Month: June 2016

June 30, 2016 Nick Kempe No comments exist

I am delighted that both Keith Bryers from HIE – see previous post – has confirmed that at least some of the destruction undertaken by Natural Retreats required planning permission and that they now expect two retrospective planning applications to be made to the Cairngorm National Park Authority, one for the bullodzed track and the other for the destruction of the bank below the shieling ski tow.


The need for planning permission has also been confirmed by the Cairngorms National Park Authority in an email to Ron Greer, although they are less specific about which works were undertaken outwith the scope of the planning permission granted.


Dear Mr Greer
Thank you for your email and photographs of various construction works in the vicinity of the Sheiling Tow, Coire Cas, Cairngorm. Your photographs show various stages of development between late 2015 and earlier this year.
The CNPA issued planning permission for the replacement of the Shieling Tow and works began in late 2015 and continued after the end of the skiing season in 2016.  The reinstatement and restoration works for the site are ongoing with phases of reseeding of vegetation currently underway and planned for the future.  The CNPA has been monitoring the development since last year and will continue to do so.  The CNPA has also been in discussion with Natural Retreats since last year over the implementation of the planning permission and the restoration of the site. Where works have taken place that the CNPA considers would require a different planning permission in order to be authorised, we expect retrospective planning permission to be applied for.  
Kind regards
Gavin Miles
Head of Planning
Cairngorms National Park Authority

While the email is not specific, there is evidence that more than two unauthorised works have been undertaken by Natural Retreats at Cairngorm.   If CNPA are now looking at all the works undertaken by Natural Retreats that should have had planning permission that would be a positive thing.   Its another indication that the situation is worse than HIE has so far admitted.  I believe this reinforces the need  (see for the public authorities at Cairngorm to ensure an independent report is commissioned into the scope of the damage caused by Natural Retreats and the works undertaken outwith planning permission.


In terms of any retrospective applications (I have checked again today and so far there is nothing on the CNPA website about this), I believe HIE in their email have provided NO case for approving the creation of a new track at the Shieling Ski Tow.   Access tracks to installations such as ski lifts would normally be discussed and agreed as part of the specification for their development prior to planning permission being applied for.  The fact that it wasn’t suggests there was no need for it – either that, or Natural Retreats are so incompetent that their lease should be terminated.   The most likely reason I can see for the creation of the track is that so much vegetation had been destroyed by the contractors – contrary to the requirements of the planning permission that it be stored and re-used – that they did not have enough left to resurface the ski slope.  A shortfall in vegetation would also explain the holes which were excavated by digger from outwith the area granted planning permission.   So, as to alternative to finding yet more vegetation, what better solution than a new bulldozed track (which of course has an unvegetated surface), hope no-one notices but, if they do, then invent a reason to justify it.    It seems very strange, if this track was justified and its omission a genuine mistak, that Natural Retreats did not submit a planning application months ago.   The CNPA should therefore I believe reject any retrospective planning application and use its enforcement powers to ensure the area is properly restored.  If CNPA does not do this,  a precedent will have been set the for whole of Cairngorm and other ski areas within the National Park.  Indeed, we could end up with bulldozed tracks alongside every ski lift in Scotland.


HIE also claims in the email that the bank below the ski tow was destroyed because the area around the lower shieling lift needed to be raised.  Again, any competent surveyor/designer should have identified this as a requirement before an application for planning permission was submitted.   Had this been done,  there would have been no need to bury the “excess” “spoil” which appears to have come from the shieling tow slope (and is incidentally  another example of the destruction that does not appear to have been covered by the planning application which was approved).

Ab Sheiling Pit Back-Filled
Photo credit Alan Brattey

Instead the spoil could have been re-used to raise the ground for the lift.

The evidence suggests that the bank was destroyed simply because it was the easy option.   Cairngorm has been treated like a derelict building site in central Scotland with the whole landscape bulldozed without any regard to its value.   The question is do CNPA and HIE believe this is acceptable and if not what are they going to do to remedy the damage and make sure such destruction will never ever be allowed in future?


It may now however be impossible for CNPA to require the bank to be restored to how it was originally – too much material has been removed.    This is another good reason why the CNPA and other public authorities should  require Natural Retreats to pay for an independent report. Such a report could, as well as surveying the damage,  look at the options for restoration, including the bank below the shieling ski tow.  There is an obvious opportunity here to require planting of montane scrub species – by someone qualified to do so as part of a wider vision for the Cairngorm ski area   Indeed, since there isn’t any “spare” vegetation to restore the track, rather than re-seeding it with grasses, this seems a good opportunity to plant more montane scrub species along the fenceline.  In other words the CNPA and other public authorities could use the terrible failings at Cairngorms as an opportunity to start realising a new vision.





June 30, 2016 Nick Kempe 2 comments

Keith Bryers, Head of Property and Infrastructure at Highlands and Island Enterprise, has responded to my post on why the destruction at Cairngorm happened   I welcome the fact Mr Bryers is prepared to explain HIE’s position which is as follows:

“This project was funded by HIE as part of a package of works to enhance the skiing infrastructure following competitive tender which led to the award of a lease to Cairngorm Mountain Ltd (CML) in 2014. The works contracts for the Shieling ski-tow replacement were awarded and managed by the ski area operator, CML, who obtained Planning Permission in 2014.

As part of that planning approval to replace the Shieling ski-tow with a new tow, ground works were undertaken to remodel embankments created by the bulldozing of ski pistes in the 1960s. The work has created a ground profile more suited to the new tow and modern ski operations and, once reinstatement is complete, this will result in a more natural-looking profile and appearance.

Rather than simply seed the former lift track, which was used to move materials and components of the new tow, avoiding further disturbance due to continual tracking, a permanent maintenance route is being formalised on the same alignment. This was kept within the 30m x 300m agreed work site of the 2014 planning approval. It makes operational sense that CML wish to retain this track as it will allow routine maintenance to the new tow and others nearby. It will also allow movement of snow cannons to take place without having to drive across vegetation in these areas and will minimise ground disturbance to the surrounding ski pistes in the future. The access track verges are currently being revegetated, reducing the width, installing cross drains and creating a central vegetated strip.

Approval has previously been obtained by CML from SEPA to create bridged culverts at the Allt a’Choire Chais watercourse adjacent to the base of the ski-tow. This is part of on-going environmental improvement works and, when completed, combined with the new ski-tow, will increase safety, drainage, and provide better contours for skiers as a replacement for the previous timber bridge crossings.

The area of embankment that was re-profiled is along the Lower Loop path/ track which also originated in the 1960s to create a track and ski piste. This area is used as the primary descent route for skiers to Base level. Late in the process of installing the new lift it became apparent that the area around the base of the lift needed to be raised and the material from the bank was used to create the required ground levels. This has provided a wider, safer piste whilst removing the snow-making earthworks and steel pipes from the 1960s. CNPA have advised CML that a retrospective planning application is required to document the levels and ground works associated with the regrading of part of the bank along the Lower Loop Path and this application has been submitted by CML .

The project remains a ‘work-in-progress’ and is not complete; CML and their contractors are well experienced in ground restoration work. This experience is being applied to this project and adjacent areas of ground disturbed during underground cable renewal and ski-tow remediation works. Restoration at this altitude and with the prevailing ground conditions takes at least 2 to 3 years to have full effect but we believe the success of the restoration works undertaken during the funicular project demonstrates it will be successful.

The Lease provides that CML are responsible for maintenance, including that of the ground. HIE is satisfied that the measures currently being taken by CML will address the issues raised in your article.”

June 29, 2016 Nick Kempe 2 comments

I was never in favour of the funicular railway, a white elephant that has drained resources about the ski area,  but  great care was taken in its construction as is shown by the photo below.

AB 20160619_155243 (3) (1)
Funicular construction –  Photo credit George Paton

The area where earth works could take place was clearly demarcated and many of the bases for the stanchions were dug out by hand to avoid damage to vegetation from heavy machinery.  A similar provision was included in Para 1.3 of the Method Statement for the Shieling ski tow 2014_0251_DET-METHOD_STATEMENT-100105315 “site cordon for access will be established to control vehicle movement and prevent damage to vegetation.”    This however does not seem to have happened as evidenced by the photos below, taken below by two separate witnesses,  which shows there was no demarcation of the site granted planning permission.RG 100_0042

Photo Credit Ron Greer


GP No Pretection Measures (1)
No evidence of site boundaries Photo Credit George Paton

The result was that the diggers used to regrade the former bulldozed track that formed the old ski tow crossed out of the area granted planning permission.   One of the things they did was cut back the bank below the bottom of the piste.  This was not related to the planning permission at all – its seems that Natural Retreats just took advantage of the diggers being present to do a bit of “piste improvement” below the area of the rope tow.   The diggers also however dug out  vegetation from outwith the area granted planning permission in order to “restore” the re-alignment of the slope which had been granted planning permission.   Clearly, the requirement in the original planning permission that all the vegetation removed from the piste was stored and then re-used to cover it again had not been observed otherwise there would have been no need to do this.

GP Ripping out vegetation (2)
Digger operating outwith area granted planning permission – the lack of boundary markings made it easy for them to do this
GP Ripped away Vegetation
Hole created by ripping out vegetation outwith area granted planning permission Photo Credit George Paton









One wonders if the operators of the diggers were even informed by Natural Retreats about the site boundary or what work had been granted planning permission.   I suspect not.   The people who operate these machines are often highly skilled but they will only do what they are told to do (and are paid for).  In the absence of any site boundary markers, they can hardly be held responsible for what happened.  Instead responsibility lies with Natural Retreats, who were responsible for appointing and managing the contractors, HIE who funded the work  and the CNPA as the planning authority.


These photos demonstrate the importance of the people who draw up and agree specifications for works in our mountain areas monitoring them to see they are enforced – without this the specifications are not worth the paper they are written on.   The monitoring arrangements for the Sheiling Ski tow work were  clearly grossly inadequate.   While it appears the CNPA did eventually visit  when alerted to the breaches in planning permission and after the damage was done we don’t know if HIE visited at all.


While I know enough about Cairngorm to know that standards have gone up and down over the years – the lift supports for the now defunct Coire na Ciste chairlift were helicoptered in to restrict damage to ground vegetation – what we now appear to be witnessing is an unprecedented drop in standards so that almost anything now appears acceptable.  Responsibility for allowing this to happen lies with our public authorities.  My suspicion is that CNPA took their eye off the ball because of the lack of public objections to the planning application for the replacement ski tow.   If lots of people had objected to that application they would have appreciated they were under public scrutiny and I suspect would have devoted the resources necessary to ensure this development was carried out as planned.  Meantime, HIE, because of the parlous finances of the ski area, had no incentive to do anything which might increase costs.  The consequence of these failures has been the disgraceful destruction that has taken place at and around the Shieling ski tow.


The fall in standards in Cairngorm goes far wider than the shieling planning applications as previous posts on parkswatch have demonstrated.   As further evidence,  parkswatch was sent some photos taken a couple of weeks ago from around the Fiacaill Poma loading area. The background to these photos  is that the wooden loading platform at the Poma was very rotten and was removed last Autumn. A new and smaller wooden loading platform was constructed this Spring along with a new Lifties Hut.  This did not require planning permission and responsibility for the standards of the work therefore lies with Natural Retreats and HIE as the manager of their lease.


Why not clear and tidy up as you go?

ABFiacaill CIMG7898
Photo Credit Alan Brattey
Photo Credit Alan Brattey








If leaving rubbish is just carelessness, allowing old pieces of timber to remain embedded in the peat is clear proof of negligenceABFiacaillCIMG7900

Detritus from the old Fiacaill poma embedded in peat near the start of the northern corries path – Photo Credit Alan Brattey


Natural Retreats has had months to clear this up.  They clearly cannot be trusted and HIE as the grantor of the lease should be supervising everything they do.  HIE have now acknowledged my request for a copy of their lease with Natural Retreats under FOI.   It will be interesting to see if its released and if so whether it contains any provision for financial penalties for failures in management  and indeed if negligent care of the ski area by Natural Retreats ultimately gives HIE the right to terminate their contract.


What needs to happen now?

At present the Cairngorms National Park Authority only has restricted planning powers – a power to call in applications made to the Local Authorities that make up the Cairngorms area.  They have recently been lobbying to have all the planning powers that still lie with local authorities transferred to them.   On the evidence of Cairngorm they have a lot to do to prove they are fit to assume these functions.   The destruction caused by the Sheiling tow provides quite a contrast to the way the funicular was constructed prior to the creation of the National Park.   Since then standards should have gone up, not down.   I would suggest any decision on the transfer of planning powers should be put on hold by Scottish Ministers until the CNPA shows it is capable of using its enforcement powers to restore the destruction that has taken place at Cairngorm and show that it can do at least as well as Highland Council once did.


HIE as owner of the area, funder of this work and the body responsible for the lease with Natural Retreats needs to start taking pro-active steps to address the destruction and prevent this happening in future.  This should include a review of the lease with Natural Retreats.  My own view is if they fail to do this they will have demonstrated themselves as being unfit to continue their custodianship of the ski area.


