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Locallandscapes 29092005asfinal

  1. 1. The Macaulay Institute Aberdeen Final Report:A Critical Review of Local Landscape Designations in Scotland Dr Alister Scott and Peter Shannon Socio-Economic Research Programme Macaulay Institute Craigiebuckler Aberdeen 1
  2. 2. Contents1. Introduction 42. Aims 73. Local Landscape Designations: Policy Background 74. Local Landscape Designations: The English and Welsh 11 Experience5. Local Landscape Designations: The Scottish Experience 136. Methodology 177. Results 218. Discussion 519. Conclusions and Further Research 5810. References 63 2
  3. 3. Acknowledgements The authors gratefully acknowledge the funding of this independent research from the Macaulay Development Fund. Special acknowledgement is made to Scottish Natural Heritage and their staff who allowed access to internal material and offered valuable advice throughout the project. Finally thanks are due to those local authority staff who participated in the project. 3
  4. 4. 1 Introduction1.1 Landscapes play an important part in our lives, shaping our national, regional andlocal identities, affecting our quality of life and providing the context within which social andeconomic development takes place.1.2 Within a UK context it is the uplands and coasts that have been particularly favouredby policy makers within National Parks and Areas of Outstanding Natural Beauty. Gold andBurgess (1982) criticise this bias and argue that more local and accessible ruralenvironments, although experienced by a majority, have been neglected. At the local level itis the distinctive identities of landscapes with particular associations and interactionsbetween people and place which are of significant value and which are increasinglycontested in the face of competing pressures for change. The strength of attachment tothese ‘ordinary’ places and landscapes frequently only emerges when they are threatened bychange. Familiarity and experience with landscape have long been recognised as importantfactors in perception studies by Burgess et al (1988) and Penning-Rowsell (1982). AsTapsell (1995) acknowledges, the most valued open areas are often the familiar ones whichplay a part in peoples daily lives and experiences.1.3 The town and country planning system is the principal institution used to resolvecompeting interests in the landscape. This is achieved primarily through a system ofdesignation and associated policy development recommending restraint through whichelected planning committees ultimately adjudicate. However, today designations areincreasingly questioned as to whether they represent the best and most equitable means ofdeciding the kind of landscapes stakeholders really want and value (Scott and Bullen, 2004;Welsh Assembly Government, 2004). 4
  5. 5. 1.4 This research responds to local authorities and other stakeholders’ concernsregarding the status of local landscapes and the current mechanisms in place for theirconservation and enhancement. Whilst there is a general policy presumption againstdevelopment in the open countryside there are Local Landscape Designations (LLDs) whichprovide the main focus of the research. Widely used by local authorities since the 1960s asplanning tools for landscape management in the UK, they remain significantly under-researched and misunderstood by public, planners and policy makers alike (Scott andBullen,2004; Scott, 2001). Yet, in theory, they offer an avenue within which local landscapepriorities can be identified and realised in policy terms.1.5 As landscape management tools, LLDs sit beneath the national tier of designations(National Parks and Areas of Outstanding Natural Beauty, Green Belts and National ScenicAreas (Scotland)) and arguably provide complementarity as local and flexible frameworks forlandscape protection and enhancement (Scottish Natural Heritage and Historic Scotland,2005).1.6 Local designations, in comparison to their national counterparts1, have largelyoperated on a top-down presumption of perceived value with little research or evaluation intotheir efficacy and additionality in planning practice, especially given the strong generalplanning policies of constraint currently operating in the wider countryside.1.7 This neglect is curious given the significant reservations from government andnational agencies in their published guidance on LLDs for their future use and development(ODPM, 2003; 2005; Rural Development Commission 1998; Scott and Bullen, 2004).Furthermore, the fact that LLDs sit within what some people consider to be an increasinglycomplex suite of designations impacting upon the UK raises wider issues about the need forrationalisation of designations more generally (Bowen Rees, 1995; O’Riordan, 1983).1 For a detailed review see Scott and Bullen (2004) 5
