NEMT's Response to SNH's proposal for a Cairngorms National Park (December 2000)

The North East Mountain Trust are very pleased to comment on SNH's proposal (December 2000) for a Cairngorms National Park. As in previous consultations, we fully support the concept of protecting Scotland's finest natural heritage. We would again emphasise that success will depend on adequate resourcing. We particularly commend the CCS 1991 Report "The Mountain Areas of Scotland", with regard to both the scope of general principles contained therein and to the specific detail relating to the Cairngorms. We are mindful that a considerable investment of public money was made to produce the CCS Report. More recent proposals have drifted away from tackling the problems identified in that report.

Key Issue 1

We feel that an area in the Cairngorms meets the requirements for designation under the National Parks (Scotland) Act. The high montane area is of outstanding natural importance both nationally and internationally. It has a distinctive character and a coherent identity. Whilst we have real concerns that the proposed environmental and landscape protection may not be strong enough, there is no doubt that the area requires greater protection than it currently receives. Strong planning guidance, properly administered in the past, might have afforded adequate protection without designation, but this has not been forthcoming and we now feel a National Park is essential. The terms of the designation must be robust enough to achieve the aims on which this designation is based.

Key Issue 2

The area designated should be sufficiently large to ensure complete protection of the core mountain area, and regeneration of its natural habitat (primary aim). The Zoning Principle as detailed in the 1991 CCS Report is essential to the success of the Park. Protection of the core mountain area can only be achieved by designating further areas around the core. In the surrounding zones secondary aims and activities can be given greater importance than they receive in the core.

As required by the Act, the area designated should have a coherent identity. We do not feel that some of the current options achieve this. The presentation of sub-units confuse the issue. Intensively farmed agricultural areas (sub-unit 29 and some of 12) are inappropriate for inclusion on the periphery of a National Park of this character and will lead to an overly complex National Park plan which attempts to control too many diverse issues. The southern boundary (in Angus) appears to be too far south as it encloses rich agricultural land. Perhaps the Highland Boundary Fault would form a suitable natural boundary.

The upper Spey catchment area needs protection within this National Park. As the source of a major water resource it affects what happens within the Cairngorms. However worthy of further protection, Creag Meagaidh and land to the south do not form a coherent whole with the Cairngorm massif. The fate of other land west of the A9 depends on plans for a further National Park based on the Fort William and Glencoe hills.

We comment elsewhere on the inclusion of communities.

Overall, we favour designation of the largest area (option C with the provisos mentioned) to ensure complete protection of the core mountain area.

Key Issue 3

We welcome SNH's attempt to be objective about the selection of land to be designated. However we feel that this approach would work better if the sub units themselves had coherent identities and this is not often apparent. MLURI and SNH should be able to provide information on land-use, vegetation type and topography in a readily accessible format that would facilitate the creation of such units

Key Issue 4

We feel that the inclusion of large communities in the National Park detract from its efficient administration and will create overly complex planning problems. We favour including settlements only if they are an integral part of, and largely dependent on land that is included. Examples are Aviemore and Braemar. Other larger settlements (such as Aboyne, the Angus towns and Pitlochry) that are gateways to the designated area, but are not so economically dependent on the use of the Park, need not be included. Smaller peripheral settlements should have the option to decide whether they wish to be included within the Park boundary.

Key Issue 5

This exercise is about landscape. Landscapes are divided by watersheds. Watershed dividing lines form logical boundaries.

A significant part of the character of this particular Park is shaped by its rivers and lochs. To be effective, the Cairngorms National Park Authority must have control over developments affecting the waters flowing into its area, as well as having a responsibility to include such catchments in Park planning.

It is often not appropriate to form boundaries along rivers themselves as both sides of a glen floor are likely to have a similar identity and be equally appropriate for inclusion. Furthermore, the status and use of the whole catchment affects water resources and the ecological status of rivers and lochs. We believe that, while worthy of protection in its own right, too much land west of the A9 has been included for coherent identity.

Wherever a boundary is drawn, there is a danger that development will be allowed just outside. Care in selection of the boundary and co-operation with the neighbouring planning authority (Local Authority) is needed to minimise the detrimental effect on the Park.

Key Issue 6

If the Scottish Executive is serious about this designation, the Park Authority needs to have control over the creation and implementation of plans covering all activities which potentially have a significant impact on the natural habitat or landscape within the boundary. These will include Forestry, Agriculture, and Deer Management, licensed vermin control, water management and hill tracks. Of paramount importance is the control of the allocation of all public funds within the area.

