Tag: camping

By Ross MacBeath

Loch Chon infrastructure

Driving along the B829 where trees are coming into full boom after the recent rain, the greater area of natural woodlands has greened up with mosses and other vegetation moving into their main growing season. Nowhere is this more obvious that at the Loch Chon site where easy access to the ancient woodland has been opened up with the campsite paths.  Here nature is fighting back after the trauma of machinery driving  unchecked over the hillside (see here) but even she can’t erase the scar of sterile (perhaps treated) forest bark at the approach to almost every camping pitch in the site.  An act of wanton environmental damage inflicted for no good reason in this sensitive eco-system.

 

 

On arriving at the gate, happy to see it open after previous experiences, we were met with an unfinished road surface.  At least I hope it’s unfinished with it’s uneven potholed surface, strewn with loose hardcore.

 

Expectations dashed by first impressions

 

The good news is the bin store is complete, the bad news is its a 2.7 metre high structure which dominates the vista.  It doesn’t even have a maze to hide the 6 or so bins now in place, remaining in full view from the car park opposite.   This is bin overkill, even if the Park’s projected 90% occupancy of the campsite should ever prove to be true, its too high, and an unnecessary intrusion in this natural setting.

 

Ranger Base and non compliant bin store
This image was taken 10th April 2017, Note:green bins now in store, 13/05/2017

It would  have made so much more sense to position the bins beside the toilets (rather than the office), where they would be more convenient for campsite users, but campers have never been a priority in this development.

 

Perhaps it’s more important for the refuse collectors to save the additional few hundred metres drive than to hide this monstrosity out of the way.  It’s a disastrous first impression of the site and is not what was discussed at preliminary meetings with the local community.

 

The bin store is not on the plans – a Breach of Planning Consent?

Following the granting of planning permission,  National Park planning staff granted a Non Material Variation to the plans.  Neither the original plans or the letter mention a bin store or any other structure at this location – the document NMV decision letter final refers.


The ‘S’ on the plan indicates the location of the Ranger Base/Store container.

 

 

Well there you have it.   The National Park Authority have breached their own planning consent while as the Planning Authority, they have so far failed to any take enforcement action.  In fact I have found out that the Planning Authority have not even made a compliance check on this planning application.  A surprising oversight for a £350k plus project which is a sensitive development in ancient woodland.

It seems the Park Authority also grant themselves special dispensation when it comes to planning compliance.

 

Containers!   Plunging our National Parks into mediocrity

 

Next door to the bins, the Ranger Base as it is affectionately known, is just a container or, more correctly 1/2 a container, the other 1/2 being a store for fire pits, wood and other sundries.  Currently it also serves as the main drinking water supply cupboard, more of which shortly.

 

Nevertheless the Ranger Base is a home from home and surely much appreciated by the overworked rangers traveling in from afar.  What with all their new enforcement duties it must give them time to reflect on what being a Ranger is really about.  It’s reminiscent of a sales office at a housing development, probably because that’s what it was.  The Park really should give priority  to toning down the white wall and the clinical door – its as if the National Park Board, whose members apparently visited the site, have decided that rural charm has no longer any place in our National Parks.

 

The container shows it’s true nature and it’s not natural – Fail

 

The last memory of your camping experience as you leave this site is this view of the office (below),  a shipping container more at home in Tilbury docks, than a sympathetic camping development.  It’s another one in the eye for the National Park’s Marketing Department.

 

 

It’s another breach in planning consent – Fail

This end elevation in the photo above is very different to the elevation shown in the engineering drawings for this container contained in the plans.  It did seem odd at the time the planning department allowed a drawing to be approved on their system that showed only one end elevation, not both, a very unusual situation.  What was not shown  is what we see here, a considerably larger and obtrusive industrialised door. The more cynical among us could be forgiven for believing this omission from the plans was not accidental.

 

Other apparent breaches of the planning consent in respect of the containers include: the construction method of the cladding, which is not mounted as shown in the plans; the omission of the concrete embedded posts from all containers on the site; and the hardcore which has not been graded to form a rise in ground to door level.

