This is the final APRS and SCNP joint response to the NatureScot full technical consultation on the proposal for a Galloway National Park.

The full consultation document is on the NatureScot website here.  

Further information on the consultation from NatureScot can be found here.

The deadline for responses is 14th February 2025

Gauging support for the proposal and alternative to it

Q1a To what extent do you support the idea of a new National Park being established in the south west of Scotland?

1. Strongly support 

Q1b Please tell us the main reason(s) for your opinion.

Historically the area of Galloway and Southern Ayrshire in southwest Scotland has been specifically identified as worthy of more attention for its natural beauty, diverse landscape and rich natural and cultural heritage from the 1940s onwards. This is documented in “Unfinished Business” (SCNP & APRS, 2013). The management strategies produced by Dumfries and Galloway Council for the three National Scenic Areas in the early 2000s all highlighted that the special landscape qualities of the area and the potential benefits of better management extended beyond the existing boundaries (see https://www.dumfriesandgalloway.gov.uk/publications/national-scenic-area-management-strategies, management strategies for Nith Estuary NSA, East Stewartry NSA and Fleet Valley NSA).  

The Scottish Government expects a new National Park in Galloway to contribute to its key priorities of growing the economy, tackling the climate emergency and improving public services.  It should deliver environmental benefits alongside economic growth and progressive land use, including renewable energy, agriculture and forestry. It should support the visitor economy and have a positive impact on people’s social, mental and physical health. It is recognised that the Galloway area and southwest Scotland more widely are under intense pressure for land use change in multiple ways including commercial afforestation, energy developments and agricultural intensification, which will need to be carefully planned and managed to ensure that this doesn’t damage the natural beauty and heritage value of the area. A National Park could bring that much-needed focus on integrated land management and natural capital approaches and, in doing so, help address the climate and biodiversity emergency. We strongly advocate that addressing climate change is not just about new energy infrastructure – there are important roles in nature restoration, carbon sequestration, water management and sustainable transport and sustainable housing that a National Park would help drive forward.

Establishing a National Park to manage the area for the longer-term would allow for better Park-wide planning and much needed increased resources and investment in the area. In doing so, it would bring new jobs to the area through direct employment in the Park Authority itself. It should also contribute to economic development more generally, for example through employment in nature restoration, climate mitigation and adaptation projects, as well through new opportunities for nature-based and sustainable tourism.  There is an opportunity to further build on existing recreational opportunities in the area, which overall adds further carrying capacity for visitors, so long as there is the appropriate planning and management that a National Park could help co-ordinate and provide.

There is potential for a considerable marine element to this new National Park, which would be a legislated first for the UK and increase the attention given to marine conservation and restoration, the blue economy, coastal/marine recreation and helping to address the impacts of climate change on the marine and coastal environments. Some of our most important habitats and the pressures across land, coast and sea can only be managed by considering ecosystems together.

A new National Park would put southwest Scotland ‘on the map’, reinforcing the international profile that it already enjoys as a UNESCO Biosphere, and would highlight and help protect the region’s wealth of natural capital and cultural assets.

The focus and resources a National Park would bring would help to reconcile the sometimes-conflicting demands on its land (and recognise the high degree of multiple pressures for land use change in the area). At the same time it would support resilience in local communities, business and enterprise, which is especially needed, given the current economic and demographic issues facing the area. It would strengthen the tourist offer in the area and generate new resources within the local economy.

Support for a new National Park 

We note the positive impacts of the two current National Parks in working to achieve the four statutory aims of Scottish National Parks collectively and in principle we’d support the four aims being applied more widely. Given that the aims collectively cover the conservation and enhancement of natural and cultural heritage, promotion of the sustainable use of natural resources, promotion of understanding and enjoyment (including recreation) and the promotion of sustainable economic and social development of the area’s communities it is perhaps harder to say where in Scotland you would chose not to apply them.  It is well documented that there is a high level of support from the Scottish public for the creation of more National Parks, with a poll undertaken in 2022, and published in 2023, finding that 89% of the Scottish Public supported the creation of one or more new National Parks in Scotland, with 44% strongly supporting and 45% tending to support the proposal. Only 3% opposed the suggestion while 8% didn’t know (NatureScot Research Report 1335 – NatureScot Opinion Survey 2022). Further polling carried out by Survation for Scottish Environment Link in 2022 found that 78% of the Scottish public agreed that the overarching purpose of National Parks should be focused on nature recovery and tackling climate change with only 3% disagreeing (Attitudes to Nature  – opinion poll. https://www.scotlink.org/wp-content/uploads/2023/01/Scottish-Environment-Link-Summary-Document-updated.pdf).

Ensuring that each of the four National Park aims are collectively achieved in a co-ordinated way, would mean that conservation of the natural and cultural heritage continues to underpin the economic, social and recreational value of the new National Park over the long-term.

There is scope for the new National Park to lead a process that would tease out and help to implement the findings of and recommended actions arising from the pilot Regional Land Use Framework prepared for the south of Scotland. Similarly it could begin translating into practical action the region’s identification as Scotland’s Natural Capital Innovation Zone.

If the Scottish Government introduces amendments to the National Parks (Scotland) Act in the forthcoming Natural Environment Bill which (as consulted on in 2022) put a stronger duty on public bodies to deliver the aims of the National Parks and to engage with and seek to implement the National Park Partnership Plans, the positive impacts of a National Park for nature and climate and communities could begin to be delivered even more quickly and effectively.

The current proposal offers a chance to bring wider benefits  – environmental, social and economic – and to speed up the shift to a greener more diverse economy across an area with very different characteristics to the two existing Scottish National Parks. However, a new Park could build on the two decades of experience of the existing Parks and learn from that – eg the importance of planning for sustainable transport from the start, and the need to stimulate the availability of affordable and social housing. The Galloway proposal offers the opportunity to have a very different National Park for Scotland – in the South, with a different landscape of hills, rich farmland and an extensive, beautiful coastline and a clear connection to the marine environment. 

Further details on the potential socio-economic benefits of a new National Park in Galloway, and the particular circumstances of the region beyond the common features of rurality shared with other parts of rural Scotland are described in the 2019 report by SCNP and APRS “The potential socio-economic impacts of a new National Park for Galloway”.

Q2a Are there any alternatives to a National Park in Galloway that you would support?

No.

Please explain your answer.

None of the alternatives presented in the proposal consultation come with the additional and long-term certainty of funding from Scottish Government that National Park designation would bring. Furthermore, whilst the special natural and cultural heritage qualities of the region are already acknowledged globally through its status as a UNESCO Biosphere, none of the alternatives now on offer would confer the additional benefits of the internationally recognised National Park brand. Neither would they have the functions and powers or governance arrangements or the policy status that a National Park could bring. Indeed, closely integrated management of the area as a dual National Park and Biosphere, even if the two designations were not exactly co-terminous, would represent a real first for Scotland and would help to harness the enthusiasm for both approaches that exists world-wide.