The Park Authority will require not only full planning powers, but also many powers currently vested in other bodies such as the Forestry Commission. Powers must be made available and used by the National Park Authority to make real improvements to the environment (e.g. footpath maintenance; forestry management; car park management), not just having in place a bureaucracy of consultation with Local Authorities.

In order to achieve the aims of this designation, we consider it imperative to impose binding statutory orders on other bodies in specific areas currently outside Local Authority planning control, e.g. water management.

We have no confidence in the use of voluntary codes and are concerned about the overuse of "positive incentives" to landowners.

Key Issue 7

We favour vesting full planning powers in the Cairngorms National Park Authority, but with the option of delegating planning control in the community zone only, to the Local Authority.

The Reporter indicates a view that the Cairngorms National Park Authority will not require full planning powers. This approach is clearly inconsistent between The Cairngorms and Loch Lomond & The Trossachs. In our view, it is incorrect to state that Loch Lomond and the Trossachs is more vulnerable to developments. A development within the Cairngorms may well have proportionately much more impact. It is the sensitivity of the area that requires that the Park Authority have full planning powers. One reason given for an option of no powers is that much town planning in built up areas will not be relevant to the authority and a drain on resources. It seems more logical, rather than weaken the Park Authority, to draw the boundaries so that large gateway settlements are not included. In the outer (or community) zone it may be more efficient for the Local Authority to have delegated Town and Country Planning Powers.

In the whole of the Park, building control needs to be considered against a single Park Plan. A single (Park) Authority is able to provide a common approach appropriate to the national interest. They would be considering the National Park as the centre of interest, whereas, to each Local Authority it would continue to be a non-contiguous, peripheral area.

We strongly urge the Executive to learn from the English example where planning powers have been transferred to Park Authorities that were not granted them initially. Without powers, the Cairngorms National Park Authority will not function effectively. The Cairngorms National Park must not become a global rarity in having a National Park Authority with no planning powers - this would detract heavily from its national and international importance in the world league of nationally valuable and protected areas.

Key Issue 8

We feel that The Cairngorms National Park should have a single, over-riding Park Plan for the whole of the designated area. This should be written by the National Park Authority, who should hold the powers to implement it. As indicated in Key Issues 7 limited powers may be delegated in the outer zone, but the Local Authorities would remain accountable to the Park Board.

Should the Scottish Ministers not be persuaded that it is essential for the Park Authority to be the statutory planning authority, we believe the Park Authority should have the strongest possible consultative status. The Park Authority should be a statutory consultee on all development proposals within the Park. Local authorities should be required to notify Scottish Ministers every time they are minded to give planning permission against the wishes of the Park Authority. We think it unlikely that the Park Authority will concern itself with objecting to planning proposals which do not have a significant impact on the objectives of the National Park.

Key Issue 9

We support the maximum sizes proposed (i.e. 5, 10, 10) to ensure that national interests are fully represented in the face of concessions given to local interest groups in the drafting of the Act. Above all the Park Board needs to provide a balance of relevant knowledge and experience to ensure a secure future for Scotland's natural heritage.

Key Issue 10

A major issue at stake is the protection of land in the national interest, so we favour the allocation of membership based on land area. Local issues are already represented on a population basis.

Key Issue 11

The Park Authority needs to be formed to deliver the stated aims of the designation. We remain convinced that the conservation aim is paramount, particularly in the core montane zone. Board members should have substantial knowledge and expertise in a balanced range of areas of interest. These will cover all forms of land management, including recreation, agriculture, forestry, tourism and local community interests. There should be a spread of international, national and local interests. One or more members should have experience in sourcing external funding (especially EU).

Key Issue 12

"Local members" should represent truly local interests, not a distant Local Authority ward. In addition to residents, the "local" community comprises the "visiting" community from nearby (North East of Scotland) whether for work or recreation. Elections and appointments should be conducted to ensure that local and national interests are in balance.

Key Issue 13

We feel that local elections should be the first stage in the appointment process, followed by Local Authority nominations. The Scottish Ministers' own appointments should be the final stage. This is the most likely process to produce the necessary balance of outstanding expertise and knowledge.

Key Issue 14

We can suggest no better name than Cairngorms National Park.
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