 

Site uncompleted – Fail

 

What is wrong with the Park Authority?    It would seem they lack the commitment to finish anything to do with this project and it is the local community and park users that have to put up with the mediocre result.

 

Why are the logs in the image above still lying on site, they interfere with the vegetation regrowth and will result in another bare patch when removed?  If they must be stored, do it on hard standing, better still in the Forestry Commission car park along the road.

 

Many of the pitches remain unusable, or just too small with slope remaining a problem as does wet or rough ground.

 

Talking of bare patches it would seem that reseeding work with the specified seed mix has not taken place, this should have been completed before the start of the growing season and should be carried out immediately to provide effective restoration in this season.

 

The use of containers sets a low tone for the whole development  – Fail

 

The design of this development is just not in keeping with the ethos of National Parks.  The LLTNPA really should take a leaf out of the Forestry Commission’s book when it comes to designing quality facilities.

 

Toilets

 

Compare the toilet block in Forest Drive which, when you see it, looks right to the abysmal containers at Loch Chon which have poor visual appeal and lower the tone of an otherwise beautiful woodland setting. It’s depressing to see Scottish Tourism dragged down on the world stage.

 

Forestry Commission – Shelter & Charm LLTNPA  – Containers, no shelter no charm

The Forestry Commission’s rustic solution to toilet blocks, shown on the left hand image was the preferred style choice at Strathard community meetings and what most people would wish to see in our National Park, in stark contrast to the “industrial” containers the Park Authority favours. It’s time the Park Authority started listening to its Partners instead of running roughshod over them.

 

The Park Authority’s  choice shows a lack of commitment to the success of this project.  The temporary nature of the installation means it can be moved to another site if required, or taken away in the winter,  a fact alluded to at the community consultations by Gordon Watson their Chief Executive.   This has been given precedence over all other design requirements with dire consequences.

 

The toilet blocks are containers like the ranger station, with high security metal doors to each “cell” opening in direct view of the car park opposite, offering no privacy to users. This is surely a breach of regulations.

 

No shelter for toilets queues in wet and windy weather  – Fail

 

Then the Park Authority’s failure to provide anything in the way of shelter is a serious design fault.  No consideration has been given to the needs of visitors who find themselves caught in the rain when all toilets are occupied, with nowhere to take cover.  Getting soaked  to the skin is difficult to recover from when camping and should be avoided.  At very least a canopy should have been provided across a widened gap between the two containers but of course what was really required was some forethought and a custom designed visitor toilet block with some visitor friendly features instead of this minimalist offering.

 

One camper remarked in its defence, “it’s not too bad” and that sums up the aspirations of the current National Park Board for new developments, “Not too Bad”.  Sadly at this site,  they’re often failing to achieve even that.

 

Dark Skies a Project to which the Park Authority just pays lip service – Fail

 

The inappropriate plastic bulkhead light fittings have been chosen with no consideration of the specification laid out in International Dark-Sky Association guidelines that the National Park claim to be promoting (see here).   The Park Authority are failing to make capital of this ideal site located away from any light pollution except for that of their own making.

 

Since the toilet block image (above) was taken, the fittings have been recessed into the wood cladding but still fail to comply with the dark skies requirement.  Light fittings should shade upward light emissions while other light output should be directed downwards by internal reflectors not flooding the hill side opposite and sky as is the case here.

 

Water Supply

The National Parks Chief Chief Executive Gordon Watson continues to preside over the issuing of false information in connection with the availability of drinking water at Loch Chon and the completion status of the site.

This statement is currently posted on the LLTNP blog By on
(see here under the section “Teething Issues”)

 

“Teething issues

Of course, with any new system or facility there will always be snagging issues. At our new Loch Chon campsite, the running water was unavailable for a few days after opening due to a temporary problem with the new connection. We immediately put in place contingency plans for anyone still wishing to camp so that they still had water and toilets at all times. The connection problem was fixed and the hot and cold water is up and running”

 

Then he assures us further down the post

 

“The most important thing is that we are responding quickly to any issues that arise and despite these snags”

 

Clearly the National Park Authority are failing to correct issues in good time.

