11 PERTH AND KINROSS COUNCIL 15/130

Enterprise and Infrastructure Committee

25 March 2015

Landscape Guidance

Report by Depute Director (Environment)

This report provides a summary of the comments received on the Landscape Supplementary Guidance which was formally consulted upon from 28 November 2014 to 19 January 2015. As part of the process of developing the supplementary guidance, a Review Panel was established and workshops were held at the AK Bell Library on 24 April, 20 May and 10 June 2014 respectively. An online survey to allow wider participation in the review process was also used. The report makes recommendations for changes where appropriate and seeks consent to finalise and adopt the Supplementary Guidance to support the Local Development Plan (adopted 3 February 2014).

1. INTRODUCTION

1.1 The Adopted Local Development Plan sets out the Supplementary Guidance to be prepared to support the policies and proposals in the Plan, an updated programme for which was approved by the Enterprise and Infrastructure Committee on 20 November 2014 (Art 13/546). As part of this programme, the Landscape Supplementary Guidance was consulted on for a period of 8 weeks from 28 November 2014 to 19 January 2015

1.2 The Scottish Government’s Chief Planner wrote to all Heads of Planning on 15 January 2015 suggesting that there needs to be a different approach taken towards supplementary guidance. His letter discusses the fact that different authorities are taking different approaches to supplementary guidance, not all of which are appropriate. It states that it is “essential that supplementary guidance is limited to the provision of further information or detail and that the local development plan expressly identifies the matters to be dealt with in supplementary guidance”. Having reassessed the proposed supplementary guidance, we are confident that it is compliant with this new guidance as it is referred to specifically within the plan and provides further, technical guidance in respect of the policies in the plan.

1.3 Under The Town and Country Planning (Scotland) Act 1997 (as amended) and the Town and Country Planning (Development Planning) (Scotland) Regulations 2008, Supplementary Guidance can be adopted and issued by a planning authority. Any such guidance issued and consulted upon will form part of the development plan. It should be noted that the comments received are not subject to Examination by a Reporter.

99 1.4 This Supplementary Guidance (SG) has been produced to incorporate the review and update of Local Landscape Designations in Perth and Kinross into the Council’s planning policy framework. The previous designations around Perth were made in the 1980s and were designated with a less rigorous methodology than is now available. Consequently, it was considered that it was opportune to undertake a complete re evaluation across the whole of Perth and Kinross. Prior to the Local Development Plan coming into effect, the Area of Great Landscape Value designations‐ were concentrated on the area around Perth and in Kinross-shire. The re evaluation was therefore intended to consider the full range of areas of landscape quality through an up to date and consistent methodology. ‐ 1.5 This report briefly outlines the context, the contents of the Supplementary Guidance, considers the comments received, and suggests changes to the Supplementary Guidance where considered appropriate. The Landscape Supplementary Guidance has been prepared to support Policy ER 6 (Managing Future Landscape Change to Conserve and Enhance the Diversity and Quality of the Area’s Landscapes) and help bring forward land management initiatives to protect and enhance the Local Landscape Areas. It was developed in partnership with the Landscape Review Panel through a series of workshops facilitated by Land Use Consultants (LUC) and the STAR Development Group. The consultants and Review Panel are to be commended for the work undertaken to help inform the Supplementary Guidance.

2. POLICY CONTEXT

2.1 This supplementary guidance document supports European and national policies and initiatives relating to landscape and the following paragraphs outline the policy and statutory context within which the guidance sits.

European Landscape Convention

2.2 The European Landscape Convention (ELC) came into force in the UK in March 2007. The Convention established the need to recognise landscape in law; to develop landscape policies dedicated to the protection, management and planning of landscapes; and to establish procedures for the participation of the general public and other stakeholders in the creation and implementation of landscape policies.

Scotland’s Landscape Charter

2.3 Scotland’s Landscape Charter (2010) encourages action from everyone to fulfil its vision to ensure that all Scotland’s landscapes are protected for future generations.

National Planning Framework

2.4 The National Planning Framework for Scotland 3 (NPF3) recognises the contribution Scotland’s landscapes makes to our quality of life, our national identity and the visitor economy.

100 Scottish Planning Policy

2.5 Scottish Planning Policy (SPP) is the Scottish Government's policy on nationally important land use planning matters. The policy outlines the need for planning authorities to protect, enhance and promote “access to natural heritage, including green infrastructure, landscape and the wider environment” (para 29).

Wild Land

2.6 The Scottish Government's third National Planning Framework, published in June 2014, recognises wild land as a "nationally important asset", and indicates Scotland's wildest landscapes merit strong protection. Scottish Planning Policy sets out how this should be achieved. This includes the identification of wild land and its safeguard in Development Plans and in Spatial Frameworks for onshore wind farms, and the need for development to "demonstrate that any significant effects on the qualities of these areas can be substantially overcome by siting, design or other mitigation". (SPP paragraph 215)

Hierarchy of Landscape Designations

National Scenic Areas

2.7 NSAs are designated under Section 263A of the Town and Country Planning (Scotland) Act 1997, and are defined as “of outstanding scenic value in a national context.” The legislation also states that within an NSA “special attention is to be paid to the desirability of safeguarding or enhancing its character or appearance.” It should be noted that there is no overlap with the Local Landscape Areas (LLAs) although as Map 1 shows a number of the Local Landscape Areas abut NSAs.

National Parks 2.8 The National Parks (Scotland) Act 2000 enabled the establishment of National Parks in Scotland. The purpose of National Parks is to conserve and enhance landscapes within the countryside whilst promoting public enjoyment of them and having regard for the social and economic well being of those living within them. In addition, they are designated to promote the sustainable use of the natural resources of the area and the sustainable social and economic development of its communities. These purposes have equal weight and are to be pursued collectively unless conservation interests are threatened.

Gardens and Designed Landscapes

2.9 The Inventory of Gardens and Designed Landscapes (GDL) identifies sites of national importance and provides information about them ensuring that change is managed in an appropriate way, taking into account the qualities and significance of these landscapes and their constituent elements. This means seeking to retain key landscape features and characteristics for the future, while also allowing the landscape to adapt to modern demands. Under the Town and Country Planning (Development Management Procedure) (Scotland) Regulations 2013, planning authorities are required to consult Historic Scotland on development proposals that they consider may affect an Inventory Garden or Designed Landscape. It should be noted that a number of the LLAs contain GDLs within them.

101 Wild Land Areas

2.10 Wild Land Areas are identified as nationally important in Scottish Planning Policy, but are not a statutory designation. Scottish Natural Heritage published a new map of wild land areas in June 2014. It should be noted that there is an overlap between some Local Landscape Areas and Wild Land Areas.

Local Landscape Areas

2.11 Scottish Planning Policy sets the requirement for Local Planning Authorities to designate locally important landscapes. Local landscape designations are shown in local development plans, and have associated policies to safeguard their valued features. LLAs complement the National Scenic Area designation, which identifies those landscapes that are seen as nationally important owing to their unsurpassed scenery. Whilst two of the LLAs adjoin the Parks, there is no overlap.

3. BACKGROUND

3.1 Perth and Kinross is renowned for its high quality, distinct and diverse landscapes, many of which form a significant part of Scotland’s natural and cultural heritage. These landscapes are an important resource that contributes to the social and economic well-being our area. They provide the surroundings for our daily lives, adding positively to the quality of life and economic performance of the area. And they provide the special places whose character and scenic quality is the main attraction for sport, tourism and outdoor recreation and can contribute to health improvement and wellbeing.

3.2 The landscape character of Perth and Kinross is constantly changing as a result of various forces that affect the physical appearance of the landscape and consequently, landscape character. By controlling the location, siting and design of new development and proactively planning for change, we will have a strong influence on the nature of change and the character and appearance of the landscape.

3.3 There are various factors which affect the change to landscape character; for example renewable energy projects, meeting the area’s housing requirements, improving infrastructure, creating employment sites and improving countryside management. Both the Council and the Scottish Government have recognised the need to marry development and environmental protection in order to achieve a balanced approach to implementing wide-ranging policies. Concern for the landscape is, therefore, part of wider efforts for a more sustainable future.

3.4 While it is important to value all landscapes, this is not a substitute for identifying and taking action for landscapes which merit special attention; either because they are of particular value and warrant protection or because they are degraded and require active management or positive restoration or are under threat from inappropriate development. Consequently, in order to meet these challenges, we need to do more than just identify important or “high quality” landscapes.

102 3.5 In addition to the core landscape policy, a number of other LDP policies and proposals support the promotion and development of green infrastructure in Perth and Kinross of which landscape is a key part. The Forest and Woodland Strategy also recognises the importance of landscape and has guidelines relating to tree and woodland planting for landscape mitigation, existing woodland management and new planting. The Forest and Woodland Strategy accords with the landscape sensitivities and guidelines covered in this supplementary guidance. In addition, the Place- making Supplementary Guidance recognises the importance of landscape at all scales.

3.6 In summary, the purpose of this supplementary guidance is to help developers, land managers and decision makers to take appropriate steps to protect, manage and enhance the landscapes of Perth and Kinross. The guidance is intended to ensure that Perth and Kinross’s landscapes are protected, enhanced and well managed for future generations as a place to live and work. It is emphasised that the Local Landscape Areas Supplementary Guidance does not duplicate or provide guidance for National Scenic Areas, Gardens and Designed Landscapes or Wild Land Areas. These national designations have their own guidance and management initiatives.

3.7 Copies of the Supplementary Guidance together with the consultant’s Report are available online.

4. LOCAL LANDSCAPE DESIGNATIONS

4.1 The objectives of the study can be found in full in the Consultant’s Report but in summary they were to:

 Review the purpose, coverage and function of the former Areas of Great Landscape Value (AGLVs).  Define and implement a clear methodology for proposing new Local Landscape Areas (LLAs).  Assess the Perth and Kinross landscapes to identify areas which merit protection as LLAs and areas that do not.  Identify the local landscape character and qualities of individual LLAs and previous AGLVs.  Develop draft Supplementary Guidance (SG) based on the review of AGLVs and identification of LLAs.  Improve the effectiveness of Local Development Plan Policy ER6 by providing robust and defensible LLAs.

4.2 The role of the Local Landscape Area designations is part of an “all-landscapes approach”, outlined in SNH/HS Guidance which emphasises the need to:

 safeguard important landscapes and landscape features which are particularly valued and may have limited capacity for change;  promote understanding and awareness of the distinctive character and special qualities of the landscapes of a local authority area;

103  promote some of the most important outdoor settings for recreation and tourism within a local authority area; and  contribute to wider policies for guiding urban expansion, by specifically identifying and safeguarding areas of landscape importance within, or close to, existing settlements.”

Structure of Information on Local Landscape Areas

4.3 In order to ensure consistency across Perth and Kinross, evaluation criteria were developed and agreed by the Landscape Panel and the Project Steering Group. These are shown in Appendix 1. The Landscape Review Panel was an important part of the overall process and was established involve a range of stakeholders in helping to guide the review and share their knowledge.

4.4 The first meeting in April 2014 introduced the review and the reasons why it was needed, along with an explanation of the process that was to be used to assess potential candidate areas. Importantly, this created an opportunity for the participants to share their knowledge about the potential areas that should be considered for designation. The second meeting in May allowed Land use Consultants to present their suggested candidate areas which were informed by the Review Panel and provide further advice and comment. The third meeting in June considered recommendations from the consultants and the draft report.

4.5 The Review Panel used the evaluation criteria to demonstrate the reasons for their choices, and to identify which criteria were represented in their selections. Participants used a map of the area to record their selected landscapes, and in many cases identified features, such as important views, within those areas.

4.6 It should be noted that people were asked to use the same criteria when commenting on the draft document to ensure that, if they were suggesting new areas to be included as Local Landscape Areas, the same criteria were used to ensure consistency.

4.7 Appendix 6 to this Report details the 47 areas considered and the evaluation results using the above criteria which resulted in the 11 candidate Local Landscape Areas being identified and subsequently consulted upon. The 11 candidate LLAs are spread across Perth and Kinross – and consist of a range of highland and lowland areas covering some 1444 km2, or around 27% of Perth and Kinross. These are shown in Map 1 below. They complement but do not overlap with the National Parks and National Scenic Areas.

104 Map 1: Candidate Local Landscape Areas, National Scenic Areas and National Parks

4.8 The following are provided for each Local Landscape Area:-

1. A map showing the location and boundaries of the Local Landscape Area. 2. Description of the Local Landscape Area. 3. Key Qualities of the Local Landscape Area. 4. Objectives.

4.9 In addition to the designation of Local Landscape Areas, Policy ER 6 recognises the importance of protecting ‘wild land’ areas in bullets (c) and (d) which state:

“(c) they safeguard the tranquil qualities of the area’s landscapes; and (d) they safeguard the relative wildness of the area’s landscapes”.

4.10 Consequently, the supplementary guidance includes 6 of the 42 Wild Land areas shown on the SNH map and makes clear that the supporting statements when published by SNH will be material considerations when development proposals are considered. This is in line with the requirements of Scottish Planning Policy. The areas wholly or in part are:

10 Breadalbane - Schiehallion 11 Lyon - Lochay 12 BenLawers 14 Rannoch – Nevis – Mamores -Alder 15 Cairngorms 16 Lochnagar–MountKeen

105 Map 2: Wild Land areas

4.11 In the context of the Local Landscape Areas where wildness is one of the ‘special qualities’, there is clearly an overlap between the LLAs and the Wild Land Areas. In those instances, the SNH descriptions and guidance will be a material consideration.

5. KEY CONCERNS, RESPONSES AND PROPOSED CHANGES

5.1 The key concerns, responses and proposed changes are highlighted below. Appendix 2 provides the comments received and the recommended Council response to these.

5.2 Twenty-seven individuals, organisations, communities, and NGOs commented on the draft Guidance, 35 individuals attended the 3 workshops, 220 individuals responded (the majority were local) to the online survey and nominated 500 ‘favourite’ landscapes. Whilst relatively few responses were received, the comments made were helpful and have helped shape the final document, allowing a number of modifications and improvements to be made.

5.3 Whilst there was overall support for the aims of the Supplementary Guidance, there was much detailed comment. The comments raised through the consultation process can be grouped into a number of key issues and these are set out below. Full details of all the comments received, the revised Landscape Supplementary Guidance and associated Consultant’s Report are available online and copies can be downloaded (http://www.pkc.gov.uk/landscape).

106 Overall vision and aims of the Landscape Supplementary Guidance

5.4 There was general support for the aims of the Supplementary Guidance and how this was to be achieved. It was considered that the guidance will be “a valuable tool in contributing to the maintenance and enhancement of the quality of place in Perth and Kinross” (SNH). It was also considered that it would help deliver the aims of the Scottish Landscape Charter.

Context, current resource and opportunities

5.5 The setting out of the context for the guidance and the existing resource was welcomed and it provided important local context. However, there was some concern that there was insufficient clarity around the purpose and scope of the guidance. These issues have been addressed by adding additional diagrams showing the linkages with other policy and Supplementary Guidance. In addition, specific reference was made to the role of landscapes to outdoor learning, sport, recreation and activity as a way of contributing to the rural economy. The Supplementary Guidance has been amended to make this more explicit to accommodate the changes suggested by sportscotland.

5.6 The geographic spread of the Local Landscape Areas was welcomed and, in general terms, all of the candidate LLAs were supported. However, the Kinross-shire Civic Trust and others, whilst welcoming and supporting the Local Landscape Areas covering the Ochil Hills and Loch Leven and Bishophill, expressed concern that the Cleish Hills and the Devon Gorge had not been put forward as a Local Landscape Area. This matter is covered in paragraph 5.12 below.

Methodology and style of presentation

5.7 The methodology adopted in the development of the Supplementary Guidance was considered to be “robust and a model of good practice” by most respondents. The John Muir Trust commented that “The Council is to be commended on its inclusive, open and consultative approach”. Scottish Natural Heritage expressed similar sentiments and it said that it was “pleased to be a member of the Steering Group to guide the methodology for this work”. Whilst the majority of respondents were happy with the methodology adopted, two respondents had major concerns and suggested that “the Council embarks on an urgent programme of work to address the key force for change in the landscape incorporating, as a minimum:

a. An evaluation of the current landscape resource – drawing to an extent on the work to date b. An evaluation of the effects of wind farm development, including consented but unbuilt schemes, on that landscape resource to identify where the landscape resource has already been compromised c. The identification of landscape areas that should be protected d. The incorporation of that work into Supplementary Guidance and a Spatial Strategy developed in accordance with SPP2 but to include, as a relevant and additional factor, the consideration of cumulative impact”.

