WILD LAND & NATIONAL PLANNING FRAMEWORK 3

Dave Windle

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.

Q1 What is your view on the Core Areas of Wild Land 2013 map?

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".

Q2 Do you have specific comments on any of the areas of wild land identified?

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.

Q3 Are there any other issues regarding the Core Areas of Wild Land 2013 map, or its preparation, that you would like to raise?

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.

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:

Overwhelming public support for wild land map

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

• 80% back the wild land map
• 14% oppose the map
• 6% are neutral

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."

Background Notes Responses: Total: 410 For: 329 (80%) Against: 59 (14%) Neutral: 22 (5%) (All figures have been rounded down to the nearest %, hence the figures add up to 99%). Breakdown: For the wild land map 264 individuals 55 not-for-profit organisations (including over 20 environmental and outdoor charities; 5 national government agencies including sportscotland, Historic Scotland and Forestry Commission Scotland; 6 local authorities; and an assortment of community councils, campaign groups, park authorities and academic institutions). 10 businesses (mainly small businesses in the environment and tourist sector; plus the Speyside Business Alliance, a consortium mainly of distillers, and 4 estates). Against the wild land map 9 individuals 40 businesses (27 energy corporations, plus 11 property developers, landowners and representative bodies such as Scottish Land and Estates, and the Scottish Property Federation). 10 not-for-profit organisations

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:

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