Month: October 2016

October 28, 2016 Nick Kempe 1 comment
Photo credit Alan Brattey

On Tuesday I learned from one of the good folk at the North East Mountain Trust that a helicopter had been seen at Cairngorm carrying the sandbags, which had been sitting in Coire na Ciste, into the area by the Shieling Rope tow area.   Last night I was sent some photos.    Its not clear to me what the sandbags are for (whether they are intended as a dam or are simply being stored)  or who paid for them to be brought here – but it was by helicopter!

The unlawful Sheiling track runs in front of the middle fence while the rope tow runs behind it. Photo credit Alan Brattey

That’s how it used to be done when our public authorities cared more about what happened at Cairngorm.    If sandbags can still be brought in by helicopter then so could all the materials for new fencing and for upgrading the lifts.  What that shows is there is NO need for the unlawful track that Natural Retreats has created, and which it claims is necessary for maintenance purposes (see here).   If it was the CNPA or Highlands and Islands Enterprise which required the sandbags to be brought in by helicopter they should be congratulated for acting at long last.     If the heli-lift was organised by another party, HIE and CNPA should take note and insist on such methods, which avoid damage to vegetation, being used for all future works.  Whatever the case there is no reason now for the CNPA not to reject the restrospective application for planning permission for the track and they should then start to turn their attention to how the damaged ground can be repaired and enhanced.


While its possible Natural Retreats organised the helicopter on its own initiative, there was plenty of evidence on Wednesday from elsewhere on the hill that basic standards are still being ignored.

Photo Credit Alan Brattey

The fuel bowser is still on the  west wall poma site despite the Method Statement in the planning application saying it would be stored at the Ptarmigan Garage.  Highland Council, who approved this planning application, would still appear not to have taken any enforcement action.

This ground, the line of the cable along the Car Park T-bar was supposed to have been restored but has now become a de facto track!              Photo credit Alan Brattey

The line of the ditch for the new cabling that was laid beside the car park t-bar has been turned into a new track by constant use.  There has been NO planning applications that I am aware of to create a new track here and of the justifications in the retrospective application for the shieling track was to enable vehicles to access the area from above without damaging vegetation lower down. Natural Retreats staff are clearly  driving their vehicles anywhere without any controls and HIE and the CNPA need  to stop this and ensure the damage is repaired.

Photo credit Alan Brattey

The open ditch for the cables at the bottom of the Fiacaill Poma that I saw back on my first visit to Cairngorm in June is still there!   Another illustration of Natural Retreats incompetence.


HIE should terminate their lease with Natural Retreats at Cairngorm.   Unfortunately the environmental provisions in the lease are pathetic and the other clauses not much better.  This was illustrated by a story this week in the Press and Journal under the banner “Tourism goldmine being lost” about the limited opening hours of visitor attractions in the Highlands.  The article mentioned Cairngorm Ski resort which it said is open 9am – 4pm throughout the year.    Now the P and J may have made a journalistic or printing  error, but the HIE lease with Natural Retreats requires (Clause 4a) that catering facilities at Cairngorm should be open 9-5pm in summer and 9-4pm in winter.  So, is this another example of Natural Retreats simply ignoring the terms of their lease?


While HIE’s Cairngorm Mountain has never been a goldmine – a publicly financed bank would be a much closer analogy, with investment in the wrong things and with Natural Retreats siphoning public money out of the area –  the tourist offering at Cairngorm, as the article suggests, is not good.   While catering is a tiny part of this, as an example of the tourism failure in winter there are dozens of climbers returning from the northern corries after 4pm who cannot even get a cup of tea.


The questions that HIE should answer publicly about the Cairngorm ski resort are not just why its record on the environment is so appalling but why it cannot even get basic services right for visitors and how it ever appointed such an incompetent organisation to run the ski resort.    Whether or not they are ever brought to account for their record, the answers to the problems at Cairngorm lie in transferring the land back to the Forestry Commission and transferring management of the ski area from Natural Retreats to a community based enterprise.

October 27, 2016 Nick Kempe 1 comment

p1000099-copyI was in Aberdeen on Tuesday night giving a talk to the North East Mountain Trust on “What is the Cairngorm National Park for?”.   I have been a member for years, because of the excellent work they do and their magazine Mountain Views, which I regard as an essential source of information for anyone who cares about the Cairngorms.


The latest issue contains the responses the Scottish Government has made to questions in the Scottish Parliament about the continued killing of mountain hares.     Before my talk one of their members told me they had driven over the Lecht that afternoon and seen a group of gamekeepers by the road with rows of dead hares like those that have been featured on raptor persecution Scotland (see here).     If they’d taken a photo I’d have ask to post it here but unless you have a camera with a powerful telephoto lens or are fearless (and possibly foolhardy), its very difficult to record these incidents.   Most massacres of mountain hares in the National Park, just like the illegal killing of raptors, are simply not recorded.


In my talk I showed some photos of grouse moor management taken on a recent walk  around the Dinnet Estate including the mountain hare above.  I remarked on the number of traps I had seen and asked the audience if there was anywhere worse in the National Park?p1000140-copy

Trap Glenfenzie



Two traps, one on either side of pool, leaving nothing to chance, Morven burn


A chorus of estate names rang out from the back of the room, including Invercauld which borders on the Dinnet Estate. A hillwalker had found a common gull caught in a trap earlier in the year at Geallaig Hill on Invercauld (see here) and unusually, the Gamekeeper in this case has been dismissed, although he has not apparently been charged.


At the end of my talk I was asked what we could do to make the Cairngorm National Park more effective in protecting wildlife and our landscapes.   My reply was  to the effect that photos are worth a thousand words and that ideally more people should keep a keen eye on the workings of the National Park and not just respond to consultations but take more active roles through submitting FOI requests and complaining where necessary.   In responding, I was aware that I had not entirely convinced myself or the audience.  While photos and lobbying can effect some changes, these will only go so far.


Yesterday, I thought about this again, prompted by accounts I had heard after my talk about how NEMT members were involved in not just enjoying that National Park but in practical conservation work such as maintaining paths and monitoring tree regeneration on Mar Lodge estate.  This reminded me that the recreational community, in a broad sense (not just physical activity but observing the landscape and nature) cares far more about the Cairngorms than most of the people who own it (who are responding for the persecution of wildlife and the trashing of the landscape with tracks and developments).  Yet the recreational community, who are people who basically argued for National Parks in the first place have been sidelined and don’t have a seat at the table in the proposed Partnership Plan.   Instead, what we have is Fergus Ewing MSP accusing the Cairngorms National Park Authority of bias (see here)  for not privileging gamekeepers above all other interests.  As a former member of the Mountain Rescue one might have hoped he would have appreciated the need for the recreational voice to be at the centre of what the National Park does.


So, I think the answer to the question of how do we make the Cairngorm (and indeed the Loch Lomond and Trossachs) National Park more effective, is that the recreational organisations need to assert their right to be centrally involved in running our National Parks   The answer to the question “What are our National Parks for?” lies in the question “Who are our National Parks for?”.

October 24, 2016 Nick Kempe No comments exist
The LLTNPA figures

The Loch Lomond National Park Authority Board is considering their long-awaited camping plan, which they are now gracing with the title “Camping Development Strategy” at their meeting this afternoon (see here) and (here).    Its 27 pages, full of pretty graphics and based on assertions for which there is no evidence (as I have established through FOI requests).  While I will come back to that in further posts, its worth looking at the numbers:


  • The paper refers several times to the number of existing camping places (504) but makes no reference to the current numbers who camp.  According to the Your Park consultation records shows over 800 tents camped on the lochsides on busy weekends in the summer (outside of the campsites which are generally full).  Ranger patrol records do not show the number of campervans as opposed to caravans but you could safely add another 100.   The “provision” of 322 “places” therefore leaves a shortfall of about 600 places.  Nothing is said in the strategy about this but the clear effect of the plan, if successful, will be to cleanse the National Park of campers and campervaners.
  • The number of new camping places being delivered is not 73, as claimed, but 34 (26 at Loch Chon and 8 at Rowardennan Youth Hostel).  The Sallochy campsite has now been open for three years and Loch Lubnaig two.  The LLTNPA has totally failed to deliver new campsite places since the Your Park consultation – which as it says almost everyone believes is what is needed – and there is NO sign in the strategy that this is going to improve.  There is no mention of its failure to deliver the campsites proposed in the 5 Lochs Management Plan.
  • The provision of just 20 permits for motorhomes – the term is the Park’s – is a complete disaster.   Campervans have become increasingly popular and on most days this summer I reckon at least 40 campervans pull off the A82 for the night on the way north.   The Park is proposing to provide just 9 places for campervans on West Lomond.   There are NONE in the West Trossachs Management zone despite the Park’s claim its trying to balance provision across 4 zones.   The Park have done no tourism impact assessment but its obvious this is going to be a disaster for the National Park.   Local businesses should be calling for the resignation of the Park Board if they approve this.
  • The LLTNPA has justified the provision of 26 places at Loch Chon costing c£250k  (where there is only demand for around 10 places (see here)) on the grounds that it wishes to achieve  balance across the four management zones.  This is complete rubbish.  Originally there was just one Trossachs Management zone and the lack of camping places in Trossachs West is simply a consequence of the way the boundaries have been withdrawn.   Any talk of balance is meaningless without discussion of numbers camping and the facts are that the West Trossachs zone is the least popular place for camping in the Park at present.   This number of places is simply not justified.  The only reason for the Loch Chon campsite is that the Park has failed to deliver campsites elsewhere.
  • Even more staggering though is the creation of 72 places under permit along the Forest Drive, on Forestry Commission land, north of the Duke’s pass.  The LLTNPA claims this is a popular place for camping.  A look at their ranger patrol records for July and August 2015 shows the maximum number of tents recorded there as 8!!!    In other words its an even less popular place to camp than Loch Chon but the Park is proposing three times as many places.  They are clearly wanting to cleanse the lochsides and send campers to the backwoods.   The only reason for the 72 places under permit here is because the LLTNPA needs to be able to say to Government that it has met its commitment to provide 300 places within the proposed management zones.   The LLTNPA paper which approved the byelaws listed all the places suggested for camping provision – Forest Drive was NOT included; that says it all.
  • There are also places where the number of campers who will be allowed to camp lawfully is precisely nil:
    • the A82 North of Inveruglas all the way to the Ben Glas farm campsite.  This is popular with fishermen, cycle tourers etc.   The Park has justified this complete ban by claiming that pulling off the road here is dangerous but why this should be so for campers but not day visitors is not explained.   The Park also ignores the fact that not all campers arrive by car but by bike, canoe etc, ie the type of lightweight camping the Park claims to support.
    • east Loch Lomond south of Milarrochy.   The Park’s map of existing campsites is simply wrong.   There is no campsite in Balmaha, though there is a site on Inchcailloch which is not shown.  There is no campsite in the area between Drymen and Balmaha (the nearest is at Drumquhassie Farm) south-east of Drymen.   There is a campsite at Cashel which is not shown.   This is an important issue because backpackers on the West Highland Way arrive at Balmaha after a long first day and find they have nowhere to camp and the Park has done absolutely nothing to address this issue.   So much for the West Highland Way being a world class walk!
  • The only consolation I could find in all of this is that some camping is going to be allowed under permit on the Invertrossachs Rd, the location of Loch Venachar House, the home of the Park Convener, Linda McKay.   None will be allowed at Loch Venachar Weirs and Dam (which is on the north side of Linda McKay’s property) where 25 tents were recorded in 2014 and which would make an excellent campsite.  Four permits however will be allowed on the Invertrossachs Rd.  In 2014 Ranger Patrols recorded 69 tents at Loch Venachar Quay, directly adjacent to Linda McKay’s House on land owned by the Park – camping is now impossible there because the Park has planted prickly scrub and trees all along the quay which had been gifted to the people of Callander.  The permits are therefore likely to cover the area further down Invertrossachs Road from Linda McKay’s house at Beetle Bay where a further 68 tents were recorded in 2014.
October 23, 2016 Nick Kempe No comments exist
The Owen McKee case (see here),  which I last considered a couple of months ago (see here), is on the agenda for the Loch Lomond and Trossachs Board Meeting on Monday.   Owen McKee was the former convener of the LLTNPA planning committee who, after approving the Cononish goldmine, started trading in the shares of the company that owned the mine, Scotgold Resources Ltd.  When the Board found out they conducted a secret investigation and covered up what had happened.   This came to light six months later through my FOI requests about discrepancies in the LLTNPA Board minutes.  After I referred Owen McKee to the Commissioner for Ethical Standards in public life he resigned last year.   A Hearing of the Standards Commission in April found Owen McKee had breached the Code of Conduct and would have suspended him had he not resigned.
The reason the Owen McKee case on the agenda is not because the LLTNPA Board has suddenly  started to act transparently but because the Standards Commission has forced them to do so agenda-item-6-appendix-1-standards-commission-hearing-decision.    In this letter dated 15th April the Standards Commission Chief Executive informed the Park the law required them to consider the content of the decision within three months (in public).   There is nothing in the Board paper agenda-item-6-standards-commission paper to indicate that the Park asked  for an extension and it could and should have been considered at the June Board Meeting.  Another basic failure in governance which the Park’s new auditors should take a look at.
The Board paper itself says very little.  It ask Board Members to approve a) that their attendance at a further training workshop on the registration and declaration of interests in December 2015 was an appropriate response to what happened and b)  that they should continue to update their own register of interests and declare interests at meetings.  Why Board Members should have found the declaration of interests so difficult that they needed to attend extra training, I am not sure, particularly when they rehearsed what declarations they would make at the secret Board Briefing session which took place before the meeting that approved the camping byelaws (see here):
Declarations of Interest & Decision Making 09:50-09:55
I will now hand over to Sandra to brief you on how Declarations of Interest and Decision
Making will be handled at the Special Board Meeting today.
Rehearse declarations.
As we are discussing Live Park any Members with property interests (including residential
property) in the Park, should declare a potential interest in this matter.
 Linda “I declare a potential interest in both the Your Park and Live Park
items. I own a residential house [and an area of adjoining land] within the
Park. In relation to Your Park, this may be relevant because the house is
within the boundary of the proposed Trossachs North management zone”.
 David McCowan – potential interest in business, landowner on boundary of Park
 Owen McKee – village shop, residential shop selling fishing permits, half acre land
and vice Chair of Management Committee of Rural Stirling Housing Association.
 Martin Earl – residential house
 David McKenzie – residential house in Blairmore
 David Warnock – residential house in Callanderand why they need to approve what they are legally bound to do anyway is beyond belief.
The ironic thing about this was, having written down exactly what she would say, Linda McKay forgot to actually say it at the meeting which led to another investigation by the Commissioner for Ethical Standards.    Just why the LLTNPA on Monday also need to approve that they should keep their register of interests up to date and declare interests at meetings, when they are legally bound to do anyway, is beyond belief.
When I discovered the LLTNPA Board had covered up the Owen McKee case I referred all the Board Members at the time to the Commissioner for Ethical Standards for acting contrary to the principles of transparency, honesty and integrity which are supposed to govern public life.  The Commissioner for Ethical Standards however said that since there was NO specific clause in the Code of Conduct requiring Board Members to report colleagues who had breached the Code he could take no action.    I found this bizarre but accept that what the Commissioner can and can’t do at present  is closely regulated.

What the LLTNPA should do following the Owen McKee Case

LLTNPA Board Members though do have a chance to redeem themselves on Monday.  The Paper asks them for any other actions or decisions as a result of the decision by the Standards Commission.   I think they should welcome what the Standards Commission panel chair, Kevin Dunion,  said after the Hearing:
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”
and admit they were wrong not to refer Owen McKee to the Commissioner for Ethical Standards.
They could consider:
  • whether it was right for Board Members to sign off the investigation into Owen McKee by the chair of Audit, Lindsay Morrison, without reading his report
  • whether Owen McKee’s backing for the Cononish goldmine planning application prior to buying the shares was motivated by a wish to benefit from this personally and what influence Owen McKee had, as planning chair, on the decision-making process
  • why Owen McKee continued to purchase shares in Scotgold Ltd (as documents in Lindsay Morrison’s report) when the share price was falling
  • what procedures need to be put in place to ensure cases like this are referred to their auditors timeously (Audit Scotland only found out when the story appeared in the Sunday Herald)
  • the role of their Audit Committee in such cases.  The Audit Committee never considered the case despite referring to “the Authority’s values of transparency” and claiming that “The Committee has received full reports on issues raised; considered recommendations
    made; and approved responses and actions” in their annual report to the Board which also appears in Monday’s meeting papers.
  • the role of their Convener, Linda McKay, in the whole debacle and whether they should not have challenged her further on the need to  refer Owen McKee to the Commissioner for Ethical Standards (as suggested by one Board Member).

Whether the Board will consider all of this is another matter.

October 21, 2016 Nick Kempe No comments exist
“This slope is revegetating well” CNPA ecology adviser 16th September 2016.

The CNPA planning committee is today but there is NOTHING on the agenda on the retrospective application for the Shieling Hill track or other works which Natural Retreats undertook without planning permission(see here).  The deadline for determining the planning application was 6th October so I thought it might appear but the CNPA  planning portal still does say whether the application will be decided by Committee or not.  Committee Members should ask officers what is going on.


Meantime, here’s some more evidence for them to consider.  Thanks to a reader for some photos of the bank  which was “reprofiled” by Natural Retreats without planning permission and which they have since claimed makes the area look more natural.  The latest photos show the revegetation referred to by the ecology adviser does not look quite so impressive from other angles.bank161019b

The bank below the Shieling rope tow 19th October 2016



The lack of vegetation compared to what was there previously is obvious.  More evidence that Natural Retreats did not store or re-use most, if any, of the vegetation whch covered the old bank before they destroyed it in order to obtain material to raise up the bottom pylon of the shieling rope tow.

The bank, on the right of the photo, was not eroding prior to it being destroyed as claimed by the ecology adviser in their report to the CNPA.

I was on the hill yesterday with a civil engineer who had been involved in construction of the funicular.  Not only was all the vegetation stored but each layer of soil was stored separately (in bags) and replaced in the right order.   The people involved made sure everything was done properly because they knew if not the then planning authority would have landed on them like a ton of bricks.  Everything they did was scrutinised.   The problem with the Shieling rope tow was not so much in the original planning – the Method Statement setting out the proposed construction techniques said most of the right things (its quite easy of course to pay consultants to write down all the things that should  happen) – it was the complete lack of monitoring by HIE and a lack of will on the part of CNPA to take enforcement action as soon as they were informed of what was going on.


Unfortunately, our National Parks are not alone in failing to enforce Method Statements.   The consequence has been that its common across Scotland for Method Statements, which tick all the boxes in terms of setting out good practice, to be ignored in practice.   Our National Parks should be doing better.  The current silence from the CNPA about the Shieling Hill track suggests they are simply hoping the matter will go away.

October 18, 2016 Nick Kempe 2 comments




I am up in the north-west Highlands for a week, staying near Gairloch, and yesterday walked into Beinn an Eoin from Loch Bad Scalaig.   The first part of the track is through a native woodland scheme planted in 1998 and then leads on to the former bothy, Poca Buidhe, almost 12k in all.   Its  used by vehicles for stalking.  What struck me is how narrow it is, like a footpath, about 1.5m wide and as a consequence enjoyable to walk.  In many places the Poca Buidhe track just disappears from view although there are still places where there is a signficant impact on the landscape, as is in the photo above where the track runs above the Abhainn a Garbh Coire.


On my reading the Loch Lomond and Trossachs National Park Authority set out similar aspirations for hill tracks in the National Park in its Guidance on Renewables:


“It is expected that where possible, the type of vehicles that will require access after restoration of the tracks  will be light, low-pressure vehicles, such as quad bike or equivalent.

If access tracks are to be retained for light low-pressure vehicles, the visual impact of these tracks should be minimised by downsizing the width, green re-instatement track methods and local mitigation measures such as planting and rock/boulder placement”.

ALL of the hydro tracks in Glen Falloch, approved by LLTNPA officers are far wider than would be needed for a quad bike or similar, leaving aside there is no evidence that there was any “overwhelming need” for these tracks to be retained (see here).

Looking across Glen Falloch from the Eas Eonan track

The narrowest tracks are about 2m wide.   Gordon Watson, the Chief Executive of the LLTNPA, has subsequently stated in writing that planning conditions require construction tracks to be reduced to 2m (2.5m at bends).    While I believe this is simply his latest re-interpretation of the LLTNPA’s policy and, as the Torridon photo shows, is needlessly broad, in practice the LLTNPA was approving tracks in Glen Falloch while he was Director of Planning that are wider than his quoted maximum:


  • The Glen Falloch extension track is 2.5m wide (see here)
  • The Eas  Eonan and Allt a Chuillinn schemes 2.5m (see here)
  • Allt Fionn width not specified but the “minimum” necessary for use by a landrover (see here)


Only the Ben Glas track, approved at end of 2015, states the track should be reduced to 2m (and 2.5m at bends).


This shows that once again LLTNPA officers are ignoring their own policy, both the written policy which was good in intention if too vague, and Gordon Watson’s re-interpretation of this to mean tracks should be 2m wide.    I don’t believe there was an “overwhelming reason” to allow these hydro construction tracks to be retained but even if there was, if the Gairloch Estate can manage on 1.5m tracks so should estates within our National Parks.

Part of the West Highland Way in Glen Falloch which is also used by estate vehicles. Its closer to 1.5m in width than 2m.

Reducing the width of these hydro tracks would help them merge with the landscape over time (which is what the LLTNPA claims it wants).  The LLTNPA should be setting an example of best practice and I regret that so far it has conspicuously failed to do this.  It is not too late.  The Glen Falloch Estates will make a fortune from these hydro schemes over the next 10 years paid for by the public and the least they can do in return is reduce the impact of the destruction they have caused.

Hill track Dinnet


At least the LLTNPA appears to have a policy position on the width of tracks.  The Cairngorms National Park Authority produced an 18 page report on the Dinnet Hill Tracks without mentioning the width of tracks once item8aadinnettracks20160004det.   More on that in a future post.


