The Scottish Gamekeepers Association (SGA) believe the proposed aims of new parks, for nature recovery and Net Zero, are likely to impact most on people currently working the land for a living.
However, despite this, they say that agriculture and private interests are currently under-represented in the process, with government bodies and environment NGOs dominating.
Furthermore, they claim the consultative experience has alienated land managers because communications are laden with policy jargon the ordinary person can’t understand.
The creation of at least one new national park by 2026 is a commitment of the Scottish Government; a legacy of the Bute House agreement between SNP and the Greens.
Amongst contenders wishing to see a park in their region are Galloway and the Borders, with the present 2 parks being sited around Loch Lomond and the Trossachs and the Cairngorms.
Writing in response to a consultation, which closes on Wednesday, the SGA questioned the process so far, with much at stake for the likes of gamekeepers, farmers, deer managers and crofters.
“The question must be raised, if the Scottish Government and NatureScot genuinely wish to encourage an inclusive and wide-reaching response, why is the consultation process so inhibiting? The lack of representation by those that earn their living from the land and ordinary citizens is apparent,” the organisation stated.
“The narrative that pervades the consultation document and associated conversations applies a technical discourse that is specialised, selective and marginalising.
“Loaded with policy speak and legal jargon, it poses considerable challenges to the layperson.”
The SGA provided a breakdown of bodies and organisations which have featured, so far, in the principal discussions on the future of new and existing parks.
They say agriculture and private interests comprise only 7% whilst environment NGOs account for 25% and government agencies, 60%.
“By proposing to accelerate the transition in land use to address climate and nature emergencies, effectively, it is local people and families who are impacted most.
“Therefore, regarding the statutory aims of national parks, there needs to be greater emphasis on respecting traditional land management practice and retaining existing employment.
“In designating new national parks in Scotland, nature recovery is placed high on the agenda, however, Scotland’s people are important, too. The rural environment is a working environment and the rural population is indispensable.”
Earlier this year, the SGA joined Scotland’s regional moorland groups in protesting against the Partnership Plan drawn up by Cairngorms National Park Authority (CNPA) Board.
Since then they have met twice with authority figures, to discuss land management issues.
However, in their consultation response they remain critical of the CNPA’s stance on saving the Capercaillie, something they feel is relevant to future parks potentially seeking more power.
“What measures have been taken, since NatureScot’s report on measures required to save Capercaillie, to safeguard the future of the capercaillie? Has predation been addressed, have paths been re-routed or access restricted?
“The CNPA already has existing powers to address these issues but seem reluctant to do so. How would additional powers help?”
Scottish Gamekeepers Association
Response to the Consultation ‘The Future for National Parks in Scotland – Have your say’
The Scottish Gamekeepers Association is a national organisation with membership distribution throughout Scotland. It is likely that the establishment of any new national park will therefore impact on our members regardless of the selected location.
Having examined the consultation document, together with the notes from stakeholder meetings, engaged with Regional Land Use Partnership pilot meetings and online National Parks workshops, rather than address individually the 38 questions within the consultation, our response is best provided in the following statement.
Underpinning the rationale for this type of response is the frustration in the way the process and consultation document and questions have been crafted. Therefore, our response, detailed below is headed accordingly:
1.Critique of the Process
Following the announcement of this consultation, the first step was to invite and discuss views in a National Discussion regarding the establishment of new national parks in Scotland. The next step was to engage with stakeholders to discuss the findings. These stakeholders were selected by NatureScot and aimed ‘to bring together a wide range of organisations and sectors with an interest in this area’. Whilst claiming the stakeholder group was not meant to be ‘fully representative’, nonetheless, it is evident this group is top heavy with government and public agencies and environmental organisations that are government funded.
An analysis of the stakeholders involved in these meetings and invited to attend subsequent meetings reveals that 60% were government/public funded agencies, 25% were environment charities, yet their representation was duplicated as they were already represented through Scotlink (also in receipt of government funding) and/or Scotland’s Landscape Alliance. Only 7% represented agriculture/private interest, 4% represented European interest, 4% represented renewable energy.
