Response 638962346

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About You

What is your name?

Name
Annie McKee, Jessica Maxwell, Rowan Ellis and David Miller

Are you responding as an individual or an organisation?

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(Required)
Individual
Ticked Organisation

What is your organisation?

Organisation
James Hutton Institute

Key Considerations

1. Does the draft Guidance (Chapter 3 of this consultation) respond appropriately to the considerations of Section 44(2) of the Act?

Please select one item
Ticked Yes
No
Please explain your answer.
Yes, we believe that the draft Guidance does respond appropriately to the consideration of Section 44(2) of the Act. However, at present the draft Guidance is too brief for there to be detailed responses to each of the key points listed in Section 44(2).

2. Do you agree with our proposed scope for the Guidance?

Please select one item
Ticked Yes
No
Please explain your answer.
Yes, we agree with the proposed scope for the Guidance. However, we encourage the development of an expanded scope to the document, and associated training programmes, to initiate and support a culture change around how communities are engaged by land owners and managers in decision-making in relation to land in Scotland. Ideally, best practice community engagement should become a ‘natural’, rather than prescribed, element of land and property management, of all ownership types and scales of land-holding. Furthermore, embedding positive community engagement in land management can support the development of partnerships between landowners and communities, for mutually-beneficial outcomes (see Glass et al., 2012). This draft Guidance could provide an important contribution to community empowerment and landowner accountability that seeks to overcome unequal power relations to promote sustainable development (see McKee, 2015). We also believe that further clarity is merited on what is meant by ‘engagement’. For example, paragraph 19 of the consultation document states that “engagement might be formal or informal, and will include a variety of different forms of communication…[and] level[s] of engagement”. The Guidance should include further detail about what these different forms of communication and levels of engagement might be. There are a number of different typologies of engagement that could be described and/or used here, including: • Arnstein’s (1969) ladder of participation, which includes different levels of non-participation (manipulation, therapy), tokenism (informing, consultation, placation), and citizen power (partnership, delegated power, citizen control; • Davidson’s (1998) wheel of participation, which includes a spectrum from: inform (minimal communication, limited information, high-quality information), consult (limited consultation, customer care, genuine consultation), participation (effective advisory body, partnership, limited decentralised decision-making), and empower (delegated control, independent control, entrusted control). • Rowe and Frewer’s (2005) typology based upon the direction of the flow of information from: communication (one way flow of information from the sponsor to the representative), consultation (one way flow of information from the representative to the sponsor), and participation (two way flow of information between both the sponsor and the representative). McKee, A.J. 2015. Legitimising the Laird? Communicative Action and the role of private landowner and community engagement in rural sustainability. Journal of Rural Studies 41: 23-36. Arnstein, S.R., 1969. A Ladder of Citizen Participation. Journal of the American Institute of Planners, 35(4), pp.216–224. Davidson, S., 1998. Spinning the wheel of empowerment. Planning, 1262(3), pp.14–15. Rowe, G. and Frewer, L.J. 2005. A typology of public engagement mechanisms. Science, Technology & Human Values, 30(2), pp.251-290.

3. Do you agree with our approach to the relationship with existing statutory requirements?

Please select one item
Ticked Yes
No
Please explain your answer
We agree in part with the approach to the relationship with existing statutory requirements. However, we suggest that there is an important difference between community ‘consultation’ and ‘engagement’, which are used interchangeably in paragraph 23 of the consultation document. ‘Engagement’ represents different types of participatory processes and information flows, in particular reflecting the higher ‘rungs’ of Arnstein’s ‘ladder of participation’ (SCDC, 2011; Arnstein, 1969). The type of community engagement mechanism (i.e. the appropriate tools and approaches adopted) are critical issues that rely on the context, outcome and the power relationships between participants and those facilitating the process (Sarkissian et al., 2009; Richards et al., 2004). Arnstein’s ‘ladder of participation’ illustrates levels of participation (1969; see below). Others categorise participatory processes by their purpose: ‘consultative’, ‘functional’ or ‘empowering’ (Farrington 1998 in Reed, 2008; Stirling, 2006). As mentioned in the consultation document, the level of engagement that is most appropriate depends upon the purpose and context. In keeping with the culture of the Guidance document, community engagement should be designed to best fit the needs of the community and the specific topic under discussion. Additional community engagement mechanisms should be used where they are more appropriate to those prescribed according to statutory requirements. Arnstein, S.R., 1969. A Ladder of Citizen Participation. Journal of the American Institute of Planners, 35(4), pp.216–224. SCDC 2011. ‘Community Resilience and Co-production: Getting to grips with the language’, A briefing paper, Scottish Community Development Centre, March 2011. Sarkissian, W., Hofer, N., Shore, Y., Vajda, S. and Wilkinson, C. 2009. ‘Kitchen Table Sustainability: Practical Recipes for Community Engagement with Sustainability.’ London, Earthscan. Richards, C., Sherlock, K. and Carter, C. 2004. ‘Practical approaches to Participation’, Socio-Economic Research Programme (SERP) Policy Brief Number 1, Macaulay Institute. Reed, M.S. 2008. ‘Stakeholder participation for environmental management: A literature review’. Biological Conservation, 141: 2417-2431. Stirling, A. 2006. ‘Analysis, participation and power: justification and closure in participatory multi-criteria analysis’, Land Use Policy 23: 95-107.

