Month: July 2016

July 29, 2016 Nick Kempe 2 comments
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Ledard Farm, by the southern path to Ben Venue off Loch Ard, home to Board Member Fergus Wood

In my first post on the proposed campsite at Loch Chon and camping in Strathard, I included the two photos below and questioned why, since its since its impossible to camp along most of the north shore of Loch Ard, this area had ever been included in the proposed camping ban?

The flat headland opposite Ledard House, at the start of the southern path to Ben Venue
The flat headland opposite Ledard House, at the start of the southern path to Ben Venue
Most of the Loch Ard shoreline looks like this
Most of the Loch Ard shoreline looks like this








I had not appreciated at the time that Board Member and SNP Councillor Fergus Wood has a 50% share in Ledard Farm Ltd  and the land in the first two photos.  I should have because, although Fergus Wood was not present at the Board Meeting of April 2015  where the Board endorsed the proposed byelaws without any Board Member making a declaration of interest about owning property in one of the proposed management zones, he was present at the meeting in October 2014.   At this meeting,  unlike that of April 2015,  Board Members did declare whether their properties were in the proposed management zones and Fergus Wood was one of four members to declare “a potential interest” Minutes of meeting held on 6th October 2014 Draft v1. The other members to declare ownership of property in the zones being Convener and member of the Management Board of the civil service in Scotland, Linda McKay, fellow Stirling Councillor for the Teith and Trossachs ward, Martin Earl, and the disgraced Owen McKee.


Recorded in the minute is the following:

  • “Members discussed the areas included in the proposed management zones”, and  
  • “Members proposed that page 19 of the consultation document be updated to clarify that we are interested in hearing from all landowners interested in campsite development within the National Park i.e. those inside and outside the proposed management zones.”

There is nothing in the Minute recording any member leaving the meeting for this part of the discussion or making any further statement about their interests.


This is quite a contrast the Board meeting in June 2016 where the Park’s camping plan was on the agenda and Councillor Fergus Wood declared an interest at the beginning of the meeting, without to my recollection specifying what this interest was, and then left the meeting for the camping discussion.   While I will ask the LLTNPA to clarify the exact nature of this interest and this may eventually be recorded in the Minute (which is not due to be published until a few days before the next Board Meeting), it seems likely that Fergus Wood was in discussion with the Park about provision of a campsite on his land – most likely the land in the first two photos above – and as a consequence his interest was of a financial nature.  (If Fergus Wood had been going to provide land for free, whether for a formal campsite or for people to camp under permit,  its hard to see why he would have had to leave the meeting).  It was entirely appropriate that if he had a financial interest he left the meeting.    It would appear from Gordon Watson’s statement (see previous post) that there are now no plans for further campsite provision in Strathard apart from Loch Chon and the proposed permit area on the south shore of Loch Ard, that whatever discussions took place with Councillor Wood have now terminated.


Now the point of reporting all of this is because it raises questions about the nature of Councillor Wood’s interests in the Your Park proposals at the time they were being developed.  That he did have interests has been demonstrated by his leaving the June 2016 Board Meeting.  If it was appropriate for Fergus Wood to have excluded himself from that discussion, why does he appear to have participated in the Your Park discussion in October 2014 which explicitly considered the boundaries of the proposed management zones and landowners role in campsite development?    As the co-owner of Ledard Farm Ltd, which has plenty of suitable land for a campsite, throughout this period how could he have sat through that meeting without a thought about the potential for him to develop a campsite on his land – particularly when landowners were explicitly encouraged to come forward with proposals?  Or how ensuring byelaws were in place along the north shore of Loch Ard might not help make such a campsite a financially viable proposition?   After all Gordon Watson, the Park’s Chief Executive, is on record as saying that one reason for the camping byelaws is that without them the Park did not believe people would use campsites.


The LLTNPA’s Code of Conduct for Board Members states:

“You must, however, always comply with the objective test  (“the objective test”) which is whether a member of the public, with knowledge of the relevant facts, would reasonably regard the interest as so significant that it is likely to prejudice your discussion or decision making in your role as a board member of the Authority.”


Fergus Wood clearly acted appropriately in terms of the Objective Test in June 2016.   The question is whether he did so in October 2014 and, one might add, all the other secret discussions that took place on the development of the Your Park proposals?   The Commissioner for Ethical Standards in Public Life is formally tasked with answering such questions but normally only considers alleged breaches of the Code of Conduct within a year of their occurrence.  It is now almost certainly too late for him to consider this matter.

July 26, 2016 Nick Kempe 2 comments

A fair amount of information has come to light in the last three weeks about the LLTNPA’s camping plans which raises serious further concerns about both the adequacy of those plans and the whole camping byelaw proposal.


