Guidance on responding to SNH Wild Land Areas consultationPublished: 8th March 2017
Assessing impacts on Wild Land Areas: SNH consultation on draft technical guidance
The Trust considers that the acid test of the guidance is – will Wild Land Areas (WLAs) be safe from the impact of large-scale development if this guidance is adopted? In other words, is the guidance “fit for purpose”?
SNH asks two broad questions in the consultation document:-
- whether the guidance provides a clear methodology and general principles for assessing the impact of proposals on Wild Land Areas?
- if the examples are helpful in illustrating the approach to assessing these impacts?
We are concerned that the way in which the consultation questions have been framed is quite narrow and “closed. It is not clear whether comments on aspects of the draft guidance other than clarity will be taken into account but we think it essential that members and supporters take the opportunity to comment on the substance of the document, not just its readability.
We have identified three specific principles that we consider vital if the technical guidance is to do its job of protecting the Wild Land Areas and fulfilling the Scottish Government’s stated aim of protecting Scotland’s wild land. We will be making these in our response to SNH and hope you will find these helpful in writing your own response:-
- The guidance is only “fit for purpose” if it results in assessment and decisions that protect Wild Land Areas from gradual attrition. For detailed comment on the proposed methodology see the response from the Wildland Research Institute, experts in wild land mapping. The Trust supports this analysis. For our more detailed analysis click here
- Baselines - the proposed guidance says that “Step 2 of the proposed guidance/methodology requires the assessor to “establish the baseline ...” We firmly believe this cannot be a moveable baseline and that the correct baseline for a study area with a WLA must be the SNH descriptor of that WLA as originally published (January 2017). We believe that giving the assessor the remit to establish the baseline could be very problematic. For our more detailed analysis click here
- SNH should have the lead role in assessing whether a wild land assessment is required in situations where there is a possibility that the proposed development will impact on a Wild Land Area. For our more detailed analysis click here
We appreciate that the draft guidance is a technical document but we hope you will support us in making the important points outlined above to SNH by including these comments in your own response.
- SNH has asked people to respond by completing their online form - the Trust has not provided a template form for responses for this reason. You can find the SNH website online form here
- you will need to cut and paste your comments into one or both of the boxes in the SNH form. Don't worry if you are not specifically answering the question above that box. The boxes will expand to take as much text as you wish to include
- if you have problems using the online form, responses can be sent by email to: email@example.com or post to: Wild Land Assessment Guidance Consultation, Scottish Natural Heritage, Great Glen House, Leachkin Road, Inverness, IV3 8NW. You will need to include a printed off copy of the respondent information form available here respondent information form
- please use your own words as much as possible for maximum impact
- the consultation closes on Friday 7 April