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MINISTER PRESSED OVER NATIONAL PARK SHORTCOMINGS

17-07-2002


From: The Chairman, Neil E Rankin CB CBE

Ross Finnie MSP
Minister for the Environment and Rural Development
SEERAD
Pentland House
47 Robb's Loan
EDINBURGH, EH14 1TY

15 July 2002

CAIRNGORMS NATIONAL PARK DRAFT DESIGNATION ORDER

I write on behalf of Scottish Environment LINK's member bodies to urge that you reconsider the provisions proposed by the Scottish Executive for the Cairngorms National Park, as set out in the recently published Draft Designation Order.

A recent meeting of LINK bodies discussed the proposals in detail. They were united in the view that the proposed National Park, if established on the basis of the limited planning powers and reduced area set out in the Draft Designation Order, would:

Fail to meet the intention of the National Parks (Scotland) Act 2000.
Ignore the advice of the Executive's own Reporter, in particular over the boundary.
Fail to meet modern international standards for National Park designation and, as they stand, preclude the possibility of World Heritage Site designation.

The revised boundary alignment is both illogical and arbitrary when measured against the statutory requirement for an area of "coherent identity" and entirely disregards all prior expectations of what the Cairngorms area covers, as recognised by the Cairngorms Partnership and Scottish Natural Heritage.

The proposed planning arrangements, which leave strategic planning and development control in the hands of Local Authorities, could also undermine the purposes of the National Park. Experience has shown that, for a National Park to be successful, strategic planning and development control must be the responsibility of the National Park Authority (NPA). It was for this reason that, 40 years after their establishment, the remaining eight Parks in England and Wales were given independent planning authority, as the Lake District and Peak District had been from the outset. This change was made after extensive analysis revealed the mistake of not adopting this approach (Fit for the Future, Countryside Commission, 1991). While we respect the argument that the operation of Scottish National Parks should be adapted to local conditions, it seems a glaring inconsistency to confer planning powers in the case of Loch Lomond and the Trossachs but to withhold them from the Cairngorms National Park..

Recent experience in Badenoch and Strathspey in particular has already demonstrated that extensive housing developments are being planned throughout the district (in line with the new Highland Council Structure Plan) at the expense of the natural heritage, landscape and local community ambitions. We remain unconvinced that such developments could be controlled or amended by the proposed Cairngorms NPA even were they to be inconsistent with its Park Plan.

As a consequence, we would welcome the opportunity to discuss these crucial issues with you as a matter of urgency, in order to avoid unnecessary delays and controversies that might otherwise arise during the forthcoming designation process. There is a real danger that if the Designation Order is not significantly amended then, instead of being recognized as a world class National Park, the Cairngorms will face international, national and local condemnation and become a source of controversy for years to come.

I look forward to hearing from you.


THIS LETTER IS SUPPORTED BY THE FOLLOWING BODIES:-
Association for the Protection of Rural Scotland
Badenoch and Strathspey Conservation Group
Cairngorms Campaign
Friends of Loch Lomond
Mountaineering Council of Scotland
North East Mountain Trust
Ramblers Association Scotland
RSPB Scotland
Scottish Council for National Parks
Scottish Countryside Activities Council
Scottish Native Woods
Scottish Wildlife Trust
Sustrans Scotland
The National Trust for Scotland
The Woodland Trust
 
CAIRNGORMS CAMPAIGN RESPONSE TO CAIRNGORMS NATIONAL PARK DRAFT DESIGNATION ORDER
GENERAL.

The Cairngorms Campaign has pressed for designation of the Cairngorms as a national park since its inception. The Campaign however concludes that the proposals set out by the Scottish Executive in the Cairngorms National Park Draft Designation Order (May 2002): -

    * fail to meet international standards for national parks
    * fail to meet the requirements of the National Parks Scotland Act 2000
    * severely jeopardise any possibility of establishing the Cairngorms as a World Heritage Site.

In essence, despite an expensive and prolonged consultation exercise that led to clear recommendations from the appointed reporter Scottish Natural Heritage, the Draft Designation Order fails to reflect its advice on the boundary in particular. The weaknesses arising from the reduced area, arbitrary boundary alignment and confused planning arrangements calls into question whether designation should proceed any further if the proposals, as presently drafted, are not to be amended.
ABOUT THE CAIRNGORMS CAMPAIGN.

The Campaign was established in 1996 from its predecessor the Save the Cairngorms Campaign. In the last six years, it has recruited over 1,000 individuals and 20 organisations as members. It aims to stimulate public interest in the future of the Cairngorms area, to promote public appreciation of and care for the beauty and ecology of the Cairngorms area and to encourage all concerned, whether landowners, land occupiers, land management or other users, to foster or participate in active conservation of the Cairngorms area.

It is an independent voluntary body and a registered charity. Its Board members and supporters have accumulated extensive experience of Cairngorms affairs, drawing international commendation for its advice. It has over the years drawn such wide attention by responding to the pressures that have been exerted upon the area and also previously published a manifesto that detailed the measures necessary to address those pressures. The first guiding principle set out in 'Stepping Forward' (1997), was that a strong National Park Authority should be established with appropriate planning and other powers.

SPECIFIC COMMENTS ON THE CAIRNGORMS NATIONAL PARK DESIGNATION, TRANSITIONAL AND CONSEQUENTIAL PROVISIONS (SCOTLAND) ORDER 2002.
ARTICLE 3 DESIGNATION OF NATIONAL PARK.