Camping in Strathard


It says a lot about the LLTNPA that they have kept their camping development plan secret, refusing on a number of occasions to divulge it under FOI legislation on the grounds that it is not yet finalised or else that this would prejudice negotiations with landowners.   However, after local residents in Strathard  demanded more information from the LLTNPA about their plans at a public meeting on the Loch Chon planning application (see here), they have been forced to provide some basic information. Strathard Community Council should be congratulated for publishing all the information they have been able to obtain on their website


The information includes the written response loch_chon_gw_13_july they received from Gordon Watson, the LLTNPA Chief Executive, following the public meeting.   For the first time this makes public how the LLTPNA intends to apportion the 300 places it has committed to providing across the four “management zones” where camping is banned.  It also shows I was not entirely correct to suggest (see here) that another campsite was being planned at Loch Ard on land owned by local Board Member Fergus Wood – instead an area has been identified where camping will be allowed under permit.   Almost every point made by Gordon Watson raises serious concerns and illustrates the fundamental incoherence of both the proposed bye laws and the Park’s camping plans:


  • South Loch Ard Permit Area (point 1).  Mr Watson provides a map of the proposed area southlochard.    Its on the very edge of the proposed management zone.   Now I guess some fishermen may be prepared to pay for a permit to be able to camp nearer to where they want to fish but for anyone else, they are likely to simple move over the line to where they can camp for free.   A campsite at Loch Ard with basic facilities would help reduce impacts, e.g through provision of a toilet, and could be attractive to visitors but having to pay a fee to camp in a place the Park is saying people will need to walk to when they can walk ten steps further and camp for free is unlikely to be attractive anyone.  Who thought this up or is it simply so the LLTNPA can claim to have “provided” 300 camping places?
  • Extent of provision (point 3).  Mr Watson states that within the proposed West Trossachs zone, which extends from Loch Ard to Loch Arklet along the road to Inversnaid,  “there is no other plans for camping provision apart from the campsite at Loch Chon and permits in an area by Loch Ard”.   What this means is:
    • No-one will be able to camp along the north shore of Loch Arklet, where the bye-laws were extended after consultation.   It doesn’t matter if you are fishing or using the underused path along the north shore for cycling or camping, you won’t be able to camp.
    • The LLTNPA’s oft repeated claims that the camping bye laws were needed because of the sheer number of campers are complete bunkum.   This is not about a reduction in numbers, it’s a complete ban – there is no evidence that the north shore of Loch Arklet is a particularly sensitive site and the  evidence of the Park’s own ranger patrol records is that very little camping ever took place along this shore anyway.    There is no justification for this, legal or otherwise and its a complete abuse of power.   In how many other places is the Park intending to ban camping completely without any justification?  No wonder the Park is refusing to reveal its plans.
    • Since all the “pitches” in the proposed campsite at Loch Chon are located away from the loch shore and GW has confirmed there will be no permits, no-one will be able to fish from their tents in future around Loch Chon.   A large number of campers by the lochsides are fishermen, most are responsible and all require permits to fish (which is outside access rights), but the pleasure of being able to sit by your rod and tent will no longer be possible in this area of the National Park except for the small permit zone at Loch Ard.   Is the intention of the LLTNPA to replicate this across all the management zones and destroy the tradition of folk being able to fish by their tents?
  • Size of proposed Loch Chon campsite (point 5). Mr Watson’s claim that a large campsite at Loch Chon is required because only a large campsite would be financially viable is risible.   The Park’s own data shows that the numbers of campers at Loch Chon rarely exceeds 10 so if large campsites are needed then this is NOT the place to do it!   If this is true, why then did the Park claim as recently as 25th May not to have taken a decision about the north Loch Venachar campsite  and other proposed campsites in the 5 Loch Visitor Management Plan all of which were much smaller?     Mr Watson’s comparison with the Sallochy which is a thirty place campsite is equally ludicrous.  Sallochy is on the West Highland Way on the east shore of Loch Lomond and demand there far exceeds supply.  What I find most worrying though are his statement that “I am prepared to consider modest reductions (in the size of the site)” and “I would be prepared to reduce the number by 5 to 28”.  Since when were decisions about the number of camping places delegated to Mr Watson to decide personally?
  • On-site supervision (point 6).  Local residents in objecting to the planning application rightly objected to the creation of a large campsite without a warden.  Mr Watson’s suggestion that this might be paid for out of campsite fees appears pie in the sky.   What is likely to happen at Loch Chon, should a large campsite go ahead, is that it will be empty most of the time – a waste of resource but this also means there will be very little income.  However, as one of the few places close to a loch within the National Park where people would still be allowed to camp in numbers, its quite predictable that on occasion large groups will decide to turn up and probably party.  I see little chance of the Park being able to arrange a warden when one might be needed.   This is the wrong place for a large campsite. There are other places in the National Park, at Balmaha on east Loch Lomond for example, where there is high unmet demand and a campsite could  easily support a warden but the Park has so far refused to progress sites in such areas.
  • Alcohol byelaws (point 7).   Mr Watson repeats yet again that alcohol byelaws are nothing to do with the National Park – when of course on east Loch Lomond they were brought in as part of a package of measures including the camping ban there and the 5 Lochs Visitor Management Group regularly discussed alcohol byelaws, in fact these were part of the 5 Lochs Plan.  What has happened to the vision of the National Park co-ordinating and joining up activity between all public authorities?   Is that not what the LLTNPA’s partnership plan was for?  Mr Watson appears to have taken another unilateral decision to abandon all of that.


