The original documentation for the proposals can be read at the
Scottish Natural Heritage website

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As one of the organisations that has campaigned for National Parks in Scotland, the Mountaineering Council of Scotland (MCofS) is pleased to see National Parks on the Scottish political agenda, and for the debate to reach this stage. Along with a number of other Scottish NGO's we believe that the efforts of mountaineers, and others with an interest in the conservation and enjoyment of Scotland's most scenic areas, have led to there being a recognition of the need to protect such places with the highest possible countryside designation. For far too long Scotland has not been a member of the world's nations with National Parks, and we are delighted that is about to be corrected.

Having said that, we are deeply concerned about this current consultation exercise. The consultation document does not attempt to analyse what has gone wrong with the existing system, and we believe that this paper should have explained why a National Park is required in north east Scotland, and what the current problems are that could be addressed and remedied by the introduction of a National Park. Without this appraisal of where we are now and how we arrived here, it is difficult to plan our way forward.

We are very much aware that Government will wish to see Scotland's first two National Parks working effectively before agreeing to consideration of further National Parks. If either of the two National Parks currently being developed should fail to achieve their aims, it is unlikely that any further National Parks will be considered. This is of concern to the MCofS, as we believe that several other areas in Scotland meet the criteria for a National Park and which are deserving of the protection this would offer. Their future National Park status depends on this National Park being a success and we have grave concerns that the process is already heading in the wrong direction.

Planning issues

Given the historic moment at which we now find ourselves with a new Scottish Parliament and a Government commitment to developing our first two National Parks, the MCofS finds it saddening that this consultation document is proposing policies that would make this National Park one of the weakest in the world. The issue of planning powers is fundamental, and in our view a National Park that does not have its own planning powers is simply not going to achieve any significant level of protection for the natural heritage values. The landscape and nature conservation interests, and the promotion and management of recreation and understanding of the National Park can only be administered effectively if there is a unified National Park planning authority as accepted throughout the rest of the world.

It is important that lessons are learned from other countries with existing National Park systems. We do not need to look far to learn from the mistakes made in England and Wales where all the National Parks, except the Lake District and Peak District, were originally set up without their own planning powers. After years of failing to work efficiently this policy was reversed with the 1995 Environment Act, which made the rest of the Parks their own planning authorities. Our fear is that if this National Park begins its life on the wrong basis, then it too could take 40 or 50 years of ineffective working before it is finally given the powers it deserves. It is important that this National Park makes a good start to its life, and that will only happen if it is its own planning authority.

Turning to particular aspects of planning, the issue of bulldozed tracks extending into the heart of wild land areas is one of the greatest threats to the scenic qualities of the Cairngorms landscape and also the main detractor from the quality of the wild land experience. If the National Park is to have any control over planning issues, it is vital that the Park acts with one policy and is able to control the proliferation of such tracks on all sides of the main mountain range. It is of no use whatsoever if one local authority controls such activities, whilst another one allows them to go unimpeded.

The control of forestry development within the National Park is another issue on which the Park Authority must act with one policy and be able to control the type of forestry practice that is allowed to be implemented within the Park's boundaries. Forestry has a major impact on the landscape and biodiversity in this kind of upland area, and it is vital that a National Park authority has a high level of control over an industry that can have a significant, and often negative, impact on the special qualities of the area. The MCofS believes that there should be a strict policy against the use of clear felling within Scottish National Parks.

Likewise, fencing is another issue where the Park Authority must have strong and unified powers to control the use of deer fencing and, for the sake of landscape and nature conservation, to reduce dependence on its use.

