The idea of the UK’s national parks goes back almost a century, and owes much to Labour governments. In 1929 a committee was set up by the then Labour government, chaired by Christopher Addison (later Viscount Addison), a one-time Liberal politician who moved over to the Labour Party in the early 1920s. His committee’s report (which was published in 1931) proposed two types of national park: ‘national reserves’ which had outstanding scenic and wildlife interest; and ‘regional reserves’ which were more akin to country parks close to towns. However, the timing of the report was unfortunate. Ramsay MacDonald’s Labour government collapsed in the wake of the great depression, and the UK was led by a National (coalition) government, dominated by the Conservative Party until and (in a different format) through the Second World War. Economic considerations, the descent to war, and the World War itself, meant that the idea of national parks was firmly on the back burner throughout this period.

However, in 1945 a Labour Government was elected brimming with energy and ideas and with a substantial Parliamentary majority. It will forever be associated with the foundation of the National Health Service, but it was also responsible for many other profoundly important measures, such as the Town & Country Planning Act 1947 and the National Parks and Access to the Countryside Act 1949. Four national parks were set up in 1951, three in England (the Peak District, Lake District, and Derbyshire) and one in Wales (Snowdonia). Two more followed in 1952 (Pembrokeshire Coast in Wales and the North York Moors in England) and they were followed in 1954 by the Yorkshire Dales and Exmoor. Northumberland followed in 1956 and the Brecon Beacons (now called by the Welsh name of Bannau Brycheiniog) in 1957. The number rested at ten for more than thirty years, until the Broads national park was created in 1989 (technically it is only akin to a national park, and was set up under its own special legislation, the Norfolk and Suffolk Broads Act 1988).

The obvious omission from the above list is Scotland. Following the devolution settlement, national parks are a devolved matter, to be dealt with by the Scottish government in Holyrood, under the National Parks (Scotland) Act 2000. To date, two national parks have been created in Scotland – Loch Lomond and the Trossachs (2002) and the Cairngorms (2003, extended in 2010). Following the (now defunct) co-operation agreement between the Scottish National Party and the Scottish Greens, a commitment was made to the creation of a new national park north of the border. Despite the fact that the Greens are no longer part of the Scottish government, the momentum for a new national park seems to be unstoppable (though there are some who would like to stop it).

Galloway

In October 2023 the Scottish government invited local communities to put forward nominations for the third national park, and nominations were received from communities in Galloway, Loch Awe, Lochaber, Scottish Borders, and Tay Forest. There has been a well-organised campaign for a Galloway national park, and sure enough, the Scottish government is proposing (subject to the outcome of a reporter investigation) to proceed to make Galloway the third Scottish national park. The report is to be prepared by NatureScot. It will build on the submission of the Galloway National Park Association and the Galloway and Southern Ayrshire UNESCO Biosphere.

Of great interest to the inhabitants of East and South Ayrshire and Dumfries and Galloway is where the boundaries of the proposed national park will be. Depending on one’s point of view, being within or without the national park might be a good or a bad thing, so the area to be included is of critical importance. And here a strange thing has happened. Consultations between local residents and proponents of the national park commenced in or around 2017. By 2021, the boundaries that were being suggested by the Galloway National Park Association seemed (as they did in 2017) to include Southern Ayrshire and upper Nithsdale and to extend almost to the outskirts of Ayr. This appeared to be with a view to including the whole of the Galloway and Southern Ayrshire biosphere. The Thornhill Uplands also seemed to be included and the proposed park would have extended in the east almost as far as Dumfries. The Rhins of Galloway were excluded (or, at least, weren’t obviously included). In my ignorance, this is the sort of area that I assumed might be included in the proposed park.