4. Do you agree with our approach to using the National Standards for Community Engagement to inform this Guidance?

Please select one item
Ticked Yes
No
Please comment if you have ideas on how we could better integrate these Standards.
Yes, we agree with the approach to using the National Standards for Community Engagement to inform the draft Guidance. These Standards have recently been updated and provide a greater level of detail regarding best practice community engagement than the current draft Guidance. It is important that the National Standards underpin the Guidance, therefore we suggest that further be undertaken to align the key messages, and to utilise the same language within both documents. For example, the National Standards contains a list of five outcomes of good community engagement which should be restated in the Guidance. It would be beneficial to provide an overview of the National Standards for Community Engagement in the Guidance, rather than expecting users to locate and refer to the separate document. At minimum, the Guidance should include a list of the key steps for good practice in community engagement, as outlined in the 2016 National Standards, for example: • Inclusion: we will identify and involve the people and organisations that are affected by the focus on the engagement. • Support: we will identify and overcome any barriers to participation. • Planning: there is a clear purpose for the engagement, which is based on a shared understanding of community needs and ambitions. • Working Together: we will work effectively together to achieve the aims of the engagement. • Methods: we will use methods of engagement that are fit for purpose. • Communication: we will communicate clearly and regularly with the people, organisations and communities affected by the engagement. • Impact: we will assess the impact of the engagement and use what has been learned to improve our future community engagement. We also recommend that the Guidance refers to the ‘good practice principles for landowners and communities’, compiled by McKee and Roberts (2016), as follows: Good practice principles for private landowners - (i) Ensuring clarity and transparency regarding engagement processes (e.g. regarding intentions, through an agreed discussion format and recording discussions); (ii) Ensuring supportive behaviour and attitude (i.e. respect, honesty and responsiveness, plus commitment to community engagement); (iii) Fostering positive relationships through direct communication, and building a ‘track record’ of community engagement; (iv) Involving expertise and specialist knowledge, and ensuring that professional land management advisors adhere to good practice principles; (v) Reflectivity in land ownership and management (i.e. promoting a transparent approach to producing a estate development strategy, including community engagement, recognising the public interest in decision-making, identifying surplus land/assets and make available for community land-based activities, etc.). Good practice principles for communities - (i) Ensuring positive and early engagement with the relevant landowner(s) (e.g. presenting proposals, and seeking up-to-date information and views); (ii) Undertaking strategic and critical thinking (i.e. regarding community dynamics, capacity, governance, and needs, in addition to the role of asset ownership and alternatives); (iii) Establishing a ‘sustainable development’ plan, demonstrating community visioning, land use assessments and resource planning; (iv) Achieving a unified community voice, through active participation in local democracy and dialogue; (v) Building community capacity, positive engagement behaviours and knowledge (e.g. of valuation processes, negotiation practices, business planning, etc.); (vi) To work with objective and highly skilled community advisors (including development officers and land agents), in order to support the progress of land-based activities (e.g. in seeking funding, devising business plans, commissioning feasibility studies, transacting land sales, etc.) (McKee and Roberts, 2016: 5). McKee, A. and Roberts, D. 2016. ‘Good practice in overcoming barriers to community land-based activities’. Report for the Scottish Government, June 2016. Published online: http://www.gov.scot/Publications/2016/07/7298

