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Landscape Institute Scotland (LI)
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Craig An Turic House
Balquhidder
Lochearnhead
Perthshire
Scotland
Balquhidder
Lochearnhead
Perthshire
Scotland
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FK19 8NY
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Vision, Objectives and Principles
1a. Do you think that the Vision, Principles for Sustainable Land Use and three long term Objectives are still fit for purpose?
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1b. Please provide your reasons for your answer.
1b
The objectives and principles remain fit for purpose.
The vision should however emphasise 'the value and importance our land resources' for all, not just the chosen few, a vision that should be echoed within the land reform proposals.
The Landscape Institute Scotland would appreciate a greater emphasis and importance being placed on...
'e) Landscape change should be managed positively and sympathetically,
considering the implications of change at a scale appropriate to the landscape in
question, given that all Scotland's landscapes are important to our sense of identity and to our individual and social well being.'
...as this principle underpins many, if not all, of the other principles outlined within the Land Use Strategy.
The vision should however emphasise 'the value and importance our land resources' for all, not just the chosen few, a vision that should be echoed within the land reform proposals.
The Landscape Institute Scotland would appreciate a greater emphasis and importance being placed on...
'e) Landscape change should be managed positively and sympathetically,
considering the implications of change at a scale appropriate to the landscape in
question, given that all Scotland's landscapes are important to our sense of identity and to our individual and social well being.'
...as this principle underpins many, if not all, of the other principles outlined within the Land Use Strategy.
Natural Resource Management
2a. Do you agree that continued use of an ecosystems approach is an effective way to manage Scotland's natural capital?
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2b. Please provide reasons for your answer.
2b
An ecosystems approach should allow for a harmonious balance of benefits to the existing ecosystems and biodiversity of Scotland's landscapes, while delivering economic prosperity and security for future generations.
This long-term management approach to Scotland's landscapes could see greater diversity in our flora and fauna and a landscape scale rewilding of some of our most iconic, valuable and treasured landscapes, resulting in potentially substantial economic benefits.
This long-term management approach to Scotland's landscapes could see greater diversity in our flora and fauna and a landscape scale rewilding of some of our most iconic, valuable and treasured landscapes, resulting in potentially substantial economic benefits.
Policy Alignment
3a. Is the relationship as set out in the draft Land Use Strategy 2016 - 2021 clear?
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3b. Do you have any comments on the relationship between the LUS and Scotland’s Economic Strategy 2015, National Planning Framework, National Marine Plan and other relevant policies?
3b
A national level strategic approach to the delivery of policy commitments set out in the National Planning Framework to ensure compatibility with the vision, objectives and principles of the Land Use Strategy.
The Scottish Government commitment to ambitious renewable energy generation targets (equivalent of 100% of electricity generation capacity needs by 2020) is an example of one such potential conflict with its land use strategy. Given the continuing pressure for a proportion of this capacity to come from further onshore wind development, it is suggested that policy pressures for developments which require substantial areas of land for their deployment, and therefore may conflict with the vision,objectives and principles of the land use strategy, should be subject to a more strategic planned approach, to ensure a harmonious balance in maintained between site specific land use pressures and national policy objectives.
The Scottish Government commitment to ambitious renewable energy generation targets (equivalent of 100% of electricity generation capacity needs by 2020) is an example of one such potential conflict with its land use strategy. Given the continuing pressure for a proportion of this capacity to come from further onshore wind development, it is suggested that policy pressures for developments which require substantial areas of land for their deployment, and therefore may conflict with the vision,objectives and principles of the land use strategy, should be subject to a more strategic planned approach, to ensure a harmonious balance in maintained between site specific land use pressures and national policy objectives.
Planning
4a. Do you think that the activities described above could be useful?
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4b. Do you have any suggestions on other kinds of information and activities that could be useful?