Given the environmental and economic challenges of the area there is a strong case for building upon the strong foundations already established by the Galloway and Southern Ayrshire Biosphere in this way. Likewise, the trail-blazing management strategies prepared for the three National Scenic Areas (NSAs) in the region have not had the follow-through in terms of practical action that they deserved. The National Forest Park is on its own far too small to provide the range of visitor experience and opportunities needed and the scale of change required. Much of the region’s landscape and heritage interest lies outwith its boundaries and as of now it even lacks a single, coherent management plan. There are the makings in all these separate initiatives of something powerful and potentially capable of transforming the region’s fortunes, and making it an example of sustainable land use and development for others to follow. But it requires the co-ordinating leadership and impetus that a National Park could bring.

We can’t see how any of the alternatives suggested can deliver as much and as cohesively for the long-term. This is in part based on previous experience in Scotland, not least in the long run-up to the designation of the two existing National Parks. In both cases, a sequence of different designations (including Regional and National Forest Parks), reviews (eg a Park System for Scotland, 1974 and the Mountain Areas of Scotland report ) and coordinating  organisations (eg the Cairngorms Partnership and HIDB) all over time, led step-by-step to the recognition of the need for a National Park with legislative backing, a broad remit, and central government funding, in order to address natural and cultural heritage, recreational interests, environmental and social concerns all together.  We have concerns that any initiative or organisation without the legislative aims and powers and broad recognition of a National Park will simply not be equipped to deliver the hoped-for improvements for people, nature and climate. On the other hand a National Park could in our view very much help to deliver other aspirations for the region and indeed the south of Scotland more widely, such as the Natural Capital Innovation Zone.

As indicated above, however, we do see it as vital to build on the existing designations and not to lose the benefits of Biosphere designation, including strong community links, a focus on environmentally sustainable development and a collaborative approach. As the two designations are most unlikely to have the same boundary, it is vital that the National Park and Biosphere complement each other and work together in a closely integrated way. This will provide a sound platform for a new National Park to build upon.

Scottish National Parks are considered to be “category V” protected landscape or seascape in the IUCN classification of protected areas. They already accommodate a far greater degree of socio-economic development than other National Parks in many countries, which are considered “category II“ and have protecting functioning ecosystems as their primary objective. So whilst National Park designation rightly brings with it a greater emphasis on natural and cultural heritage (and hence on enhancing biodiversity), this is not the only aim of the Scottish designation. While there would be benefits for the environment and for people if the focus on biodiversity and climate of Scotland’s National Parks was strengthened via future legislative change, we would expect the social and economic aims of Scottish National Parks to be retained too.

Q2b What are the advantages of your preferred alternative(s) over a National Park?

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Area of the proposed National Park: Possible options for the National Park area

Q3a If a National Park was to be designated, which of the three options presented in Map 4-1 and Table 4-1 would you support?

We are generally supportive of the largest of the options (option 3 – ‘Hills, coast and countryside’) presented, but see our more detailed comments below at 3b and 3c.

Q3b Please give your reasons.

In principle, we prefer the largest of the options proposed to enable the National Park to play the strategic role in guiding future land use that is required in an area facing so many pressures and challenges. Something like option 3 would enable the National Park to play the leadership role envisaged in relation to delivering a just transition and nature recovery at scale, as well as to boost the economic fortunes of the region’s most deprived communities (which tend to lie to the west and north). Thus option 3 gives greater opportunity for a National Park to address the social and economic needs of the area which includes some of the 20% most deprived data zones in Scotland  (see Scottish Index of Multiple Deprivation).

The area included within the boundary should encompass the full range of diverse natural and cultural heritage interests – this diversity of landscapes and habitats being a key reason for selecting Galloway as a potential third National Park. It should include the region’s most significant natural and cultural assets from the Galloway Hills to the Carrick, Irish Sea and Solway coasts. The area covered should be large and coherent enough for the Park Partnership Plan, and its delivery, to have a meaningful strategic function, and to reflect the interdependence of town and country within Scotland’s rural southwest. The larger area also allows for a more proactive approach to spreading benefits and mitigating possible impacts of increased tourism.

The Scottish Government report, “Scottish new National Parks – phase 2 – strategic environmental assessment (SEA): SEA reasonable alternatives that was published in December 2024 clearly identifies that the environmental benefits of designating a larger area as a National Park such as option 3 are predicted to be far greater than those of designating a smaller area, or of retaining the status quo of no National Park. We feel that the much smaller ‘option 1’ will not achieve the desired landscape scale of change and also excludes much of two of the NSAs.

While designating a smaller (option 1 or 2) National Park would still have benefits, albeit fewer than a larger National Park, prior experience (not least in the Cairngorms), has shown that once National Parks are created there tends to be a strong drive from local communities to seek inclusion through expanded boundaries, potentially leading to further changes later. Furthermore, a larger scale National Park gives stronger justification for the scale of resources (notably professional expertise of various kinds) required for any National Park to successfully play the crucial strategic role across its collective aims that is needed.

In the 2013 report “Unfinished Business” published by SCNP and APRS, paragraph 5.13 described the potential for a National Park in Galloway:

“Any National Park in Galloway would preferably bring together the National Forest Park and the three NSAs, and could also incorporate an additional marine component in the Solway Firth. The three NSAs incorporate a rich variety of dynamic coastal scenery, including extensive estuaries and mudflats and several distinctive islands, with views south to the Cumbrian fells. There is a gradual transition from the coastline through well-wooded farming landscape with many traditional features including fields, dykes and hedges to the upland hills. The National Forest Park includes the Merrick, the highest mountain in southern Scotland, and has more recently acquired reputations for mountain biking trails and the quality of the stargazing allowed by its dark skies. This diversity makes Galloway an outstanding example of the type of fine landscapes that Scotland has to offer beyond its classic and best-known Highland scenery.”

Q3c Do you have comments on the extent of the area in your preferred option? Would you add or remove particular areas, features or settlements to make the option smaller or larger? And if so, why?

Whilst our preferred option is along the lines of option 3 we have the following comments, some of which suggest that potential amendments could be considered.

We can see good arguments given the spectacular coastline scenery and importance for biodiversity (including seabirds and migratory birds) for the inclusion of the Mull of Galloway and the Machars (and Whithorn) as proposed in options 2 and 3. Including consideration of cultural heritage too strengthens the case further.

Whilst we recognise that there are some parts of the area under consideration in option 3 that may not merit National Park status on landscape grounds alone (eg the extensive windfarm areas on the Wigtownshire Moors south of the Stinchar valley and west of the A714; and areas in the hinterland of the Rhins under intensive dairy farm management) their inclusion should still be considered if it makes more strategic sense and with an awareness that more sensitive future management is possible and that environmental enhancement of 21^st century landscapes and habitats should be very much the goal. 

Some of the uncertainty about the inclusion, or not, of areas with large windfarms comes from the Scottish Government having stated that it will develop bespoke planning guidance for new National Parks with regard to wind farms, but not yet intimated what this will say. The extent to which the Wigtownshire moors should be considered for inclusion might depend on precisely how that policy guidance is phrased. However, because of the size and long-distance visibility of modern turbines, it is essential that wind farm development both within and in the vicinity of an National Park is exemplary in its sensitivity to landscape and other environmental impacts.

We would support the inclusion of the Nith Estuary NSA, with Caerlaverock as an obvious visitor gateway, and the inclusion of the area around Threave Gardens and Nature Reserve and Threave Castle which respectively are excluded from option 1, and options 1 and 2. 

