This is the joint APRS/ SCNP response on the Addendum to the Environmental Report on the Galloway National Park Proposal. Written February 2025

• The Strategic Environmental Assessment (SEA) for the future of National Parks in Scotland (September 2023) can be viewed here

• The SEA Environmental Report Addendum (December 2024) can be viewed here

Summary

In general we would support the findings of the SEA Environmental Report Addendum. We found it informative and the included maps, showing the suggested options for National Park boundaries and existing designations, very helpful. It seems a valuable assessment given it looks much more to what a new National Park could achieve for the topics covered by the SEA remit. In doing so it places more emphasis on the role a National Park could play in addressing and helping to overcome the area’s challenges (both environmental and socio-economic) and is reasonably aspirational.

Its findings indicate that designating a larger, coherent region as a National Park will bring much greater benefits than a smaller one, but that even a smaller National Park could bring significant improvements. Whereas, in considering the reasonable alternative without a National Park at all (alternative 4), it found the current decline in the environmental trends considered is likely to continue, with adverse or significantly adverse effects on all SEA topics except landscape. Alternative 3 stands out as the best option. Whilst it might be possible to argue that for any appropriate mechanism the larger the area it covered the more it could potentially achieve, that would be to ignore the minimum scale required for a worthwhile strategic role, which a National Park should have. The consideration of alternative 5 which includes a large buffer zone, suggests this would produce a reduction in overall positive impacts.

Further Comments

The Addendum Report considers the likely impact of the 5 alternatives in terms of Biodiversity and Geodiversity; Climate Change; Environmental Quality (encompassing air, soil and water resources); Material Assets; Cultural Heritage; Landscape; and Population and Human Health. In the SEA addendum it was found that a larger National Park area along the lines of Option 3 in the NatureScot Galloway NP Proposal consultation would result in significant positive effects across all the subject areas considered, whereas the ‘Do nothing/no National Park’ scenario would result in negative or significant negative effects in all but one subject area (landscape was considered neutral). A small or medium sized National Park were also expected to produce positive impacts, but to a lesser degree than the larger National Park.

Overall, it seemed that the landscape value of the areas under consideration had been potentially underestimated with a reliance on national designations and less consideration of regionally important landscapes. Conversely we consider that perhaps the negative impacts on landscape of Alternative 4 (no National Park) are underplayed, given the significant cumulative impact of intensifying land uses in the area – such as energy infrastructure and monoculture forestry – that a National Park could be expected to influence and guide to ensure it is conducted with more sensitivity to the landscape.

Population and public health – the wellbeing benefits of designation, and of a wider area were, though recognised, perhaps underestimated given the difficulty of interpretation of SIMD data in rural areas.  There are likely to be pockets of deprivation even in the rural areas seemingly least deprived.  It is recognised that the wellbeing benefits of environmental improvements have more impact on the most deprived.  We wonder if the report underplays the potentially positive impacts of a National Park, and of a larger park extending further west and up towards Girvan. 

Coastal and marine issues – We welcome the highlighting of coastal erosion and flood risk as an expected significant challenge for this area in the future given continuing climate change, and the recognition that National Park designation has the potential to support the implementation of nature-based solutions to this risk, with alternatives 2, 3, and 5 encompassing most of Galloway’s coastal environment. Additionally it is welcome that the report highlights that National Park designation will improve adaptation to climate change through the protection and restoration of natural landscapes such as wetlands, peatlands, and woodlands, which can absorb and slow down water flow, reducing local flood risks, acting as a form of natural flood management.

Further information

SCNP and APRS, have campaigned together for National Parks in Scotland for many years, making the case that Scotland’s beautiful and varied landscapes deserve more recognition and protection. For more information, please contact kat@aprs.scot or 0131 225 7012