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Re-drafted SNH SOAC pays little heid to consultation
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
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
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
What an unnecessary mess!
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.
CLICK HERE TO VIEW
2. Scottish Natural Heritage (2003).
SNH draft Scottish Outdoor Access Code: a consultation document.
3. Editorial (2003). Draft Scottish
Outdoor Access Code: Lack of adequate public access to the responses
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