National Access Forum - 20 September 2023

Agenda and papers for 61st meeting on 20 September 2023.

Agenda

National Access Forum – 61^st meeting on Wednesday 20^th September 2023, 10:30 – 12:30

Hybrid meeting – In-person at Battleby and Virtual via MS Teams

Welcome, introductions, apologies – Don Milton – Convenor – 10:30 – 10:45
Minutes of previous meetings, action points and matters arising – 10:45 – 11:00 – (unconfirmed minutes from the hybrid meeting held 7th June 2023 attached)

Carried over from 7th June 2023:

AP 56/5: - NatureScot to investigate the legal position on liability for third party promotion of paths. On-going: Feb 2023 update: Bridget Jones confirms NatureScot has prepared a draft brief and will be seeking legal advice, using our legal advisors, with a response anticipated by early spring. May 2023 update: No progress on action point, carry forward - delayed and on hold, hoping to make progress later in the year.

AP 60/1: Members to identify and highlight any areas of woodland planning process where there are issues pertaining to access - discharged, no feedback

AP 60/2: NAF members to help in disseminating upland deer management and access messaging to their members/audiences, especially those within the commercial, recreation and land management sectors - Discharged

AP 60/3: ADMG to ask members about the possibility of extending HFTSH to include the hind season, and to encourage increased engagement with HFTSH by its members - on-going

AP 60/4: Members to identify where there are hotspots relating not only to deer management and access, which have issues with national implications and/or relating to commercial operators - no feedback received

AP 60/5: NAFSec to produce a document with answers to NAF/LAF attendee questions, with help from the Convenor - discharged

AP 60/6: Graeme McLean to inform NAF if he comes across any e-MTB issues that may require NAF attention and to update the NAF on progress as necessary - on-going

Access for education - paper - Ali - 11:00 - 11:20
Resources for access update - Helen - 11:20 - 11:30

Comfort Break - 11:30 - 11:40

VMS overview - Bridget - 11:40 - 12:00
Update on responsible mountain biking - Graeme McLean - 12:00 - 12:10
Forthcoming meetings and agenda items – Don Milton – updated work programme attached – 12:10 – 12:20

NAF meeting - TBC (7th/14th Feb 2024) – Battleby
NAF meeting – Wednesday 5th June - 2024 - TBC

Future agenda items

Camping wording - action from VMS
Feedback on the managing access in areas of wildlife sensitivity guidance

A.O.B - 12:20 - 12:30

Helen Todd - SORA LAF Workshop, 8th November

Close 12:30

Access for Educational Activities

Purpose

The purpose of this paper is to seek feedback and clarification from NAF members as to whether there is a growing issue surrounding permissions, administrative requirements and charging for access to sites for educational activities and whether this is impacting on outdoor practitioners using public open spaces for education.

Background

NAF has been approached by the Chief Operating Officer of Learning through Landscapes and co- lead of the National Network for Outdoor Learning (NNOL) noting that they and other outdoor education practitioners are reporting that they are being challenged on their right to access to outdoor spaces for education purposes, particularly those seeking to access urban green spaces. Examples provided include:

Schools/ nurseries being charged a fee to obtain a licence to use parks.
Requests from local authorities for group information that NNOL consider excessive including exact times, dates, adult names, all risk assessments, insurance and more.
Schools/ nursery group, requested by a Local Authority, to not undertake educational activities on a piece of private owned land as they did not have 'written' permission.
Educational requests seemingly being treated similarly to commercial organisation organising a run or bike race.
Some landowners being very directive over what spaces can be used.

Learning through Landscapes and the NNOL feel there is a change in attitude, albeit well-meaning as a way of managing visitor pressure, which is now creeping into something against the spirit of our Access Rights.

What the Legislation and Scottish Outdoor Access Code Says

Land Reform (Scotland) Act 2003 - ‘The Act’

S1 Access rights

(1) Everyone has the statutory rights established by this Part of this Act.

(2) Those rights (in this Part of this Act called “access rights”) are—
(a) the right to be, for any of the purposes set out in subsection (3) below, on land; and
(b) the right to cross land.

(3)The right set out in subsection (2)(a) above may be exercised only—
(a) for recreational purposes;
(b) for the purposes of carrying on a relevant educational activity; or
(c) for the purposes of carrying on, commercially or for profit, an activity which the person exercising the right could carry on otherwise than commercially or for profit.

