New National Parks - appraisal framework: consultation analysis

5. Criterion 3: Meeting the special needs of the area

This chapter presents an analysis of views on Criterion 3 and its five components, which consider whether meeting the special needs of the area should be part of assessing nominations.

Views on the criterion

Q5. Do you agree that ‘meeting the special needs of the area’ should be a criterion for assessing nominations for new National Parks? If you disagree, please give reasons for your answer.

There was widespread support for Criterion 3 among those answering Q5. Over nine in ten (91%) agreed with the criterion, making it the joint most supported criterion along with Criteria 7. Support was equally high among individuals (90%) and organisations (93%), with no organisations opposed and two unsure.

Supportive comments

Q5 received 26 open text comments. Some respondents expressed support for Criterion 3, agreeing that the special needs of the area must be considered when assessing nominations for a new National Park.

“Yes, we agree that nominations must explicitly address how national park status will provide benefits for existing communities and businesses, and to attract and retain the local population to stay and work in the area. Nominations should set out how they will address specific issues such as rural connectivity, ageing populations, transport infrastructure, housing shortages, and permanent employment.” – NFU Scotland

A few added that candidates’ adherence to Criterion 3 will help to support nature recovery and habitat and species management efforts.

Reasons for disagreement

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. For example, one described agricultural and farming practices as at odds with rewilding and ecological restoration efforts, and another described public access and tourist activity as incompatible with nature conservation work.

“There is potential tension between supporting nature recovery and restoration and promoting the understanding and enjoyment of the area by Scotland's people. There can be a need to restrict access to enable nature recovery and this does not always sit well with the national park designation and the ability to attract more visitors. We have also seen ecological damage done by visitors which require careful management and messaging.” – Scottish Land & Estates

Others highlighted that the special needs and priorities of different candidates will vary significantly, and this may result in difficulties in assessing bids.

Other comments

A few respondents emphasised the importance of balancing the needs of local communities with national needs and the wider aims of the National Park. One commented more explicitly that it is important to consider the special needs of the entire country rather than a specific area when selecting a new National Park.

“We agree that meeting the special needs of the area should be a criterion, this is important to ensure that the needs of local communities are adequately taken into account. It will be vital to ensure that any new National Park is equipped and ready to work with communities to ensure their sense of place is not negatively impacted, for example through increased traffic, tourism numbers, housing development, or infrastructure development. Ideally, bids will also outline how they propose the National Park will help lead a Just Transition to nature positive and net zero in a way that benefits local communities, in line with the Scottish Government’s ambitions for National Parks.” – RSPB Scotland

A small number of respondents did not fully understand the meaning of ‘special needs of the area’ and asked for more detail or specific examples to be provided.

A few responses to Q5 were not directly related to Criterion 3. These included the need for any new National Park to be adequately resourced and that any successful candidates will require investment to help develop tourism infrastructure like hotels, restaurants and public toilets.

Views on the components

Q6. Do you agree with the components of criterion 3 (meeting the special needs of the area)? If you disagree, please give reasons for your answer.

As with the overall criteria, there was widespread support for all five components of Criteria 3.

• 94% agreed with Component 2, the highest rating of all components in the framework.
• 92% agreed with Component 5, the second highest rated of all components.
• Between 86% and 91% agreed with the other three components.
• Between 90% and 97% of organisations agreed with each component, with no single organisation or type of organisation being consistently opposed.

Q6 received 49 open text comments, covering comments related to each component, and other more general points.

Component 1: How would National Park designation support the conservation and enhancement of cultural heritage and the historic environment?

Few respondents commented on Component 1. A few considered the preservation of cultural heritage as a lower priority than the other components under Criterion 3, with one describing themselves as ‘ambivalent’ towards it. One suggested switching the order of Component 1 and Component 2 so that nature recovery is listed first and is therefore presented as the highest priority.

However, Historic Environment Scotland and ScottishPower Renewables welcomed this component, agreeing that a new National Park should support Scotland’s rich cultural heritage and historic environment. Comhairle nan Eilean Siar advised that if a new National Park is within a traditional Gaelic-speaking community, there should be a focus on enhancing the language and its related culture.

Component 2: How would National Park designation support nature recovery and restoration in the area, including ecosystem restoration, protection and recovery of vulnerable and important species and wildlife management?

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.