Fast forward to the map included in the proposal submitted to the Scottish government, and the proposed boundaries have changed substantially. Upper Nithsdale and the Thornhill Uplands no longer seem to be included, and there is a strange bulge where a section of the biosphere in Ayrshire is now excluded. The Rhins of Galloway are encompassed within the boundaries. Coincidence or not, the exclusion of a large bulge, comprising much of South Ayrshire, handily excludes an area where various wind farms either already exist or are under construction. Parts of the Thornhill Uplands already enjoy regional scenic area (RSA) designation, so their exclusion from the final submission area seems strange. Despite that RSA designation it seems to be an area firmly in the sights of wind farm developers. One might think it should be included within the proposed national park in order to obtain protection from intrusive and damaging developments of this sort, but one would be wrong to think that. This isn’t how things work in Scotland these days.

It certainly appears that protection from wind farms depends on being within, rather than outside, a national park boundary in Scotland. The Scottish Government website has a page dedicated to “The Future for National Parks in Scotland”. A remarkably frank answer is given to this question: “What criteria should we use to decide where the next new National Parks in Scotland should be?” Indeed, it is so frank, that I think it is worth quoting at length:

In designating any new National Park or Parks, The Scottish Government must balance its ambitions to increase the number of National Parks in Scotland with the need to deploy more renewable energy to meet our legally binding target of reaching net-zero by 2045 and the binding interim targets for 2030 and 2040. To realise the enormous environmental, economic and social benefits that both National Parks and renewables can bring to Scotland it is our recommendation that only areas which fall within existing National Scenic Areas should be considered.

Why the contribution is important:

Scotland’s planning system determines where renewable energy generation technology can be deployed and is critical to determining whether enough energy can be generated to meet our legally binding target of reaching net-zero by 2045 and the binding interim targets for 2030 and 2040, as well as realising the economic and social benefits renewables offers.

Planning policy states that wind farms will not be built in either National Parks or National Scenic Areas. The renewables industry supports this policy.

To keep Scotland on track to achieving net-zero, we will require an additional 11GW of offshore wind, at least 12GW of onshore wind and 4GW of solar by 2030 to provide the electricity to decarbonise heat and transport…

…Creating a National Park in an area that is not currently covered by any designations that precludes wind farm development, will have significant ramifications for meeting Scotland’s renewable energy targets, and pose a direct conflict with the priority given to the Climate Emergency, as seen in draft NPF4.

It will not be possible to repower any wind farm already sited in a newly designated National Park. This will mean that, over time, there will be a loss of generation. Resulting in a loss of opportunity for increasing generation with larger and more efficient turbines typically seen with a repowered site.

There could be a loss of opportunity to life extend existing assets, therefore wasting the opportunity to maintain output at an operational site….

…There may be wind farm projects not yet determined at earlier stages of the development process in a new designated National Park which are no longer viable, meaning a significant financial loss to developers and future investor confidence.

Scottish Renewables would be keen to engage further with this agenda and would be happy to discuss our response in more detail.

Scottish Renewables is the voice of Scotland’s renewable energy industry. Our vision is for Scotland leading the world in renewable energy. We work to grow Scotland’s renewable energy sector and sustain its position at the forefront of the global clean energy industry. We represent over 300 organisations that deliver investment, jobs, social benefit and reduce the carbon emissions which cause climate change.

At this stage my scepticism borders on cynicism. That looks to me remarkably like the Scottish government working hand-in-glove with Scottish Renewables to ensure that any new national park doesn’t get in the way of giving Scottish Renewables what it wants. I feel it’s reasonable to question whether the latest boundaries that form the submission for a Galloway National Park – which frankly look weird from a coherence point of view – have been drawn so as to exclude existing and proposed wind farm developments. I surmise that only by doing that would the Scottish government be minded to grant the designation of a third Scottish national park to Galloway. Do I have any evidence beyond a gut feeling? Well, there’s this:

Windfarms – Existing and Proposed

The Scottish Government Energy Consents Unit (ECU) website gives us some interesting information. In East Ayrshire, fourteen applications have received planning consent, while only two have been refused. In South Ayrshire, a similar situation obtains, with twelve having received consent, and one having been refused. In Dumfries & Galloway the situation is less straightforward, but there have still been twelve consents to seven refusals, with one application referred to the Scottish government’s Planning and Environmental Appeals Division.