The Your Park Camping Proposals and the Park’s Development Plan


Parkswatchscotland has previously covered the inconsistent and contradictory terminology which the LLTNPA has applied to camping provision in its Your Park Plan and Camping Development Plan (see here).   I am delighted that the Reporter appointed to scrutinise the draft Development Plan asked the LLTNPA to explain this.  The LLTNPA has now provided their response Information Request 02 Issue 22 Visitor Experience V1_0


The LLTNPA are claiming that because camping definitions appeared in guidance that is intended to accompany the Development Plan, but not the plan itself, this is not a matter for the Reporter and is something the Park will address at a later date.   The Park has already had over a year to resolve the inconsistencies between its two plans, done nothing and now apparently believes it is acceptable for it to sort out these fundamental issues at some unspecified time in the future.   However, the LLTNPA in its  Loch Chon planning application has used the terminology from the Development Plan Guidance to describe its camping proposals so this issue is current – its not one that can wait.  How can planning committee members can be expected to take a decision on the Loch Chon campsite when their basic policy position on camping development is so unclear?


While technically the LLTNPA may or may not be correct that accompanying Guidance is separate to the actual Development Plan and therefore outwith the remit of the Reporter, this begs the question about whether the definitions should not be part of the Development Plan itself – I suggest they should be as the Park needs to be clear about what levels of camping provision DO require planning permission (eg would a campsite where the only facility was a tap and composting toilet require planning permission?).   I hope therefore the Reporter insists this is considered at the Public Hearing on the Development Plan.


What’s happened to the proposals in the 5 Lochs Management Plan?


The Park has continued to deny that it has made any definitive decisions about the campsites that were proposed and not delivered in the 5 Lochs Management Plan.  Two weeks ago I received EIR 2016-024 Response to my request for copies of minutes of the the 5 Lochs Visitor Management stakeholder group which had taken place since December 2014. The stakeholder group consists of Board Members, community councils and public sector partners such as Stirling Council and the Sports Council. The response states that two meetings have taken place, the last in November 2015.   So the external stakeholders in the 5 Lochs VMP have been given no opportunity to participate in the development of the Park’s camping development plan since the Minister approved the byelaws, despite the 5 Lochs VMP have developed a coherent set of proposals for a large part of the Trossachs area.


The LLTNPA  has refused to provide the minutes of the November meeting on the grounds they have not yet been finalised so its impossible to tell if the group were consulted then about the camping development plan.   Anywhere else failure to finalise minutes 9 months later would be consider a fundamental failure in governance.  In the LLTNPA it is one of the methods used to avoid having to make information public.


The Minutes of the April 2015 meeting Finalised Minutes contain some other interesting information:

  • Bridget Jones, the member of staff who chaired the meeting,  informed those present about the proposed new camping management zones which would cover more than the original 5 Lochs area.  The St Fillans Community Council rep Nice Muir asked what the  implications of this for the 5 Lochs Visitor Management Plan – an excellent question.  The minutes record (4.1 (g)) he was told that there were two scenarios but its NOT recorded what these were.   Reason for another FOI request!
  • Graham Archibald, another member of staff, reported on what is described as the Phase 2 Loch Venachar developments – which were part of the 5 Lochs VMP – and involved improvements to two laybys on the Invertrossachs Rd. Work had started in January.  What is not recorded in the minute is whether he explained that the original plans had been changed and the reasons for this.   At the Loch Venachar Quay site the changes included installation of a gate (a member of the group asked if it would be locked), planting of prickly shrubs along the fence with the neighbouring property where grass had originally been planned  and planting of trees all over the old quay which had been gifted to the people of Callender for their enjoyment.  The neighbouring property, Loch Venachar House, happens to be the home of the Park’s convener Linda McKay.
  • Sue Morris, the Trossachs Community Council, had to ask about what was happening at the North Loch Venachar site where an eight place campsite had been planned.  She was told budget had not been available to proceed with this work – nothing about small sites such as this being financially unviable as Gordon Watson is now claiming – but there might be money available in the next year.  As parkswatch has previously reported the North Loch Venachar plan has indeed gone ahead but without the campsite.
July 26, 2016 Nick Kempe No comments exist

Yesterday was the start of National Parks week, an annual celebration of National Parks in the UK.   The theme of National Parks week this year is adventure.  The Cairngorm National Park Authority has responded to this with a positive press release press release about celebrating National Parks, announcing a number of events and encouraging people to share ideas for adventures.   Quite a contrast to the LLTNPA whose press release makes no mention of adventure.


Instead the LLTNPA have used National Parks week to announce the implementation of their new powers to fine litterers ( see and a number of other initiatives to ensure everyone visiting the National Park behaves responsibly under the banner of “Respect your Park”.  Now I am not against any of these initiatives but I think the fact that the LLTNPA has simply ignored the theme of adventure, which is about people have positive experiences in our National Parks, and instead focussed in this week of all weeks telling people what they should not be doing tells us something.  If the Park started to promote adventure, this would conflict with its proposed ban on lochside camping, which is one of the most important ways people have adventures at present.   Think of Duke of Edinburgh expeditions, backpacking, cycle touring, canoe touring, all activities which involve adventure.  Better then simply to ignore the adventure theme to National Parks week.


The LLTNPA Press release contains another interesting statement relevant to the camping byelaws from Chief Superintendent Stevie McAllister, Divisional Commander for Forth Valley and Police Scotland Lead for the Loch Lomond & The Trossachs National Park:


“For the best part of a decade, officers based within the Loch Lomond and Trossachs area have worked closely with the National Park to deter offences such as antisocial behaviour and identify those responsible.

