SSE CAIRNGORMS NATIONAL PARK LOCAL PLAN OBJECTION SPECIAL QUALITIES NOTE FROM MARK TURNBULL 1 Introduction 1.1 Mark Turnbull (MT) of Mark Turnbull Landscape Architect (MTLA) was instructed by Scottish and Southern Electricity (SSE) to prepare this note on the ‘Special Qualities’ of the Cairngorms National Park in support of SSE’s objections to The Cairngorms National Park Local Plan 2 Basis for Note 2.1 Experience of preparing the document “The identification of the Special Qualities of the Cairngorms National Park and of the Special Qualities present in the area affected by the dismantling of the existing 132kv overhead transmission line and the construction and operation of the proposed 400kv overhead transmission line” (ANNEX 1) 2.2 Experience of living in Loch Lomond and The Trossachs National Park and being involved in the National Park Plan (ANNEX 2 and 3) and Local Plan processes. 2.3 Topic Paper: The Special Qualities of the Cairngorms National Park (undated) prepared by the Cairngorms National Park Authority (CNPA) 2.4 Meeting with Don McKee of CNPA on 26-03-09 to discuss the Topic Paper. 2.5 Telephone Conversation with Hamish Trench of CNPA on 8-04-09 to discuss the Topic Paper and MT conclusions. 3 Key to understanding CNPA Position 3.1 The National Parks (Scotland) Act 2000 (The Act) in Section 1 sets out the aims of a National Park. In Section 2 the conditions for designation of an area as a National Park are specified as follows: • That the area is of outstanding national importance because of its natural heritage or the combination of its natural and cultural heritage: • That the area has a distinctive character and a coherent identity. CNPA - MT special qualities Note Final 20-04-09 1 20-04-09 • That designating the area as a National Park would meet the special needs of the area and would be the best means of ensuring that the National Park aims are collectively achieved in relation to the area in a co-ordinated way. 3.2 Special Qualities are mentioned only once in Section 1 of the Act in terms of “promoting understanding and enjoyment (including enjoyment in the form of recreation) of the special qualities of the area by the public”. 3.3 With regard to Special Qualities CNPA have interpreted The Act as follows in Section 3 of the Topic Paper: • The special qualities of the Cairngorms National Park are those natural and cultural heritage qualities that not only make the area of outstanding national importance, but combine to give the area the distinctive character and coherent identity that is required in the conditions for establishing a National Park. • While it is possible and desirable to identify individual components that make up the special qualities, it is the sum of their parts – the distinctive character and coherent identity – that is the basis on which the National Park is designated. There is therefore no prescriptive or definitive list of special qualities, as the relevant qualities, their relationships to each other and to the whole will vary over time and place. 3.4 Section 3 of the Topic Paper also notes with regard to this interpretation that this is and has been a consistent approach taken by the Cairngorms National Park Authority and others throughout relevant policies and plans. Clearly this is not the approach taken by Loch Lomond and the Trossachs National Park, the only other National Park in Scotland (Paragraphs 3.6, 6.2, 6.5 and ANNEX 2 and 3) and there is no indication given as to who the others are. 3.5 On this basis, from the outset of work on the National Park Plan, CNPA decided to describe the Special Qualities of the Cairngorms National Park using General Text approach supported by a variety of policies (See Topic Paper Sub-section 5.1), Supplementary Planning Guidance on specific development topics (See Topic Paper Sub-section 5.2) and separate, sometimes very complex and technical documents, some of which have (For example Analysis of Wildness Qualities) or may have spatial expressions (For example:. landscape character) (Topic Paper Sub-section 5.3 to 5.10). 3.6 This, what might be referred to as a Textual Approach, is very different from the Spatial Approach taken by the Loch Lomond and the Trossachs National Park for their National Park Plan. That approach offers both strategic spatial guidance and a detailed evaluation of the “special qualities”. 3.7 CNPA’s position, according to Don McKee (Meeting 26-03-09), is that Ministers approved their approach when they approved the National Park Plan although this meant that the two National Parks did not adopt a consistent approach to the same requirements. 3.8 Given this background the work indicated in Section 5 of the CNPA Topic Paper for the Local Plan Inquiry represents Work in Progress. This would appear to be different from the position taken by Loch Lomond and The Trossachs National Park in which the Special CNPA - MT special qualities Note Final 20-04-09 2 20-04-09 Qualities were defined spatially at the stage of approval of the National Park Plan by Ministers through a detailed evaluation process. 