Perth and Kinross Council suggested amending ‘vulnerable and important species’ to include ‘vulnerable and important species and habitat’. In their response, Scottish Rewilding Alliance discussed the benefits of rewilding and described it as “a clear route by which we can achieve nature recovery within our national parks.”

Component 3: How would National Park designation help to promote the understanding and enjoyment of the area by Scotland’s people?

Most of those who commented on Component 3 agreed with its inclusion. However, some called for it to be amended to include a reference to tourists and international visitors.

“On Component 3, I would hope this also brings benefits such as sustainable tourism - attracting not just Scottish nationals but other residents and visitors. Otherwise I agree.” – Individual

“Mention should be made of the international community, for reasons of: i) the importance of National Parks in the promotion of Scotland internationally, and in attracting visitors; ii) the international significance of the natural or cultural heritage of Scotland's National Parks which, increasingly, can be accessed or learnt about using digital tools.” – James Hutton Institute

Dumfries and Galloway Council described the word ‘enjoyment’ as “personal” and “difficult to assess” and called for a less subjective term to be used.

Component 4: How would National Park designation support the sustainable development and well-being of local communities?

There was little consensus among comments on Component 4. The following separate points were made:

• Highland Council described Component 4 as particularly important, especially in relation to the availability and affordability of housing and access to high-quality transport infrastructure.
• Paths for All suggested that Component 4 could be broadened to include ‘communities of interest’ instead of ‘local communities’. They also highlighted mental and physical health being enhanced by enjoying outdoor recreation as a key aspect of the component.
• The Royal Town Planning Institute Scotland called for Component 4 to include a reference to Community Wealth Building in order to increase clarity, coherence and alignment with other policies on this point.
• Two respondents pointed out inconsistencies between the language used in Component 4 and the National Parks Act. Galloway National Park Association and Campaign for a Scottish Borders National Park both highlighted that the relevant Aim in Section 1 of the Act states, “sustainable economic and social development of the area’s communities” and advised that the wording of Component 4 should be amended to reflect this.

Component 5: How would National Park designation support the sustainable use of the area’s natural resources and how it would make a significant contribution to climate change mitigation and adaptation?

Component 5 was well received; some respondents expressed agreement that National Parks have a key role to play in addressing and mitigating climate change. A few respondents considered Component 5 to be the most important component under Criterion 3, with one arguing that it should carry the most weight during the assessment of candidates.

However, one individual disagreed with the inclusion of Component 5, describing a National Park’s ability to influence climate change as minimal. Another flagged that Component 5 may be incompatible with other assessment criteria in the framework.

“The wording of component 5 could give rise to conflict with the other components. For example, the imposition of wind farms and dams could be seen to help combat climate change but at the expense of local landscape, beauty, biodiversity and character.” – Individual

Additional components suggested

Some respondents called for more recognition of an area’s economic needs i.e. economic growth and job creation within Criterion 3, particularly for sectors like forestry and agriculture.

“It would be helpful to include a component on the economic needs of the area. There is potential for there to be benefits to business and individuals through enhanced tourism and other sectors. It is important that any national park helps to enhance the local economy as well as the environmental and social goals.” – Scottish Land & Estates

“An area’s agricultural output must always be considered when making decisions around national park status. We believe that food production and a thriving agricultural economy is crucial to many areas in Scotland. The creation of new national parks must not threaten this in favour of increased tourism or environmental protection. Scottish agriculture can deliver on food production, as well as environment and climate challenges only if it is enabled and supported to do so.” – NFU Scotland

A few organisations, including South of Scotland Enterprise and Scottish Campaign for National Parks, did not feel that socio-economic benefits were emphasised strongly enough under Criterion 3. They suggested that more could be done to highlight or promote this aspect.

“SCNP strongly supports this criterion, which reflects the overall principle of place-based policymaking as well as the aims set out in current National Park legislation. We have, however, detected a concern amongst some who have hitherto supported the designation of more National Parks that this appraisal framework as now presented plays down the socio-economic aim (and hence the potential benefits to local residents) relative to the others… Perhaps the sustainable socio-economic aspect could be better drawn out in accompanying guidance notes for nominations and reflected in the weighting of scores?” - Scottish Campaign for National Parks (SCNP) and Action to Protect Rural Scotland (APRS)

A small number called for the inclusion of a component that addresses depopulation and seeks to grow the human population within the National Park area.

Architecture and Design Scotland suggested that the following component should be added under Criterion 3: "How would National Park designation support collaboration between stakeholders, local and national, to the benefit of nature, people and places?"