Category: Loch Lomond and Trossachs

November 23, 2017 Nick Kempe No comments exist
Upper section of tracks in Coilessan Glen. Neither FES nor LLTNPA appear concerned about the landscape impact of the track works here. If these were not deemed forestry tracks, I believe the LLTNPA would have required a full landscape impact assessment.

Since my post in June (see here) on Forest Enterprise’s  “upgrade” of the Coilessan Glen forest track, I have been trying to get to the root of what has gone wrong.  First I established that no planning application or prior notification had been received by the Loch Lomond and Trossachs National Park Authority, then I took the matter up with  Simon Hodge, Chief Executive of Forest Enterprise Scotland.  I believe my correspondence with him shows there are serious issues about how the Forest Estate is being managed in the Loch Lomond and Trossachs National Park and will highlight evidence for this in this post (you can view the full correspondence below).

The Prior Notification System and the track upgrade

Forestry Tracks are, under planning legislation, classed as permitted developments but under the Prior Notification System all new or alterations to existing forest tracks are supposed to be notified to the Planning Authority.    FES is usually good at doing this, and indeed has now done so for two small changes to the track in Coilessan Glen.  However, they disputed my claim that all the track upgrade and other works needed prior notification, claiming these were “maintenance” rather than alterations.

In response I sent them some photos:

View of track extension from below

FES response to photo:

In plain language this is an acknowledgement from FES that the works included a new section of track which they should have notified to the LLTNPA under the Prior Notification System.  However, they try and excuse this failure by saying they had told the LLTNPA about a new section of track in Coilessan Glen but in a different place, 250m away!  Imagine someone trying to justify building a house in one place on the grounds that the planning authority had accepted this in a different location!

The LLTNPA’s response to that Prior Notification (link to full letter below under correspondence) is telling:

 

Another view of the track extension

This extension is according to standard FES designs and therefore its reasonable to say that the original 250m away would have had a similar landscape impact.  Yet the LLTNPA was quite happy to state in response to the Notification that such extensions do not raise “any significant landscape” concerns.   I don’t think any recreational walker would agree.  The works have had a serious adverse impact on the Cowal Way.  The LLTNPA needs to ensure its staff and Board Members get out more and review their policy in this area.  I know the LLTNPA and other public authorities are strapped for resources but this is simply not good enough for a National Park.  At least according to the correspondence FES and LLTNPA have now met to discuss what to do about this section of track.  Now both need to explain publicly what they will do to restore the damage to the National Park landscape.

FES response to photo:

By saying this, FES seem to be trying to imply that this work to reinforce the side of the track is not an alteration but maintenance.  They have however accepted, by calling in the Scottish Environmental Protection Agency, that the works could have  serious ecological implications (with silt eroding into the river).  Reason enough one might have thought to notify the LLTNPA.

Apart from the technicalities of the failing Prior Notification system, the substantive issue is that FES has trashed what would otherwise be an attractive section of river.  In the current Ardgarten Forest Design Plan (which is not publicly available although FES are now publishng new forest plans as they are agreed) all the main riparian edges in Coilessan Glen were designated for native woodland.  Good plan, shame its being ignored.

Evidence that FES had altered the track and extended it beyond its existing footprint

FES response to photo:

The evidence shows that what has been done is more then vegetation removal.  Scottish Government Guidance on tracks and the Prior Notification system SG FinalGuidance june 15 Smith et al 2014 states:

 

“The distinction between”alteration” and “maintenance” may sometimes be difficult to determine. Maintenance‟ work could include routine repairs to private ways such as filling potholes or clearing drainage channels or replacing culverts in line with recommendations and guidance by SEPA to comply with good practice.

Work such as resurfacing to provide a materially different road surface (for example replacing loose gravel with tarmacadam), or to widen or extend a track, would generally be considered an “alteration‟.

 

While I believe the Coilessan tracks have been altered, whatever the Prior Notification technicalities the substantive issue is why FES is allowed to do work like this in the National Park?  The slope is too steep, will erode rather than re-vegetate and contrary to good practice (such as contained within the LLTNPA Guidance on Renewables).   The LLTNPA should be demanding that Forestry Commission Scotland, which agrees the standard specifications for forest tracks, to review them to ensure they are fit for National Parks (and other areas of landscape importance in Scotland).

FES response to photo:

Accepting FES assurances that the work is not complete, it is  disturbing that National Park Officers apparently have deemed the work at Coilessan acceptable.  Do they not even think further monitoring is required to see that any restoration work by FES is acceptable?    I would like LLTNPA Board Members to go out – preferably in the company of people who have an interest in our landscape and nature conservation in our National Parks –  take a look and re-think.

FES response to photo:

So, quarries can be built and extended in National Parks outwith the planning system.  I am grateful that FES sent me the letter from FCS EIA101 Ardgartan Quarry – even if it basically attributes responsibility for this to them –  although they have made no mention of the mitigation measures which FCS said needed to be agreed with the LLTNPA and are not anywhere public on the Park’s planning portal.   While I will pursue this, the substantive issues is that  quarrying does not have to look like this.  Here is an alternative example from the Cairngorms National Park I came across last weekend:

Borrow pit in Glen Tromie on the Glen Feshie Estate. The photo accentuates the track up the slope, which is hardly visible from other angles.  Ignore too the heap of aggregate and foreground and note how vegetation has been replaced on the quarried slope even though, just to the left, the borrow pit is being worked.

In Glen Tromie (which I will blog about in due course because of the positive lessons there for the rest of Scotland) the estate are restoring the quarry as they go, a complete contrast to FES.  The contrast in how the land is being treated and landscape respect is in my view stark.

 

The new Prior Notification for a 70m section of track in Coilessan Glen

 

At the beginning of October, FES submitted a Prior Notification to the LLTNPA for further work in Coilessan Glen – to “straighten” the section of track beyond the bridge in the photo above.  The response of the LLTNPA was that this did not need Prior Approval (see here) because:

Leaving aside the implication that any forestry road deemed commercial can go ahead in the National Park without any consideration of landscape or conservation issues, the LLTNPA has failed to properly consider the issues as this extract from the second FES letter shows:

First, FES are now claiming the track is needed in case there is a need to fell larch trees in an attempt to prevent the spread of Phytopthera Ramorum, a disease that is decimating larch plantations across the UK and not for normal commercial forestry purposes.   Second, FES are not proposing to remove the old track but to leave it in place, so there will be two tracks at this point in the glen for what appear to be spurious reasons.  (I had been rather hoping they might use the opportunity to reduce the old track to footpath width so improving the walking experience on the Cowal Way).   So why did the LLTNPA not ask what was happening to the 70m section of old track before simply approving the new one?   If this is anything to go by it appears the LLTNPA are simply rubber stamping FES Prior Notifications without any consideration of the landscape or conservation implications.

 

What needs to happen

The issues raised here are much broader than the track in Coilessan Glen and have implications for the whole of the Argyll Forest Park.   When the Loch Lomond and Trossachs National Park was originally proposed, Cowal was not included, but this changed as a result of local pressure.  Part of this was because local people thought a National Park might be a way of changing how forestry was managed in the Argyll Forest Park.

Initially the LLTNPA did take an interest in Argyll and a new forest framework was produced lltnpa woodland framework action area 3. (This is not publicly available – the FES appears to have just one copy – but I am very grateful for the FES planning section for copying the relevant part of this and sending it to me by return without an FOI request).  While this did not propose a radical change of direction – it clearly states that commercial forestry would predominate – it did set out some aspirations and suggested areas for change (on some of which there has since been progress).  The problem is that the thinking behind the framework has never been reviewed or developed despite opportunities to do this, mostly recently in the draft National Park Partnership Plan consulted on earlier this year.

The most important thing that I believe needs to happen therefore is that the new National Park Partnership Plan should commit both the LLTNPA and FCS/FES to a public a review of Forest Management  in the Argyll Forest Park and how this meets the National Park’s statutory objectives.  While the spread of Phytopthera Ramorum – a conservation disaster which I will come back to – is another reason to do this, the failed operation of the Prior Notification system in Coilessan Glen and the landscape and conservation impact of track works there should in themselves be sufficient.  It will be interesting to see if the final National Park Partnership Plan due to be presented to the LLTNPA Board in December says anything meaningful about changing forestry practice in the Argyll Forest Park.

Addendum – correspondence with FES

  • 30/08/17 Email (see here) and link to my June post sent to Simon Hodge asking if agreed the Coilessan track works should have been notified to the LLTNPA
  • No acknowledgement
  • 19/09/17 Polite reminder sent (see here) with my MSP, who everyone knows as Nicola, copied in.  Hey pronto, immediate (same day) acknowledgement
  • 22/09/17 Response claiming Prior Notification not required as work within “footprint” existing tracks, that the final “running track” would be narrower and that the tracks were needed to control Phytopthera Ramorum  Final response to Mr Knowles
  • 02/10/17 Follow up letter sent with photographic evidence disputing FES claim that works within existing footprint Letter to Simon Hodge, Coilessan 171002
  • No acknowledgement
  • 17/10/17 Polite reminder sent (see here), noting further issues raised by recent notification to LLTNPA of work to straighten a section of track in Coilessan Glen, with my MSP once again copied in.   Hey pronto, acknowledgement!
  • 25/10/17  Response (see here), treated as Information Request, with two attachments: the first the LLTNPA response to a prior notification in 2016 for a new 50m section of track at Coilessan (on planning portal) (see here); the second, the response from Forestry Commission Scotland EIA101 Ardgartan Quarry saying an Environmental Impact Assessment was not needed for the quarry which has been used to source material for the tracks
  • 10/11/17 provision of Ardgarten Forest Plan (document too large to provide on website) and lltnpa woodland framework action area 3 by FES planning department.

 

The timing of the responses from FES is a neat illustration that when it comes to senior personnel in public authorities its not what you say that matters but who you know.

 

November 20, 2017 Nick Kempe 7 comments
Extract from Flamingo Land/Iconic Developments consultation display

On Friday I went to the first of the Flamingo Land consultation events at Lomond Shores in Balloch.  I was not sure what to expect partly because the proposals have been developed in secret (see here) but also because – like many people I suspect – I don’t think like a developer.   The display of the proposals – they are now all online (see here) – made it clear Flamingo Land want to develop ALL the land they and we/Scottish Enterprise own to create a holiday resort.  This is encapsulated in their portrayal of the “site wide experience” (see above) but there was already a big clue in the name of their development vehicle, “Iconic Leisure Developments”.

 

I left Lomond Shores thinking that the only way the Loch Lomond and Trossachs National Park Authority can only approve the development of this holiday resort if they ignore all four of their statutory objectives, conservation, public enjoyment of the countryside, sustainable economic development and wise use of resources.

 

The “consultation”

Extract from Flamingo Land/Iconic Developments consultation display

While the detailed design plans for each component of the development may well be at an early stage,  Flamingo Land’s statement that it will submit an application for Planning Permission in Principle (see here) early in 2018 means the main elements of the proposal have already been decided.  If an overwhelming majority of consultees object to one or more elements of the proposal, there is no time to develop alternatives.  In addition, most parts of the Environmental Impact Assessment must either be well developed or complete by now but all of these have been withheld until the planning application is submitted.   So much for the Scottish Government’s commitment to “co-production”.  On the one hand they support community planning events, which included the Balloch charrette (see here) earlier on this year,  but at the same time they allow developers and “the market” to carry on as they always have.

 

Something is very wrong when consultation and involvement for what is an extremely large development in a National Park – and remember the emphasis now is on consultation prior to any planning application being submitted – is limited to a handful of days when the public can view an exhibition and are given the opportunity to comment on this.    Those attending were hit with a chocolate box of  new proposals from a mono-rail and aerial walkways to outdoor swimming pools and, while given the opportunity to ask questions of the team of consultants present, after this tasting were asked to give an immediate response.  While I overheard and took part in a number of very interesting discussions, there was no real opportunity to think or talk through the implications let alone offer alternatives.

 

There is another, and final, consultation event Monday 4th  December but at least the consultation questionaire is now online which gives people a little longer to consider how to respond.

 

The main elements to the proposals

Extract from map showing proposals for Riverside site

The two key big ideas developed in the Balloch Charrette, for a walkway along the River Leven connecting the town to Lomond Shores (about which I was sceptical) and a bridge across the mouth of the River Leven to connect Lomond Shores with Balloch Country Park (and therefore the countryside) have both been dropped.   Both proposals were about improving the public realm but neither would have brought financial benefit to the developer and its almost certain money is behind this raising the legitimate question as to what appointing a private developer will bring to Balloch.

 

Instead, the proposals appear to about using every available inch of space on the site to make money for Flamingo Land.

Greenspace 

While Flamingo Land are claiming to be preserving this, every element is to be intensively used, as you can see by the number of lodges in the proposals map above.   Just why this number of holiday lodges are needed at Balloch is not explained.

Drumkinnon Wood

This is very well used by the local community, but the proposal is for it to become one of the gateways to the development via an aerial walkway (4) which conveniently by-passes Loch Lomond Shores, as well as providing (from a count) 31 holiday lodges, some of which apparently may be up in the trees.  Along with this is a Forest Adventure Area” (3) and Children Area’s (5).   How this will leave any room for nature in what is an Ancient Woodland Site is not explained.

The parkland along the River Leven

This is to be filled with another 39 (again my count) Holiday Lodges (that makes 70 Lodges in all) but is also site for a new monorail linking the station to the Flamingo Land visitor hub.  This is private transport to take people to a private development,  quite a contrast to when the public railway took people to the edge of the loch in Balloch’s heyday.  While Flamingo Land are saying that none of the lodges will be fenced off, I think people will be left feeling intensively uncomfortable about intruding on private space if they step off the path which forms part of the John Muir Way.  The proposal changes what was a path through parkland into a path through a glamping site giving people every incentive to take the monorail.

The pierhead

The land at what is described as the pierhead (7 in diagram above), which currently offers the best views over Loch Lomond, is being proposed for intensive development which may be as high as the Drumkinnon Tower.  This includes a 60 place luxury hotel and an indoor water sports development.

Viewing Tower

For those who who not want to pay for the resort facilities to enjoy the views, the proposal is for a viewing tower behind the development so people can pay to look out over the hotel and watersports facility to see Loch Lomond.   This is I believe privatisation of a public good, made even worse because the design of the resort is such that there is nowhere else people can go to enjoy the views and nature.  This might have still been possible if a bridge was constructed over the River Leven into Balloch Country Park and if Drumkinnon Woods had been left as a space for informal recreation.

Transport

While the proposal claims to put walking and cycling at the heart of the development,  current roads and parking are basically to remain as they are, except for the Lomond Shores overflow carpark which is to be taken over for people staying in Flamingo Land accommodation despite current shortages.  Locals and visitors can therefore expect parking to get worse at peak periods.

The Ben Lomond Way behind the Drumkinnon Tower separating Lomond Shores from Drumkinnon Wood (photo from day of consultation event).  The lack of people tells you everything.

There are currently two roads to the the Pierhead area, Ben Lomond Way and Pier Rd. These see little traffic except when people are trying to access the Park operated public boat launching slipway, the only one left on the loch, and a parking area which is distinctively suburban.   The roads and carpark segment the site with the result that walking from Lomond Shores to the River Leven is not a good experience.   With a bit of radical thinking, consultation with boat users on their needs and alternatives and some expert input there must be opportunities to remove one of the roads  and the parking area improved.  Instead, the suburban blight is left at the heart of what is supposed to be an iconic development.  Another opportunity missed.

 

Are there any good elements to the proposals?

I thought there were two elements to the proposals that might enhance the National Park, rather than undermine its core purpose, and both were well away from the loch shores.

Extract from Flamingo Land/Iconic Developments consultation display – Station Square

 

The charrette identified the space by the bridge over the River Leven as needing improvement and the ideas Flamingo Land has produced appear informed by this (helped I think because there has been some involvement in other stakeholders such as Sustrans in how this part of the site might be developed).   Is a big developer needed to do this?  It seems to me the sort of proposals being made for this space could, with a little vision from our public authorities, be implemented by a Community Development Trust.   This could, for example, provide a bridge between people in the local community and effective use of the proposed outdoor performance space.

The other part of the proposal I liked was for the land in front of Woodbank House, basically a public space for people to enjoy themselves without having to spend money.   Not a natural landscape but not incompatible with the objectives of the National Park.

 

How do Flamingo Land’s proposals fit with the statutory objections of the National Park?

Conservation

The proposals are to jam pack the areas of ancient woodland on the Riverside part of the site with developments so they became a version of Go Ape.   That was not appropriate for Pollok Park in Glasgow and is not appropriate for a National Park.

In landscape shores, what can be seen from a sixth storey hotel bedroom, will equally be seen in the opposite direction.  Since the 1980s the woodland setting on the west side of the mouth of the River Leven has been progressively destroyed, first with Lomond Shores and now by the Pierhead Proposals.   The most intensive part of the development is in the wrong place.

 

Public Enjoyment

While the shoreline between Lomond Shores and the Maid of the Loch does not offer a quality experience in terms of the immediate environs, the public have a right to walk along most of shore and enjoy the views.  This space, if the proposals go ahead, will effectively be privatised while the ability of local people to enjoy Drumkinnon Woods will be severely compromised.

This is part of a wider process about control of space:  the camping byelaws for example, which prevent people from camping where they always have done in direct contact with nature, have been used to channel people to commercial campsites.  The commercial success of the proposed camping pods at Flamingo Land will depend on the continued ability and commitment of the LLTNPA to the camping ban.

Moreover, the Park’s statutory duty is to promote enjoyment of the special qualities of the Park, not to promote indoor leisure developments or intensively used tree top walkways.   I have been to Landmark in Carrbridge a couple of times, and while I have never much wildlife there,  at least you get the feeling that you could step outside the centre, away from the crowds and aerial walkways, and see something in the neighbouring woods.  At Flamingo Land there is no space left for nature or for people to enjoy it.

 

 

Sustainable Economic Development

Without detailed design plans, its not possible to tell yet whether the development will be sustainable in terms of issues such as use of materials and energy or how many and what type of permanent jobs it will create.     One can at this stage question other elements of sustainability.    Apart from the claim that Abellio is interested in improving the train service, all the indications are that the development will increase traffic to an area which already groans under the number of cars. The bigger issue though is about sustainable tourism and why people would wish to stay in a Flamingo Holiday Lodge or hotel at Balloch for a week?

The idea of promoting Balloch as a gateway to the National Park makes sense but people tend not  to linger in gateways for long (unless forced to do so, for example by the camping ban) and the  pattern of tourism to the countryside is changing to short stays.   There is not one element of the proposal that I can see that is about enabling people who book accommodation to travel out to experience and enjoy the National Park.  Instead, its about keeping people in the resort and getting them to spend money, not on enjoyment of the natural qualities of the National Park but on amusements.   How it contributes to the development of sustainable tourism in the National Park is something therefore the LLTNPA needs to answer.

 

Sustainable use of resources

Again, its too early to tell but to me the outdoor swimming pool area, no doubt heated, tells a tale.

 

What needs to happen

We need to remember that the Riverside element of the proposed development is publicly owned.   Our Public Authorities however are so wedded to the tenets of neo-liberalism – that only the private market can and should deliver developments – that they are happy to promote a development which is, judging by how it matches the National Park’s statutory objectives, to be in the private not the public interest.

A different approach is possible starting from the idea that publicly owned land should be used to deliver public goods in partnership with local people and other stakeholders to meet the statutory objectives of the National Park.   There are two ways this could happen.  The first is if the LLTNPA were to start upholding its statutory objectives rather than promoting/acting as a facilitator for inappropriate development.  The second would be if the local community were to launch a bid to takeover some or all of the site (just like the Aviemore and Glenmore Community Trust intend to do at Cairngorm).  Combine the two and you could develop a much better alternative to Flamingo Land’s offering.

November 17, 2017 Nick Kempe 14 comments
The Cononish gold mine as it looked on a dreich day in May – the same day as the pre-consultation event in the Tyndrum Village Hall

The failures in the Loch Lomond and Trossachs National Park’s consultation system

A couple of weeks ago, at the Scottish Wild Group AGM, I was told that a planning application  had been submitted back in August for the new proposal for waste storage waste from the Cononish Gold Mine (see here).   The formal consultation period lasted 28 days and, while I have spent a few days feeling bad that I had missed this and failed to advertise what is being proposed, what I have realised is very few other people knew about the application either.  That is until Scotgold placed a story in the press earlier this week presenting the application as a done deal (see here for example).

 

This demonstrates a fundamental flaw in our planning system.  There was no a single objection on the Loch Lomond and Trossachs National Park Authority planning portal (see here) until I lodged one on Wednesday.  Although this was outwith the formal consultation period, because the application has not yet been determined, you can still lodge comments and I would urge anyone with an interest to do so.

 

The lack of public comment until this week – there are three letters of support which all appeared on the same day – is not I believe because people don’t care about what is being proposed.   There there were significant number of objections to earlier applications.  The reason is that either people don’t know what is being proposed or don’t understand.  I have checked and it appears that neither the Ramblers nor Mountaineering Scotland were informed about the application even though the Ramblers Scotland tweeted a photo of an unlawful Scotgold anti-access sign at the weekend (see here).  (The sign is unlawful because its placed far beyond the current working site boundary).   It should be the business of the Loch Lomond and Trossachs National Park Authority as Planning Authority to make sure that recreational organisations are informed.  When the LLTNPA consults RSPB as a matter of course (they did in this case and every hydro application I can recall) – a good thing – why cannot they also consult the Mountaineering Council about similar developments in the hills?

 

It took me a couple of hours to understand how the 147 documents then on the Park planning portal relate to each other.  There is the main Environmental Statement  then a jumble of appendices and supporting documents which unfortunately don’t appear in the right order.  After scrutinising this I realised the first two appendices to the Environmental Statement, the Pre-application Consultation summary and Consultees responses, appear to be missing from documentation:

 

I have asked the LLTNPA to make these missing appendices public.  There seems little point to the current emphasis the Scottish Government puts on open and transparent pre-consultation if that is not reported.  I look forward to seeing the responses scotgold has made to the questions I and a friend made when we visited the consultation event at the village hall, which were all about how much more mine waste was going to be dumped on the hillside and the reasons for this.