  6. 6. 1.8 Previous research from Wales raised questions about the role, consistency andappropriateness of LLDs, given their impacts on the wider countryside and reported upon aperception of ineffectiveness of such designations in planning and landscape enhancement.Crucially, the lack of public awareness and involvement in LLD designation and managementwas identified as a major inconsistency given their alleged local imperatives (Scott andBullen, 2004).1.9 This report considers the Scottish experience where, for the first time in the UK,comprehensive guidance for local landscape designations has been published by ScottishNatural Heritage and Historic Scotland (2005). This research, funded by the MacaulayInstitute can be seen as a useful adjunct to this guidance by providing the opportunity for anin-depth assessment of LLD theory and practice across a range of rural and urban localauthorities.1.10 The report begins with a general policy review of local landscape designations withparticular analysis of the Scottish experience and legislative background. The core of thereport focuses on the results of primary and secondary data obtained from all 32 localauthorities in Scotland, together with an assessment of the recently published SNH/HSguidance (2005). 6
  7. 7. 2 Aims2.1 Four key aims lie behind this work • to identify and explain current approaches to LLD use and designation; • to critically assess LLDs as planning and landscape management tools; • to provide a preliminary assessment of the efficacy of current guidance for LLDs; and • to assess what role, if any, LLDs might play for the future.3 Local Landscape Designations: Policy Background3.1 Scott and Bullen (2004) provide a critical review of the wider context of landscapedesignations in the planning system and the development of local landscape designationsfrom English and Welsh perspectives.2 Their narrative reveals how landscape protectioninitially focussed on protecting upland landscapes, reflecting key personal biases inherentwithin the Dower and Hobhouse reports and enshrined in subsequent legislation for nationalparks in 1949 (Shoard et al, 1982a). Here the approach to landscape protection, widelypractised for the rest of the century, was one firmly rooted in “drawing lines on maps”.3.2 Designation provided the security and tool for planners around which policies ofconstraint could be developed, positioned and strengthened, albeit with questionablesuccess as agriculture and forestry lay outside formal planning control and were able toeffect significant and detrimental landscape change (Shoard, 1982b).2 The paper uses the term ‘non-statutory designations’ which has been changed to ‘local landscapedesignations’ as by default all policies and designations in the development plan are seen as statutory.The term ‘local landscape designations’ is therefore less ambiguous. 7
  8. 8. 3.3 The guiding principle behind designation was that particular landscapes weredeemed more ‘special’ than elsewhere based on key criteria of importance and sensitivity.Such ‘landscape elitism’ was widely contested by key stakeholders and land managers,particularly given the perceived negative implications of designation on rural developmentactivity. However, there is emerging evidence that this wholly negative view might bechanging. For example, the clamour for inclusion by communities in the Scottish nationalparks and the low level of protest in the roll out of NATURA 2000 flows from the increasingrecognition that designation can bring benefits to the area from different funding regimes atEuropean, national and regional levels.3.4 However, towards the end of the twentieth century designation was slowly beingchallenged through the development of a new conceptual approach to landscape thatfocussed on ‘landscape character’. Landscape was seen “as an area, as perceived bypeople, whose character is the result of the action and interaction of natural and/or humanfactors” (Council of Europe, 2000: Article 1). This placed the emphasis on managementprescriptions that tried to protect or enhance the character of any particular landscapethereby shaping a broader, and arguably more inclusive approach to landscape planning andmanagement.3.5 The European Landscape Convention recognises the importance of “protecting,managing and enhancing landscapes” with signatories to the Convention agreeing to includedevelopment and management issues relating to landscape in public decision makingprocesses. Unfortunately, the UK government has not signed up to this yet. 8
  9. 9. 3.6 The main focus of UK work has been the national programme of LandscapeCharacter Assessment (LCA) which has been undertaken in different ways across Wales(LANDMAP) (Countryside Council for Wales 2001) and Scotland/England (LCA)(Countryside Agency/Scottish Natural Heritage 2002). This programme has enabled alllandscapes to be surveyed and described in terms of their key characteristics, though atpresent there is a risk that this will remain as a domesday style record. Further work hasensued looking at landscape capacity, tolerance to change and landscape quality, albeit withvariable results (Scott and Falzon, 2004; Nottingham Consultants, 2004; Swanwick, 2003).3.7 The different approaches inherent with landscape designation versus landscapecharacter approaches are summarised in Box 1. The fundamental difference is thatlandscape character assessments are more inclusive across all landscapes with a degree ofdynamism and integration that is absent from traditional designations of landscapeimportance that tend by their very nature to be hierarchical.3.8 Boundary issues are also fuzzier where character is concerned. The impact of a linein a designation has much more significance than a character boundary. This brings sharplyinto focus the methods and tools involved in the boundary process as well as recognition thatsuch decisions can be politically motivated, as evidenced in the recent designation of theCairngorm National Park (Illsley and Richardson, 2004). However, as Jones (2002) hasstated, “landscape character does not preclude the development of designations thereafter”.For example several local authorities in Wales have used LANDMAP LCA as a basis forsubsequent LLD designation citing the method as a means of providing greater rigour todesignation (Scott and Bullen, 2004). 9