107 5.8 Another respondent considered that “the scope and reach of the ‘stakeholder engagement’ elements of the LLDR was very unsatisfactory. It is superficial, biased and flawed”.

5.9 Whilst it is acknowledged that methodologies and stakeholder engagement can always be improved upon, it should be noted that the project Steering Group consisted of a SNH landscape advisor, together with representatives from Community Greenspace and Planning and Development and they all agreed the methodology and stakeholder engagement. The methodology used was based on the methodology developed by SNH and Historic Scotland and adapted in light of experience in its use. In terms of stakeholder engagement, the Council invited anyone who had commented on the landscape or related policy in the Local Development Plan to participate in the Review Group. It should be noted that not everyone was able to attend all three workshops. In addition, the opportunity to participate in the Review was ‘advertised’ prominently on the Council’s web site and all those who responded participated in the Review Group Workshops. Some 100 individuals or representatives of organisations from across Perth and Kinross were invited and around 30 attended the 3 workshops. A list of those who attended can be found in Appendix 4 to this Report.

5.10 In terms of the online survey, people were invited by email to participate in the survey, it was advertised on the Council’s web site and a press release was issued inviting people to participate.

5.11 In summary, it is considered that the methodology was not flawed nor was people’s ability to participate in the process restricted. Consequently, it is not considered necessary to start the process again.

5.12 As can be seen from the comments received (Appendix 2), the biggest and most contentious issue relates to Kinross-shire and its relationship with the hills that surround it. Whilst all respondents from the area welcomed the inclusion of the Ochil Hills and Loch Leven and Benarty Hill as potential Local Landscape Areas, some concern was raised about the boundaries. These are largely technical in nature in that they suggest extending them to make the boundaries more consistent with features in the landscape or to align them with designated areas in adjoining local authority areas. In the main, the suggestions have been accepted i.e. to extend the north western boundary of the Ochil Hills LLA and extend the northern boundary of the Loch Leven LLA (see Appendix 3). In one instance (the suggested change to the north eastern boundary of the Ochil Hills to the M90), it is recommended this should be rejected as it is no more ‘firm’ than the one in the draft Supplementary Guidance.

5.13 The second issue is the suggestion that two further Local Landscape Areas are designated. One covers the Devon Gorge and the second covers the Cleish Hills. These were suggested and supported by the Kinross-shire Civic Trust, Muckart Community Council, Cleish and Blairadam Community Council, Councillor M Barnacle, Fife Council, Fossoway & District Community Council, Friends of the Ochils, J Hampson, K Myles, Portmoak Community Council, and S Dean.

108 5.14 It should be emphasised that the Steering Group and the Consultants had long discussions and carefully considered these areas prior to the completion of the study and the completion of the Report. It had been anticipated that it was likely that representations would be received on these areas. The active participation of individuals, Community Councils and other groups is welcomed, and their discussions and submissions are well thought out.

5.15 In terms of the suggestion that the Devon Gorge is designated as a Local Landscape Area, it is acknowledged that the area is attractive and an important geological feature. However, it is not considered appropriate to designate the area as a Local Landscape Area given its small scale in comparison to the other more extensive candidate LLAs. There are other areas similar in nature elsewhere in Perth and Kinross which have not been designated; for example, Craighall Gorge, north of Blairgowrie or the Deil’s Cauldron near Comrie. In light of the above and the work undertaken by the consultants, it is not considered appropriate to designate the Devon Gorge as Local Landscape Area. This is not to diminish the importance of the landscape to the people of the area.

5.16 The Cleish Hills have also been suggested and again were considered as part of a wider area of search covering the Loch Leven Basin for a Local Landscape Area. However, it was recognised through the evaluation that whilst the Loch Leven Basin had elements which scored highly in the evaluation criteria it did not score as highly as the 11 candidate LLAs. The criteria was designed to ensure that there is consistency in the assessment across Perth and Kinross. Consequently, whilst the Cleish Hills are an important element in the Kinross-shire landscape they do not ‘score’ as highly as other parts of the ‘search’ area in terms of their high scenic quality, recreational value and cultural associations. That is not to diminish their importance to local people.

5.17 It is important to note the findings cannot be directly related to the findings of other similar studies carried out in relation to other localities i.e. while the Cleish Hills are designated in Fife it does not necessarily follow that they would merit designation in Perth and Kinross. This point is acknowledged by Fife Council who appreciate the need to ensure consistency in the assessment and that the landscapes identified in Perth and Kinross will not necessarily mirror those proposed in adjoining Council areas. Consequently, given the above it is not considered that there should be a Local Landscape Area covering the Cleish Hills.

6. CONCLUSION AND RECOMMENDATIONS

6.1 This report provides an update on the changes that are suggested to the Landscape Supplementary Guidance as a result of public consultation. Following consideration of this report, the guidance will be finalised and submitted to Scottish Ministers. On completion of this process, the guidance will become statutory policy and have the same status as the Development Plan.

6.2 It should be emphasised that should Members wish to significantly change the Supplementary Guidance by way of introducing new Local Landscape Areas, significantly changing boundaries or amalgamating Local Landscape Areas, it will be necessary to open up the guidance to further consultation. This will clearly lead to significant delays in having protection for some of the area’s most sensitive landscapes.

109 6.3 The Committee is asked to:

i) Approve the Landscape Supplementary Guidance as a key policy documents to support the Local Development Plan;

ii) Remit the Executive Director (Environment) to finalise the Supplementary Guidance and submit it to Scottish Minister prior to adoption;

iii) Remit the Executive Director (Environment) to approve minor changes to the Supplementary Guidance if requested by Scottish Ministers and proceed to adoption.

Author Name Designation Contact Details Graham Esson Team Leader [email protected] Sustainability, Policy & Extension 75383 Research

Approved Name Designation Date Barbara Renton Depute Director 16 March 2015 (Environment)

110 ANNEX

1. IMPLICATIONS, ASSESSMENTS, CONSULTATION AND COMMUNICATION

Strategic Implications Yes / None Community Plan / Single Outcome Agreement Yes Corporate Plan Yes Resource Implications Financial None Workforce None Asset Management (land, property, IST) None Assessments Equality Impact Assessment Yes Strategic Environmental Assessment Yes Sustainability (community, economic, environmental) Yes Legal and Governance None Risk None Consultation Internal Yes External None Communication Communications Plan None

1. Strategic Implications

Community Plan / Single Outcome Agreement

1.1 This section should set out how the proposals relate to the delivery of the Perth and Kinross Community Plan / Single Outcome Agreement in terms of the following priorities:

(i) Giving every child the best start in life (iii) Promoting a prosperous, inclusive and sustainable economy (iv) Supporting people to lead independent, healthy and active lives (v) Creating a safe and sustainable place for future generations

Corporate Plan

1.2 This section should set out how the proposals relate to the achievement of the Council’s Corporate Plan Priorities:

(i) Giving every child the best start in life; (iii) Promoting a prosperous, inclusive and sustainable economy; (iv) Supporting people to lead independent, healthy and active lives; and (v) Creating a safe and sustainable place for future generations.

111 2. Resource Implications

Financial

2.1 The Head of Finance has been consulted in the preparation of this report. There are no financial implications arising directly from the recommendations of this report.

Workforce

2.2 None.

Asset Management (land, property, IT)

2.3 None.

3. Assessments

3.1 An Integrated Appraisal of the Green Infrastructure Supplementary Guidance has been undertaken using the Integrated Appraisal Toolkit which combines the functions and requirements of Equality Impact Assessment, Sustainability Assessment and the pre-screening / screening for Strategic Environmental Assessment. The Integrated Appraisal in relation to this report can be viewed here [http://www.pkc.gov.uk/landscape]

Equality Impact Assessment

3.2 Under the Equality Act 2010, the Council is required to eliminate discrimination, advance equality of opportunity, and foster good relations between equality groups. Carrying out Equality Impact Assessments for plans and policies allows the Council to demonstrate that it is meeting these duties.

3.3 The Forest and Woodland Strategy Supplementary Guidance was considered under the provisions of the Equality Act 2010 using the Integrated Appraisal Toolkit with the following outcome:

(i) Assessed as relevant and the following positive outcomes expected following implementation:

 The Supplementary Guidance supports the land use policies and proposals of the LDP. The implementation of the Guidance is not determined by a person’s race, gender, disability or any other protected characteristic. The benefits of the Landscape Supplementary Guidance will be equally accessible to all and therefore the Guidance should have a neutral impact on the population in terms of equality.

Strategic Environmental Assessment

3.4 The Environmental Assessment (Scotland) Act 2005 places a duty on the Council to identify and assess the environmental consequences of its proposals.

112 3.5 The Landscape Supplementary Guidance was considered under the Environmental Assessment (Scotland) Act 2005. However, it was screened out as the Assessment of the policy framework undertaken for the Local Development Plan’s Main Issues Report was considered to be sufficient as there was no change to the core Policy.

Sustainability

3.6 Under the provisions of the Local Government in Scotland Act 2003 the Council has to discharge its duties in a way which contributes to the achievement of sustainable development. Under the Climate Change (Scotland) Act 2009 the Council also has a duty relating to climate change and, in exercising its functions must act:

 in the way best calculated to delivery of the Act’s emissions reduction targets;  in the way best calculated to deliver any statutory adaptation programmes; and  in a way that it considers most sustainable.

3.7 The proposals have been considered under the provisions of the Local Government in Scotland Act 2003 and Climate Change Act using the Integrated Appraisal Toolkit. The Supplementary Guidance supports the policy framework set out in the Local Development Plan which seeks to achieve sustainable development and reduce the impact development through its vision, strategies, policies and proposals. A key aim of the Supplementary Guidance is to manage the areas landscape resource for current and future generations. The Supplementary Guidance will, therefore, have a positive impact on the sustainable development of the area.

Legal and Governance

3.8 The Head of Legal Services has been consulted.

Risk

3.9 None.

4. Consultation

Internal

4.1 The Council’s Development Management, Greenspace and Flooding Teams, and Elected Members were consulted in the preparation of the supplementary guidance considered in this report.

External

4.2 A full public consultation has been undertaken in the preparation of the supplementary guidance considered in this report. Feedback was received from the public, NGOs, land managers and other agencies including SNH, SEPA, Historic Scotland and sportscotland.

113 5. Communication

5.1 None.

2. BACKGROUND PAPERS

Adopted Local Development Plan, February 2014 Local Landscape Areas Review, LUC, 2014 Letter from the Chief Planner, January 2014

3. APPENDICES

Appendix 1 – Evaluation Criteria Appendix 2 – Summary of the consultation comments and the recommended responses. Appendix 3 – Map showing suggested changes in Kinross-shire Appendix 4 – List of respondents to consultation Appendix 5 Members of the Local Landscape Designations Review Panel Appendix 6 – Local Landscape Areas, Evaluation Report online Appendix 7 – Local Landscape Areas, Consultation Questionnaire online Appendix 8 – Updated Local Landscape Areas Supplementary Guidance online

114 Appendix 1 Evaluation Criteria Criterion Question

Does the landscape contain features, or combinations of features, Identity and that are distinctive of Perth and Kinross, making a positive sense of place contribution to its wider identity, image and sense of place?

Does the landscape contain features or a combination of features Rarity which are rare or unique within Perth and Kinross, or which are known to be uncommon elsewhere?

a) Is the landscape intact or has it experienced a decline in quality? Are present and future changes likely to lead to such decline, for example as a consequence of changes in landscape management, Intactness and patterns of development, or the influence of development in condition adjacent areas? b) Are the landscape features or combinations of features in a good state of repair?

Does the landscape display characteristics of wildness, including perceived naturalness, lack of modern artefacts or structures, Wildness rugged or physically challenging landform or remoteness / inaccessibility?

To what extent is the landscape of scenic value in its own right or Scenic qualities to what extent does it contribute to the scenic qualities of the wider area?

To what extent is the landscape enjoyed by local people and visitors, for example in the form of walking, cycling or horse riding, Enjoyment or in the form of more formal recreation activities, which are focused on enjoyment of the landscape?

a) Do built heritage assets have a significant influence on the Built heritage character of the landscape? assets b) Does the landscape provide key views, in to and away from, important built heritage assets?

Does the landscape have specific historic or cultural associations Cultural (including literature, music, art, local history or particular spiritual qualities associations) or does it contribute to the wider cultural heritage of the area?

Naturalness and Do features of natural heritage interest, including important natural heritage habitats, protected sites, and features of geodiversity value make a assets significant contribution to the landscape?

115 Criterion Question

Settlement How important is the landscape in providing the setting for setting settlements as a whole, or particular aspects of a settlement?

Does the landscape provide key views into and out of the Views landscape?

116 Appendix 2 Analysis of Comments on the Landscape Supplementary Guidance

GENERAL sportscotland We note references to physical characteristics of the landscape which are important to sporting interest; and indeed references to sporting / recreation interests, and welcome the fact that these features are recognised as well as visual landscape qualities. Examples in this respect include the Loch Tay special quality of “Focus for tourism and recreation; walking; riding, sailing, canoeing and more,” and the Loch Leven and Lomond Hills Special Quality of, “Essential recreation resource for the region…as well as walking and cycling.” This is important in recognising, promoting and protecting the attributes which make these areas desirable for sport. We also welcome the tone which is clear that SLA designation is not intended to restrict development. It is clear that the focus is to ensure any development is of a high quality, for example where recreation is identified as a force for change; then an objective is noted as ensuring high quality design. Certain forms of development associated with outdoor sports and access have a specific locational need; and it is considered that this draft SG makes provision for this type of development. With regard to terminology, it would be our preference if ‘sport’ is referenced separately from recreation and tourism. Reference to ‘sport’ could be added throughout the document, including at page 10 e.g. in the 3rd bullet point under paragraph 4.2, and at number 6 of 10 in the list under paragraph 4.3. Whilst ‘sport’ is a subset of both recreation and tourism, there are certain physical qualities of landscape which are of particular benefit to sport, for example gradient, rock formations, the presence and type of water. It can be helpful for sport to be referenced separately to highlight these particular features and requirements. Response: Support welcomed. It is accepted that sport should be referenced separately from recreation and tourism. Action: Changes made to text John Muir Trust Having had the opportunity to contribute to the development of this guidance at an early stage we appreciate being able to comment on the final Draft. The methodology used in preparing this document is we believe both robust and a model of good practice. The Council is to be commended on its inclusive, open and consultative approach. We fully support the approach taken to standardise terminology in line with SNH guidance and believe the use of the term Special Landscape Area is applied in a measured and appropriate manner throughout the document. This document when finally implemented will be a very useful addition to guidance on landscape types and use. Response: Support welcomed Action: None required Scottish Natural Heritage Thank you for forwarding the consultation for the Local Development Plan (LDP) Supplementary Guidance (SG) on Landscape. We have been pleased to be a member of the Steering Group to guide the methodology for this work. We welcome the production of this guidance as a valuable tool in contributing to the maintenance and enhancement of the quality of place in Perth and Kinross. Response: Support welcomed Action: None required

