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 http://parkswatchscotland.co.uk/2016/05/27/disappearing-campsites-loch-lomond-trossachs-national-park-development-plan/.) 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! http://www.lochlomond-trossachs.org/planning/online-planning-information/menu-id-595.html
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EIR 2016-018 now at last admits admits that the original plans for the north Loch Venachar site have been superseded: “As stated in FOI response 2015/026, the Park Authority has been reviewing approaches to camping management and provision in the 5 Lochs areas as part of the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 The original proposals…………have been superseded”.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?
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.
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
- 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?
- Who authorised the submission of a planning application 2014/0264 which clearly precluded the possibility of developing a campsite at North Venachar?
- Which members of the Senior Management team and Board knew about this?
- Why did the Chief Executive, Gordon Watson, allow his staff to persist with claims that no decision had been taken?
- What alternatives have now been identified to the north Loch Venachar site?
What needs to happen?
- The LLTNPA needs to start operating transparently
- 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
- The consultation should include engagement about all the campsites that were previously approved as part of the Five Lochs Visitor Management Plan
- Authorisation of recommendations for campsites that are opposed by local communities or recreational organisations should be taken at public Board meetings
- 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)