October 16, 2016 Nick Kempe No comments exist


On 11th October Natural Retreats posted this photo on the behind the scenes section of the Cairngorm Mountain blog.   The caption above it read:

The West Wall Poma project is progressing well, with the steel work installation scheduled to commence on Monday 17th of October. The picture below shows a 20 tonne excavator which has been instrumental in most of the excavations, ground works and lifting and positioning equipment. In this image you can see the driver creating a path of pads for travelling over the route to Tower 16.


Has good practice now arrived at Cairngorm?    Its too early to say, but I suspect excavator creating its own board walk was done for the cameras judging by the evidence from the Ptarmigan webcam just a few days earlier (see here).     You only have to scroll down to the previous post, dated 7th September, to see how Natural Retreats operates for most of the time.




The caption to this read “Below you can see a digger starting work on the initial trench that that (sic) cable will go into. This ground will be fully reinstated once the entire cable is laid.”

What you can see clearly in the photo is how use by vehicles (which are not supposed to drive here), including the digger, have eroded the ground vegetation and created tracks prior to the cable trench being dug.   The ground could never be fully reinstated as Natural Retreats as claimed in their photo caption because their vehicles had already destroyed much of it.


Highlands and Islands Enterprise, are not just the landowners, they are funding much of this farce.  Dave Morris had a letter in the Herald on Friday (see here) about HIE which included this paragraph on HIE’s ownership of Cairngorm:

In 1971 a disastrous decision by the UK Government led to the transfer of nearly 1,500 hectares of the upper slopes of Glenmore National Forest Park from Forestry Commission ownership to Highlands and Islands Development Board, the HIE predecessor body. Today the First Minister can see the result of so-called stewardship of this iconic tract of land by HIDB/HIE – abandoned ski tows and chairlifts, derelict and decaying buildings, collapsed and rotting snow fences and zero possibility that her public agency knows how to plan for the future. The economic heart of our largest national park continues its downhill spiral. Ms Sturgeon needs only a brief exposure to HIE’s incompetence in mountain land management to realise this land must be returned to the Forestry Commission (FC) as soon as possible. We need integrated planning and operations, from the lowest to the highest slopes of Cairn Gorm, by the public body which has been managing land in the Cairngorms since 1923; even better if the FC can also establish a community development trust to involve local and national stakeholders in its management of the whole Forest Park.

With the Government currently reviewing the role of HIE it could, if it had the political will, put a stop to the destruction at Cairngorm in a twinkling as Natural Retreats have shown they won’t  do anything without public funding.

October 15, 2016 Nick Kempe No comments exist


As the gateway to Loch Lomond and the unofficial capital of Scotland’s first National Park the village of Balloch should be the jewel in the crown of Loch Lomond and one of Scotland’s top tourist destinations. However, it has it has failed to live up to this billing for some time now which, in part, is due its industrial past, fragmented land ownerships and various abortive attempts by the private and public sector to realise its full tourism potential. Is this all about to change with the emergence of the £33 million plans for the former derelict land at West Riverside and the derelict and unsightly  Grade A Hamilton House  site between Loch Lomond Shores and the A82? Will this turn the village and the nearby £45million Loch Lomond Shores  into a year round holiday resort destination instead of a dislocated village dominated by Loch Lomond Shores where there is predominantly an 11.00am-4.00pm day visitor economy separated from the ‘old village’ by the partially reclaimed West Riverside site? Will more much needed year round jobs be created with decent wages to replace some of the large number of jobs lost in nearby Vale of Leven? It is difficult to say at this stage due to the scant information that has been announced by Scottish Enterprise who have kept their ‘preferred developers’ at arms length from the local community and other interested parties such as the Friends of Loch Lomond for more than 9 months now despite the Balloch Charrette (a supposedly dynamic and open community planning  consultation exercise) providing a golden opportunity for the developers to sit in and obtain a flavour of what the local community wants as well as sharing their preliminary plans.


Unwittingly, the secrecy of Scottish Enterprise and the clumsy way they have handled the PR so far has proved to be a major setback for the ambition to realise Balloch’s tourism potential with several petitions and reams of negative press emerging over the past month or so to try and block any plans that the Scots owners of Flamingo Land have for the village. This is a great pity and probably could have been avoided if SE officials had engaged in a more open and meaningful consultative process at a much earlier stage and hadn’t hidden behind  ‘commercial confidentiality’ screens. Hopefully the situation can be retrieved and there will now be more open and meaningful dialogue with the local community and interested parties to help shape plans that could be of major benefit to the village as it seeks to realise its tourism potential in a way that greatly enhances its status as the gateway to the National Park and the unofficial capital of the National Park. Time will tell.


In the pre and post Second World War era Balloch was a hugely popular destination with a large section of the West of Scotland population being regular visitors when the factories shut on a Friday night and thousands of workers and their families made a break for the clean air of nearby Loch Lomond with its  range of simple  and largely free recreational opportunities. This began to change in the 1960s and 1970s with the advent of the cheap sun package holidays which, for decades now, has seen tens of thousands from the Greater Glasgow area taking flight overseas resulting in the Glasgow Fair fortnight being one of the quieter periods in Balloch. Notwithstanding this, Loch Lomond (not Balloch) has remained  the number one countryside day visitor destination in Scotland largely due to its close proximity to large concentrations of population. There have been some notable tourism investments by local companies such as the long established and family owned Sweeney’s Cruises and more recently by some national pub and hotel chains.


Scottish Enterprise and House of Fraser spent close on £45 million on the phase 1 Loch Lomond Shores development which opened in 2002 to coincide with the establishment of  the National Park. The central feature of this development, Drumkinnon Tower, which cost the taxpayer around £14 million, quickly failed and had to be re-invented  following a costly conversion into a Sealife Centre. However, in recent years Loch Lomond Shores has begun to flourish largely due to the hard work and dedication of the small management team led by Clare Gemmill who has introduced a strong and very successful events led programme. A number of businesses have stuck with Loch Lomond Shores through leaner times and are now hopefully in a  much healthier position trading wise. The Park Authority has encouraged some outdoor activity and birdlife operators to locate there too in recent years and has also directly invested in much needed boat trip pontoon facilities connecting the loch and the shores development for the first time. Plans are also being progressed to convert the National Park Gateway Centre into a restaurant and events venue. This publicly funded facility has sadly lain empty for several years now despite still being signposted on the main road network.


It has been interesting to see the five or so articles on ‘Parkswatch’ relating to the outline plans for the land at West Riverside linked with a good dose of agency bashing. I don’t believe the National Park Authority  deserves a bashing in this instance as they have not been leading the efforts to interest developers in the site-this has been the sole responsibility of Scottish Enterprise as landowners on behalf of the Scottish Government and  taxpayers.  Makes for good copy though but factually incorrect, particularly in some of the earlier articles regarding issues such as the  non- advertisement of the site . It has been widely advertised in publications like the Herald and the potential range of site uses has been listed on a large hoarding prominently displayed next to the Balloch end of the site and adjacent to the tourist information centre for several years at least. Various schemes for the site have come and gone over the past 30 years or so. There have also been several preferred bidders over the last 7  years but they have never quite made it over the line for various reasons including, allegedly, Scottish Enterprise’s unwillingness to fund further land remedial works.  However, you are correct in mentioning the site was formerly derelict . Going back to the 1980s much of the site was a no go area with contaminated land linked to its former uses as a silk dye works factory, extensive railway sidings and sand and gravel workings. Much of the site was abandoned derelict land which had been neglected for many years by the owners of three separate pieces of land.

The attached photo above, which was taken around 1960, provides a birds eye view of the site which is currently the subject of so much controversy. Hardly a picture postcard extolling the scenic qualities of Loch Lomond! Admittedly, much of the dereliction no longer exists but the site doesn’t have high scenic qualities and is still generally in a poor condition. You can clearly see the extent of the land covered by railway sidings and the former rail link with the pier where Maid of the Loch is moored awaiting restoration. In the middle foreground you can see the steam beam engine house and slipway. This has been restored by the Steamship charity with funding support from HLF, Scottish Enterprise and others (£600k plus) and they organise popular steam days throughout the main tourist season. Interesting also to see part of the site next to the disused gravel pits was used as a caravan park with more than 60 static caravans in view. You can also see part of the former silk dye works site in the middle right of the picture which has largely been covered by a housing estate now. This used to be dominated by large chimney stacks which acted as a navigation beacon for boat users on the loch.

In the mid 1980s the Area Tourist Board tackled some of the dereliction on the edges of the site with the use of 100 or so unemployed people from the Vale of Leven with the help of Manpower Services Commission funding as part of ‘Operation Bonnie Banks’. This resulted in a safe beach area being created, the removal of the remains of dangerous and unsightly brick walls as part of the main gated entrance to the silk dye works and much more as part of an effort trying to provide some useful jobs for the long term unemployed and addressing  civic pride issues. A great success with limited resources .


At that time the Scottish Tourist Board also joined forces with Bredero to have a comprehensive look at what could be done longer term if the piecemeal land ownerships were brought together. A major development options study was undertaken and concluded there was scope to develop an indoor leisure centre (similar to Rhyl Sun Centre in North Wales) and housing. Some time later Cala Homes came forward with an ambitious plan to cover the site in luxury housing with those on the loch front having their own private boat moorings. Dumbarton District Council planners in their wisdom recommended approval but thankfully Councillors refused the development planning permission after listening to the strong representation from the Friends of Loch Lomond, the Area Tourist Board and the Balloch community who argued that this was too important a site for recreation and tourism to be allowed to be developed for housing. An expensive public inquiry was then held and the late Hannah Stirling, the then Chairman of the Friends of Loch Lomond contributed a substantial sum to hire a QC to fight the case along with local Councillors and the Area Tourist Board. Fortunately the case was won by the objectors and Scottish Enterprise was encouraged to purchase the site and to progress plans primarily for tourism and leisure development.


This is the background to what led to the phase 1 Loch Lomond Shores development and there was always an intention to develop a phase 2 to link the centre of Balloch with the lochshore more effectively. Much earlier In the early days of the Joint Committee which preceded the creation of a National Park the then Scottish Development Agency was encouraged to purchase the West Riverside site which was owned by British Rail. They worked with the Joint Committee and the Area Tourist Board to restore the derelict former railway station building in the centre of Balloch which was converted into a tourist information centre and offices. The land between the Station building and Balloch Pier beside the River Leven was also restored and extensively landscaped with a new path. Derelict moorings and sunken boats were also removed from the West Riverside edge of the River Leven with the help of Loch Lomond Association.


Various attempts have been made over the years to market all or part of the site for hotel and leisure development with mixed success. Occasionally Scottish Enterprise have mooted the idea of part of the land being used for housing but this has been strongly resisted by the Friends and others. There was also previously a couple of preferred bidders to develop the site which fell by the wayside for a variety of reasons. In previous cases and this case the site was well advertised by Scottish Enterprise. The site has also appeared in local Development Plans as an area with tourism and recreation development potential.


Given this site history (apologies for the level of detail but I think it is important to set the context) the Friends and others have been consistent in their desire to see the site being developed for a range tourism and recreational uses. However, this doesn’t mean we will accept anything and we will be reviewing the latest plans very carefully though it does appear the general thrust of what is planned is entirely consistent with what has been proposed for the site for many years with strong riverside boardwalk links between the centre of Balloch and a mix of family orientated tourist accommodation and recreation facilities.


