Camping on the shore of Loch Chon. The LLTNPA wants to prevents people from camping by the Lochshores and force people to camp on fixed pitches away from the loch.
On Wednesday, a day after posting an email from Strathard Community Council saying its members had voted not to object to the planning application, the Loch Lomond and Trossachs National Park Authority published a Report recommending approval of the application by its Planning Committee. This will meet on Monday 26th September (conveniently on a holiday Monday when many West of Scotland campers will be out camping!).
While it will be interesting to see what undertaking the LLTNPA have given to Strathard Community Council – and indeed what if anything has been put in writing – the representations from the Community Council and public campaigning have resulted in some changes to the scheme. The most positive changes are the Park has dropped its daft idea of camping platforms on the hillside – one wonders if any of the staff behind this proposal had ever slept in a tent! – and the shipping containers which were going to be covered with some very expensive photographs are now going to be clad with larch panels.
The proposed printed images on the metal shipping containers have been dropped
Most people I suspect will think wood cladded containers will be an improvement on the di-bond panels but just why does the LLTNPA need to join the international market for used shipping containers rather than paying a local business to construct the toilet blocks out of locally sourced materials?
The LLTNPA has also reduced the size of the campsite from 33 to 26 pitches – well above the peak number of tents ever recorded for camping on ALL the places where people camp around Loch Chon. Now while I objected to the size of the campsite at Loch Chon, the reduction in places without the creation of new places elsewhere (and there needs to be a network of SMALL campsites through the Trossachs, camping byelaws or not) will simply reduce the total amount of camping that can take place in Strathard. Indeed, what I don’t think people have appreciated yet is that because there are NO campervan places on the development overnight stays in campervans on Strathard will become completely unlawful. (The only other place in Strathard where it appears overnight stays will be allowed is on the south shore of Loch Ard in a location inaccessible to vehicles).
Campervans at Loch Chon – because the camping byelaws cover the whole of the B829 through Strathard, from Milton to just above Inversnaid, staying overnight in campervans will become unlawful
So,the LLTNPA in effect wants to ban campervans from one entire section of the National Park. Does the LLTNPA Board understand nothing about current trends in tourism or how people are enjoying the countryside? Luckily, unless the Park spends even more on ranger patrols than it does at present (the rangers currently only patrol Strathard at weekends and stop work at 10pm) this, like the rest of the byelaws, is likely to be unenforceable.
The north shore of Loch Arklet. The proposed camping byelaws, which prevent any overnight stays, extend along the B829 and in theory will make it impossible for people to stop here overnight in their campervans. The Park would say campers can walk round to the south shore of the Loch or up the hill – not much use if you are cycle touring or fishing
While the Committee Report clearly states that “Demand is not a relevant planning consideration” the question of how best to facilitate camping and overnight stays by campervans is a relevant consideration to the LLTNPA as a whole, if not to the Planning Committee. As the Park’s patrol records show there is no demand for a campsite of this size at Loch Chon (more analysis to come on this soon). The LLTNPA is therefore wasting scarce public resources (the budget allocation for the Loch Chon con was £345k for this year alone and £100k last year). This money would be much better used to create 26 pitch campsites in places where there is high demand such as Loch Venachar – but you need to remember the convener of the LLTNPA, Linda McKay, lives there and all campsite plans there have been scrapped. Alternatively, it could be used to create further new small campsites/overnight stop offs in areas of like the north shore of Loch Arklet where there is low demand but great potential to increase uptake of the current path network.
The Loch Chon planning application is only being pushed through so the LLTNPA can say to Ministers it has created a certain number of new camping places before the scheduled start date of the new byelaws. I am not sure if Board Members really care whether its used or not and I suspect Strathard Community Council Members when voting about the proposal came to the same conclusion. Most of the camping places will probably never be used. Indeed the Report even says this – contradicting Gordon Watson, the Chief Executive’s claims at the public meeting on the campsite that only a large campsite would be financially viable “It should also be noted that camping will be seasonal and is likely to operate at capacity at peak summer periods only.”