Based on quality of the landscape, there are arguments for including more of the headwater valleys in Dumfriesshire (along and to the north of the A702), up to the spine of the Southern Uplands (but probably excluding the windfarms on the watershed itself). It might be worth considering including more ground to the east of New Galloway, including perhaps the whole River Urr catchment?

Whilst it might be possible to exclude “gateway” communities such as Girvan and Dalmellington, and possibly even Stranraer, and rely on Biosphere designation for them, (especially if the two designations were tightly integrated, with a planning regime that reflected that symbiosis), on balance we would much prefer their inclusion so that the new NPA is better able to work with and influence the gateways.

We think that giving consideration to maps of multiple deprivation is a helpful pointer as to where there is greatest need and merit in potentially broadening the economy with more diverse and ‘greener’ jobs and improving wellbeing. For the smallest option (option 1) we note that it excludes many of the areas most in need of such a boost (eg coastal areas to the west and north).

We note that the consultation document indicates that the coastal boundary could be set at the Mean Low Water Spring (MLWS) mark as suggested by the Galloway NPA Bid document. Given the four aims of Scottish National Parks and the potential to encompass marine areas in the legislation, we see no reason why the coastal boundary couldn’t extend further into the marine environment. This is given weight by the number of national and international designations for both natural heritage and landscape that extend further into the sea, as does the extent of the Biosphere.

We note the consideration of alternative proposals for a National Park boundary in Galloway and reasonable alternatives to the creation of a National Park in the area at all presented in the Scottish Government’s “Strategic Environmental Assessment (SEA) for the future of National Parks in Scotland. SEA Environmental Report Addendum” December 2024. The 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 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..

Q4 Is there another option for the area of the proposed National Park which should be considered? If so, what do you suggest and why?

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Q5a Looking at the description of the options presented in Table 4-1, do you think they meet the legislative conditions for designation?

a) the area is of outstanding national importance because of its natural heritage or its combination of natural and cultural heritage

Yes/Partially/No

Why?

1. Yes. Yes overall, despite recognising a degree of patchiness of quality inevitable in such an extensive area. The combination of cultural and natural interest is very important. Also the sheer diversity of interest and the range of challenges makes the area an excellent testbed for developing responses to the nature and climate crises.

b) that the area has a distinctive character and coherent identity

Yes/Partially/No

Why?

2. Yes, the area has its own historic identity and personality, even if the boundaries of this are hard to pin down exactly.

c) that designating the area a National Park would meet special needs of the area and would be the best means of ensuring that the aims of the National Park are achieved in a co-ordinated way.

Yes/Partially/No

Why?

3. Yes, above all because the region is currently and prospectively subject to the most intense pressure for large-scale land use change (afforestation, agricultural intensification, renewable energy development) anywhere in rural Scotland. This process desperately requires steering in a direction that maintains and if possible enhances its remarkable and under-appreciated qualities. The economy also very badly needs a boost and local communities want more say in the way that the area evolves. A National Park can both “put the area on the map”, protect and enhance its existing heritage and bring people together to help shape its future.

The anticipated environmental benefits of creating a National Park in Galloway are described in the Scottish Government’s “Strategic Environmental Assessment (SEA) for the future of National Parks in Scotland. SEA Environmental Report Addendum” December 2024.

Q5b Do you have any additional comments on Table 4-1 which might be relevant to the consideration of the geographic area?

The quality and interest of the settlements (from clachans and villages to market towns) makes a much more significant contribution to the quality of the environment than in the existing Scottish National Parks (and makes the area in that respect more akin to some of the National Parks south of the border). This is relevant both to the choice of area for designation and to its future management, including potentially the powers required.

On points specifically raised in Table 4-1, we consider that:

•  The communities of Dalmellington and Straiton should be included,

• The inclusion of Cairnsmore of Carsphairn (the most northerly of the local Corbett hills) should be considered,
• On balance we would include the countryside of the Machairs and Rhins in addition to the coast (although there is some very intensive agriculture in places, there is also much attractive and interesting countryside, with a distinct “away from it all” atmosphere. Within the context of a large Park it could and would largely retain its distinctive feel but with the benefit of some extra amenities which would be at least as much to locals’ advantage as to that of visitors).
• Girvan should be included in the National Park, but possibly not all of the moorland to the south of it,
• The Nith Estuary National Scenic Area (NSA) and the coastal uplands (Criffel) should be included.

Boundary considerations

Q6a Do these principles provide a reasonable basis for drawing up a detailed National Park boundary for the area?

Yes, generally. However, the “easily distinguishable” feature of the first one would seem more difficult to apply in the marine sphere if interpreted as meaning easily visually distinguishable.

Q6b Do you have any suggestions for changes to these principles which would be specifically required for drawing up a boundary for a National Park in this part of Scotland?

As referred to in the previous answer a critical issue not addressed in the consultation questions is the drawing of a coastal boundary. Whilst MLWS is tentatively put forward, this is not fully explained given the range of boundaries in place for existing designations (see the Scottish Government’s amended SEA, December 2024). A justification might be that a low water mark is where a local authority’s administrative boundaries extend, though in a small number of cases in Scotland, a local government area has been extended by legislation around a port or harbour into the surrounding sea beyond the low water mark. 

Selecting the MLWS mark also sits uncomfortably with the three NSA boundaries which extend further out and it seems hard to say why those boundaries might not be matched by that of a National Park. The marine boundaries of other designations could also be considered for application within the new National Park, for example the Solway Firth SPA. A report published by BMF proposes being ambitious on boundaries and taking opportunities to unite the land and sea and bring more cohesion. Whilst designation requires a mapped boundary, in practice fuzzy ‘Management’ boundaries often do a good job for the vast majority of interests and an NPA should be able to engage with marine issues beyond the low water mark that affect the coast.

More generally (and relating to powers and functions rather than boundaries per se) it is desirable that the operations of the Park Authority are not rigidly restricted to its territory, except where this cannot be avoided as a result of statutorily prescribed geographical limits to its legal powers. This would give the National Park the potential to engage on or influence some activities beyond its boundary, especially where those activities have an impact within the National Park. If a new National Park is set up so as to be able to work “hand in glove” with the Biosphere, which covers some adjoining areas (and extends into the marine environment) this should help deliver this.

Functions and powers of the proposed National Park Authority

Q7 Are there any further existing functions and powers from recent legislation that would be beneficial for this Park Authority to be able to draw on and why?

A new National Park should be involved in the further development of Regional Land Use Frameworks and the role that these might play in targeting future public support for agriculture and forestry and potentially private “green finance” and the deployment of nature-based solutions in tackling environmental challenges. This could be linked to the development of the Park Plan for the whole National Park area.

A new National Park with an extensive coastline and including, or adjacent to marine areas, should have a key consultee role in marine planning processes. We note that the National Parks (Scotland) Act 2000 predates the Marine (Scotland) Act 2010 which set up a comprehensive system of marine planning that so far has not been put fully into action.  The National Marine Plan is undergoing its first full review and as a consequence the Regional Marine Plans have been shelved for the moment.  However, there is one planned for the Solway or at least for the northern part of the Firth (with the English Marine Management Authority preparing the south section covering an area which stretches to the Dee Estuary at the Welsh border).  The intention was for full co-operation on this but the timescales are now different.  Ideally proper planning of the Firths would cover the whole rather than parts of them.