(5) A “relevant educational activity” is, for the purposes of subsection (3) above, an activity which is carried on by a person for the purposes of—
(a) furthering the person’s understanding of natural or cultural heritage; or
(b) enabling or assisting other persons to further their understanding of natural or cultural heritage.

Scottish Outdoor Access Code - ‘The Code’

Paragraph 2.8:
Access rights extend to any educational activities concerned with furthering a person’s understanding of the natural or cultural heritage. For example, access rights would extend to the students, leader and any support staff on a visit to the outdoors to learn about wildlife or landscapes or geological features. People carrying out field surveys of the natural or cultural heritage, such as of birds or plants, as a recreational activity or for educational purposes, are covered by access rights (see paragraph 3.64).

Paragraph 3.57:
…As a general rule, the larger a group or event, or the more regularly use is made of a particular place, the greater is the risk of causing unreasonable interference with the rights and needs of land managers and other people, and of causing impacts on the environment. Therefore, if you are responsible for organising a group or an event, or for running a recreational or educational business requiring access to the outdoors, you need to show extra care.

Paragraph 3.62:
If you instruct, guide or lead people in recreational or educational activities (see paragraphs 2.8 to 2.9), either commercially or for profit, take extra care to minimise any adverse effects that you might have on the interests of other businesses, such as a farm or an estate, and on the environment. Doing a full risk assessment of your activities will provide a good starting point and you can show extra care by:

planning your activities in ways that minimise possible impacts on land management and the interests of others should you wish to use a particular place regularly or if your visit might cause any particular concerns about safety or the environment;
talking to the land managers who are responsible for places that you use regularly or intensively; and by
obtaining the permission of the relevant land manager(s) if you wish to use a facility or service provided for another business by the land manager (such as an equestrian facility);
if you are running a business that utilises access rights consider assisting with care of the resource used by your business.

SOAC: Public Parks and Other Managed Open Spaces

Responsible Behaviour by the Public: Access rights can be exercised in most urban parks, country parks and other managed open spaces. These parks are normally provided for recreational and educational purposes, but may also be managed to help safeguard the environment. Where the levels or types of use are such that peoples’ safety or the environment is at risk, local guidance or management measures, such as management rules, regulations or byelaws, might have been introduced. Follow such guidance to help ensure that safety or the environment is not put at risk.

Responsible Behaviour by Land Managers: Promote the exercise of access rights in such places where this would not put safety or the environment at risk. Use measures such as management rules or byelaws as a last resort.

Considerations for NAF

NatureScot has already requested feedback from Scottish Government Outdoor Learning Group (SGOLG) and the SOAN Knowledge Hub to ascertain the scale of the issues (local or national) and whether this is a growing issue as identified by Learning through Landscapes; and also requests feedback and views from NAF members.
Clarification may be required over the specific circumstances as there may be other factors involved such as management rules, byelaws or other elements of an activity which may require permission e.g. setting up marquees, parking, access to toilets.
Subject to the above, agreement from NAF members on the next steps –for example the development of guidance (of information in another format e.g. a briefing)by NatureScot, with input from NAF members, to promote to relevant audiences as a reminder that access rights extend to access for education activities

NatureScot
2023

Confirmed minutes - 61st Meeting

Hybrid meeting: 20^th September 2023

Present:

-	Representatives	Organisation
1	Don Milton	Convenor - National Access Forum (NAF)
2	Ali Tait	Secretary - National Access Forum (NAF)
3	Frank Spencer-Nairn	Association of Deer Management Groups (ADMG)
4	Helene Mauchlen	British Horse Society Scotland (BHSS)
5	Colin Mair	National Farmers’ Union of Scotland (NFUS)
6	Stephen Jenkinson	Kennel Club / Scottish Kennel Club (KC/SKC)
7	Davie Black	Mountaineering Scotland (MS)
8	Simon Ovenden	Scottish Land and Estates (SLE)
9	Alan Macpherson	NatureScot (NS)
10	Graeme McLean	Scottish Cycling (SC)
11	Sue Hilder	Loch Lomond and the Trossachs National Park Authority (LLTNPA)
12	Paul Timms	Cycling UK (Scotland)
13	Helen Todd	Ramblers Scotland (RS)
14	Malcolm Duce	Scottish Government (SG)
15	Eleisha Fahy	ScotWays (SW)
16	Bridget Jones	NatureScot (NS)
17	Eileen Stuart	NatureScot (NS)
18	Rona Gibb	Paths for All (PfA)
19	Lois Bayne-Jardine	Historic Houses Scotland (HHS)
20	Carol Ritchie	Wild Scotland (WS)

Item 1. Welcome, Introductions, Apologies

The Convenor welcomed and introduced the attendees of the meeting, both virtual and in person. He particularly welcomed Colin Mair, who was attending in person for the first time.