 

What’s going on at Cononish shows is that there are major democratic deficits in our planning system.  This suits Developers and, it appears, the LLTNPA, because it avoids planning proposals from being subject to external scrutiny.   Its really important that  the public demand that the Scottish Government address these failures in the forthcoming planning bill.

 

The main reasons why the new planning application must be refused by the LLTNPA

Its not clear how much of the 8000 tonnes of waste was stored in these bags when this photo was taken in May – but in visualising the impact of the waste of the new planning proposal assume there is 7000 tonnnes in the bags and consider what 100 times this amount of waste would look like.  That gives an idea of how much waste is to be dumped – sorry sculpted – onto the slopes below the mine.

Scotgold already has planning permission for the gold mine, subject to certain conditions, and earlier this year Scotgold they were given an additional permission to start work on processing 8000 tonnes of former mine waste to extract gold. For the waste pictured above thas produced ten one ounce rounds which the press reported this week were auctioned for £46k, a mark up on nearly 400% over current market price.  I will come back to how any of this can be considered sustainable economic development or sustainable use of resources in a future post.

 

Here I will focus on the two key differences from the earlier planning application.  The first is that far more waste will be dumped outside of the mine.  The original approval included the following conditions::

REASON: To minimise the adverse landscape and visual impact and ensure that the site is restored to a satisfactory standard in this sensitive area of the National Park.”

 

The key bit is under point 5, the  amount of waste to be stored outside the mine was limited to 400,000 tonnes because of the sensitivity of the National Park.  Since the original application, the areas of the gold mine has been included in the Ben Lui Wild Land area so any protection of that sensitivity should be even stronger than before.

 

In my posts earlier this year, I drew attention to the fact that that amount of waste Scotgold wanted to dump outside the mine had increased to 530,000 tonnes of tailings.  It now that this was a vast undersestimate and that in addition to this scotgold wants to dump another 170,000 tonnes of unprocessed rock waste outside the mine.  That makes 700,000 tonnes of waste in all, a 75% increase in the amount of waste that is to dumped on the hillside outside the mine.   Nowhere in the application is this enormous increase clearly stated.  It appears no-one wants the public to know.  One consequence, if this is approved, is that the waste is now going to be disposed over a far wider area than would be needed if it was limited to 400,000 tonnes as previously.

 

It appears money has driven this change.  It would cost far more to replace waste back in the mine because the construction of tailings dams requires large up front capital investment.  So the new plan is not only to avoid replacing waste back into the mountain, its to create 10 tailings stacks of approximately 72,0000 tonnes each.  The second main difference to the earlier proposal.   This represents one full year’s worth of waste if new mining machinery is installed, 6 months if its not.  The stacks will be up to 10m high and moulded into shapes Scotgold claim will resemble moraine.

Extract planning application

One of the interesting things about this is the current proposal is claimed to be much better in landscape terms than the last one – an admission that the tailings dam as approved would in fact have had an adverse impact on the landscape in a sensitive area  (and therefore should have been refused by the LLTNPA!).  This time though we are told there will be no adverse impact, even though almost twice the amount of mine waste is to be spread over the hillside.  I am sceptical and so should the LLTNPA.

The reason for this is that in order to extract the gold, the quartz ore need to be crushed until it becomes sand and it is this sand which will make up the bulk of the stacks.  Now while you find sand in glacial moraine there is also lots of rock and finer particles – silt which goes to make clay – which helps bind the whole lot together.    However, if you place sand onto what is a pretty wet hillside – it was sopping when I visited in May – it would all wash away which is no doubt why originally a tailings dam was proposed.   Scotgold’s proposed solution to this – although storing sand is never acknoweldged as far as I can see to be a problem –  is to use the rock waste which was to be left in the mine to line the ground, put a geo-textile on top of this and then mould the sand on top of that.    Here are the design criteria:

Now it doesn’t take an expert to see that there are potentially two major problems with this.  The first is there is nowhere I can see that any consideration is given either to the life span of the membrane or what happens when it breaks down as it eventually must.  A reasonable assumption is that when this happens the stacks of compressed sand will start to be eroded away from beneath.   I suspect by then scotgold will have long gone leaving the public to pick up the tabs for preventing an environmental disaster.

 

The second is there is no proper consideration that I can see of whether it is possible to revegetate heaps of sand in the Scottish Hills in such a way that they will be able to withstand the erosive force of water from above or from the sides.  The re-vegetation plan is to store turfs, up to 30 cm thick and then use them to cover the stacks.  How well these will take on dried sand, which should drain quickly and is different in composition to current soils/peat is unclear.   Cononish, as the chart helpfully shows, has over three metres of rain a year.  Some of that may run off the top of vegetation but some of it will seep into the dried out sand heaps.   What will that do?   And even if the vegetation does take and provides a waterproof seal, what happens if deer get into the enclosure and start to erode tracks over the mounds?    It seems to me there is a high and predictable risk of wash outs of the tailing stacks. And that’s without considering the risks of the Alt Anie changing course by more than the 30m safety zone or of other burns running between the stacks which could be subject to flash floods.  That sort of scenario lead to catastrophic wash-outs.

 

I find it strange that neither SEPA nor SNH in their responses – and they have a duty to protect the River Tay Special Area of Conservation  have asked critical questions about the risks associated with the current proposals or for evidence that the proposed techniques work in very wet climates such as Tyndrum.   Perhaps they think its ok for 530,000 tonnes of sand potentially to wash into the river system over say the next 200 years?   Smaller heaps, with less material as originally agreed, would of course reduce the size of this risk.

Hummocky moraine in Strathfillan below the gold mine. The slopes of many of these moraines considerably exceeds 30% but they have held together for thousands of years because of the mix of materials within them, blocky till set within a matrix and sand and silt which often sets like concrete.

I am no expert on erosion risks and there is some technical documentation in the application which relates to this which needs to be explained in lay terms as well as properly scrutinised.  However, from a scan of the documents – there are 100s of pages of engineering documentation – there is some information in the application which suggests storage of sand is problematic.  This indicates there are high risks of sand sheering on slopes of more than 30 degrees.  This is why the proposed stack heaps do not  resemble natural moraine (for an example see above) but are to be moulded across the hillside.

 

 The Landscape impact of the tailings stacks

One of the landscape visualisations. You can hardly see the enormous green shed below the mine or the tailings. The white/grey patch below and right of the mine represents an unrestored tailings stack.

The Environmental Statement contains a number of visualisations of the landscape impact from different angles (see above).  These without exception make the tailings stacks disappear into the hillside.  Maybe they will, but there are reasons to be sceptical:

 

  • All the visualisations are from a distance and none show what a 10m high stack will look like from close up either before or after restoration.
  • The photos are all browns, a depiction of the area in winter.  However, because the stacks will be well drained their vegetation is likely to be very different to the surrounding peaty slopes and therefore stand out from it.   How this might look is unclear.

 

There are no depictions of how the sand heaps will look when they start to erode away as eventually they must.

 

The landscape impact of the buildings and spoil around the mine is not really covered but is already having a significant landscape impact.  The assumption seems to be blots on the landscape, as long as developers can claim they are temporary (in this case it will be for over 20 years not for all time, are perfectly acceptable in our National Parks.

 

The wider implications of this application

Cononish is not the only potential goldmine in the area and scotgold, when trying to talk up its prospects to attract investors, claims there is potential for several other mines in the area.  So what will the cumulative impact be of potentially millions of tonnes of mine waste sculpted onto hillsides around the Tyndrum and Glen Orchy hills?

 

What needs to happen

The LLTNPA needs to subject the new planning application to  critical scrutiny and in particular make a clear statement about the sustainability or not of the tailings stacks.

 

If the erosion risks can be addressed, in terms of the existing planning permission, it might be better for 400,000 tonnes of waste to be stored in a stacks rather than in a tailings dam.  However, the LLTNPA needs to draw a line under the amount of waste it will allow to be stored on the hillside and this should not exceed the existing limit.

 

November 10, 2017 Nick Kempe 1 comment

In order to ban camping and get the camping byelaws approved, the Loch Lomond and Trossachs National Park Authority misrepresented and grossly exaggerated the impacts campers were having on the loch shores.  They did this by promulgating multiple images of irresponsible campers while ignoring their own data and misusing police data which put the problems in perspective.  Among the things the data showed was was that littering was was a far more widespread problem than the LLTNPA suggested, i.e campers were far from the only cause of litter,  and that the proportion of irresponsible campers and campervanners to the total was very low.   What was needed to address problems associated with a few campers was a targetted response, not a blanket ban.

 

What the camping byelaws attempted to do, however,  was is to remove the rights of the many because of the actions of the few.  If we took the Park’s approach to people’s rights – that its ok to remove a public right if anyone abuses it – we would end up with no rights at all.   If you applied the Park’s approach to campers to littering along the A82, all drivers (most of the litter is chucked out of car windows) would be banned with permits then being issued to people who signed up to the Park’s terms and conditions for using the A82.  Totally absurd but that is what the Park has done to campers.  The LLTNPA has an opportunity to address that absurdity when it considers a report to the Cabinet Secretary for the Environment, Roseanna Cunningham at the next Board Meeting on 11th December.

 

Regular readers will know that Parkswatch has been trying to expose how the byelaws are really working ever since they came into operation in March.   In order to try and prevent the manipulation of data which took place in the Your Park consultation, after the camping “season” – as the Park now describes it – ended on 30th September, I therefore asked for data about the operation of the camping byelaws and ranger patrols to be made public before the Board meeting.   What I wanted to do was to try and inform the official review of the first year of the camping byelaws.

 

This week, after various correspondence, the LLTNPA EIR 2017-070 Update declined to provide the data they hold, claiming they needed more time to assemble it and that they would give this to me by 7th December.  This is just four days before the Board Meeting, or the day when under Standing Orders the Park need to make all Board Papers public anyway.   This stinks.

 

Earlier this year, I made a similar request for data up until the end of June.  The data request was submitted on 3rd July, a clarification made on 11th July and the Park provided me the information on 2nd August (albeit in a pretty unusable format).   In other words they were able to process the data in 4 weeks.  They are now claiming they need over 8 weeks to process the same data.    Its actually more than that because  my original data request was not on 11th October, as stated in their letter, but on 2nd October EIR 2017-055.  

 

All that is required to make the data public is for the LLTNPA to remove the columns with personal data (people’s names and contact details) from the spreadsheets they hold on the booking system.  Indeed they need to do this in order to provide the Board with any sort of proper analysis but are now saying this won’t be ready until after that Board Paper is published.  This is complete tosh and a fundamental failure in terms of being accountable to the public.  Clearly what senior staff are wanting to do is once again con Board Members into approving a report on how well the byelaws are going without providing them with the full picture.

 

Also this week, after a reminder, I did get a partial response to the last two questions in my information request (above):

 

“I refer to your email of 11th October 2017, in which you asked why the Loch Chon campsite was currently closed. The first season of the new camping management zones and byelaws is over, so the campsite has been closed to allow for any required maintenance to be undertaken over the winter season. The camp site will re-open next March.

 

Comment: I had asked for all information about the closure of the Loch Chon campsite but instead have been told the campsite is closed because the camping byelaw season is over.  I don’t recall any public decision that LLTNPA  campsites should only be open to the end of the byelaw season.  Moreover, both Sallochy and Loch Lubnaig campsites are open until the end of October.  All this says is its closed because its closed.   Whatever happened to the idea that what is important is the LLTNPA puts infrastructure in place to support people enjoying the countryside?  It appears that senior staff have no real interest in improving facilities for campers in the National Park.

 

You had also enquired about when the Police Scotland Operation Ironworks report is due.  We anticipate that we should receive this report from Police Scotland by the New Year.”

 

Comment: so the information that was seen as crucial to the justification of the camping byelaws, Police statistics on Anti-social behaviour – the Park wrongly claimed the camping byelaws were responsible for an 81% drop on anti-social behaviour on east Loch Lomond – is not even going to be available to the Board before its takes a decision on its review report to Ministers.  What that says is that senior staff are just not interested in data or any information which could potentially contradict and disprove that their propoganda that the byelaws have worked well – even they no longer claim the byelaws are an outstanding success.

 

What needs to happen

The Board’s review of the first year of the camping byelaws will be a farce unless this includes a proper consideration of all the relevant data.  By proper consideration I mean it should have been subject to public scrutiny  and engagement with stakeholders before any decision.  A fair and balanced report would include among other things the following:

 

  • A public explanation for the collapse of the byelaws in respect to campervans and the reasons for this (see here)
  • An analysis of the total number of people reported camping in 2017 compared to previous years and implications of this (eg ability to enjoy outdoors, displacement elsewhere)
  • Adherence to the byelaws, including the numbers of campervans ignoring the ban before it officially collapsed, the numbers of tents found outwith permit areas (and whether they were doing anything wrong), numbers camping or campervanning in permit areas without a permit and the extent to which landowners are breaching the byelaws (see here)
  • The resources the Park has devoted to trying to get the byelaws work, particularly numbers of Ranger patrols, how rangers were used to enforce the byelaws and how this changed during the year as well and the impact this has had on other areas of work and the workforce.
  • As part of this, the expenditure on signage and analysis of how effective this has been
  • Analysis of the number of exemptions applied for under the camping byelaws (very few) and the impact that the byelaws have had on DofE, Scout Groups etc which have now basically decided to avoid using the National Park.
  • A summary and analysis of all complaints received into the operation of the camping byelaws and how this relates to the alleged positive feedback on the permit system (see here) (senior staff failed to refer to the existence of such complaints in the report presented to the Board in September).
  • A comparison of the number of abandoned campsites compared to previously (the LLTNPA while presenting lots of photos to illustrate abandoned sites did not say how many campsites had been abandoned or what resources were needed to clear these up).
  • The number of permit places actually available day to day during the byelaws compared to the 300 places promised to the Scottish Government taking account of the overall fitness of each permit area for camping (many are unusable and some have now been abandoned) and factors such as flooding.
  • The work the LLTNPA has undertaken to make it possible to camp in certain permit areas and the extent to which this has been successful
  • The reason why certain permit areas have now been abandoned
  • The consequences of trying to force campers into a few places (see here)
  • The impact of campers within wider context (litter etc).
  • Total expenditure to date on the Loch Chon campsite compared to original budgets, evaluation of the problems caused by poor planning (stench from toilets due to inadequate water supply, unuseable pitches etc) and .
  • Progress – or rather lack of it – on infrastructure which would help reduce impact of campervans and campers (waste disposal points etc) as well as the Park’s commitment to create new campsites

 

I do not believe such a report can be produced without engagement and consultation.  The LLTNPA at its next Board Meeting therefore needs to agree to delay the submission of its report to Ministers on the operation on the byelaws until it has made public all the information it holds and allowed this to be subject to public scrutiny.

 

I will now submit a formal review of the LLTNPA’s decision not to make crucial information for the evaluation of the camping byelaws public at the present time.  There is a formal stakeholders meeting next week and I hope the stakeholders there will join the call for all this information to be made public so they also can analyse it and provide proper feedback to the LLTNPA.

November 5, 2017 Nick Kempe 1 comment
Extract from Scottish Wildlife Trust magazine which dropped through my letterbox this week

While I would love our National Parks to be litter free, when litter is getting worse everywhere in Scotland (see here), any attempt to reduce litter which does not take account of the wider context is almost certainly doomed to failure.

 

Yet that is what the Loch Lomond and Trossachs National Park Authority did when it tried to blame littering in the National Park on campers and campervanners and came up with the counter-productive idea that the way to address the litter problem was to ban and control these activities through the camping byelaws.   I say counter-productive because the LLTNPA has been attacking the very people who should have been its strongest allies in tackling the litter scourge.  For its the people who enjoy being out in the countryside – who camp and fish among other activities – who probably have the most developed anti-litter ethic in Scotland.  Think of “leave only your footprints, take only the air”. Hillwalkers, wild campers and other such recreational visitors are not perfect, of course, but most are a great deal more litter aware than the rest of the population.

 

What’s more a small but significant proportion of outdoor recreationists pick litter up.   I bumped into two fell runners on Ben Lomond a couple of months ago and jogged down with them.  Normally I don’t pick up litter when running – it interrupts the flow – but these two stopped to pick up every piece of litter they saw on the way down.  So, so did I.  The Scottish Wildlife Trust initiative near Ullapool (see above) is a wonderful example about how our public authorities could harness this goodwill from people who enjoy the countryside and use it to make our countryside litter free.

 

Imagine what might have happened if instead of trying to ban campers, the Loch Lomond and Trossachs National Park Authority had provided litter pickers and made it easy for responsible campers to pick up litter left by others?   Litter pickers remove much of the unpleasantness and health risks associated with picking up litter and would therefore encourage more people to clean up.   That might have truly helped to “transform our lochshores” as the LLTNPA claimed it wished to do.  Before however the LLTNPA could copy the Highland/SWT initiative,  it needs to ensure all its member local authorities follow the example of Perth and Kinross Council and not just provide adequate numbers of litter bins but ensure these are emptied regularly.

 

While our National Parks could probably do more to prevent the main source of litter, which is packaging, by themselves they can never change the social attitudes which makes littering acceptable to a large proportion of the population.  What they could do though is set an example and harness the support of the people who do care and who are most likely to influence others.  If you are an unaware member of the public walking along that beach near Ullapool and see someone using the litter picker, I suspect that might make you think twice before dropping litter.  Clean places help but so does the example of your peers.  Its the same in our National Parks.  The LLTNPA could be leading on this but to do so credibly it will need to re-think its whole attitude to camping and other recreational visitors, start treating them as partners rather than problems and seeking their ideas.  The litter picker initiative is just one example how the National Park could make a difference.

November 2, 2017 Nick Kempe 4 comments
The area of the proposed application (from LLTNPA planning portal). There is nothing in the document about WHAT Flamingo Land are actually proposing

On 27th October, after six months of silence, agents for Flamingo Land lodged a pre-planning application consultation strategy with the Loch Lomond and Trossachs National Park Authority.  Anyone who follows Scottish Government planning policy knows that one of the big ideas and big pushes is towards “front loading” the planning system, with a shift to consultation and engagement taking place prior to planning applications being submitted.  The idea is this should improve proposals and help create consensus around developments.   What front-loading fails to acknowledge is that current planning system is unbalanced, with local communities having little power, and is driven by the self-interest of developers.  This, and the pathetic inadequacy of current pre-application consultations are clearly evidenced by the Flamingo Land proposals.

Its still them and us

The “They” is the public, you and me – the heading illustrates typical attitudes of developers towards the public, a hurdle to be got past, not a partner in developments.

The Pre-application consultation is supposed to include the following:

The only description you will find in the planning documentation about Flamingo Land’s proposals is this:

 

 

 

The LLTNPA will no doubt be patting itself on the back that Flamingo Land is holding three consultation events, rather than the minimum recommended, which is one!   How the public are expected to meaningfully inform the proposals by turning up to an event on the day, with little idea of what to expect, and then respond with no time for reflection, I don’t know.  Any meaningful consultation has to take place over time, to allow exchange and development of views, but instead of using the last six months to do this, the LLTNPA is allowing Flamingo Land to run three tokenistic events.   This is apparently what good consultation looks like – the document states “Best Practice for Consultation is also outlined”  – in the planning world.  This is a major development proposal in a National Park which has enormous implications both for the local community and the National Park and is quite frankly not good enough.

Its also a recipe for conflict:

Extract from Empowering Planning to Deliver Great Places. One of the three authors was Petra Biberbach from the Planning Advisory Service who is also on the LLTNPA Board and chairs the Planning Committee

So, why is Petra Biberbach not using her position as Chair of the LLTNPA Planning Committee to empower the local community to get actively involved in planning the Riverside and Woodside sites as she recommended two years ago?

Community Empowerment and planning

While Scottish Government pronouncements and the discourse of our public authorities is full of buzz words about “community engagement”, “community empowerment” and “co-production”, the actions of our Public Authorities continually contradict what is being said.  The Park of Weir planning decision, where Planning Minister, Kevin Stewart, overruled the views of the local community at Dunblane in favour of the developers is just one example of this.

Its worth reading what the organisation Planning Democracy had to say about the Scottish Government’s planning white paper (which was developed in response to the review of Planning Petra Biberach was involved in):

The lack of meaningful involvement however fundamentally comes down to power.   What the map above illustrates is that Flamingo Land could be granted a stranglehold over the land to the West of the River Leven and therefore over the local economy.   Scottish Enterprise has agreed in principle to sell the Riverside Site, which is currently in public ownership, to Flamingo Land while their purchase of Woodbank House and also the boathouse on the point to the north west of Lomond shores means they surround that development.  There are serious issues to be addessed about whether this is in the public or local community interest.

 

There is, however, now that the Community Empowerment Act is law, an opportunity to challenge this.  One way for the local community to prevent Flamingo Land from acquiring too much power would be to request the Riverside site from Scottish Enterprise as an asset transfer.  This would not be with a view to stopping all development from going ahead but rather to ensure the community is able to influence the development, retain control in the long-term and ensure some community development.   For example, if the local community owned the land they could refuse development in certain places, such as Drumkinnon Wood, prevent inappropriate applications being made in future (e.g viewing towers which I suspect will be the sacrificial lamb Flamingo Land offers up to get their development proposals through) and ensure community benefit through rent payments.

 

Against what criteria should Flamingo Land’s development proposals be judged?

While the planning application still describes the development as Flamingo Land, the developers have set up a website in the name of Iconic Leisure Developments. This is more informative than the planning application and makes clear that fundamental to the application will be an attempt to “drive the number of visitors”:

This is worrying.   It is  exactly the same type of wording which HIE uses at Cairngorm – we all know what happened there – and is, in my view, inappropriate for a National Park.