“This has already proven extremely successful with crimes of this nature now significantly reduced, particularly within the East Loch Lomond and other lochshore areas and the vast majority of visitors behaving responsibly during their stay.”


I am delighted that Police Scotland are now publicly acknowledging that anti-social behaviour crimes are much reduced and most visitors behave responsibly in the National Park – why then did they support the proposed extension of camping byelaws?   Readers may recall that in trying to justify the camping byelaws the LTNPA continually asserted that it was camping byelaws that had led to an 81.5% reduction in ASB on east Loch Lomond, when in fact the statistic was for a wider area and represented a reduction from 27 to 5 crimes.  Police statistics showed that there had been a 42.4 reduction in ASB in the rest of the central Scotland Police division of the National Park where no camping byelaws, alcohol bans or other special measures were in place.   Well done the police but how can Stevie McAllister now continue to justify the removal of access rights from “the vast majority of visitors behaving responsibly during their stay”?
Each time the LLTNPA publishes anything on visitor management, they provide yet more evidence of  the incoherence of the proposed camping ban.   While I believe the timing of this education campaign is extremely unfortunate, with anti-social behaviour tackled, and with its new powers to tackle litter, what further justification has the Park and Ministers got for proceeding with the camping byelaws?

July 24, 2016 Nick Kempe No comments exist

A week ago the National Trust for Scotland announced that four hen harrier chicks had fledged on their Mar Lodge estate, in the central Cairngorms.  Raptor Persecution Scotland commented in their blog last week time that the chances of the young harriers surviving were extremely low given the history of raptor persecution in the Cairngorms National Park.    Just a week later the truth of this comment was demonstrated by the announcement that an illegal trap had been discovered on the neighbouring Invercauld Estate along with evidence that a further 8 illegal traps that had been removed before the police were able to start their investigation.    While the trap that was found contained a common gull, it could just as well have caught a hen harrier – proof of Raptor Persecution Scotland’s comment that if the young harriers moved east they were likely done for.


It was good to see another quick response from the Cairngorms National Park Authority Chief Executive, Grant Moir,  unequivocally condemning the use of the trap.   His request for a meeting with the Head Trustee and Sporting Partner at Invercauld however, though I am sure well intentioned,  simply illustrates the weakness of National Parks.   A strong National Park would have summoned the estate and all the trustees to explain themselves or risk losing their right to hunt (which as the blog has pointed out they could control through byelaws).  Instead, the CNPA has not even named the Head Trustee and Sporting Partner.   Do the CNPA  not know who the people are?   Or are they allowing the people ultimately responsible for management of the estate to hide their identity?   The Farquharson family, who control the Invercauld Estate, hide behind a trust structure that protects their assets but why should the National Park perpetuate this?  What about some openness?


Moreover, instead of calling on other public authorities to contribute resources for enforcement (resources that are unlikely to materialise under austerity), why does not the CNPA  simply use the powers it already has to license all hunting in the National Park and suspend or remove that license whenever evidence of wildlife crime such as this occurs as  previously suggested on this blog   The deterrent effect of this would I believe be sufficient to solve the problem of wildlife persecution overnight and would NOT require other public authorities to contribute further resources.


Unfortunately, the CNPA in trying to work in partnership with landowners appears to have  got far too close to them.   The problem is illustrated by the CNPA’s new Partnership Plan, which is currently out for consultation, and which set the future direction of the National Park over the next five years.  It includes nine issues reports, the second of which is on Deer and Moorland Management 160621DeerMoorlandManagementFINAL1-1 (there is no conservation issues report as such despite the Park’s primary objective being conservation).


On page 5 of this report CNPA quotes from the Game and Wildlife Conservation Trust, treating them apparently as an authoritative source:



No mention here of the impact of raptor persecution on grouse numbers.   It was the very same GWCT which on Friday issued a press release on behalf of the Invercauld estate (see here) first denying the crime and then alleging that if the illegal traps had been set this must have been done by people trying to discredit the grouse shooting industry.  Why is the CNPA giving the GWCT credence by quoting them uncritically?


While later in the Deer and Moorland Management Issues Report the CNPA does question some of the statements of the grouse lobby, the report contains is no fundamental questioning of the impact of current grouse moor management on wildlife or whether this is compatible with the conservation objective of the National Park.   It is worth stating loudly and clearly that in the case of conflict – and the CNPA does acknowledge some of the conflict  – the Scottish Parliament intended the conservation objective to override all the other objectives and this is enshrined in law in the National Parks Act.    This should be the basis of the Partnership Plan.


Instead of giving a firm lead based on its legal obligations, however, at the end of the Issues Report 2 on Deer and Moorland Management the CNPA asks two 2 questions, the first on deer numbers (which I will cover in another post) and the second on grouse moor management:




I believe this is the wrong question.   The right question, based on the CNPA’s founding legislation, would be to ask HOW can grouse moor management be made compatible with the National Park’s conservation objectives?  The answer to both that and the Park’s own question is “not by voluntary means”.  The CNPA has been trying to prevent raptor persecution by persuasion for over ten years without any significant success.   It is time to admit defeat and the interests of grouse moor managers are such that the system will never change voluntarily.


