RTPI Scotland's Response to 'The Future for National Parks in Scotland'

Survey found at:

https://www.smartsurvey.co.uk/s/nationalparkscommissionsurvey/

 

The Role of Scotland’s National Parks

1. Do you support "leadership of nature recovery and a just transition to net zero” becoming the overarching purpose of Scotland’s National Parks? If not, what else would you propose?

Yes. RTPI Scotland supports the proposed overarching purpose which aligns with the recently published revised draft National Planning Framework 4 (NPF4)[1] which places tackling the twin climate and nature crises at the heart of national policy moving forward. It is worth noting that as set out in Planning (Scotland) Act 2019 the planning system also 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. RTPI Scotland also wishes to see some clarity as to what the connection of the proposed overarching purpose is with the existing four collective aims set out in the National Parks (Scotland) Act 2000. This is an important consideration as currently planning decisions for development within National Parks must be consistent with the National Parks (Scotland) Act 2000. Therefore, careful consideration should be made to changes to this regulatory framework and the effects on planning decisions, with particular attention given to the new regulatory and policy context of the planning system.

2. Which of the proposed elements of leadership and action set out in the list above do you support? What others - if any - would you propose?

RTPI Scotland supports all element of leadership and action set out in this list. It is important to ensure there is a clear and consistent read across from other areas of Scottish Government policy and regulation – especially the planning system. Therefore the list of proposed elements of leadership and action could be strengthened through reference to, for example, the Place Principle, Community Wealth Building and inclusive growth.

3. What opportunities are there for National Parks to generate private investment in natural capital?

RTPI Scotland believes that careful consideration needs made to how the National Parks can engage with the existing ecosystem of regional governance and frameworks to maximise investment opportunities in natural capital. The careful alignment of Regional Economic Strategies underpinning City Region and Regional Growth Deals, Regional Economic Partnerships, Regional Land Use Partnerships and the Strategic Transport Project Review 2 will be key to this. RTPI Scotland believes that emerging Regional Spatial Strategies need progressed in order to express the spatial ambitions of these regional frameworks and governance bodies and a provide a strong and clear steer for National Parks going forward.

4. What role should local communities play in the National Park and how should National Park authorities work with and for them to secure a just transition?

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^[2]. 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), a provision introduced in the Planning (Scotland) Act 2019. They are a new type of plan providing opportunities for communities to develop proposals and ideas for the development of where they live, something that could be directly tied to the establishment of a new National Park. LPPs have the advantage of being developed at a more granular level with local community buy-in about the types of development that are needed and the best locations for the proposals, if combined with a rigorous site assessment process to make sure the land is suitable for development. In England, research has shown the equivalent form of community-led plans known as Neighbourhood Plans have had a significantly higher uptake in rural areas^[3]. RTPI Scotland has called upon the Scottish Government to provide dedicated resources for planning authorities to support LPPs, ideally through creating dedicated planning officer roles or through support provided by a national body that can facilitate local links. To support communities to produce LPPs, RTPI Scotland has called upon the Scottish Government to establish a national grant scheme for communities as has been established in England to support Neighbourhood Plans. Tied back to the previous principle, RTPI Scotland wish to see appropriate resource provided to support communities to produce Local Place Plans and for planners to engage local communities in the preparation of Local Development Plans.

5. Do you support a “vision and mission” for all of Scotland’s National Parks being clearly set out in a national statement? If not why not?

RTPI Scotland supports this proposition.

6. If you favour a national statement for Scotland’s National Parks being developed, what else should it cover?

The production of a national statement would allow for an opportunity to update the role of National Parks to include recent policy initiatives such as the Place Principle, inclusive growth and Community Wealth Building.

7. To what extent should new National Parks be about the future potential of an area for nature restoration as well as what’s currently in place

RTPI Scotland believes that nature protection and restoration is a significant purpose of National Parks and this needs to be fully reflected in a national statement.

The Statutory Aims of National Parks

8. Are any specific changes to the existing four Aims required? If so why, and what are they?

As set out in response to Q6, if revisiting the four statutory Aims, an opportunity could arise to include more up-to-date policy principles.

9. Which of these possible options, or mix of possible options, do you think would help strengthen the focus and contribution of National Parks, and why?