Although perhaps less relevant in Galloway, given the smaller average size of land holdings compared with those in the existing National Parks, there is a question as to how far a Park Authority should have a role in implementing any new requirements on landowners and managers arising from proposed land reform legislation (eg scrutiny and approval of management plans). Even if they were not the final arbiter, commenting on (and ideally providing expertise and guidance on) proposed management regimes might be an obvious function. 

In relation to the Agricultural and Rural Communities Act, National Parks should play an active and influential role in designing, targeting and monitoring the effects of future land use support programmes, even if not directly administering them.

Although not strictly an existing power or function, we hope that the forthcoming Natural Environment Bill will contain amendments to the existing National Parks legislation that introduce stronger duties on other public bodies to contribute to the implementation of National Park Plans and to further their aims.

Q8a Do you agree with the need for a bespoke approach suggested for the planning function for a National Park authority in Galloway?

No/Maybe/Yes 

Q8b Looking at the possible options in Box 5-2, how do you think this should work in practice?

We do not feel that options a or b in Box 5-2 would be effective and that it is essential that the NPA is responsible for development planning (as a minimum), so that the Local Development Plan (LDP) for the area is consistent with the Park Plan. The local authorities will have priorities beyond the National Park area. Not being the planning authority would reduce the Park’s ability to tackle some issues at scale. Our preference is for a new NPA to have full planning powers, given our reservations (see discussion below) about the alternatives suggested.

The relationship between the Park Plan and the Development Plan must be clear – after extensive consultation, the National Park Plan will set out the vision for the National Park and all public bodies are obliged to take account of it where their work affects the National Park. However, the LDP together with NPF4, turns this vision into policies and guidance for development within the Park, and specifically should give more certainty to the private sector over development proposals.

Both the Park Plan and the LDP are essential for the National Park to deliver on the aims set out in the National Parks (Scotland) Act. They should in effect be the opposite sides of the same coin to create the kind of co-ordinated approach that is needed. It is important to recognise that while the Councils in the Cairngorms deal with Planning Applications they are dealt with under the terms of the Local Development Plan, prepared and agreed by the National Park Authority.  Given the number of households within the larger areas considered in the Galloway proposal, especially if all of the larger settlements are included, a bespoke approach like that in Cairngorms might also be workable.  This would be a combination of  c) and e) from box 5-2, but where the NPA had full responsibility for the development plan and had staff with expertise in development management as well as other specialist staff including ecologists.  A call-in arrangement, similar to the Cairngorms, is seen to have the advantage of avoiding getting the NPA bogged down in too much minor casework of little relevance to Park objectives, but there could be potential for a call-in regime to generate friction between the NPA and the local authorities.

A more bespoke “partnership” arrangement is sometimes suggested as a way of keeping down overall cost, although to make such an arrangement effective the NPA would still need planning expertise in order to engage effectively, potentially with multiple local authorities over multiple LDP development processes.

We recognise that the planning system has evolved with the adoption of NPF4 and its incorporation into Development Plans across Scotland which should guide local authorities on protecting the natural and cultural assets of any National Park.  However, that does hinge on the interpretation of NPF4 policy 4c) in each decision. Policy 4c) refers to “the objectives of designation and the overall integrity of the areas” but does not specifically refer to the National Park principle – which in cases of conflict between the National Park aims says greater weight should be given to the first National Park aim which focuses on conservation and enhancement of the natural and cultural heritage. So there is a question as to whether NPF4 could be a strong enough framework for an effective partnership approach.

Not being the planning authority has specific disadvantages in addition to not being in control of giving guidance and adjusting local policy. It would mean, for example, that the NPA would not have direct control over short term let control areas, nor would it be able to prepare masterplans which can then be approved formally with the intention of speeding up the development process. Also potentially negatively, it would not be able to engage as the planning authority with communities preparing their Local Place Plans, which would be somewhat ironic given that early versions of these were developed in the Trossachs largely supported by LL&T NPA before being incorporated into the Scottish planning system.

The work done by both existing Scottish National Parks on affordable housing has relied heavily on the Park’s planning powers to ensure the flow of sites, and the proportion of affordable housing in new build can be properly controlled; only as a planning authority would the new NPA have the ability to set targets above those in NPF4.

If the NPA is not the planning authority it will be relatively powerless if it turned out that local authorities have different priorities – whether that may be for example focusing on areas beyond the park boundary or a LA preferring high value housing (more Council Tax, less need for schools, etc.) when local people including workers and young folk within the Park, need a higher percentage of ‘affordable’ housing.

The suggestion of an option for the NPA to produce LDPs in partnership with the local authorities, suggests that the NPA would have to have staff potentially involved with three different plan processes all operating on different timescales.  There would be implications for staffing levels (potentially duplicating roles in LAs but with no guarantee that the LDPs would align with the Park Plan). There would also be concerns over the three local authorities having different timetables for reviewing their LDPs and that these may not be in ‘sync’ with the Park Plan which could add potential complications and delay to the process.

In exercising its functions, a National Park Authority adheres to section 9(6) of the National Parks (Scotland) Act 2000, this is the so-called Sandford or National Park principle. The principle clarifies that whilst the statutory aims should be achieved collectively and in a co-ordinated way, if it appears to the authority that there is a conflict between the first aim (to conserve and enhance the natural and cultural heritage of the area) and the other aims the authority must give greater weight to the first aim. How is this achieved in planning decisions if the NPA is not the planning authority?

Whichever scenario is selected, the Park needs a strong strategic role, which might be reflected in the Park Plan playing (for its area) the role in the planning system envisaged for Regional Spatial Strategies. To back this up (and to support local authorities who may no longer employ staff with this full range of skills) we support the idea of the Park employing not only landscape, ecology and built heritage professionals but also qualified planners. These could be attractive posts for talented, younger members of the relevant professions.

Q8c What alternatives should be considered and why?

We feel that the NPA should EITHER be a full planning authority with responsibility for development planning, development management and enforcement within the National Park boundary (ie option a under the Act) OR operate under a bespoke arrangement similar to the call-in system operated in the Cairngorms National Park (a combination of options b and c under the Act). In the latter case the NPA would have responsibility for development planning and  the ability to call-in significant planning cases. 

All existing UK NPAs are planning authorities, and as stated in the consultation document a mechanism to prevent significant negative impacts of development and land use proposals is a requirement of park status. Historically National Parks in the rest of the UK were found to be less effective when they were not planning authorities, leading to changes starting under the Local Government Act 1972, that gave all National Parks in England and Wales full planning powers.

Being the planning authority gives the NPA a degree of clout and past experience in National Parks demonstrates conclusively that landowners and land managers are more likely to engage with the National Park if the NPA has planning powers.  This can be a two-way benefit resulting in improving the standard of applications and, with Park staff better understanding a business’s operations, they can be in a better position to deal effectively with any planning applications.

Being the planning authority (whether full or on a call-in basis) would enable the NPA to have a role for the NPA planning team (and others in the Park Authority) in helping local communities prepare Local Place Plans to feed into the higher level documents and ambitions.

