On behalf of the Landscape Institute Scotland, Rebecca Hughes, the Landscape Institute’s recently appointed Policy and Development Officer for Scotland has submitted the following response to the proposed map definition of wild land in Scotland.
The response was accompanied by a letter which you may also wish to read. This is available as pdf to download.
|Q.1. What is your view on the Core Areas of Wild Land 2013 map?|
|The Landscape Institute Scotland Branch (LIS) welcomes the opportunity to comment on the Core Areas of Wild land 2013 map and believes it seeks to define where particular wild land characteristics occur in the Scottish landscape.
Consultation with LIS members shows there is a positive consensus amongst members that there are areas of landscape in Scotland that should be very carefully considered for capacity to accommodate any further development. LIS welcomes the increased recognition of wild land in national planning policy terms in order to offer a measure of assistance for these landscapes to retain their distinctiveness.
However at the moment without a clearer definition of Core Wild Land in planning policy terms, it is difficult to see how the 2013 map is to be used and what status it will have, in order for it to be appropriately applied, or successfully defended. For LIS this is especially true in terms of the assessment of effects on landscape character and consideration of the landscape’s capacity to accommodate change where development proposals may occur within or nearby the Core Wild Land areas shown on the 2013 map.
In particular LIS would like to have a fuller understanding of the how the extended and new areas (ie parts of class 6 of Map A – Classes of Wildness Across Scotland) on the 2013 map have been arrived at without undertaking detailed landscape character assessment of the wild land qualities of each area. LIS suggest that the landscape character assessments that have been undertaken in each local authority area across Scotland, and other area wide landscape assessments of Special Qualities such as those in the National Parks and National Scenic Areas, which are in the main established SPG’s, could be the basis or starting point for such assessments of where wild land special qualities exist and their key attributes. This could contribute to the analysis of GIS datasets that have been the basis of the 2013 map.LIS would also like to have clarification on how to treat the status of the areas shown on the 2013 map which are already designated as National Park and/or NSA’s and if the Core Areas shown on the 2013 map are to be treated in effect as another designation even if not in name. To have such areas defined by geographical boundary lines will no doubt be tested in the planning process of planning application determinations and will require certain clarity in the rigour of how such areas have been arrived at for them to be upheld.
|Q.2. Do you have specific comments on any of the areas of wild land identified?|
|LIS would like to see more verification and a better explanation of the methods and data used for identifying the additional areas included in the 2013 map. This map increases the total area indicated in the Search Areas for Wild Land 2002 map which have core wild land qualities by over 55%. LIS believes this is an important point of verification particularly when the 2002 Search Areas were stated as encompassing all the main wild land areas.
Generally LIS is surprised to find that only limited coastal areas and seascapes that have been identified in the analysis for inclusion in the 2013 Wild Land Map and would like to understand more fully the nature of considerations for remote coastal areas especially where wild coastal conditions and qualities are known to exist but may not meet the extent criteria. A result of the 1000 hectare land extent being a pre-qualifying condition for inclusion in all settings north of the Central Belt perhaps also explains the limited areas included in the 2013 map in the Northern Isles of Orkney and Shetland. This of course raises the issue of the rationale and evidence for the extent criteria.
Whilst recognising and agreeing very much with SNH on the different landscape context south of the Central Belt we are not so convinced by the limited identification of wild land areas in that region which qualify, even when applying different categorisation of the 500 hectare extent test for presence of wild land qualities in the 7 & 8 classes of Map A.
As a result of the points outlined above LIS consider that the 2013 map tends to skew towards representing core wild land areas found in inland, elevated locations of the north and west of mainland Scotland and less on other settings such as coastal, island and seascapes where arguably Scotland has a reputation for various combinations of coasts and islands with wild land qualities and interfacing seascapes.Whilst the 2013 map may be a reasonable reflection of the distribution of core wild land qualities of the areas shown, it does however beg the question of having a clearer substantiation of how all areas on the 2013 map were verified without ground truthing or field assessment by landscape or other specialists, especially for the extensive areas that have been added since the 2002 map version. The experience of LIS members who work in all types of landscapes across Scotland find that the qualities of wild land can occur in other quite extensive locations. However these areas would not qualify on the land area extent criterion as set for the 2013 map, but would easily qualify in other ways; such as the intensity, or completeness of wild land qualities due to topographic enclosure for instance, or relationship to the coastal edge or seascape which can result in a strong wild land experience in these places. The obvious question then arises that should these areas not be recognised also for having the qualities Core Wild Land?
|Q.3. Are there any other issues regarding the Core Areas of Wild Land 2013 map, or its preparation, that you would like to raise?|
|LIS would like to have a clear definition of what is meant by wildness and Core Wild Land and how they interrelate particularly in their extent. We would suggest that following the current work on citations, which we understand is underway for the special qualities of individual Core Wild Land areas as shown on the 2013 map, that this will then be related to each of the four attributes and data sets used to define each wild land area.
LIS would like to understand the level of scrutiny that has been applied to the methodology in the new approach and the detailed justification to include wildness class 6 for identifying potential new areas of core wild land contiguous with areas of classes 7 and 8, which from examining Map A does not appear to be consistently applied but was informed by internal consultation.
Paragraph 4.6 of the consultation paper indicates that field survey has not been carried out to support the analysis as the map is to be used as a strategic tool. LIS would suggest it would be highly desirable for this to happen in order for the 2013 map to be more fully verified and to avoid the resource implications and unevenness of justification for the mapped areas that is likely to arise from a case by case approach.
Lastly LIS is of the view that it will be essential to prepare a detailed document to explain the map and how it should be used before it is incorporated into policy.