  10. 10. Characterisation DesignationPurpose Describes all landscape character Identifies special landscapes in the types in the local authority area. local authority area.Scope Provides a basis for distinguishing Identifies more discrete areas of different landscape character types landscape considered to be of higher and identifying landscape sensitivity. merit and which may comprise a combination of landscape character types.Approach Based on an assessment of defined Based on an assessment of landscape features. landscape importance.Outcomes Informs development of general Informs development of specific landscape policies and guidelines planning policies geared towards for all landscape character types. enhanced protection and management of particular areas.Treatment Boundaries are based on landscape More precisely drawn boundaries areof character areas and are more defined by a range of criteria,boundaries transitional in nature. including landscape character, visual envelopes and topographic features.Box 1: Landscape Characterisation and Landscape Designation Compared (SourceSNH/HS (2005) 10
  11. 11. 4 Local Landscape Designations3: The English and Welsh experience4.1 The development of LLD policy in England and Wales began in 1973 when theCountryside Commission issued guidance to local authorities when preparing Areas of GreatLandscape Value (Cobham Resource Consultants, 1993). Thereafter, there was an advisoryvacuum with little guidance until the Policy Planning Guidance notes of the late 1980s (PPG7 the Countryside and the Rural Economy). More recently, Planning Policy Statements (PPS)emerged, where PPS7 (Sustainable Development in Rural Areas) explicitly addressed LLDs(ODPM, 2005 par24-25).4.2 This planning guidance was rooted in caution- 24 “The Government recognises and accepts that there are areas of landscape outside nationally designated areas that are particularly highly valued locally. The Government believes that carefully drafted, criteria-based policies in LDDs, utilising tools such as landscape character assessment, should provide sufficient protection for these areas, without the need for rigid local designations that may unduly restrict acceptable, sustainable development and the economic activity that underpins the vitality of rural areas. 25 Local landscape designations should only be maintained or, exceptionally, extended where it can be clearly shown that criteria-based planning policies cannot provide the necessary protection. LDDs should state what it is that requires extra protection, and why. When reviewing their local area-wide development plans and LDDs, planning authorities should rigorously consider the justification for retaining existing local landscape designations. They should ensure that such designations are based on a formal and robust assessment of the qualities of the landscape concerned.”4.3 Scott and Bullen (2004) in their research in Wales found that such caution was not inevidence with an ad-hoc approach to LLDs which raised various questions as to their overalleffectiveness, signalling a need for more research and policy debate given their potentialimpacts in landscape management and planning. Of primary concern was the mechanismsby which LLD boundaries were drawn, the rigour of methodologies used, the lack of archivalinformation on the initial development of the designation, the different roles LLDs performed, 11
  12. 12. the lack of public awareness and involvement, the lack of consistency towards planningapplications in LLD and the wider countryside, the lack of formal evaluations of theireffectiveness, the lack of joint working across unitary authority boundaries and the lack ofboundary reviews.4.4 On the positive side, however, the development of LCAs through the LANDMAPexercise was seen to provide the necessary rigour for designation which some localauthorities had pursued. Scott and Bullen (2004) suggest there was a strong case fortailoring LLDs towards a more community-led role in keeping with the locally based nature ofthe designation, where additionality and clarity could be better identified. Here, the LocalNature Reserve concept was seen as useful model to emulate.4.5 Their key conclusion, however, was over the emerging tension between planners andothers over using the more radical landscape character assessments as the prime decisionmaking tool versus using such assessments to improve existing local landscapedesignations. This had led to a mixed and inconsistent picture across Wales with someauthorities abandoning LLDs whilst others had re-invented them.3 For a full review please refer to Scott and Bullen, (2004) 12
