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Re-drafted SNH SOAC pays little heid to consultation responses


Filed 02 Dec 03

Scottish Natural Heritage (SNH) Access Forum has done a re-draft of its Scottish Outdoor Access Code (SOAC) (1): that is, it has re-drafted the version that it put out for consultation earlier this year (2). The closing date for responses to be lodged with SNH was 30th June 2003. They received 1386 responses (3), with landmanagers in one form or another being the main section of the community to express their concerns.

For the public to get access to these 1386 responses is highly inconvenient, it being necessary to make an appointment to go either to SNH offices at Battleby (some miles outside Perth) or to one of SNH's offices in Edinburgh during normal urban office hours. This is not an easy thing for "landmanagers" (such as farmers) to do. Nevertheless Land-Care managed to read the first 530 of these responses, filed in order of receipt in a substantial number of lever arch files.

The message from these responses was clear in relation to a number of important issues. The points were made again and again throughout the responses. The same points were made again and again at the various roadshows that SNH organised during the consultation period.

Yet to read the re-drafted Code of October 2003 it would appear that SNH had not listened. Indeed, it seems that SNH re-drafted the Code before they had completed an analysis of the responses they had received.

Why it should take SNH so long to analyse 1386 responses - that keep saying much the same things - is beyond comprehension. The excuse that it all has to be done meticulously and analysed fully does not wear. Seeing the wood as opposed to the twigs or even the trees would be a step forward, and could easily be achieved without hiding behind a screen of excessive political correctness. If it is indeed political correctness that is their main concern, then SNH should not have been re-drafting the Code in the absence of a competent analysis of the responses to their own consultation paper.

As Bridget Dales of SNH informed Land-Care when visiting Battleby, the intention of SNH was not to let the public know what was going to be in the revised Access Code until after it had been sent to Ministers; and that the public would not be informed about SNH's own analysis of the responses to its own consultation paper until after the final version of the Code had gone to the Scottish Parliament. Presumably the purpose was to give minimum opportunity for the public to lobby their MSPs to protest their dismay at the responses to the consultation paper being given such biased attention, if not entirely ignored.

Yet again the use of sham consultation as a means of achieving political manipulation is all too apparent (4).

SNH is a government agency. It used to be regarded as a quasi independent advisory body providing considered advice to government, but now it is little else than an errand boy for its political masters - i.e. to implement their instructions whatever nonsense or damage that may ensue. As a consequence SNH ends up seriously contradicting its own policies in terms of conservation and what they choose to call natural heritage.

These are sad and bad times for Scotland. Given the opportunity of a devolved Parliament, instead of building up the trust of its people the Parliament and the Scottish Executive together with its agencies (such as SNH) abuse it in a most shameful manner. Thereby they loose credibility. So what was the point of having a devolved Scottish Parliament? Why should we bother to vote when they ask us to?

Why should we try to logically argue a case, only to find that we have been used as a political pawn? They never were interested in the responses, but it would have been wise to be a little less obvious in their despise of what the people think.

As a consequence of this further disillusionment in SNH and its masters, what the Scottish Outdoor Access Code is heading for is serious confrontation between would-be access takers whose expectations and aspirations have been raised to absurd levels and those who work the land and who have cared for it so well over generations.

What an unnecessary mess!

© www.land-care.org.uk


1. Scottish Natural Heritage (2003). Re-drafted SNH Scottish Outdoor Access Code: October 2003.
This is not an officially published document. Land-Care has obtained a copy and put it on the website as a protest at the secretive manner in which SNH conducts its business while professing to be open in its dealings with the public. It is a lengthy document and may take time to download , so please be patient.

2. Scottish Natural Heritage (2003). SNH draft Scottish Outdoor Access Code: a consultation document. March 2003

3. Editorial (2003). Draft Scottish Outdoor Access Code: Lack of adequate public access to the responses to consultation.
See SOAC HOMEPAGE, filed 3 October 03, www.land-care.org.uk, CLICK HERE TO VIEW

4. Irvine, James (2003). Does SNH conduct itself as an honest broker, or as a political manipulator?
See SOAC Homepage, filed 25 October 03, wwww.land-care.org.uk CLICK HERE TO VIEW