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 http://strathard.org.uk/national_park_camping_proposals.htm
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.http://parkswatchscotland.co.uk/2016/05/27/disappearing-campsites-loch-lomond-trossachs-national-park-development-plan/