4b
Relevance, compatibility and consistency of the land use strategy with planning policy, and decision making is crucial. Development planning could benefit substantially from a more landscape scale and holistic strategy driven by land use, and utlilisation of natural resources for the greater good of all.
More detailed consideration of historical and cultural influences on landscapes, land use, and consequentially landscape change and could deliver added benefits in parallel with an ecosystems approach, especially in addressing substantial and important challenges like climate change adaptation and flood alleviation.
More detailed consideration of historical and cultural influences on landscapes, land use, and consequentially landscape change and could deliver added benefits in parallel with an ecosystems approach, especially in addressing substantial and important challenges like climate change adaptation and flood alleviation.
Forestry
5. How could the content of the current Scottish Forestry Strategy be updated to better reflect the Objectives and Principles of the Land Use Strategy and other key priorities?
5
The 2006 Scottish Forestry Strategy was broadly fit for purpose at the time of publication, however we now face different challenges, or more importantly in some instances, similar challenges but on a bigger scale or with greater frequency (i.e. extreme weather events with often catastrophic local and regional consequences).
The role of woodland, forestry and trees in sustainable flood management measures is mentioned within the existing forestry strategy, however the Landscape Institute Scotland feel this should be given far greater importance and priority within any new Forestry Strategy for Scotland. The recent flooding events across Scotland in late 2015/early 2016, were in part due to the poor management of land (the same poor management practices were also true of areas in northern England), and one contributing factor to this was the insistence of land owners to maintain many of our upland areas as tree less environments.
The role of woodland, forestry and trees in sustainable flood management measures is mentioned within the existing forestry strategy, however the Landscape Institute Scotland feel this should be given far greater importance and priority within any new Forestry Strategy for Scotland. The recent flooding events across Scotland in late 2015/early 2016, were in part due to the poor management of land (the same poor management practices were also true of areas in northern England), and one contributing factor to this was the insistence of land owners to maintain many of our upland areas as tree less environments.
Land Reform
6a. Do you consider that there could be advantages in having a single policy statement about land which deals with ownership, use and management?
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6b. Do you have any comments on the relationship between current land related policies and how these would relate to a single policy statement?
6b
An overarching policy statement that deals with ownership, use and management of land, could add weight and help deliver the vision, objectives and principles of the land use strategy if the two are aligned sufficiently to be compatible and ensure fairness for land owners, land users and the wider public who stand to benefit from better management of Scotland's land and natural resources.
Ecosystem Services Mapping and Tools
7a. Do you agree that models and GIS tools could help inform decision making about land use/management change?
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7b. Please provide your reasons for your answer.
7b
Ecosystem services often involve complex relationships between landscapes, the natural environment, biodiversity and people, and therefore access to accurate and up to date data about how these interactions may affect policy, development planning, land use and land management is very important.
A Geographic Information System (GIS), if developed and maintained appropriately, could become an integral part of recording, monitoring and assessing land use and management change, at a time when these changes are occurring at an ever increasing pace and rate.
A Geographic Information System (GIS), if developed and maintained appropriately, could become an integral part of recording, monitoring and assessing land use and management change, at a time when these changes are occurring at an ever increasing pace and rate.
7c. Do you think a baseline ecosystems services mapping tool could be useful?
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7d. Do you have any comments on a mapping tool?
7d
This should be sufficiently flexible to respond to new, returning and changing ecosystems services which may apply to Scotland's broad range of landscapes.
The mapping tool should be accurate and up to date, accessible, functional and easy to use in order to be useful.
The mapping tool should be accurate and up to date, accessible, functional and easy to use in order to be useful.
Regional Land Use Partnerships
8a. Do you agree that regional land use partnerships could be a helpful way to support regional delivery of the Land Use Strategy?
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8b. Who do you think could be best placed to lead these initiatives?
8b
Land use partnerships should be led by regional or local scale stakeholder partnership groups consisting of organisations and communities who have a local; interest, understanding, commitment, responsibility and reliance on the land within which the land use strategy is to be developed. They should however also be informed by national bodies such as SNH, SEPA etc. in order to advise on the development of a land use strategy which is consistent with the overall national vision, objectives and principles of the land use strategy.
