The North East Mountain Trust draws members from recreational users concerned about the future of the Scottish hills and coast. Through individual and affiliate membership we represent over 12,000 people. We are pleased to have the opportunity to comment on this draft Designation Order, but disappointed by the powers that it creates. The views that NEMT have put forward in response to previous consultations remain valid. We enclose a copy of the most recent two responses made to SNH.
We remain convinced that the primary aim of the proposed designation must be the protection of the core area of the Cairngorms. We welcomed the enabling legislation that at last proposed the highest international designation of land in Scotland. It is important that the secondary aims of sustainable use, recreation and rural development are not allowed to over-ride this primary aim.
There is little doubt the Scottish Ministers are right to choose to designate a Cairngorms National Park. The accompanying powers should ensure protection of this important and fragile high mountain environment from the many threats that it is under. The powers should be in keeping with the highest possible international designation and also with World Heritage status. We have grave doubts that this can be achieved with the proposed boundary and powers.
The draft Designation Order proposes a boundary enclosing an area that is too small. The area does not represent the whole of the Cairngorms and is not a coherent unit. In particular much of the southern Cairngorms is excluded. The Cairngorms Partnership area is more likely to succeed. We can see little logic in the boundary that has been chosen. In the north this divides communities and in the south it arbitrarily divides a mountain range excluding the Cairngorms south of a line through The Cairnwell. We continue to recommend boundaries that follow geographical or natural features and not those that follow political boundaries. With such a small area, it is essential that the boundary be drawn in the correct place.
The proposed powers are insufficient to protect the core area of the Cairngorm Mountains. Fundamental to these powers must be the ability to draw up meaningful plans for the whole area. One of the goals for National Parks has been the creation of a single authority with responsibility for the designated area. With Local Authorities retaining responsibility for Structure Plans, the Park Authority becomes little more than a puppet in preparing a Local Plan (overlapping parts of three LA Structure Plans!). Even then the implementation of that plan (or plans!) remains with the Local Authorities. One of the few benefits of waiting so long for Scottish National Parks must be the ability to learn from the examples of others. The necessity for Planning Powers has been clearly demonstrated in other places where designated land is not state-owned (including England and Wales where such powers were initially withheld). We can see no justification for a difference between this Designation and that of Loch Lomond and the Trossachs. The pressures on the two areas are comparable and the planning control workload needs to be resourced (whoever employs the staff).
This draft Designation Order fails to grasp the opportunity to introduce zonation to cope with the differing needs of different parts of the new National Park. This would be necessary to provide control in a buffer/residential area around the core area. The wish for Local Authorities to retain planning development control could be achieved in the outer zone.
There is no mention of the additional powers that are needed for the control of Land Use within the designated area. These include agriculture, forestry and deer management. We are disappointed that the Park Authority will have no control of the allocation of public funding in the area (grants etc which ultimately determine many people's behaviour).
The primary aim of the enabling legislation is to "conserve and enhance
the natural and cultural heritage". We feel that this Designation Order
(if passed without modification) will undermine that Act and fail to provide
much needed protection.
SNH have acted as both natural heritage advisor and reporter in the previous
consultation. We are disappointed that you appear to be ignoring their advice
without explanation.
Please take the opportunity of the remaining time to get the provisions of the Bill/Order right so that such a wonderful area achieves the protection that it deserves.
Appendix 1
NEMT and Scottish National Parks - 14 March 1998
Appendix 2
Response to SNH's proposal for a Cairngorms National Park
- December 2000
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