Future of National Parks: strategic environmental assessment - environmental report

Appendix B Scoping responses

Table AB.1: Scoping consultation responses

Scottish Environment Protection Agency (SEPA)

Consultation response

We agree that all SEA topics should be scoped into the assessment. We are satisfied with the proposed assessment approach. When refining the assessment questions in relation to air, soil, and water it will be useful to think about the overall objectives for these topic areas. For example, will the proposals help reduce levels of pollution and help enhance the environment.

How the response was considered/ addressed

The assessment questions have been refined for these topic areas, including with respect to whether the current draft proposals would help to reduce levels of pollution and enhance the environment. These are presented within the SEA Framework – see Chapter 3 of this Environmental Report.

Consultation response

The Scottish Government SEA Guidance provides guidance to Responsible Authorities about the type of information that is expected to be provided at each SEA stage; we have also produced SEA topic guidance for those issues which fall within our remit.

Our guidance includes example objectives and assessment questions for the different topic areas. The NPF4 policy intent for the relevant polices might also be useful to consider when refining the assessment questions. For example, protecting the ecosystem services that soils provide and restoring valued soils are key policy outcomes of the soils policy.

How the response was considered/ addressed

The SEA has been informed by the guidance notes, which have been a useful source of reference throughout the assessment process.

Consultation response

It is not clear from the scoping report the specific time period proposed for consultation on the Environmental Report. Typical consultation periods range from 6-12 weeks depending on the content and nature of the plan. On completion, the Environmental Report and the plan to which it relates should be submitted to the Scottish Government SEA Gateway which will forward it to the Consultation Authorities.

How the response was considered/ addressed

A public consultation on proposed legislative changes to the aims, functions, powers and governance of National Parks in Scotland will take place from September to November 2023. This Environmental Report, which is the main output of the SEA process, accompanies the consultation.

NatureScot

Consultation response

We agree with all the topics being scoped in. For those relevant to our remit, we are content with the scope and level of detail proposed, subject to the detailed comments that follow.

How the response was considered/ addressed

Comment noted.

Consultation response

Grouping of topics

We note, as it may be useful for the Environmental Report, that the categories / division of SEA topics is different in Table 1 (paragraph 4.3.1) and paragraph 4.2.2 and section 5. In our own SEA guidance, we link geodiversity with biodiversity flora and fauna rather than landscape, and this may better reflect the range of its contributions. Alternatively, it may be better in a separate category. See also points below.

How the response was considered/ addressed

For the purposes of the SEA, 'geodiversity' has been linked with biodiversity, flora and fauna rather than landscape, reflecting the range of its contributions.

Consultation response

Assessment questions

We have a couple of suggestions for the sample assessment questions in paragraph 4.2.2:

Biodiversity, flora and fauna: In addition to "Will the proposals help to protect and restore nature in existing and new National Parks?" you could consider "Will biodiversity and geodiversity benefits be maximised while realising socio-economic potential?' and 'Will implementation secure sustainable development and management practices?' Alternatively, put geodiversity in a category by itself.

Landscape: Instead of "Will the draft proposals help to protect and conserve landscape and geodiversity in existing and new National Parks?" we suggest "Will the draft proposals help to conserve, enhance or restore landscape character and local distinctiveness and the special qualities of the area?"

How the response was considered/ addressed

The two suggested assessment questions suggested have been included in the SEA Framework presented in Chapter 3 of this Environmental Report.

Consultation response

Understandably, given when the report was written, it refers to previous national planning policy rather than NPF4 (for example SPP in paragraph 5.7.1 p.20). We recommend this is updated.

How the response was considered/ addressed

Reference to Scottish Planning Policy has been updated, with NPF4 referenced.

Consultation response

We strongly recommend that the source of landscape information in paragraph 5.8.2 is changed to the national landscape character assessment, held on the NatureScot website. This, which provides national mapped coverage at 1:50,000 scale and is based on fieldwork, should replace the JHI 'regional landscape' descriptive paragraphs. The link in the SEWeb site does not flow through to the NatureScot dataset, and we recommend a direct link is used instead.

The landscape aspects of section 5.8 could make more of the interplay between natural and cultural factors. It is not just 'iconic built landmarks and townscapes' that are relevant, but settlement more widely and also the experiential qualities of landscape.

How the response was considered/ addressed

The national landscape character assessment (including a link) has been referenced in the baseline section of this Environmental Report. It has also been a useful source of evidence during the SEA process.

The 'experiential qualities' of landscape has been considered within the 'Landscape' appraisal findings presented in Chapter 4 and Chapter 5 of this Environmental Report, alongside the interplay between natural and cultural factors.