It is the CNPA’s reliance on voluntary means, which its staff must know by now will not work, which I believe accounts for the Issues Report proposing the following targets/direction of travel for the new Partnership Plan:





The first is totally wrong as well as being so vague as to be meaningless.  What the National Park’s overriding conservation objective should mean is that the economic and cultural interests of shooting estates should not be at the expense of wildlife or habitats.   I would suggest the following should flow from this as a start:

  • All hunting in the CNPA should be licensed.  I appreciate there is now a campaign to license all gamebird hunting nationally but there is nothing to stop the CNPA starting a consultation on new hunting bye-laws now which should be broader than just gamebirds and include hunting of mammals from deer to mountain hares.
  • The use of ALL traps should be banned within the National Park except in limited cases under license. The CNPA should not be prioritising one species over another in terms of conservation objectives (in contrast to grouse moor management priorities grouse over everything from mountain hares to stoats to golden eagles) and there is no general justification for trapping in our National Parks.   I would suggest the only trapping that could be justified in the National Park would be for introduced species such as mink.


The second “target”, to “improve raptor population conservation” as phrased does not even mean the CNPA is committed to increase numbers of raptors in the National Park.   To give this bite the CNPA should:

  • Consult with RSPB and the raptor study groups and come up with a (conservative estimate) for the minimum number of nesting pairs of each species of raptor the National Park could be expected to support at present (given current state of habitats without any wildlife persecution). For example, 30 pairs of hen harrier, 20 pairs of golden eagle etc.   The target should then be to reach this number before the end of the Partnership Plan.   This should not be difficult to achieve.  Raptor populations would expand quickly if they were not illegally killed and their primary food sources apart from red grouse, such as mountain hare, ceased to be systematically cleared from the moors.
  • Make a commitment to satellite tag all species of raptors where persecution has had a serious impact on populations.  The National Park used to be involved in a satellite tagging project and its very sad that this now depends on the efforts of others.  According to the reports on the young NTS hen harriers only one of the four is to be tagged.  Tagging appears the best deterrent against persecution because it provides evidence of where birds were last seen alive (and this evidence could play an important role in the CNPA being able to revoke  hunting licenses because of illegal persecution).  Every reason then for our National Parks to fund satellite tagging.
July 23, 2016 Nick Kempe No comments exist
The trench that has been dug along the entire length of the car park T bar to install new cabling – photo credit George Paton

I was delighted that the coverage by parkswatchscotland of the destruction at Cairngorm was picked up by Rob Edwards in the Sunday Herald and on his website two weeks ago.   The articles are significant because they include confirmation from a senior member of staff within the Cairngorms National Park Authority that the work undertaken by Natural Retreats on the Shieling ski tow breached planning permission.   After six months of efforts by local activists at last the CNPA appear to be accepting there is an issue.


Whether Highlands and Islands Enterprise accept there is an issue is far less clear as this email to me from HIE illustrates:


“Thank you for your e-mail of 23rd June 2016 received below asking for  ‘copies of all the written information you hold about the Planning Application for the replacement Shieling ski tow (DET 2014_0251) including correspondence with Natural Retreats about how they managed the works and any communications HIE had with the contractors about these works’.

I can confirm that HIE holds no information about the actual Planning Application for the replacement Shieling ski tow (DET 2014-0251) we also hold no direct correspondence with Natural Retreats about how they managed the works.”

HIE, as landlord with ulitmate responsibility for the good custodianship of the area, need to explain why they hold NO information about the unlawful works conducted by Natural Retreats at Cairngorm?   The absence of any information or records suggests that HIE has expressed no concern and taken no action about the damage caused by its tenant at Cairngorm although it was first alerted to this nine months ago.   It also raises questions about how Keith Bryers in his  post on parkswatchscotland was able to claim the new track that was constructed without planning permission was justified for maintenance purposes and to move snow cannon.   This claim now appears not to have been based on any written information.  A good reason for the CNPA to reject any retrospective planning application for the unlawful track.


One might have thought that having been subject to such adverse national media publicity Natural Retreats would have been more careful about what they were doing at Cairngorm or that HIE would have warned them that standards needed to improve.  Unfortunately the photos in this post illustrate that nothing has changed.CIMG8128 (2)

Photo credit George Paton



Natural Retreats has dug the trench along the entire length of the Carpark T-Bar without any ground protection measures being in place.   All of the spoil materials have been dumped onto the surrounding vegetation and nothing was done to try to protect that ground from the tracked vehicle used for the install new cabling.


Given their recent history, you’d have thought that Natural Retreats would have contacted the CNPA Planning department beforehand but parkswatchscotland has seen an email that shows the CNPA was unaware of these works.