The public authorities involved in the ski area (CNPA, HIE, SNH, SEPA) need to ensure an independent ecological report is commissioned (it can be paid for by Natural Retreats but they should have no part in managing whoever was appointed) to look at the damage that has been done at Cairngorm and how it might be restored.


Linked to this Scottish Ministers and the CNPA should signal that its time to look at a new vision for the ski area get all stakeholders together to produce this and a practical plan for how it could be realised.



June 27, 2016 Nick Kempe 1 comment

On Friday I received a response (EIR 2016-018 Response) to the questions I had raised about the proposed north Loch Venachar campsite.  This was approved in the Five Lochs Management Plan of 2012 but the Loch Lomond and Trossachs National Park had failed to deliver it as planned in 2013-14.  (For  background see    I had asked Gordon Watson, the Chief Executive, on 26th May why the LLTNPA had changed its plans for this site, as evidenced by the work that has been undertaken there, when on 25th May 2016 the LLTNPA had again claimed ( EIR 2016-017):


“No decision has been taken about the outstanding proposed campsites in the Five Lochs Management Plan. In FOI Review Ref 2016/026, dated 2nd July 2015, we explained that “once a decision is received from Scottish Ministers – “consideration will be given as to which developments we will progress.” The Park Authority is currently working on camping proposals for all of the management zones in the National Park.

Accordingly, I have to advise you under Section 10(4)(a) of the Regulations, that the Park Authority holds no relevant information on this subject.”


The latest response appears to demonstrate that neither of the claims made in the LLTNPA  letter of 25th May were true.  The second paragraph is clearly NOT true because the Park has now referred me to the written information it holds in the form of a planning application for the site which dates back to 2014!
The planning reference is 2014/0264/DET.   So, it did hold “relevant information” and I find it very difficult to believe that it holds no other written information about the decision to submit this application to itself as Planning Authority.


EIR 2016-018 now at last admits admits that the original plans for the north Loch Venachar site have been superseded: “As stated in FOI response 2015/026, the Park Authority has been reviewing approaches to camping management and provision in the 5 Lochs areas as part of the Your Park project. The original proposals…………have been superseded”.  The LLTNPA has used exactly the same wording to answer all the specific changes I had identified from my site visit and included in my letter to Mr Watson, namely the change in the number of parking bays, the removal of dedicated bays for motorhomes, whether a cesspit had been installed under the carpark for a toilet block, the original woodstore for fires and recycling facilities.  As worded this suggests that the plans have been superseded recently but its very hard to see how that can be the case because a planning application that basically omitted all these features from the site drawing was made back in October 2014!  This strongly suggests that the Park’s claim last month and in previous letters that no decisions had been taken cannot be true either!


Original plan with toilet block and camping area

A plan was actually submitted for this in 2012 but we now know from the planning portal was withdrawn in September 2014 – why would it be withdrawn if as the Park subsequently claimed no decision had been taken?

Loch Venachar North Plan






Extract from revised Plan 2014 2014_0264_DET-NMV_proposed_layout-100252452.  The revised plan had no provision for toilets or a cesspit as in the original plan..  Note how the woodland to the right of the site where the campsite was to be situated is now described as “ancient woodland” – not a statutory designation but an excuse the Park  later used to justify its camping byelaws.

north loch venachar plan 2014

The application was subsequently revised  further before the final version 2014_0264_DET-Proposed_Layout-100254713 Final 2016.   The evidence suggests that whoever authorised the submission of this planning application effectively precluded the development of any campsite on this site.  This is  because without a cesspit being installed under the carpark, the costs of installing the toilets necessary for a campsite at a later date would have been prohibitive.  Note this is not just a failure by the Park to provide camping places but also a failure to provide toilets where they are needed.


The truth about the Loch Venachar North campsite proposal

The truth was stated way back in December 2014 when it was recorded in a minute that Bridget Jones had told the Five Lochs Visitor Management Group that it had been decided not to go ahead with the campsite on north Loch Venachar (Appendix D see para 6.7).  The planning application which had been submitted prior to that meeting was entirely consistent with that decision.  However, the Park did not want to admit this.  Why?  Well, this all took place in the middle of the Your Park consultation when the LLTNPA was consulting people about campsite development in the Park.  To admit it had already decided to abandon the development of campsites it had previously agreed would have destroyed its credibility.  What’s more it would have shown the Your Park consultation on new camping places to be an absolute farce with the Park having already taken all important decisions in secret.   So, while the LLTNPA admitted it was  looking at other options back in July 2015 it continued to repeat that it had taken no decision up till last month and during the whole of this period made no reference to the fact it had made a planning application which basically precluded any development of a campsite.  I don’t believe that is an acceptable way for any public authority to operate.


Now I appreciate that the LLTNPA has referred to representations to Trossachs Community Council in information it previously released under FOI and the original planning application shows that  Trossachs CC was consulted (though not what they said).   However, if Trossachs CC had concerns about the use of this land owned as a campsite and it really was that that caused the re-think in 2014 the LLTNPA should have been open about that.  Indeed it could have indicated in the Your Park consultation that its view was that any camping development plan had to take account of concerns expressed by local communities.  This would have promoted open dialogue and understanding between recreational organisations and local communities but the LLTNPA said nothing.  Again, not an acceptable way for a public authority to operate.


Questions the LLTNPA now needs to answer

  1. Who authorised the withdrawal of the original planning application for the north Loch Venachar site that was submitted in 2012 and withdrawn in September 2014?
  2. Who authorised the submission of a planning application 2014/0264 which clearly precluded the possibility of developing a campsite at North Venachar?
  3. Which members of the Senior Management team and Board knew about this?
  4. Why did the Chief Executive, Gordon Watson, allow his staff to persist with claims that no decision had been taken?
  5. What alternatives have now been identified to the north Loch Venachar site?

What needs to happen?

  1. The LLTNPA needs to start operating  transparently
  2. In terms of the development of campsites, the LLTNPA should be consulting publicly on all proposals instead of taking decisions secretly as at present. That means engagement with both local communities and recreational organisations prior to decisions being taken
  3. The consultation should include engagement about all the campsites that were previously approved as part of the Five Lochs Visitor Management Plan
  4. Authorisation of recommendations for campsites that are opposed by local communities or recreational organisations should be taken at public Board meetings
  5. Scottish Ministers should ensure the LLTNPA Board conduct a review into the decision-making process around the north Loch Venachar site, including the adequacy of governance arrangements (it is not acceptable in my view that decisions can apparently be taken verbally without any paper trail saying who authorised what and why)
June 27, 2016 Nick Kempe 2 comments

The National Trust for Scotland, which owns two important properties in our National Parks, Ben Lomond and Mar Lodge, was in the news again last week because of its latest financial crisis  (Herald “NTS faces death by 1000 cuts “).   The script is wearily familiar: the need to re-organise to make ends meet and cut expenditure; modernise to attract new members and increase visitors to properties; and of course a net loss of jobs.   This is the third time this has happened in the last ten years and each time the NTS claims what they are proposing will solve the issues  as Simon Skinner, their current Chief Executive, did last week


I have my doubts.   When Kate Mavor, the previous Chief Executive, departed in April 2015 after 6 years the Herald carried an interview with her which makes interesting reading 15 months later:


“making the trust pay is exactly what she has done in her six years”

Is it fair to say that the trust was on the brink of ruin? “It was heading that way,” she says. “It was like putting on a huge brake to stop it careering over the edge of the cliff and because we did that, that stopped it happening. It would have gone over the edge.”

So what evidence is there to suggest that another re-organisation is any more likely to solve NTS’ problems than the last one?   I am not sure there is any.   What one can say for certain though is in each previous re-organisation the NTS has lost excellent staff and, inevitably during any re-organisation the whole focus of management is on what jobs they will get in the new structure rather than doing what needs to be done.  You can almost guarantee that this will put back any timetable for the renovation of Derry Lodge by at least two years  but then those who promote re-organisation, a very British disease, never consider the adverse consequences, only the alleged benefits.


The real problem is not being discussed openly but was hinted at by Simon Skinner the new Chief Executive in the Herald:  “Mr Skinner has revealed that despite an overall rise in the popularity of Scotland’s tourist attractions, visits to Trust properties have declined by 250,000 in the past decade as many potential customers view it as “castle-owning elitists””.   Now,  I don’t think Simon Skinner is right that its perceptions of the NTS which is actually the biggest issue, its that people are excluded from NTS.   This is partly because as a result of the financial crash and austerity people simply don’t have enough money in their pockets to visit NTS properties.  To become a single member is £48 and the one-off entry fee to see the “state of the art” Culloden visitor centre is £11 for non-members.  Hence, the crash in visitor numbers over the last ten years.


The cost of joining NTS points to the fundamental issue.  NTS is a private membership organisation which was set up by members of Scotland’s elite to act as custodians for much of Scotland’s heritage. On the one hand the consequence of this has been that much of Scotland’s population has never had access to its cultural heritage (and NTS manages far more than just the former homes of the great and the good).  On the other hand, it has meant that the funding of its countryside properties like Ben Lomond and Mar Lodge, which are open to all, is dependent on NTS’ income from membership and legacies and that is not sufficient to keep NTS going.   With a huge backlog in building funding, there is never enough money to invest in its countryside properties including Ben Lomond and Mar Lodge or those such as Glen Coe which should be part of a National Park.    When a specific crisis happens, like the flooding on Deeside in December which caused something like £100k of damage to paths on the Mar Lodge estate, staff are left to run appeals to raise the necessary funds.


One solution would be for NTS to ask its members to pay more.  The problem though is that doing so would probably prompt many members (like myself) to leave and in the past the very rich in Scotland, while very happy to leave large properties to NTS, have not shown much willingness to contribute to revenue costs.  With the rich now siphoning money off to tax havens as a matter of course I cannot see that changing.   The consequence is that NTS as a membership organisation is in constant crisis.


I believe the solution is that the assets that are held by NTS should be treated as national assets and not those of a private organisation.  There is a citizenship argument for this, people should have a right to be able to access the country’s heritage.   This is recognised with our museums and art galleries where admission is normally free.  There is also a tourism argument.  We know that our museums are a major attraction to visitors and that large entry fees are  a deterrent (unless they are for somewhere like Edinburgh castle). Yet NTS continues to think that if only it makes its built properties attractive enough somehow they will pay.  Meanwhile the Scottish Government is ignoring the potential boost that opening up these properties might give to tourism, particularly in rural areas.   Its time that we started to talk about how NTS could become an open and accessible custodian of Scotland’s assets and what government funding might be needed to do this instead of constant attempts to re-structure to make ends meet.


There is a precedent for this within NTS and that is its countryside properties.   Percy Unna, whose gifts enabled NTS to purchase Glencoe, Kintail, Torridon, Goat Fell and Ben Lawers – all prime areas for National Park status – did so on the basis there should be unrestricted access to the public.   So, on the one hand NTS runs properties that are exclusive, on the other hand property that is open to all.  There has always been some tension though between these two sides of NTS, which has manifested itself in the way it has managed its countryside properties.  An example is Ben Lomond in the Loch Lomond and Trossachs National Park.  On the one hand NTS as an organisation did not protest strongly about the camping bye laws on east Loch Lomond (which extended to cover its property at Rowardennan below Ben Lomond) or about the LLTNPA’s proposed permit system.  Both are totally contrary to the Unna principles that there should be unrestricted public access to its properties.  On the other hand NTS staff two years ago offered the Loch Lomond and Trossachs National Park Authority land at Rowardennan for a campsite (an offer which as far as I am aware the LLTNPA has done nothing to progress).


Unfortunately though, while there are and have always have been some very good people working for NTS, the overall balance of power – as hinted at by Simon Skinner in his reference to castle owning elites – is still held by those who think that the private way is the only way of doing things and to whom “social inclusion” is a foreign concept.   I am fearful therefore that the latest round of cuts will inevitably impact adversely on the countryside properties – the proposed distribution of resources between buildings and countryside in the new structure is far from clear – and on Ben Lomond and Mar Lodge in particular.


I believe our two National Park Authorities could play a role in developing alternative ways of managing NTS properties.  Indeed this could be part of their new Partnership Plans, about to be issued for consultation, which will set out what our National Parks propose to do over the next five years.   This needs to start by proper look with NTS about what funds are actually required to manage these properties effectively, including nature conservation/re-wilding,  recreational infrastructure  (footpath maintenance, renovation Derry Lodge,  provision of campsites) and dealing with the impacts of unforeseen events such as the flooding on Deeside this year.   There could then be a national conversation about whether we should treat these properties  as national assets – there is a precedent for this as in 1995 Ben Lomond was designated as a “National Memorial Park” – or whether they should remain entirely in the custodianship of NTS.   My own view is that I don’t believe NTS will ever be able to deliver its aspirations on its own and the current model is broken beyond repair..



June 25, 2016 Nick Kempe No comments exist

I was in the Lake District last weekend, camping in Borrowdale, where there are at least 8 campsites in the 12 kilometres south of Keswick with not a holiday chalet or caravan in site.   The contrast with the Loch Lomond and Trossachs National Park, where the National Park Authority has granted provision for much of the far more limited provision to convert to caravan parks could not be more striking.