 

 

Bottled water for drinking and dish washing? – Water supply faulty – Fail.

The National Park Authority first of all claimed the water supply had been working with just a short period out of action, but evidence collected on our many visits show that to be untrue.

The Park have now changed their story to say the contractor provided an external water supply during the period since opening.   On the  6 occasions I have personally visited since the site opened,  on 4 visits there was no drinking water and on 3 no water in the toilets. On another two occasions where a a local resident attended, there was no drinking water.  In total this represents 2 months without a contractor supply and 6 weeks without drinking water.

 

Incredibly on my 6th visit water was being supplied in plastic bottles – which raises the question once more, why?  (see here for recent history of the water issue)

 

In any case to recap on the real problem,  With a reported £100,000 spend, even before planning consent, the hydrology of the stream they chose to use as the water supply should have been monitored over the previous year’s cycle to identify any periods where the stream levels were low or dried up before selecting it as a source. The question needs to asked why would the planning department grant permission for a campsite without a guaranteed water supply?  It’s beyond comprehension.  In fact when you look at the plans, there is no detail of the water intake design or specification for the size of the header tank, reservoir or pool that would be a requirement  for a successful water supply. The upshot has been there is only a trickle of water in the stream in dry spells which goes a long way to explaining the intermittent nature of water supply.

 

 

After each visit I have made, I have pointed out the short comings to the Park who have then modified the installation to mitigate each issue but as of yet have failed to take on board what is required to be done.  After the dry spell at the beginning of May 2017, the water level dropped so low air could be drawn into the intake pipe.  The Park has responded by creating a slightly more substantial dam using sandbags instead of the the pebbles and rocks of the last one.  This is getting them through by the skin of their teeth, providing  unfiltered water for the toilets and wash hand basins but has not provided the solution to the drinking water problem.

I think SEPA should have something to say about interfering with culverts in this way.

 

Intake pipe without strainer – Fail

 

The intake pipe remains open to the flow of water which poses serious risks for debris to enter the system with potential for blockages (see Solution here).

 

The sandbag issue aside, the problem with the water supply is even more serious, it’s a design fault which the Park Authority have been aware of from before the 1st March 2017 but for reasons known only to them have failed to correct. The problem is simple, the intake pipe being below the bridge is effectively underground and the level between the intake and outlet at the taps is too small for water to flow as this diagram explains.

 

Diagram showing principle of water head expaiming pressure loss in system

 

The solution is equally simple,  assuming everything else is equal and no damage has been done to the plant through running it without a water feed.  Raise the intake pipe level by moving it higher.  There is a natural reservoir just upstream at the base of a waterfall, in the form of a pool which provides a natural header tank, something that’s required for all such installations to ensure as continuous supply.  They could of courses go one better and take the feed from above the waterfall giving even more gain in elevation and therefore water pressure.   Campers will just have to wait with baited breath and struggle without effective dish washing using instead 330 ml bottles of water to somehow fill the massive trough of a sink. With no reliable water supply for over three months, questions need to be asked what are the Park Board going to do about it and why have the planning department not enforced this requirement?  What other campsites are allowed to operate without running water?

 

Drawings missing from the Planning Portal

 

Inexplicably a header tank was never a feature of the Park Authorities design.  In fact there is no design for any water supply intake.  There was a reference to the intake location on a previously available drawing which has been removed from the remaining document set (18 documents) on their planning portal, another instance of lack of transparency in this project and indeed with many other Park projects.

 

A new screening fence has been fitted behind the toilets – success!

The protruding tops of sewerage works and other toilet related plumbing is now screened from view hiding the surface installation of inspections chambers which should have been hidden below ground in the first place.