  13. 13. 5 Local Landscape Designations : The Scottish Experience5.1 In Scotland there is a different history and legislative background to LLDs. This isdiscussed in some detail below as it provides vital context to the current research reportedhere.5.2 The first piece of Scottish guidance lay with Circular 2/1962 which set out actions thatlocal planning authorities should take where outstanding scenic areas required specialconsideration under the Planning Acts. All local authorities were to survey their areas toidentify “areas of great landscape value (AGLV) which can be described as vulnerable in thesense that there are or may be pressures for development that may affect them in one wayor other”.5.3 For each area identified, local planning authorities were to prepare a writtenstatement of the general character and quality of the area, definition of the boundaries andpolicy for control and phasing of development. Significantly, there was no further guidanceuntil 1999 when National Planning Policy Guideline (NPPG) 14 indicated that planningauthorities should avoid the unnecessary proliferation of local designations. Nevertheless, itconfirmed the continuing relevance of AGLVs and other local landscape designationsalongside new methodological developments of landscape character assessment. It statedthat boundaries should be clearly defined and justified in development plans. The guidancemade it clear that AGLVs were at a level in a hierarchy below national designations with clearimplications for the level and nature of protection.5.4 More recently, Planning Advice Note 60 addresses local designations includingAGLVs. It suggested that local designations were “of most value where they form part of awider landscape and habitat framework and contribute to the realisation of Natural HeritageStrategy, LBAP or Local Agenda 21 objectives to enhance the quality of urban living and help 13
  14. 14. make an area more attractive as a location of economic activity” (par. 39). This morepositive and strategic role represented an interesting shift in view from the more cautionarystatements elsewhere in the UK.5.5 With specific reference to AGLVs, PAN 60 suggested that a single tier of sub-nationaldesignations should be sufficient for practical planning purposes, with areas selectedbecause of their importance beyond their ‘immediate locale’. It also recommended thepreparation of specific development guidelines to safeguard their landscape character.5.6 Guidance published by SNH and HS (2005) builds from this national policyframework. At the outset the report states that “local landscape designations are a well-established and valued approach to protecting and guiding change in areas of particularlandscape importance” (1.1). Here there is explicit recognition of the value of LLDs and theguidance sees no tension between an all landscapes approach via the landscape characterassessment process and the revitalisation of LLDs through three interrelated roles: asaccolades, through policy development and as management tools.5.7 The interesting observation from this viewpoint is that designations are seen asproviding something extra that an all-landscapes approach cannot, a theme observed in theWelsh study where some planners were reluctant to relinquish the traditional security of lineson maps in favour of a more integrated approach for fear of increased development pressureand loss of countryside. Scott and Bullen (2004) speculated that it was the economicdeterminism of planning committees with respect to interpretation of planning policies thatwas instrumental in driving this response. 14
  15. 15. 5.8 This 2005 guidance is highly significant as it represents the only substantivedocument on LLDs in the UK and it therefore demands closer inspection. Its remit is to: • promote greater understanding and support for local landscape designations among local authorities, the public and other key stakeholders; • reaffirm the role of local landscape designations as part of an ‘all landscapes’ approach and define the circumstances when they could be used; • secure greater consistency in the selection and use of local landscape designations by local authorities; and • clarify the relationship of local landscape designations to the wider family of Scotland’s landscape designations. p65.9 The guidance provides a useful checklist for local authorities to consider LLDdesignation based on a range of different criteria that includes:- landscape character(typicality, rarity, condition); landscape qualities (scenic, enjoyment, cultural, naturalness);landscape criteria (significance, representativeness and relative merit); and practical criteria(need, integrity and support, including public support). These criteria bear more than apassing resemblance to the Countryside Commission criteria for designating AGLVsoriginally published in 1973 (Scott and Bullen, 2004).5.10 However, the process and methodology by which particular landscapes are valuedand assessed for LLDs is seen as a matter for local authorities themselves to decide upon, inpartnership with experts and stakeholders. The guidance argues that a national frameworkis