Over the years I have enjoyed staying in a number of the campsites in Borrowdale and elsewhere in the Lakes.   While there is no legal right to camp as such in England, in practice its as hard to stop people as it was in Scotland before our access laws and you will see people camping all over the fells.   There are very few attempts to “wild camp” in the valley bottoms in the popular areas of the National Park simply because there are so many campsites.  Because of this the Lake District National Park Authority does not have to waste its resources “policing” campers – which is what the LLTNPA is now proposing.


I took a few photos which demonstrate some other things the LLNTPA could learn from the Lake District about the provision of campsites.

Part of the campsite at Stonethwaite.

I have never seen any fixed “pitches” in the Lake District campsites I have stayed.  You can camp where you like.  Contrast this with the LLTNPA proposed campsite at Loch Chon where they are creating 30 fixed places.    The LLTNPA acts like big brother and decides where you can camp.   Now I appreciate the terrain is different but so it the attitude of mind in the people running the LLTNPA.

Camping overspill field Stonethwaite


One of the points a number of people made to the LLTNPA during the Your Park consultation was that all you needed to do to address the lack of facilities in the National Park was to install  portaloos at times of peak demand.  Add a tap and you have a basic campsite.    The cost of this is tiny but instead of this the LLTNPA is spending £345k to develop just one totally overspecified campsite at Loch Chon where there is no demand.   It should have learned from its experience of developing the campsite at Loch Lubnaig where it spent a fortune.   Its beautifully done of course but if the LLTNPA spends its resources in this way it will take 50 years to create anything like adequate camping provision.  It needs a total re-think.IMG_2471



This sign indicates that anti-social behaviour is not just a problem in Loch Lomond and the Trossachs.  Indeed I have been in Lake District campsites when being camped near people drinking under Union Jack gazebos was not a pleasant experience.  The campsite owners and operators however have by and large IMG_2472learned how to manage this – and that’s the answer, they manage people rather than banning them completely.

June 24, 2016 Nick Kempe No comments exist

It feels a little strange to be writing about the CNPA Board Meeting today – a small issue in the scheme of things – when Britain has voted to leave the EU but Scotland has voted the other way.   I believe the political and economic uncertainty this has already caused creates opportunities as well as risks.


An example that affects our National Parks is our wildlife legislation.   In my email inbox this morning was a message from Friends of the Earth which started “many of our environmental and nature protections are now at risk”.    FoE along with RSPB have for a long time put much of their effort as regards nature conservation into trying to increase the land covered by the EU designations of Special Area of Conservation and Special Protection Area.   I remember when I was on the Board of SNH the RSPB pushing for more Special Protection Areas, the EU designation to protect birds, to save Hen Harriers.  I observed then that because the criteria for SPAs was that the land to be protected had to contain  a certain percentage of a bird species that, having drawn a line on a map around hen harrier nests, all the landowners had to do was to magic away a couple of the hen harrier and the criteria for the SPA were not met.    In my view this actually resulted in increased persecution!  This was because SPAs did not tackle the real issues.   The point is that whatever you think about the EU, we have the ability to protect our hen harrier in Scotland much better than we do at present.  I am not claiming the international dimension to wildlife protection is not important – it clearly is for migrating birds – but there are plenty of ways the Scottish Government and organisations like our National Parks could protect our hen harriers here and now.


It is disappointing therefore to find there is nothing on the CNPA Board meeting agenda about wildlife persecution in the National Park  or any opportunity for the Board to consider what it could do about this.  One of the positive differences between the CNPA and Loch Lomond and Trossachs National Park Authority is that there is far more focus on conservation and wildlife in the Cairngorms.   The issue is  that despite lots of positive wildlife initiatives, the really major challenges such as the lack of hen harriers in the National Park are simply avoided – in public at least.   The  papers for the Board Meeting today provide an illustration of the challenges that are being avoided and which I believe our National Parks were set up in part to address.


The CNPA has a number of key performance indicators.  For wildlife this is the number of capercaillie in the National Park and one of the aims is to increase the number of males counted at Leks from 175 in 2014 to 180 in 2018.   Reporting figures are not available so far for this year.   Now while you could question the lack of ambition in the indicator I don’t think this is the real issue.   We know enough to say first that the reasons that account for the perilous status of capercaillie in Scotland are complex and second that there are some  organisations with very committed staff on the ground (Forestry Commission Scotland and RSPB) who are trying all they can to manage their land in a way that helps capercaillie.    The capercaillie Performance Indicator suits them because it helps justify their efforts and I suspect to secure funding for their work.  Meantime, the moorland in the Park which should be supporting large numbers of hen harrier is devoid of them.   I can’t helping thinking that the number of successful pairs of hen harrier breeding in the National Park would be a far better performance indicator which would encourage the CNPA Board to consider how it could achieve change rather than being able to sit back and leave this to others.


Another example of this is the paper on Land Management Training.  The National Park runs a number of subsidised training events for farmers and estates staff which are about improving skills and includes events on such things as montane scrub restoration, which clearly are related to the fundamental purspose of the National Park, but also more general skills such as chainsaw and ATV handling.   One wonders if whoever on the Invermark estate down the tree where sea eagles nested had been on a National Park sponsored chainsaw course?!    The paper says the training is all about assisting the National Park to achieve its objectives (which I applaud) but then gives no consideration of what should happen where estates and farmers appear not to be working to meet those objectives.  In the jargon there is nothing in the paper about “cross compliance”.


The biggest issue which has been avoided in the papers for the Board Meeting is the status of designated conservation features in the Park.  The CNPA target is to increase the number of these in favourable or recovering condition from 79% in 2014 to 90% in 2018.  In January 2016 this had gone up by just 2% to 81% which suggests its unlikely the target will be met.  Yet there is nothing in the Board Report to highlight this and no analysis given of what is going on.  Instead there are updates on a number of conservation initiatives.  These of course are commendable but the real issue is why is it that in Scotland, even in our National Parks fourteen years after their creation, so many conservation sites are still not in favourable condition.   The answer of course lies in how the land is being managed but that is an issue which it appears either the Board is not allowed to discuss or discussions happen in private.


The Board Papers do suggest  certain opportunities in the papers though.  An example is that one of the CNPA targets is to increase planting of native woodland by 5000 hectares and this also appears behind schedule (1500 hectares planted 2013-15) – so why not do something visionary and include the ski area in this?


The other agenda item which I thought was of particular interest were the papers on the Glenmore consultation (where I have been involved representing the Scottish Campaign for National Parks)


There is no revised strategy as yet but there are some indications of the direction of travel, both positive and negative.  On the positive side there is a reference to all the main partners agreeing there needs to be integrated management  in Glenmore and Cairngorm and it appears there are plans afoot to integrate the Ranger Service at Cairngorm, which is operated through HIE, with that at Glenmore, operated by FCS.    The major issue of course is whether the land will be managed in an integrated manner, from glen to summit, and unfortunately there is information in the papers to suggest this has a long way to go.  So “HIE are finalising their management plan” and “Natural Retreats are continuing to develop their master plan”.   This is almost certainly code for saying that the CNPA staff do not know what either HIE or Natural Retreats are planning let alone whether this will be compatible with the proposed strategy.   How can different land managers preparing their own plans in isolation be compatible with the vision of integrated land management?    That is one of the major questions CNPA Board Members should be asking today.

June 23, 2016 Nick Kempe 1 comment

The creation of the new rope tow in Coire Cas, which created so much destruction at Cairngorm, required planning permission Removal of Shieling Ski-Tow & replace with a modern rope-tow of similar length and profile   The Shieling tow replacement supporting  images document  is worth looking at as it gives a very clear picture of how this slope appeared before the works and what was planned: removal of the existing tow, smoothing out the existing bulldozed tow line and replacing the bridges over the Allt a Choire Chais with culverts.    I don’t think any of this was objectionable in principle and it had the potential both to improve the skiing and the appearance of this part of  Coire Cas.


The problem with the planning application was  twofold.  First  because the replacement sun-kid rope tow  2014_0251_DET-VISUAL_INFORMATION_-_TOW_LIFT-100105314 required a constant gradient the work required on the slope along the line of the lift was probably more extensive than was made clear in the supporting documents.  Second, and related to this the Method Statement 2014_0251_DET-METHOD_STATEMENT-100105315 while clearly describing how the turf on the existing slope would be removed, stored and then replaced and referred to soil being removed, stored and replaced it did not say how much or where it would be put.


I am not sure the planner appreciated just how much soil and boulders would be shiftedRG 100_0042

Shifting and storage of soil and boulders was not mentioned in the Method Statement – a huge pile can be seen centre background outwith the area granted planning permission                                 Photo Credit Ron GreerAB Excavated Hole

Photo credit Alan Brattey

AB General Mess
The Method Statement did not say what would happen to boulders that impacted on the “reprofiling” of the slope Photo credit Alan Brattey
















The Planning Application was from Cairngorm Mountain Ltd, which is run by Natural Retreats, and it was Natural Retreats who were responsible for the day to day monitoring of the works.  However, the Method Statement made it clear that the overall plan was authorised by Highlands and Islands Enterprise and indeed that HIE (rather than Natural Retreats) was to appoint the contractors.   It appears therefore that HIE as well as Natural Retreats are responsible for everything that has gone wrong.   This is important because HIE is a very powerful body in the Highlands with a proven history of driving through its own agenda for the ski area, including the funicular white elephant.  I would not underestimate how difficult it would be for the Cairngorms National Park Authority to take on HIE without political backing.


Having said that, I believe there have been a number of clear breaches of the planning permission granted  for the Shieling Ski Tow replacement for which the CNPA needs to hold both HIE and Natural Retreats to account.    These include:

The new bulldozed track

There was no reference to a new bulldozed track in the planning application – a clear breach of planning requirements                                                               Photo Credit George Paton















Work undertaken outwith the area granted planned permission

GP image1
Working taking place on the bank below the shieling ski tow – the planning permission did not cover this area                                                                                               Photo credit George Paton
A hole excavated by a digger outwith the area granted planning permission – it appears the contractors were short of vegetation (implying they had not stored turf in the manner specified) and tried to address this failure by taking vegetation from elsewhere. There is no mention of this in the Method Statement and it is also clearly outwith the planning permission granted                                                                                           Photo Credit Alan Brattey
























The contractor  has failed to finish off the new culvert  let alone in the manner specified

Photo Nick Kempe

And there is the question of whether this pit was covered by the planning permission?

Pit into which soil, peat and boulders was later dumped Photo Credit Alan Brattey

What needs to happen about the breaches in planning permission at Cairngorm?

There are some lessons here for planning authorities and the CNPA in particular and these are that it is not wise to trust applicants for any planning permission to monitor their own work.   I believe the photos demonstrate neither HIE nor Natural Retreats can be trusted – if they disagree with this I would be happy for them to justify what they have allowed to happen on Parkswatchscotland.  While I understand because of resource issues its impossible for planning authorities to monitor every application,  Cairngorm is not just anywhere but crucial to the well-being of the National Park.  Independent monitoring by the CNPA as planning authority should have taken place throughout the works.  This would have limited the breaches of the planning permission granted.    The CNPA and Highland Council (which is responsible for more minor planning applications) should ensure this is in place for any future planning applications involving IE and Natural Retreats.


The CNPA now need to take firm action to enforce the requirements of the planning permission it granted otherwise its going to lose all credibility.  I suspect that HIE will resist this and unless they offer a full and public apology for what has happened and take a lead in re-instating the bulldozed track and repairing the other damage, I believe they are no longer fit to own the ski area.

The solution to these problems and to realising the vision I have outlined for Cairngorm is to transfer the ownership of the Cairngorm back to Forestry Commission Scotland while leaving liability for the funicular and for re-instatement of any of the other parts of the ski development that might eventually be removed with HIE.   I will cover how this might happen and the quality of the restoration work undertaken at the shieling in due course.


Author’s note

I am very grateful to all the people who provided parkswatchscotland with photos following my first post on the destruction at Cairngorm and for allowing me to include them in this post but I should hardly need to point out that the views expressed above are purely my own.




June 21, 2016 Nick Kempe No comments exist
Spotted on the headwall of Coire Cas
Spotted on the headwall of Coire Cas – thanks to the reader who sent this

I picked up earlier this winter that there has been a lot of discontent from downhill skiers and boarders about how Natural Retreats has been operating the ski area, with the general perception being they have neglected winter sports in favour of summer visitors.    There is also a lot of concern on Speyside about the quality of the tourist offering and the implications of this for the local economy.  What is really interesting is that people are now openly expressing this.   In the past there has always been a certain tension between conservationists and recreationists, mountaineers and skiers, local people and national organisations and this has allowed Highlands and Islands Enterprise to get away with a series of poor decisions, the latest of which appears to be its lease with Natural Retreats.   I believe the general discontent with Natural Retreats will help turn the spotlight on HIE.    There is now a great opportunity for the various interests to get together and rethink a vision of the ski area and the role it should play within the wider Glenmore corridor.