One of the key requirements of the National Park (Scotland) Act is that designated areas are of 'distinctive character and coherent identity'. This condition is in line with international convention. We understand you have recently been advised to this effect through the recommendations of the Head of the World Commission on Protected Areas, Professor Lawrence Hamilton.

In the case of the Cairngorms, the area proposed in the Draft Designation Order is illogical, unjustified and arbitrary. It falls far short of being of distinctive character and cohesive identity since, inter alia, it eliminates almost half the area recommended by its own reporter. There is little cohesion of identity in the proposed area since:-

    * The present proposals, at best, only represent a "Northern Cairngorms National Park" rather than a true Cairngorms National Park.
    * The boundary actually splits many Cairngorms mountain summits in half.
    * River catchments are divided, impeding integrated catchment management. The proposed Southern boundary alignment excludes some of the most remote and wild mountain landscapes within the UK, a characteristic widely regarded as a key element of the appeal of the Cairngorms landscape as a whole.
    * The proposed Western boundary extends into a separate mountain range (the Monadliath), an alignment that would be logical if it included the whole of the River Spey upper catchment. Since however the planned area eliminates the Laggan and Dalwhinnie area, yet extends into the catchment of the River Dulnain, there is no such coherence.
    * The North Eastern moors of Cromdale and Morven are split in half and Ladder Hills (which have similar moorland characteristics) are eliminated completely.
    * Settlements and communities, which have long been associated with the Cairngorms, are excluded. In particular the elimination of gateway settlements such as Blair Atholl, Dalwhinnie and Laggan discounts the traditional role those settlements have played for those reaching the Cairngorms from the South.
    * The alignment actually splits some communities in half i.e. at Cromdale, Cock Bridge and Dinnet.
    * The boundary line is drawn to include all of Glenshee ski centre but cuts in half the Lecht ski centre.

In conclusion, there is little justification for (i) the reduction in size of the area proposed by Scottish Natural Heritage, (ii) disregard for cohesive areas for integrated management of landscape and wildlife, and (iii) elimination of those communities that have played an active part in the Cairngorms Partnership for the last seven years.

The Cairngorms Campaign recommends that the boundary proposed by SNH be adopted as a minimum with the addition that:-

    * The whole of the upper Spey catchment around Laggan area is included.

ARTICLE 7 PLANNING FUNCTIONS.

The Cairngorms Campaign agrees that the National Park Authority should be responsible for preparation of local plans. However, we strongly disagree with the proposed arrangements for other planning functions, in particular structure planning and development control, which we consider must be the responsibility of the National Park Authority.

The arrangements proposed in the draft Designation Order are completely unacceptable since they:-

    *
      are at distinct odds with arrangements for the Loch Lomond & Trossachs National Park, whilst failing to justify why they are so inconsistent with the solution for that area, even though there are non-sustainable development pressures in both areas.
    *
      do not recognise existing experience from England and Wales, and elsewhere, where it has been demonstrated that full planning powers need be the responsibility of the National Park.
    *
      leave some areas of the National Park more vulnerable than others, for example in Badenoch & Strathspey where the present Structure Plan requires large scale increases in the number of the houses in the area. This is a compelling reason why structure planning must be a function of the National Park rather than Local Authority.
    *
      leave the Local Plan to be shaped by the Structure Plan of surrounding local authorities that have a different brief to that of the NPA, a history of controversial planning decisions and potentially differing strategies from each other.
    *
      lay the ground for confusion, arguments and dissent as applicants for planning permission become confused about respective responsibilities and enforcement of standards.
    *
      provide for inconsistency in the way that development control decisions are made between different local authorities.
    *
      inhibit the National Park Authority from taking a positive pro-active role, rather forcing it into a negative stance of objecting to local authority proposals.


Development control should also be the responsibility of the National Park Authority. That arrangement will:-

    *
      ensure that that those who make policies also implement them on the ground.
    *
      avoid public confusion about where responsibility lies.
    *
      consequently, streamline the system for dealing with applications.
    *
      afford the opportunity to Board members (including those directly elected) to shape the environment they are responsible for, as is the case in Loch Lomond & the Trossachs.
    *
      ensure consistency in standards across the Park and better cohesion in decision making.

The Cairngorms Campaign recommends that the solution to these issues is to grant full planning powers to the National Park Authority. One possibility could be to subsume local plan provisions within a single tier development plan, to be the responsibility of the National Park Authority. That development plan would be both a local plan and structure plan as currently being considered for those local authorities within Scotland beyond the four city regions.
ADDITIONAL CONSIDERATIONS - WORLD HERITAGE SITE DESIGNATION.

Since 1991, the Cairngorms have been proposed as a potential World Heritage Site. World Heritage designation would provide long term unsurpassed economic and environmental advantages to the area.

A strong and effective National Park Authority is vital if the Cairngorms are to have a serious possibility of designation since integrated planning and management arrangements are a key requirement of such designation.

Integrated planning and management requirements for WHS designation also dictate that full planning powers and an extensive boundary such as that proposed by the Executive's own reporter, SNH, must be implemented.

The Cairngorms Campaign recommends that measures be taken to ensure that the Designation Order for the Cairngorms National Park is fully consistent with the proposal for the area to become a World Heritage Site at the earliest opportunity.

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