 

There is nothing wrong with development at Balloch as long as it is sustainable and benefits both local people and the wider public.  While its a gateway to the National Park, gateways are not normally places people choose to linger.  People want to get inside and in the case of National Parks to experience nature.  It appears the only way Flamingo Land believe they will be able to attract visitors to remain longer term is if they offer a theme park type development.  They may be right about this but it  would be totally inappropriate for a National Park.   The fundamental problem is that this site is being viewed from a commercial, rather than a National Park, perspective and that is likely to drive a certain type of development.  Most of it is still public land and other solutions are possible.

 

Whatever is proposed should, I believe, be evaluated against the National Park’s four statutory objectives.   Here are a few pointers of how I think the proposals should be judged:

  • Sustainable economic development
    • will the long-term jobs on the site be reasonably paid (talk in Scotland is now of £10 an hour minimum wage) and provide good terms and conditions or will the development provide yet more precarious jobs on the minimum wage with precarious hours?
    • will local community businesses and other organisations be able to operate within the development area on fair terms and conditions?
  • Conservation
    •  how much of green parts of the Riverside and Woodbank House sites will be retained, will aerial shots of the site look as green in five years time and will Mackinnon Woods be kept free of development?
    • what will the landscape impact of the development be and will there be a viewing tower which could be seen from the summit of Loch Lomond
  • Sustainable use of resources
    • Will any polluted land on the site be cleared up?
    • Will the development when operational be powered entirely by renewable energy?
    • Will the development result in more traffic and does it incorporate improved public transport links?
  • Public enjoyment
    • Will traditional informal recreational uses of the site be able to continue (boating and angling on river leaving, walking in Mackinnon Woods)
    • Will people visiting site be able to access nature easily, e.g, through a new bridge over the River Leven?
    • Will the amount of good quality public space increase or decrease?

This is far from an exhaustive list and other people will have different ideas.  The LLTNPA and Flamingo Land should have been engaging with the local community and nationally about such objectives but they haven’t done so so far although they have been clearly having secret talks since January:

The way its going Flamingo Land should provide an ideal opportunity for both local community and national lobbying organisations to demonstrate to the Scottish Parliament the inadequacies of our current planning system within the forthcoming Planning Bill which is intended to create a different approach.

October 31, 2017 Nick Kempe 4 comments
Forest Drive is the grey road bottom right of map (its one way) while the Dukes Pass Rd lies a few hundred metres to the left of the map.   Map from LLTNPA planning portal.
Map showing location from planning portal

In September the Loch Lomond and Trossachs National Park Authority submitted a planning application (see here) to itself as planning authority for a new campsite on the south shore of Loch Achray on Forest Drive in the Trossachs.    There is widespread agreement that new campsites with basic facilities are needed in the National Park.  So far the LLTNPA has been poor at delivering these.  It appears to have abandoned the excellent Five Lochs Plan (see here for example) which proposed a number of new campsites in the Trossachs and has also failed to deliver a new campsite this year on the south shore of Loch Earn.  This application therefore is welcome.   In this post I will look at what the LLTNPA has learned from its experience at Loch Chon and the camping byelaws to date.

The main camping area will provide for 9 out of the 17 proposed places

The area to the east of the burn is excellent for camping, being a well drained grassy sward.  It is owned by the Forestry Commission and has  previously been managed by Forest Enterprise as a Youth Campsite without facilities for Duke of Edinburgh expeditions and Scout groups.  Its far better for camping than most of the permit areas at Forest Drive (see here for example).  What is also good about the proposal is it allows people to camp by the Loch shore – a contrast to Loch Chon where the Park tried to force campers away from traditional camping places by the loch up onto the hillside.

Extract from plans

However, you can see from the campsite plan above that the LLTNPA is still wedded to the idea of fixed camping pitches and what is even worse they appear to wish to replace the grassy sward with bark.  That is not a traditional camping pitch, its suburbanisation.  The Park would be far better to abandon any idea of fixing camping pitches in this area and allowing people to camp where they choose.  This would also enable areas of bare ground to recover.  All the Park would need to do to manage this is to put up signs by worn areas asking people to choose a less worn area to pitch their tent (this is how it should be dealing with erosion throughout the Park – there is no need to ban people to protect vegetation).

Another positive is that this campsite is significantly smaller than Loch Chon.  At Loch Chon, Park Chief Executive Gordon Watson insisted (see here) that the minimum viable size for a campsite would be 26 – he reduced the numbers from 33 after pressure from the Local Community.  At the time Parkswatch said this was rubbish and Gordon Watson did not know what he was talking about.  That the Park is now proposing a 17 place campsite provides proof of this.  Its good someone has listened but don’t expect any apology to the Strathard Community.

Having visited the site, I do think the recreational community should have concerns about some of the areas where it is proposed to locate the other 8 pitches.

How many people would choose this as a place to camp?

Three of the places (far left of map above) are in woodland up on the hill well away from the loch.  To provide camping places here will require the creation of paths and pitches like at Loch Chon.  I suspect the main reason for these pitches is to enable the Park can claim to have provided a certain number of new camping places – its target, which it has failed to meet, was to provide 300 new camping places in the first year of the camping byelaws.

 

The LLTNPA appears to be repeating he mistakes it made at Loch Chon, which was its failure either to consult campers about where they are likely to camp or to check whether the pitches, as depicted on the map, were campable or not.   At Loch Chon many were too sloping or covered in tree roots to provide good camping places.  They also failed to provide sufficient space, with many only providing for a tent and no suitable space for sitting or cooking round about.   Unfortunately there is still no sign of the Park consulting campers about what type of camping places are needed but the LLTNPA at least needs to undertake thorough checks before agreeing to the three places here, including that there is sufficient space.  I would argue that its money would be better spent on creating camping pitches elsewhere, e.g. at Inveruglas, where the camping permit area is rough  and not good for camping at present, similar to these three places, but is much closer to the lochshore and the toilet (if it was opened).  If the LLTNPA  are going to engineer new camping places, they should consult campers about where best to do this.

Area on left (west) side of burn

On the low-lying area on the west side of the burn (upper centre part of site plan) the LLTNPA is proposing to provide a further 3 places.  This is much closer to the loch than the proposed pitches on the hillside but the edge of the lochshore here is boggy, the ground itself boggy in places and has become overgrown.  This perhaps explains why there is little sign of people camping here at present.  It could though potentially provide good camping places with some engineering.  While not designated as ancient woodland some of the fungi on the trees are fantastic.  I would like to see mimimal path creation,  with importing of hardstanding materials limited to the boggy areas., to keep it as natural as possible.

Looking up hill from camping area on east side of burn towards where disabled camping pitches will be located

The site includes proposals for two camping pitches suitable for people with wheelchairs (bottom of site plan).   Its very positive the Park is including facilities for people with disabilities, who are too often excluded from enjoying the countryside, but its unfortunate because of the very steep approach to the loch shore disabilities that people with disabilities will in effect be segregated from other campers (bottom two places in diagram).   I hope the places get used.  What the LLTNPA should be doing is consulting organisations representing people with disabilities to ensure it has got this right (there are no disability or recreational organisations on the list of those consulted).

 

The proposed facilities at the campsite

Evidence of site investigations at Loch Achray – September 2017

The LLTNPA appears to have learned from its Loch Chon experience and conducted more thorough site investigations for utilities prior to the planning application being submitted.   This is to be welcomed.  Six months after the LLTNPA had got a certificate signed at Loch Chon stating the work on the campsite was complete, there was still no water.  As a consequence bottled water had to be provided to campers for most of the year and the stench from the toilets was at times terrible – another own goal for Gordon Watson, the Park’s Chief Executive, who had claimed to Strathard Community Council that composting toilets don’t work properly.

 

However, having checked with the LLTNPA, I can confirm that at present there are NO plans for a chemical disposal point to be included with the toilet block.  This is despite the LLTNPA trying to encourage more campervans to Forest Drive.  The consequences are predictable.  At some stage someone in a campervan will empty the contents of their toilet out on Forest Drive (as has happened elsewhere in Scotland where there are no facilities).  If the Park and Forest Enterprise are going to promote Forest Drive as somewhere to stay, they have a responsibility to ensure the right infrastructure is in place and the Park Planning Committee should insist on a chemical disposal point here.

 

Another aspect of the application which needs to be changed is there is no provision for any campervans in the parking area.  While there are permit places for campervans on Forest Drive, none offer toilets and smaller campervans don’t have their own internal toilets – so why not allow them to stay here?  In addition, groups of people wanting to enjoy time away together often include both campervanners and campers.  The Park still appears to have an unwritten policy of trying to segregate the two – it was still impossible by the end of September to book to stay at Loch Chon if you were a campervanner despite there being lots of parking space there.   Its time the Park abandoned this approach which appears to have developed out of a desire to divide campers from campervanners in order to rule.

 

Finally, given all the publicity about the toxic effects of diesel, its very disappointing the National Park are proposing a diesel generator to pollute the atmosphere along with what may or may not be an aerobic digestion system.  If this behaves like the one at Loch Chon it will fill the surrounding air with a malevolent stench. There is no detail on the cycle time of the generator running times, fuel consumption or fuel storage and any bunded facility to prevent environmental pollution in the event of a spill incident. There is no detail on the effects of air pollution in the way of diesel fumes presents to the local environment the environment. The diesel generator is not eco friendly, and it is a missed opportunity for the National Park who claim to champion the environment to provide a solar/ wind powered combination. There was however a diesel generator at Loch Chon, even after the connection to the National Grid had been made and it appears that the LLTNPA may be trying to re-use equipment it has already bought.

Restrictions on vehicle access at Forest Drive

At present the gates to Forest Drive are locked at 4pm over the summer months which prevents people turning up on spec.  In addition Forest Drive is one way at present  and its about a 6k drive round Forest Drive to get to the site of the proposed Loch Achray campsite.   If the campsite is to be a success, both of these restrictions need to be changed.   I look forward to seeing proposals about two way access between the main road and the campsite – which would reduce carbon emissions and disturbance to other people staying along Forest Drive – and how current access restrictions could be lifted in the Planning Report when the application goes to Committee for decision.

 

Comments on the planning application

While welcoming the proposal for a campsite on Loch Achray, the planning application shows the Park has still not learned all the lessons it should have about campsite development and I have therefore objected to a number of aspects to the proposal.  This helps ensure these will be properly considered by the LLTNPA.  I would encourage others to do so.  You can make a comment online (here) – click on the comments tab.

October 26, 2017 Nick Kempe 1 comment
Looking southwest down Gleann Casaig. The track on the left preceded the hydro scheme, while that on the right marks the pipeline and, as part of the restoration work, was granted planning consent as a new footpath. Photo credit Jim Robertson (all other photos unless otherwise credited Jim Robertson).

Gleann Casaig runs from the east shore of the Glen Finglas Reservoir, north of Brig O’Turk, up to the ridge between Ben Ledi and Ben Vane in the Trossachs.  The glen forms part of the Woodland Trust’s Glen Finglas estate and part of the Great Trossachs Forest project which in 2015 was designated as Scotland’s newest and largest National Nature Reserve.  It lies wholly within the Ben More and Ben Ledi Wild Land Area, where national policy indicates there should be a presumption against development.   In December 2014,  a few months after National Policy on Wild Land Areas had been issued, the Loch Lomond and Trossachs National Park Authority issued consent for the Allt Gleann Casaig hydro scheme.

 

The development has been completed much quicker than most (November 2016) and in July 2017 Jim Robertson, from the Munro Society, went out to have a look.  Jim is helping co-ordinate the national survey of hydro schemes by Munro Society volunteers (see here – which explains the scheme and how you can get involved) and he used his visit to help trial the hydro scheme reporting form I helped the Munro Society develop.  I have been meaning to blog about what he found ever since but meantime Jim has made another visit to check a couple of things.  We have had a very good dialogue about this and while this post is based on what Jim has found, the opinions in it are solely my own.

 

Jim’s report (see here) – which is well worth reading – and photos show that most aspects of the design and restoration of this scheme have been done well.

The vegetation over the lower section of pipeline is recovering well and the line will soon only be detectable by the marker posts
The powerhouse has been clad in natural materials and the surrounds are less suburban than many schemes
The main intake is well hidden
as is largest of secondary intakes
although in my view the landscaping around the main intake is better

While some of the finishing of the development could be better (e.g the walls of the dam could have been disguised more and if you look carefully you will see yet another blue pipe, contrary to LLTNPA best practice design), I agree with Jim that generally the work on this scheme has been carried out to a high standard.   Indeed, Jim was unable to identify to spot the other intakes which were included on the approved plan.

 

Approved location plan – LLTNPA
Braemar community hydro – photo Nick Kempe

While it is possible the plan was amended post-consent – the LLTNPA is still refusing to publish documentation required by planning consents as a matter of course making it almost impossible for the public to understand what standards have been applied to each development and to report breaches of these – the plans showed intakes C-F were tiny (less than 1.5m broad) and therefore like the example left hard to see from any distance.  In landscape terms if a concerned hillwalker cannot see these micro intakes or the lines of the pipes, that is a job well done.

 

The main concern about this development, as with most of the hydro schemes in the Loch Lomond and Trossachs National Park is the track which, as the top photo shows has a significant landscape impact.

 

The track which is supposed to be a footpath

Unfinished culvert

In track construction terms, the new track up Gleann Casaig is in my better than most and Jim commented its one of the best he has seen.   The banks on the uphill side are not too steep and while sufficient vegetation was not retained to cover them, they should revegetate in time.  Jim identified some poor finishing but this should not be that difficult to address and could be done without large machinery (which has all been moved off-site).

The problem though is that in planning terms (see here for all papers) this track is supposed to be a footpath and that the LLTNPA gave consent for a new footpath into a wild land area without any proper consideration of the impact on landscape or wild land .  This “path” was not needed to provided access to the intakes because there was already a track up the Glen and the application included an extension of the existing track up to the main intake which was consented to by the LLTNPA:

 

Landscape and Visual Impact

A Landscape and Visual Impact Assessment (LVIA) was submitted in the ES.  The consultation response from NP Landscape Adviser notes that existing access tracks will be used and extended to reach the intakes and the penstock route will be fully reinstated leaving a 2m wide new footpath to provide a circular route for recreational users.  The Landscape Adviser agrees with the findings of the LVIA, that during construction there will be significant visual effect on Glen Casaig footpath and also during the operational period at The Mell near the powerhouse.  The proposed mitigation would however reduce this over time.  In terms of landscape effects the wooded upland glen is highly sensitive but no significant effects will result on this or the other LCT’s.  (Extract from Report which approved the application)

 

The LLTNPA not only decided there would be no impact on the landscape – the top photo shows that this is NOT true – it also decided there would be no impact on wild land:

 

Impact on Wildland

The proposed development is located within the SNH Ben More ‐ Ben Ledi (Area 7) area of wild land and within the LLTNPA wildness buffer area, adjacent to an area of core wildness.  An assessment in the ES states that the proposed development would not result in a reduction of the overall wild land quality.  The introduction of new infrastructure – specifically the new footpath alongside the pipeline route, the new access track spur to the main intake and the intake structures themselves – must be considered alongside the presence of the existing access track through the glen.  Appendix 5E of the ES sets out a number of mitigation measures during construction, as well as restoration and enhancement measures post construction.  Provided these are implemented the development should integrate with the landscape and not detract from the special qualities of the wild land character.

 

The logic here appears to be that because there is already one track into a wild land area, that means there is no problem adding a second track.  On this argument we would end up – and indeed are ending up – with tracks everywhere.   The LLTNPA appears to be completely unaware of the Unna Principles governing the land Percy Unna bequeathed to the National Trust for Scotland which said there should be NO new footpaths into the hills and the subsequent heart searching which led to the current position where footpath work in hill areas on NTS is seen seen as being only justifiable in response to severe erosion.   One might have hoped that our National Parks would support that position – indeed that has generally been the position in the Cairngorms – but instead the LLTNPA is consenting to new paths and tracks into Wild Land areas without any proper consultation or debate.

 

This failure to protect Wild Land was not helped by SNH’s response to the consultation which failed to make any mention of the Wild Land Area (see here) but left it to the LLTNPA to consider all the issues (despite the fact that it was SNH which drew up the excellent reports describing the special qualities of the wild land area).

 

While the LLTNPA consults the RSPB as a matter of course – in this case the RSPB drew the Park’s attention to Black Grouse leks which could have been affected by the development – they do not consult recreational organisations. Unless recreational organisations are alerted about developments which impact on Wild Land its impossible for them to keep up with what is going on and there were NO objections to this development.  In my view our National Parks should consult all the main recreational and landscape interests about all developments affecting Wild Land (e.g Ramblers, Mountaineering Scotland, Scottish Campaign for National Parks – I am a member of all three) so they can comment on developments such as this.

 

The first thing the LLTNPA might have questioned was whether there was any demand for a circular route round the Glen.

The LLTNPA could also have asked how the new circular route would fit into the network of tracks promoted by the Woodland Trust at Glen Finglas.  The current leaflet on walks in Glen Finglas shows no routes round Glen Casaig (centre of map above).   One wonders if the Developer ever talked to the Woodland Trust about this?

 

The other thing the LLTNPA could have questioned is why a path 2 metres wide was needed.  Most paths into the hills, unless severely eroded, are far narrower than this so how does a 2m wide footpath fit with generally accepted standards for footpath construction?

Track October 2017 – is this really a path?

In the Report that approved the application the  National Park access adviser is quoted as saying this:

 

“The development will bring benefits to public access through a new loop option and hopefully improved path surfacing. Final specifications for this new path need to be agreed.”

 

Whatever vision National Park staff had, its not been realised.  The truth is this track was never intended as a footpath.  Being 2m wide – in fact Jim has confirmed with me that the track is more than 2m wide in many places so does not even conform to the planning consent – it can still be used by vehicles and is, making the track totally unsuitable in walking for places.

 

There appear to be several possible explanations for why  this “path” was proposed.  The first is because it allows more direct access to the intakes than the older track up the Glen, which winds round the hill, and therefore takes more time.  The second is that it could potentially assist with other aspects of estate management (e.g future tree planting planned as part of the Great Trossachs Forest) – if that is the case that should have been made clear.  The third was it enabled the developer to save on restoration costs:  so instead of fully restoring the ground above the pipeline, by including in the application a proposal for a 2m wide footpath the developer was able to reduce the amount of turf and soil it stored and reduced the amount of land it needed to restore.  It seems to me that none of these reasons justify the retention of this track.

 

What needs to happen

While legally  its too late now for the LLTNPA to require this track to be removed, it should take enforcement action to ensure that the restoration of the land around the track is the best possible standard and the track stops looking like a track and starts looking like a footpath.  That means banning vehicles from using it.  I am sure because the land is owned by the Woodland Trust, which should be more sensitive than most landowners to adverse publicity, that this should be possible (if any reader is a member of the WT please contact them and ask them to stop vehicle use of this track).

 

What Gleann Casaig and theGlen Feshie track prior notification covered in my last post show (see here) is that our National Parks are failing to consider properly developments which intrude into Wild Land areas.  Our National Parks should be at the forefront of protecting wild land and developing best practice into how developments which impact on wild land should be treated.   Instead, their actions are undermining the whole concept of Wild Land Areas.    I believe there is an urgent need for both our National Parks to develop explicit policies to inform how they respond to developments in Wild Land area and that a key part of this should include consultation with recreation and landscape interests.   The sad fact is that the LLTNPA in particular only stands up to developers if somebody objects to an application and therefore the best way to improve how they protect Wild Land is to ensure the public are aware of all such developments through recreation and landscape organisations.

 

I would also like to see that where our National Parks do consent to new paths or tracks, they include conditions about how they are used.  These should include presumptions against motorised vehicles using new paths and also conditions forbidding vehicles from going off track.  This would prevent the “track-creep” we see in both our National Parks where new tracks, instead of stopping vehicle erosion, simply open up new areas to vehicular use and all the damage that creates.

October 22, 2017 Nick Kempe No comments exist
Photo of volunteers working by the A82 on west Loch Lomond – Photo Credit Friends of Loch Lomond and Trossachs

I spent Saturday evening, along with a few hundred others at a sold out event in the Glasgow Concert Hall, listening to George Monbiot talk about his new book “Out of the Wreckage”.   George’s message was that contrary to neo-liberal ideology, the vast majority of people are altruistic and will contribute to the wider good expecting nothing in return.   Volunteering epitomises that.  Its a great thing.

 

Why therefore did the photo above and accompanying news release from Friends of Loch Lomond and Trossachs (see below), of volunteers who are obviously enjoying themselves, make me feel uneasy?  The answer, in a nutshell, is that the volunteers are compensating for failures in basic service provision by our public authorities, in this case Transport Scotland and the Loch Lomond and Trossachs National Park Authority.

 

The voluntary work included “dozens of bags of rubbish being collected from litter strewn laybys and neighbouring areas beside the A82”.  Transport Scotland, who are supposed to maintain our trunk roads, should be ensuring this work is done.   Instead, neither they nor the LLTNPA nor Argyll and Bute Council can even agree who should provide litter bins in the A82 laybys – with the consequence that there are none – let alone who should empty them.  This makes what is a national litter problem even worse.  And then volunteers are left to clear up.

 

The other work volunteers were involved in in this case was clearing the cycle path and removing scrub to enable people to enjoy views of Loch Lomond.

Photo Credit Friends of Loch Lomond and Trossachs

Its a shocking indictment of both the National Park and Transport Scotland – both of which claim to promote cycling – that basic maintenance of the path network is being left to volunteers.   In the Spring the verges of the A82 along Loch Lomond were all cleared of scrub by professional contractors, so why not the cycle path?     While I am sure the volunteers did as good if not better job than professional contractors, had the work been done by people equipped with electric rather than hand tools, it could have been done by just one or two people.  Was this really the best use of volunteer time?   If there are not enough resources to keep cycle paths clear, Transport Scotland and the LLTNPA need to call upon the Scottish Government to provide these and challenge the neo-liberal narrative that the state can do ever more  less and that voluntary effort can be used to substitute for paid jobs.