117 Kinross-shire Civic Trust It is not clear from the document as it stands where it will stand as a Supplementary Guidance document and what its status will be in Planning terms. Is it simply a guidance document or will it have enforcement category. It is recognised that Local Plan policies can be reversed by a local authority, but only if the authority justifies its decision in reversing that policy in coming to a decision on a particular application. It is noted that there is no specific Policy offered for the Special Landscape Area, but that this Supplementary Guidance will reinforce Local Plan Policy ER6. It is noted that specific Candidate Local landscape Areas are offered and defined. The Trust strongly supports the DRAFT Candidate Local Landscape Areas Nos 10 and 11, the Ochil Hills and Loch Leven and Bishophill. However it is astonished at the gross omission of the Cleish Hills as a Candidate Local Landscape Area. Response: Support for the Ochil Hills and Loch Leven & Bishop Hill Local Landscape Areas. Rather than duplicate matters the response to the suggested Cleish Hills LLA can be found below. Action: See below Forestry Commission Scotland Para 2.7 page 3. We support this general statement Para 2.22 page 5. We support this general policy Figure 1 page 6. We welcome the link to the Forest and Woodland Strategy adopted by Perth and Kinross Council. Response: Support welcomed Action: None required Forestry Commission Scotland Throughout the document there is an inherent bias towards native woodland species. This is not in keeping with the Forest and Woodland Strategy or Scottish Government policies. There needs to be recognition of the importance of woodland planting and traditional tree species within Perth and Kinross. It is therefore important to ensure that future woodland creation maintains and enhances this legacy that makes the landscape of Perth and Kinross so special to start with. There also needs to be recognition of the impact that changes in farming practices, the Common Agricultural policy and farming subsidies could and will have on future land based activities and the potential for change. Response: It is not accepted that there is an ‘inherent bias’ towards native woodland species in the document as many of the candidate areas contain plantation and commercial woodlands and their importance to the landscape Is recognised. However, what the document recognises is that there may be opportunities to plant woodlands including ‘traditional’ tree species and native species to enhance the landscape. Clearly the Forest and Woodland Strategy will assist in identifying the most appropriate locations for new planting. Clearly there is the potential for changes in European Policy and subsidies which could have an impact on the landscape. Action: Additional text added recognising the importance of woodland planting and ‘traditional’ tree species in Perth and Kinross. The Braes of the Carse Conservation Group We generally welcome the proposals and are very supportive of the strategy and policy behind the designation. Response: Support welcomed Action: None required

118 Glen Lyon & Loch Tay Community Council This is a welcome document and we would be pleased to see all the candidate areas designated as Special Landscape Areas. Response: Support welcomed Action: None required Friends of the Ochils Friends of the Ochils fully supports the proposed Special Landscape Area designation for the Ochils as described in the Draft Supplementary Guidance issued for Public Comment on 2 December 2014. Friends of the Ochils are delighted with the proposed designation of that area of the Ochils within the Perth & Kinross Council area as a Special Landscape Area. Friends of the Ochils have long been concerned that such an iconic landscape has not been granted a consistent landscape designation neither within Perth & Kinross nor across Council boundaries. The proposed Special Landscape Area designation will address these concerns. We are however aware of the recommendations being made by Drew Jamieson for the small extension of the proposed boundary of the Ochils in two areas and we fully support these recommendations. Adoption of these recommendations will ensure that robust and easily identified boundaries are used, wherever possible, to define the Ochils as far as the Perth & Kinross Special Landscape Area designation is concerned. The two areas in question are:  The north-western corner by Greenloaning (the Western Extension)  The south-eastern boundary towards Milnathort (the South Eastern Extension) Response: Support welcomed. It should be noted that the matters raised regarding extending the Ochil Hills LLA are dealt with in the section which deals specifically with the Ochil Hills LLA. Action: None required.

Muckhart Community Council Muckhart Community Council shares a border with Perth and Kinross Council and many footpaths and trails cover both the Community Council area and the Perth and Kinross Council area. In view of this strong link, we feel that it is important to respond to the above consultation and comment on the Special Landscape Areas which have relevance to Muckhart. The Community Council welcomes the designation of the candidate Ochils LLA. The document outlines well the special qualities of the area and objectives associated with the designation. In fact, the Community Council has worked closely with the Woodland Trust on the planting and management of native woodlands. The Community Council is also a Member of the Ochils Landscape Partnership which, with the help of Heritage Lottery Funds, has worked to preserve historical landscapes and vernacular buildings. Response: Support welcomed Action: None required A Godfrey “… I congratulate you on the guidance, it is well researched and thought out and easy to follow. However, I think that it concentrates too much on the far end of what might be defined as “local” and the use of the word “special” instead of “local” reflects that.” The use of the word “special” in the guidance is almost parallel to a national designation and clearly in some areas it is intended to fill in gaps between nationally designated areas. In quoting Scottish Planning Policy, the landscape consultant’s review distinguishes between locally important and regionally important. If “special” is equivalent to “local”, what is “regional” equivalent to? Perth and the surrounding area is the most local, having the largest population.

119 Perth is a beautiful city set in one of the most inspiring settings for an urban settlement. The AGLVs were not designated in such a lax manner as suggested in the consultation document and were clearly designed to protect Perth and the surroundings from the pressure of developments. Did the Director of Planning at the time lack the expertise and judgment in defending these AGLVs when under threat? I do not think so and his position was supported by the Scottish Office Reporter; therefore paragraph 1.1 in the consultant’s review is erroneous and is the basis of much of what follows. What concerns me is the lack of support for the Perth area landscape in supplementary guidance, and in the absence of which there will be lesser control over developments arising from the Local Development Plan. The consultation document states “The Local Development Plan recognises the importance of landscape at all levels and in a number of policies in addition to the core policy ER6. This supplementary guidance has been prepared to provide further detail on the application of:” and this is followed by ER6 quoted in full. The heavy bias towards the top end of the definition of “local” means the guidance cannot aspire to support the policy. In “Special Landscape Areas” the landscape is designed by land management practices which are affected in many different ways over which the planning authority has a lesser control than the area around Perth over which the planning authority has greater control and influence due to the inclusion of this area within the LDP. In defending the Local Landscape Area at one end of the spectrum, the more vulnerable area will have no guidance on landscape, and which will be affected by many more planning applications. I would recommend that suitable guidance is produced for the Perth Core Area. The quotation in the consultation document from NPF3 helps to explain further what I mean. At one end we have national parks and on the other: “Closer to settlements landscapes have an important role to play in sustaining local distinctiveness and cultural identity, and in supporting health and well-being.” In terms of the definition “local”, local means closest to where people live and in Perth & Kinross, Response: Support for the guidance welcomed. The Sidlaw Hills candidate LLA recognises the importance of Kinnoull Hill to the setting of Perth and the recreational opportunities it provides. In addition, Perth has a number of Gardens and Designed landscape which provide further protection to the area. Most importantly, however, is the Perth Greenbelt whilst not a landscape designation controls the type of development that is acceptable within its boundaries. Policy NE5 in the Local Development Plan identifies which types of developments would be or would not be acceptable. Work has started on the preparation of a management plan for the area which will be subject to consultation in due course. In addition, the Council has published Supplementary Guidance on Green Infrastructure Action: None required Graham & Sibbald (I Kelly) The LLDR lacks transparency with reference to the use of the unpublished ‘Landscape Study to Inform Planning for Wind Energy’ to inform the LLDR landscape baseline as well as the LLDR quantitative evaluation. Response: It is not accepted that the Local Landscape Designations Review lacked transparency. The Landscape Study to Inform Planning for Wind Energy is available and is in the public domain. It has been used at many recent Public Inquiries. Chapter 3 of the LLDR details how the landscape baseline was drawn up and this was agreed by the Project Steering Group which consisted of officers from the Council, SNH and the Perth and Kinross Heritage Trust. The LLDR drew upon the landscape character assessment (LCA) presented in the Landscape Study to Inform Planning for Wind Energy Final Report (David Tyldesley and Associates, 2010), referred to in LLDR as the Tyldesley Landscape Study. This refined and sub-divided some of the landscape character types and units identified in the earlier Tayside Landscape Character Assessment (TLCA) (LUC, 1999), and is therefore the most recent and detailed available characterisation of the whole of the Perth and Kinross landscape. The Tyldesley Study recognised that landscape units in the TLCA were “in some cases very extensive and provided too course a grain” and the following principles were adopted for defining landscape units: “a) All landscape units are based on landscape character assessment and each unit comprises no more than one landscape character type; b) The landscape character types are based on the types in the TLCA;

120 c) A landscape character type in the TLCA has only been divided into two or more different landscape character types (as opposed to two or more units) where it was considered that the landscape characterisation is too course and does not provide a fine enough grain for the distinction of areas with significantly different landscape sensitivity to wind energy development; d) Division of a landscape character type in the TLCA into two or more different landscape character types in this study is based on landscape characterisation only, with particular attention being paid to the 7 landscape sensitivity criteria L1 to L7 in Tables 2 and 3 of this report; no other factors have been taken into account; e) Where the TLCA already divides a landscape character type into different units, either because of spatial separation or because of slight differences in the character of the units, these sub-divisions have generally been adopted; f) The geographical extent (size) of landscape units of a single landscape character type in the TLCA were considered for subdivision only where there appeared to be significant differences across the unit, relevant to the study (for example, criteria L1 to L7 in Tables 2 and 3); g) Landscape units were adjusted where necessary following fieldwork and as other evidence emerged.” As the LLDR study notes professional judgement was used to further refine the Landscape Character Types/Units to make suitable for the purpose and to establish a “consistent and manageable baseline for the purposes of the LLDR”. All of this is explained in some detail and as a consequence it is considered that the process used in establishing the baseline is open and transparent. Action: None required Graham & Sibbald (I Kelly) The LLDR is unduly circumspect as to the effects of windfarm development on the evaluation of LLAs and their boundaries, ‘Forces for change’ and ‘Management recommendations’. Response: The effects of wind farm developments on the cLLAs is recognised and highlighted in the Forces for Change section(s). However, it is acknowledged that in some instances greater recognition of this has to be made and changes have been made to the citations for individual LLAs. Action: See changes for individual LLAs. Graham & Sibbald (I Kelly) The overall impression of the two documents, taken together, is that they are almost a theoretical academic exercise undertaken without a clear purpose. This can be illustrated by two key aspects: a. There is minimal consideration of what is without doubt the most major recent, current and future force for change in the Perthshire landscape and that is wind farms and the associated transmission infrastructure b. The draft Supplementary Guidance has no Development Management provisions at all Response: It is not accepted that there isn’t a clear purpose for the LLDR. The overall purpose agreed by the Steering Group was to:  identify Perth & Kinross landscapes which are have particular value and merit special attention as designated local landscapes.  inform a Perth & Kinross wide ‘all-landscapes’ approach and future landscape objectives.  inform the preparation of the Development Plan.  inform future design guidelines, development briefs, master plans and developers’ concept statements.  support Perth & Kinross Council’s wide ranging objectives, in terms of the key themes of the Perth & Kinross Community Plan/Single Outcome Agreement, including the Biodiversity Action Plan and Core Path Plan The Development Management provisions are contained within the Local Development Plan policy framework and in the statements contained with the Supplementary Guidance. Action: None required

121 Stirling Council Thank you for consulting Stirling Council on Perth and Kinross’s draft Supplementary Guidance on Special Landscape Areas, upon which the following comments are made. General Stirling Council welcomes the proposal to formally designate that part of the Ochils in Perth and Kinross as a Special Landscape Area. The Statement of Significance has been reviewed and its findings align well with Stirling Council's 'citation' for the Western Ochils Local Landscape Area, as set out in Supplementary Guidance SG27 - Protecting Special Landscapes (copy attached). The proposed LLA designation would also accord with relevant guidance in SPP and SNH, and will ensure a consistent approach can be taken in respect of cross boundary development and land management issues. Response: Support is welcomed. Action: None required Portmoak Community Council Portmoak Community Council makes the following comments on the Draft Consultation Document - “Landscape Supplementary Guidance”. The Council:  recognises that the Guidance is both comprehensive and thorough and that as such it will make an important contribution to the Local Development Plan.  accepts that the proposals have the potential of enabling policy ER6 of the Local Development Plan to be advanced (Managing Future Landscape Change……..); is concerned that it remains uncertain how in practice planning development will be influenced by the Guidance - including the interplay with complementary policies such as Housing in the Countryside and Conservation Areas. It believes that it is essential that the Guidance on how this interaction is intended to take place is clear and explicit so that all interested parties know what the rules are. Response: Support welcomed. As the Supplementary Guidance will form part of the Local Development Plan then potential developers will be aware that the whole document has to be read and will form part of any consideration by the Council. It is acknowledged that the interaction between policies is very important. Tithe Supplementary Guidance contains three statements which ensure that the statements of the special qualities will be used as material considerations to better evidence relevant development management decisions, and to help inform decisions on conservation and enhancement measures for management of the Special Landscape Areas. In addition monitoring of the implementation of the SG should identify any instance where additional guidance is required in the review of the LDP. Action: Emphasise the importance of policy interactions through the provision of an additional diagram and briefing of Development Management Team. P Symon As part of the public consultation on Perth & Kinross Council's draft Supplementary Guidance on Special Landscape Areas, I wish to draw attention to flaws in the methodology employed by the contractors, LUC with the STAR Group, which was published as Perth and Kinross Local Landscape Designations Review (November 2014) ("the LLDR") and which forms the basis of the draft Landscape SG. I write as a resident of the Carse of Gowrie with an interest in landscape matters. Stakeholder Engagement In particular, the scope and reach of the "stakeholder engagement" elements of the LLDR was very unsatisfactory. It is superficial, biased and flawed. It compares highly unfavourably with the comprehensive process of community engagement carried out for Fife Council by LUC and the STAR Group as part of the Fife Local Landscape Designation Review, and which was reported in a 110 page Appendix (October 2008). Review Panel

122 The work of the Review Panel appears to have been done too rapidly, to have involved too small a number of people, and to have been biased toward certain interests deemed to be "stakeholders" by the Steering Group. No evidence is given to support the claim (LLDR, 2.5) that the invitation-only group of "around 30 people" was "representative" of "interest, background and geography" across the Council area. We are given no details of how members were selected, including selection criteria. No information, whether in summary form or in transcripts of proceedings, is given of the extent to which each panel member actually participated in workshops or otherwise contributed inputs to the project. At the very least, a list of members of the Review Panel should have been published, but was not. We are told for example that "farm, estate and woodland" interests were included, giving immediate rise to suspicion that landed vested interests may have had an undue influence over the selection of the candidate LLAs, or that certain geographical interests may be overly represented (for example, the list of background information acknowledges "materials submitted by Friends of the Ochils"). We are left wondering, "Who are these people?" and it is surely appropriate for such information to be placed in the public domain. Questionnaire Survey There is insufficient information presented to be able to judge whether or not the questionnaire survey was sufficiently well-publicised. Certainly the response rate was far too low to be considered in any way statistically representative. A response of 220 individuals (the exact number is not disclosed, the total number of respondents being stated as "more than 220", LLDR, p. 54), is well below the number required for a survey to be statistically representative, for which a standard rule of thumb in survey design good practice is at 1,000 respondents (regardless of population size or response rate). Furthermore, it is untrue to state, as on LLDR page 54, that "the great majority of [online survey] respondents were local residents". Only 56 per cent, little more than half the respondents were residents of Perth & Kinross, i.e. only 123 of the 220 respondents were residents. Almost one in every two of the respondents was not a local resident (even although some of them did have a local connection, through work, leisure or otherwise). Of these 123 respondents, an unknown number would have been selected purposively by contractors, as we are informed that [an invitation to participate in] the Online Survey was "sent to interested parties" (LLDR, 2.6). Not only is the online survey therefore unrepresentative, it is also probably the case that responses to the survey reflect a selection bias towards "interested parties". At best, with a response of just over 100 residents of Perth & Kinross, the purpose of the survey should have been restricted to the formulation of questions suitable to be cast in a closed- response format in a subsequent, much larger, statistically representative survey. It should also be noted that the survey was conducted only a few weeks prior to the Independence referendum, probably contributing to reduced reach of the survey in the local population. Response: Whilst appreciating much can be done to improve community engagement and we can learn from the work undertaken for this study it is considered that the techniques used were innovative and resulted in a more informed study. Our understanding is that workshop sessions with a ‘Review Panel’ did not form part of the work undertaken in Fife and those who participated in the Fife consultation were not actively involved in identifying any Special Landscape Areas. The purpose of the Fife workshops was:  To provide further information on the project process;  To discuss the results emerging from the technical process;  To disseminate the results of the community engagement to date;  To gather feedback on the emerging areas, views on additional areas for consideration and views on potential boundaries for candidate Special Landscape Areas. The approach we adopted was much more inclusive as it involved the Review Panel in identifying potential areas, suggesting boundaries and the extent of the LLA and using their local knowledge to suggest/chose names for the cLLAs. The Panel was also able to review the results of the online questionnaire to help inform their suggested boundaries. Action: None required