CNPA has now confirmed that planning permission was not required because the replacement cabling is not classed as a new development.   If this is true – and I suspect it is – it makes a mockery of how our planning laws are protecting our most fragile areas.   On the one hand, during the funicular construction, stringent measures were required to limit damage to soils and vegetation.  On the other hand, the operator of Cairngorm Mountain is now free to adopt whatever practice they see fit to replace the cabling on the car park ski tow which runs parallel to the lower part of the very same funicular and over similar ground.   While this illustrates that our planning laws are hopelessly inadequate in the protection they offer our mountains,  our National Parks really should be able to find a way to stop damage like this happening.CIMG8140 Alan Brattey

Although the Car Park ski tow runs parallel to funicular very different standards have been applied                                                          Photo credit Alan Brattey



The solution is not difficult:  HIE simply needs to require its tenant to adopt best practice as recommended by CNPA for all ground works and the management of its land at Cairngorm.  Unfortunately it looks like Natural Retrreats are only too aware that neither the CNPA nor HIE are going to stand up to them and are operating accordingly (taking the cheapest route possible).CIMG8141Alan Brattey

More evidence of the lack of care by Natural Retreats                               Photo credit Alan Brattey




July 20, 2016 Nick Kempe No comments exist




Your Guidance on Renewables recommends the use of fencing should be kept to a minimum.  Is this fencing at the Derrydarroch power station what was meant?   Or has perhaps this been designed to keep walkers on the West Highland Way, from where this photo was taken, at bay?


July 18, 2016 Nick Kempe No comments exist




I know that the LLTNPA is very pre-occupied with branding, so that every signpost has to be in your corporate colours, but I really wonder if this is the best way to get messages across?   I have been a few time to the Carrick Nature reserve and never seen any litter.  There is a bin by the entrance, which helps, but I think this small notice is more powerful than anything our National Parks have ever produced.


I am reminded of the old message – which had nothing to do with our public authorities – “take nothing but photos, leave nothing but footprints”.   Instead of deciding everything centrally, why not fund local communities and people who visit the National Parks to produce their own signs?   It might just be more effective.


Here’s to a litter free Scotland



July 16, 2016 Nick Kempe No comments exist














Dear CNPA,

I know that you did all you can to influence the siting of the Beauly-Denny powerline away from the National Park and this was not your decision, but should our National Parks not be able to influence and enforce proper restoration after construction work?     The rubble and tarmac dumped here is just south of the Drumochter within the National Park boundary.

July 14, 2016 Nick Kempe No comments exist




I am afraid by the time you read this, the section of turf in the photo will have long gone – its just too comfortable for cattle to walk on.  This is a shame because your  Guidance on Renewables recommends the creation of a turf/soil strip along the centre of all new bulldozed tracks leading to dams to help them blend in with the environment.   A good idea and the contractor at Glen Falloch has tried to do this but it appears they were wasting their time.


I look forward to hearing who is going to pay to have it fixed.




July 12, 2016 Nick Kempe No comments exist






I was interested to see in May that meters had been installed at the carpark in Inveruglas.  I appreciate you are short of money but it seems to me particularly mean to advertise the new wooden structure at Inveruglas, as part of Scotland’s scenic routes, and then charge people for the privilege of stepping out of their cars to take a closer look.    I might not mind so much if it was clear what the money was being used for and litter bins were being installed not just at Inveruglas but at all the stopping points along the A82.    I would like our National Parks though to assert the fundamental value of being able to experience our countryside for free, as a common good, and what better way to demonstrate this than by creating a free campsite at Inveruglas (behind the parking area) from which people could experience the glories of the loch overnight?


The experience of sleeping out is worth more than any hotel.









July 10, 2016 Nick Kempe No comments exist




In May I visited the Loch Venachar quay site off the Invertrossachs Road where you installed a new carpark with gates last year, just outside Invertrossachs House, the home of your convener Linda McKay.   I note that the trees on the quay, which were not in the original plans, were growing particularly well – I suspect that whoever did the work was instructed to feed the trees with a large dose of fertiliser.  I normally love trees – indeed I have been criticised by readers of my posts for promoting trees at the expense of deer – but here they are a symbol of everything that is wrong with the National Park.   This quay, hard to see in the photo, was gifted to the people of Callender for their enjoyment and handed over to LLTNPA on the creation of the National Park.   People used to camp here but in a couple of years, when the water in the loch is high, it will no longer be possible for anyone even to walk to the end of the quay.  Should our National Parks be about planting trees at the expense of people, to keep out the hoi polloi, to stop access?.


So, here’s to the people of Callender using the new powers of the Community Empowerment Act to re-assert their right to land that was gifted for their enjoyment.

July 8, 2016 Nick Kempe No comments exist


Dear CNPA,


Apologies, I could not find the best card.  The track in the foreground as you will recognise is outwith your boundary but the one in the far distance is within it.   Travelling through the Drumochter though I  am not sure the boundary has made any difference: every hillside is cut like the one in the foreground with bulldozed tracks for grouse-moor management.    I know this might not matter for people whizzing by in their cars but really I think we are missing a trick.  Drumochter, the gateway to Speyside, the most popular area of the National Park.  It should be a scenic route, a place to stop off, a place to go for a wander, a place to see Hen Harrier.   Its a great place, for people in the know, to run or walk or ski tour but all the time the views are marred by tracks, ones ears accosted by the sound of traffic and ones enjoyment lessened because of the absence of anything that might eat a grouse.


Perhaps though the dualling of the A9 provides a new opportunity – just a thought but how about the National Park developing a vison  for the Drumochter as part of your new Partnership Plan?