June 20, 2016 Nick Kempe 1 comment

Following my post  Ron Greer sent  parkswatch some photos of montane scrub from North America and Norway and some useful links which help illustrate the type of landscape that might result from planting the ski area.

NH1 montane
Montane heath woodland from eco-equivalent zone in North America.  With our own native species complex, this is very like what could be obtained at Coire-Cas and environs. We could thus have an upland sylvan environment with high amenity value and conservation qualities with pistes (with self-repairing& carbon sequestrating capacity living ‘fences’) and walking trails built integrally to it. This is an ‘as well as’ and not ‘an either or scenario’. Photo commentary Ron Greer


Fjällväxter-Norwegian hills near Sweden. The plant species that are pictured in this photo are essentially the same as can be found at Cairngorm and the hill in the background even looks similar.


Here are some useful links from Ron:














June 20, 2016 Nick Kempe No comments exist

The Loch Lomond and Trossachs National Park Authority Board Meeting last Monday included a paper on “Your Park” after a request from a Board Member at the previous meeting for regular updates this year.    That there is now some public reporting on how the Park is developing its camping proposals is a step forward.  The Board Member who suggested this should be commended.  The original proposals for the byelaws were developed in a dozen or so secret “Board Briefing Sessions” for which no minutes were taken.  The Park has refused to publish the written information it holds on these meetings and these are currently subject to an appeal to the Freedom of Information Commissioner.   So, we should welcome the greater transparency the publication of this paper represents.


It was not a good sign though that Fergus Wood, a Councillor on the Board and farmer in Strathard, had declared an interest at the start of the meeting without saying what this was, although every Board Member seemed to know.  It suggests Board Members had discussed this at the secret Board Briefing session which took place that morning.  Anyway, Cllr Wood left the meeting for the item which I think was right and proper.   My guess is he did this because he is now talking to the LLTNPA about providing a campsite on his land by Loch Ard – which would be an obvious declarable interest (one wonders if he left the secret Board Briefing session in the morning if the camping plans were discussed there).   A shame though the Park could not  be open about this and an opportunity lost – “Board Member shows lead to other farmers in the National Park”.


The most negative aspect of the Board_20160613_Agenda8_Your Park paper was the continued secrecy about the Park’s Camping Development Plan.  For over a year now there have been references to negotiations with landowners and significant progress delivering camping places but the only proposal that is public is that at Loch Chon The huge flaws in that proposal show just why the LLTNPA needs to be open about what it is doing and consult with local communities and recreational organisations.   While there was reference by Board Members at the meeting to the outcry from local residents at Loch Chon and the need to consult earlier there was not a single reference to engaging with recreational organisations.   This is unacceptable and a path to disaster.  I suspect when the LLTNPA do go public with their proposals it will be far too late to change anything and we will end up with more daft ideas like the proposals for camping on wooden platforms at Loch Chon.


The paper revealed that there appears to have been a significant shift by the LLTNPA about the number camping places needed:   “There is also a commitment to bring forward further facilities beyond this date (March 2017 when the Park has said it will provide 300 new camping places).  Now I had previously asked under FOI about how the Park had decided 300 camping places were needed in the camping management zones when its own figures shown on a popular weekend 850 or so tents have been recorded.    The response I got then indicated there was no science behind the figure – its was simply based on the view of unnamed staff – and basically that it had been plucked out of thin air.   If the Board has recognised this, its a step forward.  The problem however is twofold, the LLTNPA is still not being open about how many places it will deliver in the longer-term (I would suggest that will depend on the amount of public pressure to deliver new places) and how it proposes to manage all the “surplus” campers in the short-term?


The paper also included updates on the development of the proposed permit system which was never part of the Your Park consultation and, needless to say, about which there has been no public consultation or engagement.   The most interesting revelation was that the LLTNPA is proposing an on-line booking system which it is developing in conjunction with Digital Scotland – in other words with the involvement of central government.   While no details were provided about how this will work, David McKenzie – the Board Member who suggested Owen McKee should be reported to the Standards Commission – asked about developing 4G coverage in the National Park so people could book remotely and Martin Earl asked if staff knew where mobile phones work in the proposed management zones.    Indeed Martin Earl followed up his question by asking how people would access permits and how the LLTNPA would approach people who did not have one?   He assumed there would be a need to be flexible and understanding, to which there was general assent, but there was no detail of what this meant apart from people might be able to get permits from local businesses (another about turn as a previous meeting Gordon Watson had stated all permits would be issued centrally).


The clear implication of this is the LLTNPA Board have started to realise that booking permits in advance won’t work.  Unfortunately the discussion did not go quite far enough.  No Board Member thought to ask what would happen if say a cycle tourer decided they wanted to stop and found all the local places where one could camp with a permit were occupied.   Unfortunately too, no Board Member thought to ask what happens on a sunny weekend and 600 people turn up in the Park to camp.   They still seem to be crossing their fingers that this won’t happen.


I was struck too that in contrast to the discussion on how the LLTNPA could enforce Fixed Penalty Notices for litter, where the Board seems to have realised that education will work far better then enforcement, there were no questions about whether the proposed permit system will be enforceable.    All it will take is for people to carry on camping and the permit system will collapse, whatever plans the LLTNPA has for joint work with the police and FCS.


My prediction is that the LLTNPA will very soon start to realise it cannot manage the camping permit systems as currently proposed and that where Rangers find people  camping without a permit, they will simply ask the person to apply for one rather than referring them to the Procurator Fiscal for breach of byelaws.   There might be some exceptions, where people are camping too close to houses or within the boundaries to villages, but other than that people will end up being able to camp where they always have.    The difference will be there will be a CHARGE for doing so.   This is why the camping byelaws and proposed permit system are still so dangerous.  They would in effect introduce a charge for access which undermines the whole basis of our access rights and which, if successful, will provide a precedent for every landowner in Scotland.    People need to remember that the agenda of landowners now is no longer predominantly about preventing access, though there are still some battles about this, but about how they can make money from what should be a public good.  The Duke of Buccleuch’s attempts to charge for access at Dalkeith Country Park being a case in point.


In the limited discussion that took place on the Your Park item, the other major omission was no Board Member asked any questions about the implications for civil liberties.   I have not touched on this so far on Parkwatchscotland but, for a permit system to work, the Park needs to keep information on irresponsible campers, for example,  people who have been issued with a permit but then abandon their tents.  This means the LLTNPA  needs to keep a data base on you and me and to have developed a clear and open system about how it will use this data to make decisions.   For example,  if a 17 year old with a permit leaves litter around their tent and is banned, how long will this be for?  For life?    We simply don’t know. If on the other hand permits set no conditions about use, it begs the question why they were ever proposed.  I am amazed that not a single Board Member has questioned the civil liberties implications.   The civil liberties aspect of the camping management proposals  is reason in itself why the permit system should be subject to full public consultation and is something the Minister at the time, Aileen McLeod, should have insisted upon before approving anything.


What needs to happen?

The best solution to the ill-thought out proposals of the LLTNPA and their  implications for access rights and civil liberties would be for the Minister to suspend the decision to implement the bye-laws and  require the LLTNPA to consult publicly on the development of new camping places.

Meantime though I believe the  LLTNPA should:

    • publicly consult on its camping development proposals and engage with recreational organisations of location, design and numbers of camping places
    • consult with the Scottish Human Rights Commission on the civil liberties aspect of the byelaws
    • fully explain the implications of their proposals for access rights
    • fully explain how it intends to enforce these byelaws in conjunction apparently with Police Scotland and Forestry Commission Scotland





June 17, 2016 Nick Kempe 17 comments

Approaching the abandoned ski tow in Coire na Ciste two weeks ago, partially concealed by the rows of abandoned chairlift seats, three men in flak jackets, each with a camera whose lense was the size of a telescope, were reclining on the ground.   Two of them had come to Speyside from the south east of England to watch birds and had spent half the day are the Coire na Ciste carpark getting to know the Ring Ouzel.   On an average year I see a few Ring Ouzel, but always around boulderfields and often under crags, although these birds are normally associated with montane scrub zones.   Cairngorm is a good place to see them because the forest is growing back.


An hour later we had wandered up into Coire Cas where we saw first an adult then the chicks

Photo credit Dave Morris
Photo credit Dave Morris
Ring ouzel chicks
Photo credit Dave Morris








Brilliant, ring ouzel in montane scrub!    It got us thinking.    What an opportunity missed.  It would have been perfectly easy to put a camera on the nest and relay the photos to the Day Lodge.  Do that and suddenly tourists would have a reason to be there, even when the cloud was down as on our visit.  Something far better than the funicular – it had us grinning for the rest of the day and not just because we had got better views than the men with enormous cameras.  Visitors might go into the cafe afterwards to have something to eat or even a drink to celebrate.   Travel to Speyside to see Osprey at Boat of Garten, Peregrine at Aviemore (this summer you can watch them by video link from the Youth Hostel), Ring Ouzel at Cairngorm and, here’s hoping, Hen Harrier at Newtonmore.      Better still though, imagine the whole of the lower part of Coire Cas was covered in montane scrub, the numbers of Ring Ouzel – which are in serious decline nationally – might increase and people could just wander along paths or up through the pistes and see them like we did.


Now in general I am opposed to planting on the edges of forest which are relatively natural and capable of regenerating naturally as the Caledonian pinewoods are doing on Cairngorm.   Speeding up rewilding is likely simple to create habitats the way we, or the powers that be, think they should be.  A form of gardening, however sophisticated.  But Cairngorm I think is different.


It is ecologically different because the soils and ground vegetation have for a long time been affected by intensive human use and now in places, as in the bulldozing done by Natural Retreats,  in effect destroyed.  In destroying these soils and the ground cover, erosion is bound to increase and the chance of a major catastrophic event, such as the whole slope failing, more likely.      Planting trees that will develop into montane scrub won’t do any more damage on areas which have been extensively modified and could help stabilise them.  There is even guidance on how to do this


Cairngorm has also been subject to a number of tree planting experiments which provide precedents, the latest of which show that a montane scrub zone could probably be well established in 10 years.IMG_6127

These lodgepole pine – non-natives – were planted by an employee of the then Cairngorm ski lift company.  Guerilla gardening!

These native trees originated from a grant awarded by the then Nature Conservancy at the end of the 1970s to demonstrate to the chairlift company that trees would grow in Coire na Ciste. Subsequently there has been some natural regeneration









These trees were planted when Ben Humble’s Alpine Garden was relocated uphill at the time of the funicular construction.

Trees here are unlikely ever to grow to full height, unless global warming ends the harsh winters and wind speed decreases, but the photos show that a planted montane Alpine scrub zone in Coire Case could become well established in relatively short periods of time.


IMG_6132While there is some natural regeneration in the ski area, this has been limited, probably in part due to accidental destruction by ski machinery and skiers.    Planting trees behind the solid new fences would offer them protection from this threat but in time soften the harsh linear lines of the fencing improving the landscape.  In time, the trees might provide an effective alternative to snow fencing.


There is nothing revolutionary about this idea.   Look at similar ski areas in Norway and Canada and the runs are often through forest or montane scrub which help trap the snow and look much better.   Imagine if trees had been planted at the time of the construction of the funicular, this area would have been transformed.


The potential attraction of a montane scrub zone is not just limited to the Ring Ouzel and trees.   At present there is very little montane scrub in Scotland due to the long history of overgrazing and the best such habitat at Inshriach is inaccessible to the general tourist.   If a montane scrub zone was planted here it would provide an attraction for the general tourist which they could not see anywhere else.


Indeed, at the time of the funicular construction, the staff at Cairngorm made a serious attempt to promote understanding of montane scrub zone.   While a lot of the interpretation that was developed then is now sadly neglected, it points the way and some of it could still be used.IMG_6046

One of a number of signs in the “viewing” station on the edge of the Coire na Ciste carpark



No sign of the alpine bistort among the dwarf cornel







A once great idea undermined by neglect
Wildlife of montane scrub in Norway




















Info from James Hutton Institute on fungi
Cloudberry growing on the ski slopes








There are still some very informative signs, including ones comparing Cairngorm with similar mountains in other parts of the world.  At present almost all the interpretation is in the neglected “Alpine” garden above the Day Lodge.  There is scope to extend this onto the ski slopes in Coire Cas where its possible even now to see plants that the general tourist is unlikely to see anywhere else.  Some further planting of  Alpine plants in suitable places along sections of the existing paths and tracks in lower Coire Cas could create an attractive trail like some of the Alpine gardens on the continent which are much larger in scale than the current one in Coire Cas.


The creation of montane scrub habitat in Coire Cas could help counter the steady drop in the number of visitors using the funicular.   This has approximately halved since it was constructed and continues to threaten the whole financial viability of Cairngorm which, on the current model, depends on visitor numbers.  Visitors coming to the ski area to see the wildlife won’t in themselves rescue what is a white elephant but it could be part of a different model of sustainable tourism which is based on recreational enjoyment of  the natural environment.   It might even  put the “natural” back into “Natural Retreats”.