 

The other point here is parkswatch has been reliably informed that when the A82 was re-aligned, a landscape plan was produced.  This preceded the creation of the National Park but the Loch Lomond Joint Committee which preceded it, visited Lochlomondside with the then Scottish Office Roads Chiefs and commitments were given that the landscape along the road would be maintained.  All this has  conveniently been forgotten as austerity has sunk its ugly tentacles ever deeper into public life.

 

In saying this, I imply no criticism of the Friends of Loch Lomond and the Trossachs.  They have long understood that the landscape of the National Park should underpin everything the LLTNPA does and a fundamental aspect of this is that all people should be able to enjoy the landscape.   Hence the initiative a few years ago to clear the scrub from pulpit rock – Transport Scotland missed another trick in failing to provide decent parking there when it widened the A82 by the former traffic lights.   FOLLAT have effectively had to step into the breach left by our Public Authorities.    It has been using that experience to show up the failures of our public authorities, inform its advocacy for what should be happening in the National Park and its call for the National Park to get back to basics.

Letter to Herald last week following release of Keep Scotland Beautiful Report on litter levels in Scotland

Which bring me back to Monbiot and the people who volunteer.   While volunteering is a demonstration of altruism and generally good for the mental and physical health of those involved,  and volunteering outdoors doubly so as it helps connect people to nature and involves physical activity,  the experience of volunteers is sidelined by those in power.   The clearest current example I can think of this is Food Banks, which could not operate without thousands of voluntary contributors all of whom do so because they care.  And yet these people are fundamentally disempowered when it comes to debate about how our social security system is falling apart as the rich  become ever richer.   If the volunteers had power, I doubt we would have any food banks and the volunteers could go and do something else.

 

Its the same in our National Parks.   The draft LLTNPA National Park Partnership Plan makes noises about the importance and success of volunteering in the National Park, but nothing about how volunteers are being used to compensate for cuts:

 

“The number of people volunteering in the National Park has grown significantly and in our annual
volunteer survey 80% of volunteers indicated that volunteering benefited their health and wellbeing.”

 

More importantly, there is no acknowledgement that volunteers in the National Park might have something important to say about how the LLTNPA and other public authorities operate at present.  These are after all people who do not just enjoy being out in the National Park, they contribute their own labour on  a voluntary basis to protecting or improving the landscape.  In short, they care and should be key stakeholders of the National Park.

 

I would like to see the LLTNPA explicitly acknowledge that they should not be using volunteers to compensate for or hide failures in service provision.  Instead, I would like to see them engage with volunteers about how they could be empowered, not just through representative organisations but directly.  Part of this would involve engaging volunteers about their existing experience of  how basic issues, such as litter, could be addressed and using this to inform the “back to basic agenda” for service provision.  It should also though involve engagement about where voluntary work is best directed in future.   There are lots of great things for volunteers to do but compensation for cuts should not be one of them.

 

For anyone interested in the current role of volunteering in our National Parks and its future potential, the Scottish Campaign for National Parks (I am a member of its Committee) produced a report on volunteering and National Parks in 2015 (see here).   In the Report it was estimated that the potential value of volunteering if new National Parks were created was £500k a year.   While National Parks offer great opportunities for volunteering, I think the figure demonstrates that volunteering will never compensate for the cuts in basic services that have been taking place ever since the crash in 2008.

The Friends of Loch Lomond and Trossachs New Release from the beginning of October

Volunteers help to open up views of Loch Lomond as part of special Make a Difference Day event

 

Volunteers taking part in the latest ‘Make a Difference Day’, organised by Friends of Loch Lomond and The Trossachs, the independent and conservation and heritage charity for the National Park, helped to remove trees and shrubs to open up scenic views of Loch Lomond and Ben Lomond along a stretch of the busy A82 tourist route.

 

A group of 30 volunteers travelled to Inverbeg, just north of Luss, to remove several hundred metres of overgrown plants and shrubs from the side of the road, giving motorists, cyclists and walkers clear views of Loch Lomond. Also, part of the day was a litter clearance exercise, which resulted in dozens of bags of rubbish being collected from litter strewn laybys and neighbouring areas beside the A82. This was part of the Friends’ ‘Windows on the Loch’ project, which aims to improve views of Loch Lomond along the busy A82 tourist route.

 

The volunteers came from a variety of walks of life including Luss Estates, the Department for International Development and Scottish Water as well as motivated individuals who volunteer regularly with the Friends and Loch Lomond and The Trossachs National Park Authority. The nearby Inn on Loch Lomond Hotel also provided shelter and complimentary lunch for the volunteers.

 

The event was the latest Make a Difference Day to be led by the Friends, and builds on the efforts made by the conservation and heritage charity in recent years with funding support from the National Park Authority to remove stretches of the Loch Lomond ‘tree tunnel’ which for years effectively meant there were no views of Loch Lomond along the entire twenty mile stretch of the A82 between Duck Bay, near Balloch and Tarbet.

 

In recent years other Make a Difference Days have involved litter and rhododendron clearance and path improvements works at different locations around the National Park with volunteers and corporate bodies helping to protect the special landscapes of the National Park.

 

Friends Vice-Chairman John Urquhart, who was among the volunteers who took part on the day, said: “Anybody passing this area of Loch Lomond now has a much better view of its natural beauty, and it is all down to the efforts of the volunteers, who turned out in force to ensure that this event was a great success. We even noticed passing motorists stopping in laybys to have pictures taken against the new backdrop!

 

“We were delighted with the response we had to Make a Difference Day, especially at a time of year when the weather can be so unpredictable. Fortunately, we had the elements on our side this time around, and with the hard work of so many people to open up views of the loch and Ben Lomond has made a real difference.”

 

Niall Colquhoun, owner of the Inn on Loch Lomond, added: “We were very pleased to support the Friends and the volunteers on the day, helping the hard workers to enjoy a relaxed lunch in between their spells of unstinting efforts. The improved views of Loch Lomond from the A82 has already been positively commented on by some of our visitors and I am delighted with what has been achieved by the volunteers.”

October 21, 2017 Nick Kempe 2 comments
The Allt a’Chuillinn hydro track from slopes of Beinn Chabhair, Eas Eonan hydro track right background – photo credit Tom Prentice Autumn 2017

Last Saturday, sitting in a hut in the Snowdonia National Park, I came across a Guardian travel supplement “Adventures in Wild Britain” which featured ten places to experience Britain’s most stunning wildlife.  One of the places was Glen Falloch at the head of Loch Lomond (see here).

 

Regular readers and anyone who hillwalks there, will know that the landscape in Glen Falloch has been trashed by what were supposed to be temporary hydro construction tracks being granted consent by the Loch Lomond and Trossachs National Park Authority to remain on a permanent basis.     Of all the new Glen Falloch hydro tracks, the one up the Allt a’ Chuillinn is the least obtrusive in landscape terms from the bottom of the Glen and has been used by the National Park to demonstrate what a good job they are doing.

Track up to Allt a Chuillinn intakes June 2016

The quality of the restoration work on the Allt a’ Chuillinn track is indeed better than most of the other Glen Falloch tracks to date but the top photo shows the landscape impact.  A harsh artificial line, which is far more prominent than the Allt a Chuillinn itself, which penetrates up into the hills right to the edge of a core wild land area.  The LLTNPA officers failed to take this into account when they gave consent under delegated powers to the Glen Falloch Estate to retain this and other tracks.

 

Glen Falloch runs between the two Wild Land Areas that have been agreed for the Loch Lomond and Trossachs National Park.   Any development in Glen Falloch has obvious implications for wild land areas 6 and 7 but instead of thinking about how these wild land areas might be enhanced,  the LLTNPA has allowed tentacles of development to penetrate up all the side glens.  Wild Land areas 6 and 7 feel considerably less wild now than they did when they were created three years ago.

 

You would not know any of this from reading the Guardian article.  There is not a mention of the new hydro tracks although it would have been almost impossible for the journalist and photographer to go where they did without seeing some of these tracks.  Anyone looking at the photos in the article or reading the purple prose – “We walk for hours and miles for glimpses of deer, but what glimpses” – who didn’t know the area would be left with the impression that Glen Falloch estate is pristine.

 

The Guardian makes no mention either of the impact of the 700 deer on the estate, whether on the areas of ancient woodland at the bottom of the glen or on the mountain sites of special scientific interest or whether the estate is managing this effectively.  The article refers to “the stalker” – I have met him, a nice guy who is very relaxed about access – but it appears nothing has changed since 2013 when in their submission to the Land Reform Review Group (see here) the estate reported it employed one full-time member of staff.   Even with occasional part-time assistance one stalker could not possibly “manage” 700 deer effectively.  The Landowners however use their staff – who undoubtably work in tough conditions – to sell a message which journalists and politicians find very hard to question.

 

The promulgation of landowning ideology has always swithered between claiming how many jobs are sustained through their goodwill and current management practices and describing these jobs as precarious (with the implication that any land reform would lead to a total collapse in rural employment).  Glen Falloch however now has lots of money because its hydro schemes are operational and generating significant profits.  It will be interesting to see if any of this money is used to promote management of the estate in accordance with National Park objectives or even, dare I say it, to promote rewilding in the two wild land areas.  One suspects, however, that just like on the grouse moors very little of the money earned by the estate will be re-invested and the tracks, by making it quicker for the stalkers (or gamekeeper) to travel round the estate,  will simply enable the estate to keep the number of people they employ to a minimum.

 

The Guardian article illustrates the extent of the challenge facing proponents of conservation and land reform.   Landowning interests are extremely good at manufacturing portrayals of Highlands life for public consumption which are based on images of unspoilt landscape and wildness.  These, as in Glen Falloch, conceal the truth as to how the land is actually being managed.  Our National Parks should be challenging all of this.   My suspicion however is that in this case the LLTNPA’s large marketing team, which is mentioned in the second sentence, set the whole thing up.   Unfortunately, the LLTNPA in Glen Falloch is part of the problem, they have been failing to protect the landscape and wild land while doing nothing to promote local employment or to use the hydro schemes as an opportunity to invest in more sustainable forms of land-use.  They need to be pressurised to take a different approach in their next 5 year National Park Partnership Plan.

October 20, 2017 Nick Kempe No comments exist
The upper part of track in the photo appears (from the site plans) to be new, the lower part of the track to have been widened

Following my post about how the planning documentation for the Ledard farm campsite has been altered  (see here), I have been trying to obtain final confirmation from the Loch Lomond and Trossachs National Park Authority of the status of the new track being used to construct the Hydro Scheme (see here).  On 28th September a member of staff  told me:

 

“I can confirm that the temporary track which has been constructed does not have planning permission.  The route of the track follows the route of the approved penstock and has been subject to monitoring as part of the approved hydro scheme ref 2013/0267/DET.  The agent was advised that planning permission was required for the track and this has led to the submission of the planning application which is currently being considered.”

 

However the day before, when I visited the site with a friend, it was claimed (see below) that planning permission for a temporary track had been consented by means of a Non-Material Variation to the original application.  I therefore asked the LLTNPA three weeks ago for a final clarification but have not had a response.   I therefore need to qualify what I say here but it appears that Fergus Wood, who until every recently was an LLTNPA Board Member and Member of the Planning Committee, has allowed a track to be constructed without planning permission on his land.    This post will develop the argument that unless the LLTNPA refuses the retrospective planning application that has been submitted for this track (see here), the credibility of the entire planning system in the National Park will be in shreds, and that to enforce the planning conditions will benefit the local economy.

Powerhouse is wooden building right of centre

The first section of track above Ledard Farm was already in existence but has been broadened and the creation of a pipeline through the trees has made the section of new track above more visible (see top photo).

The existing track appears to have ended just above the trees and section in the bottom 2/3 of the photo is new.  The buried pipeline is to the right (the pipeline is not the issue).
The track without planning permission is marked in red as a “working corridor”.

A document uploaded to the planning portal in October after our visit described this as a “working corridor” (see left).   The photo above shows that this is not true.  A track has been constructed.  At the time of our visit there had been recent work both to landscape it (the mound of earth on the left) and to created a drainage ditch.

This section of track is not only highly visible it is also quite steep and appears to exceed the maximum angle recommended by SNH in the Good Practice Guidance on Hill Tracks – 14 degrees.   Another reason, no doubt, why staff would have originally advised that there should be no access track constructed on the east side of the Ledard burn.

 

 

Above the steep section the track turns west and takes a more or less horizontal line across the open hillside.  It was the visibility of this section of track from afar which informed the advice staff gave to Fergus Wood, prior to the original application, that the access track should be on the far side of the Ledard burn (through the trees beyond the digger).  The reasoning behind this advice was repeated in the report to the LLTNPA Planning Committee which approved the original application.  Fergus Wood, who is still the landowner,  has nevertheless allowed the developers to construct a new access track on this section of ground.   If Board Members can ignore planning conditions and requirements, I am afraid the message is so can everyone else.  This is why the LLTNPA should have taken enforcement action as soon as they heard about this and should now refuse the new planning application.

Its not just that a track has been created, a large section of hillside above has been altered – another concern in the original committee report – and various soil types mixed.  The LLTNPA had agreed to some work here – necessary to construct the pipeline – but a much wider section of land than that set out in the original working corridor appears to have been affected.    The LLTNPA should be requiring a full report on the works that have been carried out, including their ecological impact.   The planning application to retain the track says this section of hillside will be planted with trees.

Another photo showing works appear to have been carried out outwith the working corridor approved by the National Park Authority.   We wondered if turf had been “robbed” from here in order to restore the land above the pipeline?  (The work on the ground in this photo is unlikely to have any significant landscape or ecological impact but the point is its being carried out on a Board Member’s land apparently outwith planning consents).

The intake to the hydro scheme is well hidden and will have almost no impact in landscape terms – the creation of a hydro scheme on Ledard Farm is not the issue.  The question for the LLTNPA though is how much of the excavation of the hillside on the right was agreed as part of the pipeline work and how much due to the creation of the construction track (e.g as a “borrow pit” from which to obtain materials to created the track)?

Incidentally, its worth noting how the muddy water in the burn below the intake, a contrast to the water above (see left) which was totally clear.   This is why detailed plans about how sediment will be prevented from entering river systems are required as part of planning consents.  I don’t have the expertise to know whether the amount of sediment entering the river in this case is within agreed limits or not but SEPA have been notified.

 

Could the track have been granted planning permission?

On returning down the Ben Venue track we were met by Fergus Wood and a group of people working on the site (who appear to included staff from Vento Ludens, Baby Hydro and the contractors MAM).  It quickly became apparent that most of the workforce, who were friendly, did not really know what was going on and the main discussion was between my friend, myself, Fergus Wood and another person who did not introduce himself but appeared to represent Vento Ludens. He confirmed that Vento Ludens had bought the scheme from Fergus Wood, something I had not been certain of up till then and had obviously read the articles on parkswatch because he claimed a permanent access track was needed to allow future maintenance to the site.

 

The only reason I can repeat what was said next is that I had taken the precaution of switching my voice recorder on before starting our walk round the site and can produce this in Court if the man who appeared to speak for Vento Ludens wanted to challenge the veracity of what I have to say next (we were potentially two witnesses against six).   This person claimed to me that a temporary construction track (as in the photos above) had been agreed by the LLTNPA by means of a Non-Material Variation (NMV) to the original planning application.  I replied that I had looked carefully at the planning portal and as far as I could recall the NMVs that appeared there did not include a temporary construction track.  However, accepting I could have missed something or the Park might have failed to publish the consent, I requested that he could send me the NMV consent and I would be happy to publish with a correction on parkswatch.  When he repeated the claim, another guy, who wanted to be helpful, asked for my email – I said it was on parkswatch – so he could send the NMV to me.  He obviously believed an NMV had been submitted and granted consent.    I have never received it and, having checked the planning portal again there is no such consent there.  This is why I have also asked the LLTNPA to confirm that when they say the access track never had planning permission, that includes any temporary construction track agreed by means of a NMV.

 

Once I have final confirmation of the planning position, I will comment further about the implications of this case for the Board Members Code of Conduct.  Meantime, I think there are some lessons here for the planning system.

Implications for the planning system

What struck me from the discussion on Ledard Farm is the workforce appear to have very little awareness of what has and what has not been agreed through the planning system.  The guy who said he would send me the NMV obviously believed such a variation had been agreed but it appears he had never seen the document.  It appears he trusted that someone had made the application.  This made me realise that people working for contractors on the ground on this or other hydro schemes often may have little idea about whether the necessary planning consents are in place, let alone what they require.   This is not their fault, they just do as they are told but this may help to explain why planning conditions are often not met, whether at Ledard, other hydro schemes, the Beauly Denny restoration etc.

 

What then happens is driven by money.  If developers and owners of hydro schemes also know the National Park is reluctant to take enforcement action, the temptation to take shortcuts to increase profit levels increases.        The man who claimed an NMV had been obtained for a temporary construction track at Ledard, also claimed that that “due diligence” had been carried out before the purchase of the hydro scheme.   Now, one might have thought, if an access track is essential for maintenance purposes as he claimed, due diligence would have included checks on whether consents were in place for access to the site both for construction and maintainance purposes.  Perhaps checks were undertaken, but if so someone appears to have concluded that the absence of consents for an access track would not impact on the value of the hydro scheme.  What does this tell you about the respect given to the planning system in the National Park?

 

The basic problem is that while many of the conditions the LLTNPA has applied to planning consents for hydro schemes are excellent, they are not enforced.  As a consequence they become meaningless as soon as a developer puts money before the natural environment or their own interests before the planning system.  While part of the solution to this is enforcement – which is why it is so essential the LLTNPA is seen to act robustly in this case involving (now former) Board Member Fergus Wood – the other part of the solution is to have an informed workforce.   Where developments are carried out according to planning requirements and shortcuts are not taken, that should create MORE work.  More work would give more pay to the people working on these schemes and put more money back into the local economy.   Its in the interests of the workforce therefore to understand exactly what planning conditions are in place and to empower them to speak out when these are broken.   The LLTNPA could be encouraging this.  It could ask all developers to confirm that every member of the workforce has seen the relevant plans that have been approved and could set up a confidential reporting line for use where they have been broken.   That would also help other people report potential breaches of planning permission (its hard to clype on your neighbours).

 

What’s good for the environment is good for local jobs

Vento Ludens (“Playing with the Wind”) – the company appear to have started out in windfarms before branching out into hydro – is a Company with their address registered in Scotland at South Charlotte St in Edinburgh.  It is ultimately owned by a company registered in Germany which is controlled by H.Walz (who is also Director of Vento Ludens).  Its latest accounts vento ludens accounts, for the year ending December 2016, show shareholders funds of £3,938,194.

 

This is important because developers in general are always complaining about the unnecessary costs imposed by the planning system.  Renewable energy developments, however, are are highly profitable, hence the investment from Germany in this case but also why many of our hydro schemes are now ultimately owned by the City of London or other tax havens.   Vento Ludens’ accounts show they have plenty of money that could be used to pay now for the re-instatement of the access track, which would provide more employment to the people working on the scheme.  They are also likely, once the scheme becomes operational, to make enough money to pay for the Ledard hydro intake to be maintained without an access track.  That would also help local employment (the time taken to walk up to the hydro instead of driving there to clear the screens of debris).  If  larger scale replacements – once every ten years? – could not be brought in by vehicle off-road, helicopters could be sued.   The LLTNPA therefore have no reason to fear that by enforcing planning conditions that would somehow harm the local economy.

 

The lesson from this I would suggest is that the best way the Park could help the local economy, is by ensuring the highest standards possible are applied to hydro schemes.  This would help reduce the amount of money taken out of the local area, Scotland and indeed the UK.

 

Even better would be if it could promote more community owned Hydro Schemes.  One wonders if Fergus Wood ever thought about trying to sell the Ledard hydro scheme to the local community in Strathard rather than to a company controlled from abroad and what sort of system might have helped him do this.

 

The Ledard Hydro track planning application is still open for comment and you can do so here

Addendum

At 13.20 today, 3 hours after this post appeared, I received an email from the LLTNPA which stated “that the change to a new track has not been considered as a Non-Material Variation”.  In other words a track that has been constructed on land owned by Fergus Wood when he was a Board Member and a member of the Park Planning Committee is unlawful.  This is a scandal which needs full public investigation.    I have removed the ? after “unlawful” in the original title of this piece and many of the other qualifications to what I wrote no longer apply.

October 18, 2017 Nick Kempe 1 comment
Overused camping area by Loch Achray. The National Park claimed the camping byelaws would reduce damage to vegetation by enabling camping to be controlled. The opposite has happened – by concentrating campers into a few permit areas this type of (minor) damage has almost certainly increased.

Following my post (see here) on why people should be sceptical about the Loch Lomond and Trossachs National Park Authority Board paper which claimed the camping permit system had been successful, I have been passed information from two readers about complaints submitted to the LLTNPA.  Both concern Forest Drive and accord with what I saw when I visited there with Ross MacBeath at the end of September.  This is that the camping byelaws have made things worse, not better, for the great majority of responsible campers.

Complaint 1

The complainant has agreed I can publish the information on parkswatch but has asked I summarise rather than quote from their complaint.

While the person did not tell me what area they had booked, the description fits with what we saw in Zone I.

The person had booked to stay in a specific permit area by Loch Drunkie because they knew the area well, having used it in the past to launch their canoe and a canoed and had mountain biked around Forest Drive.  While on previous visits they had come across campers, they had never noticed any significant camping related problems. However, on their stay they found the area was covered by fire scars, litter, human waste and toilet paper, far worse than they had previously experienced and reported this to the Park.  They made a point of saying they would no longer choose to launch their canoe from the area because of the high risk of stepping in excrement and also that while they appreciated that people when they book are being advised about good practice (as set out in the permit terms and conditions) this is clearly not working.  They feared for what the sites will look like in future.

 

The Park used the existence of fire scars to justify introducing camping byelaws.  They clearly haven’t worked.  The metal barbecue (right photo) is good idea – perhaps it was brought in after the tree in the centre was burned?  Fundamentally though, forcing people who want to be able to enjoy a fire to camp under trees is asking for trouble.  People used to be able to camp on loch shores away from trees and the majority did so.  The byelaws are creating, not solving, problems.

