed with including size as a qualifying factor in the assessment framework, fearing this may restrict the consideration of smaller potential sites. A few advised against including a minimum size requirement.

“My concern is that emphasizing size as a primary criterion could exclude smaller areas of natural beauty that may have a distinctive character and coherent identity.” – Individual

“I agree that character and coherence should be prerequisites but depending on exactly what size is set, that could rule out any contenders from within an urban region - such as, for example, Holyrood Park.” – Individual

“Including 'size' has got potential to dissuade small areas of significant biodiversity/rare eco systems from applying/being chosen.” – Individual

However, others agreed with considering the size of potential sites, noting that candidates must be large enough to deliver their core functions and warrant the significant expenditure and resource associated with National Park status.

Suggestions for additional components

Some additional components were proposed for inclusion under Criterion 2, such as:

• Biological health and diversity of the landscape, including the presence of peatland.
• Local tourism infrastructure i.e. hotels, car parking, tour bus/sightseeing facilities.

Other comments

Galloway and Southern Ayrshire UNESCO Biosphere advised the Scottish Government to consider evaluation methods similar to that of UNESCO Biospheres by adopting “a three-tiered zoned approach that runs from areas of high ecological value; through to low key sustainable activity and ecological connectivity; and then onto a wider area that embraces cultural diversity and sustainable development.”