123 P Symon Quantitative Evaluation of the Landscape While accepting that systematic evaluation of landscape on the basis of objective criteria is an appropriate methodology, unfortunately no discussion is presented on the selection of the criteria for the study. We are merely informed (LLDR 2.13) that these criteria were "agreed" with the Steering Group and Review Panel. The criteria are therefore "taken as given" even though they are peculiar to the Perth & Kinross Council case and may not be the same as those used in other Council LLDRs and, more importantly, the criteria selected may pre-determine to some extent the outcomes of the LLDR. It would have been helpful to know, for example, what criteria were considered but discarded as inappropriate, for the purposes of the present LLDR, and for what reasons. Response: In terms of the criteria used they represented a range of aspects of landscape which may help identify an area which is considered worthy of designation. They were therefore designed to identify those aspects of Perth and Kinross which the Steering Group felt would merit designation. The process of defining criteria began with the suggested aspects of landscape set out in the Guidance on Local Landscape Designations. These are presented as “aspects of landscape character” and “landscape qualities” (pp.15-16). LUC then expanded and developed these criteria in order to identify high quality or highly-valued landscapes within Perth and Kinross, in relation to the project brief. Indeed the criteria used are almost identical to those used in the Fife study although adapted in light of the consultants experience in their use in other parts of Scotland including the Scottish Borders. Change: None required P Symon Policy Context Tourism development Given that one of the stated objectives of SLA designation is the development of tourism within these areas, it seems strange that the entire Tay Landscape Partnership (TLP) area should not also be designated SLA status. One of the principal reasons for the TLP programme is to develop the area's tourism potential, which is thought to be currently insufficiently realised. Wind energy development The draft Landscape Supplementary Guidance at present leaves large areas of the highland areas of Perth & Kinross Council area relatively unprotected, being outwith candidate SLAs, including several sites which have been the recent focus of intense development pressure for wind energy development. Whether or not this is a deliberate or an unintended consequence of the combined results of the landscape evaluation criteria is not clear but, either way, the Council would be advised to anticipate criticism of its draft Landscape Supplementary Guidance as having the effect of helping to steer wind energy developments to those areas currently identified as being outwith candidate SLAs. Response: As is noted one of the objectives of the LLA designation is to support the development of tourism through the management of the areas landscapes. However, it is not the sole purpose leading to the designation of an area. If that were the case then much of Perth and Kinross would be designated. It should be noted that the purpose of the Supplementary Guidance is to support the landscape policy of the Local Development Plan it is not Wind Energy Supplementary Guidance; separate Supplementary Guidance is currently being prepared which will cover the issue. It is also emphasised that the Policy in the Local Development Plan applies to all landscapes not just those areas within the LLA boundaries. Action: None required

124 LANDSCAPE CHARACTER

Kinross-shire Civic Trust Geographically, Kinross-shire is surrounded by the Ochils, West Lomond, Bishophill, Benarty and the Cleish Hills. It is a natural Bowl which contributes to the natural landscape beauty and significance of the whole county. Loch Leven was at one time a much larger inland sea, extending as far as Crook of Devon surrounded by the hills. You cannot separate the Cleish Hills from the other surrounding hills. The Cleish Hills contribute as much to the landscape character of Kinross-shire as the others. If one crosses the Kinross-shire/Fife boundary to the south side of the Cleish Hills, the latest Local Plan by Fife Council for this area designates the land clearly as a Local Landscape Area, which is accompanied by a clear Policy in the Local Plan. Other important landscape policies also cover this area. Response: Comments noted. The issues raised are dealt with later in the document. Action: None required. Graham & Sibbald (I Kelly) the findings of the unpublished ‘Landscape Study to Inform Planning for Wind Energy’ should have been set aside; the degree to which the LLDR has been influenced by existing or future windfarm development is unclear; the extent to which the ‘Landscape Study to Inform Planning for Wind Energy’ has influenced the LLDR quantitative evaluation is unclear; whilst it is reasonable to conclude that LU 43 does not warrant consideration for inclusion within a LLA, this is a consequence of the effects of windfarm development rather than the intrinsic quality of the landscape; Response: The matter of the ‘unpublished’ study has been addressed in an earlier response but in summary it is publically available as is evidenced by its use in the critique of the LLDR. However, it needs to be emphasised that the LLDR and the consequential Draft Supplementary Guidance are not intended to be guidance for wind farm developments separate Supplementary Guidance is in preparation which will address that issue. It also needs to be emphasised that only element of Landscape Study to Inform Planning for Wind Energy used was in determining landscape units and these were in fact further refined by the consultant to ensure they were of sufficient size. Action: None required P Symon Landscape Baseline It is accepted that, as discussed in section 3 of the LLDR, it would be impractical to assess a very large number of landscape units within the constraints placed on the project. However, the methodological approach of working with higher levels of aggregation fails to take account of the fact that certain landscape evaluation criteria may only be appropriately analysed at a high level of geographical disaggregation: for example, evaluation of "Scenic qualities" is based partly on assessment of "pleasing combinations of features ... visual contrasts", entailing a finer-grained landscape analysis than for some other criteria. For example, Carse of Gowrie (38) landscape unit here includes at least two Landscape Character Types, distinguished in the study by LUC and the STAR Group for Tay Landscape Partnership (Landscape Character Assessment of the Tay Landscape Partnership Area, October 2012). Evaluation Results Applying the evaluation criteria to the landscape units, it is suggested that insufficient regard has been had in the LLDR to certain landscape features which are set out below and which may materially alter the score for the landscape units concerned. Due to time and resource constraints only a few of the most material concerns have been identified, with particular reference to those touching on the evaluation of the Carse of Gowrie (37) landscape unit.

125 Rarity Some landscape units deserve to be reclassified. Lower Glen Shee (41) possesses a unique geological feature, namely the Old Red Sandstone conglomerate incised by the Ericht gorge at Craighall, which is unique in Scotland (according to Geikie). The landscape unit therefore should be changed from "low" to "high" on the Rarity dimension. Its neighbouring landscape unit, Clunie Foothills (40), possesses several glacial kettle hole lochs which are the only such examples in Perth & Kinross and may be uncommon elsewhere in Scotland. Its Rarity score could be raised from Medium to High on this basis. Finally, although it is agreed that the inner Tay estuary contributes to the High Rarity of the Carse of Gowrie (37) landscape unit, nowhere in the LLDR is it mentioned that the Carse of Gowrie is Scotland's only "graben" (geological rift valley): this landscape feature alone makes the Carse of Gowrie unique in Scotland, thus meriting its Rarity rating as High. Wildness It is not possible to agree with the statement that Carse of Gowrie (38) landscape unit "has no or limited wildness" because to do so would only be possible were the River Tay to be excluded from that landscape unit. As a matter of fact, roughly between one quarter and one third of the land surface of the landscape unit is comprised of highly wild, intertidal offshore islands, sandbanks and mudflats of the inner River Tay estuary, much of which forms the Inner Tay Nature Reserve, and other area-based environmental designations. They include Abernethy Bank, Mugdrum Island (which, despite its proximity to the southern shore of the Tay, is in Perth & Kinross, not Fife), Carthagena Bank, Dog Bank and Kingoodie Bay mudflats. The River Tay has the largest debit of water of any water course in the United Kingdom, giving it a good claim to be the country's wildest river. However counter-intuitive it may seem, were the classification to be based on the mistaken assumption that only the highly domesticated, non-tidal, dry land area is what counts, the Carse of Gowrie landscape unit "has a high degree of wildness". Were Wildness reweighted to High to reflect the significance of the Tay landscape within the landscape unit, the total score for the Carse of Gowrie landscape unit would, before taking account of changes due to re- evaluation of other criteria, increase from 24 to 26 respectively, placing it within the top one third of landscape units that were considered for inclusion as search areas (LLDR 5.3, Table 5.1), being ranked either 14th respectively. Even if the Carse of Gowrie landscape unit were considered to be only "Medium" with respect to wildness, being comprised partly of landscapes of low and partly of high wildness, it would still score a total of 25, placing it 15th equal. It appears unreasonable to consider the Sidlaw Hills (38) to have Low Wildness, when the Ochil Hills (28) are considered to be Medium on this criteria: a field visit to Pole Hill is suggested. Scenic Qualities Clunie Foothills (40), Forest of Clunie (44), Strathardle (45) and Carse of Gowrie (37) all should be changed from Medium to High on this criterion since, in all cases, a pleasing combination of scenic qualities characterises these landscapes. Forest of Clunie includes the highly scenic and very popular recreational area around Loch Ordie. Clunie Foothills are characterised by the variegated kettle hole loch and woodland landscape surrounding the exclusive Snaigow estate area. Strathardle is an equally scenic strath to the others rated High on this dimension. Carse of Gowrie not only contains important visual contrasts within its own area, comprising low lying "firth" lands, "Carse inches" landscapes of higher land, and the riverine landscape of the inner Tay estuary sand and mud banks, reed beds and islands. The Carse landscape is also an essential element offsetting the scenery of the two landscape areas to the north east and south east, which are either candidate SLA (Sidlaw Hill) or actual SLA (Tay coast, in Fife). Enjoyment NCR 77 is also present in the Carse of Gowrie (37) as well as traversing part of the Sidlaw Hills (38). Facilities for recreation at Errol Airfield are extensively used. Efforts are being made to increase the facilities for recreation associated with the River Tay. In general its proximity to the cities of Perth and Dundee contributes to making it an area well-used for recreation and its paths network and other facilities (e.g. orchards) are being expanded by the work of the Tay Landscape Partnership.

126 Cultural Qualities Carse of Gowrie (37), Sidlaw Hills (38) and Strathmore (39) should be increased from Medium to High. Strathmore has important cultural and historical associations with the pre-Reformation church, particularly at Scone and Coupar Angus, and as a site of power at Scone. Carse of Gowrie and Sidlaw Hills form the heartland of the ancient province of Gowrie, with many cultural associations, including Jacobite history. Notable sources of local history for these areas are: Melville, L., Errol: Its Legends, Lands and People (Perth, 1935); Melville, L., The Fair Land of Gowrie (Coupar Angus, 1939); an unpublished Ph.D. thesis by Adrian N. L. Hodd, Agricultural Change in the Carse of Gowrie, 1750-1875 (University of Dundee, 1974); and an unpublished Ph.D and various recent publications by Mary Young on the history of the Carse. Historical sources often make reference to the perceived advanced state of agriculture in the Carse of Gowrie, as an early adopter area of "improvement" in methods of agricultural production. Naturalness and Natural Heritage Assets For the same reasons as stated above, with reference to Wildness, the Carse of Gowrie (37) should be rated High rather than Medium on this criterion, since natural heritage features are a key aspect of the landscape of the area. The inner Tay estuary, which forms roughly between one quarter and one third of the land area of the landscape unit, is protected by a number of Natural Heritage area designations, in recognition of the importance of these assets within Scotland and, in the case of the Ramsar designation, a wetlands area of European importance. The reed beds of the inner Tay estuary constitute a natural heritage asset of national importance. On the Carse lands to the north east of the Tay, the raised beaches are likewise a key aspect of the landscape of this landscape unit. Settlement Setting It may be necessary to upgrade the rating of Carse of Gowrie (37) from Medium to High, because the landscape makes a strong contribution to settlement identity. Almost all of the main settlements (with the exception of Errol Airfield/Grange, the coastal town of Kingoodie, and Invergowrie) are on historic "inches" or higher ground rising above what were once the lower-lying wetlands and bogs of the low Carse, examples including Kinfauns, Inchyra, St Madoes (Pitfour), Chapelhill/Hawkstone, Errol (a notable example), Inchture, Longforgan, as well as a number of smaller localities which were once fermtouns or fortified houses on the smaller areas of higher land. The unique settlement character of the Carse, in which clay drawn from the low lands was used as traditional material for the vernacular architecture of the landscape area, has long been recognised in the various sources referenced above and is relevant to the programme of work of the Tay Landscape Partnership on "clay biggins" of the Carse. Views Here the Carse of Gowrie (37) should be upgraded from Medium to High. Its landscape is important in views from key viewpoints, notably Kinnoull Hill, Moncreiffe Hill, various points in the Sidlaw Hills (38) as well as from Fife and from Dundee, as well as from the key transport routes of the A90 and the Perth to Dundee railway, where Queen Victoria famously asked for her train to be stopped so that she could admire the view of the surroundings. The role of the Carse as one of the busiest transport corridors in the Perth and Kinross area makes views from these transport routes of the highest importance for the overall landscape quality of the Council area. Relationships with other landscape units The Carse of Gowrie landscape unit not only has a relationship with the neighbouring Sidlaw Hills landscape unit (37), it also has a strong relationship with the River Tay, which is partly included within landscape unit 38, but also with the Ochil Hills, which rise steeply from the opposite bank of the river Tay in neighbouring Fife, and which has been designated as Tay Coast SLA by Fife Council.

127 Combined Results It will be easily appreciated, from the foregoing analysis of the methodology used in the LLDR that the combined results of the evaluation of the criteria for landscape designation will be quite different to those which were output in the LLDR. Constraints of time and resources make it impractical to present the revised combined results that would be output were the criticisms all taken into account. Very probably a practical result of the reworked assessment would be that the Carse of Gowrie (37) would emerge as a candidate SLA in its own right, thereby negating the need for boundary extensions to the south east of the Sidlaw Hills (38) landscape unit, and suggesting the south east boundary of the latter should form the boundary of these two SLAs. In connection with the "Search Area D" discussion in the LLDR, it should be noted that, although LLDR 6.29 states that the "farmland of the Carse of Gowrie to the southeast of the A90" is "flatter" than that to the north east of the A90, this is not actually the case. If anything, indeed, much of the land contained in the strip of land between the A90 and the Braes of the Carse includes the flattest farmland in the entire Carse of Gowrie (e.g. Myres of Megginch, Flatfield) while the landscape to the south east, in the western part of the landscape unit in particular, includes a large amount of "inch" (island) landscape - as LUC themselves have identified in their study of the landscape of the Tay Landscape Partnership area. Response: Comments noted. Action: None required

GUIDELINES FOR SPECIAL LANDSCAPE AREAS

Forestry Commission Scotland Para 4.1 page 10. As stated the document will help to assist Planners in making comments on landscape management that will include Forest management and woodland planting. It is however very important to ensure that within each of the distinct landscape zones that there are no negative or narrow focused comments that go against current Forest Policy and the Perth and Kinross Forest and Woodland Strategy. Response: Comments noted Action: None required Forestry Commission Scotland Para 4.4 page 12. There is a presumption here that if not identified in the Local area objectives that what is being proposed by land managers would not be supported. This could have significant impacts on Forest and species choice. Response: In most instances land management activities are outwith the land-use planning system and as is noted elsewhere the recently approved Forest and Woodland Strategy provides guidance to land managers on woodland planting. In any event the Council would prefer to work in partnership with land managers and others in managing the area’s landscapes. Action: Wording added to emphasise the importance of working in partnership with those with an interest in the landscapes of Perth and Kinross.

SPECIAL LANDSCAPE AREAS GENERAL

Scottish Natural Heritage The different scales of the maps of the proposed SLAs can be confusing and we recommend they are all at the same scale for consistency. 2.10 Welcome reference to the European Landscape Convention and also suggest this is referred to Appendix 1. 2.24 We support the cross-referencing to other key policies in the LDP. We recommend explicit mention of the Green Infrastructure SG, and reference to the Council’s Housing in the Countryside SG.

