Following the poorly designed consultation on creating a new National Park for Scotland which took place May-June (see here), the Scottish Government asked NatureScot, its statutory adviser on such issues, to provide advice on the role of National Parks and “how new nominations for National Parks could be evaluated”. In the summer NatureScot set up a Stakeholder Advisory Group (see here), which has considered two papers and then on 6th October launched a consultation with 40 questions (see here). This closes on 30th November .

Just over half the questions in the survey are about the thorny issue of how to select what area should be designated as Scotland’s next National Park.  That issue may well raise a fair amount of heat but is in my view far less important than re-designing both our existing and any new National Parks to be fit for purpose.

Questions about this comprise the first half of the survey and are grouped into three sections on the role, statutory aims and powers and functions of National Parks.  Unfortunately,  they appear designed to turn our National Park Authorities into vehicles for “green finance”, controlled by “green lairds” which will benefit neither visitors or locals and where “greenwashing” will be the order of the day.

 

What is the problem?

The first paragraph after the introduction contains the key to understanding what has gone wrong:

“Scotland has ambitious targets and priorities to meet the challenges we face in tackling the climate and nature emergencies and we need to transform what we do, and how we do it, if we are to deliver them. Scottish Ministers wish to see Scotland’s National Parks as places that will actively demonstrate nature recovery and the transformational change needed in our approach to land-use, providing leadership and showcasing a just transition to net zero in Scotland.”

It may seem strange that I am critical of this statement, having long argued on parkswatch that our National Parks need to being doing more to address the climate and nature emergencies (eg floods, landslips, overgrazing, muirburn etc).  Indeed, the use of the term “nature emergency” is a significant step forward as the Scottish Government has so far refused to declare one and National Planning Framework 4 which has just been published only refers to “nature crisis”.  It looks as though the Green Minister for National Parks, Lorna Slater, is having an impact but the problem is that the emphasis  is being put on climate and nature to the exclusion of everything else while at the same time the main solutions to these issues is seen to lie with private enterprise.

It is important to note here that there has still been no analysis of why our National Parks have delivered so little to date, something I called for in my post back in May.  Instead the introductory section contains false claims such as that our National Parks “are at the forefront of landscape-scale action for nature restoration” when all the successes have been almost entirely down to conservation minded landowners.  No mention of the failure of the Loch Lomond and Trossachs National Park Authority to change damaging industrial forestry or that of the Cairngorms National Park to reduce deer numbers in places like Caenlochan.

Before explaining these problems further in my draft response to the first three questions in the consultation, it is worth reading the last part of the introduction

Commentary on the first three questions

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

No. It is not that these are unworthy aims or that National Parks could not be giving far more of a lead in this area, it is that this will distort all the other aims of National Parks. So, for example, if “just transition to net zero” is the overriding purpose there would very quickly be pressure from developers to open up all the land in our National Parks to windfarms without any regard to the landscape.

The National Parks (Scotland) Act was designed to require National Park Authorities to consider and promote four separate statutory aims collectively and not put any of these first, except where they conflicted with each other (in which case the Sandford principle which put conservation first was meant to apply). Three of those aims taken together (wise use of resources, conservation and sustainable development) should in theory have enabled our two National Parks to be at the forefront of tackling climate change.  No analysis has been presented of why this hasn’t happened or why a new purpose, whether overriding or not, is required..

There are, however, two basic flaws in our National Parks current duty to conserve the natural heritage. The first problem has been that the conservation duty has not strong enough to override planning policy that was designed for all of Scotland and as a result our National Park Authorities have consented to damaging developments on the proviso that the developer does some mitigation elsewhere just like every other planning authority in Scotland.  The second problem lies in conservation legislation where the emphasis is on conserving what is there (even grouse moors!) rather than restoring natural processes (or enabling nature to restore itself).