inappropriate as these are essentially locally derived designations and the use of a “onesize fits all” approach would be problematic (3.9-3.10). Therefore a menu driven approach isfavoured which local authorities can adapt to local circumstances. The guidance does stressthe need for transparent and rigorous methods to be employed so they can be defendedunder cross examination at public local inquiry and here there is specific mention of the roleof pilot capacity studies such as in Cupar (Fife Council, 2004). It also recommends the needfor improved strategic management of LLDs through better arrangements for cross authorityworking and co-operation where LLDs are near or cross boundaries, the need for systematicreviews of boundaries and improved community involvement and awareness in LLDdesignation and management. 15
  16. 16. 5.11 In terms of planning policies the guidance also makes some key recommendationswhich reflect the focus of LLDs as positive landscape management tools rather than negative”no development zones. Furthermore, there is a role for Supplementary Planning Guidancecovering issues such as design and capacity, which could steer quality applications in theseareas. Other tools such as management statements and complementary designations suchas regional parks are also seen as having a role to play in changing the traditional negativeoutlook of LLDs. 5.5 In terms of best practice, development plan policies should recognise the positive contribution that appropriate development and other land use change can often make to the landscape character and qualities of the designated area. Nevertheless, some development and land use change will be inappropriate for such areas. Development should therefore generally only be permitted within a local landscape designation when i) it will not have significant adverse impacts on the special character or qualities of the landscape of the area; ii) the social and economic benefits of the development are considered to be more than of just local significance in the context of the local authority area. For development that meets these tests, the location, scale, design, materials, and landscaping should be of a high standard and, where appropriate, should seek to enhance the special qualities and character of the landscape.SNH/HS (2005):245.12 Certainly the national guidance provides a useful template upon which to base ourresearch method and deliberations. 16
  17. 17. 6 Methodology6.1 A letter was sent to all planning directors within the 32 unitary authorities in Scotland(Figure 1) outlining the aims of the research and requesting interviews with key developmentcontrol and forward planning staff. A copy of the interview schedule (Box 2) was included soas to allow officers adequate time to prepare and collate the necessary information anddocumentation prior to the interview. Special Landscape Interview list 1. Explain the purpose of the research a. To examine the role and effectiveness of non statutory landscape designations as planning and landscape management tools 2. Any response made to the SNH study on role of NSD for guidance 2003/4 3. What designations affecting landscape exist within the county a. Include all designations (hierarchy) Conservation areas, NSA, Green Belts (Need maps) b. What designations do you have NOW that are non statutory (landscape) and others e.g. nature conservation/community. (Define non statutory as designations confirmed and under the sole control of the local authority independent of any other agency ) c. What non stat designations have you had in the PAST 4. Extent (For each non stat designation (NSD)) a. Are there maps of these designations b. Area of land of these designations c. Predominant land use/type 5. Definition (For each NSD) a. How do you define it (compare) b. How is the designation defined (refer to stated policy if possible) c. How does it fit in with the other designations d. How does it fit in with neighbouring authorities (is there are strategic approach) e. Ensure we have all relevant extant development plan policy numbers that are relevant to NSD) If possible the whole development plan and/or other strategies (the landscape strategy is a key documents ) f. Try to compile an up-to-date list of the relevant plans that are passed, prematurity, (take care to get SP and LP updates 6. Designation (For each NSD) a. How were they designated (and when) (give criteria if possible) b. Have the boundaries reviewed at any time c. Role of public/community involvement in the process. 7. Differences between (NSD) and policies in development plans for wider countryside a. Additionality in policy emphasis or planner perception between NSD and WC b. What happens when a planning application falls in a NSD are there special procedures invoked for development control staff c. Do you have a process of informal negotiation with developers to advise about NSD (have you any figures to quantify how many applications were prevented) d. Level of development pressure in NSD vs. WC e. Use of planning tools to achieve NSD objectives ; conditions vs. refusals 8. SWOT analyses PROMPTS a. Are all NSD viewed the same here or are some better than others b. Especially whether the designation is understood by the developers and local community and local members 9. Role of landscape character assessment a. Is LCA changing your perception about the role of NSD b. How are you using LCA to guide landscape management in your county (more NSD vs. Abolishment) 10. Future a. What are your strategic plans for NSD (are they being proposed in development plans b. How do you respond to landscape elitism vs. landscape character tensionBox 2 Interview questions sent to planning officers in advance of meetings. 17
