As a group of eight organisations with more than 350,000 members who value
Scotland’s high quality landscapes, we commend the Scottish Government for
recognising the value of Scotland’s wild land, which is without price.
However, we must emphasise that all impacts upon valued areas need to be
managed, not simply developments within such areas. We feel the Scottish
Government, Scottish Natural Heritage and other organisations must now use
all relevant policies to safeguard the experiential qualities that make
Scotland’s landscapes so valuable to residents and visitors.
We welcome the growing recognition in national government of the importance
of Scotland’s landscapes and the need to ensure their special qualities are
not lost through unsuitable development. The current government
consultations on the Scottish Planning Policy and the National Planning
Framework are an opportunity to set the national planning rules for many
years to come.
We support the increased protection proposed for national parks and
national scenic areas, though this merely formalises the present de facto
Such protection should apply also where development is proposed beyond
their boundaries that would impact upon the very qualities they were
established to safeguard.
While the current greatest threat is large onshore wind developments, the
same considerations should apply equally to any large development proposal,
including transmission lines.
We fully support the recognition of the importance of wild land but are
very concerned at the level of protection proposed for these and other
important areas such as national nature reserves.
The current draft states that in such areas wind power developments will be
acceptable “where it can be demonstrated that any significant effects on
the qualities for which the area is identified can be substantially
overcome by siting, design or mitigation”.
This will allow inappropriate developments to be approved because of the
lack of clarity in using subjective words such as “significant” and
“substantially” when set against the primacy afforded in Government policy
to economic and energy development.
Core areas of wild land as defined by Scottish Natural Heritage should be
given the same level of protection as national scenic areas, including
protection from visually intrusive developments beyond their boundaries.
Several current planning applications lie within core areas of wild land.
They must be rejected now if there is to be substance to the Government’s
affirmation of wild land’s importance.
We are concerned at the proposal that locally significant landscapes,
designated as such by local councils, should be regarded nationally as
areas where there are “opportunities for wind farm development”.
If local authorities and their electorates think particular local
landscapes are important then this should not be over-ridden nationally.
The consultations close on July 23. Our members will expect the outcome to
be a planning framework that ensures no more of Scotland’s iconic
landscapes are damaged.
Association for the Protection of Rural Scotland;
Chairman, John Muir Trust;
President, Mountaineering Council of Scotland;
President, The Munro Society;
Convener, Ramblers Scotland;
Chairman, Scottish Rights of Way and Access Society;
Co-ordinator, Scottish Wild Land Group;
Chairman, National Trust for Scotland,