Enhancing Our Care of Scottish Landscapes

The Royal Society of Edinburgh (RSE) is pleased to respond to the Scottish Executive Rural Group consultation on Enhancing Our Care of Scottish Landscapes. These comments have been compiled with the assistance of a number of expert Fellows of the RSE, under the direction of the General Secretary, Professor Gavin McCrone. Landscape (scenery) is given as a major reason for tourists visiting Scotland, and is important for both tourism and for attracting inward investment into a pleasant environment. The proposals, therefore, to tighten the legislation designed to protect (and enhance) Scotlands natural heritage are to be welcomed. One of the key issues with landscape is that people enjoy a diversity of landscape and therefore the question is not just the kinds of landscapes which we want, but also the mix or diversity of landscapes that people want. The specific questions in the consultation paper are now addressed below: Legislative Provisions for National Scenic Areas (NSAs) The proposed purpose and aims of NSA designation We welcome the proposed definition of purpose, which provides a clear statement and objective, and provides continuity by building on the 1978 definition. In terms of the second bullet point, it could be questioned whether a landscape could be enhanced, as a change might be viewed as enhancement by one person and as degradation by another. It would be difficult, therefore, to easily define enhanced. With regard to the proposed aims of the designation, whilst we support the statement recognising the social and economic needs of communities, it may be appropriate to add the words and of the nation to that bullet point. At times the socio-economic needs of a community might differ from those of Scotland as a whole, and Ministers will need to be able to balance competing needs or aspirations. The aims of the designation should also recognise that change cannot always be accepted, and therefore the suggested phrase managing change arising from development should not always be the case. Primacy of protecting the landscape should be recognised, while understanding that many NSAs are dependant on human activity to retain those elements that make them attractive. The proposed powers of designation The power to designate, de-designate (under special circumstances if a site has been damaged) and revise the boundaries of National Scenic Areas is appropriate. However, it would be better if designation and dedesignation decisions were primarily the responsibility of an independent body such as Scottish Natural Heritage (SNH) to recommend to Scottish Ministers, who would be able to make minor changes, but with major changes subject to Parliamentary approval. This would then avoid conflicts between scenic heritage and short-term financial/ political issues. Roles in the designation and review process identified for SNH and local authorities As mentioned above, we recommend that the power to designate and review NSAs should be driven by SNH. Given the intimate linkage between the NSA concept and local authority planning policies, it is essential that local authorities have a leading role in operating the NSA system in practice. However, one of the main reasons why the operation of the NSA designation previously was fairly ineffective was that the controls were not strict enough, and therefore the proposal for SNH to manage change by influence rather than strict control is at variance with this. Many NSAs are important on a national level and therefore the role of driver for this national designation should lie with SNH, with SNH keeping tight control to maintain the integrity of the system and to ensure that standards of management are maintained.

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The need for NSA designation within National Park boundaries It should be remembered that though national parks do include NSAs, National Parks were also recognised as areas under significant visitor pressure. The existence of areas protected for other purposes such as Sites of Special Scientific Interest and National Nature Reserves were seen as helpful as they were managed for their conservation interest and added further heritage. All these things contribute to heritage quality and require formal recognition and therefore the continued existence of NSAs, alongside other land-use designations, should be retained to contribute effectively to the development of planning guidelines or indicative planning strategies within the Park, for example to guide the location of new economic or industrial developments in or close to areas of outstanding landscape and nature conservation value. Management Strategies The preparation and implementation of NSA management strategies Legislation to designate or de-designate is beside the point unless the practical policies applied to designated areas are appropriate. There has to be recognition that some changes and proposed developments will not be acceptable. It is likely that Local Authorities will not have the resources to effectively manage and monitor this initiative without them reviewing their priorities for spending and, although willing, when hard decisions are taken it is (always) the soft targets that will get lost. There should, therefore, be very much more pressure on local authorities and national park authorities to implement NSA management strategies. The suggested voluntary arrangement for supporting and protecting the NSAs is likely to lead to differing standards of protection and place SNH in an invidious position. The roles envisaged for local authorities, SNH, VisitScoltand, Historic Scotland and other local and national stakeholders in the preparation and implementation of management strategies It could be questioned whether the preparation of management strategies for 32 NSAs at an estimated total cost of 1.98 million is good value for money. Alternatively, there could be nationally agreed planning guidelines, together with a technical capacity linked to an understanding of landscape values retained as part of the responsibility of a central unit within SNH. This unit would then be in a position to respond to requests from local planning authorities or other agencies whenever there is a perceived threat to a specific landscape area, rather than being commissioned to maintain an overview for all NSAs in a fairly mechanistic way. Any management strategy assembled under the proposed approach would soon fall out of date and thereby be diminished in practical terms. A small survey team capable of assembling a response to a specific development would be more efficient and effective than the one outlined in the consultation paper, and would avoid the move into more prescriptive or overly mechanistic working methods which remove the necessary elements of discretionary judgement and latitude that are needed for deliberation and decision at central and local government levels. Embedding the new NSA/ landscape proposals in a disciplined way within SNH and allowing a practical overview to emerge using geographical information systems (building upon the SNHs Landscape Character Assessment study) would be the preferred approach. Additional Information In responding to this consultation the Society would like to draw attention to the following Royal Society of Edinburgh responses which are of relevance to this subject: National Scenic Areas Review (April 1999); National Parks (Scotland) Bill (March 2000); Natural Heritage Zones Programme (July 2001). Copies of this response and of the above publications are available from the Policy Officer, Dr Marc Rands (email: mrands@royalsoced.org.uk) and from the RSE web site (www.royalsoced.org.uk).

April 2006

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