Apologies: Hugh McNish (Scottish Forestry), Nick Cole (LAFs representative), Constable Graeme Scott (PoliceScotland), Peter Clark (British Association of Shooting and Conservation), April Armstrong (Confor), Roy Barlow (Woodland Trust Scotland)

Convenor’s Report

Don gave the following statement, “In July, it was my sad duty to report to you the death of Jonathan Kitching from the cancer which he had been fighting and I must now put on record the NAF’s sadness at his loss and recognition of all that he did for access. As most of you know, he was one of the earliest members of the NAF following passing of the access legislation and his dedication and joy to be supporting the NAF continued to the end. He contributed most positively from his long and comprehensive experience, his enthusiasm and commitment. His presence and engagement will be sorely missed and he will be positively remembered by NAF members, SAPOE and the wider access community. I hope that he understood the esteem in which he was held and that it was some solace in his final days. Many members contributed their thoughts and the feelings of loss and this has been passed to his family. It is understood that the issue of a replacement for Jonathan was raised at a recent SAPOE meeting.”

As Hugh McNish was unable to attend, Don gave an update on his behalf, “the next edition of the UKFS is being finalised by the four UK governments following consideration of feedback from the second stakeholder consultation. We are grateful to the 57 individuals and organisations who submitted a consultation response from across the UK. All responses have been reviewed by an independent consultant and their report along with the responses, where respondents gave permission, are published on the Citizen Space website. Further updates will be provided in due course. With regards to refresher access training for woodland officers, the first round of refresher training for the new intake of woodland officers will start in November 2023. This will be delivered as part of the woodland creation module of the woodland officer training. Following on from this the refresher training will be rolled out to the remaining staff by April 2024.”

AP 61/1: NAFSec to make link to UKFS consultation responses available to members.

Item 2. Minutes of Previous Meetings, Action Points and Matters Arising

Bridget explained that she will be taking the NAF into her remit within NatureScot. Alan will be stepping back somewhat, though he will still be involved with the NAF going forward. Don thanked Alan for his work with the NAF over the years, and looks forward to having Bridget Jones come aboard. Bridget highlighted that her involvement with the NAF will allow for more cohesion between forum work and wider visitor management work.

Members discussed whether it would be suitable to move the date of the February 2024 meeting in order for Francesca Osowska (NatureScot CEO) to attend. It was agreed that the date would be moved from the 7^th Feb 2024 to the 14^th Feb 2024. Don noted that he had received a suggestion that instead of Francesca coming to a full NAF meeting, she could attend a smaller gathering on site somewhere. However, it was agreed that her attendance at a full meeting was preferable.
Following on from the June meeting, there is still a vacancy in the NAF for a local authorities representative. The role involves acting as a link between the NAF and local authority staff working on access and recreation, ensuring NAF’s work and advice is fully informed by local authority views and local experience. The representative will be a contact point for their sector, seeking input and providing feedback to colleagues. The local authorities rep would attend NAF meetings, and participate in relevant short term working groups/sub-groups set up by NAF to consider specific issues. The NAF meets three times a year and there is also an annual meeting between the national access forum and local access forums. Meetings are currently held in a hybrid (face to face/virtual) format, with other business progressed through correspondence with support from the NAF Secretary. The role is complemented by a local access forums representative on the Forum, currently filled by the Chair of the Perth & Kinross LAF.

As yet, there is no sub-group set up to facilitate the 2024 NAF/LAF meeting. Nick Cole was nominated to the lead the sub-group, as he is the local access forums representative for the NAF.

AP 61/2: Members to self-nominate to be part of the sub-group by end of October, contact NAFSec.

Scottish Athletics made contact with the NAF a few days before the forum meeting, highlighting an issue around organised events and access, specifically in the Pentlands. This could be a potential agenda item for the February meeting of the NAF.