128 4.1 We welcome the intent that the guidance provides assistance to developers, land managers and decision makers, and also assistance to the Council in planning decisions, commenting on land management proposals and monitoring landscape change. Figure 12 is very helpful in providing context for the draft SLAs in relation to national designations and existing local designations in the surrounding local authorities. It should also refer to Wild Land Areas 2014 which though not a designation are relevant to the SLAs. 4.2 The SNH/HS guidance doesn’t ‘emphasise the need,’ rather it states that experience has shown that LLDS can be ‘particularly useful’ in the circumstances listed in the 4 bullet points. 4.4 We support the role of the SLAs in complementing NSAs and National Parks. We suggest this section relates directly to the paragraph headings in the subsequent texts individual SLAs – i.e. ‘Boundaries’, ‘Statement of Significance’, ‘Special Qualities’, ‘Forces for Change’ and ‘Objectives Response: It may not be possible to have all the maps at the same scale given the difference in size of the LLAs and as a consequence if all were at the same scale some maps would become unreadable. It is considered that there is sufficient detail in the maps to help people identify features and boundaries together with scale bars to avoid confusion. There is cross referencing to other Supplementary Guidance both in the text but also in the diagram. However it may be possible to emphasise those connections more clearly. Action: Changes to text and diagram made. Fife Council We welcome this recent work to review landscape designations using the Scottish Natural Heritage/Historic Scotland guidance, aimed at ensuring Scotland’s local landscape designations are identified using a robust and rigorous methodology. I appreciate that the landscapes identified for designation are those that are special in the context of the range of landscapes found in the Perth & Kinross Council area. Therefore, although our own Local Landscape Areas were identified using a similar methodology, they will not necessarily mirror those landscapes which are proposed within Perth and Kinross, even across boundaries. Response: Support welcomed and comments noted Action: None required Graham & Sibbald (I Kelly) The LLA boundaries should be redrawn to address the inaccuracies identified in this review and proper consideration should be given to linking LLAs 3 and 6 as well as the expansion of LLAs 7 and 8 to the west and LLA 4 to the east (to include an area to the north and west of the River Tay (Dunkeld) NSA). Response: Careful consideration has been given to the area between cLLA 3 and 6 and there was considerable discussion between the members of the Steering Group about whether the boundaries should abut one another or whether the LLAs should be combined. This latter option was subsequently rejected by the Steering Group as they are quite distinct and separate landscapes as is evidenced in the TLCA, the Tyldesley study and in LUCs assessment. A similar difficulty arises when consideration is given to abutting the boundaries as the special qualities of the glens is quite different to what is in effect an upland plateaux. Action: None required Stirling Council Terminology To ensure consistency in terminology para 139 of SPP (2010) advised planning authorities to designate landscapes of local value as 'Local Landscape Areas'. It is acknowledged that SPP (2014) is now less specific. SNH's Guidance on Local Landscape Designations (2006) proposed the term ‘Special Landscape Areas.'

129 It is the case however that both Stirling and Clackmannanshire Councils have used the term 'Local Landscape Area' for both LDP policies and related Supplementary Guidance. Whilst acknowledging the discretion available to Perth & Kinross Council to use 'Special Landscape Area' it would be the case the Ochils would have two distinct, possibly confusing, local landscape designations. Response: It is agreed that it would assist the public and others in having consistent terminology across Council areas. As a consequence the areas will be changed from Special Landscape Areas to Local Landscape Areas. Action: Change made to text to ensure consistency with adjoining authorities.

CANDIDATE SPECIAL LANDSCAPE AREAS

Rannoch Forest

Scottish Natural Heritage Amend Special Quality no. 6 to “Scenic drive along the B846 to and from Rannoch Station.” Forces for change - add hydro-schemes Objectives - replace “seek restructuring of Rannoch Forest plantations, or removal of trees for moorland restoration” with “Restore Caledonian pine and peatland mosaics in Rannoch Forest and its environs and enhance habitat connectivity.” Amend 3rd objective to “Enhance access and raise awareness of this, via Rannoch station, for a range of user groups.” Response: Comments noted and suggested changes accepted. Action: Suggested changes made Forestry Commission Scotland Page 15 – Forces for change. This could also include changes to farming and upland grazing practices that could release land for forestry. Page 15 – Objectives. ‘Seek restructuring of Rannoch Forest plantations or removal of trees for moorland restoration’ – this needs to be quantified e.g. proposed % of land to be changed etc. Response: Comments noted and suggested changes accepted. Action: Suggested changes made

Loch Lyon and Loch an Daimh

Scottish Natural Heritage Amend Special Quality no. 2 to “remote and wild landscape accessed only after long journey up Glen Lyon or minor road from Killin via Kenknock” Forces for Change - add (small-scale) hydro schemes and associated infrastructure, and new woodland planting. Response: Comments noted and suggested changes accepted. Action: Changes made. Forestry Commission Scotland Page 17, end of second paragraph. What is the significance of ‘The landscape around the Lochs is almost treeless, and tracks cut into the open hillsides are highly visible in places’. Do the guidelines advocate more tree planting? Page 18 – Objectives. This should include support for appropriate tree species and woodland expansion. Appropriate in this instance means the right tree in the right place to suit both soil and landscape. Response: The Supplementary guidance does support new tree planting in appropriate locations with appropriate tree species. However, if an area’s special qualities are of a treeless landscape then new planting may not be acceptable.

130 It is accepted that a new objective should be added which supports appropriate trees species and woodland expansion in the right place to suit both soil and landscape. Action: Changes to text and an additional objective. Glen Lyon & Loch Tay Community Council Boundary: From a Community Council point of view the present boundary leaves this northern part of Glen Lyon disconnected from the rest of the Glen although the whole of Glen Lyon is within the Glen Lyon & Loch Tay Community Council Area. Is this because the rest of the Glen falls within the Loch Rannoch & Glen Lyon National Scenic Area? The objectives of a SLA are similar but not quite the same as the objectives of an NSA Is there any reason for an area not to be covered by both? The eastern boundary could follow the Community Council boundary to where it joins Area 3.Area 2 and 3 can still be retained as the discrete areas they are. Response: As is noted in the Community Council’s comments the reason for the whole glen not being designated as a Special Landscape Area is because the remainder is within the National Scenic Area and whilst consideration was given to whether LLAs should extend into NSAs it was conclude that this was unnecessary and could be confusing. Action: None required. Glen Lyon & Loch Tay Community Council Forces for change: We would like to see specific reference to the construction of small scale run-of-the-river hydro-schemes. Not just upgrading of hydro-schemes. Response: The suggested addition of “small-scale hydro schemes” to forces for change is accepted. Action: Text amended to include “the construction of small scale run-of-the-river hydro-schemes” Glen Lyon & Loch Tay Community Council Objectives: Given the existing boundary - to include, ensure that construction of small scale hydro-schemes is carried out in a sensitive manner. If the boundary were changed to include the rest of the Glen then further objectives would be needed to be included to cover protection and use of farmland and building siting and construction. Response: See above Action: Change to text made. See above. A Godfrey I would include the whole length of Glen Lyon; it is said to be the longest glen in Scotland and is attractive throughout its length. On the north side of the lower glen the Carn Gorm range provides an impressive backdrop and on the south side the back of the Lawers range provides a similar aspect. Extending the area should also include Meall Ghaordaigh and the surrounding hills, which are just beyond the boundary of the proposed area on the south side. Response: It is acknowledged that Glen Lyon is attractive throughout its length. However, the part of the glen not designated as an LLA is already part of the National Scenic Area and as a consequence and for the reasons given above it is not necessary to designate the whole glen as a LLA and would be confusing. Action: None required

131 Loch Tay

Scottish Natural Heritage Amend Special Quality no. 1 - “...all overlooked by Ben Lawers massif” Forces for change - add small-scale hydro-schemes and associated infrastructure. Response: Comment noted Action: Changes made to text Forestry Commission Scotland Page 21 – Objectives. ‘maintain native character of loch side woodlands and expand cover of deciduous woodlands’. After deciduous it should state and other appropriate woodland types. Response: Commented noted Action: Changes made to text. Glen Lyon & Loch Tay Community Council Most of this area falls within our Community Council area and there has long been a feeling that this area merits special recognition. Now especially, as it is a corridor between Loch Lomond, The Trossachs and Cairngorm National Parks and, therefore, more vulnerable to developers and in greater need of protection. Statement of Significance: There is much more evidence of early settlement apart from crannogs. There are also important remains of Highland settlement including Old Lawers Village. The long history of agriculture along the lochside and the valley between Fearnan and Fortingall needs to be remembered for its Shieling and Crofting heritage and its contribution to the landscape. The enclosed grazing on the lower slope provides a green fringe along the edge of the loch which contrasts with and enhances the rugged upper slopes and creates open space which gives rise to the long views along the loch that have been listed under Response: Comments noted and wording added to the Statement of Significance to incorporate local knowledge. Action: Changes to text Glen Lyon & Loch Tay Community Council Special Qualities. Walking and cycling routes do not circumnavigate the loch as there is not yet a suitable off-road track between Killin and Kenmore. Response: Comment noted and alteration made to text Action: Alteration to text. Glen Lyon & Loch Tay Community Council Objectives: Ensure sensitive siting and size as well as high quality design for tourist development proposals. The existing agricultural land needs maintaining and conserving. Proportionally there is not much of it and it has been hard-won over centuries and plays an important role in the landscape and history, and the economy of a wider area. Response: Comments noted and recognition of the importance of agricultural land to the areas landscape and economy added to the Statement of Significance Action: Change in text

132 A Godfrey In the Loch Tay area, the Shee of Ardtalnaig and Creag Gharbh on the south side of the loch are striking when seen from the north side of the loch and are prominent when seen from the A827. In addition, there may be value in providing connectivity to the Glen Almond area through the glen that connects both areas. Response: Noted. Creag Gharbh is outwith the Council Area. Action: None required. Graham & Sibbald (I Kelly) proper consideration should be given to linking LLAs 3 and 6; Response: Consideration was given to the eastern boundary of the LLAs. However, it Action: None required Graham & Sibbald (I Kelly) … the northern boundary of LLA 3: Loch Tay is ill defined and does not follow the ridge line or the watershed; the LLA 3 ‘Forces for change’ and ‘Management recommendations’ sections fail to acknowledge windfarm development; Response: It is acknowledged that wind energy developments are a force for change in the area and an additional statement recognising this has been added. Action: Change to text

Strathtay

Scottish Natural Heritage Main text: amend spelling to Castle Menzies Forces for Change - add small-scale hydro and associated infrastructure Amend final objective to “Support initiatives to preserve field boundaries and to restore trees and woodlands” Consider adding objective to retain and enhance policy woodlands. Response: Comments noted and changes accepted. Action: Text added. Forestry Commission Scotland Page 24. - Forces for change should include windfarms Page 24 - Objectives. After ‘expand coverage of deciduous woodland,’ we would like to see and other appropriate woodland. Response: Comments noted and accepted Action: Text added Graham & Sibbald (I Kelly) … proper consideration should be given to the expansion of LLAs 7 and 8 to the west and LLA 4 to the east (to include an area to the north and west of the River Tay (Dunkeld) NSA); Response: This area was considered as part of Search Area B which “extends from Loch Tay on the western boundary of the study area, along Strath Tay to the Dunkeld NSA in the south. It also includes Pitlochry and Ben Vrackie to the north, and Strathardle and Clunie Forest to the east. This area contains a number of landscape types, with distinctly different landscape characteristics”. However, “Beyond the Tay-Tummel confluence at Ballinluig, Strath Tay becomes more open and more influenced by coniferous plantations and transport routes, with less visual diversity. The focus was therefore on the western section of unit 15 (Upper Strath Tay), with parts of the adjacent upland area 3 (Schiehallion) to the north and fringes of area 17 (Meall Dearg and Craigvinean Forest) to the south”. (para 6.15) Given this the areas suggested whist attractive are not considered to be of sufficient merit to warrant being part of extended LLAs 7, 8, and 4. In addition it needs to be understood that this Supplementary Guidance is not a spatial strategy for wind energy proposals.

133 Action: None required

Ben Vrackie

Scottish Natural Heritage Amend final sentence of statement of significance to read “… part of the Cairngorm massif SPA, with qualifying interests of Golden eagle.” Forces for change - first sentence – amend to include “moorland management and agricultural practices…” Add (small-scale) hydro schemes and associated infrastructure Response: Comments noted and accepted Action: Text changed Forestry Commission Scotland Page 27. Forces for change. Under this section we would like to see changes in farming practices included. Page 27. Objectives. ‘Promote creation of native woodlands across lower slopes…’ We would like to see ‘native’ replaced with appropriate woodland types. Response: Comments noted and suggested change accepted. Action: Text changed

Glen Quaich

Scottish Natural Heritage Forces for change - these appear to be a more detailed re-write of the Special Qualities? Suggest these replace the original Special Qualities. Add intensification of grouse management including hill tracks Special Qualities - there is a significant omission to the special qualities of this area and these should be amended to add the following; “Scenic route from Amulree ascending to high point by An Chrois with first glimpses of Loch Tay and the mountains to the north.” Amend first objective to “maintain open character of the glen, and views north from the glen, particularly…” Response: Comments noted and suggested change accepted Action: Text changed Forestry Commission Scotland Page 30 – Objectives ‘Promote further expansion of native woodland’ We would like to see ‘native’ replaced with appropriate woodland types. Response: Comments noted and suggested change accepted Action: Text changed: Glen Lyon & Loch Tay Community Council Boundary: “The minor road through Glen Quaich is the highlight of this area, and a popular tourist drive.” It seems anomalous, therefore, not to include the whole road in the SLA. The northern boundary could quite easily be extended to meet the southern boundary of Area 3 above Kenmore. Response: It is acknowledged that the minor road between Amulree and Kenmore is “a popular tourist drive” and the views from it can be spectacular. The consultant’s study recognises that “Glen Quaich is a small- scale, contained glen with a strong identity within Perth and Kinross. Many visitors pass through the glen on the way to Strath Tay, either on foot or by car. The glen presents a series of scenically diverse views, across Loch Freuchie and along the glen to the enclosing ridges which rise to over 900m. The glen supports a natural moorland land cover with lowland plant communities and fauna.” (para 6.22)

134 The report continues by stating that the “Designation of Glen Quaich would recognise its importance as a distinctive highland glen landscape, framed by mountain summits and ridges. As highlighted in the evaluation, the glen is relatively wild, yet accessible, and therefore popular with walkers and those driving the minor road through Glen Quaich and towards Loch Tay. It was therefore decided to take this area forward as a candidate LLA, under the name Glen Quaich, including the whole of unit 20 (Glen Quaich) and the fringes of areas 17 (Meall Dearg and Craigvinean Forest) and 21 (Creag Liath) where these contribute to the setting of the glen.” (para 6.23) However, crucially it recognises that it is “the ridge lines which enclose the glen form natural boundaries for the LLA.” (para 6.23) Consequently, to extend the boundary would remove that relationship. It should also be recognised that whilst there is a ‘gap’ between the two cLLAs any development proposed would be assessed against any potential effects on the LLAs and would have to be assessed against the criteria in the core policy. It is considered that this should give sufficient protection to that area. Action: None required. Graham & Sibbald (I Kelly) the northern boundary of LLA 6: Glen Quaich is ill defined and does not follow the ridge line or the watershed; the LLA 6 ‘Management recommendations’ fail to identify what action should be taken to ensure that windfarm development does not compromise the LLA ‘Special qualities’; Response: It is not accepted that the northern boundary is on the whole ill-defined. The boundary largely follows the catchment/watershed for Loch Freuchie. Nonetheless it is acknowledged that a minor adjustment should be made to ensure that the upper reaches of the Remony Burn are excluded from LLA6 rather than drawing a line between Ceag an Sgliate and Meall a’ Choire Chreagaich. It should be emphasised that any proposal would have to be assessed against the criteria in the core policy and the LDP’s Renewable Energy Policy and the emerging Renewable Energy Supplementary Guidance and Wind Energy Spatial Strategy. Action: Minor modification to boundary.

Sma’ Glen and Glen Almond

Scottish Natural Heritage Special Quality - 2nd sentence - delete ‘is accessed’ Forces for change - possible extension of parking area? Add intensification of grouse management including hill tracks Add (small-scale) hydro schemes and associated infrastructure Response: Comments noted and suggested change accepted Action: Text changed Forestry Commission Scotland Page 33 – Objectives ‘Promote further expansion of native woodland’. We would like to see ‘native’ replaced with appropriate woodland types. We would also question why you are advocating replacement of existing conifer plantations and if so with what and how? Response: Comments noted and suggested change accepted Action: Text changed

Upper Strathearn

Scottish Natural Heritage Statement of Significance - 2nd sentence; reference to the Highland Boundary Fault (HBF) - suggest amend this from “However, it is nowhere more clearly and dramatically expressed...” to “Here it is clearly and dramatically expressed…” Pond of Drummond - amend statement in relation to the Pond of Drummond to include Drummond Lochs SSSI, and inclusion in the South Tayside Goose Roosts SPA.