I wonder if the company selected to work up a scheme for this former derelict site hadn’t been called Flamingoland if there would be such a furore? Had Forest Trails come forward with a scheme here I doubt it. Pleased to see glamping and a much needed youth hostel featuring in the emerging proposals given the loss several years ago of Loch Lomond Youth Hostel to a private house and the emergence of Balloch as a key location where the John Muir Way and Three Lochs Way Great Walking Trails merge. It will be interesting to see in due course what the eventual mix of accommodation is by type and price point. Sounds as if they are aiming to serve a wide range of socio-economic groups which would be very welcome as not everyone can afford to stay at the up market Cameron House and neighbouring timeshare lodges.


The detail of the preliminary plans have not yet been made public, apart from the scant information in the poorly pulled together news release issued by Scottish Enterprise, so let’s not pre-judge their plans and prematurely question Flamingo land’s ability to deliver a quality  tourism development along the lines of a possible mini-Center Parcs with a blend of accommodation and indoor and outdoor recreation facilities that are potentially a ‘good fit’ at this location. Scottish Enterprise needs to remove the shackles now from the preferred developers so that they can meaningfully engage with the local community and other interested parties. The Friends are on the case and following an approach to a local businessman who is involved in the project a preliminary exploratory meeting with the owner of Flamingoland has now been held. Direct communication channels have also been established with the Community Council. There is much work still to be undertaken investigating ground conditions, traffic management issues and more before a revised master plan for the site is finalised. However, a preliminary viewing of the outline plans suggests the developers are taking account of the sensitivities of this important site at the southern end of the loch and the plans are far removed from what has been suggested in the press and elsewhere. Hopefully there will be an opportunity to influence the final plans as they are worked up into a detailed masterplan prior to a detailed planning application being submitted to the National Park Authority.


I hope this note helps bring some balance to the current debate on the future of what is the last major site for tourism and recreation development in the Loch Lomond area . I am hopeful that a scheme emerges which meets the aspirations of local residents and visitors from all backgrounds and socio economic groups. Incidentally, great news that West Dunbartonshire Council has recently committed  £1.4 million for two village squares and public realm works in the centre of Balloch which emerged as community priorities during the recent planning charrette exercise. Just goes to show the agencies do sometimes take on board community wish lists. Shame though about loss of land next to NPA HQ for housing instead of much needed car parking. The recent announcement on the planned £33 million investment by Flamingoland reinforces the folly of this decision by the NPA Board members based on the recommendation of planners who failed to recognise the importance of providing more parking at key locations such as this close to the main street in the village and the entrance to Balloch Castle Country Park. Not convinced the Balloch Charrette final report or the preliminary study terms of reference for work on the village square at the former railway station have fully grasped the scale of future car and coach parking requirements to ensure Balloch flourishes as a year round quality tourist destination but that is another story.

October 14, 2016 Nick Kempe 4 comments
Eroding bulldozed track with burnt heather moorland behind on Dinnet Estate September 2016


As readers will know, there are now several organisations trying to get the Cairngorms National Parks Authority to address the problems associated with grouse moors: destruction of habitats, destruction of the landscape, destruction of wildlife and destruction of the rural population.    There have been several signs in the last couple of weeks that landowners are fighting back and putting considerable pressure on the CNPA to make sure the new National Park Partnership Plan contains nothing that will upset their interests.
The first was at the last CNPA Board Meeting where Grant Moir, the Chief Executive had this to report on moorland management:
“We have just received confirmation that we have been successful in obtaining funding through ECAF (Environmental Co-operation Action Fund) for the East Cairngorms Moorland Partnership. This will fund project development work to enhance habitat and species diversity”.
In the draft Partnership Plan the East Cairngorms Moorland Partnership was identified as the main mechanism to deliver the Park’s ambitions for grouse moors (nothing was identified for moorland estates in the rest of the National Park)  and now we know why, a funding application had already been submitted.     Now there are some good things about the ECAF (see here)  – Hen Harrier is a priority species on moorland even if nothing is said about eagle or mountain hare  – but there is nothing that I can see in the scheme about cross-compliance.    Despite the recent raptor killings on Speyside, the eastern Cairngorms is where wildlife persecution has historically been most intense.  So the landowners who have done most to persecute and destroy our wildlife and habitats are now being paid to restore a bit of it.    The public should be very sceptical.    I suspect this is an attempt by the Scottish Government to try and kick the issue of wildlife persecution in the National Park into the long grass.  In response to any demand for action, they can now say “we have funded the East Cairngorms Moorlands Partnership to address these issues and need to give this time to see if it works.     I hope that the CNPA will help ensure that there is transparent reporting about the objectives that have been agreed and what progress is being made.  These estates need to be held to account and, as I have suggested before, any further incidences of raptor persecution should result in the removal of ALL rural payments to the estate concerned.
The second sign of the landowners fight back appeared on the  CNPA blog on 7th October:

The Cairngorms National Park Authority (CNPA) met with the Scottish Gamekeepers Association (SGA) on the 29 September to discuss the National Park Partnership Plan consultation and specific issues around grouse management. The SGA raised concerns about a recent blog on the CNPA website which they felt did not reflect the work being done on grouse moors.

There was a robust exchange of views with Gamekeepers setting out their views on grouse and moorland management and the CNPA setting out the need to debate future management as part of the consultation. The meeting ended with an agreement to meet more regularly with the SGA and Moorland Groups so that further discussion can take place on these issues.


I welcomed (see here) the original blog by Will Boyd Wallis for trying to promote debate on how our grouse moors should be managed but criticised it for not being radical enough.  While we already know that the Scottish Gamekeepers Association, who act on behalf of their employers, the landowners, object to any debate on moorland management what is interesting is that the CNPA has had to give them time to air their much voiced views.  The danger here is that the CNPA tries to convince itself that there is a middle way, in which the current lack of any real action is continued into the next Partnership Plan, and this is then justified as a need to hold the ring between two opposing interests.


The third sign of the pressure the CNPA is under was the open attack by Fergus Ewing, MSP for Inverness and Nairn, but now Cabinet Secretary for the Rural Economy in his column in the Strathie last week (see here) .  Fergus Ewing states the CNPA meeting with the Scottish Gamekeepers Association was  “following my intervention, subsequently arranged actually to hear the views of local keepers and others”.  In other words he forced the CNPA to meet the representatives of the people who, on behalf of the landowners, have been responsible for killing so much wildlife in the National Park.   He goes on to say  “But in a letter to me the park refused to accept there was anything wrong, and refused to permit the other side of the case to be published on its website. Given that a formal park consultation is ongoing, that does not seem to be balanced or fair. The second principle of natural law is – Audi Alteram Partem – hear both sides of the case! ”   


Fergus Ewing does not appear to realise that while there are two sides to the case on moorland management, the CNPA at present is not on either side.  It has been sitting on a fence somewhere in the middle.   If Fergus Ewing wants SGA’s views promoted on the CNPA website he should also, according to the Latin, be calling for Raptor Persecution Scotland, the LINK hill tracks group etc to be given space on the CNPA blog.


What the SGA, the landowners and now apparently Fergus Ewing are worried about is that the CNPA might now at last, in the face of overwhelming evidence, jump off the fence and start to stand up for the conservation purpose of the National Park and develop an altnerative plan for the moorlands in the National Park (some of which might be to allow these areas to go wild).   This would end gamekeeping as we know it but could also create more and better paid jobs.


Fergus Ewing does not have Ministerial responsibility for National Parks but I would not underestimate the pressure he will be putting on Roseanna Cunningham, the Environment Secretary, to ensure the new CNPA partnership plan does nothing to address the destruction going on in the moorlands of our National Park.  Both the CNPA and Roseanna Cunningham should stand up to both Fergus Ewing and the landowning interests which have been working on him behind the scenes.


Both should take heart from the annoucement yesterday that there is to be a debate in the UK Parliament about banning driven grouse shooting on 31st October.  Many of the people who signed were from Scotland and this is a clear sign that public opinion is now in favour of changing the ways our moorland is managed.



October 13, 2016 Nick Kempe No comments exist


Last week I received a reply from the Loch Lomond and Trossachs National Park to my question about how much the new parking meters at Inveruglas had cost.  I made the mistake first time of asking how much it had cost the LLTNPA to install these meters and was told (eir-2016-040-response-car-parks-and-charges)  £562.20 plus two hours labour from National Park staff.  So, I had to ask again but now know   (eir-2016-050-response-cost-inveruglas-pay-and-display) they cost £7846.   However, because the LLTNPA  tendered for an Automatic Number Plate Recognition system for this car park  (see here) almost as soon as it had installed the meters,  this money has been wasted as new equipment will be required.


Leafield recycled litter bin £145

Its a bit like dreaming how you might spend the lottery but I would have spent the £8408.20 on litter bins for the west Loch Lomond laybys and then asked (or shamed if necessary) Argyll and Bute Council to get their bin lorries to empty them as they drive past.   On the internet and heritage litter bins cost somewhere between £150 and £350.   Purchase through a public sector contract and maybe the National Park would get a discount and the delivery thrown in.   Even 24 high quality bins would be a start.


There was a very good article on the management of litter in the Voice, the magazine of the Friends of Loch Lomond and Trossachs, which came out this week.  Along with a photo of overflowing litter bins at Balmaha, it pointed out that every layby along the A9 has bins, unlike the A82, and there is no litter problem.

Layby between Ballater and Balmoral

The Voice might have added that the A93 on the other side of the Cairngorms National Park is the same and what’s good enough for Royal Deeside should also be good enough for Loch Lomondside.


The level of waste at Inveruglas is paltry compared to the £345k that the LLTNPA budgeted to spend this year on creating camping places for which there is no demand at Loch Chon  (see here).  And that is likely to be dwarfed by the resources the LLTNPA will have to devote to trying to police the proposed camping byelaws.


I believe the main explanation of this waste of resources is less management competence than the LLTNPA getting its priorities wrong.  If instead of trying to police campers the LLTNPA were to focus on basic infrastructure such as toilets (the Voice has another excellent article on the impact of staff cuts on the public toilets at Luss), litter bins and barbecue pits, it would have far more chance of success.   This infrastructure would cost far less than the extension of camping byelaws and would remove the need for the National Park to start charging for everything, which is what led to the stupid decision to install car parking meters in Inveruglas in the first place.

October 12, 2016 Nick Kempe 1 comment
The new concrete plinth for the replacement West Wall poma return wheel can be seen just left of centre
Breaches of the planning permission granted by Highland Council to Natural Retreats to replace the West Wall poma return wheel and re-landscape the off-ramp have been continuing (see here)
Fuel bowser and plastic container on site


The Planning Method Statement required “All fuelling and oils to be carried out in appropriate areas” and stated this would be “outside top station garage, where all fuelling and proper storage of fuel is to be kept”.    The point of this was to prevent an oil spill on the plateau.  Natural Retreats and the contractors have ignored the requirement.