SLE gave an update on their involvement with the access issue regarding the Pentland Land Managers Association and race organisers. In SLE’s view, the issue is partially down to transparency from PLMA and going forward a softening of language may be beneficial to improve communications between the parties. This was echoed by Ramblers, Mountaineering Scotland and NatureScot. It was also highlighted that communication around impact could be improved; however, SLE noted that in the view of the PLMA, incorrect information fed to the media by event organisers did not accurately reflect the positive discussions that had taken place with Scottish Athletics which enabled events to take place. SLE reported that Jessica Morgado (City of Edinburgh Council) is also in discussion with the involved parties. Simon highlighted outdoor events requirements guidance that is available from PLMA; Helen highlighted FLS guidance on permissions and permits.

Concern was expressed that this is precedent setting, and it was highlighted that case by case discussions are needed. Eileen highlighted that a Quality and Impact assessment has been used by NatureScot recently, this could be something to take forward for similar issues to increase transparency. Paul Timms also highlighted that there is potential for third-party liability/damage insurance to be used to help provide for remediation to damaged sensitive sites.

AP 61/3: Members to identify areas with issues, similar to that in the Pentlands with regard to organised events, in their regions/memberships to determine if this is a local or national issue. Provide details by correspondence to NAFSec ([email protected]).

The minutes from the last meeting were largely accepted. ScotWays raised that they would like it noted that they dissent from the position of the NAF that the terminology issue relating to “access-takers” should not be taken any further by the NAF.

AP 61/4: NAFSec to add clarifying statement of ScotWays position to minutes of 60^th NAF meeting.

Actions from previous meeting:

AP 56/5: - NatureScot to investigate the legal position on liability for third party promotion of paths. On-going: Feb 2023 update: Bridget Jones confirms NatureScot has prepared a draft brief and will be seeking legal advice, using our legal advisors, with a response anticipated by early spring. May 2023 update: No progress on action point, carry forward - delayed and on hold

AP 60/1: Members to identify and highlight any areas of woodland planning process where there are issues pertaining to access - discharged

AP 60/2: NAF members to help in disseminating upland deer management and access messaging to their members/audiences, especially those within the commercial, recreation and land management sectors - discharged

AP 60/3: ADMG to ask members about the possibility of extending HFTSH to include the hind season, and to encourage increased engagement with HFTSH by its members - discharged

AP 60/4: Members to identify where there are hotspots relating not only to deer management and access, which have issues with national implications and/or relating to commercial operators - discharged

AP 60/5: NAFSec to produce a document with answers to NAF/LAF attendee questions, with help from the Convenor - discharged

AP 60/6: Graeme McLean to inform NAF if he comes across any e-MTB issues that may require NAF attention and to update the NAF on progress as necessary – discharged now standing action

Don has updated the NAF work plan.

Tom Turnbull gave an update on the proposed removal of the closed season for male deer (all species) in Scotland. Tom highlighted the need to educate the public that there are still busier periods, “key periods” where deer managers will be working to achieve their cull targets.

Item 3. Access for Education

Ali Tait presented a paper for the NAF, the purpose of which is to seek feedback from NAF members as to whether there is a growing issue surrounding permissions, administrative requirements and charging for access to sites for educational activities, and whether this is impacting on outdoor practitioners.

NAF has been approached by the Chief Operating Officer of Learning through Landscapes and co- lead of the National Network for Outdoor Learning (NNOL) noting that they and other outdoor education practitioners are reporting being challenged on their right to access to outdoor spaces for education purposes, particularly those seeking to access urban green spaces. Examples provided include:

Schools/ nurseries being charged a fee to obtain a licence to use parks
Requests from local authorities for group information that NNOL consider excessive including exact times, dates, adult names, all risk assessments, insurance and more.
Schools/ nursery group, requested by a Local Authority, to not undertake educational activities on a piece of private owned land as they did not have 'written' permission.
Educational requests seemingly being treated similarly to commercial organisation organising a run or bike race.
Some landowners being very directive over what spaces can be used.

Learning through Landscapes and the NNOL feel there is a change in attitude, albeit well-meaning as a way of managing visitor pressure, which is now creeping into something against the spirit of our Access Rights. NS has sought feedback on this issue from SGOLG (Scottish Government Outdoor Learning Group) and received feedback from FLS, who are aware of this issue.

