Following my post on the proposed loch achray campsite, which received some well-informed comments from readers, further documents relating to the application have been uploaded to the Loch Lomond and Trossachs National Park Authority Planning portal (see here). The papers for the December LLTNPA Board Meeting confirm that Loch Achray is the ONLY “new” campsite development being worked on for next year. This post considers what all this tells us about the coherence of the Park’s camping strategy which was supposed to be delivered in tandem with the camping byelaws.
The main flaws in the proposed Loch Achray campsite
My main criticism of the original application was that it included no chemical waste disposal facility – a no-brainer one might have thought when the LLTNPA and Forest Enterprise and trying to promote Forest Drive as a paying campervan destination. Unfortunately, this has not changed and is, in my view, a fundamental omission.
Chemical disposal points do not cost much (see above) where other sewerage provision is being planned as at Loch Achray but this appears off the Park’s radar. Its well past time that the Park started putting in place proper facilities for campervanners who do not want to stay in registered caravan sites.
The more recent planning documents for Loch Achray raise a further concern, that the LLTNPA is proposing to create ARTIFICIAL camping pitches. In one place the papers refer to:
Camping on bark is horrible and describing it as traditional is simply “parkspeak”. However, it appears that the current proposal is for rubber pitches on raised sand beds:
No-one from the Park appears to have asked any campers whether they like camping on artificial mats – although I guess if people were asked they might suggest their use on some of the sloping pebble beaches which the Park has designated as camping permit areas!
Just why the National Park is wanting to create 9 artificial places on this beautiful grassy area where people have been camping for over 30 years is not explained.
The creation of fixed pitches here is control freakery. It appears the Park cannot bear the thought of people being able to choose where they camp, picking a suitable spot according to the conditions. This is contrary to the spirit of freedom to roam. While the Park has said it wishes to develop basic campsites that promote the wild camping experience, paradoxically it appears it cannot abide anything basic and feels compelled to adopt suburban solutions for a National Park whose fundamental purpose is to enable people to enjoy nature.
While some work might be required to create the 3 camping pitches on the west side of the burn, where the land is boggy and overgrown, this could be done without rubber matting. NO artificial pitches are needed in the largest camping area on the east side of burn.
The Park is once again, just as at Loch Chon, destroying vegetation through the creation of formal camping pitches. At the same time in their report to the December Board staff claim they are trying to measure vegetation recovery in places where people used to camp in order to evaluate the success of the camping byelaws. The Park appear blind to their own hypocrisy.
The Park’s concession to wildness is that instead of creating artificial paths over the grassy area, they are prepared to let this happen naturally (see left). There has been camping at Loch Achray for 30 years without paths developing here so why they should do so now is unclear.
Other concerns about the Loch Achray campsite
The Scottish Environmental Protection Agency have objected to the planning application because of the risk of flooding. I did wonder briefly if theartificial pitches were a response to SEPA’s objection but there is no mention of this in the lengthy justification the Park has commissioned (two large to upload here). I do feel sympathy for the Park about this. Readers had pointed out the Loch Achray site was under water at the beginning of October but the report confirms this was caused by the opening of the Loch Katrine sluice gates, a rare event and manageable. While Scottish Planning policy is to avoid placing any developments on flood plains, this campsite is supposed to provide a wild camping experience. What’s more none of the infrastructure, apart from the artificial pitches, is located on the area that floods. Still the Park is now having to install a paraphernalia of flood guages and warning signs to get this through the planning system. It could have avoided many of these difficulties if the Guidance on Visitor Experience which its Planning Committee approved earlier in the week had addressed these issues (I will come back to this but it failed to do so).
The Park also now appears to be proposing the campsite is staffed 10 hours a day:
This is madness which appears driven by the need to get SEPA to withdraw their objection. The Loch Achray site is actually much better and safer for camping than some of the camping permit areas created by the Park which are regularly underwater and unusable (e.g the beaches at Firkin Point). The difference though is the permit areas never required planning permission. More hyprocrisy from the LlTNPA and other agencies. Should SEPA not have been objecting to many of the permit areas because of their flood risk?
The cost implications of this staffing are signficant. 10 hours at even £10 per hour (minimum wage plus on costs) is £100 a day. 17 places are planning and lets the campsite does twice as well as Loch Chon, which was always too big and is more remote and whose occupancy is as follows:
So, 44% occupancy – call it 8 places at £7 a night. That is £56 income. So, if staff are here 10 hours a day that is going to leave a minimum net cost to the Park of £44 each day (setting aside all the other running costs, from power supply to vehicles for the staff concerned). In reality it will probably be far far more than this and for what? What the Park have not yet appreciated, because they have never done a proper cost benefit analysis of any of the Your Park proposals, is that it would be far better use of resources to let campers supervise themselves and just service facilities (whether toilets or bins) than it is to try and police campers (which should be a matter for the police).
The response to SEPA also raises questions about when this campsite will be open:
This makes it sound as though, just like Firkin Point, the Park toilets won’t be available for use at the start of the camping byelaw season on 1st March. Its also unclear whether the statement that the tourist season runs till October means the campsite will close on 30th September, as Loch Chon did this year, or at the end of October. In my view ALL the Park’s facilities such as toilets should be open year round.
To end this consideration of the Loch Achray campsite planning application on a positive note, one excellent document has been added to the Park’s planning portal: a “soft landscape” specification (see here) for revegetating and planting trees in the area around the carpark. This was from a Sarah Barron, whom I assume is the Park’s ecologist. Its very detailed, leaves nothing to chance and sets the sort of standard the Park should be applying to this sort of work everywhere – hydro schemes come to mind. The Park has some excellent knowledgeable staff, the problem is that best use is not being made of their expertise.
What needs to happen
The concerns described here about the design and opening times of the Loch Achray campsite could easily be sorted out if the LLTNPA had the will and consulted properly with recreational interests instead of thinking it knows best. Given their general reluctance to do this I hope people will object to the application, the main things to object to being the lack of a chemical disposal point and the proposal to create artificial camping places.
My greatest concern however is that this is the only concrete proposal for a new camping facility in the National Park in the next year. Now, I know that austerity is really biting but if its budget custs which are preventing the Park from doing more they should be saying this loud and clear. They promised delivery of new camping infrastructure as part of the Your Park plan and so far have delivered very little. There are lots of small things the Park could do, for a lot less cost than the Loch Achray Campsite, which would make a real difference.