Drilling down, we find in Dumfries & Galloway that the vast majority of applications for wind farms are in respect of sites that now fall outside the proposed Galloway National Park boundary. Those within the boundary seem to be meeting with no official opposition, and it might be assumed that they will get the nod before the National Park status is confirmed (with the result, presumably, that they can go ahead regardless). Mid Moile at Cairnryan (15 turbines to a height of 230m) met with no opposition from the Council and is currently with the ECU. Artfield Forest (north west of Newton Stewart) involved an application for 12 turbines to a height of 180m. The Council did not object and the ECU granted consent.

Clauchries, north east of Barhill, Newton Stewart seems to have been an exception – although the Council raised no objection, consent was refused by the ECU. Kilgallioch, north west of Kirkcown, involves 96 turbines to a height of 147m. Again, the Council did not object and consent was duly granted by the ECU. Its extension (another 11 turbines to a height of 180m) again met with no objection from the Council and is currently with the ECU. The Arecleoch extension (involving 13 turbines to a height of 200m) met with no Council objection and duly received consent from the ECU. Stronach 2, north west of New Luce, Stranraer, unusually received an objection from the Council and is currently in pre-application with the ECU. Stranoch, at New Luce (28 turbines to a height of 135 metres) was objected to by the Council, but received consent from the ECU. The same is true of Brackcraig, New Galloway, which seems to be on the boundary of the proposed national park. It involves 23 turbines to a height of 110m. Over thirty other wind farms in Dumfries & Galloway are outwith the revised boundary of the proposed national park.

One of the strange things about the developing story of the national park boundaries at the eastern end of the proposed national park relates to the Southern Upland Way (a 40 year old 214 mile long trail). This website describes it as “Britain’s first official coast to coast long distance path”. While wandering the hills of southern Scotland I have walked quite a few sections of it myself and in places it is stunningly beautiful; much of it involves walking through wild country. If the website pictures are to be believed, there isn’t a wind turbine in sight. Anyone walking the trail, however, will be bitterly disappointed if they don’t want to see turbines. Where the route goes through upper Nithsdale it travels almost entirely through an area of wind farms, either existing or in the course of seeking planning consent. Locals hoped that the proposed National Park would offer protection from the new applications. Now it seems that no such protection will be forthcoming, and the National Park won’t extend to cover this area after all.

When we turn to Ayrshire, and the “loop” or bulge of land that is now excluded from the proposed national park boundaries, the situation does seem to be particularly stark. In South Ayrshire, it’s difficult to be completely certain (due to the small scale of the plan available to check) but of eight applications that have either been recently consented, or are in scoping, have completed pre-application or are in application with the ECU, seven are outwith the revised boundaries (five definitely in the looped area, two just above it, and one (Mark Hill, near Barrhill) is possibly in the looped area. It’s a similar story in East Ayrshire, with five proposed wind farms outwith the revised boundaries (though in fairness the strange loop is more of a South Ayrshire issue).

Residents who might be affected by the designation of a Galloway National Park, and for whom the drawing of the boundaries of the proposed park is important, would be well advised to start lobbying now, and certainly to engage with NatureScot, which says it will seek the views of local residents and other stakeholders. There will be a twelve week period of formal consultation, which NatureScot says is likely to be from November 2024, with advice to Ministers being provided by 28^th April 2025. In other words, time is of the essence, as is ensuring that residents make their views known. Whether it’s being inside the boundaries, to seek to exclude wind farms, or being outside the boundaries, to minimise planning restrictions, it will be vital to lobby NatureScot.