135 Forces for changes - add renewables pressures including (small-scale) hydro schemes and associated infrastructure. Amend 4th objective to “Support initiatives to retain the pattern of field boundaries and to restore trees and hedges.” Consider adding objective to retain and enhance policy woodlands. Response: Comments noted and suggested change accepted Action: Text changed Forestry Commission Scotland Page 36. – Objectives. Needs to include ‘Additional mixed woodland planting with appropriate species subject to site suitability’ Response: Comments noted and suggested change accepted Action: Text changed

Sidlaw Hills

Scottish Natural Heritage Statement of Significance - amend final sentence to “The drama of the cliffs, woodland and tower at Kinnoull Hill, high above the motorway, and the cliff extending beyond towards Dundee.” Forces for change - we are uncertain what the reference to “changes in farm management around the loch shore” refers to. Pressure from renewables – add wind farms and single turbines, and possibly hydro. Objectives - amend to “Seek to manage and expand native woodland in existing areas and glens, strengthening…” Response: Comments noted and suggested change accepted Action: Text changed Forestry Commission Scotland Page 39. – Objectives. ‘Seek to expand native woodland cover …..’ should be changed to ‘Seek to expand woodland cover using appropriate species to meet the site conditions and owners objectives and to strengthen the existing woodland network. Response: Comments noted and suggested change accepted Action: Text changed Braes of the Carse Conservation Group In the Statement of Significance, mention is made of hill pasture contributing to the landcover, but this is not included in the objectives, missing an opportunity to help with its protection. Open moorland composed of grassland with some heather covers substantial part of the Sidlaws tops. It is currently at risk of degradation from over-grazing as well as from cultivation, inclusion could offer protection. Another landscape type found in the Sidlaws, are the areas of open scrub land, which is equally threatened by changes, including recent burning. The inclusion of the objective to expand native woodland in Glens is to be encouraged, but only if it is not at the expense of other habitats. Response: Comments noted and suggested change accepted Action: Text changed Abernyte Heritage Group and Abernyte Community Company We endorse the proposal to designate the area of the Sidlaw Hills as a Special Landscape Area and support the strategy and objectives of the designation. Response: Support welcomed Action: None required

136 P Symon STATEMENT OF IMPORTANCE OF CANDIDATE SIDLAW HILLS SLA Some critical observations about the Statement of Importance for the candidate Sidlaw Hills SLA, as per Draft Landscape Supplementary Guidance document: p. 38 Statement of Significance: why are the roads linking the settlements along the Braes with Strathmore described as "drove" roads? What source is provided for such a designation? p. 38 country houses and designed landscapes should include Rossie Priory. p. 39 Forces for Change: clarify to what topographic feature the words "around the loch shore" are intended to refer; the phrase is repeated on p.45 (draft Loch Leven and Bishop Hill candidate SLA). Response: Comments noted. Action: Text amended to delete reference to “around the loch shore”.

Ochil Hills

Crieff Community Council Crieff Community Council warmly supports the decision to designate the area of the Ochils within the jurisdiction of Perth and Kinross Council as a Special Landscape Area. Response: Support welcomed Action: None required Scottish Natural Heritage Objectives - the 2nd objective seems inconsistent with the approach for other proposed SLAs and we suggest it is added in other cSLAs as appropriate. Response: Comments noted and suggested change accepted Action: Text changed Forestry Commission Scotland Page 42 – Forces for change (or should this be an objective?) ‘Expansion of native woodland’ should be changed to ‘expansion of woodland cover using appropriate species. Response: Comments noted and suggested change accepted Action: Text changed Clackmannanshire Council The Council supports the principle of a proposed designation of the Ochil Hills as a SLA as this designation acknowledges the importance of the Ochils in conjunction with the adjoining designations in Clackmannanshire and Stirling as a regional feature on the northern edge of the Central Valley. They also have significance in defining the travel routes between the Central Valley and northern Scotland as well as the setting of numerous communities in Stirling, Clackmannanshire and Perth and Kinross. Their wild and relatively tranquil qualities with ready accessibility to a large proportion of Scotland's population for recreational pursuits is a significant quality. Your Council's objectives are noted and Clackmannanshire Council are keen to work with Perth and Kinross to help deliver them and ensure that development is sensitive to the special qualities of the Ochil Hills. Response: Comments noted and the offer of working together to manage the landscape of the Ochils is welcomed. Action: None required to text.

137 Friends of the Ochils 1. The South-Eastern Boundary Towards Milnathort. The south-eastern boundary towards Milnathort, on both sides of the M90, as currently chosen, tries to separate the upland Ochils from the lowland Ochils in this area, by following the break-in-slope using minor roads and farm tracks. It reflects the boundary of the old AGLV. The purpose of an SLA is different from AGLV and may take account of a range of historical and cultural criteria, in addition to the physical and visual criteria of landform and land cover. It is acknowledged that the lower, enclosed, ground towards Milnathort does not share the inspirational physical qualities of the upland part of the Ochils but it could be considered that the historic and cultural aspects of this area bring it within the criteria for SLA designation for the following main reasons:  Economic and Heritage. The Ochil Hills SLA is not defined by altitude or limited to upland landforms. The enclosed ground north of A91/M90 forms an integral component of the Ochil Hills culture – “the culture of sheep”. These lower, enclosed fields are mainly used for over-wintering, lambing, fattening and finishing sheep. If used as arable many of these fields produce improved grassland or crops used as winter feed for sheep. They form an integral part of the Ochils culture, economy and heritage.  Cultural. Milnathort and the area immediately to the north include the birthplace and childhood home of James Logie Robertson (1846 – 1922). Writing under the pen-name of “Hugh Haliburton”, he published several volumes of poetry, including “Ochil Idylls”. He earned the unofficial title of - “The Bard of the Ochils”, and is an important interpreter of the history and culture of this landscape.  “Views From and Into the Selected Area”. This low-ground area of enclosed fields and shelter belts forms the foreground views into the Ochil Hills cSLA from the M90, the main access into Perth and Kinross. It similarly sets the scene for views out from the cSLA towards Loch Leven and the Lomond Hills cSLAs.  “Clear and Permanent Feature” The A91/M90 provides a better “clear and permanent feature which can be tangibly identified on the ground”.  “Areas of Lower Merit”. SNH/HS guidance also recognises that not all of the area within an SLA will be of the same highest quality, particularly around settlements: “6-l0; Particular challenges also arise in selecting boundaries close to, or within the envelope of, settlements and larger urban areas. In these circumstances, small areas of lower merit may need to be included within the local landscape designation where this allows for a better physical boundary to be used, or to provide for more effective protection and management of the landscape in the longer term. Equally, in establishing boundaries consideration should also be given to the prospect of future growth of settlements close to or within locally designated landscapes. This advice could take account of any “areas of lesser merit” around Milnathort in order to create a clearer and more defensible boundary along the A91/M90. It is suggested that the A91/M90 would make a more clear and defensible boundary. Response: Whilst recognising that the A91/M90 would create boundary to the cLLA it is not accepted that it is a “more clear and defensible boundary” than the one used which follows the line of some unclassified roads in the area. It is just a different boundary and given the recognition that the area suggested is of “lesser merit” the concern would be that the inclusion of this area would be inconsistent with the approach adopted for the whole of Perth and Kinross. It is as also noted the one used for the former AGLV and despite there being some cultural associations with this extended area it is uncertain that the exclusion of the area would seriously harm the special qualities of the Ochils. This is not to diminish the importance of the landscape to the people of the area. However, considerable time and effort was taken by the consultants using their experience and knowledge to arrive at the boundary chosen.

138 There is also a concern that if this area was included together with the an addition of a LLA, suggested by the Kinross-shire Civic Trust, of covering the Cleish Hills but extending to the north side the A977, on the east side the M90, on the south side the Kinross-shire/Fife boundary and on the west the boundary with Clackmannanshire then only a very small part of Kinross-shire i.e. the area between the A977 and the A91 would not be within a LLA. To do this would diminish the merits of the Ochil Hills and Loch Leven, Bishop Hill and Benarty cLLAs and their rarity. Action: No change Friends of the Ochils 2. North-Western Boundary – Adjoining Western Ochils LLA, Stirling Council area. It is noted that the extreme western boundary stops at the minor road from Sherrifmuir to the A9 at Greenloaning, rather than continuing to the Perth and Kinross Council boundary. This gives a defined feature to follow and extends the present boundary of the Western Ochils LLA in Stirling. However, the Western Ochils LLA is based upon the old AGLV boundaries and Stirling Council has a commitment in its LDP Action Plan to re-consider these boundaries, particularly to the north and west. Bearing in mind the extent of the designated battlefield of Sherrifmuir (Map 2) it is possible that the Western Ochils LLA may be extended, possibly to the A9 and the Stirling Council boundary near Greenloaning. If that were to happen, the proposed boundary of the Ochil Hills cSLA at Greenloaning would leave a small triangle of the Ochils without any SLA coverage! It is suggested that the Ochil Hills cSLA boundary at Greenloaning should extend to the Perth and Kinross Council boundary. Justification It is noted that the cSLA boundary in the east of the Ochil Hills – beyond the M90 – extends to the boundary between Fife and Perth and Kinross councils, despite there being no clearly defined feature in many areas. Response: Comments noted and suggested change accepted Action: Text changed Fossoway & District Community Council The Community Council welcomes the inclusion and boundaries of the Ochil Hills Local Landscape Area and urge Perth and Kinross to fully implement this recommendation. The Kinross Area Local Plan 2004 included the Devon Gorge AGLV and the Community Council is disappointed that this area has not been included as a candidate Local Landscape Area. The area of the former AGLV meets all the criteria on a LLA and in addition Clackmannanshire Council has included the contiguous area as an LLA. Such abrupt changes in designation at Local Authority boundaries are both illogical and potentially problematic in planning decision making. We therefore urge the creation of a Glen Devon Gorge Local Landscape Area, following the boundaries of the former AGLV. Response: The support for the Ochil Hills LLA is welcomed. Whilst recognising the attractiveness of the Devon Gorge it does not form part of the Ochils landscape. In addition, it is understood that whilst the Gorge is identified by Clackmannanshire Council as part of its ‘green network’ it is not a Local Landscape Area in Clackmannanshire. It should be noted that Clackmannanshire Council does not mention the lack of designation of the Devon Gorge as an issue in their comments (see above). Nonetheless, it should be noted that it will be reviewing its Local Landscape Areas as part of the review of the Clackmannanshire Local Development Plan. The outcome of that review is not known at this time. In light of the above and the work undertaken by the consultants it is not considered appropriate to designate the Devon Gorge as Local Landscape Area. Action: None required.

139 Stirling Council The Statement of Significance has been reviewed and its findings align well with Stirling Council's 'citation' for the Western Ochils Local Landscape Area, as set out in Supplementary Guidance SG27 - Protecting Special Landscapes (copy attached). The proposed LLA designation would also accord with relevant guidance in SPP and SNH, and will ensure a consistent approach can be taken in respect of cross boundary development and land management issues. Boundaries A map is attached showing, cross hatched, a small parcel of land that is excluded from the proposed designation. Taking account of SNH advice on boundary definition in the above noted Guidance it is suggested it may be appropriate to include this land within the designation to better 'round off' the designated area. Stirling Council also intends to review the north eastern Sherriff Muir boundary of the Western Ochils LLA (see attached extract from SG 27 for further information) and this would also ensure a more natural relationship with any extended area. Response: Comments noted and suggested change accepted Action: Text changed Portmoak Community Council Strongly supports the candidatures of Loch Leven and Lomond Hills (including the northern edge of Benarty); and the Ochil Hill Range as Special Landscape Areas. Response: Support welcomed Action: None required

Loch Leven and the Lomond Hills

J Hampson It is important to consider the Loch Leven Basin on an holistic basis which means placing as much emphasis on the land to the west and south of the loch as that to the north and east of the basin When one considers the wider geography and topography, the argument for embracing the Cleish Hills is strong. This relates mainly to distant views from the land both North and East of the basin For the purposes of redefining the area covered, the Cleish Hills are conveniently within the same Landscape Type as the Lomond and Benarty Hills namely Dolerite Hills Since it is essential to avoid the industrialisation of the Cleish Hills in order to preserve the character of Kinross-shire the alternative would be to give the Cleish Hills separate SLA status Response: The Cleish Hills were considered as part of a wider area of search covering the Loch Leven Basin for a Special Landscape Area. However, it was recognised through the evaluation that whilst the Loch Leven Basin had elements which scored highly in the evaluation criteria it did not score as highly as the 11 candidate LLAs. It is important to note that the judgements of low, medium, or high are relative to the landscapes of Perth and Kinross, and do not indicate absolute levels or thresholds. By the same token, the findings cannot be directly related to the findings of other similar studies carried out in relation to other localities i.e. while the Cleish Hills are designated in Fife it does not necessarily follow that they would merit designation in Perth and Kinross. What the criteria ensure is that there is consistency across Perth and Kinross. Consequently, whilst the Cleish Hills are an important element in the local landscape they do not ‘score’ as highly as other parts of the ‘search’ area or more importantly when compared with other candidate Special Landscape Areas in terms of their high scenic quality, recreational value and cultural associations. Given the above it is not considered that there should be a Special Landscape Area covering the Cleish Hills. Action: No Change

140 Scottish Natural Heritage Clarify the name of the proposed SLA - it is ‘Loch Leven and Bishop Hill?’ (Figure 13k, page 43). Statement of significance - amend reference to Vane Farm nature reserve to reflect that this area is a National Nature Reserve and RSPB Loch Leven. This section does not mention that the area is also a SPA and SSSI and we recommend the document is re-checked to ensure accuracy when referring to natural heritage designations. Special qualities - 4th sentence; amend spelling to “gliding and bird watching”’ - recommend that the expanse of open water fringed with wetland providing an internationally important habitat for birds is recognised Objectives - amend 2nd to add “…adjacent hills while retaining the dramatic open landform.” Add additional objective to “increase the extent of wetland around the loch in order to enhance this internationally important wildlife site.” Response: Comments noted and suggested change accepted Action: Text changed Forestry Commission Scotland Page 45 – Forces for change ‘management of Forestry Plantations at Munduff Hill’ should include reference to the timing of felling and also restocking with appropriate species. Page 45 – Objectives. ‘Retain and expand native woodland coverage’ should be changed to ‘retain coverage of existing native woodland and seek expansion with appropriate species. Response: Comments noted and suggested change accepted Action: Text changed K Myles I wish to object to the above plans as proposed in relation to Kinross-shire. The Ochils are proposed but currently there is no inclusion of the Cleish Hills and the land that links these two hill ranges. This land stretches westward from Loch Leven toward Crook of Devon and beyond and provides fine uninterrupted views from the A977 after exiting from the M90 Junction 6 and on approach to Kinross after exiting Drum. Also as viewed from the Ochils and the Cleish Hills this land provides a rural, relatively unspoilt open countryside important to the setting of the settlement of Kinross. I would consider these a necessary addition in order to provide continuity to safeguard and enhance the character and quality of the Kinross-shire landscape. Response: The Cleish Hills were considered as part of a wider area of search covering the Loch Leven Basin for a Special Landscape Area. However, it was recognised through the evaluation that whilst the Loch Leven Basin had elements which scored highly in the evaluation criteria it did not score as highly as the 11 candidate LLAs. It is important to note that the judgements of low, medium, or high are relative to the landscapes of Perth and Kinross, and do not indicate absolute levels or thresholds. By the same token, the findings cannot be directly related to the findings of other similar studies carried out in relation to other localities i.e. while the Cleish Hills are designated in Fife it does not necessarily follow that they would merit designation in Perth and Kinross. What the criteria ensure is that there is consistency across Perth and Kinross. Consequently, whilst the Cleish Hills are an important element in the local landscape they do not ‘score’ as highly as other parts of the ‘search’ area or more importantly when compared with other candidate Special Landscape Areas in terms of their high scenic quality, recreational value and cultural associations. It is not accepted that the Cleish Hills form part of the setting of Kinross. Loch Leven and the Lomond Hills are more important in terms of a setting for Kinross.