As we feel that the NPA should be the access authority we also feel it should have responsibility for Rights of Way which are usually dealt with by planning authorities.

If the “call-in” option is chosen it should be noted that the skills needed for development management are different to those of other planning specialities (for example it is necessary to be fully up to speed with the ever changing regulations).  Any scheme which asks a NPA to deal only with the most contentious and complex applications via a call-in must have full-time staff experienced in doing this work and follow the correct procedure otherwise there is greater risk of legal challenges or losing investment. The consultation implies call-in may be a cheaper option than full planning powers, but this seems by no means certain given that the NPA would require development planning expertise for the called-in applications. Depending on the extent of the National Park there might be less duplication of roles if the NPA was the full planning authority.

Is there any review evidence from the Cairngorms as to the effectiveness of the call-in arrangement in terms of alignment with National Park aims? It would be informative to know whether planning decisions taken by LAs within the park boundary are always felt to be taken in line with the NPA’s development plan or if there is more divergence from policy than would be hoped for.

Access, recreation and visitor management

Q9a Do you agree that the National Park should, in principle, become an access authority for its area?

Yes

Access and its management is part of the core of a National Park’s aims and operation. We understand that the Land Reform (Scotland) Act 2003 defined the two existing National Parks as Local Authorities for the purposes of the access arrangements but for some reason did not extend this to include any future National Parks; we do think this should be the case. The third aim for National Parks in the 2000 Act is “to promote understanding and enjoyment (including enjoyment in the form of recreation) of the special qualities of the area by the public”. We think that a new Park must have all of the powers that are set out in the 2003 Act or it will fail to achieve this aim. Pretty much everything else related to access follows on from that.

We feel strongly that the NPA should form a local access forum and become the access authority.  This will allow access to be managed strategically with the ability to consider and plan for any displacement of visitors. It would also allow for a park-wide approach which should be more easily understood by visitors compared with the alternative of different jurisdictions taking different approaches to provision, signage, etc.

Q9b If not, what other options could be considered and why?

N/A

Q9c Do you agree with the suggested approach to core path planning?

Yes/Maybe/No/Don’t know

It is not entirely clear what the “suggested approach” to core path planning is – we could interpret the consultation text to mean “review existing” or “create a new core path plan” for the whole Park area).

Q9d If not, what other options could be considered and why?

We support a more extensive National Park area, and a single access authority/ local access forum, which means we favour preparation of a new core path plan, treating the area as a coherent whole. The basis for this would be a review of the existing three core path plans to ensure the new plan covers the whole National Park area, and works strategically for the whole Park area as well as for local communities.

This would allow a single approach for access to be taken for much of the western section of the southern Uplands, including Merrick, the highest of these hills which is currently split between three local authorities. A clear forum within which the development of a coastal path can be discussed with landowners and land managers is also needed, and would also allow engagement over wider issues that improving and maintaining access will raise.

Q9e What are the strengths and weakness of these options for access and other fora?

[the options seem to be either have a NPA access forum or be represented on the 3 LA access fora, but only one of the 3 is active]

A new National Park should have its own access forum. The more that can be done to encourage people to think and act on access Park-wide the better for more active and more sustainable transport for locals and visitors. This is especially true given that even the smallest Park area proposed straddles the watershed and that the existing administrative and social divides are deep and entrenched – to the disadvantage of the communities concerned.

It seems unlikely that if a National Park was to be established that currently inactive LA access forums would become active and adequately cover the NPA. It would be less effective and more onerous for an NPA to make representations to 3 local access forums to manage access strategically and consistently across the whole Park. 

Given the concerns of part of the farming community it will be crucial for the NPA to engage and develop a good relationship with farmers and to demonstrate that responsible access will not impinge on day-to-day work on farms. A functioning whole Park access forum would play a role in this by allowing issues to be raised and dealt with timeously and speeding up the strengthening of the path network.

We would be happy to see a National Park Authority establish an advisory forum with a wider remit on recreation and visitor management in addition to a local access forum covering the whole Park.  Experience from existing National Parks suggests that advisory forums or working groups need to adapt over time, sometimes having a short timespan.  We note that the LLTNP currently has a “Your Park stakeholder forum” which includes partner public bodies, outdoor recreation groups and community groups.

Q9f Are there any other options you would want to see considered?

We would like to see a new NPA also taking responsibility for rights of way. We assume that this would need to be detailed in the designation order.

Q10a Do you think that the new National Park should establish its own ranger service?

Yes/Maybe/No/Don’t know

Q10b What are the strengths and weakness of this approach?

The National Park should have its own Ranger Service which should be properly financed, and develop good partnership working with existing ranger services. The partnership arrangements and different options for how the ranger service operates will likely evolve over time and grant aid funding, if available from the NPA, would have appropriate scrutiny, oversight and contracts as with current grant-aid arrangements. A National Park Ranger Service would fill gaps in, and enhance existing provision and give a degree of certainty currently missing as we understand there are significant gaps in the provision of Rangers in Galloway at present. By filling those gaps, Rangers could play an important role in helping to achieve the right balance between access, public understanding, land management requirements and nature conservation interests.

The Ranger Service often acts as the public face of a National Park and are the only contact many people will have with Park personnel. They have the advantage of being able to act quickly to identify and defuse potential problems and help develop solutions to issues that arise. Their effectiveness is increased with support from the NPA for example over provision of legal, financial and training advice.

The strengths of a National Park Ranger Service are a common identity and a consistency of approach which are highly desirable. Weaknesses can arise where there are different types of Rangers (a mix of National Park and site based) which could lead to uncertainty from the public about the role of rangers – eg if National Park Rangers are expected and empowered to enforce byelaws/issue fixed penalty notices whereas site-based Rangers are not.

Periodic options analysis should be carried out to ensure the Ranger Service is as effective as possible as a new National Park develops over time. There is potential to learn from the evolution of the existing National Park Ranger Services, with careful consideration given to the most effective way of deploying Rangers in the new Park. For instance, consideration could be given as to whether funding roaming seasonal Rangers is most effective (both for employees themselves and for visitors and residents) versus the funding of additional site-based hours by the NPA ,which can be delivered as appropriate with scrutiny/ oversight and appropriate contracts with the NPA in place, as with all grant-aided Rangers).  The size and shape of any new National Park will clearly influence the requirements and form taken, with consideration needed regarding scheduling across the area, familiarity with the ground and coast, and specific roles.

An additional benefit of a Ranger Service is that it can be the focus of the creation, management and promotion of volunteering in a National Park. The costs of providing a Ranger Service can be offset many-fold by the value of the volunteer work that is carried out and the benefits to the volunteers themselves and the wider population. The SCNP and APRS publication “Volunteering and National Parks in Scotland” (2016) details the potential value and benefits of more National Parks through encouraging volunteering.

Q10c Are there any other options which should be considered and why?

Forestry and wind farm development

Q11a Do you agree with these possible arrangements? 

Yes/In part/No/Don’t know

Q11b If not, what alternative approaches should be considered and why?