Reform is therefore needed in this area but these two problems will not be addressed by “leadership” alone while the term “nature recovery”, again used in NPF4, is highly problematic. What we need is an approach which lets nature re-wild itself,  which would happen if grazing levels were reduced, muirburn stopped and industrial forestry based on plant and fell was replaced by continuous cover forestry.  This would  be a far cheaper and more effective way of restoring nature and locking up carbon than planting trees behind deer fences which is what currently counts as “nature recovery”.

It is also predictable that without proper funding, as soon as an overriding purpose is adopted National Park Authorities will be driven to spending what resources they do have on that purpose: on projects like peatland restoration, rather than on outdoor recreation and footpaths. In other words important aspects of their current purpose will become completely neglected.

 

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

None. If we are to address climate change and the nature crisis we need public investment. Promoting, recognising, accelerating, testing, championing and leading on improving don’t actually DO anything that will result in change. Instead, the primary role of National Parks being proposed is to facilitate private investment in “natural capital”.

Had there been any analysis accompanying the consultation, it would have been obvious that the main consequences of so-called green investment in natural capital to date has been soaring land prices as private companies seek to evade their responsibilities to decarbonise their operations by carbon offsetting. The rub is that almost all the projects to capture carbon on the land that has been bought by these new “green lairds” – like BrewDog in the Cairngorms National Park – are being paid for by the general public through forestry grants and peatland restoration schemes.

Moreover, most of the “ecological restoration” paid for in this way is unlikely to last long because the fundamental issues that have caused so much damage to the natural environment are not being addressed. Much peatland restoration work is already failing because deer numbers have not been reduced, so deer are once again trampling and browsing the vegetation back to bare peat.  Meantime a high percentage of the native woodland planting projects paid for by the public purse have failed to develop into healthy regenerating forests because deer have got through the fences which are not maintained after the first few years.

The whole approach being proposed in this question encapsulates the neo-liberal view that the state should not do anything directly but everything should be left or handed to the private sector.  That ideology has played a major role in failures across the world to address the climate and nature crises and why biodiversity in Scotland has continued to collapse since the creation of the Scottish Parliament and our National Parks.

 

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

Scotland should reject private investment as the main means of addressing the climate and nature crises. There are private landowners, like Anders Povslen who owns and finances Wild Land Ltd, who have invested large amounts of their own money but they are very much the exception, not the rule.

What businesses – those owned by Anders Povslen included – and wealthy individuals need to prioritise is investing to reduce their own carbon emissions and polluting practices.  And where they fail to do so, government needs to take enforcement action. While the Scottish Government does not have the same range of powers available to the UK Government, there is plenty it could do.  For example, it controls waste disposal, air quality and water quality and could either limit practices that damage the natural world or consume carbon directly or use tax, as it has done with plastic bags.

Without addressing carbon emissions, all encouraging “private investment” in “natural capital” will do is turn the land market into an even bigger casino that acts as further block to progress..

But as importantly from a public investment perspective, the amount of money required to restore natural processes, which will also help absorb carbon from the atmosphere, and end the main forms of damaging land-use in our National Parks is relatively small. The worst impacts of intensive grouse moor management could be addressed simply by banning muirburn which would allow large areas of moorland to develop either into peatbog or woodland,  Agricultural subsidies could be redesigned so that farmers were paid more to keep fewer numbers of sheep in enclosed areas.   The largest investment required would be to reduce the numbers of deer but much of this could be financed if the money currently spent on erecting deer fences and planting trees in plastic tubes was used to employ stalkers.  Once deer numbers were reduced our National Parks could then start leading the way in  extending continuous cover forestry, as practiced on the continent, across areas not primarily zoned for nature.

 

An alternative model for National Parks

I hope I have said enough to indicate that NatureScot’s consultation questions are highly problematic and to prompt those who are concerned about greenwashing and corporate takeovers of the countryside to register their objections through the consultation to National Parks being given any role in this.

Interestingly, one of the papers (see here) written by NatureScot staff and presented to the Stakeholder Group sets out a couple of very different models for National Parks.  It provides a very useful sources of ideas for answering some of the other consultation questions, e.g on what new powers are needed, and I will consider it in a further post before the consultation closes.