141 Given the above it is not considered that there should be a Special Landscape Area covering the Cleish Hills. Action: No Change: Cleish and Blairadam Community Council The exclusion of the Cleish Hills as a Candidate Local Landscape Area is astounding given its importance to the landscape of Kinross-shire and the Loch Leven basin. In the beginning, the body of water now known as Loch Leven extended in a westerly direction for a considerable distance, perhaps as far as Crook of Devon. Extensive gravel extraction which has taken place in the Cleish and Balado areas and beyond, and continues to this day, is indicative of the deposits of alluvial plain. The Cleish Hills form the southern edge of this inland sea and are therefore as significant to the Loch Leven basin as the Ochils, Benarty and the Lomonds. The Cleish Hills are therefore a significant factor in understanding the formation of the landscape we see today. The undulating, hummocky landform is distinctive. The tops of the slopes with their crags, knolls, ridges, fissures and level domes form the skyline along the southern flanks of the Loch Leven basin. The 3 SSSIs, archaeological and historic sites which include Scheduled Monuments of Dumglow Hill Fort and Cleish Castle; several listed buildings including the renowned Blairadam House and designed landscape, are significant Historical settings. The breath-taking views and vistas over Kinross-shire from the road above Nivingston and along the ridge line are unrivalled. Cleish Hills provide an essential recreational resource for activities including horse-riding, walking, cycling, birdwatching and paragliding. Nivingston crags are home to protected species of bird. In relation to cLLA 11, (Loch Leven and Lomond Hills) the influence of the Loch Leven Basin clearly extends considerably further west than the map currently shows. As a significant part of the landscape of Kinross-shire it is essential that the Cleish Hills are designated a Special Landscape Area. Response: It is acknowledged that the Cleish Hills form a southern boundary to the Loch Leven basin and it was for that reason that they were considered as part of a wider area of search covering the Loch Leven Basin for a Special Landscape Area. However, it was recognised through the evaluation that whilst the Cleish Hills had elements which scored highly in the evaluation criteria it did not score as highly as the 11 candidate LLAs. It is important to note that the judgements of low, medium, or high are relative to the landscapes of Perth and Kinross, and do not indicate absolute levels or thresholds. By the same token, the findings cannot be directly related to the findings of other similar studies carried out in relation to other localities i.e. while the Cleish Hills are designated in Fife it does not necessarily follow that they would merit designation in Perth and Kinross. What the criteria ensure is that there is consistency across Perth and Kinross. Consequently, whilst the Cleish Hills are an important element in the local landscape they do not ‘score’ as highly as other parts of the ‘search’ area or more importantly when compared with other candidate Special Landscape Areas in terms of their high scenic quality, recreational value and cultural associations. It is not accepted that the Cleish Hills form part of the setting of Kinross. Loch Leven and the Lomond Hills are more important in terms of a setting for Kinross. Given the above it is not considered that there should be a Special Landscape Area covering the Cleish Hills. Action: No Change: Muckhart Community Council Muckhart Community Council would like to support a candidate Devon Gorge SLA. Although small in size compared with the other candidate Special Landscape Areas, we feel that it is of great significance in terms of landscape value. The Devon Gorge SLA would cover the gorges at Rumbling Bridge, Cauldron Linn and Muckhart Mill. The candidate SLA would also include the rivers and burns that link the three gorges and would be tightly drawn around the gorges and rivers.

142 The Community Council would like to put forward the following reasons for the inclusion of the Devon Gorge as an SLA:-  The proposed Devon Gorge SLA contains important geological features which make it a special area in both Perth and Kinross and Clackmannanshire and a destination for tourists and visitors coming to the area.  The power of the water generated in the gorges is highly significant and an exciting feature for tourists and visitors It has been historically important in harnessing power as demonstrated by Muckhart Mill which dates back to 1560 and its present day significance is demonstrated by the hydro-electric scheme.  The proposed SLA includes a variety of terrains with well-established paths around Rumbling Bridge and Muckhart Mill alongside other parts of the Devon Gorge SLA which are more remote and difficult to access.  There are Sites of Special Scientific Interest in the Gorge area and these include areas of ancient woodland.  The Gorge has historical links to Robert Burns and James Hutton. Muckhart Community Council would wish to see the Devon Gorge SLA stretching into Clackmannanshire and asks that Perth and Kinross Council consults with its neighbouring authority on this issue. However, the Perth and Kinross part of the proposed SLA contains important features such as Rumbling Bridge and the southern part of the Devon Gorge SLA is more accessible than the northern area. It could stand as a candidate SLA in its own right Response: Whilst recognising the attractiveness of the Devon Gorge it is not considered appropriate to designate the area as a Local Landscape Area. It should be noted that Clackmannanshire Council does not mention the lack of designation of the Devon Gorge as an issue in their response to this consultation (see above). Nonetheless, it should be noted that it will be reviewing its Local Landscape Areas as part of the review of the Clackmannanshire Local Development Plan. The outcome of that review is not known at this time. It is understood that whilst the Gorge is identified by Clackmannanshire Council as part of its ‘green network’ it is not a Local Landscape Area. The area is also identified as part of a green network in Perth and Kinross. This together with its geological interest may make it worthy of consideration as a potential Geodiversity Site and this will be explored with Clackmannanshire Council In light of the above and the work undertaken by the consultants it is not considered appropriate to designate the Devon Gorge as Local Landscape Area. Action: None required. Fife Council Perth & Kinross’s local landscapes are important throughout Fife and we particularly note the identification of the Sidlaw Hills, Ochil Hills and Loch Leven and Lomond Hills/Bishop Hill. Fife’s Local Landscape Area designation covering the Lomond Hills will be complemented by your proposed Loch Leven and Lomond Hills/Bishop Hill Special Landscape Area. The Lomond Hills are notable in views both from within Fife and from Perth and Kinross in the area around Loch Leven with a strong association between the surrounding hills and slopes and the loch basin. In applying practical criteria to the selection of the designation boundaries for this Local Landscape Area, and considering cross boundary issues, I would suggest that there may be merit in extending the designation boundary northwards. This could include the area to the south of the B996/A91 and east of B919, making the landscape designation between the two authorities contiguous, along the line of the A91. I appreciate that this small additional area may be of less merit. However, there could be value in including it within the designation as part of the coherent protection, management and enhancement of the wider Lomond Hills/Loch Leven area viewed from the A91 and other surrounding routes.

143 I note that the evaluation work for landscape unit ‘29 Loch Leven Basin’, which includes part of the Cleish hills and slopes, identifies the high ranking relationship between the basin and the surrounding enclosing hills. The assessment also notes that the Cleish Hills are designated within Fife. Only the eastern part of unit 29 has been included with the proposed Special Landscape Area and I assume that the western area, including the Cleish Hills has scored less well, although I haven’t found this evaluation. I would suggest that there may be potential in reconsidering some designation in this Cleish Hills/Slopes area, if this can be backed up by the results of the evaluation, including particular reference to the non-ranked criteria. Our own landscape evaluation highlights the value of the various distinct Cleish hills in relation to the settled lowlands in both Perth & Kinross and Fife. I understand that given your area’s range of upland landscapes, this area may not rank as particularly valuable but I would welcome any reconsideration of its potential, recognising its importance to the setting of the surrounding low lying areas and the coherence of the protection of the Loch Leven Basin, important to both local authorities. Response: The importance of the cLLAs to Fife are recognised. There was considerable discussion by the Steering Group and the authors of the report on the northern boundary of the Loch Leven cLLA as was whether it was necessary for boundaries to be contiguous across Council boundaries. It was considered that there was no reason for boundaries to be contiguous unless the designated areas were in the same landscape unit. That was why it was not considered necessary to have the northern boundary extending to the A91. Nonetheless, there is some merit in extending the boundary northwards to address the concern raised by Fife Council. Turning to the Cleish Hills it is recognised by Fife Council that whilst they are important in a Fife context they may be of lesser importance in a Perth and Kinross context. The Cleish Hills were considered as part of a wider area of search covering the Loch Leven Basin for a Special Landscape Area. However, it was recognised through the evaluation that whilst the Cleish Hills had elements which scored highly in the evaluation criteria it did not score as highly as the 11 candidate LLAs or indeed as the Ochil Hills or Loch Leven cLLAs. It is important to note that the judgements of low, medium, or high are relative to the landscapes of Perth and Kinross, and do not indicate absolute levels or thresholds. By the same token, the findings cannot be directly related to the findings of other similar studies carried out in relation to other localities i.e. while the Cleish Hills are designated in Fife it does not necessarily follow that they would merit designation in Perth and Kinross. What the criteria ensure is that there is consistency across Perth and Kinross. Consequently, whilst the Cleish Hills are an important element in the local landscape they do not ‘score’ as highly as other parts of the ‘search’ area or more importantly when compared with other candidate Special Landscape Areas in terms of their high scenic quality, recreational value and cultural associations. Given the above it is not considered that Cleish Hills be designated a Special Landscape Area. However, it should be emphasised that the same policy and criteria will be used to determine the effects of development in this area. Action: Extend northern boundary to the A91. Portmoak Community Council Strongly supports the candidatures of Loch Leven and Lomond Hills (including the northern edge of Benarty); and the Ochil Hill Range as Special Landscape Areas. Response: Support welcomed Action: None required

144 Councillor M Barnacle The LLAs proposed for Kinross-shire are Loch Leven, Ochil Hills and Portmoak which I fully support. Despite strong representation from myself, Cleish & Fossoway CC's within the Review Panel, the consultants have excluded from designation the former AGLV's of the Cleish Hills and the River Devon and its gorge. I believe this is a major omission and seek a change to the proposals to include these omitted areas. An examination of the 10 evaluation criteria used by the consultants for designating LLA's is necessary to see what landscape characteristics these excluded areas possess that justify designation. The criteria are landscapes which: 1. make a positive contribution to the wider identity, image and sense of place of Perth and Kinross. 2. are rare or unique landscapes 3. are well managed and in a good state of repair 4. feel wild or remote 5. have strong scenic qualities 6. are important for recreation and tourism 7. have a strong historic character or important cultural or spiritual associations 8. have important natural features and habitats 9. form part of the setting of towns and villages 10. have important views, viewpoints or land marks Council's LLA's border the PKC boundary here and cross boundary designations were raised in the Review Panel but have been ignored here. As regards the River Devon and its gorge, it should be remembered that the Reporter to the Local Plan public enquiry in 2003 regarded this area as of outstanding quality that merited inclusion as an AGLV, especially as the river flows out of the Ochil Hills designated area. I suggest that the river and its gorge meet at least eight of the above and I note the strong historic character and important cultural association of the Devon with Robert Burns' song 'The banks of the Devon'; conversely, in supporting an LLA in the Aberfeldy area, the consultants quote Burns' song 'The Birks of Aberfeldy'. I note that Muckhart Community Council and Clackmannanshire Council are discussing the merits of designating the Devon Gorge as an SLA. I would commend the submissions of Fossoway Community Council and Kinross-shire Civic Trust as regards the Devon Gorge and Cleish Hills respectively. I would also cite the excellent submission from Friends of the Ochils to your consultation, noting particularly their support for the inclusion of these omitted areas as SLAs. In summary, I am extremely disappointed that the final consultant's report has ignored review panel representation on the Cleish Hills and the River Devon/Gorge when selecting their proposed LLAs and seek to ensure that PKC and its elected members change these proposals and include these areas as LLAs within the supplementary guidance for our recently adopted LDP. Response: Support welcomed. It is as also noted the one used for the former AGLV and despite there being some cultural associations with this extended area it is uncertain that the exclusion of the area would seriously harm the special qualities of the Ochils. This is not to diminish the importance of the landscape to the people of the area. However, considerable time and effort was taken by the consultants using their experience and knowledge to arrive at the boundary chosen. There is also a concern that if this area was included together with the an addition of a LLA, suggested by the Kinross-shire Civic Trust, of covering the Cleish Hills but extending to the north side the A977, on the east side the M90, on the south side the Kinross-shire/Fife boundary and on the west the boundary with Clackmannanshire then only a very small part of Kinross-shire i.e. the area between the A977 and the A91 would not be within a LLA. To do this would diminish the merits of the Ochil Hills and Loch Leven, Bishop Hill and Benarty cLLAs and their rarity.

145 Whilst recognising the attractiveness of the Devon Gorge it is not considered appropriate to designate the area as a Local Landscape Area. It should be noted that Clackmannanshire Council does not mention the lack of designation of the Devon Gorge as an issue in their response to this consultation (see above). Nonetheless, it should be noted that it will be reviewing its Local Landscape Areas as part of the review of the Clackmannanshire Local Development Plan. The outcome of that review is not known at this time. It is understood that whilst the Gorge is identified by Clackmannanshire Council as part of its ‘green network’ it is not a Local Landscape Area. The area is also identified as part of a green network in Perth and Kinross. This together with its geological interest may make it worthy of consideration as a potential Geodiversity Site and this will be explored with Clackmannanshire Council In light of the above and the work undertaken by the consultants it is not considered appropriate to designate the Devon Gorge as Local Landscape Area. Action: Minor change to the southern boundary of the Ochil Hills cLLA to address issues raised by Stirling Council and Friends of the Ochils. Minor change to northern boundary of the Loch Leven cLLA to address issue raised by Fife Council Kinross-shire Civic Trust Rumbling Bridge Gorge has a unique place in the landscape of Kinross-shire. The Gorge is a dramatic box canyon set in a relatively undulating and gentle surrounding countryside. It would not be an argument to say that no development could take place in this area because of its geography. That would be a negative argument and the gorge deserves a positive policy in landscape terms to ensure that any development should be inhibited from taking place. Its natural beauty must be preserved so that people can continue to enjoy it. For this reason the Trust advocates that the Gorge be added to the DRAFT Candidate Local Landscape Areas for Kinross-shire. A suitable area needs to be marked surrounding the Gorge in order that the Gorge can be protected from intruding and visual development. Response: Whilst recognising the attractiveness of the Devon Gorge it is not considered appropriate to designate the area as a Local Landscape Area. It should be noted that Clackmannanshire Council does not mention the lack of designation of the Devon Gorge as an issue in their response to this consultation (see above). Nonetheless, it should be noted that it will be reviewing its Local Landscape Areas as part of the review of the Clackmannanshire Local Development Plan. The outcome of that review is not known at this time. It is understood that whilst the Gorge is identified by Clackmannanshire Council as part of its ‘green network’ it is not a Local Landscape Area. The area is also identified as part of a green network in Perth and Kinross. This together with its geological interest may make it worthy of consideration as a potential Geodiversity Site and this will be explored with Clackmannanshire Council In light of the above and the work undertaken by the consultants it is not considered appropriate to designate the Devon Gorge as Local Landscape Area. Action: None required.

WILD LAND

John Muir Trust The document on page 12 gives some detail of the 11 candidate areas and how they complement the National Scenic Areas and National Parks. We would suggest at this point that reference is also made to Wild land areas (WLAs) as defined by Scottish Natural Heritage. The WLAs are discussed in section 5 in detail however it is important to explicitly state the connection between them and the other designations at this early stage. We would also recommend that Hyperlinks to the relevant documentation is included for the sake of completeness. Response: Comments noted. Action: Suggested changes made.