The lack of representation by those that earn their living from the land and ordinary citizens is apparent.
Consequently, the narrative that pervades the consultation document and associated conversations applies a technical discourse that is specialised, selective and marginalising. Loaded with policy speak and legal jargon, it poses considerable challenges to the layperson. Jargon was a key concern that emerged in discussions from the SOSE RLUP pilot and National Park Workshops attended recently.
Furthermore, within the stakeholder meeting notes, concern is expressed regarding the design and content as being too technical. A Likert scale type survey with boxes to invite comment would perhaps have been more appropriate.
The question must be raised, if the Scottish Government and NatureScot genuinely wish to encourage an inclusive and wide-reaching response, why is the consultation process so inhibiting? Or, is it all about targeting the ‘right audience’ as hinted in Stakeholder Advisory group meeting notes of 1st September? https://www.nature.scot/doc/stakeholder-advisory-group-papers-and-confirmed-notes
2.Response to Section 1: The Role of Scotland’s National Parks
The question is asked, do you support “leadership of nature recovery and a just transition to net zero” becoming the overarching purpose of Scotland’s National Parks?
Whilst this purpose may be considered commendable, there are serious issues that need to be addressed.
There is no mention of the local population and the contribution they have made in nurturing an environment that is worthy of designation. There is nothing ‘just’ when local livelihoods are threatened. This issue is further compounded when these local livelihoods provide an extensive skill-set and local knowledge that contributes to safeguarding biodiversity loss and climate change mitigation. By proposing to accelerate the transition in land use to address climate and nature emergencies, effectively, it is local people and families who are impacted most. Local estate workers who live in tied houses may well lose their family home if further restrictions are placed on deer stalking and grouse moor management for example. This trend is already happening.
Therefore, regarding the statutory aims of national parks, there needs to be greater emphasis on respecting traditional land management practice and retaining existing employment.
With reference to powers and functions of National Park Authorities there are major concerns surrounding red-listed species. If National Parks are to be considered the exemplar of nature recovery in Scotland, they must heed the evidence and act accordingly.
For example, within the CNPA, the Capercaillie is facing extinction. Within NatureScot’s own commissioned report, ‘Review of Capercaillie Conservation and Management - Report to the Scientific Advisory Committee’, predation by foxes, crows and pine martens and human disturbance are contributing to the demise of this iconic species.
In their recently published study, Summers et al (2022), also concluded disturbance was having a negative impact.
What measures have been taken since to safeguard the future of the capercaillie? Has predation by pine martens been addressed, have paths been re-routed or access restricted?
The CNPA already have existing powers to address this issue but seem reluctant to do so. How would additional powers help?
In the notes of the 3rd meeting of the National Park Stakeholder Advisory Group, it states on page 2:
Where red-listed species are compromised by disturbance and access, if national parks are to uphold their aims and mission, i.e., to lead nature recovery, it is imperative that access rights are restricted in favour of nature. Rather than considering additional powers, the powers that are already available should be deployed when appropriate.
3.Response to Section 2: Criteria for selecting National Parks
This section is particularly challenging to respond to.
Whilst it is intended the nomination process will be bottom up and transparent, again the technical jargon is alienating; it reveals a distance from the reality of those that live outwith the policy environment. Subsequently, it is likely that ‘bottom-up’ responses from the general public will be limited.
In designating new national parks in Scotland, nature recovery is placed high on the agenda, however, Scotland’s people are important too. The rural environment is a working environment and the rural population is indispensable.
Within any new National Park, if a Just Transition is to be upheld, it is imperative to recognise and retain the land management skills and expertise within the local population. These skills, often provided by members of the Scottish Gamekeepers Association, contribute to safeguarding biodiversity loss and afford protection to red-listed species. Climate change mitigation is delivered through peatland restoration and wildfire prevention, and deer and river management are practised ethically and sustainably. This extensive local knowledge is part of our cultural heritage and should be considered a key component of any new National Park.