Consultation response

We consider that geodiversity is rather underplayed in the report. Scotland's world-class geodiversity is important in its own right and integral to our natural (and arguably cultural) heritage and its protection is not just "part of landscape planning and management" (paragraph 5.8.3). This could be made clearer in the Environmental Report and SEA process.

How the response was considered/ addressed

The SEA Framework has been updated to include a specific assessment question and a set of objectives with respect to Scotland's geodiversity resources.

Consultation response

We welcome the inclusion of blue green infrastructure in the Material Assets topic. And that Population and Human Health includes access for recreation and the role of environment and place in mental and physical well-being.

How the response was considered/ addressed

Comment noted. The interplay between natural and cultural assets and their links to mental and physical well-being is explored within the appraisal findings for the current draft proposals, presented in Chapter 4 and Chapter 5 of this Environmental Report.

Consultation response

Appendix B could include the European Landscape Convention in the international and EU level PPS section.

How the response was considered/ addressed

European Landscape Convention has been referenced in the 'existing environmental protection objectives' section of the landscape baseline.

Consultation response

Timeframe

We note and are content with the consultation timeframe.

How the response was considered/ addressed

Comment noted.

Historic Environment Scotland

Consultation response

Scope and level of detail

It is our understanding that The Scottish Government is progressing proposals for:

• The establishment of a new National Park(s) in Scotland, including draft proposed evaluation criteria for site selection.
• Potential changes to the governance arrangements for existing and new National Parks; and
• Potential amendments to the aims, purpose, and functions of existing and new National Parks.

We note that the historic environment has been scoped into the assessment. On the basis of the information provided, we are content with this approach and are satisfied with the scope and level of detail proposed for the assessment, subject to the detailed comments provided below.

How the response was considered/ addressed

Comment noted. 'Cultural Heritage' has been scoped into the SEA process, with the likely effects on historic environment assets associated with the current draft proposals and reasonable alternatives presented within the Environmental Report – see Chapter 4 and Chapter 5.

Consultation response

Assessment questions

Policy HEPS4 of the Historic Environment Policy for Scotland sets out that 'plans, programmes, policies and strategies, and the allocation of resources, should be approached in a way that protects and promotes the historic environment.'

In view of this, we recommend that the assessment question for cultural heritage is reworded to ask if proposals promote cultural heritage, in addition to protect and conserve.

How the response was considered/ addressed

The assessment questions and objectives for the 'Cultural Heritage' SEA topic have been updated appropriately to consider whether the current draft proposals would also 'promote' cultural heritage, in addition to protecting and conserving.

Consultation response

Relationship with other plans, programmes, and strategies

We welcome the inclusion of the Historic Environment Policy for Scotland (HEPS) at Appendix B. We recommend that Our Past, Our Future, Scotland's new strategy for the historic environment, should also be included in the review of relevant PPS for the historic environment. Our Past, Our Future will be officially launched in June 2023.

Conservation and enhancement of cultural heritage (incorporating the historic environment) is one of the aims for an area designated as a National Park as set out by the National Parks (Scotland) Act 2000. In view of this, we would expect to see HEPS and Our Past, Our Future included in the summary of the policy context set out at section 2.3.

How the response was considered/ addressed

Comment noted. HEPS and Our Past, Our Figure have been sources of evidence for the SEA process.

Consultation response

Baseline

We recommend that the reference to Scottish Planning Policy is updated to reflect the recent adoption of National Planning Framework 4 (NPF4).

The discussion of key pressures and trends could also:

• Reflect NPF4's increased emphasis on retaining and reusing existing buildings and structures.
• Recognise that the net zero agenda will drive a significant increase in demand for the retrofit of traditional and historic buildings.
• Recognise the pressures and opportunities that tourism and recreational access can have for the historic environment, particularly in the context of National Parks.

How the response was considered/ addressed

Reference to Scottish Planning Policy has been updated in conjunction with th adoption of the NPF4.

The key pressures and trends identified have been included in the 'key issues' section in Chapter 3.

Otherwise these key pressures and trends have been essential considerations through the assessment process, particularly with respect to considering potential impacts to Scotland's historic environmental assets associated with the current draft proposals. The assessment findings are presented in Chapter 4 and Chapter 5 of this Environmental Report.

Consultation response

Consultation period for the Environmental Report

You have indicated that the consultation is likely to run between July and September but have not set a specific time period for the consultation. We recommend that there should be a minimum period of six weeks, or longer where the consultation is lengthy or complex.

Please note that, for administrative purposes, we consider that the consultation period commences on receipt of the relevant documents by the SEA Gateway.

How the response was considered/ addressed

A public consultation on proposed legislative changes to the aims, functions, powers, and governance of National Parks in Scotland will take place from September to November 2023. This Environmental Report, which is the main output of the SEA process, accompanies the consultation.