146 Scottish Natural Heritage The inclusion of areas of wild land in this guidance is welcomed. We recommend a hyper link to SNH’s map and this is reworded to “SNH’s map of wild land areas (June 2014) http://www.snh.gov.uk/protecting-scotlands-nature/looking-after-landscapes/landscape-policy-and- guidance/wild-land/mapping/ Response: Support welcomed Action: Change to text made and hyperlink added Forestry Commission Scotland Page 46 – What is the role for the Forestry and Woodland Strategy here? It does not get a mention? Response: The Forest and Woodland Strategy is referred to in the text which outlines the linkages between the various Supplementary Guidance. There is also a diagram which shows linkages. Nonet less it is accepted that this may need to be further highlighted. Action: Emphasise importance of connections

SUPPLEMENTARY PLANNING STATEMENTS

J Hampson The Revised Development Plan could prescribe the types of development which would not be permitted in a SLA e.g. buildings over 2 storey, wind turbines and certain types of industrial development . Response: The guidance is intended to ensure that Perth and Kinross’s landscapes are protected, enhanced and well managed for future generations as a place to live and work. Consequently, the purpose of the supplementary guidance is to help developers, land managers and decision makers to take appropriate steps to protect, manage and enhance the landscapes of Perth and Kinross. However, what it cannot do is go beyond the policy contained in the Adopted Local Development Plan. That is it cannot prescribe the types of development which would not be permitted within the LLA. This as noted could form part of any new Local Development Plan Action: None required Scottish Natural Heritage Policy 2: “Statements of Special Qualities” - a list of special qualities are contained within the wider statements accompanying each proposed SPA. However it is unclear whether this policy relates just to these special qualities or the entire statement; please clarify. Response: Comments noted and suggested change accepted Action: Text changed

OBJECTIVES

Scottish Natural Heritage We support medium to long term goals for landscape in Perth and Kinross. We also recommend an aspiration to improve the quality of new development including new homes in SLAs. This includes their design, fit in the landscape and ensuring they enhance local distinctiveness of these areas. Response: Comments noted and suggested change accepted Action: Text changed

147 MONITORING

Scottish Natural Heritage We support the monitoring process described. The use of fixed point photography is supported in para 8.4. We recommend timescales are included as to when monitoring will be undertaken. Response: Comments noted. Action: None required

NEW LANDSCAPE AREAS

EA Mason I have read the documents with all the beautiful areas set aside for Managing Future Landscape change and to conserve and enhance the diversity and quality of the Area’s landscapes. However, the areas where the Cateran Trail extends may be on part of these areas I feel the Cateran Trail itself should be included as a Feature in its own right. Response: The Cateran Trail falls outwith the candidate Special Landscape Areas being consulted upon. However, a number of the 47 potential landscape areas (Strathmore, Clunie Foothills, Lower Glenshee, Alyth Foothills, Forest of Alyth, Forest of Clunie, Strathardle, and Ben Earb) which contain parts of the Cateran Trail were evaluated. It was recognised through the evaluation that whilst each of the potential Special Landscape Areas had elements which scored highly in the evaluation criteria they did not score as highly as the 11 candidate LLAs. It is important to note that the judgements of low, medium, or high are relative to the landscapes of Perth and Kinross, and do not indicate absolute levels or thresholds. By the same token, the findings cannot be directly related to the findings of other similar studies carried out in relation to other localities. However, what this ensures is that there is consistency across Perth and Kinross. Consequently, whilst the Cateran Trail is clearly a very important recreational facility and element in many landscapes it is in itself not a landscape feature. Given the above it is not considered that there should be a Special Landscape Area covering the Cateran Trail. Action: No change G & C Findlay Identity and Sense of Place The Trail takes in a range of landscape features which characterise Perth & Kinross: rivers and burns, moorland, gently rolling hills and fertile valleys. It provides a distinctive mix of farmland, forests and moors. Intactness and condition Several stretches of the Trail cross wild, open landscapes: for example, Kirkmichael via Enochdhu to Spittal of Glenshee or Spittal of Glenshee to Kirkton of Glenisla. Scenic Qualities Rich in visual and sensory delights, including an impressive variety of wildlife such as deer, cuckoo, woodpecker, lark, hen harrier, grouse, hare, red squirrel, stoat etc. Enjoyment In addition to regular use by locals and tourist alike there is an annual Blairgowrie Walking Festival as well as an annual weekend Cateran Yomp which in 2014 attracted over 400 participants. Built heritage assets Standing Stones, Glasclune Castle, Forter Castle, Dirnanean Gardens, battle sites and burial mounds. Roman military road. Cultural qualities

148 Steeped in myths and legends (see Maurice Fleming’s book ‘The Ghost o’ Mause, for example). Currently The Cateran Common Wealth project is building arts events into places along The Cateran trail which already have some literary, musical, spiritual or general cultural connection with the area. www.commonculture.org.uk/ Response: The importance of the Cateran Trail is recognised. However, it falls outwith the candidate Special Landscape Areas being consulted upon. However, a number of the 47 potential landscape areas (Strathmore, Clunie Foothills, Lower Glenshee, Alyth Foothills, Forest of Alyth, Forest of Clunie, Strathardle, Ben Earb) which contain parts of the Cateran Trail were evaluated. It was recognised through the evaluation that whilst each of the potential Special Landscape Areas had elements which scored highly in the evaluation criteria they did not score as highly as the 11 candidate LLAs. It is important to note that the judgements of low, medium, or high are relative to the landscapes of Perth and Kinross, and do not indicate absolute levels or thresholds. By the same token, the findings cannot be directly related to the findings of other similar studies carried out in relation to other localities. However, what this ensures is that there is consistency across Perth and Kinross. Consequently, whilst the Cateran Trail is clearly a very important recreational facility and element in many landscapes it is in itself not a landscape feature. Consequently it is not considered that there should be a Special Landscape Area covering the Cateran Trail. Action: No change Kinross-shire Civic Trust Using the terminology in the Draft document, the following is offered for justification for the inclusion of the Cleish Hills Cleish Hills This candidate SLA includes the whole of the north face of the Cleish Hills running from the valley between them and Benarty on the east up till they meet the Clackmannanshire boundary in the west. The southern face of the Cleish Hills is Locally Designated in Fife Boundaries The proposed boundaries are on the north side the A977, on the east side the M90, on the south side the Kinross-shire/Fife boundary and on the west the boundary with Clackmannanshire. Statement of significance As with the other hills in Kinross-shire, Loch Leven is a feature of central significance within Perth and Kinross and also has had an important role in Scottish history generally. Similarly it has the deep links with historical events of the area. The Cleish Hills along with the Ochils continue the valley from the west which leads to Loch Leven itself and the long narrow wedge formed by the two hill scapes creates a focus which points towards the heart of Kinross-shire. On the north face of the hills there are many important settings. These include 3 No SSSIs, many archaeological and historic sites including Drum Glow Bronze Age fort and Iron Age fort and Cleish Castle which are Scheduled Ancient Monuments. On the eastern end of the hills is Blairadam house, a listed building with its important Garden Landscape, designed and built by William Adam At the end of the 18th century, Sir William Bruce built the important Kinross House on the side of Loch Leven. As well as having an important west – east axis which passes along the Kinross House approach avenue, through the House and points directly toward the Castle island, the house also has an important north – south axis which points directly toward the Cleish Hills. The ridge line of the hills forms a natural boundary between Kinross-shire and Fife. Crossing the ridge from the south by the several roads over it leads one onto breath-taking views across the county, over the loch to the hills on the north and east. Special Qualities Contrast between the broad, flat loch, farmed foothills and the sometime gently sloping hills and sometime steep escarpments of the Cleish Hills. Striking and dramatic form of the Cleish Hills seen from the loch side, the Ochils and Kinross.

149 Historically a key boundary between Kinross-shire and Fife and an important key relationship between Kinross and the Kinross House and its Garden Landscape. 3 No SSSIs on the north face of the Cleish Hills. Essential recreation resource with walks through the woodlands above Cleish and spectacular views from the escarpments across Kinross-shire. Forces for Change Management of forestry plantations on the Cleish Hills. Changes in farm management on the lower foothills. Possible Major Wind farms on the ridges on the Fife side of the hills. Objectives Maintain accessibility of this area for diverse user groups and diverse recreational groups from bird watching to hill walking. Maintain the SSSIs along the face of the hills Maintain the important archaeological and historical settlements from the Bronze and Iron Ages along the face of the hills and the Garden Landscape of Blairadam House. Response: It is acknowledged that the Cleish Hills form a southern boundary to the Loch Leven basin and it was for that reason that they were considered as part of a wider area of search covering the Loch Leven Basin for a Special Landscape Area. However, it was recognised through the evaluation that whilst the Cleish Hills had elements which scored highly in the evaluation criteria it did not score as highly as the 11 candidate LLAs. It is important to note that the judgements of low, medium, or high are relative to the landscapes of Perth and Kinross, and do not indicate absolute levels or thresholds. By the same token, the findings cannot be directly related to the findings of other similar studies carried out in relation to other localities i.e. while the Cleish Hills are designated in Fife it does not necessarily follow that they would merit designation in Perth and Kinross. What the criteria ensure is that there is consistency across Perth and Kinross. Consequently, whilst the Cleish Hills are an important element in the local landscape they do not ‘score’ as highly as other parts of the ‘search’ area or more importantly when compared with other candidate Special Landscape Areas in terms of their high scenic quality, recreational value and cultural associations. It is not accepted that the Cleish Hills form part of the setting of Kinross. Loch Leven and the Lomond Hills are more important in terms of a setting for Kinross. Given the above it is not considered that there should be a Special Landscape Area covering the Cleish Hills. Action: None required S Dean Perth and Kinross Local Landscape Designations Review. Proposed SLA designation of the Devon Gorge and the Cleish Hills. In 2014 I was a member of the Review Panel which proposed a number of candidate Special Landscape Areas within Perth and Kinross-shire. I attended in my capacity as Chair of the Friends of the Ochils but we were encouraged to propose areas beyond those with which we are involved in a formal capacity. Along with others on the Panel, I supported the designation of two areas that have not been included in the draft Supplementary Guidance as candidate SLAs, namely the Devon Gorge and the PKC area of the Cleish Hills. I would therefore wish to propose that these areas should also become SLAs within PKC and fully support the case for both detailed in the documents submitted by Andrew Jamieson with whom I have worked closely on this issue.

150 Response: It is acknowledged that the Cleish Hills form a southern boundary to the Loch Leven basin and it was for that reason that they were considered as part of a wider area of search covering the Loch Leven Basin for a Special Landscape Area. However, it was recognised through the evaluation that whilst the Cleish Hills had elements which scored highly in the evaluation criteria it did not score as highly as the 11 candidate SLAs. It is important to note that the judgements of low, medium, or high are relative to the landscapes of Perth and Kinross, and do not indicate absolute levels or thresholds. By the same token, the findings cannot be directly related to the findings of other similar studies carried out in relation to other localities i.e. while the Cleish Hills are designated in Fife it does not necessarily follow that they would merit designation in Perth and Kinross. What the criteria ensure is that there is consistency across Perth and Kinross. Consequently, whilst the Cleish Hills are an important element in the local landscape they do not ‘score’ as highly as other parts of the ‘search’ area or more importantly when compared with other candidate Special Landscape Areas in terms of their high scenic quality, recreational value and cultural associations. It is not accepted that the Cleish Hills form part of the setting of Kinross. Loch Leven and the Lomond Hills are more important in terms of a setting for Kinross. Given the above it is not considered that there should be a Special Landscape Area covering the Cleish Hills. Whilst recognising the attractiveness of the Devon Gorge it is not considered appropriate to designate the area as a Local Landscape Area. It should be noted that Clackmannanshire Council does not mention the lack of designation of the Devon Gorge as an issue in their response to this consultation (see above). Nonetheless, it should be noted that it will be reviewing its Local Landscape Areas as part of the review of the Clackmannanshire Local Development Plan. The outcome of that review is not known at this time. It is understood that whilst the Gorge is identified by Clackmannanshire Council as part of its ‘green network’ it is not a Local Landscape Area. The area is also identified as part of a green network in Perth and Kinross. This together with its geological interest may make it worthy of consideration as a potential Geodiversity Site and this will be explored with Clackmannanshire Council In light of the above and the work undertaken by the consultants it is not considered appropriate to designate the Devon Gorge as Local Landscape Area. Action: None required K Myles The Ochils are proposed but currently there is no inclusion of the Cleish Hills and the land that links these two hill ranges. This land stretches westward from Loch Leven toward Crook of Devon and beyond and provides fine uninterrupted views from the A977 after exiting from the M90 Junction 6 and on approach to Kinross after exiting Drum. Also as viewed from the Ochils and the Cleish Hills this land provides a rural, relatively unspoilt open countryside important to the setting of the settlement of Kinross. I would consider these a necessary addition in order to provide continuity to safeguard and enhance the character and quality of the Kinross-shire landscape. Response: It is acknowledged that the Cleish Hills form a southern boundary to the Loch Leven basin and it was for that reason that they were considered as part of a wider area of search covering the Loch Leven Basin for a Special Landscape Area. However, it was recognised through the evaluation that whilst the Cleish Hills had elements which scored highly in the evaluation criteria it did not score as highly as the 11 candidate LLAs. It is important to note that the judgements of low, medium, or high are relative to the landscapes of Perth and Kinross, and do not indicate absolute levels or thresholds. By the same token, the findings cannot be directly related to the findings of other similar studies carried out in relation to other localities i.e. while the Cleish Hills are designated in Fife it does not necessarily follow that they would merit designation in Perth and Kinross. What the criteria ensure is that there is consistency across Perth and Kinross. Consequently, whilst the Cleish Hills are an important element in the local landscape they do not ‘score’ as highly as other parts of the ‘search’ area or more importantly when compared with other candidate Special Landscape Areas in terms of their high scenic quality, recreational value and cultural associations.

151 It is not accepted that the Cleish Hills form part of the setting of Kinross. Loch Leven and the Lomond Hills are more important in terms of a setting for Kinross. Given the above it is not considered that there should be a Special Landscape Area covering the Cleish Hills. Action: None required Portmoak Community Council Strongly recommends that the northern edge of the Cleish Hills running west between Benarty and the Clackmannanshire border also be included as a Special Landscape Area. The Cleish Hills have specific merits but importantly play a key role (along with the Ochil Hills, the Lomonds and Benarty in delimiting the Loch Leven Basin. Their omission weakens the important case for supporting this basin as an invaluable landscape entity. The Community Council understands that the southern edge of the Cleish Hills has been designated by Fife as a Special Landscape Area. Response: It is acknowledged that the Cleish Hills form a southern boundary to the Loch Leven basin and it was for that reason that they were considered as part of a wider area of search covering the Loch Leven Basin for a Special Landscape Area. However, it was recognised through the evaluation that whilst the Cleish Hills had elements which scored highly in the evaluation criteria it did not score as highly as the 11 candidate LLAs. It is important to note that the judgements of low, medium, or high are relative to the landscapes of Perth and Kinross, and do not indicate absolute levels or thresholds. By the same token, the findings cannot be directly related to the findings of other similar studies carried out in relation to other localities i.e. while the Cleish Hills are designated in Fife it does not necessarily follow that they would merit designation in Perth and Kinross. What the criteria ensure is that there is consistency across Perth and Kinross. Consequently, whilst the Cleish Hills are an important element in the local landscape they do not ‘score’ as highly as other parts of the ‘search’ area or more importantly when compared with other candidate Special Landscape Areas in terms of their high scenic quality, recreational value and cultural associations. It is not accepted that the Cleish Hills form part of the setting of Kinross. Loch Leven and the Lomond Hills are more important in terms of a setting for Kinross. Given the above it is not considered that there should be a Special Landscape Area covering the Cleish Hills. Action: None required

152 Appendix 3 Map showing suggested additional Local Landscape Areas and boundary changes in Kinross-shire

153

Appendix 4 Respondents to the Consultation

1 A Godfrey 2 Abernyte Heritage Group and Abernyte Community Company 3 Braes of the Carse Conservation Group 4 Clackmannanshire Council 5 Cleish and Blairadam Community Council 6 Councillor M Barnacle 7 Crieff Community Council 8 EA Mason 9 Fife Council 11 Forestry Commission Scotland 12 Fossoway & District Community Council 13 Friends of the Ochils 14 G & C Findlay 15 Glen Lyon & Loch Tay Community Council 16 Graham & Sibbald (I Kelly) 17 J Hampson 18 John Muir Trust 19 K Myles 20 Kinross-shire Civic Trust 21 Muckhart Community Council 22 P Symon 23 Portmoak Community Council 24 S Dean 25 Scottish Natural Heritage 26 sportscotland 27 Stirling Council

154 Appendix 5 Members of the Review Panel Name Organisation Ian Campbell PKC Helen McDade John Muir Trust John Low John Muir Trust Alan Livingston PKC Ann Cowan PKC Christopher Dingwall Garden History Society in Scotland Mike Strachan Forestry Commission Scotland Jane Dekker Rannoch & Tummell Bob Benson LRCA Carol Pudsey Tayside Geodiversity Michael Barnacle APRS Campbell Gerrard sportscotland Lynne Palmer Perth resident Fiona Ross Carse Sustainability Group Malcolm Best Auchterarder Community Council Gavin Ramsay Carse of Gowrie resident Stuart Dean Friends of the Ochils Drew Jamieson Friends of the Ochils Adam Strange Balmyre Farm Malcolm McSwan Braes of the Carse Conservation Group Louisa Evans Horsecross Bill Macpherson Glenfarg Community Council Tony Simpson Carse of Gowrie resident Sally Spaven Pitlochry in Bloom Bill Wilson Local resident Andrew Finlayson Comrie Community Council Maureen Beaumont East Strathearn Community Council Kate Maitland NFU Scotland Alastair Lavery Fossoway Community Council Werner Reiche Stanley and District Community Council Cleish Community Council Robin Cairncross Portmoak Community Council Graham Huggins Highland Perthshire Communities

It should be noted that not all members attended all 3 workshops

155 156