Lake District

As I mentioned earlier, the statutory regime in England differs from that in Scotland, both with regard to the setting up and administration of national parks, and also with regard to planning rules. And thus the absolute ban on wind farms in national parks south of the border may be a moot point now that the UK government (which controls English planning policy) is gung-ho with regard to building lots and lots of wind farms both on- and off-shore so far as England is concerned. To date it seems to have been the case that wind farms are not permitted within English national parks. Certainly I have not seen a single wind turbine in my local national park, the Lake District. I do remember many years back objecting to an application within the Lake District National Park for a wind turbine (singular) and I know that permission was refused in that case.

The Lake District National Park Local Plan, adopted in 2021, may now be out-of-date. It says that “We want to increase the proportion of energy generated by renewable and low carbon sources and encourage energy provision from local scale generation, supporting a Low Carbon Lake District” and “…solar and wind can also make a contribution to increasing power from low carbon energy sources.” Then there is this fairly blunt paragraph, which seems to offer much more encouragement to (small-scale?) wind turbine developers:

We will have regard to the Cumbria Wind Energy Supplementary Planning Document when assessing wind energy developments. There is a presumption against large scale wind energy development in the Lake District, as schemes of this scale will be incompatible with the objectives of National Park designation. However, the landscape in some parts of the Lake District may have capacity for small scale wind energy schemes without adversely affecting the landscape character or other Special Qualities. The whole of the Lake District has been identified as suitable for small scale wind energy development subject to meeting the criteria set out in other policies in the Local Plan. We will assess renewable energy proposals in accordance with the Lake District National Park Landscape Character Assessment. When we assess proposals for wind energy proposals and both ground and roof mounted solar arrays we will take account of the cumulative impacts both within the Lake District and those which are visible beyond its boundary.

Then there is the Daily Telegraph article from 15^th July 2024 with the worrying heading “Revealed: The countryside that Ed Miliband could target first in onshore wind revolution – New turbine developments threaten to change England’s landscape for good”. It refers to a Lumify Energy report and concludes that:

It has found 44 authorities that positively favour wind farm developments, covering three national parks, several cities and thousands of square miles of English farmland and countryside.

They include the Lake District National Park, North Norfolk, County Durham, Mid Sussex, Stroud and Teignbridge.

Referring to the plan I cited above to the effect that the Lake District National Park is now in favour of “small-scale” wind energy schemes, the Daily Telegraph tells us that “Small-scale tends to refer to turbines up to 100ft tall.”

There are two issues with this, one positive, one negative. The first is that while that claim about turbines up to 100 feet falling within the definition of “small-scale” development that might be approved may well be correct, no evidence is provided to back up the claim, so it might not be. On the other hand, given that the Lake District National Park local plan pre-dates the election of the current turbine-mad government, there is always the worry that what is deemed to be “small-scale” might in fact be on a rather larger scale than lovers of the Lake District would like. There is also the worry that turbines up to 100 feet high might represent a foot in the door, that leads to approval of turbines 120′ high, then 150′ and on to 200′ and upwards. These are worrying times for those of us who thought that the extensive system of English national parks offered protection from fresh industrial development of our beautiful wild places (the Lake District has of course been extensively mined and quarried, though in many such places, nature is reclaiming her own). It’s bad enough that the Lake District is ringed with with wind farms built in the early days, visible from all over the national park, but the thought of turbines peppering this precious and beautiful landscape itself is too much to bear.

Conclusion

Nowhere, it seems, is safe. And wherever the boundaries of the Galloway National Park end up being drawn, there must always be the worry that the prohibition on wind turbines within Scottish national parks will be torn up if it suits politicians to do so – England seems to be setting a worrying precedent regarding the shape of things to come.

Acknowledgement

My thanks go to members of Scotland Against Spin who supplied much of the detailed information with regard to wind farms current and planned in Dumfries and Galloway, East Ayrshire and South Ayrshire, as well as supplying helpful local knowledge generally. Any errors, of course, remain my own.