In the past the primary concern about attracting visitors to Cairngorm has been about the serious threat that large numbers of people would have to the uppers parts of the mountain and the Cairngorms plateau.  This is why the funicular is to all intents and purposes a closed system in summer.   Attracting people to visit a montane scrub zone in Coire Cas though is  unlikely to have any impact on the plateau.  The vast majority of people would be what I would loosely describe as “general tourists” who tend to do short walks.  It should not be difficult to keep them in Coire Cas through path signage and interpretation.  Hillwalkers who wanted to see the montane scrub would proceed up the hill anyway and for those wanting longer walks, walking back into Glenmore will most of the time be the more attractive option.  I don’t think there is much more likelihood of the general tourist heading for the plateau after seeing the montane scrub zone than there is now of then general tourist travelling to the top of funicular and liking the view so much that once they have been taken back down they decide to walk back up on their own two feet.


I have tried in this post to put the argument for the creation of a montane scrub zone in Coire Cas through planting trees and some plants.  This would reduce the impact of the ski development on the landscape, improve the skiing, improve habitats for wildlife and create a reason for summer visitors to come to Cairngorm.  The evidence of the destruction in Coire Cas suggests then neither Natural Retreats nor Highlands and Islands Enterprise are fit to deliver such a vision and that there is a strong argument to integrate management of the ground in the ski area with that in Glenmore below.















June 15, 2016 Nick Kempe 3 comments
Cairngorms Ron Greer100_0042
Photo credit Ron Greer. Bulldozing ground lower Coire Cas before installation new ski tow and snow fencing

While I usually visit the Coire Cas carpark at least a couple of times a year to climb or ski tour it was years since I had taken a proper at the Cairngorm ski area.   I was prompted to do so with Dave Morris  two weeks ago by this photo taken by Ron Greer last year.


It was pure coincidence our visit  happened just after Natural Retreats announced their decision not to replace the Day Lodge at Cairngorm with a new building and that they were considering other options, including a mountain bike track.   I have since been doing a little digging of my own.


The destruction was to “improve” the skiing, to install a beginner’s rope tow and smooth out the slope.











In the past the destruction evidenced by Ron’s photo would never have been allowed.  The construction of the funicular 1999-2001 pre-dated the creation of the Cairngorms National Park but strict construction requirements were put in place.  For example, the use of machinery was restricted and the bases of some of the concrete stanchions which you can see in the right hand photo dug out by hand.  I disagreed with the funicular – which has always be a white elephant – but at least at that time there were serious attempts to preserve the mountain and meet some of the criticisms of conservationists or indeed anyone who cared about the mountain.  It appears that this is not longer the case, that Natural Retreats and its sub-contractors have been allowed to run amok and completely destroy the soils here.


While there have been attempts to restore the vegetation  over most of the ground, there is already evidence of extensive problems.

There are patches of ground where there has been no attempt to restore the vegetation that has been removed.
Erosion in form of gullying at the top of the track
Erosion, including gullying at the top of the new bulldozed  track
Some of the attempts to restore vegetation have clearly failed





We have had a relatively dry year so far but its clear that with a period of heavy rain significant areas of the “restoration” work will wash away and the track, which points straight downhill and has no channels to collect the water flowing down it will start to develop deep erosion channels.   This is not simply about standards of work that should be unacceptable in a National Park, its also about risks  that the whole slope is  washed away completely.   I believe the public authorities, the Cairngorm National Park Authority, Highland Council, Highlands and Islands Enterprise and Scottish Natural Heritage need to act on this and fast.

The new track in Coire Cas is several hundred metres in length and the slopes to left and right of it have been extensively modified

After our visit I found out the new track has had no planning permission – its an unlawful development in the heart of our National Park and to make matters even worse so far NO enforcement action has been taken against Natural Retreats.     Indeed I understand that significant other parts of the work undertaken by Natural Retreats had no planning permission and hope to cover this on Parkswatchscotland in due course.

The new fencing is more concentrated lower down the hill


There is an aesthetic debate to be had on whether the new fencing looks better than the former chestnut fencing.  The old fencing was well past its sell-by date and it may be the new horizontal plank design is more effective at trapping snow.   What is indisputable though is that the new fencing does not make this a good place to walk and partially undermines previous attempts to create paths for general tourists through the ski area.






Where now?

The destruction evidenced in these photos at the heart of our National Park should be of serious public concern and though harder to address than the rubbish that is littered everywhere, that would  not prevent effective action if there was the will from our public authorities and politicians.


That Natural Retreats has breached planning requirements in the first two years of what is a lease which has something like 22  more years to run should not just be taken as an awful omen, it should trigger a review of the lease by HIE who own the land.  I have already asked HIE for a copy of the lease and if this does not contain a require to adhere to planning conditions, one needs to be inserted immediately.  If Natural Retreats failed to accept this I believe this would demonstrate they were unfit to operate any ski area in National Parks and that alone should be grounds to terminate the entire lease.


Breaching planning permission in the core of a National Park is unacceptable and the CNPA now needs to undertake a full audit of what elements of the works undertaken by Natural Retreats had planning permission and which did not and then take appropriate enforcement action.   They also need to look at the quality of the restoration work in consultation with Scottish Natural Heritage who were involved in setting standards for the funicular development.  I believe this should include commissioning an independent report on the damage that has been done here and how it can be repaired.


The damage caused by Natural Retreats means the ground and vegetation cover in Coire Cas will almost certainly never be able to be restored to its previous condition.  To put it bluntly the land here has been trashed.    I believe this is unacceptable which is why there need to be serious consequences for Natural Retreats.   I very much doubt now they are fit to manage this area but the who care about this area, and the public authorities that are supposed to be its custodians, need to look forward and find solutions.   I will argue in my next post on Cairngorm that the destruction caused by Natural Retreats provides an opportunity to develop a new vision for the ski area that would make it better for skiing, walking and wildlife.

June 14, 2016 Nick Kempe 2 comments

I have now been observing Board Meetings for 18 months and the one on Monday was twice as long as usual (the shortest has been over in 45 minutes), all because there was some debate in public.  A welcome development even if the meeting again demonstrated much of what is wrong about how the Loch Lomond and Trossachs National Park Authority is run.


The meeting started with the Governance and Legal Manager reading out a statement quoting sub-clause of this and clause x of that to justify why item 17 on the agenda, on Vacant Assets, was being held in private.   The statement will no doubt be quoted at length in the minute to demonstrate the transparency and superb governance of the LLTNPA.   No reference was made of course to the secret Board Briefing session which had taken place that morning or how many other such secret meetings had taken place since the last Board but since these are never minuted, we will never know whether it was legally justified to hold them in secret.   The Park seems incapable of grasping that the concerns of transparency campaigners, like myself, is not that the Board discusses the occasional item in private – I’ve been on a Board, I know its necessary on occasion ,even if I often think the outcomes of such meetings could often be made public at a later date – but the majority of this Board’s business takes place in private, including the dozen or so meetings that developed the camping byelaw proposals.


As I expected, there was then not a single mention of the Owen McKee case in the discussion of the annual accounts – the LLTNPA is indeed trying to airbrush the glaring failures in how it handled Owen McKee’s trading in shares from its history.   Why the Board might get away with this was eloquently explained by  Lindsay Morrison, the convener of the Audit Committee, later in the meeting when he said that Audit Scotland had never once highlighted to him any issues of concern about the governance of the LLTNPA.  This is the same Audit Scotland who have confirmed in writing to me both that they were never informed by the LLTNPA about the Owen McKee case and also that they would have been expected to have been told.    While in my professional life I worked with staff from Audit Scotland and had nothing but respect for them, in this case it appears that the lead auditors have failed in their professional duties and the Annual Report is not worth the paper it is written on.  I didn’t have much sympathy therefore when it was revealed in the meeting that the Scottish Government has decided that Audit Scotland will be replaced as external auditors of the Park.  Whether Grant Thornton, a private firm, will be any better remains to be seen but just to get them going here is a list of the serious governance issues concerning LLTNPA which I raised with Audit Scotland and which they apparently failed to discuss with Lindsay Morrison Letter to Kevin Boyle151221


The Board failed to question other aspects of the annual report, which is full of photos and very little content, and formally approved it.   Some of the spin is enough to make you laugh or cry:


    • From the Forward, entitled “Welcome”  – whoever welcomed people to a document rather than a place? – Linda McKay, the convener, and Gordon Watson, the Chief Executive “Our Your Park initative to enhance the camping experience on our most heavily used lochshores took a significant step forward with the approval of the camping management byelaws by Dr Aileen McLeod, Minister………….”    The use of “our” and “your” almost says it all but  the claim that banning campers is the best way to enhance camping is Orwellian newspeak at its best.
    • Then there is this photo to illustrate the work that has been done on the West Highland Way between Rowardennan and Rowchoish




















It left me wondering whether any Board Member has walked the West Highland Way or knows where the boundary of the National Park is.

Linda McKay, the convener, then raised (under the section of the annual accounts where the LLTNPA reports on gender equality) concerns that the Park’s Board is predominantly composed of men.  Councillor George Freeman challenged her on this, pointing out that most of the Board were democratically elected (unlike Linda McKay) and ultimately it was up to the electorate to take these decisions.   Unfortunately, he did not have the temerity to point out that it was this same Linda McKay who sat on the interview panel which selected the most recent Government appointee to the LLTNPA, one Major James Stuart,  and that she was the one member of the Board who actually had any power to change this.   The quiet effrontery of Linda McKay never ceases to amaze me but then she was playing to the national politicians.   What Linda McKay did not say was that though the senior management is presented as balanced within the Annual Accounts, within that team the men have the best paid and the women the lowest paid jobs.   She of course has had the chance to influence the structure of that team more than anyone else.  Hypocrisy and more spin!


The meeting then started to improve.  First there was a report on progress on the Park’s camping management proposals which I will deal with in another post.   There were no decisions taken and still too much secrecy but reporting on progress in public was still a step forward.


The discussion on litter though was a revelation, a view shared by Peter Jack of the Loch Lomond Association who has been attending Board Meetings with me for the last 18 months.  It would be nice to think that some of the debate was spurred by my post  two days ago but Board Members made a number of points that added signficantly to that analysis:

  • Cllr George Freeman set the context of litter being a national problem, that roadside verges and that of the A82 in particular, were a disgrace and pointed out that Transport Scotland have a major role to play here as they manage trunk roads in Scotland.   Spot on!
  • Cllr Freeman also asked if the Fixed Penalty Notices for fly tipping which the Park was about to implement would cover landowners (a clear acknowledgement that landowners are a major source of the problems).  They will not, but Gordon Watson I think it was stated that the Park could report these cases to Local Authorities who could take action.   No-one asked about the obvious failures of the Park to do this
  • Cllr Fergus Wood though expressed great disappointment at the lack of progress with Councils about litter collection facilities which had been talked about for years – and which have been highlighted on Parkswatch.  Several other Board Members strongly agreed with this.  Cllr Wood pointed out that he had never been asked to liaise with his Council to help sort this since he had been on the Board – amazing as this is why I thought Councillors were on the Board but good for Cllr Wood for raising this as a concern –  and also that as bin lorries pass all the popular stopping off places in the Park anyway it should not be difficult for the Councils to install litter bins and uplift the litter.   Spot on again!
  • Someone then had the temerity to suggest the LLTNPA should maybe suggest to the Scottish Government that throwing litter out of cars should become a Road Traffic Offence.  I thought this was a great idea but it was quietly deflected by the Convener.
  • Colin Bayes, the one Scottish Government appointed Board Member who avoids Government speak (outcomes, governance, missions etc) then reminded the Board that lack of toilets and litter facilities are the two concerns that have been consistently raised in the LLTNPA’s visitor surveys.
  • David McKenzie raised the issue of litter at the head of Loch Long (again featured on parkswatch) and pointed out that after one storm half of the 3500 items of rubbish collected by the local community originated in adequate sewerage facilities along the loch (tampons etc).  Part of the answer therefore should be to engage with Scottish Water.  Spot on!
  • David McKeown, the local rep for Luss, then asked if the Park rather than just talking about this did something, took the bull by the horns and started to pick up litter.  He made the very interesting suggestion that funds be diverted from education to pay for litter collection and justified this because he had done litter picks and found that where places are clean, litter is far less likely to be dropped.   While greeted initially with amazed laughter, he kept going and then Colin Bayes came in to support him saying all the research shows there is less litter in clean places.  Unfortunately, no-one suggested one way to reconcile education with litter picking would be to allow the LLTNPA’s very own Ranger service to remove litter rather than simply leave it at the side of the road.
  • Councillor Martin Earl raised questions about how new technology, such as remote cameras, could be used to prevent flytipping in the worst spots (an obvious solution to the huge fly tip on Loch Long at the old torpedo station)
  • Various members asked about how Fixed Penalty Notices for littering would be enforced and were strongly supportive of the educative rather than punitive approach.

