New National Parks - appraisal framework: consultation analysis

7. Criterion 5: Added value

This chapter examines Criterion 5 and its two components. It asks for opinions on whether added value should be a criterion for assessing new National Parks. The components would ask applicants to show how their proposed National Park would justify the investment in creating and managing a park, and the value it would bring to the area.

Views on the criterion

Q9. Do you agree that ‘added value’ should be a criterion for assessing nominations for new National Parks? If you disagree, please give reasons for your answer.

Seven in ten respondents (72%) who answered Q9 agreed with a criteria of added value. While this is still a high level of agreement, Criterion 5 recorded the lowest level of agreement of the seven criteria. Agreement was lower among individuals than for other criteria, with 69% agreeing, 19% disagreeing and 12% unsure.

Among organisations, 86% agreed that added value should be a criterion. The only organisations who did not agree were all in the interest organisation / stakeholder category; The National Trust for Scotland and Scottish Rewilding Alliance disagreed, and John Muir Trust and the joint response from Scottish Campaign for National Parks (SCNP) and Action to Protect Rural Scotland (APRS) were unsure.

Supportive comments

There were 44 comments in response to Q9. A few respondents noted they supported the criterion as long as added value was defined widely and not limited to financial value. Another suggested adding a caveat to include value for residents and visitors.

Along with concern about concepts of value and who or what should benefit from the park, a few comments questioned the word ‘added’, noting that there is a reciprocal beneficial relationship between a National Park and the area or community surrounding it.

“Whilst agreeing with the Criterion, we note that the term 'added value' is not entirely appropriate. The current importance and values of an area may be a sufficient basis for designation, onto which designation leads to further value being gained. An alternative terminology should be considered.” – James Hutton Institute

A small number of organisations stressed the importance of ensuring that investments consider the overall cost and the impact on businesses and communities. One individual agreed but noted that many good projects have been left unfinished due to the ‘inability to construct a whole investment case’.

“Yes, we strongly believe that nominees for new national parks must set out the merits of designation compared to existing or other approaches. A national park has to demonstrate what it can deliver for businesses, communities, and people over and above existing policies and legislation. These benefits must outweigh the threats, perceived or otherwise. This is crucial if national park authorities are to bring local communities on board with the national park process.”- NFU Scotland

Highland Council supported the criterion as it would enable environmental investment.

“Many of Highland’s most important areas for nature and landscape have not seen significant investment in habitat/species management or visitor management more generally. It is unlikely that this position will change without special status/national designation and additional /existing resources prioritized accordingly.” – Highland Council

Dumfries and Galloway Council suggested that added value should be viewed from a local perspective and across all sectors, ensuring a new National Park provides the greatest benefit to the locality. Galloway and Southern Ayrshire UNESCO Biosphere agreed with this criterion as a way to judge whether National Park designation would be best in contrast to other designations, such as UNESCO Biospheres, which may offer better value for investment depending on the area.

Reasons for disagreement

Many respondents who disagreed highlighted their dislike of the term added value, often due to their interpretation of this as monetary value or financial gain. Some noted the value National Parks can bring to nature, the environment and biodiversity as a top priority, as described in Chapter 3. Some others, all individuals, dismissed the concept of added value as being irrelevant to the primary purpose of National Parks.

“Creating a new national park will bring inherent value in the designation alone, I think the foreword quite clearly outlines that a new national park will prove beneficial across the board and help towards our climate goals.” – Individual

“Not my idea of the main purpose of a national park.” – Individual

“Added value is benefit, but cost neutral or even a small cost to provide an area of outstanding significance is fine.” - Individual

Defining added value

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.

“I put don’t know because I don’t disagree but want to be sure that ‘value added’ is not a simple measurement of financial gain; it has to be about other, often more important gains such as protecting the future of life on this planet.” – Individual

“I think ‘added value’ should be a criteria but what are the criteria for "added value"? Is it financial, and if so to whom - residents, investors, Treasury under English law which gets the taxation and keeps it to spend on Westminster expenses. Is it environmental? Is it health and wellbeing benefits to those who live there and those who visit - and how will you measure this? GDP is a poor measure of anything, and the kind of benefits that really matter are not easily defined or measured, or even known unit after the changes are in place. Unintended consequences can be good as well.’ – Individual

Views on the components

Q10. Do you agree with the components of criterion 5 (added value)? If you disagree, please give reasons for your answer.

Three quarters (76%) agreed with Component 1, with relatively similar levels of agreement among individuals (76%) and organisations (74%). However, only two organisations disagreed - The National Trust for Scotland and Scottish Rewilding Alliance – with the remaining five organisations answering ‘don’t know’.

Component 2 was supported by 72%, which was the lowest level of support recorded across all components. Individuals were less likely to agree than organisations - 71% and 78% respectively. Again only two organisations disagreed - Comhairle nan Eilean Siar and Scottish Rewilding Alliance – with the remaining four organisations answering don’t know.

There were 47 comments in response to Q10. However, many commented on the clarity of the wording of both the criterion and the components, specifically the language around ‘added value’ as discussed above, rather than the individual components.

Component 1: How would the benefits of a National Park in the area justify the investment required?

Only a small number of respondents commented on Component 1. Those who did made one of the following two suggestions:

• In order for applicants to be able to justify the investment required, they will need to be provided with an approximate cost of a new National Park.
• Rather than understanding the investment in terms of the benefit it may bring to the surrounding area, also consider whether an area has enough investment to protect the natural environment from the impacts of a new National Park.

Component 2: What is the added value that National Park designation would bring to the area?

The few respondents who commented on Component 2 suggested:

• Consideration should be given to assessing unforeseen negative impacts on some sectors, such as housing stock and land values.
• Component 2 would be a good place to explain and further define the term added value.

Other comments

Some respondents suggested further considerations for the criterion and components as a whole. These included:

• Requests to broaden the language used, including highlighting the value a new National Park would bring to the nation.
• How investment will be used to bring in further investment, as well as the potential loss of investment such as in local businesses that run and maintain windfarms.
• Providing a clear understanding of a funding plan.