All around the areas of strimmed and flattened vegetation in Zone I there were little paths into the bracken.  These invariably ended at heaps of crap and toilet paper.    This is not all campers fault.  The ground under the trees is covered with lots of roots and digging a hole deep enough to bury crap properly would not be that easy.  It should have been quite predictable that if you provide very few areas which are suitable for camping – and the vast majority of ground in each permit area at Forest Drive is totally unfit for camping ((see here for example) – that impacts would be concentrated.  Add to that a failure to provide toilet facilities and the LLTNPA have created a major problem.  Simon Jones, the Park’s Director of Conservation, acknowledged the problem at the last Board Meeting when he said that human waste was a major problem in certain places.  What he didn’t explain was the role the byelaws and the LLTNPA’s failure to provide facilities in creating this.

The irony is there is an FCS toilet block on Forest Drive.  The problem is its not in or near any camping permit area.  Despite there being flat areas in the trees near the toilet block which would be good for tents, camping is banned here – you would be committing a criminal offence to put a tent up within reasonable walking distance of the toilets!     The reason, it appears, is that neither FCS nor the LLTNPA want campers and day visitors to mix – talk about social apartheid – although recently a single campervan permit place was added to the carpark.  Lucky campervanner!   Just one hitch, if they have their own toilet,  there is no chemical disposal point.

 

If the LLTNPA and FCS want to concentrate people in certain places, as is happening at present, they should have a duty to provide facilities such as toilets.   Facilities should come first.  Towards the end of the summer the LLTNPA and FCS deliberately started to increase the number of campervan “permit places” on Forest Drive  and encouraging visits from campervanners but without any plans to  to provide chemical disposal points.   The LLTNPA has submitted a planning application  for a new campsite at Loch Achray and the toilets there will help but I can see nothing in the toilet block plans to indicate a chemical disposal point is included  (see here).

 

Complaint 2

 

I received this from someone involved in outdoor education and it concerned a DofE group.  The Leaders had apparently obtained permits for the group to camp at Loch Drunkie, with staff accessing the site by vehicle.    On arriving at the Forest Drive gate (which is locked after 4pm) one leader was trying to find the code for the gate on his phone when van full of people appeared wanting to get through as well.  They shouted out the code – “Park have never changed it, so we came once officially, then been coming whenever there’s good weather for a party.  Our friends are on their way”.

 

My informant went on:  “Needless to say the party went on into the early hours, despite repeated requests to consider the youngsters.  Tents & people all over the place.  The youngsters were moved on at first light to get them away.  Throughout the night, leaders phoned Park staff on the contact forms – ansaphone saying office closed till next day; police – no response, etc.  Leaders have sent in “feedback” to Park including videos and photos but heard nothing back.  The feedback system says: thanks for your feedback and Park will review things at end of the season.”

 

“This was the first time the leader used this particular site and never again…  He also said that at other private campsites there are stories of people, especially families arriving very late asking for a plot as they had abandoned their “official Park site plot” due to similar activities…

 

So a system designed to improve access to the “park” has instead succeeded in enabling free use for party / rave sites to the detriment of people’s peaceful enjoyment.”

 

I could not have put it better.  The problem always was and still is policing.  The byelaws have solved nothing.  What the LLTNPA need to do is ditch the whole permit system (except for where facilities are provided where it could be used as a campsite booking system) and concentrate on working with the police to develop a rapid response where problems occur.  This would benefit both local people – rural policing has been slashed – and responsible campers.

 

The future of Forest Drive as a camping destination

An attempt to create a camping place in the heather in Zone C

After promising Scottish Ministers 300 new camping places in the camping management zones and because they wanted to stop all camping along many loch shores, the LLTNPA persuaded FCS to provide a large number of camping places at Forest Drive.  This was to meet targets.   Most were totally unsuitable – as Ross MacBeath has described on several occasions – and a number of these zones have been removed from the Park booking system.  Other unsuitable areas remain.

Marker post for Zone M, on the edge of Forest Drive.

The Rangers to their credit, just like at Loch Chon, have been doing a good job helping people move to more suitable areas of which there are about half a dozen on Forest Drive.   Unfortunately, due to the ban on camping elsewhere in the National Park this is concentrating use.

Some basic management measures like blocking off vehicle access to good camping areas and provision of adjacent parking would really help reduce impacts

The lack of basic infrastructure has then made the impact of this increase in use far worse than it need have been.

 

The fundamental problem at Forest Drive is that the LLTNPA has wanted it to provide over 60 camping places when in reality it can probably support half that number on a regular basis (excluding the new proposed campsite at Loch Achray).  Managers have forced staff to “create” camping places in wooded and boggy zones where no-one in their right mind would want to camp.   The sensible course of action now would be to abandon promoting  the rest of these unsuitable places and allow the few people who might want to go there to do so under access rights.

The only suitable place for camping in Zone C is very boggy and only likely ever to be used by people fishing

The LLTNPA  should then focus on creating facilities to support camping at the places which are good for pitching tents which are almost all down on the lochshores on flat turfy areas.   There are only half a dozen such places and it would be easy, for example, for the LLTNPA to install portaloos (as they do in English National Parks) in all these areas for next year.   That and a few rubbish disposal points would justify the Park collecting a small charge from people camping here.

New campervan places on Forest Drive
Who would want to stay here overnight?

The LLTNPA is now promoting Forest Drive as a destination for campervans.  I think this results from criticisms of the failure of the LLTNPA to provide for campervans and the impossibility of enforcing the byelaws against campervanners because of people’s right to sleep overnight in vehicles on roads.   What’s happening at Forest Drive – a large increase in the number of campervan places – can be seen as a desperate attempt to provide evidence to the Government that byelaws are still needed in relation to campervans.  Byelaws aren’t needed and the attempt to create new campervan permit places without any consideration of whether they might be good places to stay is just repeating past mistakes.

Zone E – its far better for campervans than for tents

 

However, the nature of Forest Drive, means that in some places it provides a very good campervan experience as shown by the photo above.  Hard flat ground which is poor for tents is just what campervans need.  Add in the view and  Zone E, and a few other places on Forest Drive, are potentially great places to stop off ovenight.

 

What the LLTNPA and FCS need to do is engage with campervan interests and work out what are the good places to stay at Forest Drive.  I believe they should then only sell permits for these good areas and if campervanners want to stop off in other grotty forest laybys for free they should just be allowed to do so.   If the LLTNPA/FCS added a chemical disposal point and drinking water provision at the existing toilet block or at the new campsite on the way out of Forest Drive small charges for staying in the campervan permit areas would be justified

 

The way forward at Forest Drive

While what has been happening at Forest Drive epitomises what is wrong with the camping byelaws and the Park’s failure to provide proper infrastructure, it does also suggest alternative solutions which would help people to enjoy staying out overnight in the countryside, whether in a tent or campervan.  Its about time the LLTNPA and FCS engaged properly with recreational interests to develop an alternative plan for Forest Drive instead of their managers trying to drive through top down solutions which don’t work in pursuit of meaningless targets.

October 11, 2017 Nick Kempe 2 comments
Extract from Glasgow Airport magazine, High Flyer, September 2017. Often the LLTNPA appears to be more a tourist agency – we have Visit Scotland to do that – than National Park, with a marketing team to match. Yes, Loch Lomond is very close to Glasgow airport , but can you get there easily by public transport? Yes, the National Park is great for camping – but why not mention the camping ban then?

Looking at the papers for the Cairngorms National Park Board meeting which took place last Friday (see here), I was struck by the significant differences between the way it and the Loch Lomond and Trossachs National Park Authority operate.

 

While many (mostly retiring?) members of the Loch Lomond and Trossachs National Park Authority have lost sight of what they might contribute to the National Park (see here),  Cairngorms National Park Authority Board Members are involved in a large number of initiatives.  Here is an extract on current CNPA involvement in Groups (27 in all):

 

While attending meetings and events of course does not necessarily make Board Members effective – and the CNPA has in my view always struggled to engage with recreational interests – this wide network of groups does influence how the Cairngorms National Park operates.  The CNPA has a raft of strategies and plans compared to the the LLTNPA and there are direct links between these groups, the existence of strategies and the National Park Partnership Plan.

 

For example,  the Cairngorms Economic Forum (one of the Group above) links to the Cairngorms Economic Strategy 2015-18 and the fact that the Cairngorms National Park Partnership Plan considers economic issues, include low pay in the National Park.  While they are far from developing an alternative economic strategy, based on sustainable development and use (should that be re-use?) of natural resources, they do have a framework for considering the issues.    There is no equivalent in the LLTNPA.  As a consequence their draft National Park Partnership plan is much weaker on these issues and is little more than a set of aspirations (which its very hard for anyone to disagree with) without content.

 

While some networking does go on on the LLTNPA – you can see that locally elected members and councillors do attend community council meetings from the minutes of those meetings – what their Board Members are involved in is very difficult to ascertain as there is no public network of groups as with the CNPA.   Indeed groups which used to exist, like the east Loch Lomond and 5 Lochs Visitor Management Groups appear effectively to have been shut down.  Moreover, the public have no easy way to contact LLTNPA members, whereas go to the section of the CNPA website on Board Members, click on their name and there is an email.  So, if you are interested in social inclusion or Broadband in the Cairngorms National Park, you can work out who best to speak to and contact them.  I would suggest that is worth a lot.

 

The differences go further.  The CNPA has a Planning Committee, on which all Board Members sit, and an Audit and Risk Committee but it also has a Finance and Delivery and Staffing and Delivery Committees.  ALL meet in public.  Contrast this with what the LLTNPA say on their website:

 

“By law, we have two committees that are required to meet:

  • Our Planning & Access Committee meets monthly to consider certain planning applications, enforcement actions, policy papers, legal agreements and access matters.
  • And our Audit Committee meets up to four times a year to support the Accountable Officer (our CEO) in their responsibilities for issues of risk, control and governance and associated assurance through a process of constructive challenge.”

 

The LLTNPA operate with the minimum number of Committees possible,  just as they publish the minimum amount of information they are legally obliged to (two years).

 

The LLTNPA model has, I believe, been based on neo-liberal corporate ideology that the best way to run organisations is by slimline management, which in effect means small groups of people endorsing decisions taken by the leader.  The few know best and Park structures have been designed to prevent anything getting in the way of centralised decision-making.   No wonder their Board Members no longer saw a role for themselves and proposed their own abolition.

 

Thankfully there are signs of change at the LLTNPA.  Their new convener appears to be a genuine team player, more like the captain than the manager, and the Chair of the Park’s Delivery Group, Colin Bayes, has been trying to make more public what that group does.   The logical next step is to create a finance and delivery committee which, like the CNPA, meets in public.  Having a staffing committee also says something about the preparedness of an organisation to be open – for staff should be the most important resource our National Parks have.

 

The two National Park Boards have arranged to meet in November – its been an action point for the LLTNPA for over two years – and I think that provides an ideal opportunity for LLTNPA members to rediscover a role for themselves.

 

Structures are only the start

Extract from report on last CNPA National Park Partnership Plan progress

Networking, listening, being more open is however only a start. Having discovered a role for themselves, Board Members need to help ensure our National Parks deliver far more than they do at present and where things are not working to help change direction and come up with new solutions.  The above extract illustrates the challenges facing the CNPA.  The Wildlife Estates Initiative was dominated by landowners and hunting interests and was supposed to show how the National Park would work in partnership with estates to promote wildlife in the National Park (and reduce wildlife persecution).  What the extract above shows is that even this weak initiative has failed and it provides strong evidence that the voluntary measures to promote wildlife in the new National Park Partnership Plan won’t work either.    The landed estates basically don’t care how they appear to the public.   The challenge for CNPA Board Members is to start to assert the right of the National Park to take action on these issues where voluntary measures have failed.

 

Ironically, the LLTNPA did take firm action in one area – the camping byelaws –  though I think it is significant that this is the ONLY area of work where it has been prepared to stick its neck out.  The problem has been that the LLTNPA focussed on the wrong issue – camping management rather than visitor management – and has bulldozed through the wrong solution with disastrous consequences.   I am in favour of our National Park Boards taking a stronger line but, just like when landowners fail to co-operate, they also need to recognise when they have got it wrong.  Its these type of issues where public debate should be promoted by our National Park Boards,  rather than the manipulated Your Park consultation on the byelaws or the relative silence of the CNPA on fundamental issues of land-use such as whether grouse moor management is compatible with the aims of the National Park.   Neither of our National Parks have been very good at leading such debates to date.

October 9, 2017 Nick Kempe 4 comments
Digger 6th October 2017 just southwest of col between Geal Charn and A’Mharconaich, West Drumochter Hills. Note the hillwalkers in the foreground.  GR 592766 approx.  The track curls round into Fraoch Choire north east of Beinn Udlamain.

If you see a digger in the hills……………report it!

On Friday, I went for a run up Geal Charn and went just beyond the summit because the views then open up down Loch Ericht.  There was a digger a little way to the south on what used to be a stalkers path into the Fraoch Choire.  Over the last ten years or so new bulldozed tracks have proliferated on both sides of the Drumochter pass and had a massive impact on the scenery.

Track behind north Drumochter Lodge
Tracks leading into west Drumochter hills from Balsporran cottages. The track on the left, up the Allt Choire Fhar leads onto the col in the top photo with the digger.
Screenshot from the very helpful Cairngorms National Park estate boundaries map

Most of land on the north side of the Drumochter pass is part of the North Drumochter or Ralia Estate as it is sometimes known.   As far as I can see from the National Park and Highland Council planning portals only two of the North Drumochter tracks has had planning permission, a  short section south of the telephone mast in the Glen back in 2012 and a section of the Beauly Denny construction track running north from Drumochter Lodge.  The tracks on the open hillside appear not to have been subject to planning at all.

 

The problem has been that under the old planning rules agricultural and forestry tracks did not need planning permission except in National Scenic Areas.  Estates used the presence of a few sheep, as in the first photo above, to claim these were agricultural tracks when they have been primarily used for grouse moor management.       However, after coming under considerable pressure from environmental and recreational NGOs, in December 2014 the Scottish Government introduced the Prior Notification system where landowners are supposed to notify planning authorities of the creation of any new track and any works to existing tracks which effectively extend them (e.g broadening the width of the track).

 

Many estates, however, are not observing the new rules and its a considerable challenge for Planning Authorities to monitor what is going on on the ground.  (Its not possible for planning authorities to take enforcement action against works that are more than three years old).   The LINK hilltrack campaign has had considerable success encouraging hillwalkers to report new tracks but one of the challenges for both LINK and planning authorities is to determine when the track work was done .   The presence of diggers however provide evidence that work is being done.

 

What struck me on Geal Charn, a popular Munro, is just how many hillwalkers must pass track construction works on the hill  and assume that all is legitimate.    If you care about the landscape, report it!.  A good place to start is the Link Hill tracks group (see here).

 

Has the work on this track been granted planning permission or been properly notified?

You can also report direct to the Planning Authority.   Several planning authorities, including the Cairngorms National Park, are now placing all Prior Notifications on their planning portals and its quite easy to check if work has had planning permission if you know the council or National Park boundary.  In this case I went to Cairngorms National Park Authority planning applications and did a map search:

The OS Map is out of date and does not show recent tracks but the track in the top photo follows the line of an old stalkers path into the Fraoch Choire.

When you zoom in one level more than this you get to maps which depict all planning applications in red.   The situation in this case is a bit complicated since the yellow marks line marks the Cairngorms National Park boundary and the digger in the photo may have just been outwith the CNPA boundary (although of course it could have done works on either side of the boundary).  I therefore also checked the HIghland Council planning portal but as far as I can see no full planning application or Prior Notification has been submitted to either Planning Authority:

HIghland Council planning portal snapshot showing line of old footpath into Fraoch Choire. If the track had planning permission or been notified to the Planning Portal there should have been a red line by the line of the footpath.

Now of course its possible that North Drumochter Estate has notified Highland Council of the work and it has not appeared on the their planning portal or that works are of a very minor nature (routine maintenance of existing tracks) and therefore don’t need to be notified.   However, what the planning portals shows is that there is NO obvious explanation for the presence of the digger or that works have been agreed here.   I believe therefore there is every reason to report it.  So, I will!

 

If you find it difficult to access or the Planning Authorities on-line portals don’t let that put you off.  (The IDOX planning portal still does not allow you to see planning applications on maps if you use firefox as your web browser although I reported this glitch to the Scottish Government early this year)    You can email photos to the planning authority and ask if they know about this work (CNPA planning 01479 873535or planning@cairngorms.co.uk) and the LINK Hill tracks campaign (see here again) will always welcome information.

 

Hill tracks and protected areas

Where it can be hard for the planning authority to take enforcement action under planning law is if works are of a minor nature.   This however contributes to a new problem, track creep.   Tracks are gradually widened or extended or ATV tracks receive some maintenance work which over time then add up to a new track.    The photos I have – and unfortunately I did not have time to take a close look which would have been better – suggest this may be happening in this case.

 

There are other mechanisms however by which we could prevent this happening.   In protected nature sites many operations require consent from SNH and much of our National Parks are supposed to be protected in this way.  SNH has a very useful website, called sitelink which enables you to do map based searches of whether a site is protected (and it works with firefox!):

The big hatched block shows the boundary of the Drumochter Hills SSSI, Special Area of Conservation and Special Protection Area (birds).

It appear that the digger, while it might have been just outwith the CNPA boundary was within the Drumochter Hills SSSI, SAC and SPA boundary.   Within that SSSI all work on vegetation, ditches, tracks and off road use of vehicles requires permission from SNH.   So, I will report the digger to  SNH too, although in an ideal world one would hope that our National Parks at least would automatically pass on this type of information to SNH!  Indeed, I believe one of the primary ways that the CNPA could prevent the further extension of hills tracks – a policy commitment set out in its new National Park Parternship Plan – would be to encourage and work with SNH to make the system of Operations Requiring Consent far more robust than it is at present.

What needs to be done

Besides using its planning powers and working more closely with SNH, it seems to me its time the CNPA (and Loch Lomond and Trossachs National Park Authority) considered using the other powers it has to bring hill tracks and hill track work under control and protect the landscape.  I have previously advocated use of byelaws, which the National Park can create in order to protected nature conservation interests, to control grouse moor management.  Part of that should include extension of tracks and use of diggers on the hill.

 

It will help build the case for that if people out on the hill report what they see and, ideally, complain.

October 7, 2017 Nick Kempe 3 comments
The current debate on An Camas Mor is likely to carry into the consultation on the  new Local Development Plan. (Letter 5th October – Dave Morris is fellow campaigner and friend of mine).

Arguably the most important item on the agenda of the Cairngorms National Park Authority Board Meeting on Friday (link to papers) was the Local Development Plan.  The current five year plan was approved two and a half years ago but the consultation for the next one is due to start at the end of the year.  The  Board was being asked to consider the draft “Main Issues Report” for consultation.  It contains many important issues (which I will come back to) and a significant discussion about An Camas Mor.

 

When the CNPA Board renewed the planning permission for An Camas Mor for a paltry £203 under Section 42 of the Planning Act in the summer, part of their argument was they had no choice but to do so.  This was because the land at An Camas Mor was set aside for housing in the existing Local Development Plan.   There is a danger here of a circular argument, planning permission is granted because a new town at ACM is in the Local Development Plan and then the Local Development Plan allocates the site for a new town because……its been granted planning permission.  This could go on for years!

 

In what I see as a significant development the Main Issues report  identifies a way out of this circular argument based on the Scottish Government’s targets for new build housing in the National Park:

 

We will continue to work with the site owners and their design team to deliver An Camas Mòr. However, it is also possible that An Camas Mòr will not be delivered. The next Local Development Plan needs to be able to adapt to those circumstances if they happen and have alternative ways of meeting the National Park’s housing land requirements in the event that the site is unable to be developed.

 

The argument is that if ACM is not built, the CNPA’s proposed housing targest would  be missed so the CNPA is suggesting setting aside alternative land for housing.  Its suggestion is land at the northern edge of Aviemore  which, it says:

 

“is close to the existing road network, mains water supplies, sewage infrastructure and electricity supplies and would link to existing services and facilities in Aviemore.”

 

In other words, the infrastructure costs associated with development would be signficantly less and so make the development more likely to go ahead.   If that is the case, however, why not just choose the site now and ditch ACM?

Extract from Main Issues report

There is lots of other interesting information in the report (the CNPA is in a different league to the Loch Lomond and Trossachs National Park Authority when it comes to providing evidence about its plans – the draft LLTNPA National Partnership contains no proper evidence).   This evidence I believe will further assist with opening up a debate about whether ACM is a sensible solution to the Park’s housing problems.  Take the chart above (which excludes ACM  which is projected to provide 50 accommodation units a year till it reaches 1500).   This shows that in 2020 and 2021 new housing completions will exceed the Park’s target and by my reckoning this surplus offsets the shortfall between 2023 and 2026.  From then on the projected shortfall is only 20 houses a year, far less than the 50 a year ACM claims it will provide.   So, why is ACM needed on the Park’s projected “Annual Housing Land Requirement”?

 

If the Park’s projections of either demand or supply are wrong and fewer new houses are needed – for example if the number of vacant houses in the National Park could be reduced – there would be no justification for ACM at all.

 

The Local Development Plan is also  proposing to increase the proportion of affordable housing in new housing developments from the Scottish benchmark of 25% to 45% in Aviemore and Blair Atholl because of the shocking levels of low pay in the National Park (average pay is well below the Scottish average).  Now, I think this is a commendable move in the right direction, even if its not clear if this applies to ACM as well as Aviemore.   It should do though and, if it did, it would be very interesting to know if ACM would still go ahead (because of the high cost of new infrastructure).