McGowan’s vehicle parked on vegetation

Natural Retreats planning application claimed that “A site cordon for access will be established to control vehicle movement and prevent damage to vegetation” and required the “Contractor to park up any machinery on existing track”.  Again, this is clearly not happening.


These and other breaches of planning permission have been reported to Highland Council, who have at least visited the site, but so far no other action has been taken.  Both Highland Council and Cairngorms National Park Authority appear to be in a complete state of paralysis when it comes to using their enforcement powers.


“Empowering planning to deliver great places” is the title of the Scottish Government’s independent review of the planning system published earlier this year.    It’s quite clear about the need for planning authorities to use their enforcement powers:


We acknowledge that there are concerns about planning authorities not taking enforcement action. Our understanding is that the legislation already allows for a wide range of action to be taken and that there are already options to respond quickly to a breach including fixed penalties and interim stop notices. We also propose that this work considers whether fixed penalties and fees for retrospective applications should be substantially increased to provide a more effective deterrent. (paragraph 30)


Cairngorm is a great mountain, the Cairngorm ski area should be a great place and its time that CNPA and Highland Council recognised that Natural Retreats cannot be trusted to deliver that great place and they need to start exercising a far greater degree of control over what is happening there.  If they want advice on this perhaps they should ring Petra Biberbach, who was on the three member panel that produced “Empowering Planning” and is Chair of the Planning Committee at the Loch Lomond and Trossachs National Park Authority.   I would hope she agrees that how Natural Retreats is operating is just the sort of thing that brings the planning system into disrepute.


Planning Authorities though also need to ensure the right specfications are agreed in the first place.     The Ptarmigan area has been overrun with vehicles during the works on the West Wall poma.  This presents a real contrast to the days when vehicle access to the hill was closely controlled and the access track to the top station was still called the “emergency access track”.

Just how many vehicles are really required to do this work?                     Photo Credit Terry Smith 10/10/16
Unfortunately Highland Council never thought to question just how many vehicles would be brought up the access track and why.  Surely the contractor’s staff could have accessed the construction site  by the funicular reducing the erosion on the access track?  The problem is that the planners simply do not have the expertise to know what should be required for works in sensitive environments and whereas previously there used to be a comprehensive estate management plan for Cairngorm (cemp2-adopted-plan) which involved all the agencies, there is now………… nothing.      While primary responsibility for this lies with HIE, as the landowner, it is ironic that standards have collapsed during the lifetime of the National Park.
Its worth reading the vision from the last Cairngorm Estate Management Plan – its amazing that this was not simply updated for the Glenmore Cairngorm Strategy:
Our vision sees the high hills returned to the most natural state possible, while continuing to provide a high quality educational, wild-land and recreational experience, including downhill skiing facilities at Cairn Gorm, Glenshee and the Lecht. These uses will be managed to ensure minimal damage, and allow clear trends towards ground recovery by natural processes to develop. We also foresee that local communities will continue to benefit from the visitors who are attracted by the hills.


The last Estate Management Plan also provided for “An annual tour of inspection of the Ski Area will take place in May to which SNH and other interested parties will be invited. Works requiring restoration will be reported to Cairngorm Mountain Limited and others, as appropriate, for action.”     The planning authorities don’t need to re-invent the wheel, they simply need to say that they expect Natural Retreats to abide by former environmental standards and then enforce these.


October 11, 2016 Nick Kempe No comments exist
Rubbish in the field opposite Park Convenor, Linda McKay’s House, at the east end of Loch Venachar 8/10/16

On Saturday I went rock climbing on Ben An, the first time in many years, with my friend Mike who had never climbed there.   En route from Callander I checked whether anything had been done about the farm litter beside the road opposite Loch Venachar House, home to the Loch Lomond and Trossachs National Park Authority Convener, Linda McKay.   As you can see, its still there, 18 months after I first photographed it  (and there is more of it than is in the photo).   To my mind this is worse than any of the photographs of abandoned tents that is being used to justify the camping ban and would take a lot more effort to clear up.


However, to the LLTNPA this rubbish is a non-issue.  Its rangers, who patrol the shores of Loch Venachar on a daily basis, pass this festering pile every day during the summer but two summer seasons have gone by and nothing has been done about it.   The Park Convener must have seen it too, but her only concern appears to be to stop the campers camping on the loch shore near her house.    What counts as a problem, is ideological and the LLTNPA has made political choices about this.   Rubbish left by campers is photographed to justify the removal of access rights, while rubbish left by farmers is simply left to rot and has no consequences for them at all.   The LLTNPA could be making the argument that we should stop paying public subsidies to farmers who dump rubbish in our National Parks but its not, it would rather focus on getting rid of campers.


A couple of miles further on  we dropped in to look at the second north Loch Venachar site, owned by the LLTNPA.   The two carparks provide the best bases for roadside and lochside camping between Callander and Loch Katrine, being located away from houses and with a number of good spots to pitch a tent.    The LLTNPA had been going to provide a campsite here, under the visionary Five Lochs Plan, but those plans appear to have been scrapped without explanation  (see here)  and I will be very surprised if the site features on the camping plan which will be up for formal approval at the next LTNPA Board Meeting on Monday 24th October.   It should be.




As I wanted to take a photo, we walked over to the campers to have a word with them.  They turned out to be fishermen, who go camping all over Scotland and who were out to enjoy themselves.  One had come to camping through Fairbridge Drake, as it then was, which helped inner city young people to enjoy the countryside.   A success you might have thought


The fire pit in this picture was caused by earlier visitors. The campers had brought their own wood.


I asked the fishermen if they knew about the proposed byelaws and this could stop them camping here in future (if they wanted to camp before 30th September).   There was a chorus of no-one will stop us camping!   I was then asked why someone who was English – I am afraid I have not lost my accent in 25 years – was taking an interest in this and when I said I was from Glasgow, rather than Glesga, I was given a right ribbing!


There was a pile of empties on the ground, which the  campers unprompted said they would clear up afterwards,  and besides the logs the campers had brought pallets for burning.    Now I am not naive enough not to have wondered where the logs might have come from, although they were definitely not from around the campsite, but it seemed to me that the pleasure these guys were getting from being out in the countryside far outweighed the impacts they were having, and in any case these should be easy to manage.


Worried that rubbish might be left?   I took the guys at face value, but things can happen, people can drink a bit too much and feel hungover, it starts to pour with rain and people rush to their vehicles without clearing everything up.  The solution is simple.  Get the Rangers to take a photo of the vehicle, as the police used to do, as insurance and evidence that could be used to impose a fixed penalty notice.  You can guarantee the place would be spotless the next day.


Worried about the source of the wood?   Well the original plans in the Five Lochs Plan were not only to create barbecue pits at these carparks but also create wood stores which would have removed any temptation for people to cut down trees.    The wood store was not included in the revised plans although Forestry Commission Scotland has a huge supply of wood just down the road by Ben An.

The FCS has been removing alien conifers from Ben Avon and leaving whole tree trunks on the ground to rot. It would be very simple to provide some of this to allow people to enjoy campfires.

The solutions to problems that can be caused by people camping are very simple.    First you put in infrastructure and for north Loch Venachar the best starting place would be to implement the  5 Lochs Plan (see below) instead of abandoning.   Second, the Park’s Rangers need to talk to anyone, whoever they are.  The focus of this needs to be on what people are enjoying (we talked to the fishermen about their fishing) rather than focussing on might they might be doing wrong.  But that I am afraid requires tolerance, a quality that the LLTNPA Board and senior staff appear to be lacking.


Extract from original Five Lochs Plan showing the North Loch Venachar camping area and toilet


October 10, 2016 Nick Kempe 2 comments
Last week the Heritage Lottery Fund announced that it had awarded £2.34m to the Tomintoul & Glenlivet Landscape Partnership in the northern part of the Cairngorms National Park  to deliver 20 projects over a four year period (see here).
The plans include:
  • Tomintoul Museum will become a Discovery Centre and tourist hub
  • Blairfindy Castle and Scalan, an 18th-century seminary, will be conserved and made safe for visitors
  • Woodlands will be restored along sections of the River Avon
  • Wetland habitats for wading birds will be created
  • Improvements to paths in the area
  • A regional oral history project will collect stories that bring the landscape to life


While I am delighted that this investment is being made, we need to ask why funding for our National Parks appears  dependent on grant applications?   Like other under-funded public authorities, what the CNPA has done is to set up a number of Partnerships, which it uses to make funding applications because it does not have the resources to do things itself.   Another example recently covered on parkswatch is the investment in upland footpaths through the Cairngorms Outdoor Access Project (see here) .

The last CNPA Board meeting reported that the Tomintoul and Glenlivet Landscape Partnership had applied for £3.6m so there is a shortfall between what was awarded and what is needed.   None of the Press Releases mention this as it detracts from the good news and might get people thinking are we really investing what we need to in our National Parks.  In my response to the CNPA Partnership Plan, which completely fails to mention resources, I said this:


There is no consideration of the resources needed to deliver the Park’s statutory objectives or the Park Plan.  Instead, there are references through the Plan to various pots of money that could be drawn on to meet the objectives of the Plan.    There is no analysis of whether this is sufficient or what is really needed.  In other words the Park Plan seems to just accept the current Government narratives about austerity.  The result is there is no strategic direction in the Plan, only aspirational directions of travel.   I think the Park needs to consider a fair way of increasing revenue (and not follow the example of the Loch Lomond and Trossachs National Park who are trying to sell everything with lots of unintended consequences).  The simplest, fairest and most effective way of doing this would be through a small bednight tax as is found in many places on the continent.


With Theresa May indicating at the Tory Party conference a change in direction in terms of austerity and renewed emphasis on public investment, the Scottish Government should be able to expect increased resources.   There is no better time therefore for the CNPA to clearly set out what resources are needed in the National Park, both by itself and its other public sector partners (none of whom commit to investing any resources in the National Park in the draft Partnership Plan).


This though I think will take a major change in mindset from both the CNPA and the Scottish Government as is illustrated by their responses to the funding announcement:


“It’s great to see this investment in and support for Scotland’s landscapes.

“Our landscapes are iconic and will provide a magnificent backdrop for these projects that will encourage people to explore Scotland’s spectacular outdoors, protect our biodiversity, benefit rural communities and encourage visitors from home and abroad.”

(Roseanna Cunningham, Cabinet Secretary for the Environment)

A great statement but why does the Scottish Government not treat this as a core responsibility to be funded out of tax instead of leaving it to the lottery of the lottery?

 “This is a massive boost, not just for Tomintoul and Glenlivet but for the wider National Park. Heritage Lottery funding will result in investment in new and improved facilities and infrastructure, new job opportunities and other community driven projects – there are exciting times ahead. I would like to thank and congratulate all those involved in helping to secure this funding.” 

(Eleanor Mackintosh, CNPA Board Member and local resident)


I don’t believe investment in infrastructure or jobs should depend on the lottery.   I am not saying the CNPA should stop applying to the lottery, while that remains one of the main ways to secure resources, nor do I want to dent the enthusiasm of those who have worked to achieve this.   But Eleanor Mackintosh and other Board Members should be using the Park’s new Partnership Plan to set out a clear vision of what needs to be done in the National Park and the resources required to deliver this for the environment, for visitors and for the people who live there.