We agree with the proposals that the NPA will work closely with those sectors and draw up its Park Plan in ways that support their long-term success but which must also deliver on the National Park’s statutory aims. In addressing nature depletion and climate change National Parks must be in the forefront of mitigation and recovery, with carbon sequestration, soil protection and woodland and nature recovery playing key parts rather than the focus being solely on afforestation and renewable energy. The National Park Authority will have a key role in ensuring these are all taken forward effectively, and where most appropriate.

We firmly agree that the proposals for the NPA to become a statutory consultee on FLS management plans, Scottish Forestry regulation and funding decisions and ECU planning decisions (as stated in para 5-13) are essential steps towards integrated land management.

We also agree there is merit in the NPA and FLS jointly producing a management plan for the Galloway Forest Park, ensuring the long-term vision for nature and recreation are set out as well as for timber production.

Governance and staffing arrangement for the National Park Authority

Q12a Do you support these proposals for the potential size and composition of a National Park Board in the Galloway area?

Yes/Maybe/No/Don’t know

Given that we support a larger area for the National Park boundary we can see the requirement for a slightly larger board, but we also appreciate the stated concern about increasing the LA nominations beyond 3 representatives for D&G, as 4 nominated members from D&G would result in a total Board of 18 people, which would increase expense and is potentially unwieldy.

The suggested quota of directly elected members has been raised from the minimum set out in the Act. This is potentially workable, as long as it is somehow ensured that the overall make-up of the Board contains the necessary expertise to be effective and the onus is on those elected or appointed to be interested in and committed to the aims of the National Park and to for instance participate in elected member training (eg on the planning system) where appropriate.

Q12b What do you think would be the advantages or disadvantages of these suggested arrangements?

There is a real need for local representation on the Board, but how the balance of the Board should be drawn is hard to pinpoint.  Partly this is because it is possible for Government to appoint local people as national members if they have the expertise most sought after, but the specification for local members is geographically based, so the onus is on LAs and Scottish Government via nominations and appointments to ensure that the necessary range of expertise is available to the Board at any time. Whilst LAs have generally nominated local councillors for National Park boards, they could nominate candidates for their specific expertise instead (who need not be councillors) and this might be more appropriate if directly elected local members are more numerous on a new Board.

There is also a point of accountability at the National level given that the Scottish Government is committing funding over the long-term.

On overall size there is a balance between the efficiency of a smaller board and the need to ensure that that the right range of expertise is available.

Q12c What alternative options could be considered and why?

Appropriate alternatives are very much dependent on the boundary selected and the LAs that will be represented.

Areas of expertise required by the National Park Board

Q13a Should Scottish Minister appointments to the Board include expertise on nature, farming and forestry?

Maybe. However, if there was strong representation on the Board of some or all of those sectors from locally elected or local authority representatives this may not always be necessary.  Ministers should be obliged to ensure the overall balance of skills, experience and backgrounds with specific attention given to nature, farming and forestry. Given the skills and expertise of directly elected and LA nominated members will vary over time it is important that Scottish Government has the ability to balance the skills set and is not locked into appointing specific types that could reinforce an imbalance if not required. It must always have an eye to delivering the wider aims of National Parks.

Whilst, arguably, it should be a legal obligation on all Board members that they are guided in their decision-making and all other contributions to Park business by a commitment to the National Park’s statutory purposes, there should still be adequate natural and cultural expertise on the Board. This will help the Board ensure that in exercising its functions a National Park authority adheres to section 9(6) of the National Parks (Scotland) Act 2000, this is the so-called Sandford or National Park principle. The principle clarifies that whilst the statutory aims should be achieved collectively and in a co-ordinated way, if it appears to the authority that there is a conflict between the first aim (to conserve and enhance the natural and cultural heritage of the area) and the other aims the authority must give greater weight to the first aim. Inclusion of natural and cultural and heritage expertise on the Board would assist in the judging of the existence of a conflict and the need to give greater weight to the first aim. 

Q13b What other areas of expertise would the Board require, and why?

Recreation and enjoyment is an obvious one (with a strong health and well-being angle). Nature should explicitly include landscape. There’s also a need for people who understand the wider local economy beyond farming, forestry and renewables. A further area of expertise that the Board will require access to, to a greater degree than in most UK National Parks, is knowledge of the coastal and marine environment including recreation, blue economy, and conservation aspects.  

Additional expertise can be brought in via task-based working groups to consider specific issues, eg developing criteria and protocols for managing large-scale events or developing a Quad Bike code.

Q14 Do you have suggestions for the topics that National Park sub-committees and advisory groups should be created for?

It would be useful to draw on experience from the existing National Parks. If there is to be a land use committee, it might be good to counterbalance it with others representing wider economic and business interests and social and educational ones.

We understand that there has been some flexibility about sub-committees, advisory groups and working groups in existing National Parks and that some working groups have been set up to look at specific issues and then wound down. Potential areas could include: Nature strategy; Tourism partnership; Upland advisory; Agricultural advisory; Equality Advisory; communities; recreation; marine and coastal; business advisory; sustainable transport; youth committees and junior rangers and volunteering.

Q15 What steps could be taken to ensure a new National Park operated in ways which are inclusive of ethnic minorities and other protected characteristics?

We suggest gathering best practice information on processes and approaches to removing barriers from existing National Parks in Scotland and elsewhere. Some sources of information include the  Accessibility section on the Nature for All Resource Hub created by Scottish Environment LINK; The Campaign for National Parks has information about its work on Equity, Diversity and inclusion on its website; and Natural England published a briefing “Included Outside” in 2022.

Ensuring inclusive representation in imagery and narratives about staff, volunteers and visitors in National Parks is very important to ethnic minority groups and those with other protected characteristics. Therefore, having a range of imagery that reflects our society (e.g., Black people/those from ethnic minority backgrounds, disabled people, different ages, different genders, people wearing different religious headwear/clothing) is a good starting point.

If a National Park has Board members who come under an ethnic minority group or other protected characteristic, then asking them to be in photos to be shared could be positive for underrepresented groups. Someone seeing people like themselves in imagery, especially if they’re part of Boards, provides comfort and safety where they may have previously felt like they didn’t belong in a place/space.

Some National Parks have had additional representation on Boards for periods of time (in attendance, not voting) if helpful in broadening discussion and representation. It may be helpful to look at approaches used in National Parks with similar resident population sizes? 

It will be important to ensure that there is inclusion across all the operations of the Park – whether for visitors, staff, volunteers or board members – and that accessibility of local facilities is considered to foster an ethos of a ‘Park for All’. Initiatives such as ‘Cairngorms on a shoestring’ can help overcome socioeconomic barriers for some groups of people, including some from ethnic minority backgrounds and those who have protected characteristics (e.g., disabled people) and may not otherwise have visited or volunteered with or joined a National Park.

The Cairngorms Trust has co-developed with a Lived Experience panel a fund (also called the Park for All fund) to encourage members of the Black, Asian & Minority Ethnic (BAME) community to be able to access the outdoors in the Cairngorms, to promote connection to nature and community and inspire environmental awareness creating positive change within the Cairngorms National Park. 

Other points for consideration are how best to give clear messages which can improve safety, such as being an anti-racist Park and having a zero-tolerance approach to racism and any other form of discrimination, harassment, and bullying. Also, having a designated person who takes on complaints if they should arise, too. This person should understand safeguarding and know the steps to take in different scenarios. Having a clear and open approach to ‘reasonable adjustments – so that if someone requires additional support there will be a designated person to contact.

