SECTION 5 – STAKEHOLDER VIEWS AND NEXT STEPS
This section reports on the steps SNH took to ensure stakeholder involvement in the development of this advice. It also summarises the views expressed by stakeholders who commented, and makes suggestions for the next stage of consultation and policy development.
1 In developing this advice, SNH was asked to work closely with a range of relevant stakeholders, including those from the business, community and environment sectors. We engaged these and other stakeholders in the following ways.
- Writing to over 300 interested parties informing them of the scope of the task, the programme of work to be undertaken and inviting them to comment on the key issues and potential areas. This invitation to contribute resulted in over 60 written responses.
- Preparing press briefings and articles for newsletters to increase awareness of our work and the opportunities for engagement.
- Developing specific coastal and marine National Park pages on the SNH web-site, with key discussion papers, research findings and updates of progress posted on it, together with an opportunity to contribute via a message board. Over 40 individuals contributed to this, including many individuals - tourism operators, fishermen and farmers - from Mull and the wider Argyll area.
- A stakeholder group of 25 organisations was established to facilitate consideration of key issues.
Membership of the Coastal and Marine National Park Stakeholder Group
British Marine Federation Scotland, British Ports Association, COSLA, Crown Estate, Federation of Scottish Aquaculture Producers, FRS Marine Laboratory, HIE, Historic Scotland, Maritime and Coastguard Agency, MOD, Royal Yachting Association, Scallop Association, Scottish Enterprise Network, Scottish Environment Link (NTS, Ramblers Association and SWT), Scottish Coastal Forum, Scottish Fisherman’s Federation, Scottish Renewables Forum, Scottish Rural Property & Business Association, Scottish Shellfish Growers Association, Scottish Sub-Aqua Club, SEPA, Sportscotland, VisitScotland and the Scottish Executive.
The group met four times and discussed papers on a number of topics, including the added value of National Parks, local community concerns over National Parks, powers and governance, fisheries management, aquaculture and the assessment process. It also received presentations from the chief officers of Loch Lomond & the Trossachs and the Cairngorms National Parks on lesson learned, from a board member and land owner from the Cairngorms National Park on local community concerns and briefings on the work of the Firths Partnerships, the Scottish Sustainable Marine Environment Initiative (SSMEI) and the Scottish Inshore Fisheries Strategy. Meetings and papers for these meetings are available on the SNH website (ww.snh.org).
- National seminars were held on the 30th November 2005 in Inverness and 8th December in Glasgow 2005 – nearly 150 people attended these two events from over 90 separate organisations.
- Stakeholders requested a number of meetings both locally (Mull and Iona Community Trust, Fair Isle Community Partnership, Wester Ross Alliance, Shetland Isles Council, Western Isles Council, Argyll and Bute Council) and nationally (Scottish Fishermen’s Federation, SIFAG, Scottish Environment Link, RSPB, Scottish Council for National Parks, Scottish Canoe Association, Scottish Sea Anglers Association, British Ports Association). Concerns over coastal and marine National Parks were also raised by members of the public at an informal session of the SNH North Areas Board in Mallaig in August. A presentation was also given on the work to the Advisory Group on the Marine and Coastal Strategy (AGMACS) on 6th February 2006. Regular liaison meetings with a number of partner organisations also provided further opportunities to keep stakeholders informed.
2 An overview of the initial views made by stakeholders is set out below. Further analysis of the responses received in writing, the views expressed by stakeholders at the two national seminars and also the contributions made on the SNH message board is contained in background paper E.
3 Ministers did not ask SNH to consult on specific proposals. While some local communities and stakeholders attended the events or contributed comment in writing, we did not organise any local public meetings during the development of our advice. This has caused some confusion and concern, particularly among some of the local communities in the areas that have been suggested as possible candidates for Park status in this report. If Ministers now decide that any area, or areas, should merit further consideration for Park status, it will be vital that local communities are given the resources, information and time to consider the proposals.
