www.ramblers.org.uk

ENHANCING OUR CARE OF SCOTLAND’S LANDSCAPES

Response from Ramblers Scotland

April 2006
 

Scottish Executive Consultation Document on National Scenic Areas

INTRODUCTION

The Ramblers' Association Scotland welcomes the opportunity to respond to this consultation and appreciates the involvement of stakeholders in the process. We are pleased that the Scottish Executive is making serious efforts to integrate outdoor recreation into its rural development work.

The Ramblers' Association Scotland is the representative body for walkers and aims to:

  • Promote walking for health and pleasure;
  • Secure public access to land;
  • Develop path networks;
  • Protect the outdoor environment.

GENERAL COMMENTS

RA Scotland very much welcomes the opportunity to comment on the proposals set out in the consultation paper.

Our landscape is one of our greatest assets – valued by visitors and locals alike. We should not see landscape as some sort of impediment but as an opportunity in terms of economy and quality of life. We support the Executive’s proposals for introducing provisions for NSAs.

That said we would urge the Executive, in the longer term, to extend its attention to the landscape more widely. Scotland’s landscape is not just about the really special, really wild places, though that is part of the picture. It is also about local landscapes with their local significance – culturally and emotionally, for a sense of place and for their important contribution to peoples’ quality of life and recreational enjoyment.

In addition “Wildland” as a concept needs to be built into policies and strategies. We see protection of such “wild” qualities coming through integration of the concept within plans and policies rather than through designation of areas.

Generally, we need to demonstrate how landscape touches our everyday lives and why it is important to the people of Scotland. The UK signing of the European Landscape Convention must give added impetus to work to care for our landscape.

We are concerned that the NSA system alone cannot meet the challenge to Scotland’s landscape presented by development pressure such as renewable energy developments. We believe that landscape value needs to be built into policies much more widely if we are to develop a coherent and sustainable approach to our energy requirements. This is particularly important now the UK government has signed the European Landscape Convention.

FURTHER COMMENTS

STATUTORY PURPOSE FOR NSAs

We support the proposal to introduce a definition of purpose for NSAs, along with clear criteria for designating such areas.

We believe that the second bullet should be amended – replace “scenic beauty” with “landscape quality”. The second term is, we feel, more able to encompass what is intended – the former being more restrictive. This would make a strong link with the definition within the European Landscape Convention for “landscape quality objectives” bringing in the aspirations of the public with regard to landscape features and their surroundings.

We are not sure what is meant by “enhanced” in this context – this is potentially open to interpretation. Our worry would be that it might tend to put an emphasis on highly managed landscapes and reduce “wildness”. We feel this word should be removed.

In the third bullet point, on the proposed aims, we consider that the phrase “whilst recognising the social and economic needs of communities” is unhelpful. We consider that this phrase should be removed or it should be made clear that in any conflict the landscape qualities would have primacy over any other interest.

We welcome in 3.6 the inclusion of adjoining areas of sea, as these are such an important aspect of the Scottish landscape.

Where there is a conflict in decision making greater weight should be given, as in national parks, to the natural / national heritage.

DESIGNATION OF NSAs

We support the proposal that both SNH and local authorities can bring forward proposals for NSAs. Local authorities should involve SNH at an early stage in developing their proposals.

We agree that there should be provision for varying boundaries where there are good grounds for doing so.

With any new designation or de-designation there must be an opportunity for public comment.

3.11 makes a negative reference to there not being any new obligation on local authorities to enhance or prevent deterioration of character. We believe that there should be a clear statement that positive action is encouraged to safeguard and enhance these areas.

NSAs AND NATIONAL PARKS

NSAs should be retained within national parks, in the same way that SSSI and NNR status is retained.

The aims of National Parks and NSAs will not always concur, as the two designations do not seek to achieve the same purpose. NSAs are likely to give greater protection to landscape than our existing national parks. We do not therefore consider that NSAs should be de-designated within national parks.

One option which would enable the development of a park wide approach to landscape protection would be to extend the NSA boundaries to encompass the whole national park area.

MANAGEMENT STRATEGIES

We consider that there should be a statutory requirement on local authorities to produce a management strategy for each NSA. It will not be enough to merely “encourage” this – we believe it is essential that a duty be placed on local authorities to carry out this work. In the absence of such a duty it is unlikely that they will be in place within five years as the consultation paper suggests.

Sufficient funding will be essential to ensure local authorities will be able to develop these strategies. While the Executive or local authorities may not favour ring fencing of such funding we recommend that there should be an administrative mechanism that ensures this funding is directed to the right work area. This might involve challenge funding or routeing the funding through another organisation (perhaps SNH). Clearly the potential financial implications are considerably more for some local authorities than others. There will also be resource implications for other organisations engaged in the process.

The reasoning behind the proposed review period of 7 years is not clear. A 5-year period, as with the development plan cycle, would seem more logical.

We broadly support the proposed five key components for management strategies. The pilot work done on this topic in Dumfries and Galloway has been very useful in this regard.

In 4.7 there may need to be more than encouragement to engage the involvement of visitscotland and Historic Scotland. The Forestry Commission, SEERAD and sportscotland should also be involved. We recommend that the legislation require the engagement of these bodies.

Conclusion

Ramblers Scotland support plans for NSAs. We believe that they have an important role to play in safeguarding our valuable landscapes and their important environmental, economic, social, cultural and spiritual value. The proposals are necessary but will not tackle all the issues around landscape in Scotland. There will be a need for wider measures to build landscape into wider policies..