Draft Guidance

5. Have we identified appropriate uses for the Guidance in section 1 of the draft Guidance?

Please select one item
Ticked Yes
No
Please explain your answer
Section 1 of the draft Guidance includes appropriate uses, such as where decisions relating to land could impact on a local community and economic, environmental, social or cultural opportunities. However, it would be helpful for informing prospective users of the Guidance if examples of the types of ‘opportunities’ could be included. In support of this, a link should be made between the term ‘opportunity’ and the definition of ‘sustainable development’, as used within Part 5 of the Land Reform (Scotland) Act 2016. It is important that it is the communities which identify and communicate opportunities. This requires a better understanding of what constitutes an ‘opportunity for a local community’. The implication of the statement is that the Guidance would not be used if the land owner or manager does not consider the decision to have an impact on any opportunities for a local community. The wording of the second sentence of Section 1 could be misinterpreted, i.e. suggesting that the ‘neighbouring community’ could include private, public or third sector organisations and individuals. Whilst this could be true, we believe that the intention is to indicate to whom the Guidance is aimed, i.e. all land owner and manager types, of all scales of landholding, in Scotland.

6. Have we identified appropriate reasons for why community engagement should take place in section 2 of the draft Guidance?

Please select one item
Ticked Yes
No
Please explain your answer
We agree with the opening statement of section 2, that ‘land is a resource for the people of Scotland’, and would suggest that ‘all of’ is added before ‘the people’. This underpins the rationale for community engagement in decisions relating to land, and in consistent with the Land Use Strategy. It reflects the sense that all or any decisions relating to land can influence individual residents and local communities (i.e. beyond the immediate land owning family and/or organisation), in addition to the wider public good. The decisions made by those who own and manage land should be transparent, accountable, and legitimate in the local community and public interest (see McKee, 2015). Furthermore, as discussed in our responses to questions 2 and 4, there are a number of different aims and rationales for engagement that are not listed in Section 2 of the draft Guidance. This section should draw upon existing good practice in community/stakeholder engagement (see Reed, 2008) and should link more directly to the guidance given in the National Standards for Community Engagement. We appreciate that the Guidance needs to be accessible and relevant to land owners and land managers; however, it is important to outline all of the different reasons for engaging communities and the potential outcomes (both positive and negative), for all parties. Further consideration of the outcomes for the ‘engaged communities’ should be incorporated with those noted at present for land owners and managers. McKee, A.J. 2015. Legitimising the Laird? Communicative Action and the role of private landowner and community engagement in rural sustainability. Journal of Rural Studies 41: 23-36. Reed, M.S. 2008. ‘Stakeholder participation for environmental management: A literature review’. Biological Conservation, 141: 2417-2431.

7. Have we identified appropriate best practice principles in section 3 of the draft Guidance?

Please select one item
Ticked Yes
No
Please explain your answer.
We support the development of best practice principles for fair engagement, such as those presented in section 3 of the consultation document. However, we have reservations regarding the use of the term ‘proportionate’. The Guidance implies that the judgement of whether engagement is necessary is in the hands of the land owner and manager, who may not have a full understanding of the impact of land management decision-making on local communities. The impact may be cumulative and not immediately visible, therefore initially engagement may be considered unnecessary. ‘Fair engagement’ may require a level of effort that some would find a ‘burden’, but in the longer term it is more likely to be beneficial in sustaining trusting relationships between land owner/manager and community. We suggest that further resources be identified to support best practice in community engagement in conjunction with the Guidance. For example, this could include the provision of training courses for land owners/managers, and skilled external facilitation to support community engagement processes, where the level of impact is unknown and/or the input required is considered burdensome to any parties. We agree that community engagement should be collaborative. However, we are cautious regarding the statement that ‘community views are given due consideration’ as this affords the land owner/manager the opportunity to determine how much weight to give community views in decision-making. To underpin equality in engagement processes, the decision-making process should be as transparent as possible, adhering to the principles of Habermas’ ‘Communicative Action’, as described by McKee (2015). Ongoing engagement and communication is critical. The optimum outcome from the development of this Guidance should be a culture change in how communities are involved in decisions relating to land. McKee, A.J. 2015. Legitimising the Laird? Communicative Action and the role of private landowner and community engagement in rural sustainability. Journal of Rural Studies 41: 23-36.

8. Have we identified appropriate situations for when engagement should or should not take place in section 4 of the draft Guidance?

Please select one item
Ticked Yes
No
Please explain your answer
This section would benefit from a clear definition and further description of what constitutes a ‘significant impact’. As mentioned, the level of impact of decisions relating to land should be determined and reviewed by the local community, in discussion with the land owner/manager. Decisions relating to land may have cumulative impacts, and have unintentional/unknown longer-term impacts. We suggest that ongoing communication between land owner/manager and community should underpin all decisions relating to land, with specific mechanisms of ‘formal’ community engagement deployed at critical moments, e.g. changes to land use, infrastructure developments, etc.