Inequality may also be addressed by early planning for sustainable transport and making this inclusive eg https://www.lochlomond-trossachs.org/park-authority/publications/sustainable-travel-options-appraisal-modal-shift-report/

Work carried out on behalf of NatureScot in 2022 produced some helpful recommendations about the development of new National Parks and inclusivity that should continue to borne in mind. In summary these were:

• Proactively engage with a range of Disabled People’s Organisations and Access Panels (Access Panels being groups of disabled volunteers who work together to improve physical access and wider social inclusion in their local communities throughout the process of designating new National Parks).
• At future stages of National Park development, consider the following aspects of accessibility and inclusion for disabled people: pathways, seating, buildings, toilets, transport, information and signage.

• Create opportunities for young people to have influence over the way National Parks are managed through the use of Youth Committees or Youth Boards.
• Prioritise the accessibility of National Park sites in terms of affordable physical access to the site, physical accessibility within the site, and making visitors feel welcome to visit that place.
• A National Park has to take a holistic view, accounting for its contributions to net zero, biodiversity, the circular economy, employment opportunities, and access to nature for people.
• Communication is essential to explain the benefits for everyone.
• As part of this work, Disability Equality Scotland (DES) polled its members with the question “Do you support proposals to establish a new National Park in Scotland by 2026?” To which 88% said yes. 
• The above bullet points were summarised from National Park Commission SAG 5-1 – Centring views of Young People and People with Disabilities on National Parks available on NatureScot website.

Timing of elections of directly elected members 

Q16 Views are sought on the timing of the direct elections in respect to the selection of other elements of National Park Board.

If Scottish Ministers were to seek to balance the overall skill set of the Board, then presumably the appointment process would have to happen after the direct election and nominations process, rather than the other way round. 

National Park staffing

Q17a What options for using the existing public sector staff and resources to undertake the work of the National Park Authority should be considered and why?

Given ongoing financial pressures, it’s certainly desirable to explore the scope for sharing resources and potentially functions. In terms of place-based delivery there also needs to be careful consideration given to how best to work with the Biosphere. (The Galloway and Southern Ayrshire UNESCO Biosphere Partnership is a Scottish Charity registered with OSCR Reg: No: SC044137.)

There would certainly appear to be scope to share some corporate functions between three National Parks, potentially building on joint arrangements between the existing two. We note that the consultation document states that “with three National Parks, a single National Park agency could also become a more viable option”.  SCNP has previously floated the idea of this and considers there could be pros and cons depending on the exact role and services such a centralised service would carry out.  However, further work on this option should not be permitted to delay the establishment of a new Galloway National Park within the timescale set out by the Scottish Government.

Q17b Are there any benefits or drawbacks to these options which need to be considered?

Having National Park staff on the ground in the National Park, with continuity of personnel, is absolutely crucial, with that presence reflecting that the new National Park is run by staff and a Board based largely in the region on behalf of the Nation.

Any reduction of physical presence of staff in the area (eg if some backroom services were carried out by other National Parks) might mean the new National Park would be less effective as part of a wellbeing economy underpinning organisation, due to bringing fewer new jobs directly.

Q18a What level of staffing do you think is appropriate for the area, powers and functions and governance arrangements being considered?

A CEO, plus around 25 staff (as outlined in the consultation report re supporting Board, develop and implement partnership plan and planning, access and land use functions plus further staff (beyond the 25) to provide ranger and visitor services tbc) may not be enough to play the sort of catalytic, facilitating role that a National Park should be playing, however, there are a lot of variables which will determine the necessary level of staffing from the size of the National Park, and how any services and functions shared with other public bodies (and potentially the Biosphere) are arranged. So the scale of additional resources available to the Biosphere, may affect staffing level at the National Park.

As implied in Q17, the net increase in public sector employment and expenditure will depend on the extent to which an National Park takes over roles from local authorities (and potentially other public bodies) which they therefore no longer need to provide, and also the degree to which the National Park and these bodies can share expertise that the former would either need to acquire directly or to buy in.

Taking on a full planning authority role would probably require in the region of 10 FTE staff to cover development planning, development management (even on a call-in basis), enforcement, and administration. (Estimate based on equivalent in CNPA).

Q18b What other areas of work would require further staffing and why?

Marine/coastal conservation and engagement with commercial and recreational interests (even if the National Park boundary is MLWS on the coast). The NPA must be a key player in the Solway Marine Regional Plan, however, given that only some of the north Solway coastline is likely to be included in the National Park we do not anticipate the NPA taking over responsibility for regional marine planning.

Section 7 – Name of the National Park

Q19a Do you agree that – if designated – the National Park should be called the ‘Kingdom of Galloway National Park’?

No. 

Q19b If not, what alternatives would you suggest?

We are not keen on “Kingdom of Galloway” as it has little resonance with most people and thus prefer plain “Galloway”. However, the choice of an appropriate name is likely to be influenced by the boundary, so whilst “South West Scotland” seems too bland and vague, something like “Galloway and Carrick” might be appropriate if the wider area is chosen?

Section 8 – Other issues

Q20 Do you have any other comments you wish to make here which are relevant to the proposal?

Working arrangements with the Galloway and Southern Ayrshire Biosphere will need to be given consideration.  

Planning policy – if, as it has been sometimes represented in recent debate by the NFUS and others, the main objection to a National Park from the farming community is to the slightly more restrictive planning policy around large agricultural sheds and permitted development rights it seems sensible to look at this concern early on. Depending what the eventual planning arrangements for a new Park are, the NPA and LAs could review how planning works for this from prior notification for more modest sheds to planning applications for those outwith permitted development rights at present.  This doesn’t seem an insurmountable issue given the Scottish Government has committed to amending national planning policy on windfarms with respect to new National Parks.

Q21 Is there further evidence and information you want to provide on the potential positive or negative environmental, social and economic impacts of the proposed National Park?

A broad range of social and economic benefits arising at least in part from the designation of National Parks are detailed in the reports by SE LINK published in 2024 called ‘Social and Economic Benefits of National Parks’ and ‘Farming Benefits of National Parks’. Whilst in recent discussions much is made of the economic boost via tourism other studies have detailed the wellbeing benefits of National Parks and the economic value of this.  For example York University produced a study in 2018 which estimated that for every £1 invested, the North York Moors National Park generates approximately £7.21 of health and well-being benefits for volunteers and visitors. The pandemic also highlighted the importance of these spaces for our health. National Parks have also previously been described as ‘Wellbeing Factories’, providing access to open spaces and a wide range of activities beneficial to our health and mental wellbeing.  The SCNP and APRS report Volunteering and National Parks considers the value and benefits more National Parks could bring to Scotland relating to Volunteering. A recent report by Campaign for National Parks on “The Value of a new National Park in Wales (2024)” highlights that many of the benefits of designation extend to communities nearby but outwith the Park boundary, referring to this as the “Halo effect” and also highlights how National Parks create a range of  jobs associated with the protection of the environment.