Four things struck me about this discussion:

  • All the ideas and the debate came from Councillors and locally elected representatives, not the Scottish Government nominees.
  • That the implications of the discussion are that camping byelaws are not the answer to anything (the answers are about education, infrastructure and targetted enforcement directed to people who do not respond to an educative approach).  The question is when will the obviously knowledgeable Board Members who are able to think critically realise this and say enough is enough, there are far better and more effective ways to deal with irresponsible campers/litterers?
  • It did not lead to a single new decision.   I was left unclear at the end of the discussion what if anything would happen apart from staff being asked to go back to Councils and try harder to work with them (which is very difficult when as Cllr Freeman pointed out West Dunbartonshire Council is facing £11m of cuts this year and next).  Linda McKay resisted a couple of suggestions that the LLTNPA should write to the Government suggesting what they could change – which to my mind is exactly what our National Parks should be doing.  Acting as advocates for the changes needed in the way our countryside is managed.
  • That part of the reason for the Park’s inability to address litter issues is that there is no proper budget for this and without budgets, nothing happens.

The final revelation in the meeting was that the secret Board Briefing session that morning had been about risk.  The camping byelaw proposals were identified on the Park’s risk management register as the single greatest risk facing the LLTNPA so this was almost certainly an indication that yet more secret Board discussions are taking place on camping.  It probably explains too why there was so much less discussion at the meeting on litter than on the Your Park proposals (which should be the subject of my next LLTNPA post).

June 12, 2016 Nick Kempe No comments exist

Among the papers for the LLTNPA meeting today are three concerning the draft Annual Report and Accounts     For readers who are not aware these include statements about the governance of the Loch Lomond National Park Authority which are signed off by the Park’s external auditors, Audit Scotland.


There is not a mention in the Annual Report and accounts of the Owen McKee case – my last article on this gives links to all the information but Owen McKee was the convener for planning who traded in the shares of Scotgold Ltd after the Board had granted planning permission to the Cononish goldmine and this was then covered up by the Board.   It is still being covered up, in fact Owen McKee has been almost airbrushed from the Park’s history.  In the annual report it states “Owen McKee…………….resigned from Board duties with effect from 4th August 2015”.  Not a mention of the reason why – the exposure of his share-trading in the Sunday Herald.


I reported Owen McKee to the Commissioner for Ethical Standards in Public Life and this led to a hearing of the Standards Commission earlier this year which found that Mr McKee had breach the Code of Conduct for Standards in Public Life.  The quote from the Standards Commission press release after that Hearing speaks for itself:

“The Convener, Kevin Dunion, in delivering the Hearing Panel’s decision said: “The Panel
emphasises to all Members of Devolved Public Bodies the importance of declaring all relevant interests, financial or non-financial. The declaration of interests(including interests in shares) is a fundamental requirement.The failure to declare such interests removes the opportunity for openness and transparency in a Board Member’s role and denies any member of the public the opportunity to consider whether a Board Member’s interests may or may not influence the decision-making process.”
Rather than urge Owen McKee to refer himself to the Commissioner for Ethical Standards in Public Life when his share-trading came to light, or report him themselves if he failed to do this, the LLTNPA Board signed off a report which only their convener, the Head of Audit and at least one civil servants at the Scottish Government had read.  Their failure to act completely undermined the Code of Conduct for Board Members which would never have been referred to the Commmissioner for Ethical Standard unless I had found out what happened through FOI requests.
The LLTNPA Board cover-up also discredits a number of statements and claims made in the draft Annual Report and Accounts:
  • “Our values are our moral compass; they help guide how we make decisions” (page 9 Annual Report).  So perhaps Board Members can explain what values make it ok not to report a fellow Board Member who was clearly in breach of the Code of the Conduct?   (I reported Board Members to the Commissioner for Ethical Standards but because there is no actual clause saying you should report other members who are in clearly in breach of the Code no action could be taken despite their failure to act with the principles behind the Code, such as integrity).
  • “The Convener of the Authority is personally responsible to the Scottish Ministers for ensuring that ……………there is probity in the conduct of the Authority’s Affairs (page 15 Annual Accounts).   So, did Ministers know about the Owen McKee case or was the cover-up simply agreed with civil servants?  (Linda McKay told Keith Connal, a senior servant, about the Owen McKee case and all suggestions of reporting the case to the Commissioner for Ethical Standards then appear to have been dropped.
  • “Notification of interests.  The Authority has detailed policies in place governing situations where personal or business interests may arise in the activities and decision of the organisation” (page 10 Accounts)  – why then there is no mention of why Owen McKee resigned or consideration of whether those policies are adequate?   While the Owen McKee case demonstrates the Park’s policies are totally inadequate  its the sense of moral compass on the part of the Board that is the real issue.
  • “The internal auditor’s annual report for 2015-16 states that based on the work undertaken over the course of the year, significant assurance can be given on the overall adequacy and effectiveness of the organisations’s framework of governance, risk management and control” (page 17 accounts statement from Gordon Watson as accountable officer)”.  Among the things Mr Watson fails to mention here is that the case was never reported to Audit Scotland and the Park had appointed Owen McKee, of all people, to its Audit Committee.   He goes on to say that as Accountable Officer he thinks the report is “balanced and fair”.
  • Finally, Audit Scotland in signing off the accounts is required to report if the Governance Statement does not comply with Guidance from Scottish Ministers.  The lead Auditor states (page 24) he “has nothing to report in these matters”.  This may well be true but if so show that the Guidance from Scottish Ministers is totally deficient as it allows Boards and its own civil servant to cover up breaches of the Code of Conduct.


It would be wonderful if any Board Member today was brave enough to admit the Park had made a serious mistake, that the truth about Owen McKee needed to be properly covered in the Annual Report and Accounts and the Minister for the Environment, Roseanna Cunningham, refused to sign off the Annual Report and Accounts until this happened.      I suspect this is unlikely to happen because there is a cosy coterie who are quite content with the corrupt governance arrangements that surround the National Park Authority which individual Board Members are not strong enough to challenge.


What we now know is that not just the LLTNPA Board and senior civil servants, but also Audit Scotland who appear quite happy that  breaches of the Code of Conduct for Board Members are covered up so long as they personally are not in breach of any rules.   To me this is little different to the bankers, lawyers and accountants who, when caught avoiding tax, always state they are not breaking any rules.  How about then the Board engaging with the public – or even their staff below senior management -on how they handled the Owen McKee case and asking whether they think they acted ethically or not?   This might help restore their sense of moral compass.


June 11, 2016 Nick Kempe 2 comments

The inclusion of a paper  Agenda Item 9 – Reducing litter in the National Park  for discussion at the Loch Lomond and Trossachs National Park Board  Meeing on Monday (13th June) is welcome.  The paper makes a number of welcome statements, which are very relevant to the issues which have been raised on Parkswatchscotland by myself and Nick Halls (e.g  Unfortunately  though the paper fails explore the full implications of these and the Park still has some way to go to articulate a comprehensive plan to address litter..

  • The paper states that litter is a problem almost everywhere in Scotland and makes the implicit acknowledgement (which was absent during the whole of the Your Park consultation process on the camping byelaws) that litter is a far wider and greater problem than something caused by inconsiderate campers.  What it fails to say is that the then senior management and the Park Board claimed to Ministers that the camping byelaws had solved the litter problems on east Loch Lomond: if Roseanna Cunningham had visited Balmaha last weekend she would have seen litter strewn throughout the village due to the numbers of day visitors dropping rubbish or having nowhere to put it.
  • The paper states that at the heart of the National Litter Strategy, published in 2014, is the idea of prevention, of getting individuals to acknowledge responsibility and that education is the key to this.   What the paper does not say is this conflicts with the claim made in the Your Park consultation that education had not worked and the only way to solve litter was to ban campers.  I am delighted the paper is putting education being put to forefront again but it begs the question of why the Park ever proposed camping byelaws
  • The paper describes the inconsistencies in litter collection arrangements by Local Authorities through the Park:  Stirling does not provide litter bins, West Dunbartonshire and Argyll and Bute do so, but only in some places, while and Perth and Kinross (which only covers a small area of the National Park) is the only Local Authority that does provide bins consistently.   What the Park does not say is that the 5 Lochs Visitor Management Plan back in 2012 was supposed to have produced a litter strategy by 2013/14 which would sort this out for a large part of the Park.  This was never done and now there are not even timescales for action.
  • The paper reminds Board Members that in the Partnership Plan 2012-17 there was a vision for litter recycling throughout the Park that people would use. What has not been stated is that this has clearly failed, not because people are failing to use litter bins (they are overflowing where they exist) but because they have not been provided.    What the paper does not say is WHY local authorities have failed to install litter bins or indeed why it has failed to do so on its own land.   The paper clearly states the LLTNPA is responsible for clearing litter on the land it owns, which is to be welcome, but does not explain why there are no bins at the carparks on the parcels of land it owns around Loch Venachar
  • The paper clearly states that local authorities have a duty to keep our roadsides clear of litter but makes no mention of their failures to clear litter alongside the main roads through the National Park (now partly covered by growth of vegetation because its summer) which have been highlighted on Parkswatchscotland
  • The paper refers to the Scottish marine litter strategy but makes no mention of the litter at the head of Loch Long, which is a blight to both the local community there and visitors,  that has been highlighted on parkswatchscotland and is again nothing to do with campers.
  • The paper provides background to the LLTNPA’s new policy and procedures on Fixed Penalty Notices (fines) for littering which are included as appendices to the report.  The paper makes the welcome statement that fixed Penalty Notices should be a last resort, that education should come first.   The irony is that if this approach rather than the NIMBY one had been used for problems associated with campers the camping byelaws would never have been proposed.  Unfortunately the paper and the accompanying policy and procedures do not explain how education first might work in practice.   The reason why Countryside Rangers should have the power to issue Fixed Penalty Notices is not to turn them into a quasi police force (which is what will happen if the camping byelaws go ahead and which is why the Scottish Countryside Rangers Association objected strongly to them) but to give them “authority”.   It would allows Rangers to explain, when they come across evidence of people dropping litter or picnicking or camping next to a pile of rubbish, not just to explain to people why they should not do this but to ask  them to clear it up then and there.  If the person/people ignore them, then they can issue the fine but, with the right communication skills, I believe this should rarely be necessary.
  • The biggest omission in the paper is the failure to mention the role of the Forestry Commission Scotland, the large landowner in the Park, and its role in addressing litter.  So just what is it planning to do?    Nor is there any mention of the role of other landowners, the positive things they are doing at present (eg Luss estates does regular litter pick-ups) but also, most importantly their role in creating litter.   Farm litter in the National Park or the litter associated with some of the current industrial developments in our countryside is arguably a greater problem than any litter left by visitors.
  • The paper mentions but makes no proper evaluation of flytipping, which is mostly undertaken by local people or businesses, not visitors.  The huge dump on Loch Loch is another national disgrace but there are many smaller examples.  Its great the LLTNPA now has powers to address this through fines but what actually is it going to do?
  • The paper also fails to mention the role of local tourism businesses in generating litter.  Now many businesses in the National Park have been at the forefront to clear it up but there are some businesses that generate much of the litter that is dropped, particularly in the tourism hotspots where people buy their ice creams on a sunny day and then drop the wrappers.   There is no mention of what these businesses could do either to provide litter facilities or give out messages (“please put all packaging in the litter bins we have provided”.
  • There is also no mention of the role of the Park’s own Ranger service in collecting litter.  In the absence of litter bins, if they are not allowed to put litter in the Park’s vehicles for alleged health and safety reasons and are forced to put this by the roadside for collection, any member of the public seeing them will do the same.   And we all know what happens to rubbish left out for collection, wildlife has a feast and in doing so scatters it once again.
  • The paper makes no mention of the Keep Scotland Beautiful Audit of litter in the National Park which was supposed to be published shortly after the meeting of the Board in October last year

In summary, while the paper is a useful indication of how a strategy might be developed – and therefore a step forward – it unfortunately it has been produced under a Board which up until now appears to have thought that camping byelaws would be the Park’s answer to everything.  The paper is welcome because it does provide an alternative to the flawed logic which led to the proposed camping byelaws – if banning camping is the answer to litter left by campers, then banning drivers would be the answer to the litter thrown out of car windows along the A82 – and has started to suggest alternatives.  If this leads to a change in approach, it is very welcome but to do so the Board will need to endorse a change in direction.  Here are some suggestions about how this could be made to happen:

  • The new Minister for the Environment, Roseanna Cunningham, who chairs the annual review of the Park’s Partnership Plan, should call a special meeting of the Park and Local Authorities to review the lack of progress they have made on installation of litter facilities and set clear timescales for production of implementation of a litter strategy.   She should also insist the Park develop a proper plan – the Five Lochs Management Plan had a section outlining the actions needed on litter which have sadly never been progressed but would provide a good starting point.
  • The new Minister of the Environment should now acknowledge that campers only account for a small proportion of litter problems in the National Park and littering is not a justification for the removal of access rights.
  • The LLTNPA needs to be told that its litter strategy must  include a plan for addressing marine litter (including exploring the implications of the National Marine Litter strategy), farm litter, dumping and rubbish left by developers
  • The LLTNPA, instead of imposing education messages on people, should engage with visitors about what messages might influence them to take even more care because it’s a National Park.  It should also consider how it can use people who care about the countryside most, which includes walkers and campers, to spread the message.  This means engaging with the recreational organisations such as the Ramblers and all the activity organisers who use the Park at present and whose activities are now threatened by the Park’s proposed bye-laws.
June 9, 2016 Nick Kempe No comments exist

The Herald yesterday (8th June) carried a story that has now been recycled several times about the Mountains and People Project which is investing £6.1m in footpaths in our new National Parks.  The new angle was hillwalkers are being asked to report footpath problems, far from a new idea but good stuff.