9. Have we identified appropriate methods for engaging with communities in section 5 of the draft Guidance?

Please explain your answer
We believe that the appropriate methods for engaging with communities have been only partially identified. A deeper level of meaningful participation seems to be missing in the table in section 5. Much of what is described is communication and consultation, rather than engagement. Using Rowe and Frewer’s (2005) typology, a few examples follow of other methods for each level of engagement that could perhaps be incorporated: • Communication: website, social media, newsletters, videos, lectures, databases, publications; • Consultation: meetings, forums, interviews, questionnaires; Participation: workshops, focus groups, steering committees, advisory panels. Other relevant examples are detailed in ‘Working Together for Sustainable Estate Communities’ published by the Centre for Mountain Studies (Glass et al., 2012). We believe that the Guidance could benefit from more discussion of the need to think about community engagement at a much earlier stage when making decisions about land (i.e. the role of ‘pre-emptive engagement’ as described by McKee and Roberts, 2016). In instances where formal engagement is deemed necessary, any ambition toward co-design or a form of engagement where the land owner/manager responds to the feedback from communities requires that engagement be undertaken at a stage before most people realise they need to do so. Such a need for earlier engagement is consistent with the recommendations of the independent review of the Scottish Planning System (Beveridge et al., 2016), notable No. 43 “There should be a continuing commitment to early engagement in planning, but practice needs to improve significantly.” To inform discussion of Recommendation 10 (Digital Innovation), Miller et al. (2016), in a report for Scottish Government, describe the background and options for the use of digital data and tools to aid the empowerment of communities, and improved effectiveness of pre-planning application discussions. So, a link could be included between the Guidance and examples of good practice informing the evolution of the planning system. A criticism of community engagement is that such activities happen at too late a stage, when there is no longer scope for any significant redesign or alternation of plans (see Roberts and McKee, 2015). In our experience, a related complaint is that those who initiate a community engagement exercise rarely allow enough time for the process and that stakeholders/communities feel they do not get adequate time to reflect and consider what is being asked of them. Therefore, the Guidance would benefit from further recognition of the significant commitment of time and forward planning that collaborative and co-designed community engagement involves. Rowe, G. and Frewer, L.J. 2005. A typology of public engagement mechanisms. Science, Technology & Human Values, 30(2), pp.251-290. Glass, J.H., McKee, A. and Mc Morran, R. 2012. ‘Working Together for Sustainable Estate Communities’: exploring the potential of collaborative initiatives between privately-owned estates, communities and other partners’. Centre for Mountain Studies, Perth College, University of the Highlands and Islands. Available online: https://issuu.com/cms_uhi/docs/working_together_for_sustainable_estate_communitie McKee, A. and Roberts, D. 2016. ‘Good practice in overcoming barriers to community land-based activities’. Report for the Scottish Government, June 2016. Published online: http://www.gov.scot/Publications/2016/07/7298 Beveridge, C., Biberbach, P. and Hamilton, J. 2016, Empowering Planning to Deliver Great Places: An Independent Review of the Scottish planning System, May 2016. pp. 60. Miller, D., Morrice, J., McKeen, M., Donaldson-Selby, G., Wang, C. and Munoz-Rojas, J. 2016. Use of digital and 3D technology in planning: research report. FInal Report for Scottish Government. pp109. https://beta.gov.scot/publications/use-of-digital-3d-visualisation-technology-research-report/ Roberts, D. and McKee, A. 2015. ‘Understanding the barriers to community land-based activities’. Report for the Scottish Government, September 2015. Published online: http://www.gov.scot/Publications/2015/09/5827