4 The National Park Plan 4.1 Section 3 of the CNPA Topic Paper justifies the position as follows: “Section 3.2 of the National Park Plan sets out the approach to the special qualities of the Cairngorms National Park. It states (p25): ‘The Cairngorms is widely recognised and valued as an outstanding environment which people enjoy in many different ways. Everyone brings their own perceptions and interest to the Cairngorms, but there are some special qualities of the area that are commonly recognised and referred to. This section does not set out to describe all the characteristics of the National Park – much of that information can be found in the State of the Park Report – but it does seek to identify some of the natural and cultural qualities that combine to give the National Park its distinctive identity. Some of these qualities are similar to those in other areas, some are unique. Only here in the Cairngorms do they come together to create the richness and diversity recognised by its designation as a National Park.’ This emphasises that fact that in considering the special qualities, both the individual components and their relationship to the overall integrity of the designation should be taken into account. Section 3.2 of the National Park Plan goes on to identify the following particular components of the special qualities with commentary providing some detail on the nature and extent of those qualities: • distinctive landscape • rich biodiversity • mountains • moorland • forests and woodlands • straths and farmland • rivers and lochs • recreation and enjoyment • the built environment • culture and traditions Section 3.3 of the National Park Plan explicitly sets these special qualities in the context of a dynamic environment and the need to manage change. It states (p28): ‘The special qualities and resources of the National Park are part of a dynamic environment and the result of a long history of changing natural processes, management and perceptions. The qualities that we value today are a snap-shot in time of social, economic and environmental conditions that are continually evolving. CNPA - MT special qualities Note Final 20-04-09 3 20-04-09 The designation of the National Park brings a particular focus to these qualities and a special responsibility for their management, but it does not halt the processes of change and evolution.’ The National Parks (Scotland) Act 2000, the Report on the proposal for designation and the National Park Plan 2007 approved by Ministers therefore set out a clear and consistent basis for considering the special qualities of the National Park: a) the special qualities are the natural and cultural heritage qualities that make the area of outstanding national importance, and b) which combine together in a dynamic environment to give the area its distinctive character and coherent identity; c) the special qualities, their relationship to each other and to the overall integrity of the designation will vary over time and place.” 5 Requirements of CNPA Approach to the Description of Special Qualities 5.1 Given 1 and 2 above, particularly the recognition that the special qualities and their relationship to each other will vary from place to place (area to area), the CNPA Approach requires when considering any area, whether general or site specific, the following to be identified and described: • The Special Qualities present within the area with reference to list in Section 3.2 of the National Park Plan noting any other qualities not mentioned in 3.2 • How the Special Qualities and any other qualities combine to form a Distinctive Character and Coherent Identity • How the Special Qualities and other qualities and the Distinctive Character and Coherent Identity contribute to the designated area as a whole • How the Special Qualities and other qualities and the Distinctive Character and Coherent Identity have and may Vary over Time 6 Implications of CNPA Approach for the Development Process 6.1 Broadly speaking, there are two separate approaches to defining Special Qualities used for the two National Parks in Scotland: the Spatial Approach used by Loch Lomond and the Trossachs National Park Authority and the Textual Approach used by CNPA (Paragraph 3.5). 6.2 Loch Lomond and the Trossachs National Park Authority have satisfactorily demonstrated that Special Qualities and Distinctive Character and Coherent Identity can be identified and described both textually and spatially as part of the National Park Plan (ANNEX 2 and 3). 6.3 There are three main difficulties with the purely Textual Approach, that is, non-spatial approach, used by CNPA.