July 6, 2016 Nick Kempe 2 comments



I know at the behest of the Scottish Government both our National Parks have been promoting  scenic routes and as part of this some interesting sculptures have been created over the last year or so including the structure at Inveruglas.  To many people like myself though the natural beauty of the area speaks louder than any sculpture.  I was dismayed therefore to see the suburbanisation of the Rest and Be Thankful, which should be one of the finest road pass in Great Britain, that took place last year.  I wonder what  the drovers and the soldiers who built the military road have thought of the turning circle and installation of an urban style bus shelter between Beinn Luibhean and  Beinn an Lochain, two of the finest hills in the National Park.  I realise the plaque in the bus stop says responsibility for this lay with Argyll and Bute Council, Strathclyde Transport and Transport Scotland but could the National Park Authority really do nothing to influence this?  I am all for improving the public transport in National Parks but is this really the way to do this?


Happy travelling



July 5, 2016 Nick Kempe No comments exist



I spotted these tents at Bein Glas campsite on Sunday 26th June at 9.30 am.  They looked abandoned to me and sure enough they were still there late afternoon.   When you published all those photos of abandoned tents by the lochshores you implied that banning camping outwith controlled areas would stop these problems – that’s clearly untrue.   Campsite owners still have to clear up mess or belongings left by a small minority of campers and so should the National Park Authority instead of trying to remove the rights of the responsible majority.


Incidentally could the LLNTPA not arrange for any abandoned camping equipment that is still useable to be sent to organisations working with refugees?


Happy camping!



July 4, 2016 Nick Kempe No comments exist
The new Coire Cas T-bar platform with spoil below. It is already being eroded away by the rain. Photo Credit Alan Brattey

Dear CNPA,


I have some sympathy with you as planning authority, about the destruction and mess at the Coire Cas T-bar because,  after Natural Retreats claimed emergency work was needed to replace the t-bar gantry before the last ski season,  Highland Council let them proceed without planning permission.  This provides an opportunity for the CNPA to say what you would have done if you had had the full range of planning powers you are requesting from the Government.  I believe the photo demonstrates the danger of allowing works to take place without proper specifications in place and no effective monitoring.  It has allowed Natural Retreats to treat Cairngorm like a building site, with material bulldozed here and there, with no overall plan and with no consideration for the environment.


I hope the National Park will now start to stand up for the environment at Cairngorm

July 3, 2016 Nick Kempe No comments exist
AB New Earthworks
Photo credit Alan Brattey

Dear CNPA,


If you want to know just how much material Natural Retreats removed from the bank below the Shieling ski tow without planning permission, this photo all the evidence you need.  Hard to believe that HIE is now justifying this on the grounds that “the area around the base of the lift needed to be raised”.    If this much material was required, surely someone should have realised this in advance?

July 2, 2016 Nick Kempe No comments exist

One of the objections I submitted to the LLTNPA’s development plan Response – Development Plan and Camping was it used totally different terminology to describe campsites than what has been used in the Your Park consultation – a case of one part of the Park not talking to another. (See


I emailed the Park’s convener of planning, Petra Biberbach (who replaced share-trading Owen McKee), drawing her attention to this last year and asking for a meeting.   She declined to see me and none of the points I had raised were even discussed at the Board Meeting which approved the plan.


I was very pleased therefore to be informed that the Reporter appointed to consider the Park’s Development Plan is now asking the LLTNPA for more information about this which is very relevant to the totally unnecessary campsite being proposed at Loch Chon.  The important bit is at the bottom where the Reporter has in effect asked the Park what it could do to help people better understand what it means when it talks about camping provision.  Exactly what not just I, but the Ramblers and SNH all tried to say to the LLTNPA but which they chose to ignore.


To:       Loch Lomond & the Trossachs National Park Authority

Cc:      Nick Kempe (662), Ramblers Scotland (701), Scottish Natural Heritage (712)

Dear Mr Killen





I am writing regarding the above plan which has been submitted to DPEA for examination by Scottish Ministers.  Under Regulation 22 of the Town and Country Planning (Development Planning) (Scotland) Regulations 2008, the appointed reporter can request, by way of notice, further information in connection with the examination.  This request is a notice under Regulation 22.

The reporter has identified that further information, as listed below, should be provided by Loch Lomond and the Trossachs National Park Authority.  It would be helpful if you could send this information to me to pass on to the reporter by 5pm on Thursday 14 July 2016.  Nick Kempe, Ramblers Scotland and Scottish Natural Heritage, who have made representations with regard to this issue, will be given a further 7 days, from their receipt of the authority’s response, to make any comments on your response.  Please ensure the authority also send a copy to them.

Please e-mail your response, however, if it is more than 10 pages or in colour, please also provide a hard copy.  Please note that DPEA cannot accept hyperlinks to documents or web pages.  When replying to this request please quote the request number above.

Issue 22 Visitor Experience



In relation to the provision of facilities and services to enhance visitor experience in the National Park area, a number of references are made to camping provision in the following publications: The proposed new local development plan; ‘Your Park’; and the Planning Guidance on Visitor Experience document.

In this context, representations from N Kempe (662) and Ramblers Scotland (701) have drawn attention to the variations and perceived inconsistencies in the terminology used by the Park Authority in those documents when referring to different forms of camping provision.

Information requested

(1)  The park authority is requested to provide a clearer and more detailed explanation of the terminology used or intended in the proposed local development plan with regard to camping provision of different forms and to provide clarification concerning its related policy position if this varies between particular categories of camping provision.

