Ten days ago I received a response to another Freedom of Information request, EIR 2016-068 Appendix A list meetings of the secret Loch Lomond and Trossachs National Park Authority Board business sessions that took place in 2016. There were six of them, a slight reduction from the ten held in 2015 (at the height of the Board plotting on the byelaws) and back to the average since 2010. That’s still six secret meetings compared to four public meetings, worse than Police Scotland which is rightly being criticised for wanting to hold 50% of its meetings in private (see bottom of last past). I have also obtained, thanks to the Information Commissioner’s ruling that the Park required to make public if asked written materials from such sessions, written materials circulated at these meetings. The LLTNPA has not put these on the FOI section of its website – indeed so far it has put up none of its FOI responses sent out in 2017 – so if you are interested in seeing/scrutinising any of them please contact parkswatch which will cover some of them in due course.
This post covers the secret Board Meeting held on 17th August 2016 which was devoted wholly to camping YP Informal Briefing – 17th August 2016 – FINAL Staff. While the agenda described it as an informal briefing, that is quite obviously false as you can see from this slide:
Recommendations are not made to informal briefing sessions, only to decision making meetings. The whole way the LLTNPA Board has operated in developing the byelaws is corrupt.
The content of the slide is of great significance. It shows there still appear a few decent staff in the Park, who are prepared to hang on to their principles, because they recommended to the Board there should be NO charge for camping permits. (You can see the logic in the argument in the full presentation 20160817 – Your Park Camping Management Models Final). Indeed, staff estimated only c£6k would be raised through sale of permits, so it was hardly worth doing and in fact they thought the costs of collecting the money might be more than that. However, staff appear to have been overruled by the Board because in the paper to the Board in 2016 (see here) in the section on “Permits: Charging considerations” (paras 5.8ff) there was no reference to the principle of charging for access, the proposal to accept donations had disappeared completely and instead there was only one option, to charge £3. This makes it pretty clear that its the Board that is behind charging for access and is yet another example of the Board acting ultra vires because it is supposed to take decisions in public. Reason enough for the Scottish Government to intervene now and insist all charges for permits are dropped.
Another example of secret decision making is that in the August slides the original proposal for campsite fees was £7.50 (up from £5 due to the extravagant costs of creating the Loch Chon campsite) but the option put to the Board in December and then approved was £7. Perhaps the reduction in charge was because in October 2016 this is what the LLTNPA told the Scottish Government in response to a question about charges:
No indication there that the Park had been discussing a 40-45% increase in charges: the Scottish Government civil servants don’t appear to have appreciated yet that they really cannot trust anything that the Park tells them.
The development of the Your Park signage
While there was very little debate on charging at the December Board Meeting, there was debate on the signage examples accompanying the Board paper some of which was quite encouraging (see here). What I and other members of the public did not appreciate at the time was that the Board had already discussed all of this in August. No wonder staff looked put out when Board Members belatedly realised and suddenly started to insist, quite rightly, that there should be signs telling people when they were leaving the camping management zones.
The “NO CAMPING HERE” signs, proposed at the secret Board Meeting in August were completely absent from the December Board paper and it appears the Board decided there shouldn’t be such signs at the August meeting. I says “appears” because it is possible the Park decided NOT to present the “NO CAMPING HERE” in December because this would appear anti-access: because there were no camping management signs of any description when I visited the Trossachs a week ago (they were supposed to be put up from the beginning of February), I was unable to check.
If NO CAMPING HERE signs are now being erected, then it appears that has been done contrary to the approval given at the Board Meeting in December. If, however, the LLTNPA has indeed decided there should be no NO CAMPIMG HERE signs, that will make the byelaws even harder to enforce. The problem is neatly illustrated by the slide below presented at the August secret Board meeting:
The A82 is a major through route with tens of thousands of people driving along it each year. So, drivers glimpse a sign as they roar past at 60mph saying “Camping Management Zone” and even possibly “Camping in the Park”. What would your reaction be? Great, let’s find somewhere, stop and pitch our tents…………….so unless there is a NO CAMPING HERE sign in every single stopping off point, as was proposed back in August, what’s going to happen is people are going to pitch tents and completely unknowingly committed a criminal offence. The NO CAMPING HERE signs put to the August meeting were crucial for enforcement purposes.
However, what do the NO CAMPING HERE signs tell the public apart from tents are not allowed? What about campervans, motorhomes or sleeping in the back of the car? And, then consider the wording of the byelaws:
(6) It shall be an offence for a person to:
(a) set up, use or occupy a tent, wigwam or bivouac at any time; or
(b) set up, use or occupy overnight any other form of shelter (other than an umbrella)
within a Management Zone unless they have been authorised to do so by the Authority
under byelaw 11.
Does the NO CAMPING HERE sign give you the message that pulling off in a campervan or putting up any other form of shelter apart from an umbrella is a criminal offence? How on earth will the fishermen or anyone else know from the signage that hanging a tarp between trees or putting up one of those fishing shelters are criminal offences, with fines of up to £500, which could result in them losing their jobs or being prevented from travelling abroad? They won’t.
The LLTNPA’s signage, whether or not it includes the “NO CAMPING HERE” sign is completely inadequate. The Park is pretending to be in favour of camping and encouraging it (“camping management zones”, “camping in the park”) while at the same time trying to ban it. Its then tried to reduce the criminal law to a branding exercise where people are supposed to be able to tell from signs and symbols what they can and can’t do. This won’t work.
Even if the Park put the NO CAMPING HERE signs in every layby and added smallprint so people could see shelters were banned it would still not tell campervans where it is legal to stop off overnight. The Park would need to put signs up indicating to campervaners all the private roads in the Park (where you can stay overnight in a vehicle) for the byelaws to be properly understood. That is never going to happen and as a consequence the byelaws are unenforceable.
The consequences of this is the Park is going to have to deploy its Rangers, as they do at present on Loch Lomond, chasing away campers and campervaners from every place that is not properly signed. This is a complete waste of resource. The new Convener, James Stuart, when he starts on Wednesday, needs to signal a completely new direction for the Park otherwise its going to sink.