Considerations for NAF:

NatureScot has already requested feedback from SGOLG and the SOAN Knowledge Hub to ascertain the scale of the issues (local or national) and whether this is a growing issue as identified by Learning through Landscapes; NS also requests feedback and views from NAF members.
Clarification may be required over the specific circumstances as there may be other factors involved such as management rules, byelaws or other elements of an activity which may require permission e.g. setting up marquees, parking, access to toilets.
Subject to the above, agreement from NAF members on the next steps –for example the development of guidance (of information in another format e.g. a briefing)by NatureScot, with input from NAF members, to promote to relevant audiences as a reminder that access rights extend to access for education activities.

The Convenor noted that this appears not to be a localised issue, rather it may be a national issue. It was also noted that there is cross-over with the previously discussed issue of access for organised events and that proportionality is required for both.

Stephen commented that there can be confusion caused by the way in which charges are presented e.g. not made clear if a charge is for associated infrastructure like toilets rather than for access itself. Sue commented that there may be a correlation between areas with no dedicated Access Officer and groups experiencing difficulty with access for education. Bridget noted that capacity management of sites is likely a factor, with some sites experiencing high usage.

Carol expressed that she isn’t aware of a similar issue affecting the commercial sector, highlighting that risk assessments and insurance can be examples of good practice, and access may therefore not be necessarily limited. Again, she noted that this issue is very context specific.

AP 61/5: Members to identify more context about where/why issues regarding access for education arise. Provide details by correspondence to NAFSec ([email protected]).

This issue could potentially be combined with the access for organised events issue, and included as a future agenda item.

Item 4. Resources for Access

Helen updated the forum on the progress of the Resources for Access sub-group. The sub-group has not been able to meet since May due to capacity. The briefing for MSPs - Twenty Years of Scottish Access Rights was sent out to MSPs and ministers at the end of June. No comments were received, but Helen noted that it is a useful resource.

The group is due to meet again in October to discuss whether a NAF response is required with regards to the Land Reform bill and the Agriculture bill. The Convenor asked the sub-group to draft responses if/when necessary.

Helen noted that there has been less capacity from NatureScot to take forward actions from the sub-groups. This was acknowledged and Alan highlighted that it is very helpful when NAF members self-nominate for sub/working groups and to take forward actions.

Rona Gibb reported that she has been in touch with the CabSec’s office about a potential meeting of some NAF members with the Cab Sec to discuss and highlight access issues including resourcing, rangers, etc. At time of NAF meeting, a holding reply had been received.

Item 5. Visitor Management

Bridget gave an update on the visitor management work being progressed in partnership by several organisations. The Visitor Management Strategy (VMS) Steering group (VisitScotland lead) meets 3/4 times per year and takes a high level view of issues and solutions. The VMS Co-Ordination group (NatureScot lead) has a broad range of representatives and focusses on the action plan and strategic issues from sub-groups. The Co-Ordination group meets monthly and feeds up to the Steering group.

There are two sub-groups: Operational and Education & Marketing. The Operational sub-group (PoliceScotland lead) also meets monthly and has a wide range of members. It is a forum to share good practice, issues and advice. When common issues are identified they can be taken to the Co-Ordination group. The Education & Marketing sub-group (VisitScotland lead) is focussed on comms and messaging.

Finally, there are three working groups, which are task focussed: Camping & Campervans (VisitScotland lead), Digital (Interface lead) and Transport (LLTNPA lead) (with a further sub-group to focus on car-parking).

The Visitor Management Strategic Framework is a 3 year VisitScotland framework, with a review due 2023/24. The VMS Action Plan is led by NatureScot. Both can be found on the Visit Scotland website.

There are areas of shared interest between the VMS work and the NAF; VMS work extends wider than NAF to include messaging beyond SOAC to inform and educate current and future visitors. VMS work includes:

Behaviour campaigns - fires/BBQs; camping/wildlife/generic public focus
Review of fire related messaging and Code advice - operational focus
Improvement of tent based camping messages - operational focus
Wildlife disturbance guidance - 1 year check in
SOAC educational/outdoor activity providers engagement

Other areas of visitor management activity include the Better Places Fund 4 (BPF4) and gathering evidence. BPF4 has funded seasonal rangers in hotspot locations until the end of September 2024, with a budget of £900k. Rangers engage with visitors, promote SOAC and tackle issues relating to visitor management.

