Every five years, the Scottish Government updates and revises the National Planning Framework, which sets out objectives, issues to be considered and desired outcomes for planned developments across Scotland. Last year, the consultation copy of the document included a map provided by SNH showing the remaining areas of wild land in Scotland. The intention was to raise the profile of these areas and afford them some measure of protection. Unfortunately, following consultation, the map was removed from the document. However, before the map was removed, and during the planning consultation, SNH decided to consult on the map itself. A copy of NEMT's response is included below.
NEMT agrees that this map includes most areas that can be considered as wild land. Furthermore, NEMT welcomes this map as, broadly speaking, an excellent step forward in conserving what remains of our wild land heritage. It will be particularly helpful in promoting our tourist industry. Many people come from over-crowded Europe to experience Scotland's wild land. Quantitative and spatially specific data will be needed to manage this resource properly in the future and to ensure that the ongoing erosion is reduced. Our wild land is under huge development pressure, often short-term and opportunistic in nature. Losing any more wild land is something that we have to strongly resist. There is a real risk that we "kill the golden goose" of our tourist industry, which sustains vital rural jobs.
SNH has described the process used to draw up the map. This clearly acknowledges that there is some subjectivity in determining the attributes and their relative weightings. Presumably, SNH has carried out some sensitivity studies to see the impact of different attributes and different weighting. We suggest that, in the interests of transparency, SNH publishes the results of these sensitivity studies to give an indication of how sensitive the results are to these parameters. This would clarify the robustness of the methodology and would be useful if, in future, it was considered desirable to change something.
We believe that wild land in Scotland needs improved protection. To that end, this map needs to be adopted by local authorities and the Scottish Government, accompanied with specific requirements for protection in the Scottish Planning Policy and new National Planning Framework, e.g. to be used to indicate a strong presumption against any development.
We are concerned that, both in this consultation and in ongoing planning applications, the boundaries to the wild land shown here will be continually challenged. NEMT strongly supports the current map.
If, as a result of this consultation, the area of wild land is reduced, or, in the future, there are proposals to reduce any of the areas designated as wild land, all such changes should be brought to a new round of consultation followed by a public inquiry. This map is good. Let's not see it whittled away in "a death by a thousand cuts".
The high resolution map available for download is, in fact, not very high resolution. NEMT would be pleased to ground-truth the map in our local area (Area 15) if a suitably high-resolution map was provided. However, we believe that improved protection to existing wild land is needed urgently and thus would not want to see adoption of this map held up while people discuss small changes to the boundaries.
We think that it is important that planning policy recognises that the areas of wild land identified here are all given mandatory protection. It is not sufficient to say that the better areas are already protected by our existing National Parks, National Nature Reserves and National Scenic Areas, which protect the best examples. Wild land is an iconic part of our heritage and a key part of why tourists choose to visit Scotland. We need to protect wild land in its entirety. People appreciate our wild land in its broad sweeps not as isolated pockets.
One point that stands out strongly is the comparative lack of wild land identified in both the islands and western coastal fringes. Presumably, this is an artifact of the current attributes used to derive the map. We think that this should be revisited when the map is updated, although it should not hold up adoption of the present map. This also applies to the extensive peatlands in the north.
An important point, albeit one that needs to be referred to other Government departments, is what use will be made of the map. We believe that the map needs to be accompanied by specific requirements for protection of the land identified in both the Scottish Planning Policy and the new National Planning Framework, e.g. to be used to indicate a strong presumption against any development.
The letter set out below was sent out to all North East MSPs. The core text is the same for all letters but they were individually modified depending on earlier replies to my hill tracks letter and also their committee memberships.
Alison McInnes MSP
Dear Ms. McInnes,
Wild land and Scotland's National Planning Framework 3
I am writing to you as one of my regional MSPs for the second time this month to enlist your support in both a personal capacity and also as Chairman of the North East Mountain Trust. The North East Mountain Trust represents 700 local hill walkers and climbers, who visit and enjoy wild land. We are very concerned that the National Planning Framework, currently being considered by the Scottish Parliament, has dropped any mention of wild land, as set out in the Scottish Natural Heritage map of Core Areas of Wild land.
This map was specifically referred to in the NPF Main Issues Report issued for consultation in 2013. It was also specifically referred to in the draft Scottish Planning Policy, issued at the same time. The Main Issues Report made clear that the reference was designed to protect Scotland's wildest landscapes. It is, thus, surprising that any mention of this map has been dropped from the NPF3 that has now been laid before the Scottish Parliament. It is particularly surprising given that the published responses to the consultation showed a two to one majority in favour of strengthened protection for wild land via the wild land map. The North East Mountain Trust participated in the consultation exercise and is disappointed that, despite our and other's replies, all mention of the SNH wild land map has now been dropped.