(2)  Additionally, to provide clarification regarding how and where the local development plan’s policy position on camping provision should cross-refer to and be supported by more detailed considerations set out in supplementary guidance – and on what basis the terminology used in those documents varies from the terminology used on camping provision in the ‘Your Plan’ document.

(3)  The explanations required by (1) and (2) should include possible wording that could be used in the proposed plan to allow users to better understand the approach of the Park Authority regarding camping provision.

Please acknowledge receipt of this request and confirm that your response will be provided within the time limit.

A copy of this request will be published on the DPEA website, together with a copy of the authority’s response:


Please do not hesitate to contact me if there is anything you would like clarified.


Yours sincerely



The Scottish Government


4 The Courtyard

Callendar Business Park



July 2, 2016 Nick Kempe No comments exist

When I set up parkswatchscotland in March I had no idea what I was letting myself in for.  I had broadly conceived it as an open platform for people concerned about our two National Parks and had hoped to get a team of active contributors within a few weeks.   I thought I might write a post or two a week.  Its not quite worked out like that.   While there are now lots of people contributing to parkwatch in various ways, from ideas, to providing photos to promoting posts on social media only a handful of you so far have wanted to write posts and I have no co-editors to continue to publish posts while I go off on holiday.  This is a shame because there is a lot going on at present!


However to keep up the momentum, I have scheduled a number of “Postcards to the Park” to appear while I am on holiday.     Any comments that are submitted on these may take a few days to appear as I will be in the mountains and am not much good yet at managing the blog from a phone!  If after seeing the postcards, you have a photo which you think makes a point, do please forward to parkswatchscotland.


Thankyou all for your support.



July 1, 2016 Nick Kempe No comments exist

I was out last Sunday taking a  look at the Glen Falloch hydro schemes which I had not yet visited.  In an earlier post I was very critical of the Loch Lomond and Trossachs National Park for setting out no firm rules about what locations might be suitable for hydro schemes .     The very last section of its Supplementary Planning Guidance on Renewables though has a section on “Best Practice and Mitigation Measures for Renewables in LLTNPA” which contains some excellent requirements in terms of detailed design and restoration   SPG-Renewables-final


The problem in Glen Falloch is that there is extensive evidence that the LLTNPA’s own guidance has not been followed.   This is not all the fault of the LLTNPA, because it was the Scottish Government that was responsible for approving the hydro schemes, although the LLTNPA is responsible for enforcing the conditions attached to the planning consent.   Since the Scottish Government consulted LLTNPA before agreeing to grant planning permission it is quite difficult to ascertain exactly where responsibility lies.   I plan therefore to focus on what in wrong with the schemes in relation to the Park’s own guidance over several posts, starting with the most obvious breach.


Anyone who has driven north up the A82 in the last year may have observed a bright blue pipe on the left.  This is a penstock which feeds waters from the Eas Eonan into the Derrydarroch power station.  The first time I saw it I wondered why a bright blue pipe had been allowed in our National Park.IMG_6500


The Park’s Guidance on this makes interesting reading:


Penstocks above ground should follow existing linear features such as watercourse or road routes, and be of a colour matching ground cover features, however it is expected that the penstock will be underground wherever possible.


So, why was planning permission granted to install this penstock?  I am not a technical expert and therefore cannot say whether it might have been possible to underground this section of pipe, as was done on the hillside above, but it certainly does not match the ground cover.


While you may only glimpse this section of pipe while speeding by in a car, if you are walking the West Highland Way its in full view from the end of the first of the River Falloch meltwater gorges for well over a kilometre, in other words its not hidden at all.  Its impact on the walking  experience is therefore significant and I believe is yet another blow to the West Highland Way which is continually promoted as a world class experience without a thought about how the quality of that experience could be preserved or enhanced.


Linked to the pipe in the first phone is another which crosses the River Falloch.  It is not visible from the road but is again in full view of the West Highland Way.






Following its statement that colours should match the natural environment, the Park’s Guidance goes on to state:


 If the pipeline needs to cross a watercourse, consider whether there is scope to attach it to an existing or proposed bridge, or if the pipeline will  require undergrounding, seek advice
from SEPA on how to maintain the hydrological integrity of the watercourse. From a landscape
perspective undergrounding or a location beneath the bridge is preferred.


Unfortunately the Park’s Guidance says nothing about the design of crossings where the pipe cannot be hidden under a bridge or undergrounded.   It would be easy however in such situations to use natural materials such as wood to hide the pipe or, here’s a thought, to convert it into a pedestrian bridge.


It looks however that whoever approved the various schemes in Glen Falloch simply ignored the LLTNPA guidance.  There was an obvious opportunity for concealing one of the pipes, which also runs into the Derrydarroch power station, where it crosses the Allt a Chuillinn.IMG_6565




New pipe, new bridge but still no-one insisted the pipe should go under the bridge.


There is a lot more blue penstock in Glen Falloch, such as these short sections waiting  to be installed at the new dams being created above the Ben Glas falls, an area of wild land if ever there was one.


It appears though that no-one responsible in granting this planning consent cared sufficiently, wild land or not, to require the developer to order penstock in an appropriate colour that met the LLTNPA’s guidance.  One wonders what the point of the guidance, which the LLTNPA claims was trailblazing, if no-one follows it.


I am afraid there is a lot more of this to report on but that will have to wait a few  weeks.