 

Disabled pitches the ongoing saga

 

Disabled Pitch Update – dirt pitch surfaces are not acceptable – Continued Fail

 

Disabled pitches are part of another key Park Authority project promoting access for disabled users to National Park facilities.  Our original post (see here) highlighted the disgraceful  pitches that were provided for disabled access.  This obviously caused alarm bells to ring and improvements were made almost immediately, but how the originals were ever deemed suitable by Park Board members when they visited the site, says something about the Board’s attention to detail or, some might say, total disinterest in the provision of adequate disabled facilities.

 

Dirt surface of disabled pitch 8 very unplesant in the rain
Disabled Pitch 8 13/05/2017, barely able to contain a 3 man tent with unconstrained edges posing hazards

 

The original state of pitch 8, promoted for disabled use together with pitch 9 due to their accessibility  for toilets and car park was disgraceful. (See Video Here)   They were built in a water course cut out from a bramble patch on a wet and muddy area prone to flooding. This modified pitch has been created over the top of that area by building it up on a hardcore plinth with soil covering a hexagonal geo-membrane and provides a marked improvement on the old effort in many ways but fails in an important number of others.

Fail 1:In building up this pitch the edges of the soil  should have been constrained to stop any further spread out over the surrounding vegetation.  Soil spread is already evident through exposure of the plastic mesh which is creating a trip hazard.  Further, the edge of the pitch drops off rapidly close to the tent entrance and again poses a real risk of tripping or falling down the slope.

 

Fail 2 – as with so many other pitches  in this development, this pitch is just too small, for disabled users, some of whom may need a larger tent for access or to take a wheelchair or other aids inside. Here we see a 3 man tent pushed to the back and side edges of the pitch so it will fit and still leave room to get in and out. With table and chairs filling the remainder of the pitch, the fire pan and additional seating have had to go on the path on the other side of the tent.  This is effectively the largest tent this pitch will take and even then it is cramped.  This makes the pitch useless for a larger tent suitable for families.

 

Fail 3 – This tent has been erected without the use of guy lines which has only been possible because its a self supporting tent.  Of course not using guy lines is unusual as they are important for the stability of the tent structure and a necessity in the wind where damage to the tent and poles can occur if not tensioned properly with the possibility of the tent being blown away.   Fitting guy lines at this pitch is problematic due to the hard core path to the side and front of the tent and the area to the back of the tent is the diverted water course making pegging out difficult if not impossible at times.
The other issue of course is that guy lines impede the movement of people around the pitch particularly in  the case of a disabled user with a wheel chair.or requiring assistance to get in and out of the tent  So the small size of this pitch is of serious concern and brings into questions it’s suitability as a easy access pitch pitch.for disabled users.

 

Fail 4: It is now well over a month since this “improved pitch surface” was provided to pitches 8 and 9 and they have not been seeded with the recommended seed mix stated in the planning application, This pitch should have a grass surface not dirt.  The occupants of the tent in the above image explained heavy rain over night and early morning  wet the dirt surface resulting in it being carried into the tent on muddy foot wear.

 

Pitch 9 as the second pitch assigned for disabled and easy access and is only a little better.

 

Pitch 9l It'sdirty hard surface remains unseeded and unsuitable for use

 

Other than the fact it’s is easier to peg out guy lines as it sits back from the path.  The dirt surface remains a problem carrying a muddy mess into the sleeping area in wet weather but has also compressed below the level of the Geo-membrane leaving an unsuitably hard surface for pitching a tent.

 

Perforation of the tent base is likely while the resultant surface is also very uncomfortable making it both painful to kneel on this surface and creating a risk of physical injury.

 

As before the pitch is too small for anything more than a three man tent.mitigated some what by the fact there is other ground around for occupants..

 

This path also fails to comply with the planning consent, the aggregate should not be spread over vegetation and it should be be bounded by a seeded, graded soil bank to allow it to blend in with the land scape.

 

What needs to be done.