As set out previously in the consultation response, RTPI Scotland supports the new overarching statutory purpose of National Parks to secure nature recovery and a just transition to net zero. If this is done the four current Aims may need reworded so as avoid repetition or overlap. As stated in response to Q8 the Aims could be revised to bring onboard more up-to-date policy principles. 

10. 
    Are there other options that could be considered? If so, what are they?

 

No further comment.

11. Do you think there should be any changes to the wording in the Act to require public bodies to support delivery of National Park Plans? If so, what would you propose?

Yes, with inclusion of the wording related to the Place Principle.

12. Do you have any other suggestions for improving partnership working to support the implementation of the National Park Plan by all?

RTPI Scotland wishes to highlight the key role that the planning service in delivering the aims of the National Parks. The designation of a National Park provides an opportunity to enhance the natural, cultural, social and economic value of an area and the planning system is one of the key levers to do this. Rural Scotland faces many social challenges including issues of depopulation, housing affordability and connectivity. At the same time Scotland is facing a biodiversity crisis^[4], with changing patterns of land use and management of large swathes of land in rural Scotland potentially holding the key to reversing this trend. There is a close interaction between landscape management and the planning system, with collective decisions on infrastructure and development greatly impacting upon wider landscapes over time. A review of international land use plans has shown better alignment and integration of these sectors may lead to greater efficiencies and better outcomes^[5].  The key role of planning services currently play in delivering the aims of the National Parks can be seen in their respective Planning Performance Frameworks[6][7]. Therefore any new regulatory and governance frameworks established need to have a clear and coherent alignment with the planning system. This includes clear alignment with revised draft NPF4 and the future arrangements for strategic planning as set out previously in this consultation.

As discussed in reference to Q11 RTPI Scotland believes that full recognition and adherence to the Place Principle can improve partnership working, especially with public bodies. RTPI Scotland believes that the effective implementation of place-based approaches is a critical means by which we can ensure maximum societal value is derived from interventions. Place-based approaches are about considering all aspects of a place when considering an intervention. To achieve a place-based approach, the Scottish Government and COSLA have agreed to adopt the Place Principle to help overcome organisational and sectoral boundaries. This includes improving coordination between stakeholders and enhancing collaboration and communication across local authority departments, key agencies, NGOs and the private sector. The principle requests that all those responsible for providing services and looking after assets in a place need to work and plan together, with local communities, to improve the lives of people, support inclusive growth and create more successful places. The Place Principle supports collaborative place-based action and the Place Standard is a commonly-used tool to help people think about the quality of their place and where action might be required. As both a visionary and regulatory catalyst to place-based initiatives, RTPI Scotland believes that the planning system is one of the fundamental mechanisms by which the Place Principle can be implemented. If given the right tools, the planning system could perform a central, coordinating role in implementing the Place Principle.

Powers and Functions of National Park Authorities (Q13-14)

13. Could any of the existing powers and functions be used more effectively? If so, which ones and how?

In terms of the effective use of planning and access functions of local authorities powers provided by the Act, RTPI Scotland wishes to highlight our research which has revealed significant concerns around the resourcing of planning services with:

• 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 the recently published report by CIEEM looking at LPA ecological expertise and capacity in Scotland. 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.

14. Are any of the existing powers or functions redundant or unnecessary? If so, which ones and why?

RTPI Scotland supports the establishment of a new planning authority with the establishment National Park with a terrestrial or coastal element. Moreover, as set out in response to Q12, RTPI Scotland believes the work of planning services in National Parks to be fundamental lever to achieving their statutory aims. However, as highlighted in response to Q13 we need to consider how to resource a planning service effectively in the long term and address issues associated with the pipeline of planners in Scotland.

15. What, if any, changes to the powers and functions in these areas should be considered and why?

No comment.

16. Are there any other areas where strengthened or new powers and functions will be needed by the National Park Authority? If so, what are they?

No comment.

Diversity in approach (Q17-18)

17. Should the powers and functions of National Park Authorities be decided on a Park by Park basis? Should any apply to all National Park Authorities? If so, which ones and why?

We 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.

18. Are there any changes you would want to see to the governance and management arrangements of all National Park Authorities?

