The Royal Society of Edinburgh (RSE) is pleased to respond to the Scottish Natural Heritage consultation on the proposal for a Loch Lomond & the Trossachs National Park. The RSE is Scotland’s premier Learned Society, comprising Fellowselected on the basis of their distinction, from the full range of academic disciplines, and from industry, commerce and the professions. This response has been compiled by the General Secretary with the assistance of a number of Fellows with substantial experience of conservation and the environment.

The Society welcomes the Proposal as a whole and believes that this first Scottish National Park, when established, will represent a major step forward in the conservation and management of a prime example of our National Heritage, to the benefit of all concerned.
The specific questions identified by the consultation paper are addressed below:

General

whether the general area of Loch Lomond & the Trossachs meets the legislative conditions for designation as a National Park.
From a scientific point of view, as well as in other respects, the Society believes that the general area outlined fully meets the legislative conditions for designation as a National Park. The area is undoubtedly of outstanding importance (national and international) because of its natural heritage, and it has a coherent geographical identity.

Area

on any aspect of the area illustrated in Map 2, but particularly:

whether the proposed area of the National Park generally adheres to the conditions set out in the National Park (Scotland) Act 2000;
The Society believes that proposed area does adhere to the conditions set out in the Act.

whether the proposed area is the right size to enable the aims of the National Park to be effectively delivered;
Overall the proposed area has a coherence that allows for adequate management of its various elements and in particular the natural heritage. It should not prove administratively cumbersome and the local authorities whose boundaries span the proposed Park have significant common interests and problems which are capable of joint solution.

the inclusion of the Argyll Forest Park within the proposed park area.
The Society would be in favour of including the Argyll Forest Park within the proposed park area, to which it relates effectively. The Forest Park requires careful and sympathetic management and this can be achieved economically and sensitively within the framework of an effective National Park Planning Authority.

the inclusion of Strathfillan and West Glen Dochart (including the communities of Crianlarich and Tyndrum) within the proposed park area.
An argument against formal inclusion of this area is that the natural heritage element, whilst worthy, is not unique or of special interest. If the area was excluded, the communities of Crianlarich, Tyndrum and Killin would still be close enough to the boundaries of the Park for the local authorities concerned to work together with the Park Authority to safeguard local economic, natural heritage and community interests.

the exclusion of East Glen Dochart and Glen Lochay from the proposed park area.
The Society believes arguments advanced for exclusion of these areas are strong, as they are not a coherent part of the park area.

the inclusion of the Loch Earn and Ben Vorlich area within the proposed park area.
The Society favours the inclusion of Loch Earn and Ben Vorlich in the proposed park area. The natural heritage of this area is under some pressure from recreational and general tourist interests and their inclusion would strengthen the position of the four Sites of Special Scientific Interest (SSSI) around Loch Earn.

the exclusion of Flanders Moss and the agricultural land around Loch Ruskie from the proposed park area.
Flanders Moss presents a difficult choice because of its exceptional ecological and conservation importance. Flanders Moss East is the largest single area of not too damaged raised mire left in all Britain and peat cores taken from various parts of the mire have led to informative pollen and macrofossil analyses linked to radiocarbon dating and to numerous archaeological remains. There have also been very thorough geomorphological investigations on the Late Quaternary sediments of the area.

However, geographically and ecologically it is difficult to see the area as part of the Loch Lomond/Trossachs and would enlarge the Park considerably into an area of a very different character. So long as its integrity is adequately protected by other designations (and the Moss is already an important Special Area of Conservation (SAC)), the Society believes that there is less justification for including it in the National Park.

the inclusion of the Lake of Menteith within the proposed park area.
The Society agrees that the Lake of Menteith and its woods, with their importance for biodiversity, link well to the Trossachs and should be included in the Park.

the exclusion of Strathendrick and Strathblane from the proposed park area.
The basaltic and other base-rich rocks of the Campsie Fells support a noteworthy flora and vegetation on the cliffs and in the little valleys, with a largely blanket-peat covered plateau. However, the area surrounding Balfron has quite different land characteristics to the rest of the proposed Park and so long as key areas within this area are adequately protected by other designations, there is no compelling reason for including this large, and highly populated area within the Park.

Powers

further powers that could be envisaged for the Park Authority.
The list of scheduled powers is comprehensive. It is not clear, however, whether the Park Authority will be able to exercise all the Scottish Natural Heritage (SNH) powers in their area, for example, ranger provision, all bye laws, different types of access, management and footpath agreements and bye laws over water. It is also assumed that grant aid powers will remain with SNH but that these would be exercised in consultation with the National Park. In addition, although local authorities at present have responsibility for waste disposal and related issues, some devolution to the Park Authority could be considered so that a uniform policy and ensuing actions can be followed.