Initial Stakeholder views
4 Overall, the main themes that have emerged from stakeholders are as follows.
- Support for the principle of a coastal and marine National Park,
with specific expressions of interest in the concept made by Argyll and
Bute and Dumfries and Galloway Councils, and also the community on Fair
Isle. Other areas being proposed tend to be on the West Coast, with Argyll
and Lochaber most frequently cited. The Clyde, Moray and Solway Firths,
together with Shetland and the Western Isles, were also suggested.
· Opposition to the principle of coastal and marine National Park, from specific sectors, communities and individuals.
- Concern over where coastal and marine National Parks fit in with other current initiatives – such as the establishment of inshore fisheries management groups and SSMEI project - and future ones, notably in relation to ICZM and marine spatial planning.
- Concern over the added-value of a coastal and marine National Park and doubts over what it would do in practice. Views here ranged from those seeking a Park which could do more to protect and enhance the coastal and marine environment through to those who believed that additional measures were not necessary or desirable to achieve this.
- Concerns that a National Park would impose further bureaucracy and restrict future development opportunities for specific activities or communities more widely.
- Fears that a National Park would be imposed from the ‘outside’ and that local stakeholders would be in a minority on a Park Board.
- Positive aspirations for a Park were also expressed by some environmental groups, most notably in respect to it delivering significant conservation measures in relation to fisheries management.
5 Individuals and some communities (notably on Fair Isle), tourism organisations and operators (Shetland and Argyll), environmental groups and two local authorities (Argyll and Bute and Dumfries and Galloway Councils) expressed positive interest in a coastal and marine National Park. The case put forward by these two Councils is largely based on the assistance a Park could give to the social and economic development of their more remote and fragile coastal communities. Argyll and Bute’s thinking is most developed at present, with suggestions made in terms of an area and also the detailed arrangements for the Park Authority. In partnership with Local Enterprise Company, Dumfries and Galloway Council have commissioned consultants to prepare a more detailed case for their area.
6 In the absence of specific proposals, many stakeholders remain at best neutral, or sceptical, or opposed to the concept, and have struggled to see how it would work and what it could add to existing initiatives. Concerns are strongest in the fishing and aquaculture sectors. Some local authorities (Western Isles, Shetland), communities and port and harbour interests have also expressed similar views.
7 Fishing interests in the north and west have been most openly against the concept. This contrasts with the discussions at the SNH stakeholder group. In this group there was acceptance if not agreement with the Ministerial commitment to establish a coastal and marine National Park. There was also broad support for fisheries management within a Park to be taken forward through the local inshore fisheries groups supported by the Park Authority.
8 Increased awareness of SNH’s work has led to uncertainty about what sort of Park might be created. Communities and other stakeholders are also seeking reassurance that they will have an opportunity to be fully consulted on proposals, particularly in the areas that SNH’s advice highlights for further consideration. They also want reassurance that a Park will not be ‘imposed on them’ simply to meet Ministerial commitments.
9 Some detailed comments were also made on powers and governance of a Park and its role in respect to conservation, recreation, fisheries management and social and economic development. On powers, a spectrum of views emerged. At one end many of the environmental groups called for a strong Park, with full planning and access authority functions and a range of powers to control other activities. In contrast, sectoral interests, such as fishing, aquaculture and ports and harbours, suggested limited involvement by a Park in their activities. Local authorities expressed general concern over the loss of their powers and functions to a future Park, with some arguing that it would be more efficient for these existing and democratically accountable organisations to be given the funding to take forward this work directly.
10 The balanced aims of Scottish National Parks, the powers and governance arrangements and the direct experience now emerging from Loch Lomond & the Trossachs and the Cairngorms suggests that some of the concerns and fears expressed by stakeholders would not be realised in practice. The questions of policy fit and added value are therefore perhaps more significant, though the advice provided in Sections 2 and 3 of this report provides the means to address these issues.