8c. Can you suggest any alternative means of supporting the delivery of the Land Use Strategy at regional level?
8c
Nothing in addition to the previous answer.
8d. Do you have any other comments on this policy?
8d
The policy should draw on the existing work of landscape partnerships in different areas of Scotland and the UK, as a means of delivery some of the objectives and principles of the land use strategy at a local and regional level/scale.
Regional Land Use Frameworks
9a. Do you think that regional land use frameworks could be useful to inform regional/local land use decision-making?
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9b. Which aspects of this approach do you think requires further development?
9b
A forward thinking and open mind to new land management techniques and land uses to achieve ever more important functions in response to challenges like flood management, control of plant disease and improving biodiversity.
9c. Do you have any comments on this proposal?
9c
The land use strategy framework should be developed as a long-term vision which is reviewed and monitored throughout and beyond the same timescale for the delivery of local development plans and national planning policy.
Land Use Mediation and Facilitation
10a. Do you think that land use mediation or facilitation could be useful in a land use context?
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10b. Please provide reasons for your answer.
10b
Facilitating and maintaining dialogue between interested parties is crucial, and many of the principles and objectives of the land use strategy will be unattainable without constructive negotiations and ongoing communications.
The need for mediation in some cases, albeit a somewhat undesirable situation if it were to occur, may well be necessary in situations where logger heads are reached and an outside third party may be best placed to seek and agree an appropriate and satisfactory outcome in the interests of all parties.
The need for mediation in some cases, albeit a somewhat undesirable situation if it were to occur, may well be necessary in situations where logger heads are reached and an outside third party may be best placed to seek and agree an appropriate and satisfactory outcome in the interests of all parties.
Agriculture
11. Do you have any suggestions on other potential measures to encourage climate friendly farming and crofting?
11
A reduction in the extent of intensive grazing practices with sheep and deer and to a lesser extent cattle will allow the vegetation in our upland environments to reestablish and in turn increase its ability to capture and store carbon dioxide.
A shift from high intensity, high density, mass production farming methods, to more sustainable, local scale production methods may have a substantial impact on the current negative contribution of farming and agriculture to climate change.
A shift from high intensity, high density, mass production farming methods, to more sustainable, local scale production methods may have a substantial impact on the current negative contribution of farming and agriculture to climate change.
Agri-Environment
12a. Do you agree that more localised map-based ecosystems assessments could be useful to assist in informing funding decisions?
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12b. Please provide your reasons for your answer.
12b
Landscapes across Scotland are subject to very different land use and land management pressures, and the implementation of any agri-environment scheme should be subject to locally focused ecosystems assessments.
Agri-Environment
13a. Do you agree that an assessment of ecosystems health and a spatial approach could be helpful to further inform targeting for the next SRDP?
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13b. Please provide your reasons for your answer.
13b
A targeted approach would allow the highest priority ecosystems to receive the focus of restoration and enhancement efforts when they are most needed, and before, as it may be in some cases, it is too late to be effective or successful.
Urban Land Use
14a. Do you agree that an urban pilot project could be useful?
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14b. Please provide your reasons for your answer.
14b
With an increasing swell of support and interest in permaculture and local produce there is an increasing demand for people to have access to land in an urban context to support simple life supporting functions such as food production (e.g. allotments, rearing hens etc.), therefore an urban land use pilot would be welcomed.
This may also offer an excellent opportunity to highlight potential future use for derelict brownfield land, of all scales, to support ecosystem services in an urban context.
This may also offer an excellent opportunity to highlight potential future use for derelict brownfield land, of all scales, to support ecosystem services in an urban context.
Upland Land Use
15a. Do you think that a strategic vision could be useful for the uplands?
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15b. Do you have any comments on this proposal?