  18. 18. 6.2 Fifteen authorities agreed to an in-depth interview (Table 1). For most interviews twomembers of the planning staff (development control and forward planning) were seen, but insome authorities three officers were interviewed in order to include staff responsible forlandscape management. Semi-structured interviews lasting around two hours were carriedout between January and May 2005. They were taped, transcribed and subjected tothematic content analysis. The interview schedule (Box 2) sought to capture both interviewand documentary evidence. The attitudes and perceptions of officers relating to the role,efficacy and future status of LLDs as planning and landscape tools were elicited as proxiesfor planning practice, while documentary policy analyses of development plans wereundertaken to indicate the theory.Council Method of survey GIS data AvailableAberdeen City Council Face to Face Interview FullAberdeenshire Council Face to Face Interview FullAngus Council Face to Face Interview FullArgyll and Bute Council Questionnaire FullClackmannanshire Council Questionnaire FullComhairle nan Eilean Siar Video Conference FullDumfries & Galloway Council Questionnaire FullDundee City Council Questionnaire FullEast Ayrshire Council Face to Face Interview FullEast Dunbartonshire Council Questionnaire FullEast Lothian Council Questionnaire FullEast Renfrewshire Council Questionnaire FullEdinburgh City Council Face to Face Interview FullFalkirk Council Questionnaire FullFife Council Face to Face Interview FullGlasgow City Council Face to Face Interview FullHighland Council Face to Face Interview PartialInverclyde Council Face to Face Interview FullMidlothian Council Questionnaire FullMoray Council Questionnaire FullNorth Ayrshire Council Face to Face Interview FullNorth Lanarkshire Council Face to Face Interview FullOrkney Islands Council Video Conference PartialPerth & Kinross Council Questionnaire PartialRenfrewshire Council Face to Face Interview FullScottish Borders Council Questionnaire FullShetland Islands Council Telephone Interview FullSouth Ayrshire Council Questionnaire FullSouth Lanarkshire Council Questionnaire FullStirling Council Questionnaire FullWest Dunbartonshire Council Questionnaire FullWest Lothian Council Unable to respond due to lack of time PartialTable 1: Information approach for authorities participating in LLD research 18
  19. 19. 6.3 The remaining 17 authorities were contacted by telephone to secure theirinvolvement in a follow up questionnaire prioritizing spatial data to build up a comprehensivegeographic information database about LLDs but with the opportunity for comments on LLDs.One authority was unable to respond due to lack of staff time.6.4 Complementing the data obtained, we were also able to analyse the writtencomments of 27 local authorities received by Scottish Natural Heritage as part of theirconsultation on LLDs which provided the basis for the 2005 guidance. 19
  20. 20. 27 23 Scottish Council Areas 13 1 Aberdeen City 2 Aberdeenshire 3 Angus 4 Argyll & Bute 5 Clackmannanshire 6 Dumfries & Galloway 20 7 Dundee City 17 8 East Ayrshire 9 East Dunbartonshire 2 10 East Lothian 1 11 East Renfrewshire 12 Edinburgh City 13 Comhairle nan Eilean Siar 14 Falkirk 3 15 Fife 24 16 Glasgow City 7 17 Highland 18 Inverclyde 4 19 Midlothian 30 15 5 20 Moray 21 North Ayrshire 18 31 9 14 12 10 22 North Lanarkshire 25 16 22 32 23 Orkney Islands 19 24 Perth & Kinross 21 11 25 Renfrewshire 29 26 Scottish Borders 8 26 27 Shetland Islands 28 South Ayrshire Rural 28 29 South Lanarkshire 6 30 Stirling Urban 31 West Dunbartonshire 32 West Lothian Crown copyright Ordnance Survey. All rights reserved. 0 25 50 100 Kilometres MLURI Licence No. GD27237X 2005.Figure 1: Map of 32 Unitary Authorities in Scotland 20
  21. 21. 7 Results 27 Partial Spatial Data Council Areas Historic Gardens and Designed Landscapes Local Landscape Designitions Future Removal of Local Landscape Designations 23 13 Scottish Council Areas 1 Aberdeen City 2 Aberdeenshire 3 Angus 4 Argyll & Bute 5 Clackmannanshire 6 Dumfries & Galloway 17 7 Dundee City 20 8 East Ayrshire 9 East Dunbartonshire 2 10 East Lothian 1 11 East Renfrewshire 12 Edinburgh City 13 Comhairle nan Eilean Siar 14 Falkirk 3 15 Fife 24 16 Glasgow City 7 17 Highland 18 Inverclyde 15 19 Midlothian 30 5 20 Moray 4 21 North Ayrshire 31 9 14 10 22 North Lanarkshire 18 16 22 32 12 23 Orkney Islands 25 19 21 11 24 Perth & Kinross 25 Renfrewshire 29 26 Scottish Borders 8 26 27 Shetland Islands 28 South Ayrshire 28 29 South Lanarkshire 6 30 Stirling 31 West Dunbartonshire 32 West Lothian Crown copyright Ordnance Survey. Scottish Natural Heritage 0 25 50 100 Kilometres Local Authority copyright see Appendix 1Figure 2: Map of LLDs across Scotland 21