What was new was the quote from Roseanna Cunningham, the new Minister for the Environment, who said that no-one cares more deeply about conserving our landscape “than those who walk our hills and countryside regularly”.   She is to be congratulated for saying this, but having said this I hope she will now ponder the logic of her predecessor, Aileen McLeod, to approve the Loch Lomond and Trossachs National Park’s camping bye-law proposals.  These will of course these very same people from enjoying the landscape in what is the best way possible, by not just walking through it but by staying in the outdoors.

The story was also, as is often the case, as interesting for what was not said as for what was:

  • Our National Parks were set up in part to improve infrastructure for visitors, such as paths, so why is Heritage Lottery Funding needed to do this?   If National Parks are not funded sufficiently well to do this themselves, what hope for the rest of the country?
  • The majority of the Heritage Lottery funding for the Loch Lomond and Trossachs National Park is going to Forestry Commission Scotland to fund pathwork on hills such as Ben A’An and Ben Venue in the Trossachs and the Arrochar Alps.   While FCS is making a financial contribution, far more money will be spent on FCS paths by the Mountains and People Project than what it has put in.  Why does FCS not have the funds to do the jobs its needs to do?  Is it misspending its resources, buying places like Rothiemurchus for £7.4m, or does it simply not have enough to achieve its objectives?
  • Arising from this lack of public finance, are questions about the project itself?  How will all the people who are to be trained in footpath work – and who were pictured in the paper – get jobs at the end of it?   Is the project training yet more people who will end up without a job due to a lack of finance, austerity?    Is there any point in getting hillwalkers to report problems if in three years time there is no-one left in the Park able to fix them?


Now, I intend no criticism here of the staff who have put this proposal together and obtained the funds.  They are having to work in very difficult circumstances, where due to the prevailing neo-liberal ideology, proper funding is not available for mountain paths among a multitude of other things.   So they have to scrape funding together and all credit to them for doing this.  We kid ourselves though if we fail to consider and alert people to the  wider implications.


So, the first thing that needs to be said is that we need far more investment in footpaths across Scotland and the Scottish Government needs to find ways to enable this to happen.   Walking is accepted as the single most effective way of people remaining health and getting people walking more is a national priority.   You would have thought therefore that investment in footpaths would be a political priority but its not.  In this respect walking now lags behind cycling where there is now a national commitment to increase levels of investment (even though this is far from enough).   Cycle funding though has benefitted our National Parks, for example the new cycle path between Drymen and Balmaha which is funded through Sustrans.  In the footpath world though there is no pot of money and no mechanism to channel public funds, hence the need for the Mountains and People Project.  I realise public finances are difficult but nationally believe we neecd to see a proportion of the roads budget, to increase year by year, spent on footpaths.


There are though also solutions at the National Park level and our National Parks could take a lead on this.  While I know Board Members have bemoaned the lack of funds for footpath work at Board Meetings, none are prepared to speak out and instead allow their staff to issue congratulatory press releases which only tell a small part of the story.    If Board Members are not prepared to criticise the Scottish Government, they could nevertheless put their own house in order and clearly state that there is not nearly enough funding going into footpaths and other visitor infrastructure and then lead by example.   They have a solution to hand and that is through the introduction of a tourist tax in the National Park (see previous post tourist taxes).

If they did this now, there might just be enough money available to provide jobs when the money runs out in three years time to some of the people who have been trained through the Mountains and People project.

June 7, 2016 Nick Kempe No comments exist

Raptor Persecution Scotland published a piece today  about the BBC Countryfile programme at the weekend on the Invermark Estate and the recent history of persecution in the Angus glens.  The list of crimes, most never “solved” or brought to justice is horrific.   In the interests of accuracy though its worth stating the vast majority of incidents that have been recorded took place on other estates and outwith the National Park boundary.    The BBC presenter however did not even ask Invermark how raptor persecution by these other estates affected the wildlife part of its business.


By chance earlier this week I came across these photos of estate signs from Invermark taken in 2005.

Invermark Estate sign 2005.  Two years after the Land Reform Act granted us access rights the estate still had signs up stating “Estate Path.  Access at discretion of estate”.
Invermark Estate sign 2005. There has never been any significant evidence that walkers or other visitors disturb raptors

In support of Raptor Persecution Scotland’s case, I would suggest the only reason for such signs is that greater visitor numbers increases the likelihood that the public will come across evidence of illegal activities.   Evidence from the past that the Invermark Estate is perhaps not as pro-wildlife as portrayed by the BBC and a very strong reason to preserve access rights.  Note how the estate was anti-camping  (just like the Loch Lomond and Trossachs National Park Authority, which is strongly supported by Scottish Land and Estates).  I suggest a major reason for this is that  campers are out in the field for far longer than walkers and therefore far more likely to come across evidence of raptor persecution.


The BBC missed another angle on Invermark.   All the estates within the Cairngorms National Park have been asked to produce estate management statements and Invermark was one of the estates that did so (many did not).   The Invermark Estate Management Statement  makes interesting reading, not for what it says, but what is left out:

  • There is no mention that much of the Invermark Estate is part of the Cairngorms Special Protection Area designated for its golden eagles (the BBC should have asked, if hare numbers had increased on the estate as claimed in Countryfile, whether eagle numbers had too and if not why not)
  • There is no mention of predator or vermin control.  So, which species do the estate regard as vermin and control as such?
  • There is no mention of red deer numbers, what the estate believes as a sustainable number and how these will be controlled (not surprising perhaps because the estate factor, Richard Cooke was long the secretary of the Association of Deer Management Groups which has done such an effective job lobbying politicians in Scotland to prevent any effective controls on deer numbers).
  • There is no mention of how the grouse moors will be managed, such as the extent of burning and medication of grouse
  • Or, one might add, from the two events that Raptor Persecution Scotland’s have listed as taking place on the estate, what it might do to prevent destruction of peregrine’s nests (as happened in 2004) and to protect trees where raptor are or have nested (January 2013 White Tailed Eagle nest tree felled).    Evidence of estate determination to stamp out such practice could include contracts of employment that clearly describe such actions as gross misconduct which would lead to instant dismissal.


While the Cairngorms National Park Authority was no doubt well intentioned when it asked the estates within the National Park to produce management statements, by publishing statements such as that from Invermark,  it has in effect endorsed them.   This, I suggest,  undermines the statutory conservation purpose of the National Park because there is complete avoidance of almost all the things that matter from a conservation perspective – and the Invermark Estate Statement is typical in this respect.


The solution is for the CNPA  to lead by example and require  management statements from ALL estates within the National Park setting out how they will meet the Park’s conservation objectives and putting in place sanctions for those that fail to do so.  Part of every statement should include what the estate will do to prevent raptor persecution.   Such statements should form part of a much wider plan of action to address raptor persecution and other conservation failures which I have outlined in previous posts























June 7, 2016 Nick Kempe 1 comment

On 27th May the Loch Lomond and Trossachs Park Authority advertised a planning application to create a new 30 place campsite at Loch Chon.  You can find all the papers through the Park planning portal


It is bizarre that the LLTNPA is applying to itself for planning permission when the land is owned by Forestry Commmission Scotland.   In their response to the Your Park consultation the FCS stated it would support new campsites but had no money to pay for them.  Leaving aside the fact that FCS appears to have plenty of money to lavish on private landowners, rather than the public  (it paid John Grant £7.4m to purchase Rothiemurchus), it now appears that FCS are basically taking nothing to do with campsite provision and are leaving LLTNPA to do everything.   This is totally wrong.  FCS are a public body with a recreational remit and should be serving the public.  Instead the FCS seem to have the Park wrapped round their little finger and, now they are no longer able to introduce their own camping byelaws, using the LLTNPA to do this for them as at Forest Drive by the Duke’s Pass


The Planning application contains no justification for this campsite.  I had previously asked the Park for all information they held about why they had decided to construct a campsite here and they have refused it (and that case is now with the Freedom of Information Commissioner)   The background was given in a previous post which showed there is no demand for a campsite of this size in this area and called on the LLTNPA to publicly justify their plans.


Objection from Local Residents

A similar point has been made in a objection from two local residents who have questioned the size of the campsite and the proposals for managing it (there are now three objections from residents on the planning portal).   Put simply, the proposed campsite will either be a white elephant and not used or, if used, will have attracted far more people into the area without any plans for how this influx will be managed.     While I am against the NIMBYISM which is so evident among some people who are fortunate enough to live in the National Park, I thought this letter and the other letters of objection lodged on the Park’s planning portal have made some excellent points:

  • The residents question the proposal to use old shipping containers for the toilets, store and equipment room.  The Park says the containers will be plated with aluminium and painted – their illustration shows trees painted on the sides.    I think the residents are right, these will look dreadful from the start.      At present there is a glut of old shipping containers across the world  and they are now being used to provide housing in places like Africa.   So, they are cheap.  While I am sure the Park will justify their use as their contribution to recycling what about  supporting the local wood products  industry and constructing  toilet blocks which are in keeping with the National Park?
    The forest plantation on the southside of Loch Chon which was being harvested earlier this year. Neither FCS nor LLTNPA have given any consideration to using this wood to construct toilets on the proposed campsite.

    Is it really so hard  to construct buildings out of locally sourced natural materials land help sustain local employment?    If the LLTNPA really does want to make a contribution to world recycling, it could use these containers as temporary toilet blocks, like portaloos, and install them in the places most popular for camping over the summer. 

  • How is the Park going to hire out firepits when there is no warden on site?  To which I would add, why cannot this Park Authority provide anything for free?    If fires are such a problem as claimed by LLTNPA, surely every camping place should have a fire pit?     But then, given the lack of demand for camping here, this would be throwing more good money after bad.
  • Why is the Park wanting to install gates?  An excellent question.  A reader of parkswatchscotland recently pointed out to me that the gates that had been installed at Loch Chon made it very difficult for canoeists to access the loch.   Throughout the National Park the LLTNPA, which has a statutory duty to promote access, has been busy installing gates at carparks, the only purpose of which can be to stop access.  This NIMBY culture in the LLTNPA  affects the rights of local people as much as visitors.

Other reasons why the application should be rejected

The Park is proposing to provide some of the 30 proposed places – its unclear how many – on wooden platforms.     Now, I don’t think any camper in their right mind would want to camp on a wooden platform (I know it happens on sand dunes in Australia) and this illustrates two serious issues.   The LLTNPA has simply failed to consult with campers about fire pits, places or anything else.   Either none of its staff have ever gone camping or more likely senior management in the Park have simply failed to consult their staff who do camp and could tell them what makes a good camping place.      The second issue is that there is simply not enough ground in the area the Park has identified for a campsite to support 30 camping places.

The path that goes through the proposed camping area. As the site plan states, much of the area is too boggy or steep to provide good places to camp but the Park wishes to fit 30 tents in a place that could sustain a third of that number.  The only reason for doing this is so it can say its delivered some new camping places.
The area to the east of the current carpark is unattractive for camping and, while its been left out of the plans, similar areas have been included.



At present,  the area around the lochshore close to the proposed campsite is  the most popular for camping around Loch Chon, although people do use several other places (often to fish).  However, the Park wants to stop all this and herd people onto an area of slightly higher ground above the loch.   One reason there are not more people camping at Loch Chon at present is simply that the number of good places to camp is limited.  Creating camping platforms is not going to change this.


The design of the campsite is shown in the .Loch Chon 2016_0151_DET-Engineering_Layout-100262476 and there is an accompanying design statement produced by the consultants Loch Chon 2016_0151_DET-Loch_Chon_Design_Statement-100262485


Remains of fire Loch Chon
The best places to camp, by the loch shore, are NOT included in the campsite area

The Design Statement states that are no camping places by the shore as  “this will minimise visual impact on visual receptors such as canoeists on Loch Chon”.  Its great to know the views of canoeists are so important but I am sure neither the consultants or the LLTNPA bothered to consult the Scottish Canoe Association.   The SCA strongly opposed to the byelaws precisely because their members need and like to camp on the loch shores.   The statement is doubly ironic given that canoeists have been prevented from accessing Loch Chon  by the gating of access tracks which prevent anyone getting the vehicles or trailers that carry their canoes close to the water.


The Design Statement claims that “camping pitch locations………will allow for a range of experiences loch-side, burnside, high level”.   Ignoring the fact there are no lochside places planned, this is patronising drivel but it illustrates the mindset of the LLTNPA.  You need to remember the Park is intending to try and force people to book places:  “I am sorry Mr Kempe but the burn-side places are not available tomorrow but we suggest that if we allocate you a high level place that might expand your horizons”.    Petty bureacracy to replace access rights.   I really don’t believe this is coming from frontline staff.