 

Although the CNPA is saying in the Main Issues Report that it will do all it can to facilitate ACM, the logic of the Plan and the evidence seems to me to point to a different conclusion: that is it would be much better use of public money to plan for social housing elsewhere NOW and not wait for ACM to fail.  This would also avoid an access stushi and, most important of all, the destruction of one of the finest areas of regenerating native woodland (see here) in the National Park.  The consultation on the Local Development Plan offers an opportunity to stop the new town madness that is An Camas Mor and for the CNPA to meet its objectives both for conservation and sustainable development.

October 5, 2017 Nick Kempe 2 comments

The carpark for Ben Venue, which was featured in the Stirling Observer (see here), had been cleared up by the time I visited it 8 days ago.  I had a discussion with Fergus Wood, the Board Member who own Ledard Farm afterwards and he said the layby had never been blocked to hillwalkers.  While that had been suggested in the Stirling Observer article, that was not the point I had made on parkswatch which was that a condition of the planning permission for the Ledard hydro scheme (as far as I could ascertain) was that the layby was NOT to be used to store materials.   The concern was that a development involving a Board Member had breached planning conditions, which in my opinion, sets a very poor example.  That the layby has been cleared up suggests there was a breach of planning conditions and much of the credit for redressing this lies with the local publicity given to the issue by the Stirling Observer.

 

For the last couple of weeks I have been having a dialogue with the National Park Authority about their refusal to release information about pre-application discussions which took place with Fergus Wood about the proposed campsite at Ledard Farm (which was to be located just through the gate in the photo).  Fergus Wood withdrew that planning application in May.  Unfortunately, we have been unable to reach agreement and I have now submitted an appeal to the Scottish Information Commissioner.   In gathering the paperwork for that appeal I found that the planning documentation on the Park’s Planning portal (see here for current information) had been changed since my post of 11th April which drew attention to potential conflicts of interest between Mr Wood’s involvement in the development of the camping byelaws and his application for a campsite (see here).  In my view this change has been done in a way that is misleading, covers up for the failure of the original application to state that Mr Wood, the applicant, was a Board Member and appears to involve falsification of documents.  The rest of this post considers the evidence for this and the implications.

 

In my post of 11th April, I included an extract from the Planning Application form which I downloaded from the LLTNPA planning portal on 10th April.   This showed that under the Member Interests section of the application form the “No” box had been ticked.  The form was was dated 3rd March 2017. You can see the full form I downloaded here 2017_0097_DET-Application_Form-100279676.  I was surprised to discover therefore, when checking my appeal to the Information Commissioner, that there was a new Application form on the planning portal in which the “Yes” box under Member Interests had been ticked and which included text which said Fergus Wood was on the Board.  You can compare the two versions of the form below:

Extract from form downloaded 10th April
Extract from Application Form as it currently appears on Park portal

 

I was even more surprised to see both forms were dated 3rd March 2017.

 

I then checked further and saw there were two versions of the application form on the portal, the second headed “superseded” was easy to miss.

Screenshot from planning portal

Now I was pretty certain that when I downloaded the form on 10th April there was only one version of the application form on the portal.   While I did not take a screenshot at the time, its seems hardly credible that the agents for Mr Wood would have submitted two application forms on the same day, the first say Mr Wood had no interest, the second saying that he had an interest, that both were then date stamped 13th March but one went on portal first and was later marked “superseded”.

 

I then realised that the version of the application I had downloaded on 10th April had NO “superseded” in the title (and there should be proof of this in my computer’s download history – I am away from home – which I would be very happy to make available to investigators).   What therefore appears to have happened is that sometime after my post and before the application was withdrawn, a member or members of National Park staff renamed the original application form by inserting the word “superseded” in the file name and then created or processed a new version of the application form where the Members Interest boxes were both ticked yes.

 

I don’t know whose idea this was or who authorised the changes but they appear to me to be  fraudulent and intended to give the impression Fergus Wood had declared his interests at the time the planning application was made.   I would stress here that I have no evidence that Fergus Wood was involved in this at all, although what should have happened is when he realised he had failed to declare interests properly,  he should then have written to the Park, apologised and any amended paperwork should have then shown the correct date.   That would have removed any cause for complaint.   However, certain LLTNPA staff and Board members don’t think like that.  Instead they try to cover things up which makes matters a lot worse if they get found out.

 

The significance of this cover-up is that its the third that I am aware of involving a Board Member.  First there was Owen McKee, the chair of the planning committee who traded in Cononish goldmine shares (see here).   Second, was the falsification of the minute of the Board meeting which decided the byelaws to say that Board Members with property in the proposed camping management zones had declared an interest when they had not (see here).   And now there is Fergus Wood’s campsite planning application.

 

These attempts to cover up for Board Members are part of a much wider malaise, where information and records are changed or misrepresented to ensure the Park gets its own way.    This has been evident through the whole camping byelaw saga, for example in the way the results of the Your Park consultation were falsified,  but also seems common practice in the planning system where myself and a couple of co-contributors have noted documents have a strange habit of disappearing.  I would recommend anyone interested in a planning application to always take screenshots of the planning portal and download all relevant documents.   Its a pain in the neck, shouldn’t be needed but if you don’t do it, you have no redress.   Unless I had downloaded the Ledard Farm planning application I would have no proof any changes had been made.

 

What needs to happen

First, the LLTNPA needs to conduct a full investigation into the Ledard Farm campsite planning application, how and when this was changed and who was involved/responsible.

Second, the new Board needs to make it very clear to the senior staff team that any falsification of records will be treated as gross misconduct.

Third, It could then, try and re-establish a reputation for probity.  A review of the way complaints have been addressed might be a good place to start.  For example it could carry out the long outstanding  investigation which is needed into who was responsible for falsely recording that Board Members had declared an interest at the meeting which approved the camping byelaws.   (When I wrote to Linda McKay, after the Commissioner for Ethical Standards found she had no knowledge the minute had been changed, asking that she conduct an investigation into who was responsible she passed the letter on to Gordon Watson to respond.  He declared the matter closed, which suggested to me he was fully aware of who had changed the minute but it was not in his or the Park’s interests to address this).  I suspect there are many other examples.

Fourth, it should make a commitment to operate far more openly, publish more information and stop abusing Freedom of Information law to withhold information from the public (every appeal I have made so far to the Information Commissioner has resulted in information being released but its a long a thankless process).   This would help provide public audit trails which would help staff and Board Members who are honest and want to do the right thing.

Fifth, the Board could ask the new Governance Manager – the post has recently been advertised – to put ethics, including truth, at the heart of the governance of the National Park Authority.

October 2, 2017 Nick Kempe 1 comment
Photo credit – Scotland’s Nature

I was reminded a couple of weeks ago, in SNH’s regular e-newsletter “Scotland’s Nature”(see here), that there are some great people working for the Loch Lomond and Trossachs National Park Ranger service . What better for a group of refugees without money and after all they have been through to get out and experience the Scottish landscape?

 

This seems to me to be what the National Park Ranger Service should be all about, helping people who might not otherwise do so to enjoy and connect with the countryside.    To do this type of work well you need to combine the knowledge of a natural scientist with the people skills and values of a social worker.

 

The tragedy of the Ranger Service in the Loch Lomond and Trossachs National Park is that for most of this summer it has been diverted from encouraging people to get out and enjoy the countryside to policing campers.  With the end of the byelaw season, the staff’s permanent rangers can back to what I see as their rightful jobs.

 

Thankfully there have been many signs that many of the Rangers involved in Your Park have not lost their skills or values.   The main reason why the Loch Chon campsite has received positive feedback is because of the two Rangers who were stationed there when the Park’s plans to get a private operator to run the site collapsed.  “Booked a pitch which is underwater or sloping, no problem, you can find a better place here”.   They have not just ensured bottled water was available due to the failure of the public water supply, they have strimmed a number of areas to create better places to camp and been available to sort out a myriad of problems caused by the incompetent planning of the site.   I suspect none of this was in their job description but they deserve medals.  They have rescued the LLTNPA.

 

There is evidence too that Rangers know that checking permits is a  waste of their time and have stopped doing so (which incidentally is another reason why the Park’s data on permits is worthless).  Last week I was out at Forest Drive with Ross MacBeath and we got talking to an angler with a campervan who had bought a fishing permit  but had not been told about the camping permit system.    On site, he had spoken with a Ranger who had come round in the afternoon to give him the number to undo the Forest Drive gates which are locked at 4pm (another waste of Rangers time, why on earth is FCS locking people out of camping permit areas?) but not been asked for a permit.

 

While the LLTNPA has been trying, more or less unsuccessfully, to turn its Rangers into a private police force, austerity continues to bite.  Many many people, not just refugees but a sizeable proportion of the population of the west of Scotland, never get an opportunity to enjoy the countryside.  I remember talking at a seminar before the LLTNPA  was created that an indicator of its success would be when every school child in the Clyde conurbation was able to spend a week in both primary and secondary education enjoying the National Park.  Outdoor education for the many has since collapsed, despite the valiant efforts of people working in the field.

 

The LLTNPA could and should however be helping to change this.  Indeed I think this should form a key plank of its new Partnership Plan.    If its Ranger resource was freed up from patrolling and instead was given the mission to work with local authorities, instead of visits from primary schools etc being the exception, they could become the norm: the things that Rangers did every day.  Given continued local authority cuts, this would be quite a challenge but the LLTNPA has, I believe, in its workforce, people with the necessary skills and commitment. The LLTNPA could make this happen if it empowered its Rangers to make full use of their skills and determine how best they spend their time, rather than forcing them to drive around in vans all day patrolling.

 

The LLTNPA could also make the case for abandoned resources in the National Park, like the Ardlui Outdoor Centre, to be renovated (brought into public ownership) and used once more in conjunction with its Ranger Service.  That would help the Ranger Service meet its potential.

The former Outdoor Education Centre at Ardlui – the buildings were leased by West Dunbartonshire Council.

 

October 1, 2017 Nick Kempe No comments exist
The facilities at Loch Chon campsite are now closed – photo credit Ross MacBeath

On Friday to mark the end of the camping byelaws – you were a criminal if you pitched your tent without a permit on Saturday but from past midnight could camp in the same place scot free – Phoebe Smith has a piece on Radio 4’s “You and Yours”   http://www.bbc.co.uk/programmes/b095ptx2.  (It runs from 28 mins 10 secs to 35 mins).   Don’t be put off by the howlers, “lakes” for “lochs” and Balmaha described as a town, the rest of the content is quite good – Phoebe Smith loves camping and says so.

 

The Loch Lomond and Trossachs National Park Authority took Phoebe Smith out to Balmaha.   After repeating the claim that there were far too many campers,  the Park’s Director of Conservation Simon Jones  went on to say large numbers of campers created certain problems such as litter and human waste and that the byelaws were addressing these, before correcting himself mid-speech and admitted human waste is still a problem.   This was a public admission that the byelaws have NOT addressed the problems the Park claimed they would solve.   This should not be a surprise. The problem has never been numbers, which have been concentrated on a few weekends a year,  it has been the lack of facilities for campers and other visitors.  By trying to concentrate campers in a few places through the permit system without any new facilities, all the National Park has done is concentrate impacts, the opposite of what it claimed it was wanting to achieve.

 

The LLTNPA then wheeled out Sandy Fraser, owner of the Oak Tree Inn (they use him most time they want someone to speak out in favour of the byelaws to the media), to talk to Phoebe Smith.   Powerful stuff to anyone who did not know better: people “really didn’t want to live here any longer”, “it was a no go area” and the introduction of the east Loch Lomond byelaws was “like a light switch, night and day”.  Now, I always believe money speaks louder than words, so I took a look at the accounts of the Oak Tree Loch Lomond Ltd, which was formed in 2009 and is described as a restaurant business:

 

Year till 31st Oct 09/10   10/11     11/12 12/13
Net current assets £86,785 £169,623 £265,883 £363,898

 

The accounts are abbreviated, so don’t show what contributed to profit and loss for the year, but the total profit and loss feed into the “net current assets” line at year end.    If people had stopped coming to Balmaha, prior to the east Loch Lomond byelaws being introduced in June 2011,  one might have expected the first year of the new company to have been disastrous financially.  Instead, the accounts show assets increased to £86,785 of which £76,785 came from profit.  Hardly a sign that people were no longer coming to Balmaha.  Moreover, the introduction of the byelaws in June 2011 did not mark a massive jump in profits.  I think we can take Sandy Fraser’s claims with a very large pinch of salt.

 

While there were undoubtably some problems associated with camping and drinking at Balmaha prior to the byelaws coming into effect, I think these need to be seen in perspective.  The main problem Sandy Fraser cited in the interview was that about once every three weeks people took the Oak Tree Inn benches and umbrellas down to the beach beyond Balmaha pier.  Extremely irritating I am sure, but did this justify the removal of access rights?   And what role does Sandy Fraser think the introduction of alcohol byelaws on east Loch Lomond by Stirling Council also in 2011 have in stopping this happening?

 

In terms of objective evidence about what changes had happened, the Park commissioned some research from Keep Scotland Beautiful which it eventually provided  under Freedom of Information.  It has never published this research or considered it at a Board Meeting, presumably because it makes uncomfortable reading:

The research does show the condition of sites on east Loch Lomond in 2015 (which was when the survey was undertaken) was better than in the other management zones but not that much better.  Not the miraculous improvement claimed by Sandy Fraser.   And this despite the camping ban, the alcohol ban and the clearway which prevents people visiting many of the places they used to go to.

 

Looking at the Keep Scotland Beautiful data in more detail,  one site on east Loch Lomond that has really improved is the beach north of the pier at Balmaha which sits under the metal bridge and which used to be use for partying (hence why it was selected for the survey).

Note, no alcohol related rubbish was found but this could as well been the result of the alcohol byelaws as the camping byelaws

So, maybe Sandy Fraser has a point, the environs of Balmaha have improved a bit – something everyone should welcome.  The question though remains, why were byelaws ever needed to do this?  The site under the metal bridge is small and very visible, hence easy to police by rangers but if easy to police by rangers, why not the police?   What should have happened is each time his benches went, Sandy Fraser should have phoned the police.   Its the adequacy of policing in rural areas which is the real issue, not camping.

Wayne Gardner’s new development of Luxury Lodges at Balmaha (Sandy Fraser is in partnership Wayne Gardner and will be developing another part of the site).

There are however, I believe, other agendas at play.  The evidence shows that Balmaha is being turned to a luxury tourist destination with prices to match.   My impression is campers don’t fit that image.   Hence why, despite the considerable area of flat land to the south of the village, there is no campsite.  Hence why the camping byelaws were extended down to the mouth of the Endrick, again without any evidence of problems.  Camping is just not part of the agenda of the new lairds of Balmaha.   If they understood the access legislation however they would know land can be exempted from access rights (under Section 11 of the Land Reform Act) without any need for byelaws and this could have been used to stop people camping within villages in the National Park.

 

The lack of publicity for the end of the byelaw season and the Park’s closure of facilities

 

In contrast to the launch of the byelaws in the Spring, there is NO publicity on the Park’s website and no news release to say people announcing they are now over and people can now camp freely again under access rights.  This probably explains the lack of media coverage in Scotland (please contact parkswatch if you have come across anything).  The explanation, I believe, is that if the LLTNPA had reminded the media the byelaws were over for the year, they might just have been asked some awkward questions, including what the byelaws had achieved.  Better then not to mark the occasion and hope no-one noticed.

 

While some people may have realised that the byelaws ended on 30th September, I am sure most  will not have realised that Loch Chon campsite is also now closed.    This is incomprehensible.  Here is what staff told the Board just a few weeks ago:

 

Loch Chon campsite has now been operating for six months and continues to be popular with visitors, with some weekends coming close to operating at full capacity. The total nights booked up until the end of August was 1160 with an average stay of 1.5 days. These bookings were representative of 1843 people; 1362 adults and 481 children

 

Now, leave aside everything which was wrong about this campsite (too many places, fixed pitches in the wrong places, no water supply and a toilet block which stank as a consequence) people visited because at least there were some facilities and, its one of the few lovely places where you are still allowed to camp.   Why then, having paid well over £345k for this campsite, close it just because the byelaw season  is over?   If there was such demand, surely it would be worth keeping the campsite open for at least another month and leaving the toilets open after that?

 

How too does the decision to close Loch Chon fit with the fact that the other two campsites the Park is involved in, at Sallochy and Loch Lubnaig, are both open till the end of October?  The answer is that other people operate those campsites, with no cost to the Park, but the Park has had to deploy two (excellent) rangers at Loch Chon to keep it going.

 

It makes me suspect the Park will now have also reverted to its previous practice of closing the toilets and carpark at Firkin Point.  If so, the public should treat all claims by the LLTNPA that it wishes to improve infrastructure, with scepticism.     The Park should know that human waste, about which it claims to be so concerned,  biodegrades more slowly in winter than summer and is a strong reason why all toilets operated by the National Park should be open year round.    Infrastructure is needed 365 days, not just over the summer and not just so the Park can claim to Scottish Ministers it has done something to provide for campers.

September 27, 2017 Nick Kempe No comments exist
Marquee, slate bay, 26th August, by Camstradden within the West Loch Lomond camping management zone.  There is no record I can find of Luss Estate or the Loch Lomond Arms hotel who run weddings here of applying for an exemption from the camping byelaws..

The Your Park paper update paper to the Loch Lomond and Trossachs National Park Authority Board on 18th September (see here) contained a very short section of enforcement of the camping byelaws.

While the LLTNPA has reported that 7 cases have been reported to the Procurator Fiscal since the byelaws came into effect, what they did not say is how many breaches of the byelaws have NOT been reported.  From my observations, dozens of tents and shelters have been erected outwith permit areas let alone the hundreds of campervans parking overnight outside of permit areas before the LLTNPA’s attempt to prevent people from exercising their legal right to sleep in vehicles on the road network collapsed.  The LLTNPA has also never publicly explained what methodology, if any, it has implemented to record breaches (it used to count tents and fires and record these in its ranger patrol records) or how many such breaches it has identified.    On top of this, if there is to be any proper evaluation of the effectiveness of the byelaws, it needs to estimate the number of tents and shelters which have not been recorded by its Rangers.

The methodology is important because, for example, under the byelaws its an offence not just to camp but for any form of shelter to be set up between 7pm and 7am.  While its quite easy to erect and dismantle light shelters within a day, I am certain the marquee in the picture above, even if was not used after 7pm, stayed up after that time.    What’s more – just as with the Luss Games (see here) – I cannot find any record of an exemption being applied for.  So, if the report on the first year of the byelaws which the Park intends to submit to Minister is to mean anything, it needs to record not just numbers of tents but the different types of shelter and the details of all exemptions which have been granted.

 

Park Rangers drive past Slate Bay every day on their way out from the Park HQ at Balloch.  If this ground has not been granted exemption by the Park as a campsite and specific exemptions not applied for and granted, how many times have they recorded marquees here?  How many times have they then talked to Sir Malcom Colquhoun of Luss or the Managers of the Lomond Arms Hotel who appear to be involved in these weddings (see here) and told them they needed to apply for exemptions and tried to educate them about the allegedly serious impact which the Park claims tents and shelters have on the natural environment?   Has anyone reminded the Sir Malcom that the reason why the byelaw management zones extend south of Luss and round his house was because the local community, of which he is a part, called for this?   What is the difference between Mr Trout, who has been referred to the Procurator Fiscal (see here), retreating to his shelter in a storm and wedding guests taking shelter from the rain under a marquee?

And its not just marquees……………tents at Slate bay on 2nd September

Actually, there is no difference.  Its pretty obvious that it is who you are, rather than whether you have broken the law, that determines whether the LLTNPA will refer you to the Procurator Fiscal or not.   Can you imagine Park Rangers asking Sir Malcom Colquhoun to dismantle these tents and shelters shortly before a wedding and then, when refused, calling the police?   I think not, but anglers are different, especially if they speak with the “wrong” accent.

Slate Bay, is the large bay opposite Inchtavannach.  Camstradden House, the home of Sir Malcom, is on the north side of the bay.

The byelaws would,if applied properly, not just make criminals of people camping according to Scottish Outdoor Access Code but many local people and businesses.  These examples show just how ridiculous and unfair the byelaws are.  The answer is not to try and make the exemption system work.  All that has done has produced more bureaucracy and another set of figures the Park should be providing is how many Scout and DofE groups applied for “free” exemptions – free apart from the hassle and bother?  Judging by the number of applications listed on the weekly planning lists – not many – there appears to have been a collapse in the number of expeditions involving young people to the National Park.

Since the beginning of August until this week just ONE camping byelaw application has been recorded on the Park’s weekly planning lists and that ironically for an old campsite, where camping is now banned.

 

Whether or not the Park reports on what is really going on, the truth will eventually become widely known and when it does, the byelaws will collapse.  These are bad laws and I do not see how, when there appear to be such glaring breaches by the great and the good, that the Procurator Fiscal  can possibly justify taking action in the cases referred to them.  Simon Jones the Park’s Director of Conservation told the Board Meeting he had spent lots of time talking to the PF but not what this was about.  This indicates that LLTNPA staff are finding enforcement far more complex than they ever imagined but the Board unfortunately do not appear yet to have appreciated the implications.   Its time that recreational interests started to prepare a case for the Justice Minister about the fundamental flaws in the operation of the byelaws.

 

What needs to happen

The LLTNPA must:

  • publish its ranger patrol records for this year as soon as the byelaw season ends on 30th September.
  •  provide a list of exemptions that have been granted to the byelaws and why together with an analysis of why the system is not working.
  • make public all rules and instructions to staff about enforcement of the camping byelaws

and use this to inform the drafting of its report to Ministers and whether a change in direction would do it less damage than continued attempts to gloss over how the byelaws are failing.

 

September 24, 2017 Nick Kempe 1 comment
Herald Thursday. There was a further article and leader comment on Saturday.