The CNPA won’t get everything of course, partly because any additional funds for investment are likely to be far less than the UK Government spin suggests but also because no-one ever does, but times are changing and the CNPA should be making the case that funding in our landscape should cease to be a lottery.
October 8, 2016 Nick Kempe 3 comments
The problem and the potential: signs of neglect and mismanagement with montane scrub behind

A week ago,  on the same day that the consultation on the new Park Partnership Plan closed, the Cairngorms National Park Authority approved the Cairngorm Glenmore Strategy (see here).  This had been subject to public consultation earlier this year.


All the detailed visitor management proposals which were in the consultation draft have been stripped out of the strategy and will be worked up into a Glenmore Visitor Improvement Plan and Cairngorm Masterplan.  The final strategy is much shorter, simpler and easy to understand.   A great plus compared to the morass of documents and plans that made up the draft Partnership Plan and it has avoided being competely dummed down too.


In my view there are two glaring omissions.  The first is that Rothiemurchus Estate is not included, although its an integral part of Glenmore.  I am afraid the presentation of the strategy as being about public authority owned land is simply an attempt by the CNPA to put a good spin on this.  The fact is Rothiemurchus declined to join and the CNPA was powerless to make it do so despite the Scottish Government having agreed that Forestry Commission Scotland should acquire part of the estate for £7.4m last year.   The sad fact is landowners in the National Park are a law unto themselves.


One could also say that too of the Speyside Trust who run Badaguish and who have consistently ignored planning requirements.  The Strategy has nothing to say about Badaguish.  Its not on the map of sites identified for visitor infrastructure development, unlike Glenmore Lodge, the Youth Hostel and campsite despite far more development going on at Badaguish.  This omission is quite extraordinary and conspiracy theorists will note Badaguish is named on every other map in the Strategy document apart from the visitor infrastructure one!   This undermines the credibility of the Strategy much as I hope the CNPA Board has now decided to take a firm stand and use its enforcement powers to prevent any further unlawful development on the site.


On the positive front, the Strategy contains a number of actions for the Cairngorm ski area which I believe most people who cares about the place would agree with:


  • Safeguard the plateau habitats and species by actively managing recreation pressures
  • Develop action plan to enhance the ski area by improving storage and removal of disused items
  • Ensure enhancements within the ski area are implemented to high quality standards appropriate to the sensitive environment
  • Develop agreed best practice standards for development and enhancement works in the ski area [actually good practice standards have existed since the early 1970s, they just need enforcing]
  • Expand montane woodland establishment within and around the ski area
  • Support enhancement of the wintersports experience and year round activity provision


I was particularly pleased to see the commitment to clean-up the ski area and expand montane woodland within it – suggestions which have been made several time on Parkswatch.


However, the problem is that the strategy bears no resemblance to what is actually going on on the hill at present.    Natural Retreats simply ignore all planning requirements (further photos proving this will appear soon!) and Highland Council and the CNPA as planning authorities have so far failed to do anything.


What does ensuring “enhancements with the ski area are implement to high quality standards appropriate to the sensitive environment” mean when Highlands and Islands Enterprise, CNPA and Highland Council are not prepared to speak out, condemn Natural Retreats for their mis-management and intervene to stop this?

The destruction around the Coire Cas Gantry – Photo Credit Terry Smith 23 September 2016

So what are CNPA, Highland Council and HIE going to do to meet the management aspirations set out in the Strategy?


Management interventions will improve the natural environment, landscape and visitor experience and retain the sense of wildness and space found in the area.


How does letting Natural Retreats get away with the destruction they have caused ensure that “Cairngorm and Glenmore will be a high quality mountain and sports destination”?


How can our public authorities claim that “Cairngorm and Glenmore will be at the heart of collaboration with neighbours to protect the mountain plateau”  when they are allowing Natural Retreats to destroy part of that very same plateau?  (see here)


The worst though is at the end of the Strategy where after saying that “Natural Retreats and partners to develop and deliver masterplan for Cairngorm Mountain” – a step forward – that “Natural Retreats and Forest Enterprise Scotland will lead on delivering spatial plans that set out the detailed actions focused on improving facilities at Cairngorm Mountain and Glenmore respectively. These plans are expected to be completed in the next year.”     How Natural Retreats can be trusted to lead on anything is beyond my ken.


Now this is not all the fault of CNPA.  HIE as landowner have primary responsibility for ensuring Natural Retreats as their leaseholder maintains the highest environmental standards and they have completely failed to do so.  Its about time that CNPA repeated the call they made on 7th November 2006 for the ownership of the Cairngorm Estate to be transferred to Forestry Commission Scotland:


“The board of the CNPA considered its response to the consultation on the transfer of the estate from current owners Highland and Islands Enterprise (HIE) to FCS at its monthly board meeting on Friday 3 November.

David Green, Convener of the CNPA board said: “We fully support this transfer subject to the delivery of an inclusive approach to the estate’s management and the delivery of a wide range of public benefits.

“It seems sensible that Forestry Commission Scotland should assume ownership of the estate, rejoining it to its holding at Glenmore, and the organisation has a proven track record in managing land to deliver public benefits and ensuring that local and national interests are fully involved.”

Among the other points raised by the CNPA in its response to the consultation are:

  • An early priority should be the production of a management plan to steer the future of the estate and this should be done following consultation involving a wide range of interested parties. Such a plan should include ways of delivering the priorities emerging in the Cairngorms National Park Plan as well as incorporating integration with neighbouring land holdings.
  • Short term environmental improvements, such as the removal of some ski-ing infrastructure, should not be carried out at this stage. Decisions on these proposals should be deferred and instead considered through a full management planning process and through consultation with all those interested in this aspect of the estate.
  • Bureaucracy should be minimised and all meetings relating to the management of the estate should be open to the public.

Fiona Newcombe, the CNPA’s Head of Rural Development Strategy commented: “Forestry Commission Scotland is the obvious organisation to take over the Cairngorm Estate. As an enabling organisation, the National Park Authority is not best placed to own land, but rather positively influence land management by others. We are fully supportive of this move and welcome the principle of wide stakeholder engagement in the management of the estate.

I think the CNPA were right in 2006.  Until the Cairngorm Estate is transferred from HIE to FCS (and Natural Retreats replaced as operator of the ski area) the actions set out in the Cairngorm Glenmore Strategy will remain aspirations.

October 6, 2016 Nick Kempe No comments exist
The Derrydarroch Allt Andoran intake track from Sron Garbh on An Caisteal. The dark area to the right of the track  is where the pipe is buried.  It should disappear as the vegetation recovers but the track will remain a permanent scar.     The vegetated strip down the middle of the track, highlighted by the National Park as good practice, has since been destroyed through the Glen Falloch estate allowing cattle to walk over it.


The planning permission granted for the four Glen Falloch hydro schemes in 2010 agreed to some  permanent new (short) tracks along the bottom of the glen to the powerhouses, some widening of existing tracks but stipulated that the tracks to the intake dams required for construction purposes were to be temporary.  Once work was completed they were to be restored, just like the land over the pipelines and access to the intakes was to be argocat on “green tracks”.   This position was agreed by the Board at the time (which had rejected an early application for hydro in Glen Falloch back in 2003 because of the visual impact) and later endorsed in the LLTNPA’s “award winning” Supplementary Planning Guidance on Renewables which stated:


It is expected that any access tracks required for the construction will be fully restored unless there is an overwhelming reason why they should be retained for the operational phase of the development.

I could not work out from the original planning documentation (reference 2009/0249/ECN if you want to track this down at why the tracks were still there.  Then last week when the LLTNPA responded (see here) to some questions I had asked about the Glen Falloch schemes including the bright blue pipes.  This showed a further four planning applications had been made to the LLTNPA between 2012 and 2015 to make ALL the temporary tracks permanent.   All were agreed by officers under delegated authority and did not go to Committee.   Given the history of the planning applications and the LLTNPA’s clear policy on hill tracks and renewables, that the LLTNPA Board has allowed staff to reverse their previous decisions appears to me totally wrong.  A dereliction of the National Park’s duty to protect the landscape.

Map of the Intakes, pipelines and access tracks in Glen Falloch. There were pre-existing tracks in Upper Glen Falloch (Intake 1 top right) and towards Ben Glas (Intake 7) but all the other tracks were to be restored.

The first of the tracks to be approved was the Allt Fionn back in 2012.  Originally the estate had wanted a permanent access track but the Committee report that recommended the Scottish Government approve the proposal in 2009 stated ” As a result of the pre-application process it has been agreed that the proposed access track to the intake will now be temporary rather than permanent.”   It did not take long for Falloch Estates to get this decision reversed.  The reason staff gave for approving this in their delegated report was:


As the proposed track is not just to service the intake, but also for estate/land management purposes which will be for the benefit of the estate as a whole, it is considered that the retention of this track is justified


The Allt Fionn track from Ben Glas. The restoration of the ground above the pipeline appears successful in landscape term (from the sharp bend it continues down the hill on the same line as the upper part of the track) but the creation of a permanent track cutting across the hillside from left to right has had a major impact on the landscape

Note that the decision is justified as being for the benefit of the estate, for the landowner, not the public interest or the landscape.   This reasoning, about the needs of the estate, was repeated in the three other delegated reports in which officers agreed that all the temporary access tracks should become permanent.   Now the LLTNPA has a very clear policy on this set out in its SPG-Renewables-final:


It is expected that any access tracks required for the construction will be fully restored unless there is an overwhelming reason why they should be retained for the operational phase of the development.

A small part of the new Derrydarroch track network in Glen Falloch showing how it scars what was a beautiful glen


The LLTNPA officers in my view totally failed to present an overwhelming need for these tracks given their impact on the landscape.   While the LLTNPA has ignored its own policy, what is worse is there appears no-one in the National Park prepared to stand up for the landscape in the face of developers.


Evidence of this lack of care for landscape can be found throughout the reports that approved the tracks. For example, while the Allt Fionn report  notes that the Falloch Estate had constructed “storage” by the Allt Fionn dam without planning permission, there is no consideration of whether this should be retained.   The hill goer might have thought the need for a store would disappear with a permanent track, after all there is none by any of the other dams, but its still there.

IMG_4894 - Copy
The store, across from the Allt Fionn dam, and associated rip rap embankment.   It reminds me of those nuclear bomb stores in Glen Douglas.

The failure of the LLTNPA to protect the landscape of Glen Falloch is further demonstrated by the way the reports on all four schemes deal with wild land values.    Again the LLTNPA has an apparently strong policy position on this in their Renewables Guidance:


“priority will be given to protecting these core areas of wild land character. These areas will
therefore be safeguarded from development which may detract from their relative wildness.”

Rip rap retention has wrecked the gorge below the Eas Eonan dam – in an area of core wild land. The Allt Andoran track is in the far distance.

The 2013_0153_det-delegated_report_final-100102998-derrydarroch-tracks clearly states


It is likely that a permanent track will erode the perception of wildness of this open hill slope; in particular the upper section in core wildness area and the point at which the track approaches the intake and the upper glen where there is intervisibility with Ben Dubcraig. Here the perception of wildness is more apparent and any extensive or adverse development will add to the cumulative impacts of the Glen Falloch schemes.