Boundaries

The MCofS believes that the National Park should be large enough to protect the core mountain area, but not so large as to be unmanageable. We believe that the core mountain area includes Lochnagar and the Glenfeshie hills, as well as the Ben MacDui and Braeriach ranges. Having considered the range of options given in the consultation document, we believe that the Cairngorms Partnership boundary should become the National Park boundary in most places. The exceptions we would make to this rule are:

1. The addition of sub-unit 23. We believe there is a strong case for including Ben Alder within the National Park.
2. The inclusion of the missing part of sub-unit 24. Although Creag Meagaidh is in SNH ownership, we believe that it should be within the National Park. A possible future Lochaber or Nevis/Glencoe National Park could extend this far east, and it would be strange if Creag Meagaidh were to sit as an island between the two National Parks.
3. The inclusion of the missing parts of sub-units 18 and 20. The Cairngorms Partnership boundary appears to follow a series of non-linear natural features, except for the western part of its southern boundary, where it takes a very unnatural straight line. We believe that a properly thought through line should be drawn in this area, and failing any other being put forward, we suggest the inclusion of the rest of sub-units 18 and 20.
4. We believe there is a strong argument for including more communities in the southern parts of the National Park. This would have the affect of redressing the current imbalance within the Cairngorms Partnership area with most of the population living in Strathspey. The inclusion of Aboyne would provide community input from the east, but it is the south and south east where we feel there should be more communities within the National Park boundary. We consider that there is a case for including Edzell and Kirriemuir within the boundary. They are closely connected with their glen communities, are natural gateways and centres for interpretation, and exclusion would disenfranchise them from park decision-making. We are not convinced one way or the other on the case for Pitlochry's inclusion.

The MCofS is, however, concerned that the National Park boundary should avoid passing over any significant peaks. Although we believe that watershed lines form a useful guide for the Park boundary, we are concerned that having a mountain "half in and half out" could lead to the outside half of the mountain being exploited to the detriment of the landscape of the National Park. The National Park Authority must have the power to control developments such as telecommunications masts on ridges and mountain tops immediately adjacent to the Park boundary. Where a significant peak is on the provisional boundary line we would recommend the boundary being drawn some way down the outside of that mountain, so that the summit and major ridge lines are properly protected within the National Park boundary.

Practical jobs

We believe very strongly that the National Park must create practical on-the-ground jobs throughout the communities that are within and just outside the Park's boundary. Scottish National Parks will not be seen as a success if they only create indoor office-based jobs at computer terminals. Work must take place out of doors if the Park is to make a real difference. Footpath management, education, litter control, and other practical tasks must be properly resourced. Such jobs will contribute significantly to the fabric of the National Park, as well as developing the belief in the local communities that there are tangible benefits from conservation.

Interpretation

Interpreting the National Park will be a major role for the Park Authority and it is important that this task is carried out well. Gateway centres must be identified and facilities set up to welcome visitors, especially first time visitors, to the National Park. It must be accepted, if the Cairn Gorm funicular opens for business, that the policy of promoting a facility that encourages visitors to travel straight to the centre of a National Park is against all principles of National Park management. The National Park looks like being in the difficult position of having a publicly funded development in its core mountain area, which has further public money going into its ongoing promotion. Nevertheless, the National Park Authority should invest in high quality gateway facilities to provide interpretation and other visitor services. We believe that the National Park should have a very active educational role and there should be relevant expertise on the staff and within the board.

The National Park Board

The MCofS wishes to see a range of skills within the National Park board. In particular we believe that there must be people with skills in recreation and tourism, but with recognition that the two are very different. Tourism depends on recreation, but many within the tourism industry do not understand informal outdoor recreation. This must not happen on the National Park board. We also wish to see people skilled in nature conservation and landscape conservation. Landscape is quite often the poor partner and in our view is grossly under resourced within SNH. There must be proper recognition within the National Park of the value of landscape, and there must be a board member with skills in this area.

We believe that the National Park authority must have an adequate representation of national interests. On that basis we support the Scottish Ministers' preference for a park board with the maximum total number of members and the minimum number of directly elected members.

Name of the Park

While the name Grampian would be more historically and geographically accurate, the Cairngorms name is recognised internationally as a landscape of world-class significance. We believe that this National Park should be called "The Cairngorms National Park".