The debate about visitor numbers, which started this summer with reports of visitors “swamping” Skye and the North West Coast, has moved to the Outer Hebrides and the current focus is on “motorhomes”.  However, unlike in the Loch Lomond and Trossachs National Park where the numbers of visitors are treated as a problem,  in the West the increase in visitors is generally seen as a good thing.  The challenge, as Alasdair Allan the local MSP said, is that infrastructure has been unable to keep up with demand.   In suggesting that a levy be imposed on campervans to fund the infrastructure, he has opened up the debate.  The Herald, at the end of their leader on Saturday, reflecting on that debate concluded, rightly I believe:  “Getting the infrastructure right is the solution: who pays for it is the problem”.

 

What the Herald failed to say was that if our National Parks had been working and being doing the job they were set up to do, they would now be providing a model of how to do this.  Moreover, the case for further National Parks, including that mooted for Harris, would be unanswerable.

 

Unfortunately, there is almost nothing that people on Skye and in the Outer Hebrides can learn at present from our existing National Parks.  Both seem keener to ban visitors than welcome them.  The Cairngorms National Park Authority has suggested byelaws to restrict access could be used to allow the An Camas Mor development to go ahead (see here), while the constant refrain of LLTNPA  Chief Executive Gordon Watson over the last year when asked to justify the camping byelaws has been  that the numbers stopping off in campervans and tents are too great.  The LLTNPA’s original provision for campervans under their camping permit system was a measly 30 places, with not a single campervan allowed at their new Loch Chon campsite despite all the parking space there.   The LLTNPA’s attempt to limit the number of campervans has now fallen apart because of the legal right people have to sleep in vehicles by the road but this has left a policy vacuum.

 

The policy vacuum  provides an opportunity for the LLTNPA to change direction.  Instead of trying to stop and control visitors,  they should be focussing on what infrastructure is needed to support them.   There was no open discussion of this at the Board Meeting earlier this month, although a reference in the Your Park update report that staff were looking to upgrade facilities at Firkin Point and Inveruglas suggests they may now be moving in the right direction.

 

The basic elements of the infrastructure the LLTNPA needs to provide for campervans should be quite obvious – chemical disposal points, places to leave rubbish and drinking water.  When asked for a list of chemical disposal points in the National Park earlier this year, the LLTNPA knew of none outside formal campsites (see here) and could not even say which campsites had chemical disposal points.  The LLTNPA needs to start acknowledging that the lack of facilities for campervans and the lack of public information about this as a problem and also that it has the primary responsibility to sort this out.

 

The contrast in levels of understanding and understanding between the LLTNPA and  the west is striking.   Alasdair Allan MSP was able, without apparent difficultly, to identify the lack of facilities, chemical disposal points and capacity on ferries as a challenge.    Imagine what the Western Isles could have learned if the National Park had installed chemical and waste disposal points for campervans at the toilet facilities along the A82,  (Luss, Firkin, Inveruglas, Crianlarich, Tyndrum) and made these available 24 hours a day.  Imagine too what the Western Isles could have learned if the LLTNPA had used its large communications and marketing team (there are at least 8 staff) to engage with campervanners about the infrastructure they would like to see in place and then disseminated the results across Scotland?  That could have informed provision of infrastructure everywhere but instead the LLTNPA uses that team to produce glossy materials telling people what they are not allowed to do and where they cannot go.

 

To take the contrast further, tourism chiefs on the Western Isles have criticised Mr Allan’s proposals for a ferry tax on motorhomes because it might put people off visiting.  In the Loch Lomond and Trossachs National Park tourism businesses piled in to support the byelaws banning visitors in the mistaken belief that you could force people to use commercial sites.   Funny how all those free marketeers want to constrain choice.    A study by Outer Hebrides Tourism has found that people in motorhomes, who are not forced to go anywhere in the Western Isles, on average spend £500 per visit.  Both the tourism chiefs and Mr Allan know that the increased number of visitors in motorhomes is good, the debate is just about how to fund the infrastructure and whether tourism taxes would put off tourists.   The contrast with the LLTNPA  is that in all the papers that were developed to try and justify banning campers and campervanners, there was no tourism impact development and never once did the LLTNPA consider the impact on the local economy.  The LLTNPA should acknowledge in their report to Ministers on the byelaws in December that this was a mistake as has been their attempt to limit the numbers of tents and caravans to 300 (which was an arbitrary figure which has never been justified).

 

The final contrast between the west and the Loch Lomond and Trossachs National Park about the infrastructure debate is the level of political involvement.   Its not just Alasdair Allan that is involved, Kate Forbes the Highland MSP has facilitated meetings on Skye with local councillors and the tourism minister to discuss what needs to be done to support visitors (see here).  In the Saturday Herald Leader of the Western Isles Council, Roddie Mackay, was quoted as saying “The council is exploring all options that could increase investment in infrastructure required as a result of the undoubted success of RET (the Road Equivalent Tariff which has reduced ferry charges) and tourism”.  Contrast this with the LLTNPA where local MSPs and councillors, including those on the LLTNPA Board, have been notable for their silence on the need for improved infrastructure and investment.

 

A recent example of this political silence came at the LLTNPA Board Meeting last week when a Board Member referred to visits from large cruise liners which come to the Clyde and then send busloads of passengers to Luss.  This was interesting – same issue as in the Hebrides – and helps to explain why visitor infrastructure at Luss is creaking.  Not one idea was proposed however on how to rise to this challenge and opportunity.  Instead, there was a bizarre discussion about how difficult it was to get agreement from Luss Estates, the Park and the local Council about who should pick up litter where around the Luss carpark.   

 

What needs to happen

Our National Parks should be aspiring to provide models of excellence for how to support visitors, not ban them, and focus the resources which they have, which are far greater than are available on the west coast, on getting infrastructure right.

 

As part of this the LLTNPA should be committing to develop a proper plan for the infrastructure needed to support campervans in the first year of the forthcoming National Park Partnership Plan 2018-23.  This should include a commitment to engage openly  people using campervans and local communities  to the right type of infrastructure and in what places.  Some of this should be easy, for example adapting existing facilities, some more challenging, for example installing new public toilets and disposal points (eg at the carpark at the foot of the Cobbler).  I will consider how this could be funded in a future post.

September 22, 2017 Nick Kempe No comments exist

Retiring Loch Lomond and Trossachs National Park Authority Board Member and former SNP councillor Fergus Wood was featured in the Stirling Observer last week due to his  alleged failure to abide by planning conditions set by the National Park Authority for the hydro scheme at Ledard Farm which he is reported as describing in the article as “my project”.   Fergus Wood is a paid Director and part owner of Ledard Farm Ltd which appears to own Ledard Farm.    Fergus Wood has been a member of the Park’s planning committee since at least 2013 and possibly since c2007 when he joined the Board.  (Councillors have traditionally sat on the Park planning committee but the LLTNPA’s removal of all Board records pre-2014 from its website has made it very difficult for the public to ascertain basic information like who was on what committee when).

 

The LLTNPA, as planning authority,  required Fergus Wood as applicant at the time,  to submit a Traffic Management Plan for approval as a condition of the planning permission .  This unfortunately has not been published on the Park’s planning portal, which makes it difficult for the public to submit specific complaints about breaches of planning permission, but will almost certainly have included requirements that the public layby should be kept clear.   Fergus Wood was also required to submit details of:

 

Its almost inconceivable that the Park would have allowed this on a public road.

 

Its also almost inconceivable that Fergus Wood, as a former councillor and member of the planning committee, would not understand the reasons for these conditions and as a local resident (the layby is opposite where the side road leaves the B829 for Ledard Farm) did not observe what was happening.   The first scandal therefore is that a member of the Park’s Planning Committee apparently knew the contractors/developers of the hydro scheme on his land were in breach of planning conditions and yet did nothing to stop this.

 

A second scandal is that Fergus Wood still hasn’t stopped the breach of planning conditions  despite the publicity and despite the claim (article above) by his former colleague  on Stirling Council, SNP councillor Jim Thomson, that the problem had been sorted (see the letter below, which appeared in the Stirling Observer today).

While Fergus Wood is about to retire from the Park Board, having lost his Council seat after ignoring the views of the local community over his proposed campsite (see here)and (here)  (the planning application was subsequently withdrawn), the LLTNPA cannot ignore this blatant breach of its own rules involving a Board Member.  To do so will bring them into further disrepute.   Board Members should be setting an example for any planning application which involves them because otherwise they undermine the very system of which they are supposed to be custodians.

 

An even bigger scandal however appears to be brewing at Ledard Farm.

 

The new planning application to “retain” a track used to construct the Ledard hydro scheme

 

In  August, Baby Hydro Ltd, acting as agents for Vento Ludens Ltd submitted what appears to be a retrospective planning application (see here) to retain a construction track along the line of the approved pipeline to the hydro intake (see here for all papers 2017/0270/DET).  None of the earlier planning applications related to the hydro scheme published on the Park’s planning portal appear to have included authorisation for a temporary construction track here.   While I have asked the LLTNPA to clarify this, a note of a telephone conversation by the applicant on the application form states “It was agreed therefore that a retrospective planning application was required”.  If  a retrospective planning application on a Board Member’s land is not bad enough, what’s worse is the LLTNPA Planning Committee had explicitly rejected an earlier proposal for a permanent track along this very route because of the visual impact it would have had.   The full story is quite complicated but is important to understand what is going on.

 

The original proposal for the hydro scheme was for an access track to approach the intake from the east along the line of the pipeline.  This was rejected by Park officers – and all credit to the landscape adviser for their strong recommendations on this – because of the visual impact:

Extract from committee report December 2014

As a consequence of these pre-application discussions, the revised scheme included proposals for access to the intake from the west side of the burn (on land not owned by Fergus Wood).  This was was approved by the LLTNPA planning committee in December 2014. (Because the applicant was a Board Member the decision was made by the full planning committee and not delegated to staff as now happens with most hydro schemes in the Park).

The is the best illustration I have found in the planning documents to explain the history. The original proposal for a track followed the pipeline marked in red and went through open fields above the wood – which were very visible, hence why this option was rejected. The proposal that was approved utilised the existing forestry track marked in blue and then added a short section of new track along a ride (the L-shaped bit of red line on the left).   The new track which has been constructed approximately follows the two red lines.

After receiving planning approval,  a significant number of alterations were submitted in the name of Fergus Wood to the original plans.  These were treated as Non-material Variations and dealt with by officers (you can see all the published planning documents relating to the original application at 2013/0267/DET).  Most of the NMVs approved were insignificant but then in 2016 an application was made to remove the  access track which had been approved on the west side of the burn completely.

Staff approved this  and in doing so were fully in accordance with the Park’s Supplementary Guidance on Renewables which states:

 

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

 

The fact that no alternative proposals for an access track were submitted at the time would have led staff to believe that Fergus Wood had decided there was no “overhwelming reason” for permanent vehicular access to the intake.  Its not far from the farm and it could be maintained by occasional visits on foot.  I suspect if staff had known that  a further application might be submitted a year later along the line of the route that had already been rejected they would have been very alarmed.

 

Within the original planning application for the hydro scheme there were no proposals that I can find for temporary construction tracks.  The Construction Method Statement, which was approved by officers after the planning committee, also made no reference to temporary tracks being needed to construct the pipeline.  From what I have been able to ascertain from the published documents – and its not good that the position is not 100% clear – the pipeline was to be created by “tracked excavator”:

Being a small hydro scheme with a small diameter pipe it should have been possible to dig the ditch and bury the pipe without a track – a good thing.  However, because the position is not 100% clear I have asked the LLTNPA to clarify if any approval was given to Fergus Wood or his agents at the time for temporary construction tracks and if so where this is recorded.

 

The new planning application is for a track along the line of the pipeline – ie the very line that the LLTNPA rejected three years ago because of the visual impact!   However, formally Fergus Wood appears not to be involved.  Not only is the application in the name of Vento Ludens Ltd, the form includes this declaration:

So, Fergus Wood, as a Board Member has no formal interest in this development – which incidentally would allow staff rather than the full planning committee to decide this application -and yet another part of the form shows he is still the landowner!

Now, Fergus and Francesca Wood used to be directors of a company called Hydrocrofters Ltd whose address was Ledard Farm.  I suspect this was the company that was originally intended to deliver the hydro scheme but the two Woods resigned from the Company in May and Companies House records it as being dissolved on 26th September 2017 (bizarre, I know,  that is in the future!  – but in the unregulated world of capitalism at Companies House lots worse is allowed to happen!).  It appears possible therefore that Fergus Wood has sold or leased the hydro scheme to Vento Ludens but kept the land.   As landowner, however, he is responsible for what is going on on his land, and he appears to have admitted this when referring to the scheme as “my project”.  I think it inconceivable that the developer would construct a track on his land without his permission..

 

Its worth noting this is not the first time Fergus Wood has failed to declare an interest as a Board Member on a planning application form.   He also failed to declare an interest when he applied to build a campsite on his land last year (see links above).

 

The planning application form records there was a telephone call, office meeting and site meeting with park officers and, if the reference to agreeing the need for a retrospective planning application is correct, what the LLTNPA has once again failed to do it enforce its own planning conditions.   Sometimes retrospective applications can be justified instead of taking enforcement action but in this case officers should have known that the Board Planning Committee had previously rejected a track here, so why ask for a new application to be submitted?   I think we should told not just how this decision was made but by whom?  I somehow doubt it was the staff involved who had done a fantastic job first time round stopping a track from being created here.

Photo from current planning application of the new track which Fergus Wood wishes to retain.  It appears the pipeline has been buried on the left side of the track.

 

 

In view of all of this disregard of the planning system, its not a surprise that the photo above shows is that in constructing the “temporary” construction track and pipeline normal good practice has been ignored.   LLTNPA staff are normally very good at specifying both soils and turves should be stored properly to enable effective restoration. Spot any turves here?  Moreover the track has been cut through a bank on the right, leaving oversteep sides, which are very difficult to restore and will leave an even greater landscape scar unless the slope profiles are fully restored.  Again, what sort of example is this from a Board Member?

 

The reasons given by the applicants for keeping the track they have unlawfully created  are not credible:

The hydro is close enough to walk to for occasional cleaning.  If an ATV can carry in a large sluice gate at some indeterminate time in future, it can do so off road.  Occasional use of ATVs has far less impact on both vegetation and the landscape than this track will.  If Fergus Wood ostensibly accepted  for a whole year he could manage the hydro without a track, so can the new applicants.

 

What needs to happen

If you are concerned about what is happening at Ledard Farm, please submit an objection to the current planning application.  This will help put pressure on the LLTNPA to take what has happened seriously.   Just click on the comments box on the  planning portal for application 2017/0270/DET.  In my view the most important point to get across is nothing has changed since the Board originally decided a track was inappropriate.

 

Following on from the Owen McKee case, where the former Planning Convener was found to have been trading in Scotgold shares without declaring this (see here for example), it is absolutely crucial that the LLTNPA is seen to undertake an open investigation into Fergus Wood’s involvement of breaches of planning permission arising from works at Ledard Farm.   This must not be covered up, as the Park tried to do with Owen McKee, and my view is Fergus Wood should be suspended from the Board until this has been fully investigated.

 

The LLTNPA also needs to be taking effective enforcement action to redress current breaches in planning conditions at Ledard Farm.   This should start Monday.  While having accepted the retrospective application for a track, the Park will need to go through due process but because of Mr Wood’s landownership any decision needs to be taken in public by the full planning committee and not officers (and we should not accept the excuse that because Fergus Wood’s term on the Board is about to terminate this is no longer necessary).

 

I would also like to see an investigation cover Mr Wood’s involvement, since the day he joined the planning committee, about enforcement policy and enforcement decisions (or rather lack of them) made by the LLTNPA.  In my view, the LLTNPA uses its enforcement powers far too rarely.  When there are Board Members sitting on the planning committee who apparently don’t want planning requirements to apply to their own land, its quite reasonable to ask whether their own self-interests have not corrupted the entire system.

 

After Owen McKee and with Fergus Wood, its time there was a full review of the Park’s Planning Authority functions.  With new Board Members about to be appointed, it provides an ideal opportunity for change.

September 20, 2017 Nick Kempe 2 comments
Just what we want to see in the National Park, hill tracks so broad that people can walk five abreast! One reason why the Loch Lomond National Park Authority is dysfunctional at present is its marketing department appears unaware of the Park’s own policies – hill tracks where they exist should be quadbike width – and produces glossy brochures without reference to its own staff.

The Loch Lomond and Trossachs National Park Board Meeting on Monday (see here for papers) was far more open than meetings in the past but showed the Board still has a considerable way to go.   The fundamental issue is that most Board Members appear to have little idea of why they are there.  It was telling that under Matters Arising, there was not a single question about where the Board goes now the Scottish Government has rejected its suggestion the Board be reduced in size (see here).  This was an ideal opportunity to continue the discussion from the last Board meeting about the function of Board Members but ostensibly the matter is now being treated as closed.

 

Among the welcome signs of change at Monday’s meeting were:

  • The meeting time was changed to the morning which meant there was no time for the secret pre-meetings which used to take place under previous convener Linda McKay.
  • As a consequence there was more public debate, including on issues where Board Members previously appear to have been gagged.  For example, questions were asked about why plans for the National Park’s properties at Balloch, the Gateway Centre, and Luss Visitor Centre were so far behind schedule.  Even the financial consequences were touched on, both losses and costs, and while Chief Executive Gordon Watson was very reticient in his response, the good thing is more Board Members seem prepared to discuss these issues in the open.  I hope this creates an opportunity for the Board Members representing those local communities to engage with them on what is going on.
  • James Stuart, the new convener, reported to the Board he had spent a lot of time meeting stakeholders, including people who disagreed with what the National Park had been doing, and made it very clear he thought such engagement essential.  He even pointed to Ross MacBeath and myself in the audience and said he had had a constructive meeting with the two of us and Dave Morris on camping!  He reported on a meeting with SNH who were keen to develop far closer working – there has been a stand-off over the last few years where the Park has tried to do things itself without using expertise of SNH, for example on how to engage with recreational users, which contributed to the camping byelaw disaster – and the long delayed meeting with the Cairngorms National Park Authority is now going ahead.   The message was that James Stuart really does want the LLTNPA to work in partnership not isolation.   There was no rush from Board Members volunteering to get involved in this although my view is if the National Park is to change course, other Board Members need to start engaging too and means different people need to take on different roles.

 

While the meeting was conducted in a far more open manner than in the past two local people,  commented on the lack of meaningful discussion.   (Its well worth reading Trevor Scott’s account of the meeting (see here) on the Balloch Responds Facebook Page).  They were amazed when we told them the meeting was a considerable improvement to what used to happen!.    I think though they identified the main problem with the meeting:  the Board was not being asked to take any meaningful decisions and as result the meeting was over in under two hours.

 

This was despite  two very important matters being on the table, the “Your Park” progress report and the National Park Partnership Plan.   The way the reports on these subjects were drafted though suggests that it staff, not the Board, who are at present taking the decisions.

 

The camping plan and camping byelaws

Board Members were not invited to take any decisions about the Your Park plan, instead an update report (see here) was presented:   a  report for Ministers on the first year operation of the byelaws will be brought to the December meeting for approval.    I will analyse in further posts (see here for issues with the data presented in the report) the content of the paper including the Park’s failure to deliver additional campsites and the serious problems with the permit areas (all of which were glossed over)  and here focus on the Board reaction to the paper.

 

The first good news was that Colin Bayes, who chairs the LLTNPA delivery group (of Board Members and senior staff), announced that after meeting Ross MacBeath, Dave Morris and myself he had been out to see most of the permit zones with staff and Board vice-convener Willie Nisbet.  He acknowledged that there were some serious issues and that these are now being addressed. A positive development although it would have been good if staff could have been as open about this in their paper. Its possible that its as a consequence of Colin’s visit that some camping permit areas have now been removed from the booking system.

 

Also positive was Billy Ronald’s question – first time I have heard him speak – asking why anglers cannot buy a camping permit in local shops along with their fishing permit?  The answer from staff was that if the Park allowed paper permits to be issued by local shops, they could not control numbers and as a consequence more people might end up camping in a specific permit area  than Park staff have deemed sustainable.   No Board Member thought to follow this up by questioning the justification for stopping anglers from camping in the places traditionally used for fishing but which are outside the new permit zones or by asking staff how they decide what numbers are sustainable.

 

Most significant though was the statement from former Councillor James Robb,  that the clarification that the Park had “overreached its powers” – his phrase, not mine –   in trying to ban campervans from laybys was useful.   Now the Park has never publicly admitted this although it appears from Cllr Robb’s comment that it has briefed Board Members.   There was no single reference to campervans or the LLTNPA overreaching its powers in the update paper.  Indeed the LLTNPA has refused to clarify with parkswatch whether campervans are still included in the byelaws outside of laybys and if so where (see here).    It appears that the LLTNPA is still trying to cover up the extent of the campervan fiasco, including how they and Scottish Ministers approved camping byelaws which were legally unenforceable.  More importantly, they have not started to grapple with the question of fairness: if there are now no or limited controls on campervans and caravans, what is the justification for continuing with the byelaws?  I would suggest that this is the fundamental question that needs to addressed in the report to Scottish Ministers.

 

Councillor Robb also asked staff members to take him through the process of referrals to the Procurator Fiscal (7 people have now been referred for prosecution).   This was a very good question – one which the Park have refused to answer under Freedom of Information claiming it would interfere with law enforcement – and I was not surprised when staff failed to respond.   Cllr Robb then tried to talk through the process himself and asked whether when a person refuses to apply for a permit when camping in a permit area, they are then issued with a Fixed Penalty Notice?   This was a clanger of immense proportions.   Gordon Watson  had to explain to him there are NO Fixed Penalty Notices (which can only be used for civil offences) under the camping byelaws.   Here was one Board Member who had approved the camping byelaws without apparently appreciating that they would criminalise people (fines of £500 and a criminal record).    After 13 secret meetings to develop the byelaws, I find it staggering that staff had not properly briefed Board Members on this.  This points to the fundamental issue, there has been no-one on the Board with sufficient knowledge and understanding to ask basic questions like “is it really right we criminalise people simply for not being in possession of a camping permit?”.