The  Design Statement describes the Loch Chon con as a semi-formal campsite.   One of my objections to Park’s Development Plan was it used totally different terminology to the Your Park Plan which produced the byelaws Response – Development Plan and Camping.   A case of two parts of the LLTNPA bureaucracy failing to talk to each other .  Your Park used the terms “basic” and “limited” facilities, while the Development Plan – which is still to go to a Public Local Inquiry – used the terms “formal”, “semi-formal” and “informal” campsites.   A semi-formal campsite, according to the draft Development Plan approved by the Board, appeared the same as an informal site except it could have low level lighting.   Informal sites were defined as having no water or drainage, while both informal and semi-formal sites could have temporary or composting toilets.    From the Design Statement it appears the definition of semi-formal campsites has changed so semi-formal campsites will now include waste water treatment and a water supply while the toilets can be permanent as well as temporary.  It is good the LLTNPA  has made the definitions clearer, even if it is unclear who authorised this change or if they have replaced the Your Park terms – but then the LLTNPA takes lots of decisions behind closed doors.   .


The new definition of a semi-formal campsite however has had the consequence that such campsites now require formal planning permission, which in turn means the LLTNPA has to meet not just its own but other public authorities rules.  This has created a whole set of new problems.   Stirling Council’s Flood Officer has even objected formally to the application due to a lack of information on drainage culverts.  The risk of flooding may be an additional factor which explains why there are no camping places proposed by the loch shore where most people  want to camp.  Indeed part of the application includes a proposal by the LLTNPA to operate the Scottish Environmental Protection Agency’s flood warning system only for SEPA to point out that their system does not cover the area!  To add to the planning shambles, the Stirling Flood Officer has pointed out the road to Loch Chon, the B829,  floods regularly  so there would be difficulties evacuating campers.



All of these bureaucratic problems could have been avoided if the LLTNPA simply allowed people to camp as at present under access rights and take their own decisions about where it was sensible to camp.   To minimise the impacts of people camping here, the LLTNPA could have recommended to FCS that it should take responsibility for its own property and install couple of composting toilets and some litter bins.       FCS could have done this for under £20k instead of the £345k or so the Park has budgeted.  I am sure would have been welcomed by local residents.   To address the concerns about anti-social behaviour raised by local residents, the LLTNPA  should have been talking to Police Scotland about their role and how they could respond.    As the letter from two local residents clearly states  anti-social behaviour can take place in campsites just like anywhere else.    Only good policing will address that.


The amount of money the Park has devoted to the Loch Chon proposal could have been far better spent.   According to the Park’s end of year budget report to the Board it was aiming to spend £100k by the end of the financial year 2015/16 year  on the proposals.   I had previously wondered if this money had been spent because there had been no signs of work on the ground.  Its now clear now from the papers appended to the planning application it must have been spent on consultancy to produce plans for the campsite and environmental assessments.   The environmental assessment took place in January – not a good time for surveying wildlife and not surprisingly came up with a list of common birds.   I intend no criticism of the consultants but this was a bureaucratic exercise for what?   A poorly designed campsite for which there is no demand and on which it is planned to spend another £245k this financial year.


What the LLTNPA should have been doing, is what it should have been doing across the National Park, and that is to consider what basic facilities would help those exercising access rights (not just campers) to do so responsibly and to do so in consultation with both local communities and recreational bodies.    It could even have allowed local communities to make bids to install new camping facilities in their area – I am sure they would have spent the money being wasted on Loch Chon far more effectively.


If you want to comment on or object  to this proposal you can do so on the Park’s online e-planning facility or send an email to   If you are objecting make sure you head whatever you say “Objection”.  The reference for the application is 2016/0151/DET


June 6, 2016 Nick Kempe 2 comments

The Strathie carried an article last week that Natural Retreats, the company that operates “Cairngorm Mountain” on behalf of Highlands and Island Enterprise, has dropped its plans to rebuild the Day Lodge complex by the Coire Cas carpark   This would have included new facilities, such as a conference centre.   This is to be welcomed.  It would have been a tourist facility in the wrong place.

Day Lodge 3rd June. The altitude of the
Day Lodge Friday 3rd June 2016, not a sensible location for a conference centre
The funicular was practically empty - its amazing that anyone would take a journey even further into the cloud
Funicular 3rd June.  It was practically empty – why would anyone take a journey even further into the cloud?  As in the Alps, the cloud drops and so do visitors.  The problem at Cairngorm from a tourist viewpoint is the number of days the summit is in cloud.



The decision by Natural Retreats I am sure is partly driven by money.  They have realised, after a winter season, there is no point throwing good money (they had talked about investing £10m in buildings) after bad.   Their focus, in terms of buildings, now appears to be on internal refurbishment of what is there.   While this is to be welcomed its only part of what needs to be done.


The external environment in the ski area continues to be a disgrace for a National Park.

The chairs from the former Coire na Ciste lift have been simply dumped along with other rubbish


Buildings currently in use may be being upgraded but what is being done about the abandoned ones? Restoration?
Buildings currently in use may be being upgraded but what is being done about the abandoned ones?





If the Coire na Ciste building, as the signs indicate, is not safe and cannot be restored it should be removed



There were no fewer than three skips at Coire na Ciste but unfortunately the commercial rubbish that should have been in them wasn’t.





















In Coire Cas there are plenty of signs of a similar lack of care which are unfitting for a National Park.   This is not a good visitor experience, particularly in summer when the  extent of the rubbish and neglect is more obvious.IMG_6116

Old cables straddling the burn – would it really be so difficult to remove these?

Many of the eyesores pre-date Natural Retreats but some are much more recent. Could they just not clear up as they undertake work instead of treating the natural environment as a poorly run building site?


The cloud parted for ten minutes. Expensive machinery is simply left outside to rust. There must be a better way to stop this looking like a building site. What do visitors on the funicular think when they look across to this?   There needs to be a store for machinery but it needs to be big enough and in keeping with the natural environment.  Why not bury it into the hillside?
The concrete plinth and all the industrial waste should be removed and a new place found to store spent fuel (in the red and blue metal containers)

Keeping the ski area in a manner fitting for a National Park – or indeed for any quality tourist facility – should have been part of the HIE lease with Natural Retreats.  I have asked HIE for a copy of the relevant parts of their lease.  If there are conditions about the general state of the environment they need to be enforced.  If not, HIE should pay for the cleanup, after all its the landowner.   The Cairngorm National Park Authority needs to use its powers and influence to get the external environment tidied up as a pre-condition to agreeing anything else.


I believe Natural Retreats’ decision to drop its development proposals provides a great opportunity to re-consider what could be done to improve the Cairngorm ski area  and  make it more financially viable within a wider context of how Cairngorm and Glenmore should be managed.  A draft strategic plan for Cairngorm and Glenmore, which was put out for consultation earlier this year,  treated the ski area in isolation from Glenmore.   This has been a problem ever since Highlands and Islands Enterprise purchased the ski area from the Forestry Commission.  What we now need is some joined up thinking and I would suggest the current model, in which Natural Retreats is expected somehow to make the ski area become a financially viable operation in itself, needs to be rethought.    I will outline a vision for how this might be approached in a post later this week which will focus on the potential of the natural environment at Cairngorm as a means of making the ski area into a sustainable tourist attraction.

June 2, 2016 Nick Kempe 3 comments
Glen Derry
Glen Derry

I have been meaning for a couple of weeks to refer readers to the excellent piece from Neil Reid, the Cairngorm Wanderer on the National Trust for Scotland’s latest proposals to renovate Derry Lodge

Plans announced for Derry Lodge development


I remember discussing the future of Derry Lodge at the Mountaineering Council of Scotland twenty years ago with the main options being to knock it down and restore this as an area of wild land or to turn Derry Lodge into an Alpine-style hut.   The lack of action since then is all about money, about the the National Trust for Scotland operating under a model in which it is expected to fund the vast majority of its activities despite being a national resource and struggling to do so.  It has consequently lurched from one financial crisis to another and is undergoing yet another internal restructuring at present driven by the need to balance its books.    With large historic buildings to maintain, the consequence is that Derry Lodge is a low priority and I fear that despite the good intentions of the staff who are behind these proposals, nothing may happen.    The wider financial issue is really about how do we get financial investment in rural areas.  There are lessons here from Alpine Associations on the continent and how they manage to raise funds to renovate mountain huts in locations which from a construction viewpoints are far more challenging than Derry Lodge.


The other big question is how the proposals to renovate Derry Lodge sit within the need to protect and enhance wild land – the central Cairngorms are after all one of the largest areas of wild land in the country.   Why not just knock it down?   And what is the difference, if any, between renovating Derry Lodge and installing a new run of river Hydro scheme in Glen Derry?


The arguments about the importance of wild land led the NTS to remove the bulldozed track from Glen Derry above the old lodge building and, along with nature conservation, helped drive the reduction in deer numbers which is allowing the pinewoods in Glen Derry and Glen Lui to regenerate.  So, keeping wild land values and concepts of rewilding to the forefront of thinking about Derry Lodge seems to me very important.


In this large area of wild land, the existence of Derry Lodge and a few bothies, has very little impact.  The Lodge is well screened by trees and sits at one of the main entry points for walkers and climbers to the central Cairngorms.   NTS’ proposal to include public toilet facilities would address the main human impacts on the area.   Its worth contrasting Glen Lui with Glenmore, where the road intrudes well into the mountain core and new development high up on Cairngorm  is continuing.   There are far bigger issues affecting wild land and landscape in the Cairngorms National Park.


In addition, Derry Lodge is regarded by most people as an attractive building.   NTS would have significant issues getting agreement to demolish it because it is bound to protect and conserve the historic buildings it owns.   From a cultural viewpoint too, the area has a well known history, including use by mountaineers.   All of this seems to me to be a reason to support the proposals.  This is not about new development as such but restoring an existing building in a way that should help conserve the landscape and enable people to enjoy it.


Lower Glen Lui – few signs of rewilding

While supporting the proposals in principle,  I do think there is a strong case that the renovation of Derry Lodge should be considered alongside what could be done to re-wild lower Glen Lui.    This is still dominated by the track and forestry plantations and walking or cycling along it is far from a wild land experience.   The main reason the track has been kept is again one of money, the cost of culling deer without NTS vehicles being able to transport stalkers to Derry Lodge would be considerable.    It would be good though if the NTS  vision included the case for converting the track into a footpath and outlining the  public financial assistance it would then require to continue effective deer culls.    Together with plantation restructuring this would make the approach to Derry Lodge a far wilder experience. Part of this vision could be that one day Derry Lodge provides a refuge for people uncomfortable with the idea of camping in places where wolves or lynx roam, that it part of the core wild land area and not on the edge of it.
















June 1, 2016 Nick Kempe 2 comments

Cameron McNeish has some interesting comments to make on National Parks and the political priorities for the new Scottish Government in the latest Walkhighland newsletter    In it he states he believes the reason the SNP did not commit to more National Parks was lack of cash – or to put it another way because of current UK Government policies of austerity that arise from neo-liberal economic thinking.


Raising more money in taxation is the main alternative to austerity and while the Scottish Parliament can do relatively little to raise taxes at the national level, one thing it could do if there was the political will would be to encourage the introduction of tourist taxes.   A campaign for a tourist tax in Edinburgh is now gaining momentum.  An eloquent case for this was made by Rosemary Goring in the Herald yesterday  but why not also for the countryside?


Our existing National Parks would be a good place to start.   The issues faced by the Loch Lomond and Trossachs National Park in particular are not dissimilar to Edinburgh – litter, eyesores, congestion  – and as Rosemary Goring says are both practical matters and about aesthetics.  A tourist tax would enable improvements in visitor management such as public toilet provision, litter collection etc.   A quick look at the statistics indicates that between 2009-11 on average foreign visitors spent 2.4m bed nights in the LLTNP.  An average charge of £1 a night bed tax would raise a lot of money from people who otherwise make no direct contribution to the National Parks (the VAT they pay on hotel nights etc goes to the UK Government).


Such money I believe should not be used to replace central Government funding but as additional monies to invest in rural areas.  The best way to ensure this happens is not to add any money raised to the National Park’s or Local Authority budgets but to devolve it to local communities, as on the continent.  In Europe there are many examples of where local communities get to decide where to spend monies raised in their area in a way that benefits both local residents and visitors.  This wold empower local communities against the centralising trends in Government in Scotland.


While such a model could be replicated across rural Scotland the National Parks would be an ideal place to start as they have the infrastructure to support the roll out of such a tax.  There are already some initiatives in our two National Parks which raise money from businesses on a voluntary basis and my suggestion is this should be developed into a tourist tax.  The tax would be on the tourists not the business and the main cost to the business would be in accounting for it, a small price to pay for increased local investment which can only benefit them.    In my view such a tax should also be proportional rather than flat rate, so people staying in expensive hotels pay more than people camping.