11 Finally, it is clear that many stakeholders would see a direct benefit from a coastal and marine National Park if it led to a simplification of approval procedures in its area, and this is something that it would be useful for the Ministerial Advisory Group on the Marine and Coastal Strategy (AGMACS) to consider further as part of their wider debate on the simplification of the maritime consent processes. The planning and enabling model of Parks, as suggested in this report, does not contribute to this agenda directly, though there is scope for it to develop ‘first-stop-shop’ approaches. In time if it were decided that the Park should take over the powers and functions of other bodies by direction or on a voluntary basis, the approach could also lead to a simplification of the current regulatory environment.
12 SNH’s work in preparing this advice is the first step in the much longer process required to establish a National Park illustrated in Figure 1. A programme of policy development and capacity building among key sectors will be crucial throughout this process, and suggestions of possible elements of this programme are made below.
Development of proposals
13 It is only once specific areas come forward for consideration that a more detailed case for a National Park can be made and detailed options for boundaries, powers and governance developed. We believe that our advice contains much of the framework for developing these options but further work is clearly needed on them prior to any formal statutory proposal for a coastal and marine National Park under Section 2 of the National Park Act 2000. We suggest this work would best be undertaken by local partnerships, supported by local authorities, SNH and other public bodies. A key aspect of this work will be the development of better social, economic and environmental profiles of the areas spotlighted.
14 Of all the issues SNH has addressed in developing this advice, fisheries management within a National Park is undoubtedly the one that has caused most controversy. To this end, we suggest that specific work should be commissioned to look at relevant experience of fisheries management in Europe and elsewhere. A seminar of relevant stakeholders could also be organised to discuss the conclusions of this work. This proposal has already been raised by SNH with the Scottish Executive.
15 The national stakeholder group established by SNH has provided a useful sounding board for the development of our thinking. One or more such local stakeholder groups could play a similar role at the next stage of the process of developing proposals suggested above, with membership tailored to the specific needs of the areas under consideration. Highland Council has already proposed a one-off meeting for the stakeholders in their area.
16 Information on National Parks should be provided more generally in the areas Ministers decide to focus on, and a range of means should be used to do this including web pages, newsletters, leaflets and newspaper articles. This information should include updates on the process, but also more general material on the Scottish approach to National Parks and on relevant experience from elsewhere.
17 Opportunities should also be sought for key stakeholder groups – communities, land managers and fishermen - to visit and access at first hand Parks in other locations. Such trips proved successful in building capacity among such stakeholder groups in the Cairngorms – with a study trip arranged by FWAG for farmers to two French Regional Parks and Cairngorms community groups meeting with their equivalents from Loch Lomond & the Trossachs National Park. Early efforts should also be made to engage closely with young people in the areas concerned.
18 For any areas specifically spotlighted by Ministers, consultation will need to include a range of local consultation meetings, events and surgeries, as well as a formal consultation paper. Building on the experience in the Cairngorms, the use of community-based facilitators should also be considered. Consultation at this stage need not be as extensive as the consultation SNH undertook as the statutory reporter for Loch Lomond & the Trossachs and the Cairngorms but needs to be sufficient to engage people meaningfully in the debate, to identify key issues and to gauge public opinion in the area. We are strongly of the view that this consultation effort prior to a formal proposal for a National Park is a necessary investment required to bring Ministers’ aspirations to establish a successful, locally supported, coastal and marine National Park to fruition.
19 A more detailed programme of activity will need to
be developed to deliver this work within the current timetable. As an
important first step in the process, Ministers have asked SNH to make
its advice publicly available as soon as possible. A copy of this advice
will also be sent to every organisation and individual who contributed
to the process, either in writing or through involvement in the national
stakeholder seminars or other meetings. The early release of this advice
will provide an opportunity for stakeholders to contribute their views
to Ministers, and allow for further dialogue to take place prior to formal
consultation on more specific proposals.