RTPI Scotland Response to 'New National Parks - appraisal framework'

Criterion 1 - Outstanding national importance 

1. Do you agree that 'outstanding national importance' should be a criterion for assessing nominations for new National Parks?

Agree

If you disagree, please give reasons for your answer:

No comment

2. Do you agree with the components of criterion 1 (outstanding national importance)?

Component 1: Agree

Component 2: Agree

If you disagree, please give reasons for your answer:

No Comment

Criterion 2 - Size, character and coherence

3. Do you agree that 'size, character and coherence' should be a criterion for assessing nominations for new National Parks?

Agree

If you disagree, please give reasons for your answer:

No comment

4. Do you agree with the components of criterion 2 (size, character and coherence)?

Component 1: Agree

Component 2: Agree

If you disagree, please give reasons for your answer:

We believe that a component should be included which aligns a proposed geographic area with the spatial aspirations set out in the NPF4 and emerging RSSs.

Criterion 3 - Meeting the special needs of the area

5. Do you agree that 'meeting the special needs of the area' should be a criterion for assessing nominations for new National Parks?

Agree

If you disagree, please give reasons for your answer:

No comment

6. Do you agree with the components of criterion 3 (meeting the special needs of the area)?

Component 1: Agree

Component 2: Agree

Component 3: Agree

Component 4: Disagree

Component 5: Agree

If you disagree, please give reasons for your answer:

Whilst agreeing that National Park designation should support the sustainable development and well-being of local communities we believe that
reference to Community Wealth Building should be included in Component 4 to increase clarity, coherence and alignment with other policies on this
point.

Criterion 4 - Visitor management and experience

7. Do you agree that 'visitor management and experience' should be a criterion for assessing nominations for new National Parks?

Agree

If you disagree, please give reasons for your answer:

No comment

8. Do you agree with the components of criterion 4 (visitor management and experience)?

Component 1: Disagree

Component 2: Agree

Component 3: Agree

Component 4: Disagree

If you disagree, please give reasons for your answer:

Whilst we agree with Component 1, we believe it should also include an understanding of the area's contribution to nature recovery and a just transition
to net zero.

Whilst we agree with Component 4, we believe the words "equitable" and "sustainable" should be included so it reads "How could National Park
designation support equitable and sustainable access to nature for Scotland’s people?"

Criterion 5 - Added value

9. Do you agree that 'added value' should be a criterion for assessing nominations for new National Parks?

Agree

If you disagree, please give reasons for your answer:

No comment

10. Do you agree with the components of criterion 5 (added value)?

Component 1: Agree

Component 2: Agree

If you disagree, please give reasons for your answer:

No comment

Criterion 6 - Local support

11. Do you agree that 'local support' should be a criterion for assessing nominations for new National Parks?

Agree

If you disagree, please give reasons for your answer:

No comment

12. Do you agree with the components of criterion 6 (local support)?

Component 1: Agree

Component 2: Agree

If you disagree, please give reasons for your answer:

Whilst we agree in principle with the components of this criterion, it should be made clear that part of the evidence demonstrating local support should
include policies set out in emerging Regional Spatial Strategies and community-led plans or policies, including emerging Local Place Plans.

Criterion 7 - Strategic contribution

13. Do you agree that 'strategic contribution' should be a criterion for assessing nominations for new National Parks?

Agree

If you disagree, please give reasons for your answer:

No comment

14. Do you agree with the components of criterion 7 (strategic contribution)?

Component 1: Agree

Component 2: Agree

Component 3: Agree

Component 4: Agree

Component 5: Agree

If you disagree, please give reasons for your answer:

No comment

Additional Comments - selection criteria scoring process

15. Once finalised, the appraisal framework will include details of how each criterion will be scored. This will be published ahead of the nominations process being launched. Do you have any comments that you would like to make about how the selection criteria should be scored?

No comment

Additional Comments - draft appraisal framework and nominations process

16. Do you have any other comments that you would like to make about the draft appraisal framework and nominations process for new National Parks?

It is worth noting that as set out in Planning (Scotland) Act 2019 the planning system now has a statutory purpose which is: “The purpose of planning is to manage the development and use of land in the long term public interest”. RTPI Scotland would welcome consideration of how the purpose of planning can be incorporated within the overarching purpose, aims and/or actions of National Parks. We would also welcome consideration of how the Place Principle can be embedded into the nominations process for new National Parks to improve partnership working.

We also note the differing approach to planning services undertaken by the Cairngorms National Park Authority and Loch Lomond and Trossachs Park Authority. Such divergent approaches have been carried out for a number of years and in order to establish the best options for establishment of a new planning authority commission a piece of comparative research on the matter may be beneficial in supporting decisions on future arrangements.

In addition to the above, RTPI Scotland believes that local communities need to be involved with the designation of the National Park process at the earliest possible opportunity. This ‘front-loading’ of engagement will ensure that local interests among residents are fully integrated in the functioning and management of a National Park alongside national conservation and amenity needs. The community empowerment agenda in rural Scotland has a rich and successful history of community-led planning and placemaking through, for example, the establishment of development trusts and community-led housing initiatives. RTPI Scotland therefore calls upon any designation process to take into consideration any existing Community Action Plans, Local Outcomes Improvement Plans (LOIPS) and Locality Plans. Furthermore consideration needs to be made to the role of emerging Local Place Plans (LPPs).

Finally, RTPI Scotland has for a long time expressed concerns about the resourcing of planning services, including for National Park Authorities. Our research (see https://www.rtpi.org.uk/research/2022/december/resourcing-the-planning-service-key-trends-and-findings-2022/) has revealed significant concerns, including:

• Nearly a third of planning department staff have been cut since 2009
• Planning authorities’ budgets have diminished in real terms by 42% since 2009
• In 2020 local authorities only spent 0.38% of their total net revenue budgets
• Planning application fees only cover 66% of their processing costs
• There are 91 new and unfunded duties in the Planning (Scotland) Act, which could cost between £12.1m and £59.1m over 10 years

Research has also showed that planning has demographic and succession challenges with a limited pipeline. Only around 9% of staff in planning authorities are under 30 and there is an estimated replacement demand of around 500 planners over the next 15 years. Therefore, RTPI Scotland calls on Scottish Government to ensure that resource is also made available to increasing the pipeline of planners and to develop the necessary skills in our existing workforce to tackle the biodiversity and climate crises. An effective consenting process relies heavily on the collaboration between planning authorities and a range of statutory consultees. It is vital that they too have the necessary resources to support their work. RTPI Scotland is concerned with findings from a report published by CIEEM looking at LPA ecological expertise and capacity in Scotland (see https://cieem.net/wp-content/uploads/2022/03/Scotland-LPA-survey-v3.pdf). This work revealed significant cuts to local authority ecological provisions in recent years, with low to no capacity of ecological resource or expertise available to planning authorities alongside a lack of planning enforcement staff monitor compliance.

RTPI Scotland supports the establishment of a new planning authority with the establishment National Park with a terrestrial or coastal element. However, the work of planning services in National Parks is a fundamental lever to achieving their statutory aims. RTPI Scotland believes, therefore, that we need to consider how to resource the planning service effectively in the long term and address issues associated with the pipeline of planners in Scotland.