See response to Q17

Developing a nomination process for National Parks

19. Are these the key elements of an effective nomination process for National Parks in Scotland?

Clear alignment needs demonstrated with the vision and aims of other national policies, strategies, plans and funding streams particularly including the NPF4 and its Delivery Programme. RTPI Scotland also believes that regional strategies and working arrangements need considered as set out in response to Q4.

20. Do you have suggestions for improving any of the specific elements of the process?

No comment.

21. Are there additional elements you want to see included, and if so, what are these?

RTPI Scotland would wish to see the inclusion of a local contribution which could provide a mechanism to evaluate the value of establishing a park with any existing Local Development Plans or Local Place Plans. We would also advocate for a criteria based on potential financial requirements, in order to ensure that a realistic proposition is developed through careful fiscal analysis. See response to Q13 regarding the importance of effectively resourcing any new planning authority that may be established.  

Outstanding National Importance

22. Do you agree that outstanding national importance should be a criterion? Could the clarity of it be improved and, if so, how?

Yes.

23. Do you agree with the proposed components? Are any components missing and, if so, what are they?

RTPI Scotland would support the need for considering the potential for nature recovery and a just transition to net zero in any area that is nominated.

Size and Coherence (Q24-25)

24. Do you agree with size and coherence as a criterion? Could the clarity of it be improved and, if so, how?

Yes.

25. Do you agree with the proposed components? Are any components missing and, if so, what are they?

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

Need or Added-Value

26. Do you support the consideration of the potential contribution of the National Park in delivering nature recovery and a just transition to net zero as criterion? Could the clarity of it be improved and, if so, how?

Yes. Inclusion of term of Community Wealth Building would provide more clarity and coherence to the last point.  

27. Do you agree with the proposed components? Are any components missing and, if so, what are they?

Yes.

28. Do you support the assessment of the merits of a National Park compared to existing or other approaches as a criterion? Could the clarity of it be improved and, if so, how?

Yes.

29. Do you agree with the proposed components? Are any components missing and, if so, what are they?

Yes. A component could be added looking at the estimated cost of proposed measures and an appraisal of financial sustainability.

Degree of Support

30. Do you support the consideration of existing support as a criterion? Could the clarity of it be improved?

Yes.

31. Do you agree with the proposed components? Are any components missing and, if so, what are they?

Inclusion should be made to any regional policy such as emerging Regional Spatial Strategies and any community-led plans of policies including emerging Local Place Plans.

Strategic Contribution

32. Do you support the assessment of the strategic contribution of an area as a criterion? Could the clarity of it be improved?

Yes.

33. Do you agree with the proposed components? Are any components missing and, if so, what are they?

RTPI Scotland supports the proposed components.

Selection Criteria – other issues

34. Are there any significant issues that are not covered by the proposed criteria? If so, what are they?

No further comment.

35. Do you think any of the criteria are more important than others? If so, which ones and why?

No comment.

36. Do you think the selection criteria and proposed components provide the right balance between covering the issues required and simplicity? If not, how could they be improved?

RTPI Scotland believes the criterion provide a good balance covering issues required and simplicity, notwithstanding proposed additions of criterion we have set out above.

37. Should more of the proposed components be quantifiable? If so, which ones, and how?

No comment.

38. Are there any other issues about either Scotland’s approach to National Parks or the selection of new National Parks you would like to raise in your response at this stage?

No comment.

 

[1] https://www.gov.scot/publications/national-planning-framework-4-revised-draft/

[2] Community Land Scotland (2020) Home Delivery Community Led Housing in rural Scotland. November. Available here: https://bit.ly/3AgsBH0

[3] Parker, G and Salter, K. (2017) Taking stock of neighbourhood planning in England 2011– 2016, Planning Practice & Research, 32(4): 478-490.

[4] https://www.nature.scot/doc/state-nature-scotland-report-2019

[5] Scottish Land Commission (2020) Advice to Scottish Government on the establishment of Regional Land Use Partnerships. November. Available here: https://bit.ly/2TWkxM1

[6] https://hopscotland.files.wordpress.com/2022/09/cairngorms-ppf11.pdf

[7] https://hopscotland.files.wordpress.com/2022/09/lltnpa-ppf-11.pdf