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Submission from Badenoch and Strathspey Conservation Group SUBMISSION FROM BADENOCH AND STRATHSPEY CONSERVATION GROUP Introductory Comments I am writing to you on behalf of the Badenoch and Strathspey Conservation Group (BSCG). Established in 1975, BSCG has over thirty years of involvement with efforts to safeguard fragile and outstanding natural heritage within the Cairngorms area. BSCG is voluntary community group (with membership also open to people not permanently resident within the Cairngorms area) and with a focus to the northwestern part of the Cairngorms. BSCG has long recognised the potential value for both conservation and community interests of a National Park for the Cairngorms area. From the outset, BSCG welcomed the Scottish Labour party’s commitment to put in place a proper system for the management of areas of outstanding natural beauty, consistent with the highest international standards. BSCG is happy to comment on the above bill. We also welcomed an earlier (November 2005) opportunity to comment positively on “a members Bill to extend the boundaries of the Cairngorms National Park”. This came from the MSP for North Tayside and has had wide ranging support that extends beyond local communities in Perthshire. Growing need for boundary reform for the CNP In a letter to the press (Scotsman 21 Jan 2003) to which BSCG was signatory, we argued that the flawed boundary and planning arrangements for the CNP have unfortunately led to it being dubbed the “Cairngorms national farce” (as, for example, reported in the Sunday Herald in November 2002). We advocated that the Perthshire omissions should be addressed by reform of the CNP boundaries and expressed support for the inclusion of all of Badenoch and Strathspey, the Lochindorb area and all the ground in Angus & Moray that had been recommended for inclusion by SNH. These changes, in our view, would help to deliver a proper system of management consistent with high international standards. Events in the four years since 2003 strengthen our view that effective delivery of the core remit of the National Park, such as the first key aim, has been handicapped by what has been bluntly described (eg Sunday Herald 12 January 2003) as this “crazy boundary” (quoting the Director of Ramblers, Scotland). In recent years also, the alarmist arguments used against more inclusive boundaries have also weakened. Precedents show that reforming legislation relating to Protected Areas like National Parks has the potential to deliver increased public benefits. We suggest that ecologically sound boundaries are better able to deliver environmental justice for local communities and the pledge of bequeathing protected areas as a precious heritage to future generations in line with the Durban Accord (see IUCN 2005 Benefits Beyond Boundaries Proceedings of the Vth IUCN World Parks Congress). In Scotland’s first national park considerable boundary extensions, respecting local democracy and reflecting local concern about being excluded, were made to an extent that was not matched for the Cairngorms area. In our view, it has been well argued with respect to the determination of the SW boundary of the CNP that “criteria other than those laid down in the National Parks (Scotland) Act 2000 have been used” (see Sunday Herald November 2002, our emphasis, quoting Dr Robin Pellew at the time Chief Executive of the National Trust for Scotland). Ilsey & Richardson 2004 (Journal of Environmental Planning and Management 47 (2), 219-242) noted “The final southern park boundary follows the local authority boundary, cutting mountain ranges and individual mountains in two, ignoring logical landscape or environmental divisions, dividing designated landscapes and conservation areas and failing to meet the criteria of distinctive character and coherent identity as set out in the Act.” The more sensible boundary proposed in this bill, which is closer to the considered advice provided by SNH, positively addresses these difficulties. Below I address some more specific questions. Should this area be included in the Park? Yes. We consider it should as a matter of urgency. It is important to raise standards of delivery on conservation objectives in what we consider to be Scotland’s only national park for which ultimately a case for World Heritage Site Status can most realistically be advanced. In various respects, inclusion of this area should benefit delivery on the five principles of good governance (legitimacy and voice, performance, accountability, fairness anddirection (see p257 inBenefits Beyond Boundaries Proceedings of the Vth IUCN World Parks Congress). Given that ineffective governance rather than, for example, simply size of budget can be viewed as a serious problem in the CNP promoting better governance in the Cairngorms is a priority. Progress on delivering effective systems of governance (lack of which can for example be viewed as at the root of the continuing failure to adequately safeguard national and international biodiversity interests in Strathspey) is in line with the Durban Accord and is where we believe urgent action from the executive is needed and positive change would be particularly welcome. We suggest with respect to coherent identity of the CNP area the present situation lacks legitimacy. We suggest the current boundary arrangement that have dashed legitimate expectations have failed to respect the voice of local communities such as the community of Blair Atholl. This bill addresses these shortcomings and increased the legitimacy of the boundary in line with SNH advice that was to include parts of Perthshire. Performance on delivery of for example environmental benefits for example achieving biodiversity and landscape conservation targets should be enhanced by a less artificial boundary. Wider accountability greater fairness and renewed vision and momentum in a conservation and community friendly direction are amongst further benefits we can envisage. There could also be an effect of spreading benefits of national park status and reducing excessive and unsustainable impacts and pressure on resources. What will the effects of this Bill be on both the areas of Perthshire proposed by the Bill and the existing Cairngorms National Park area, eg effects on local communities and businesses, the impact on tourism, environment and natural heritage in the Cairngorms National Park, etc? The reputation of the CNP should be enhanced and enlarged giving it more significance as a tourism destination and a protected area of world standing. Possibly a somewhat enlarged CNPA would attract individuals of higher calibre bringing relevant skills and experience to benefit performance and delivery of the aims of the park across a wide range of areas including safeguarding of natural heritage. The present defective arrangements can be viewed as likely to put off talented and outstanding applicants with international backgrounds and a breadth of expertise. Impact on environment could be positive both in Perthshire and within areas under pressure in others parts of the National Park. Extending the boundaries should create social and economic benefits in Highland Perthshire, by spreading the tourism benefits of the NP to the whole of what is generally recognised as the wider Cairngorms area. It would also facilitate the consistent management of resources and for example provision for consistent orientation and interpretation for visitors. Abrupt land use management discontinuities with negative effects on landscape quality and with negative effects on the viability of significant wildlife could be reduced with attendant general benefits for safeguarding and enhancing environment and natural heritage. What will be the effects of the Bill be on the administration and management of the National Park and the Cairngorms National Park Authority? It should be helpful in improving governance and a more inclusive style of management capable of delivering more positive nature conservation outcomes with community benefits. As suggested above it might provide greater impetus for improved management with wider vision and renewed emphasis on core conservation goals. It would broaden the scope of partnership working. The standards of decision making and the decision making process could benefit from the likely involvement of a wider range of talent and extended access to voluntary talent as well as wider access to local authority facilities (including for example perhaps Perth Museum and library, local SWT group involved with reserve management and Ranger Services currently outwith the CNP). It should have a positive effect on consistent delivery and revision of the Cairngorms Local Biodiversity Action Plan (Perth & Kinross Council were on the Cairngorms LBAP steering group for this plan) and building on some of the past work of the Cairngorms Partnership. It would help avoid futile artificial division of data sets potentially allowing for clearer analysis of conservation challenges and a more unified and less fragmentary delivery on management related to natural and cultural heritage interests. It should make delivery on conservation goals for example for wide ranging species more achievable in the context for example of increasing prospects of securing adequate habitat networks. It might also benefit conservation management of other species for example with restricted distributions currently just outwith the CNP like the heath Phyllodoce caerulea that is just outwith the current CNP boundary (has an historic cultural interest and that in The Vascular Plant Red Data List for Great
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