15b
A strategic vision for the uplands of Scotland should be a key objective of the land use strategy, and one which, as is acknowledged, will present incredibly difficult to deliver in agreement with all stakeholders who are concerned with the areas.
Nevertheless, the vision should seek to be ambitious in its objectives as the uplands present probably the biggest opportunity to make an important response to the effects of climate change. There is a fairly widespread consensus that current land use and land management practices in the uplands are unsustainable and cannot continue, and therefore there has never been a better time to have the debate about land use in the uplands, and a strategic vision for the future which benefits all.
Nevertheless, the vision should seek to be ambitious in its objectives as the uplands present probably the biggest opportunity to make an important response to the effects of climate change. There is a fairly widespread consensus that current land use and land management practices in the uplands are unsustainable and cannot continue, and therefore there has never been a better time to have the debate about land use in the uplands, and a strategic vision for the future which benefits all.
Monitoring Delivery of the Strategy - the Land Use Strategy Indicators
16a. Do you agree that the Land Use Strategy indicators are still fit for purpose?
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16b. Do you have any comments on the future monitoring of the revised Land Use Strategy?
16b
Monitoring of regional and/or local land use strategy partnerships should continue to influence and improve the land use strategy throughout its implementation (2016 - 2021) and beyond.
General Questions
17. Are there any other activities that you think we should be undertaking to achieve better understanding and application of the Principles or delivery of the Strategy?
17
Understanding how landscape change has occurred to shape the existing landscapes of Scotland, and how we can learn from past landscape change must first be clearly understood (including the historical and cultural influences) in order to ensure land use and land management of the future delivers positive landscape change in response to some of the challenges we now face (i.e. climate change, flood management, pressures on food production).
'e) Landscape change should be managed positively and sympathetically,
considering the implications of change at a scale appropriate to the landscape in
question, given that all Scotland's landscapes are important to our sense of identity
and to our individual and social well being.'
'e) Landscape change should be managed positively and sympathetically,
considering the implications of change at a scale appropriate to the landscape in
question, given that all Scotland's landscapes are important to our sense of identity
and to our individual and social well being.'
18. Are there any other points you wish to make about any aspect of this draft Strategy?
18
A greater emphasis on the importance of landscape throughout the land use strategy, as an important resource for everyone in Scotland.
Landscapes are an important part of our past, and play an important part in our lives today, and future generations.
We note there is no reference throughout the land use strategy to Wild Land, Wildness or Re-Wilding.
The omission of reference to Wild Land is somewhat surprising given the current policy pressures and uncertainty in respect of the recently defined 42 Wild Land Areas across Scotland, and the Landscape Institute Scotland would welcome further information and clarity on how the land use strategy will be delivered within the existing policy framework which controls development planning.
Landscapes are an important part of our past, and play an important part in our lives today, and future generations.
We note there is no reference throughout the land use strategy to Wild Land, Wildness or Re-Wilding.
The omission of reference to Wild Land is somewhat surprising given the current policy pressures and uncertainty in respect of the recently defined 42 Wild Land Areas across Scotland, and the Landscape Institute Scotland would welcome further information and clarity on how the land use strategy will be delivered within the existing policy framework which controls development planning.
Equalities
19. Do you have any comments on the policies and proposals in this draft Strategy in terms of how they may impact on any equalities group, i.e. with regard to age, gender, race, religion, disability or sexuality?
19
Nothing to add.
Questions on the Environmental Report
20a. Do you consider that the Environmental Report set out an accurate description of the current environmental issues/baseline?
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20b. Please give reasons for your answer.
20b
The increasing pressure for further deployment of renewable energy generation technologies, specifically onshore wind farms, in order to meet the Scottish Governments ambitious GHG emissions targets is only briefly highlighted in the Environmental Report baseline (4.2.11). The Landscape Institute Scotland would like to highlight there support for a review as to how a strategic approach may be advantageous when considering further new onshore wind deployment (wind farms located on new sites), or the inevitable second phase of onshore wind farm deployment through a process of decommissioning and re-powering, which will require consideration of different issues, especially in relation to landscape and visual effects associated with likely much larger proposed wind turbines.