10. Have we identified appropriate ways of identifying who to engage with in section 6 of the draft Guidance?

Please select one item
Ticked Yes
No
Please explain your answer
We believe that the appropriate ways of identifying with whom to engage in Section 6 of the draft Guidance have been partially explained. Section 6 states that “it is not always necessary to engagement everybody within a community”. Representativeness is a big challenge in community engagement. It is nearly impossible to engage everybody within a community. Despite efforts to be representative, it is not always possible to identify and include all stakeholders (i.e. community members who may be impacted upon by a decision relating to land), so decisions must be made about ‘who’s in and why’ based upon transparent and robust criteria relating to the issue at hand (Reed et al. 2009). This section should expand upon approaches to meeting this challenge, such as consideration of ‘hard to reach’ or ‘seldom heard’ individuals. It is important not to purposefully or accidently omit certain stakeholders or groups as this could result in the marginalisation of such groups, a bias of results, and create the potential for a lack of support for the process, outputs, and outcomes of the engagement (Reed et al. 2009). Often those who would be less obviously impacted upon by decisions, but are marginalised in other ways, are routinely not engaged or consulted. An example of this is the ways in which decisions that impact on transport networks disproportionately impact those who rely on public transportation, but may not fit a geographically specific ‘impacted community’. On the other hand, there is also no mention of the importance of engaging those who may have significant power or influence over whether a project or plan is successful or meets its promised aims. Identifying who to engage with can be done in different ways. Ideally the identification of stakeholders involves an iterative process that uses a combination of methods such as: expert opinion, self-selection, focus groups, semi-structured interviews, brainstorming, mind-mapping, and snowball sampling (Reed et al. 2009). The identification of stakeholders can be done in a participatory way, for example, asking community members to help to identify the different people, groups, and organisations that should be involved. Participation in the identification process can help to refine the scope of the issue and those who may have a stake or interest in it (Reed and Curzon, 2015). The identification and engagement of stakeholders should be purposeful and mutual benefits and expectations should be considered and made clear throughout the process (Jolibert and Wesselink, 2012). Overall, we believe that land owners/managers could benefit from more support and practical guidance in stakeholder (i.e. impacted community) identification techniques, particularly if the Guidance is to ‘tackle inequalities’ as it proposes. Reed, M.S., Graves, A., Dandy, N., Posthumus, H., Hubacek, K., Morris, J., Prell, C., Quinn, C.H. and Stringer, L.C. 2009. Who's in and why? A typology of stakeholder analysis methods for natural resource management. Journal of Environmental Management, 90(5), pp.1933-1949. Reed, M.S. and Curzon, R. 2015. Stakeholder mapping for the governance of biosecurity: a literature review. Journal of Integrative Environmental Sciences, 12(February 2015), pp.15–38. Jolibert, C. & Wesselink, A., 2012. Research impacts and impact on research in biodiversity conservation: The influence of stakeholder engagement. Environmental Science and Policy, 22, pp.100–111.

11. Considering the draft Guidance as a whole, do you agree that it has proportionate and reasonable expectations of land owners, land managers and communities?

Please select one item
Ticked Yes
No
How could we improve the Guidance in this respect?
The draft Guidance can be considered proportionate, meeting reasonable expectations of land owners/managers and communities. However, we believe that the Guidance should emphasise the responsibility of all parties in undertaking best practice community engagement, according to the principles outlined in the Guidance and supporting documents, in conjunction with the requirements of the Land Reform (Scotland) Act 2016 – especially the link to Part 5 (the ‘right to buy land to further sustainable development’). In particular, paragraph 12 of the draft Guidance states that “land owners and land managers can demonstrate that they are fulfilling the expectations of the Guidance, or so that communities can demonstrate that this is not the case”. It is unclear what the expectations of the Guidance are, and how land owners and land managers can demonstrate that they are fulfilling them. This is partly due to the fact that it is hard to be prescriptive about community engagement as it is context specific. However, further information should be included regarding what the expectations and how to demonstrate that they are met. At present, we believe that the draft Guidance is unlikely to transform practices by land owners, managers and communities because it does not provide sufficient detail to illustrate the scope and potential benefits of community engagement that underpin decisions relating to land. The Guidance could provide inspiring and practical case studies, indicate sources and means of training/capacity building to help land owners/managers to learn how to do community engagement, and to identify any available financial resources to support engagement processes. It is desirable to avoid providing high-level principles that may give the impression of there being no requirement of behaviour change by land owners/managers and communities. The publishing of Guidance provides an opportunity to instigate a culture change necessary to support community empowerment, landowner accountability and shared decision-making in relation to land.

12. Do you agree that, as a whole, the draft Guidance balances the concerns detailed below?

Please select one item
Ticked Yes
No
How could we improve the Guidance in this respect?
As per our response to Question 11, we do not believe that the draft Guidance provides sufficient detail regarding the expectations of land owners/managers, and lacks practical indicators and supporting tools/advice to illustrate how to undertake good practice community engagement. We agree that there is a balance to be struck between prescriptive community engagement exercises, and locally-specific approaches. However, the development of further detailed Guidance should include greater clarity for all parties to ensure that land owners/managers and communities can be held accountable for their behaviour and actions taken undertaking community engagement in decisions relating to land. This would be supported through the provision of other resources to accompany the publication of the Guidance, including training sessions, roundtable discussions, and facilitation support for community engagement processes.