 

There was evidence that other Board Members still have their heads in the sand.   Petra Biberbach, the convener of the planning and access committee, commented that she thought the data in the update paper was excellent.     Neither she or any other  Board Members thought to ask about what negative feedback there had been to the camping byelaws and what data existed on this?   This is despite it being clear that changes to the permit zones for example have resulted from complaints and public criticism.    Former Councillor and retiring Board Member Bob Ellis went further and said he was very heartened by the report, had only had positive feedback from campers (its good he is speaking to campers but those he has engaged appear to be a completely different subset of campers than those I have talked to), thought the report showed the camping byelaws were a great success and was proud to have been part of it.

 

To be fair to other Board Members, they did not follow this valedictory speech.  I think some of them are beginning to realise that the camping byelaws have been far from a success (no-one dared ask about the numbers of people who ignore the permit system) and that the delivery of proper new camping places is far harder than they ever envisaged.  This was reflected in several comments to the effect that “we are learning all the time”.   The prevailing assumption on the Board though still seems to be that as long as they keep throwing resources into various management measures, eventually they will be able to control all campers and make the byelaws work.  Maybe the new members coming onto the Board will be able to take a more critical look at what has actually been happening.

 

The draft National Park Partnership Plan

The development of the NPPP is well behind schedule, a reflection of the resources which have been devoted to Your Park and the significant number of staff who have left the National Park Authority.  The NPPP paper  presented the responses to the flawed consultation on the plan (see here) without saying how the Park would respond to these but that a revised plan would be presented at the December meeting for approval.

 

Colin Bayes, who is open and on the ball, pointed his finger at the issue when he asked staff what process would be used to decide how all the comments received would be fed into the final plan?  Gordon Watson’s response that the National Park Authority needed to be realistic about what it can achieve avoided the question but to his credit, David McCowan, another Board Member who is willing to be critical (he has consistently raised the Park’s failure to deal with litter) then asked that staff should record a response to every single comment received, including that resources weren’t available to deliver it.  Brilliant!   I think staff had assumed they could decide how to respond to comments without telling anyone.   A little bit of accountability at last.

 

In the main though this was an opportunity missed.  What staff should have done is brought to Board Members key issues for discussion based on the responses that had been received.  The Board could then have given a steer about how the Park should respond.   However, unlike in the Cairngorms National Park Authority, which based the whole of its consultation on its Partnership Plan on big issues it wanted to address, LLTNPA have avoided any mention of issues like the plague.  Instead, the LLTNPA consultation was based on visions and outcomes that were so broad as to be meaningless and which contained almost nothing about what partners would contribute.

 

Extract from consultation responses paper

This extract shows that a significantly higher proportion of organisations supported the draft NPPP than individuals.  In fact most of the critical comments come from individuals.   The reason for this is that the LLTNPA, through the NPPP, is not asking its public sector partners to do anything further than what is already planned.  What a relief given austerity induced budget cuts!   It suits their narrow self-interests to sign up quick and not think about really needs to be done to make this a National Park worthy of the name.   Fundamental challenges, such as how to change the industrial forestry that has wrecked Cowal, are simply avoided.

 

Even so, its noticeable how certain key public sector partners have failed to respond.   Cllr George Freeman lamented the failure of his own Council, many of the community councils and of the community trusts (which are supposed to be a key means of attracting investment to the National Park) to respond.   He was right to do so.  The LLTNPA are supposed to be working with Argyll and Bute Council to tackle litter but there is obviously no strategic liaison about this.    Later on in the meeting we heard that at Luss part of the litter problem is that Argyll and Bute are responsible for the car park, the LLTNPA for the grassy areas around it and Luss Estates for the shop and no-one can agree who is responsible for what.   My jaw dropped, but the reason for this is now fairly clear, Argyll and Bute are simply not engaging:  their new Councillors on the Board should just get stuck in and bang some heads together.

 

Hazel Sorrell, former councillor for West Dunbartonshire whom I have never heard speak at a Board Meeting (in two years), did not take the opportunity to mention the failure of her own Council to respond.  Perhaps she and they preferred not to draw attention to Flamingo Land? (the delivery of the Riverside site development being one of the few concrete actions named in the plan).

 

What these examples illustrate is not just the complete ineffectiveness of councillors on the LLTNPA at present but also that these councillors council potentially have a crucial role in enabling effective joint work between the LLTNPA and Councils.   With five new council members, the Board has a great opportunity to look at how they could improve partnership working with local authorities.

 

The most positive aspect of the NPPP paper was the Appendix with all the consultation responses (453 pages worth).  In the Your Park consultation  the responses were only made public through Freedom of Information and, as far as I am aware, Board Members were never allowed to see what people had actually said.  While at the meeting not a single Board Member referred to these responses – the sheer number are daunting – many of them have some very interesting things to say about where the National Park is going wrong and suggestions for how it could improve which I will cover in future posts.  Board members should be advised to read them and use the feedback to make a NPPP worthy of the name.

September 17, 2017 Nick Kempe 2 comments

In the paper on the camping byelaws presented at the June LLTNPA Board Meeting, it was reported that:

“86% of people said that they would be quite likely or very likely to recommend staying over in a camping/motorhome permit area”

and

“82% of people found it easy or very easy to find their permit area”.  

 

Board Members treated this as a “killer fact” for, if such a high percentage of people filling in the permit feedback survey are so happy to recommend staying in a permit area, that suggests they have accepted the removal of access rights by the Park and think the permit zones a reasonable replacement.    Both these figures are repeated (its strange that the the percentage rate has not altered at all despite the number of returned surveys increasing from 431 to 1066) in the Your Park Update (see here)  to the September Board meeting tomorrow.  This post argues it is essential that the Board subject these figures to critical scrutiny rather than accept, as they did at the last meeting, that they prove all is well.

 

Having visited the majority of the camping permit areas (many of which have been featured on parkswatch) and to have found them underwater, overrun with brambles, without any flat areas for camping etc etc I found it quite frankly incredible that 86% of people returning survey forms had said they would recommend staying in a camping or campervan permit home area.   So, I asked for the data under Freedom of Information and received it in the form of two Pdf files, one giving the total bookings for each permit area EIR 2017-055 Appendix A Permit Area Bookings 1Mar17 to 26Jun17 and the other giving the breakdown of survey responses EIR 2017-055 Appendix B Permit Area Feedback 1Mar17 to 26Jun17.   By separating the data in this way, the Park has made it much harder for anyone to do an independent proper overall analysis of the data.   However, to demonstrate there is a serious issue with the data – which the Park Board needs to explain – I will compare feedback responses from what I regard as one of the worst permit areas, Coilessan Glen, with one of the best, Invertrossachs Rd on the south side of Loch Venachar.

 

Which is best – Coilessan or Invertrossachs Rd permit area?

 

My assumption, and I think it is reasonable because its how Trip Advisor and other accommodation websites work, is that you would expect a variation in how people rate different permit areas, with some scoring much more highly than others.    In camping terms you would expect people to rate this:

Most of the area on the west shore of the Loch Long south of Ardgarten which makes up the Coilessan permit area looks like this
There are two or three small open areas at Coilessan but they are all sloping, even more though than it appears in this photograph
The dryest and flattest area I could find at Coilessan appeared to have been used for camping – it would have been hard to pitch a tent in a way to avoid sleeping on tree roots

differently to this:

The largest flat grassy area at Invertrossachs Drive, which I visited on the day of the last Board Meeting in Callander, had been clearly used by campers
It also appeared some people had camped on the beach at Invertrossachs Drive. Unlike many of the permit zones there are places on the beach which are flat and sandy, ie suitable for pitching tents. Note another patch of grassy sward left side of photo.

Now Invertrossachs Rd permit area is far from perfect (there are places in the zone where it would be very hard to camp) but I hope I have shown enough to demonstrate why I think it is a much better place to camp than Coilessan Glen.    Encapsulated in words, rather than pictures, I would point to the outlook/scenery (its hard to see much from out of the conifer forest at Coilessan), the vegetation (open native woodland at Invertrossachs) and the availability of dry flat grassy places to pitch a tent.  And its not just me that thinks this: I spoke to someone doing maintenance work near the Coilessan site who told me he had heard there had been complaints about the site (and also about the history of anti-social behaviour there).

 

The message from the feedback data supplied by the LLTNPA however gives a very different message:

According to the LLTNPA people rated Coilessan (90% favourable) far more highly than Invertrossachs Drive (71% favourable). (NB By the June Board meeting 55 people had camped at Coilessan (Loch Long) with 10 submitting feedback forms while 66 had camped Invertrossachs Drive so the level of use appears broadly comparable).

 

What is the explanation for people rating Coilessan more highly than Invertrossachs Rd?

I have been able to come up with a number of explanations for this, including:

  • I am completely unrepresentative of campers and most campers really don’t care about the scenery or having a flat, grassy area to camp, all they are interested in is getting high on drugs and alcohol.    Now, I would have to say Coilessan scores well on that count.  Unlike most of the other permit areas its well away from the public road (so is difficult to police) and been the scene of difficulties in the past (which is why the camping management zone was extended south down Loch Long).  While the photo tells a tale, people who are too intoxicated to notice what they are camping on are, I suspect, highly unlikely to take the time to fill in a survey form:
    One part of the Coilessan camping permit zone is site to half a dozen half burned out tree stumps but had nowhere you could have pitched a tent. If people party here, its in the open, or rather under the trees and you don’t need a permit for that.

     

  • Some other site specific factor explains why people did not like Invertrossachs Rd so much (its one of most lowly rated of all permit areas).   One possible such explanation is the unlawful restriction of access rights on the south side of the road (photo below), which Park Rangers must see every day while conduct permit checking trips.  Its probably not the sign that bothers people but rather than the fence which makes it much harder to go into the woods to have a crap.  Perhaps campers are actually far more responsible than the LLTNPA has tried to suggest and rate camping areas by the availability of places to “go”?
These signs contravene our access rights and the sign about shooting being in progress is a lie for all but a few hours of the year.  Welcome to the brave new world of the countryside, where your every move is caught on camera.  LLTNPA Rangers must pass this sign every day as part of their policing of the camping management zones – its not unreasonable to ask what have they done about it?
  • Grassy camping areas have become irrelevant with airbeds.  Perhaps, but air beds slide on  sloping ground and not much use at Coilessan or on many of the sloping pebbly beaches, as at Firkin Point.
  • The data has somehow been corrupted:  for example, perhaps the system was initially tested by someone entering test data for each permit site and who ticked the box “very likely” to recommend the permit areas to others and then forgot to remove all this data.  That might help explain the generally high level of positive feedback to the survey but would not explain why a poor site rated more highly than a good one.
  • The Invertrossachs Rd feedback data is correct, its the Coilessan data which is wildly wrong – that I could believe!   Invertrossachs Rd is one of better places to camp (despite no access to toilets, no bins and limited parking) and 75% favourable is credible for this site.  Its the other ratings that are not.

    Litter which campers had collected – there was an airbed at top of bag – but was abandoned, presumably because there were no bins to put it in.
  • The data has somehow been influenced, for example, Rangers on their rounds when talking to people ask those who are positive about the zones to fill in the survey form.
  • And lastly, the figures have been made up (and by someone who knew so little about camping they did not think to consider people might rate different camping places differently)

I don’t think any of these explanations, apart from the last two, can account for the differences in feedback received for Coilessan and Invertrossachs although elements of each might play a role in understanding why people might rate camping zones as they do.

 

Its worth stressing here that the issue is NOT just about one camping permit area.  Firkin Point Zone D  (see here)  which other campers have told me they thought was terrible and where I challenged Board Members to come camping, received a 100% very likely to recommend rating (only two campers made the return).   Meanwhile, Inveruglas, which up until June was covered in brambles and has hardly anywhere flat to camp received a 90% “very likely to recommend” rating.   There are many other examples.

 

What needs to happen

 

The Board needs to ask staff to explain the statistics reported from the feedback survey forms and in particular why there appears to be no relationship between “positive” responses and what the permit zones are like to camp in.  If staff are unable to provide a satisfactory explanation, the Board should commission an independent investigation for why people are apparently rating terrible places to camp so highly and commit to finding a credible explanation for its statistics with a view to developing an independent and objective feedback mechanism.

 

The wider issue is the one I referred to last week, how does the LLTNPA rediscover its sense of purpose?   (see here)   To provide proper critical scrutiny, the LLTNPA Board needs get out more.  It would be interesting to know how many of the Park’s Board Members would, after camping in some of the permit zones featured on parkswatch, recommend the experience to the public.  If the Board got out more – preferably accompanied by people with varying points of view so they learned rather than seeing what they want to see – I think they might also question some other aspects not just of the Your Park update paper (which is basically an attempt to sell the camping byelaws as a success and which I will analyse further in another post), but other papers being presented to the meeting tomorrow (Monday).

September 12, 2017 Nick Kempe 3 comments
Extract from paper on “Matters Arising” for Board Meeting 18th September, the decision as recorded in the minutes on the left

An extraordinary discussion took place at the end of the June Board meeting of the Loch Lomond and Trossachs National Park Authority in which Councillor James Robb, one of several councillors who will be leaving the Board this Autumn (see here),  proposed that the number of Board Members should be cut.  The reason for the proposal basically was that he felt there was very little for Board members to do, consequently the Board could operate with far fewer members  and cutting numbers would save money.

 

There followed a very open discussion – which would never have taken place in public under the aegis of the previous convener Linda McKay (all credit to new convener James Stuart) – in which basically Board numbers agreed with the proposal (it was clear during the discussion that Cllr Robb had discussed the proposal with some of the other councillors on the Board).   Hence the decision of the meeting, recorded in the minute, to approach the Minister and ask for a suspension of new appointments until numbers on the Board could be reviewed.

 

Unsurprisingly the proposal has been rejected by the Scottish Government. Our National Park legislation requires the Board to be composed of three types of members, those appointed by Ministers, those nominated by local authorities and directly elected members and the numbers of the three categories of Board Member to balance.   While reducing numbers of councillors and Ministerial nominees on the Board would be relatively simple, reducing the number of directly elected members would require electoral boundaries to be completely withdrawn, a complex business.  Also, I suspect the Scottish Government wants to avoid opening up the possibility of any debate in the Scottish Parliament about new or existing National Parks which would be created if the existing legislation was to be amended.

 

While I welcomed the open discussion and the honesty of Board Members – its not many people who voluntarily vote to make the posts they are leaving redundant – what was depressing was that not a single Board Member made a case for keeping Board Members, based not just on what they do at present but on what they could and should be doing.    It appeared from the discussion that Board Members feel they serve no useful purpose.

 

Now I can understand why that might have happened.  First, when Mike Cantlay was chair and Fiona Logan was Chief Executive, Board Members were  firmly told they were not to get involved in operational matters.   So Board Members who knew about footpaths, were told not to support staff on this and those that knew about conservation were told to keep clear of that while those simply with an interest in their area were also told to keep at arms length.    The reason for having Board Members with expertise or democratically elected and nominated Board Members disappeared.

 

Second, to keep Board Members occupied, Mike Cantlay and Fiona Logan then introduced the practice of monthly briefing sessions and seminars as a  way for Board Members to earn their £200 a day.  These meetings, rather than helping Board Members to speak freely, actually became a way of controlling them and under the next convener Linda McKay were turned into secret decision making forums which among other things developed the camping byelaws.   The National Park Board became increasingly autocratic and the result has been Board Members have been left unable to see a role for themselves.

 

What is very sad though is that Board Members have become so neutered that even under the new more open regime of James Stuart they cannot see a useful role for themselves.    I believe there are plenty of opportunities for the Board both to start showing leadership and also to start putting proper governance arrangements in place.  I think this should be based around a number of  areas of activity:

  1. Board Members should know what is happening on the ground and being done in their name.    This means them getting out to see everything from the hydro tracks that are destroying the National Park landscape to the inappropriate areas designated as “camping permit zones”.  This would enable them to make informed inputs into policy development and to scrutinise papers properly.   The current Board is totally failing to do this,  is  disconnected from what is happening on the ground and as a result cannot do its job properly.
  2. Elected Board Members, both councillors and those directly elected,  should be engaging with the local communities they serve and helping to articulate community concerns and aspirations.  That they are failing to do so I think was epitomised by the case of former Councillor Fergus Wood, who was resoundly defeated in the last election, in no small part because he had pressed ahead with a proposal for a campsite without consulting local people.  The same elected representatives for Strathard totally failed to listen to the concerns of the local community about the size of the Loch Chon campsite.  When push comes to shove, the democratically elected representatives have always listened to their Chief Executive before the communities they serve.   The large democratic deficit in the National Park needs to be closed and that will take time and effort.
  3. Board Members should be engaging with national recreational and conservation interests – the people with expertise in the Park’s statutory objectives to promote public enjoyment and conservation.  Had they been doing so I don’t think we would have ended up with  the camping byelaws or the land management practices which still dominate much of the National Park and are destroying its conservation value (whether intensive forestry with clearfell or overgrazing by sheep and deer).  Again, this will take time and effort.
  4. Board Members should be taking a leadership role to ensure effective partnership working with other public sector organisations.  I find it amazing that Councillor Members, having called a year ago for more effective working with local authorities to address litter (noted again in the minutes as an issue) do not appear to have done anything to assist with this process.   They appear to have no idea of how to do this and to have lost sight of the reason they form a third of the membership is to ensure effective joint work with their councils.  If the structures aren’t there, its their job to create them and they need to start doing so.   However, the issue of effective co-ordination goes far beyond local authorities.  The Board needs to have members meeting and networked with other public authorities such as the Forestry Commission, SNH  and SEPA and to have links with delivery organisations like Sustrans and Transport Scotland .   If they started doing so, the National Park might have a chance of delivering a partnership plan which made a real difference, instead of each sector just carrying on as it is managing what is left of ever decreasing public sector budgets.

 

It will be interesting to see if the Board Meeting next week has any discussion in public about creating a meaningful role for Board Members.  It appear from the fact that senior staff have marked this matter arising as “Closed” that they don’t want this to happen.

 

 

September 11, 2017 Nick Kempe 4 comments
Looking from the pole which marks the centre of the proposed new town at an An Camas Mor towards the Lairig Ghru

Anyone who tries to understand human affairs from a global perspective will have probably greeted  last week’s announcement that a poll of readers of the Rough Guides had found Scotland to be the most beautiful country in the world with a deep shrug.

 

It is of course just a piece of marketing based on a very selective sample of people who are able to travel and choose to visit certain countries.   That Scotland came out top beating Canada, New Zealand and South Africa says a lot.  This was a poll of people from the English speaking world with what appear to be anglo-saxon perspectives.   A month ago I was in the Dolomites, where its not hard to find marketing blurb claiming that the Dolomites are indeed the most beautiful place in the world.  I wonder how many Italians were included in this poll?       And what about he mass of humanity who live in the third world, often much closer to the natural environment than we do, but whose experience of beauty is being destroyed by logging companies, mines and agricultural plantations which also displace them from the land.

 

Polls like this are not just an indulgence which should be accepted with a shrug.  They feed a racist view of the world, where we rarely stop long enough to consider what people from elsewhere and who are not like us may think, and which is blind to what capitalism is doing in our name to other parts of the world.  They also feed a privileged view of Scotland, which treats a few unspoiled land and city scapes (from Skye to Edinburgh) as epitomising the country and is blind to the many far from beautiful places where people actually live, with all the impact that has for health and human happiness.   Social injustice, which is everywhere and growing, is never beautiful.

 

Even if we ignore, like the tourists, the ugly bits of Scotland, objectively, how can you compare the best bits, the beauty that lies in our hills, lochs and western seaboard with the high mountains of the Himalaya or the deserts of Australia or the savannah in Africa?   People can only answer questions about what they know about.   I love Scotland but then its the landscape of home.   If you polled everyone in the world about what was the most beautiful country I am pretty certain China, having the most people, would come out top and Scotland, being small, would come out way down the list.  That’s not much use to Visit Scotland though, in their mission to promote Scotland, so the hype and privileged world view that goes with it will continue.

 

Polls like this also ignore the reality that across the world humans are destroying the natural environment and natural beauty at ever increasing rates and although “peak” destruction in Scotland took place something like 200 years ago, it is continuing with the say-so, nay encouragement, of those in power.    The Herald in its coverage of the story  (see here) gave a wonderful illustration of the complacency of the current Scottish Government:

 

“A Scottish Government spokeswoman said its policies ensure developments are sited at appropriate locations”.  

 

Really?  It seems to me that only someone who had never visited An Camas Mor (photo above) or was blinded by business, greed and profit could ever say that.

 

And that is my greatest concerns about this poll, it lets those in power off the hook and will undermine our National Parks, which were set up to protect the landscape and find more sustainable ways for humans to relate to nature.  The thinking goes like this……..

 

….if Scotland is the most beautiful country in the world, then:

  • people cannot be really concerned about the proliferation of hydro tracks which has destroyed the landscape of Glen Falloch and Glen Dochart for example with the blessing of the Loch Lomond and Trossachs National Park Authority
  • surely, with so much beauty, we can easily afford to lose a few areas in our National Parks to development, whether to the An Camas Mor new town, Flamingo Land at Balloch or Natural Retreats at Cairngorm
  • people cannot be really concerned about how our landscapes are treated on a day to day basis, whether by Highlands and Islands Entrerprise at Cairngorm or grouse moor owners……….in fact, perhaps our landowners are right, its these land management practices which make the country beautiful
  • why on earth did parkswatch make a fuss about the beech trees on Inchtavannach being felled in the name of science?   This poll came after that felling and all the other destruction covered in the last 18 months and that doesn’t seem to have altered people’s perceptions of Scotland.
  • this just shows that people aren’t very concerned about the visual impact of blanket conifer afforestation and subsequent clearfelling by the Forestry Commission so we can just let these practices continue in the National Park

 

The point that our politicians and powers that be must not be allowed to forget is that, whatever Scotland’s position in the world, our National Parks have, since their creation, presided over a further degradation of the landscapes they were set up to protect.  What we need is not international opinion polls, which simply provide an excuse for our National Parks to continue as they are present, but a real change in direction which puts landscape and social justice first.