Evidence gathered includes a RAG (red-amber-green) rating of organisations ability to manage sites throughout the season, heat charts and core metrics. There are seven core metrics: tents, cars, people engagements (positive and negative), fires, litter, escalated incidents, motorhomes/campervans. The aim of evidence gathering is to provide a snapshot of what is happening on the ground, rather than to be comprehensive and definitive.

Bridget explained that the upcoming tasks for the visitor management groups will be an end of season review, making the case for these activities to continue to be funded, prepare the VM Action Plan 2024, prepare comms plans for 2024, update fires guidance/advice and continue to share good practice and experiences.

AP 61/6: NAFSec to distribute VMS update presentation to members.

Don asked whether it would be worth potentially updating the 2016 guidance written by the NAF: Lighting fires and access rights under the Land Reform (Scotland) Act 2003. The VMS Co-Ordination group is already looking into potential updated wording of fires guidance and will be discussed at the next meeting (21^st September).

AP 61/7: NAFSec to give feedback on fires from Co-Ordination group after next meeting.

Several NAF members highlighted the success of the Better Places Fund and expressed disappointment at the budget reduction compared to the first round of BPF. It was also noted that the announcement of funding happens late, so it is very difficult for organisations to get rangers in situ before June, which means many hotspot sites have no coverage for busy periods like Easter or May bank holidays. It was also raised that the funding is annual, despite the Scottish outdoors industry being large.

Concern was expressed by Ramblers that if visitor management is not funded, visitor experience will decline with Scotland being seen as less desirable as a destination.

It was noted that the Resources for Access sub-group could look at lobbying local authorities. Don noted the recent parliamentary question from MSP Colin Smyth: To ask the Scottish Government what action it is taking to maintain access rights for walkers secured under the Land Reform (Scotland) Act 2003 and the establishment of core path networks.

It was suggested that concerns about funding would be best voiced at the potential face to face meeting with the CabSec, followed up by a letter from the NAF. If a meeting does not happen then a letter will be sent out.

Carol asked whether materials are available for commercial operators to use to promote SOAC/responsible access from NatureScot. Bridget reported that this has commenced with schools and outdoor education practitioners, but is yet to begin with commercial operators. Carol also asked whether there is any mandatory training required for those, e.g. rangers, funded by BPF. There are three online sessions that are mandatory for BPF projects and there is also SCRA training available online.

Item 7. Responsible Mounting Biking Update

Graeme McLean updated the group that he has not had the capacity over the summer to produce guidance for e-MTBs. However, it is still the intention to produce this guidance in time for 2024. Graeme updated the group on the launch of the new strategy for mountain biking 2023-25.

There has also been funding secured for a UK trails manager to promote the responsible use of trails in the UK. There is also a new video on responsible MTB which has been launched and received good feedback.

Item 8. Forthcoming Meetings and Potential Agenda Items

NAF meeting: Wednesday 14^th February 2024 - Battleby and MS Teams
NAF meeting: 5^th June 2024 - TBC
Agenda item: camping/fires definitions/guidance
Agenda item: charging for access
Agenda item: review of guidance for managing public access in areas of wildlife sensitivity

Item 9. A.O.B

Helen raised three points:
- SORA workshop, 8^th November, open to any LAF members. More info to be sent out by NAFSec.
- Ramblers has put out a press release with regards to core paths in deprived areas, will be sent to NAFSec for dissemination amongst members: Ramblers Scotland research reveals shocking inequality in the outdoors.
- Highlighted the consultation on delivery of the Scottish Biodiversity Strategy which also includes proposed new national parks legislation. This covers issues relevant to access.

Colin raised an issue with windfarms and access in Ayrshire, wonders if this issue is potentially a national one rather than limited to just one site/company. Helene noted that BHS feels strongly that access should be a statutory part of the planning process and they would like to see this brought forward as a NAF issue. Don highlighted that this has been raised before by Nick Cole with a proposal that LAFs should be statutory consultees, but that many LAFs would not have the capacity to deal with this.

ScotWays would like to widen this to energy production more generally e.g. battery farms. Paul suggested that there are two strands to this issue: access rights and facilitating further access. Don noted that this issue could be included in the agenda for the meeting with the CabSec. Malcolm highlighted links with NPF4. Good practice during windfarm construction guidance, produced by the NAF in 2015 (and further updated in 2019), was also highlighted as a useful resource that could potentially be re-visited by the NAF. It is joint industry guidance including recommendations from a health and safety specialist.

Summary Action Points