The flawed logic in the Planning Committee report
While the Report dismisses most of the objections to the planning application which the LLTNPA has made to itself on the grounds that they are not relevant planning considerations, three major flaws in the Report are worth highlighting:
1) The Report claims: “New seasonal camping management byelaws (which come into force in March 2017 and will apply 1 March–30 September each year) to regulate camping, tackle antisocial behaviour and make it an offence to cause damage to the Park’s natural environment. They will also prevent inappropriate use of public laybys as encampments by caravans and campervans”. It appears no-one in the planning department talks to their colleagues because the provisions in the first draft of the byelaws to make it an offence to damage to the Park’s natural environment were removed on the advice of SNH and Police Scotland. This is because damage to the natural environment is already covered by the criminal law. So, the Park’s planners do not even understand the scope of the byelaws. Moreover they repeat the claim that the byelaws will prevent encampments while ignoring the fact that there are already powers for the police to remove encampments under the Criminal Justice and Public Order Act. What this shows is the LLTNPA is still scraping the bottom of the barrel when it comes to trying to justify the proposed byelaws.
2) The Report provides further evidence of the Park’s double standards when it comes to chopping down trees. One of the major ways it whipped up public outrage about campers was by publishing photos of chopped trees.
“The layout of proposed paths and camping pitches has been determined with sensitivity and consequently tree loss is at low level within the context of the site; 40 individual trees and 3 tree groups require pruning or removal; Semi-mature birch trees requiring removal are low or moderate quality trees of less than 20 years of age and the design proposals provide compensatory planting to offset the loss of trees; Of the trees surveyed, 20 are regarded as important and require special consideration during construction.”
Now I don’t condone the chopping of live trees for firewood by visitors – its stupid because green wood doesn’t burn well if at all – but the fact is in creating this campsite the LLTNPA are likely to chop down far more trees than have been chopped by irresponsible campers in Strathard in the last 40 years. It really does help put the damage caused by campers in perspective – is it really justifiable to remove access rights of the many for this? Morever, since the campsite won’t be managed, there is nothing to stop irresponsible campers chopping the occasional tree after the campsite is created.
3) The Report fails to establish that a campsite of this size is consistent with the LLTNPA development plan. Both the existing and proposed plans classify Strathard as an area where only small scale tourist development is appropriate:
“The development site is within the “Aberfoyle, Queen Elizabeth Forest Park and them Trossachs” Sub -Destination Area. Schedule 5 contains a list of tourism opportunities /constraints for each sub-destination. The relevant part of the schedule in this case specifically refers to “support for visitor infrastructure and small -scale self catering, bunkhouse, camping opportunities within Queen Elizabeth Forest Park area around Aberfoyle and the Trossachs.”
Now, the crucial part of this is what is meant by the word “small” and whether a 26 place campsite is small or not? The Report asserts that because the campsite is low density is should be classed as small even though it covers 7 hectares! While the Development Plan avoided defining precisely what small-scale means, it is relevant that the Five Lochs Management Plan (which now appears to have been axed) which promoted small campsite included plans for an 8 pitch campsite at Loch Lubnaig (now delivered), 8 pitches and 2 motorhome places at North Loch Venachar, 9 pitches at Glen Oglehead etc. None of these campsites were over 10 pitches and I think its pretty clear what the LLTNPA has meant up till now when it has talked about delivering small campsites as part of the Your Park plan. So, what has happened is that the Park has had to re-interpret the meaning of words, and therefore of whole policies, in order to get this planning applicationl through. This just brings the planning system into further disrepute. I feel every sympathy for the planning staff who must have been leaned on from on high to find the words to justify this development and have little faith that the Planning Committee will take a stand (there are unfortunately all too many examples of it ignoring or failing to enforce its own policies).
What is needed on Strathard is not one big campsite at Loch Chon that concentrates campers and results in a campervan ban but a network of small “sites” (toilet, tap and litter bin without pitches so people can choose where to put up their tents) and stopping off places. Most people would use these but those who want to camp “wild” should be able to do so – they are doing far less harm than this National Park.