Environmental, social and economic impacts

In addition to the case studies highlighted in the SE LINK report on Farming Benefits, we are aware of other examples of NPA led or supported schemes which bring a variety of benefits for farmers, nature, the environment and climate. One example is the traditional field boundaries programme led by Eryri National Park. The popular fund supports farmers and land managers to keep these important features of our landscapes managed and maintained, enabling the restoration of traditional stone and hedgerow field boundaries with various benefits for farmers, biodiversity, and carbon. Similar schemes featured in many of the Environmentally Sensitive Area (ESA) programmes that previously found much favour with many farmers – to an extent that few, if any, subsequent agri-environment schemes have matched. The 10 ESA areas in Scotland included two in south west Scotland. Now discontinued, they were introduced in 1986 to help safeguard areas where the landscape, wildlife or historic interest is of national importance; and because it was recognised that agriculture can have a major influence on the conservation and enhancement of the landscape, wildlife and historical features.

Similarly, the “Connecting the Coast” scheme in Pembrokeshire Coast National Park helped create wildlife habitats and coastal corridors, with field margins and corners close to the coast being transformed into biodiversity havens.

Other recent examples include the launch  by LLTNPA of the Resilient Farm Network (RFN), a five-year (2025-2029) programme to boost climate and nature-friendly farming in a way that is profitable for farmers. Through this programme, the National Park Authority aims to support the long-term sustainability of farming and land management within the park, to enhance nature recovery, reduce carbon emissions and promote carbon sequestration. The LLTNPA is also contributing 25% towards a (separate) Low Input Farm Business Programme which aims to support farm business staff improve their skills and knowledge in regenerative livestock systems across Scotland but with project events happening with the National Park boundary. 

There is increasing recognition that National Parks can attract a younger demographic to live and work there – partly because of the draw of the landscape and the quality environment. Anecdotal comments on these broader effects of designation turn up in publications and films such as “Gateways – Connecting communities through walking and cycling in the Loch Lomond and Trossachs National Park” by Trust in the Park, during which named participants comment “I think there is a notable sort of influx to the population of the village of young people who are working in the outdoors or are interested in working in the outdoors” and  “the extra benefits that we get from National Park status is giving it a kind of world name, a world tag if you like to bring visitors here. And it has made a big difference to our business”. See https://youtu.be/uwzdEp47-lE?si=R0C6wUTONEFkc7g5

Housing – impacts of tax and regulation changes?

Concern over the cost of housing and availability of affordable housing and social housing in particular is high across Scotland and indeed most of the rest of the UK.  We have already referred (in earlier answers) to the efforts of NPAs, where they are the planning authority, to set ambitious targets for new affordable homes and to support the delivery of these.  We also note that the tax arrangements for second homes and the regulation and tax arrangements for furnished holiday lets in Scotland (and the rest of the UK) are in the process of changing quite dramatically. The context for a new National Park is therefore quite different from that at the start of the century. These changes include:

December 2022 – Additional Dwelling Supplement (ADS) added to Land and buildings transaction tax. In Scotland there is an extra “stamp duty” on additional property purchases. This ADS is added to any Land and buildings transaction tax which may be due generally when a property in addition to a main residence is bought. As of December 2022 it was set at 6% of purchase price. [Revenue.scot]

April 2024 – Powers for LAs to introduce Council tax premium (200%) on second homes. 29 out of 32 LAs already confirmed, one more considering.

July 2024 – all short term lets in Scotland have to be licensed to operate. Control areas can also be introduced by planning authorities where dwellings being converted to short term lets require planning permission.

April 2025 – UK government to change tax arrangements for furnished holiday let (FHL) owners and bring them in line with other property businesses. From April 2025 FHLs will be treated like other buy-to-let properties. Previously they benefited from more beneficial tax treatment (over other forms of residential letting) including greater mortgage relief and capital allowances. Capital Gains Tax on sales of FHLs will also change to be in line with other property. See HMRC advice.

We have yet to see analysis of the likely combined impact of all these changes on levels of second homes and STLs.  However, it seems likely that the overall impact will be to decrease their appeal to landlords and owners and it seems possible that this effect could be more significant than any speculated gradual rise in second homes due to the designation of a National Park. Any new National Park will begin operating in the context of a housing market with very different incentives and controls to those in the early 2000s.

In 2023 there were over 24,000 second homes in Scotland, approximately 1% of dwellings. Scotland’s two existing National Parks had relatively high percentages of second homes in 2023, however, even in 2001 before either National Park was designated it was the case that Argyll and Bute and Highland were local authorities with some of the highest levels of holiday homes in Scotland. Other parts of rural Scotland including Skye, Cumbrae and Arran also continue to have high levels of second home ownership. Cumbrae and Arran were reported to have the highest proportion of second homes of anywhere in Scotland in 2023.

In Scotland, a second home is classed as any home that isn’t used as someone’s main home but is occupied for at least 25 days a year. December 2023 figures, show that there were over 24,000 second homes in Scotland, approximately 1% of dwellings. Housing statistics: Empty properties and second homes – gov.scot (www.gov.scot). Of the 2.72 million dwellings in Scotland in 2023, 92,500 (3%) were vacant and 24,000 (1%) were second homes. Empty and second homes are concentrated in different parts of the country. For example, remote rural areas had the highest percentage of dwellings that were vacant (6%) or second homes (6%). [NRS 2024]. The areas with the highest proportion of dwellings that were second homes were mainly rural and island areas, including Argyll and Bute (7%), Na h-Eileanan Siar (6%), Orkney Islands (4%) and Highland (3%).

Dumfries and Galloway has 1.8% of second homes compared to the Scotland average of 0.9% (including all rural and urban areas). South Ayrshire is 0.9% and East Ayrshire 0.2% [https://www.nrscotland.gov.uk/files/statistics/household-estimates/2023/house-est-23-report.pdf]. The two existing National Parks do have relatively high numbers of second homes, however, research from 2001 showed that Highland, and Argyll and Bute were already two of the local authority areas with the largest number of second and holiday homes prior to the designation of any National Parks in Scotland (Bevan and Rhodes, 2001).

An information note on housing prices in UK National Parks, prepared in 2017, so pre-dating all the recent tax and regulatory changes, is available on the SCNP website.

Other Housing references:

Housing in National Parks is also referred to in the SE LINK report “Social and Economic Benefits of National Parks” (2024)

Bevan, Mark Alistair orcid.org/0000-0002-7794-8380 and Rhodes, David John orcid.org/0000-0002-8988-1750 (2005) The Impact of Second and Holiday Homes in Rural Scotland. Research Report. Edinburgh: Communities Scotland https://eprints.whiterose.ac.uk/192849/ [accessed 22 October 2024]

https://spice-spotlight.scot/2022/09/07/second-homes-in-scotland-facts-figures-and-policy/

Scottish Government (2023) Rural and Islands housing: Action Plan https://www.gov.scot/publications/rural-islands-housing-action-plan/pages/7/#

Households and dwellings in Scotland, 2023 (published June 2024) https://www.nrscotland.gov.uk/files/statistics/household-estimates/2023/house-est-23-report.pdf

Information Note on housing prices in UK National Parks (2017) prepared by Graham Barrow for SCNP and APRS.

APRS and SCNP – February 2025