The draft Designation Order is available here

Introduction
The Mountaineering Council of Scotland welcome the opportunity to respond to this consultation, which concerns the future management of one of the finest mountain ranges in the British Isles. We wish to be kept informed of this issue and look forward to continued dialogue with SNH and the Scottish Executive as plans for the National Park are developed.

The Mountaineering Council of Scotland (MCofS) is the representative body for hillwalkers, climbers and off-piste skiers and receive core grant funding from sportscotland in recognition of this status. We are a membership organisation with about 1,800 individual members plus 130 affiliated clubs that contain approximately 7,000 members. Our Committee structure is entirely voluntary and appointments are the result of a democratic process. The professional staff complement is made up of 3.5 posts at our Perth office.

The MCofS has two overriding concerns about the draft Designation Order (dDO); the proposed boundary and the planning functions. We will describe these two issues separately, but should point out at the outset that we regard these two areas of concern as inextricably linked. The insistence on pursuing the policy of allowing local authorities to retain planning powers, against considerable opposition, has undoubtedly led to the proposal for an illogical and unworkable boundary. If the Cairngorms National Park is to be successful, we believe these two key problems must be resolved.

The Planning Function
The MCofS is concerned that the Scottish Executive appears determined to repeat a mistake that was first made over fifty years ago in England and Wales. The first two National Parks (Peak District and Lake District) were created with the park authorities having full planning powers, but the third (Snowdonia) had its planning functions left in the hands of the local authorities. The local authorities in the next seven parks then opted to follow the Snowdonia model as they were set up through the 1950's. After 40 years the UK government finally recognised the error that had been made, and the Environment Act (1995) converted the 8 National Parks without full planning powers into independent planning authorities.

It will be unfortunate if Scotland makes this same error, especially when so much has been learnt in the intervening time about managing areas of high scenic, recreation and conservation value. Indeed, international opinion on National Park management is now firmly behind the view that it is of vital importance that an independent planning board has responsibility across the whole of the designated area. Without this level of management the Cairngorms National Park would not achieve the recognised International Union for the Conservation of Nature and Natural Resources (IUCN) Category V criteria, the international recognition of a Protected Landscape. We are highly concerned that this would make the National Park title, in this instance, virtually meaningless, and as a consequence this could have a negative impact on the Cairngorms prospects of achieving World Heritage Site status.

We are fearful that if the English and Welsh mistake is repeated in Scotland, it could take a similar length of time before the error is acknowledged and corrected. The Cairngorms cannot afford to be administered in such an inefficient and unacceptable way for the next forty years. Furthermore, the performance of Scotland's first two National Parks will determine whether other areas of Scotland are to be awarded this highest level of designation. Having created a workable model in the Loch Lomond and the Trossachs National Park, it will be a tragedy if problems in the Cairngorms National Park result in a setback to the future management of other scenically attractive areas of Scotland.

The National Park Boundary
The proposed policy of leaving local authorities in control of planning functions has led to the nonsensical belief that the number of local authorities must be limited in order to make the National Park manageable. The consequent proposal to leave Perth and Kinross, and Angus Councils out of the Park represents a confounding lack of logic. As an absolute minimum the Cairngorms National Park should protect the core mountain area, which should involve the incorporation of a "buffer zone" around that core. By disregarding the northern edges of these two local authority areas, the southern parts of the core mountain area are left conspicuously exposed.

The proposed boundary is not justified in the dDO, and it bears no resemblance to any previous boundary that had been considered in a consultation exercise. In our view this has led to a feeling of bewilderment and disempowerment amongst many of the people who responded to previous consultations. Well thought out arguments have been ignored, and in their place we are presented with a boundary that cuts through the middle of villages, golf courses and the Lecht ski area.

The National Parks (Scotland) Act states that there should be a "coherent identity" for a National Park, but the illogical and arbitrary boundary proposed in this dDO does not fulfil that criterion. A great deal of work was carried out by SNH into the potential Park boundaries, and whilst many would dispute certain sections of their favoured option, they did conduct a thorough investigation and presented a well thought out and logical boundary. For that proposal to be discounted without any rationale being offered is at the very least disappointing, and it certainly represents a blow to all those who believe in, and take part in, consultation exercises, and who expect to see subsequent decisions being explained and a reasoning given for suggestions that have been rejected.

The dDO proposes a much smaller area than had been expected, presumably because this is regarded as being more manageable; however, if the Park is to be this size the boundary should still be re-drawn, because this current proposal appears to have no conservation or recreation management basis whatsoever. It has the appearance of being built around reasons more connected to economic development and political expediency, and if that is the case the Scottish Executive should clearly state so.

National Park Board
The MCofS supports the proposal for a National Park board with 25 members, along the lines of the new Loch Lomond and the Trossachs National Park board. We are concerned, however, that the proposal for reducing the number of local authorities to only three would mean Highland Council holding 50% of the local authority places on the board. This is not acceptable and we fear that such an arrangement would lead to ongoing criticism that could restrict the Park's effectiveness for years to come. This may be what Highland Council have indicated as their preferred option, but to build the Park around that aspiration will, in our view, be to repeat the Snowdonia mistake from 1951.

Conclusions
It is noticeable that recent consultation material published by SNH and the Scottish Executive has failed to explain why a National Park is needed in the Cairngorms, and this absence of a justification for the park is, in our view, at the heart of the reason why the existing problems, and therefore the real need for a National Park, are not being addressed and why efficient administration and effective delivery of conservation measures are not being regarded as major priorities.

The MCofS is most definitely of the view that to improve on the current management system in the Cairngorms there must be a National Park Authority with full planning powers. We believe that anything less will not lead to an improvement, and may well lead to a deterioration, in the protection of this popular mountain area. We do not want to see public money being spent on making matters worse than they are now, but sadly that appears to be a very real prospect. The MCofS is a strong supporter of the concept of National Parks, but considering the National Park on offer in this current consultation, we unfortunately question whether Scotland might be wise to reject this particular proposal for a Cairngorms National Park.

As a recreational body with a great concern for the natural environment we remain committed to National Parks in Scotland, and to there being an effective Cairngorms National Park. We hope that the illogical boundary proposals, which were not the result of public consultation, but were contained in this dDO, will now be rejected and the SNH proposals properly considered. In our view this consultation has wasted valuable time in the process of setting up a Cairngorms National Park, and it may now be necessary to repeat this dDO stage of the process. Indeed, we certainly hope that this stage will be repeated given how this document has been so disconnected from the lengthy process of consultation that went before it. The launch of the National Park may need to be delayed as a result of this, but in our view the time taken to create a more logical and workable National Park that has wide respect and support, will be time well spent.

22 August 2002

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