the approach to the planning function, and specifically the merits of the preferred option for the Park Authority becoming the planning authority for the area, with responsibility for preparing the local plan and making development control decisions based on it.
In order for the Park Authority to be able to provide leadership and implement the objectives of the Park, it will need adequate powers. Influence and consultation with a number of other planning authorities will not be sufficient, as has been well demonstrated elsewhere, and there would be a danger that different authorities could adopt different standards, resulting in a piecemeal approach. There should be a statutory duty on other bodies to conform to the Park Plan, and the Park Authority should become the planning authority for the area, with responsibility both for the local plan and for development control and it should be consulted over structure plans.

the consultation arrangements between the Park Authority and Local Authority, and on which types of cases it would be particularly important for the National Park Authority to seek the views of the local authority.
The Society believes it will be important for consultation arrangements not to be too complicated in order to allow the Park Authority as planning authority to operate efficiently. The Park Authority should only be expected to consult with local authorities on those matters of particular importance to them. This should be clearly defined as some implications for implementation of the structure plan policy outwith the park would create significant costs for local authority services.

Adequate provision should also be made for the notification and consultation of local authorities whose areas, while not within the area to which a National Park proposal relates, may be affected by proposals coming from the National Park Authority. An example would be where the rerouting of traffic within the Park affects flows on the roads in adjacent local authorities; another would be where conservation measures taken, say in relation to the marine environment, affect adjacent areas outwith the Park. Such a provision for consultation would not, however, imply that all local authorities outwith the Park's agreed boundaries would need to be members of the National Park body. Similarly, provision should be made to enable Park Authorities to influence events outside the designated area that may have an impact on the area. For example, the construction of a dam for irrigation, water-supply or industrial purposes upstream from a park; deforestation or changes in use of neighbouring land that may affect the faunal balance in a park or alter the pattern of water-run off; or mining operations.

the requirements which should be placed on the composition of any planning subcommittee of the National Park Authority necessary to ensure democratic accountability for planning decisions.
The Society accepts that where the Park Authority does not have a majority of local authority councillors or directly elected members on its Board, a sub-committee of the Park Authority should be formed to deal with development proposals.

Representation

the size of the Park Board, and the number of its directly elected members.
The Society believes that the size of the Park Board is acceptable. Given that local people will be represented through their elected members and through the Local Authority nominees, the number of elected representatives also seems appropriate. However, this number should not be reduced and some difficulty may be encountered in finding suitable candidates for nomination and for election.

the approach to local authority nominations proposed, and on alternative approaches that could be envisaged.
The Society is content with the approach to local authority nominations.

the potential areas of knowledge and expertise of nominations by local authorities and appointments by Scottish Ministers.
With regard to the list of potential areas of knowledge and expertise that nominees and appointed members of the Board might be expected to cover, the Society has one important reservation. Under aim (a) - to conserve and enhance the natural and cultural heritage of the area, an extremely important area of expertise has been omitted - this is wildlife conservation or ecology, both terrestrial and aquatic. This area of knowledge and understanding will be key to a National Park authority, and is not adequately covered by the term biodiversity within "biodiversity and earth heritage", important as this is. This is a serious omission since the Park will be a major wildlife resource, requiring good conservation practice that goes beyond the maintenance of biodiversity.

While the Society agrees that it would be unwise to reserve Board places for specific public bodies or interest groups, we would suggest that the designation order might include the list of potential areas of expertise with a wording to indicatethat it is expected that these should be 'covered as far as possible'. It will also be important to look for individuals with a range of knowledge who can take a holistic view and clarify whether substitutes will be allowed for nominated experts unable to attend meetings.

In addition, the Society is concerned that the requirement for conservation has not been given priority over the other aims. This ambivalence on the primacy of conservation, will not serve the Park well and indeed unless the prime reason for National Parks is recognised as conservation, why designate them?

the total number of local members on the Park Board, and the number of these who should be nominated to the Board by local authorities and appointed by Scottish Ministers.
The proposed numbers of 'local members' and local authority nominees seem appropriate.

the timing of the direct elections in respect to the selection of other elements of Park Board.
With regard to the timing of direct elections, the Society believes that these should precede the appointments and nominations, so that the latter could take account of the extent to which the elections have covered the requirements for 'local members' and some of the specified areas of expertise. However, it will be important that all appointments to the Park Authority are undertaken within a short space of time so that the Authority can form a cohesive group.

the name of the National Park covering the Loch Lomond & the Trossachs area.
The Society would support retaining the proposed name "Loch Lomond and the Trossachs", as giving the best overall indication of the area involved, even if the boundaries are rather wider. The general public is aware of the general area concerned and will not worry overmuch about where the boundaries are or what is or is not included.

Additional Information
In responding to this inquiry the Society would like to draw attention to the following Royal Society of Edinburgh responses which are of relevance to this subject: National Parks for Scotland (November 1998); People and Nature: A new Approach to SSSI Designations in Scotland (November 1998); National Scenic Areas Review (April 1999); EU policy on Biodiversity (May 1999); Study of Environmental Planning (October 1999) and National Parks (Scotland) Bill (March 2000). 

February 2001

Further information is available from the Research Officer, Dr Marc Rands