APRS Resources

Response to the Scottish Government consultation on Scotland’s Strategic Framework for Biodiversity

This is the APRS and SCNP joint response to the Scottish Government consultation on Scotland’s Strategic Framework for Biodiversity (Tackling the Nature Emergency). We have responded specifically in the area of National Parks.

The joint Scottish National Park Strategy project submitted a response to the  Scottish Government’s consultation on ‘Tackling the Nature Emergency’ on behalf of APRS and SCNP (December 2023).  This extensive consultation covered Scotland’s Strategic Framework for Biodiversity so we responded to the sections specifically focused on National Parks, particularly part B, section 7 which proposed potential amendments to the National Parks (Scotland) Act 2000. Following consideration of responses the government could introduce the amendments it decides to take forward in the forthcoming Natural Environment Bill, expected in late 2024. 

APRS and SCNP are supportive of the Scottish Government’s proposal to designate new National Parks by 2026, strengthen the powers and governance of existing National Parks by 2026, and ensure better biodiversity outcomes by 2030. In our response we emphasise the importance of greater collaboration among public bodies to achieve National Park aims and to develop and deliver National Park Partnership Plans effectively. On the Biodiversity Delivery Plan (part A, section 2) we suggest including additional actions, such as considering designation of further National Parks before 2030 and exploring positive management measures for areas nominated under the current new National Park selection process but where National Park designation is ultimately not deemed suitable, but biodiversity improvements are possible.

Thinking about potential amendments to the legislation, we are supportive of the proposal to include reference to climate leadership and nature recovery in a National Park Authority’s purpose, but we raise concerns about the lack of clarity in the proposed wording, particularly as the Scottish Government has said elsewhere that it will produce bespoke planning guidance on windfarms in new National Parks without giving any parameters for this. We would like to see unequivocal clarification that the inclusion of climate in the new National Park Authority purpose does not mean that the permitting of new large-scale renewable energy developments within NPs would be acceptable. We emphasise that National Parks can play a role in climate leadership through other approaches, such as natural carbon solutions (eg peatland restoration), reducing carbon emissions, and sustainable land management.

Regarding the other proposals for changes to the National Parks (Scotland) Act 2000 we mostly support the direction of the changes proposed – including the extra emphasis on reversing loss of nature and supporting biodiversity recovery.  However, we express concern about a potential oversimplification of the division between nature and culture, urging retention of wording that helps maintain the holistic approach to landscape management within National Parks. We also provide some detailed comments on the proposed wording for the new aims, expressing reservations about terms like “natural assets” and expressing a preference for retaining “natural heritage”. Additionally, we put forward alternative wording for the new third aim, attempting to better support the government’s intended outcome of an equitable transition to a net-zero and nature-positive society.

We endorse retaining the National Park principle outlined in section 9(6) of the 2000 Act. We support maintaining the principle whether the existing first aim is amended or retained unchanged. The principle’s guidance (giving greater weight to the first aim) is potentially valuable if conflicts arise between different National Park aims.

We strongly support the idea that public bodies working within National Parks should actively further National Park aims and that they should actively support and contribute to National Park plans. We therefore support the various proposed duties on public bodies but advise that the final wording should be more robust in order to achieve this. We also support the proposal that public bodies must apply the National Park principle when conflicts between aims arise.

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