The top of the Eas Eonan track and dam which the LLTNPA allowed to be constructed in an area of core wild land.

Officers used this argument to approve the track:


The track to intake 2 will enter core wild land, however due to the erosion from argo tracks already evident, it would be preferable to have one small well-designed and integrated stone track to service the intake, rather than increase the environmental damage more widely across the hillside.


This argument is shown to be false by the evidence on the ground.

The estate has created a spur off the track to the Eas Eonan to enable it to drive ATVs more easily over the hillside




The approval of the hill tracks have done nothing to reduce environmental damage across the hillside.  If the National Park is serious about this it could introduce a byelaw to prohibit the use of four wheeled vehicles in areas of core wild land but the reality is it does whatever estates asks.   While the Eas Eonan track is the only one to enter a designated area of core wild land, all the other tracks enter buffer areas – again this counts for nothing.


I argued in my first post on the Glen Falloch schemes (see here) that the Ben Glas scheme should never have been allowed because of its wild land qualities and later on that restoration is a myth (see here).

The Ben Glas intake construction track, which is now permanent, has destroyed landforms to such an extent that they can never be “restored” properly.

There was an existing track to the Ben Glas burn and the original proposal was that this would be used to access the dams.

The old track which ends lower down the Ben Glas burn was to be used to access the Ben Glas intakes

At the end of 2015 however officers agreed that the temporary access track should become permanent.  This has created a much bigger scar across the landscape.

In the original planning permission almost all the track visible in this photo should have been removed.  The decision to make this track permanent is a serious detriment to the landscape and to the wild land buffer zone.



A further effect of this decision is that there will be now be TWO tracks that cross the hillside to the Ben Glas burn.   If the LLTNPA cared even an iota about the landscape they might have insisted the original track, which should now be redundant, was restored but they have said nothing.


So what can be done?


All the tracks in Glen Falloch were financed with public money through the extremely generous subsidies that existed till about a month ago for renewable energy developments.   The Falloch Estate is making large sums of money from their hydro schemes (about which more in due course), enough money to employ more staff who could have occasionally walked up to the hydro intakes to clear them after storms or to hire the occasional helicopter.   These hill tracks were not necessary, which is why the original planning permission required them to be temporary.  LLTNPA staff, however, have simply accepted every argument the estate has made,  another failure of National Parks to stand up to landowners.


What is worse though is the National Park appears to have extracted not a single improvement or planning gain from the estates in return for approving these tracks.   I will address some of the poor construction and design of the Falloch Hydro tracks in a future post (there is plenty of evidence that the LLTNPA has failed to implement its own good practice guidance) but to me it seems the LLTNPA has lost a real opportunity.    The impact of a number of these tracks – not all – would disappear if woodland regeneration was allowed to take place.   The Upper Glen Falloch track starts  just by the Glen  Falloch native pinewood, the southernmost remnant in Scotland and long threatened by overgrazing.     What an opportunity to allow  this pinewood to extend – particularly when all the trackwork has created new mineral soils – but instead the LLTNPA is allowing the state to graze cattle as before which is destroying much of the restoration work.   I despair at the lack of any vision.

The Glen Falloch pinewood is seen just behind the powerhouse but instead of taking the opportunity to encourage regeneration over a wider area the LLTNPA simply required the estate to plant trees to screen the building

Ultimate responsibility for the terrible decision-making on the Glen Falloch tracks lies not with the poor planner who drafted the reports but with the senior management who approved them and with the Board who have allowed this to happen.   Perhaps they could now take a lead on this, not least to demonstrate that they will not simply roll-over when it comes to pressure from Flamingo Land.

October 5, 2016 Nick Kempe No comments exist
The outline master plan for Scottish Enterprise’s west riverside side submitted by a developer to the National Park in 2012

The Observer on Sunday ran a full page article by Kevin McKenna on Flamingo Land’s appointment as preferred developer for the west riverside side in Balloch (see here and here).   I normally enjoy reading Kevin McKenna but did wonder if this is the same Kevin McKenna who had previously lambasted the development in an entertaining blog post entitled “Keep Flamingo Land away from Loch Lomond – we don’t want any old bouncy castle experience in our back garden”!  (see here)   Having played a small part in stoking up the anger that resulted in over 30,000 people signing a petition to stop the development, Kevin McKenna asks in the Observer article if the anger is justified?  While the article questions that opposition McKenna’s conclusion is “In the final analysis, Loch Lomond’s worldwide appeal will probably ensure that the development, when it happens, is as pristine, sustainable and sympathetic to the surrounding environment as anything containing “glamping pods” ever could be.”


I wish I could be so confident.   I think there are three major issues about the proposed development.


The first is the secrecy that has surrounded the appointment of a preferred developer and what appears to have been the deliberate exclusion of the local community and other interests from discussions about whether this was the best means to develop the site (see previous posts). This is  wrong, contrary to Scottish Government Policy but unfortunately is the way the Loch Lomond and Trossachs National Park Authority currently operates.   Scottish Enterprise and the LLTNPA had every opportunity to consult through the local community planning event held earlier this year which considered plans for the area.  They didn’t and should be forced to explain why.


The second is Flamingo Land’s fitness to develop land in the National Park.  Flamingo Land’s experience is in running and developing theme parks not in protecting the natural environment and landscape.   The current destruction which is taking place under Natural Retreats at Cairngorm is a warning of what can happen when Enterprise Companies appoint a large developer whose interest is not primarily in the environment but in making money.   In my view the many local businesses operating around Loch Lomond who depend on protection of the landscape natural environment for their living would be a far safer bet to develop the site.


The third issue is the cost of improving the west Riverside site and I believe explains what is going on and will almost certain result in a development that compromises the National Park.  The west Riverside side covers former railway sidings, disused sand and gravel pits, a former silk dye works and some of the land has been reclaimed with former ash waste.   Some of this is definitely contaminated and all of it may be.  This will not be cheap to fix.  There will be other costs of clean-up besides contamination – Scottish Enterprise spent £40k after it acquired the site simply lifting sunken boats out the river.   The river bank is vulnerable to flooding, again more costs.   On top of that a walkway along the river will now have to be paid for  a good thing and a positive thing that did come out of the community planning event.   The total costs are likely to be significant, well beyond the means of any local business, hence the appointment by Scottish Enterprise of a single developer for the entire site.


If Flamingo Land have to pay for all of this they will need to get their money back somehow and they are not going to do this through a few glamping pods.   The pressure will be on for a more intensive development, not the type of low key developments outlined in the press release, and for the developments to raise as much income as possible,  with all that implies for other local businesses.   The way this is likely to work is that Flamingo Land will come up with an initial plan, which looks fine and gets planning consent, but then during the development processes unforeseen costs or other factors then lead to a dilution of the planning conditions.


The LLTNPA Park has quite a track record on diluting planning requirements (as in Glen Falloch where my next post will be on all the hill tracks that were supposed to be removed after the creation of the hydro schemes there).    In 2012 the LLTNPA provided a screening opinion  which indicated they would reject the outline master plan featured in the graphic at the top of this post.   Judging by that plan the funding of site improvements would have been through the sale of new luxury housing  along pier road and a large four star hotel on the banks of Loch Lomond.    New housing has been ruled out for the site which is earmarked in the latest development plan  for “Visitor Experience” (not Economic Development as stated in the Observer).

The symbols in the draft development plan indicate what anyone applying for planning permission within the area needs to consider and includes contaminated sites, flood risk, drainage, landscape and impacts on woodland

A large hotel on the lochshore appears to have previously been ruled out through the screening opinion.  Without a hotel on the lochshore, which would have a big impact on the landscape, and the housing its very difficult to see how the cost of improving the west Riverside site can be funded.     Scottish Enterprise must have a good idea of the potential costs of putting the site right and I think they need to explain how they believe the developer will be able to do this while meeting the aims of the National Park.


An alternative way of improving the west Riverside side which would not have resulted in any inappropriate development pressures would have been for the public sector to pay for the decontamination of the land and the walkway (accepting that the businesses that caused the damage in the first place have long gone).  That would then enable local businesses to have come up with proposals that were compatible with the aims of the National Park.   Unfortunately  austerity, which is a political choice, is driving commercialisation in the National Park and threatening to undermine its aims.   The 30,000 are very right to be concerned.



October 4, 2016 Nick Kempe 2 comments
Photos of this hole and associated damage caused by Natural Retreats outwith the area granted planning consent was sent to Cairngorms National Park planners in early October a month after they were first alerted to the issues.   Photo Credit Alan Brattey.
Two weeks ago the Cairngorms National Park Authority added responses from their ecology adviser (see here) and landscape adviser (see here) to the retrospective planning application from Natural Retreats for the hill track at Cairngorm (see here).   While welcoming the transparency of the CNPA in making these public at an early stage (which has given the public a chance to comment) I believe the content of these assessments are not worthy of a National Park.
The Landscape Adviser has no comments to make about most of the unlawful works undertaken by Natural Retreats, such as the reprofiling of banks or the dumping of boulders or the poor quality of the finishing.
How does this fit in with the planning permission granted?                Photo Credit Terry Smith 23th September
Half exposed pipes seem of no concern to the CNPA’s landscape adviser          Photo Credit Terry Smith
The Landscape Adviser’s main comment concerns the track itself:
Within the ski area, on land previously integrated in the infrastructure of skiing, this track is acceptable as part of the landscape. The track in question consists of a short stretch, level with surrounding ground and vegetated with initial grass growth which will provide organic matter and
prevent erosion of the track. Addition of drainage channels will further prevent erosion.
This is factually  wrong and the thinking dangerous.  The track is not a short stretch, its several hundred metres long.  The angle of the top half of the track is 12 degrees, compared to the maximum angle of 8 degrees recommended by Scottish Natural Heritage to prevent erosion (see Alan Mackay’s excellent  critique of the retrospective planning application in which he went out and measured the angle of the track!  Its essential reading for anyone concerned about this and should be read by all Board Members on the Park’s Planning Committee).    The Landscape report contains no consideration of the implications of installing “access tracks” alongside all the ski tows in Scotland – the cumulative impact would be considerable.   The tracks are also completely unnecessary.   CNPA staff seem totally unaware of the  publication “Environmental design and management of ski areas in Scotland: a practical handbook” which showed tracks were unnecessary back in 1987.  Nothing has changed except our Public Authorities are no longer prepared, it seems, to enforce basic environmental standards.
The Ecology assessment is also wrong on several points.  In commenting on the re-profiled bank below the tow the assessment claims:
Re-grading has taken place at the bottom end of the track which has reduced the steepness of the slope, reducing erosion in this area. This slope is revegetating well.
This is wrong, there was no erosion previously as this photo from Alan Mackay’s response shows:
The bank on the right of the track was covered with vegetation when work on the Shieling Rope tow started yet the CNPA claims it was eroding and appears to have used that claim as a justification for ignoring a serious breach of planning permission when Natural Retreats dug up this bank “to make it look more natural” (their words).  Photo Credit Alan Mackay
The ecology assessment further states:
The restoration works associated with the ski tow construction appear to be going well, won heather turves have been replaced on disturbed ground and bare areas seeded
No mention here that Natural Retreats was supposed to store all vegetation on terram matting and then replace it so there should have been no need to “win” vegetation from anywhere else.  The need for re-seeding should have been minimal but in fact has been required over large areas.   The Ecological Assessment makes no mention or comment on this.
Extensive re-seeding near the top of the shieling rope tow – showing how little vegetation restoration has taken place  Photo Credit Terry Smith
Its hard to see how converting a slope from heather to grass can have no ecological impact and the ecological assessment furthermore fails to refer to the extent of the unlawful works.
Re-seeding to the south of the car park t-bar well outside the zone granted planning permission. Parkswatch has photos of diggers working here – what were they doing and why? The re-seeding shows the extent of the damage.  Photo Credit Terry Smith

The assessment also wrongly claims “There is evidence of erosion on the new path which occurred during the late December 2015 storms.”    The track – its not a path, another piece of misinformation – has eroded several times already.  So, who told the ecology adviser this only happened once back in December?   The hill track is too steep but the ecology adviser, like the landscape adviser, appears unaware of the SNH guidance on hill track construction.