13. In the final published Guidance we would like to include examples of when engagement should be carried out. Can you provide examples of situations in which you think that engagement either is, or is not, necessary?

Comments:
As described in our response to Question 8, we believe that ongoing communication between land owners/managers and communities should underpin all decisions relating to land. Specific mechanisms of ‘formal’ community engagement should be deployed at critical moments of strategic land management planning decision-making, e.g. changes to land use, infrastructure developments, etc. We believe that there are no situations where community engagement is unnecessary, where ‘engagement’ includes the development and maintenance of trusting relationships between land owners/managers and communities through interaction and communication. We refer to the ‘spectrum of approaches’ presented by Glass et al. (2012) to illustrate that community engagement is a continuous process. Maintaining good communication links between land owner/manager and community is fundamental to later decision-making relating to land. Arguably, referring to the table in section 5 of the draft Guidance, the entry of ‘How to engage’ in the ‘Good Neighbour’ row should remove reference to ‘no need to engage’ and be replaced with ‘maintain good communication’. Glass, J.H., McKee, A. and Mc Morran, R. 2012. ‘Working Together for Sustainable Estate Communities’: exploring the potential of collaborative initiatives between privately-owned estates, communities and other partners’. Centre for Mountain Studies, Perth College, University of the Highlands and Islands. Available online: https://issuu.com/cms_uhi/docs/working_together_for_sustainable_estate_communitie

14. Do you have any other comments?

Comments:
We have no further comments at this stage, and look forward to reading the final draft Guidance in due course.

Impact Assessment

15. Please tell us about any potential impacts, either positive or negative, that you consider the proposals in this consultation may have on people who may be differently affected in relation to the protected characteristics.

Comments:
We do not anticipate any potential impacts, either positive or negative, that the proposals in this consultation may have on people with protected characteristics. However, we appreciate that communities differ in their capacity to undertake engagement processes. Disadvantaged communities may not be able to afford the time to take part in engagement exercises, and could struggle with costs associated with co-organising such exercises, supporting facilitation, or eventual co-management of land resources. Whilst we welcome efforts to give communities a voice in decisions relating to land, we would like to see further revision of the draft Guidance to embed and expand on principles of good practice in community engagement, seeking to ensure inclusivity and equality. Overall, if the principles in the Guidance are enacted there will be a positive impact in terms of community empowerment, with associated benefits for the democratic process and overcoming inequalities in Scotland.

16. Please tell us about any potential impacts, either positive or negative, costs and burdens that you think may arise as a result of the proposals within this consultation.

Comments:
Costs will arise from increasing community engagement processes, which will be required to be met by landowners, and possibly communities themselves (e.g. where a community group invite the landowner to initiate a dialogue with regard to land management decision-making). As mentioned above, the provision of financial and/or facilitation support would ease this likely cost burden and encourage uptake of the Guidance by land owners/managers and communities.

17. Please tell us about any potential environmental impacts, either positive or negative, that you consider any of the proposals in this consultation may have.

Comments:
As stated in the James Hutton Institute’s response to the draft Land Rights and Responsibilities Statement (2017), it is anticipated that some environmental impacts could arise with greater community involvement in decision-making around land. In particular, it is likely that local community wishes for housing and economic development may lead to proposals for both green and brown field sites with potential environmental impacts such as on biodiversity and access to green space. Alternatively, community involvement may lead to the adoption of different land management approaches to those undertaken historically, e.g. including decreasing emphasis on game management, which could lead to environmental changes. Or, community involvement could be more sensitive to potential adverse environmental impacts (e.g. on landscape, as exemplified in the approach to the development of a windfarm by the community in Udny, Aberdeenshire; http://udnycommunitytrust.org.uk/). Finally, it would be hoped that through greater access to, and involvement in, the management of land and natural resources, pro-environmental behaviours by communities could be promoted, leading to positive impacts on the local and global environment.

18. Please tell us about any potential impacts on privacy, either positive or negative, that you consider may arise as a result of the Guidance.

Please be as specific as possible.
We do not anticipate any potential impacts on privacy arising as a result of the draft Guidance.