It is noted that no mention is made of onshore wind farm re-powering, which is likely to occur within the timescale of the new land use strategy (2016-2021) and is indeed starting to occur in some areas of Scotland, where onshore wind farms were first deployed (i.e. Tangy Wind Farm, the Kintyre Peninsula in Argyll). SPP 2014 provides a clear steer on the continued use of existing wind farm sites 'in perpetuity' and it is felt that the likely continuation of large areas of Scotland for renewable energy generation should be highlighted within the Environmental Report and Land Use Strategy as a key land use and land management consideration (i.e. its compatibility alongside an updated Scottish Forestry Strategy will be a key consideration), which will stretch well beyond 2021.
It is noted that no mention is made of onshore wind farm re-powering, which is likely to occur within the timescale of the new land use strategy (2016-2021) and is indeed starting to occur in some areas of Scotland, where onshore wind farms were first deployed (i.e. Tangy Wind Farm, the Kintyre Peninsula in Argyll). SPP 2014 provides a clear steer on the continued use of existing wind farm sites 'in perpetuity' and it is felt that the likely continuation of large areas of Scotland for renewable energy generation should be highlighted within the Environmental Report and Land Use Strategy as a key land use and land management consideration (i.e. its compatibility alongside an updated Scottish Forestry Strategy will be a key consideration), which will stretch well beyond 2021.
21a. Do you consider that the predicted environmental effects as set out in the Environmental Report are accurate?
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21b. Please provide reasons for your answer including further information you feel should be considered in the assessment.
21b
The Landscape Institute Scotland generally agrees with the assessment of environmental effects set out in Appendix 3 of the environmental report, however it is noted that there is potential for conflict between the land use strategy and the ambitious GHG emissions targets set out in Scottish Government policy in terms of how the two may align while ensure positive enhancement of Scotland's landscapes.
It is noted that reference is made to the National Scenic Areas (limited reference to National Parks in a similar context) in Appendix 3 - Group 1 in terms of their legislative protection as designated features, however we would highlight the European Landscape Convention (ELC), the Council of Europe initiative which highlights the importance of 'all landscapes' and encourages more attention to their care and planning. The UK signed up to the convention in 2006, and it now provides a framework for many organisations work to protect and enhance Scotland's landscapes. It is likely that in some instances, there may be potential for negative or adverse environmental effects in terms of landscape and visual amenity through the delivery of the land use strategy objectives and the wider planning policy objectives (as set out by NPF3 and SPP).
It is noted that reference is made to the National Scenic Areas (limited reference to National Parks in a similar context) in Appendix 3 - Group 1 in terms of their legislative protection as designated features, however we would highlight the European Landscape Convention (ELC), the Council of Europe initiative which highlights the importance of 'all landscapes' and encourages more attention to their care and planning. The UK signed up to the convention in 2006, and it now provides a framework for many organisations work to protect and enhance Scotland's landscapes. It is likely that in some instances, there may be potential for negative or adverse environmental effects in terms of landscape and visual amenity through the delivery of the land use strategy objectives and the wider planning policy objectives (as set out by NPF3 and SPP).
22a. Do you consider that the recommendations and opportunities for mitigation and enhancement are accurate?
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22b. Please provide reasons for your answer.
22b
The Landscape Institute Scotland welcome the implementation of mitigation and enhancement which can bring about added consequential benefits for landscape and visual amenity, benefits which could be further enhanced by a more holistic strategy for land use and land management which an ecosystems approach advocates and which forms a key principle of the emerging land use strategy.
23. Are you aware of alternatives to the proposed policies that should be considered as part of the Strategic Environmental Assessment (SEA) process conducted for the draft Strategy?
23
Nothing to add.