At the beginning of April, Flamingo Land (see here for most recent post and links) asked the Loch Lomond and National Park Authority whether an Environment Impact Assessment (EIA) would be needed for its proposed development at Balloch (see here) The response of the LLTNPA on 13th April (see here) was that a full EIA will be required:
The development is permanent and will have an impact on a large area (33.5ha) and will have an impact on both visitors to the National Park, residents and businesses. The proposal is complex and large scale. The construction period is likely to be long and any impacts during construction will be prolonged in terms of construction traffic, noise and pollution. The operation of the development also gives rise to potential significant environmental impact in terms of landscape impact, traffic increase and noise nuisance
The response was rapid I believe because the LLTNPA could hardly have said anything else. So, what can the concerned public learn from the 125 pages of report submitted with the request for a screening opinion?
The most striking thing about this proposed development in our National Park is its size, 33.5 hectares, almost twice the size of the West Riverside Site marketed by Scottish Enterprise (map above). What the top photo illustrates graphically is how Flamingo Land, through its purchase of Woodbank House, has in effect gained control of all the undeveloped land on the north west side of Balloch and its proposed development will effectively surround Loch Lomond shores. Its power will increase further if Scottish Enterprise, as its proposing, eventually sells it the West Riverside Site. Land. In effect the southern gateway to the National Park is being handed over to a private business. There are legitimate questions about whether this is in the public interest and whether, whatever developments might eventually go be agreed by the LLTNPA, the ownership of the West Riverside site should remain in public ownership or, alternatively, be transferred to the local community.
The EIA Report makes a reference to the site as being vacant and derelict – a myth that supporters of the development are using to justify the development – and states that there is a desire across Glasgow Region to treat such land as an investment opportunity. The trouble is the portrayal of the West Riverside site as derelict is not true as the photo above shows. Yes, there are pockets of dereliction and Woodbank House is in a sad state of disrepair. While the West Riverside site may not be the best green space in the world there is far more green than dereliction and, contrary again to claims in the Balloch Charrette, its well used by people. Indeed much of the greenspace is the product of earlier restoration of what was formerly the line of the railway.
There are even pockets of wild along the shores of the River Leven. If this is developed into a constructed river walkway, as the LLTNPA and Scottish Enterprise appears to wish, how will visitors to Balloch be able to access nature? That is after all what the National Park is meant to be about?
The developers will argue that people will still be able to access Balloch Country Park on the other side of the River Leven but this is inaccessible. The EIA makes no mention of the long-wished for pedestrian bridge across the head of the River Leven which would enable people visiting Lomond Shores to access the Country Park. That might offset to some extent the development of this site but the omission of the bridge from the EIA scoping requests indicates Flamingo Land has no intention of paying for this.
The EIA scoping Report is very vague about Flamingo Land’s plans which are listed as follows:
However, other parts of the report give an indication of what this includes.
As if the existing Drumkinnon Tower at Loch Lomond shores was not enough, the report includes an outline visual impact assessment of a 100m high viewing tower. Its appears that to compensate for the removal of greenspace at Balloch, the idea is visitors should be able to view nature from afar.
You don’t need a viewing tower to see Ben Lomond from Balloch but any viewing tower will have a signficant impact on the views south from the Loch Lomond National Scenic Area, including from the summit of Ben Lomond. The EIA, though, apparently believes a solution could be found: “consideration should be given as to how to mitigate expansive southerly views from this popular hillwalking viewpoint”. A friend suggested it could be very slim and reflect the shape of a Flamingo’s neck.
There is another apparent give away in the scoping of the Zones of Theoretical Visability (ZTVs). On the maps that depict what can be seen from where there are three references to a “chute” which occurs nowhere else in the document. Is this why the proposed Leisure Development feature is 50m high? Is this an enormous water slide? It appears the Sunday Herald was fully justified in referring to the proposal as the blingy bling banks of Loch Lomond (see here). Such evidence as can be gleaned from the EIA documents provides no re-assurance about what Flamingo Land is going to propose but what it is it appears to be an intensive tourist development.
Such development is, I believe, not appropriate for a National Park. National Planning Guidance re-inforces this:
A good reason, one might have thought, for the LLTNPA to reject the proposal but the EIA provides an indication of why this might not happen:
This reads as though the application has already been agreed, its only the fine detail that needs to be sorted out and all can be mitigated. It makes one wonder if the 100m viewing tower and leisure development are being proposed to divert people’s attention from other aspects of the plan, which are fundamentally about development on greenspace at one of the main entry points into the National Park? The scenario is that following the inevitable public stushi on the viewing tower, the LLTNPA rejects that aspect of the proposal and tries to market the “compromise” which follows to the public as somehow meeting the statutory objectives of our National Parks.
The EIA contains a number of proposals for consultation, mainly with statutory bodies – potential for lots of wheeling and dealing behind closed doors – but nothing I could see about engaging with people who care about National Parks in Scotland, including the people who signed the petition against Flamingo Land. So, how about Flamingo Land starting their consultation by asking the public about the viewing tower and leisure chute?