The steeper top half of the shieling track erodes each time there is a storm because its too steep and each time surfacing from the track washes onto the surrounding re-seeded area    Photo Credit Terry Smith
Is this high quality restoration work?                                              Photo Credit Terry Smith 23rd September


The truth is that the CNPA’s ecological assessment of the hill track and associated works is nothing of the sort.  A proper ecological assessment would have looked at the extent of the damage, the impact of the failure to restore vegetation (yes it will recover eventually but how long will this now take?), the impact of the hydrology of the area, including more rapid water run-off, and the impact on wildlife. The assessment does not even refer to the impact the works may have had on the water vole in the area, let alone other wildlife (see the response of the Badenoch and Strathspey Conservation Group for the potential impact of works on wildlife).
The ecological assessment makes no reference to the number of trees killed by Natural Retreats or the vegetation they scooped out with diggers leaving holes across the bottom half of the slope Photo Credit Terry Smith
The ecological assessment contains no reference to the quagmire that has been created by diggers driving across peat and then scooping holes out of the vegetation to “restore” the ski slope behind Photo Credit Terry Smith
Th ecological assessment makes no reference to all the granite gravel that has washed off the lower part of the track onto the surrounding ground. Again the extent of destruction of the vegetation is striking. Photo Credit Terry Smith
The one positive suggestion in the assessment is that “there is a good opportunity to plant Dwarf Willow, Birch and Scots Pine on the re-graded bank” but why only here?    As I have argued previously, one way to compensate for the extensive destruction would be for the CNPA to require Natural Retreats to employ a properly qualified contractor to plant montane scrub across the area.
I suspect responsibility for the sub-standard quality of these assessments does not lie with the staff concerned but somewhere above them in the management chain.   To put it bluntly, the staff concerned have been told to tick a box.    The CNPA was first made aware of the unlawful works at Cairngorm on 4th September 2015 (I have seen the emails) and did nothing to intervene and stop Natural Retreats destroying vegetation and soils outwith the area granted planning permission.  They subsequently failed to do anything substantive for over 10 months but, after being forced to admit a retrospective planning application was required, it appears that staff are doing everything they can to ensure this is approved.   This behaviour is not worthy of a National Park.  It provides further evidence that there must be other things going on which explain why the CNPA is allowing Natural Retreats to do what it likes at Cairngorm.

What needs to happen to ascertain the extent of the damage and its impact on Cairngorm

The argument that the CNPA should require Natural Retreats to pay for an independent ecological and landscape assessment is even stronger now that the National Park has shown it is incapable of doing this properly.  Such an assessment should detail ALL the damage that has been caused at Cairngorm – not just the areas granted planning permission – and the options for restoration of the ground and vegetation.

Any proper assessment should be informed by the guidance contained in the following documents:

  • The past vegetation surveys that have taken place at Cairngorm (I asked Highlands and Islands Enterprise for copies of these under FOI but they have told me all surveys since the construction of the funicular are held by Cairngorm Mountain!   Why didn’t the CNPA landscape adviser ask for a copy?)
  • SNH’s Guidance on the construction of hill tracks
  • “Environmental design and management of ski areas in Scotland: a practical handbook”



October 3, 2016 Nick Kempe 1 comment
How did the National Park get a planning quality award for this blue hydro pnstock by the A82 in Glen Falloch?


After my last post on the Glen Falloch hydro schemes, which featured the blue penstock by Derrydarroch in the photo above, I asked the Loch Lomond and Trossachs National Park when this penstock was going to be re-painted.   The LLTNPA had approved a plan in February that showed native trees were to  be planted on both side of this pipe which was going to be painted green (see here).  While the paper trail was not all public, I assumed the LLTNPA had told Glen Falloch Estates that all the penstock had to be re-painted to accord with their award winning guidance on Renewable Energy Developments which stated all pipes should be covered where possible and where not blend in with the landscape.   It was a bit of a shock to receive  eir-2016-043-response  earlier this week.


“There has been no request for this pipe to be painted as there will  be woodland planting in the vicinity which will screen the pipeline over time”

The planning section don’t even appear to be aware that they approved this landscape plan in February 2016.

blue-pipeAlso, you can clearly see from the photo above that the tree planting, which was supposed to be on both sides of the pipe, is only on one side and will never screen the pipe from the A82 or more importantly from the West Highland Way from where the photo was taken.


Even worse is this response about what the LLTNPA is doing about all the other blue pipes in Glen Falloch:


So, as a National Park, are they or aren’t they going to enforce their own guidance?      I take the response to mean that the LLTNPA is not going to make any attempt to ensure that all the other blue penstock in Glen Falloch are painted an appropriate colour unless there is public uproar about this.  While the penstock contravenes the Park’s own Guidance,  I have learned from experience any guidance or policy from the Park needs to be taken with a large dose of salt as they continually break their own rules.   Whatever the status of their policies the important point is the LLTNPA’s commitment to landscape protection is so weak its not even prepared to commit to tackling blue pipe blight.  This example should make people very sceptical about the LLTNPA’s commitment to put the “special qualities” of the National Park first when considering the Flamingo Land development. The blue pipes of Glen Falloch are worthy of any theme park.


Earlier in the week the LLTNPA planning committee  considered its fifth planning performance report to the Scottish Government which contains two pages on hydro schemes.  The first explains how hard pressed the Park has been trying to approve a lot of hydro schemes in a short period of time (this doesn’t apply to the Falloch Schemes which were approved earlier).  Note the claim that:


 “a robust and rigorous approach to the monitoring of the build out phase of the hydro schemes was required in order to ensure the protection of the special qualities of the park”.  


The EIR Response, while listing the Park’s monitoring visits to Glen Falloch, refused to release any correspondence with the Glen Falloch Estate  so I cannot tell you at present whether this allegedly rigorous process even raised the blight of the bright blue penstock, let alone any other issues.   (I will ask for a review and remind the LLTNPA their Planning Charter commits the Park to act transparently).



The second extract (below) explains the LLTNPA received a Scottish Award for Quality in Planning this year for the way it has managed hydro schemes.  The primary reason for the award appears to have been for approving these hydro schemes quickily, before the Feed In Tariff subsidy changed, but it was also “for influencing the implementation of the development on the ground”.   I wonder if the judges knew about the blue penstock and all the other breaches of the LLTNPA’s planning guidance which it has allowed to happen?   Note the photo of the stone clad dam wall and the wooden fencing in the photo below and compare it to the reality (see here).  There is not a single stone clad dam wall in Glen Falloch and lots of galvanised steel.   The gap between spin and reality is yawning but what matters is that the LLTNPA is allowing a beautiful landscape to be trashed – rather like the Cairngorms National Park Authority and Natural Retreats at Cairngorm.




The other information in the EIR though is of even greater concern and I will cover that in my next post on Glen Falloch

October 3, 2016 Nick Kempe No comments exist
Morrone hill track. The track is extremely broad and neither the centre of the track nor the spoil which was dumped on either side of it has re-vegetated (years after it was first bulldozed) increasing the visual impact

I walked over Morrone from Corriemulizie by Braemar last Monday on a showery day.  What I saw got me thinking about what the draft Cairngorms Partnership Plan said about paths and tracks.  The public consultation on this ended officially this weekend but people can continue to influence this.


The plan says nothing about the state of hill tracks in the mountains in the National Park, although we know this of concern to the Cairngorms National Park Authority because their planning committee has agreed some (limited) action to ensure new hill tracks meet minimum standards, most recently on the Dinnet Estate.   There is nothing however in the Plan about the potential to reduce the visual impact of existing hill tracks.  Whereas 20 years ago there was a recognition serious mistakes had been made in constructing tracks into our mountains, which led to the programme of track removal by the National Trust for Scotland on Mar Lodge, the issue now appears to have disappeared from the National Park’s agenda.  The arguments for action are I believe as strong now as they were then.p1010995-copy

Standards of construction continue to be very poor. Behind the now useless drainage pipe, on the col below Morrone, you can see where material from the tracks has washed out over the moor.

The Morrone summit station is a complete eyesore.  The latest communications hut and mast has been brought to the summit by trailer.  This could have been helicoptered in removing the need for such a broad track.



Descending Morrone to Braemar the top section of the hill path has turned into a broad erosion scar whose visual impact is as great as the hill track. Unlike hill tracks though at least there is a programme to improve the condition of hill paths in the National Park through the Mountains and People Project.

Top section of the Morrone hill path has been eroded by feet to create a broad scar that is still widening as people take the vegetated ground on either side which is easier walking and less hard on the feet

There are well tested techniques that can fix this type of erosion scar, which involve creating a better surface for walking, restoration of vegetation and designing the path so people do not walk across the vegetation in future.  You can see the outcome of such techniques lower down the hill where path repair work has been undertaken.

The broad erosion scar starts on the skyline where previous pathwork ended.  This water bar needs some further work and was possibly never properly finished.
Good path construction lower down has reduced the visual impact of the paths to practically nothing. You cannot see where the path is taking you 100m ahead.

Unfortunately, the CNPA draft Partnership Plan, while supportive the Mountains for People project, does not appear to accept that the state of our hills paths should be a core responsibility of the National Park.   There is NO analysis of the state of the path network in the hills or of how much investment is needed to bring them up to and maintain them in an acceptable condition.  Now, I am delighted that the Cairngorms Outdoor Access Trust has got funds to repair hill paths through the Mountains and People Project but, to take the Morrone example, its unclear if this is part of the programme (I could not find a list of the hills included on the COAT, Mountains for People or CNPA websites).


And that’s the point, the National Park should have an inventory of all the eroded paths in the National Park and a plan of how it will address these.  This, along with its failure to have any plan to reduce the visual impact of hill tracks, is I believe a major omission from the draft Partnership Plan.  Without such a plan, there is a real risk is that the people being trained up through the Mountains and People project will have no jobs to go to – there needs to be a long-term vision and programme to sustain jobs.   Part of this could include estates being required to use the expertise of the Cairngorms Outdoor Access Trust and its small workforce to repair all the damage that has been caused through the bulldozing of hill tracks.   There is a real opportunity here for our National Parks to take a lead and demonstrate best practice and I hope the CNPA take up this challenge in the final version of the Partnership Plan.