NPF3 is intended to be a "long term strategy for Scotland" and "a spatial expression of strategy and of our plans for development". It is difficult to see how such a document can ignore wild land; one of Scotland's iconic features and also a major tourist attraction.
We are not against any further development. We believe that our wild land is a scarce and diminishing resource that can be best protected by strong local democratic control, not left to the whim of a land owner.
As one of my regional MSPs, I ask you to ensure that my, and my organisation's, views are communicated to your party colleagues on the three committees currently considering NPF3 so as to ensure that the final version of NPF3 reflects the Government's earlier aspiration to improve protection for Scotland's wild land through reinstatement of the reference to the SNH map of Core Areas of Wild Land.
I welcomed your response to my earlier letter and hope that you can support us once more.
To date, replies have been had back from 6 MSPs, who have all either written
to the minister or asked a colleague to raise the matter during committee scrutiny
of NPF3. A quoted excuse is that SNH's own consultation is ongoing and how can
you include reference to a document that is still being consulted on? However,
some MSPs acknowledge that we have a valid point in that a key part of the document
sent out for consultation has been taken out despite the consultation findings.
So far, I have had one reply back from the minister, but, unfortunately, raising two issues at the same time has caused confusion - a point to remember for the future! The Minister's reply on hill tracks has also been quoted as his reply on wild land - conservation issues are all one and the same!!
On the positive side, the letters have helped to raise awareness and, hopefully, will help to ensure that the matter is raised during the committee scrutiny stage.
In my experience, so far, this represents a typical range of replies.
However, we include this extract from the John Muir Trust website, Feb 2014:
Response to SNH consultation reveals 4 to 1 in favour
The John Muir Trust hailed the result of a Scottish Natural Heritage (SNH) public consultation on its core wild land map as a resounding endorsement of the proposal to step up wild land protection.
According to the Trust's analysis of the 410 responses received
All 410 responses can be downloaded from the SNH website.
Stuart Brooks, JMT chief executive, said "The scale of support for the map and the eloquence of the responses underline how passionately people value Scotland's wild land.
"We would now urge politicians of all parties to come together to support the map as the next step towards protecting Scotland's world famous wild land from unsightly and ecologically damaging development.
"In particular we would ask the Scottish Government to include a reference to the wild land map in the draft National Planning Framework, which is now being scrutinised by parliamentary committees."
Hundreds of individuals and dozens of not-for-profit organisations, including environmental charities, councils, community groups and national bodies such as sportscotland and Historic Scotland have thrown their weight behind the wild land map.
John Hutchison, JMT Chair, emphasised that the map is about protecting wild land from energy corporations and landowners intent on exploiting for profit.
"As one of the main driving forces campaigning for the map, the John Muir Trust would emphasise that this is not about preventing small scale development of renewable or other infrastructure by communities and local people.
"This is about stopping the mass industrialisation of our wildest landscapes under tangles of turbines, pylons, road and power substations. These developments might generate lavish profits for landowners and distant shareholders, but they create very few if any jobs for local people."
Responses: Total: 410
(All figures have been rounded down to the nearest %, hence the figures add up to 99%).
For the wild land map
Against the wild land map
STOP PRESS: It looks as though our joint campaigning with other NGOs has paid off. Here is the reply to the John Muir Trust from the Planning Minister Derek Mackay, dated April 2014:
Thank you for your letter of 22 January 2014 about wild land and the Proposed National Planning Framework 3. I apologise for not responding sooner. The concern of the Trust centres on ensuring a link is made through the National Planning Framework (NPF3), to Scottish Planning Policy and consequently to other tiers of planning decision making on development that could impact on areas of wild land character.
The Scottish Government has a long-standing commitment to recognising the importance of areas of wild land character and you are aware that Scottish Natural Heritage (SNH) consulted on its 'Core Areas of Wild Land 2013' map at the end of 2013. The analysis of the responses to that consultation was published by SNH on 3rd March 2014.
Scottish Ministers await further advice from SNH as a result of the consultation and will carefully consider that advice in finalising the policy approach. Whilst it would have been premature to refer to wild land in the Proposed NPF3 or SPP position statement in advance of receiving the SNH advice, I can assure you that the final version of both documents will reflect its importance as an environmental asset of national significance.
The period for parliamentary consideration of the Proposed NPF3 has ended and the reports of the four Committees as well as the Official Report of the parliamentary debate have been made available. Scottish Ministers will finalise NPF3 and Scottish Planning Policy having taken account of the findings of the Scottish Parliament.
Finally, I am aware that the John Muir Trust launched a campaign seeking more specific reference to wild land within NPF3. As the matters raised are addressed within this reply, the Scottish Government does not intend to respond to all of the campaign letters individually. I hope that the Trust will make this letter available to its members and those encouraged to take up the campaign.
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