  • As a matter of urgency the planning enforcement team need to visit this site and make the applicant comply with the planning consent.
  • Complete snagging – the snagging list is sizable.
  • Correct water supply as a matter of urgency. The Park Authority need look no further than this simple solution at the Cononish Goldmine supply.  A solution they and the planning authority should be aware of as they sanctioned it.SImple but effective header tank - Cononish Goldmine Simple Strainer Solution - Cononish Goldmine supplyNote also the strainer on the end of the pipe another fiendishly simple solution, a copper stopper pipe with some nail holes.  A strainer requires to be fitted at Loch Chon site to avoid future supply failures.
  • Urgently correct surface issues on disabled pitches and seed with grass
  • Pitch size needs to be increased at many pitches and some surfaces constrained – disabled pitches 8 and 9 are a priority.
  • Where pitch size cannot be increased due to poor site selection, an auxiliary area beside the pitch should be created so campsite users can sit and cook by their tents.
    This would probably require a new planning application and not be a Non Material Variation
  • Remove unsuitable pitches from the booking system
  • Change booking system and include pitch descriptions and photographs, especially in connection with the size of tent and the number occupants the pitch can accommodate.
  • Complete seeding process so recovery of damaged areas can be achieved this season
  • Rethink the use of sand as a pitch surface, it’s ridiculous and gets carried into the tent.
  • Paths constructed on spongy ground.needs to be dug out and consolidated as per the statement in the planning consent.- 3 locations identified so far.
  • Paths need to be brought  up to the specification of the planning consent with respect to edge grading and restoration of edges through seeding.
Caravan parked west Loch Lomond May 2017

Over the last month, a number of  examples have come to light about the LLTNPA’s inequitable application of the byelaws, the most notable being that Park staff have been told not to apply the byelaws to people in caravans (see here).    This post will look at the Loch Lomond and Trossachs Authority’s selective application of the camping byelaws which I believe is contrary to natural justice and human rights.

The LLTNPA’s continued attempt to enforce the camping byelaws against campervans

 

Regular readers will know that the byelaws make it an offence to sleep overnight in a vehicle unless this is on a road.  The legal definition of a vehicle includes both campervans and caravans (more on why the LLTNPA has decided to exempt caravans below) while the legal definition of a road includes their verges and private roads over which people have a right of passage.   This means campervans do not need permits in permit areas which are part of the road system, as is the case with the laybys on north Loch Earn.    The LLTNPA has obviously taken note as yesterday I spotted this notice (below) at Inveruglas which had not been there the week before.

 

The notice demonstrates how far senior management at the Loch Lomond and Trossachs Authority are out of control and making up the law as they go along.   The purpose of LLTNPA’s claim that there is “no public right of passage between 7pm and 7am” is clearly to try and stop campervan and motorhome owners claiming they do not need to a permit to stop off overnight here because it is part of the road system.    The LLTNPA however have NO legal power to suspend public rights of passage on a whim and are acting ultra vires.   They need to be held to account.  This sign in itself warrants a judicial review of the entire manner in which the LLTNPA has been implementing the byelaws.

 

Land within the camping management zones exempt from the byelaws

 

Land has also been exempted from the byelaws in an arbitrary manner.   In order to allow existing campsites within the camping management zones to continue to operate the LLTNPA and Scottish Government approved the following clause:

 

(10) These byelaws shall not apply to areas within Management Zones which have been exempted from the application of any provision of these byelaws by the Authority from time to time.

 

On 5th April I asked the LLTNPA what land they had exempted from the byelaws and, on 4th May,  received this response together with a template of an exemption letter they had sent to landowners.   The response shows the land exempt from the byelaws consists entirely of caravan/campsites confirming that the purpose of byelaw 10 was to allow formal campsites to continue to operate and the intention was not to allow camping and staying overnight in vehicles to continue elsewhere.

 

The list of exempted campsites makes interesting reading.  It fails to include at least two existing campsites:

 

 

The first is the Loch Lomond Holiday Park, between Inveruglas and Ardlui, on the west shore of Loch Lomond.   This is ironic because one of the main aims of the camping byelaws on the west shore of Loch Lomond appears to have been to try and force people to use formal campsites in order to benefit business.    Indeed the Loch Lomond Holiday Park obtained planning permission last summer for new motor home places to take advantage of the business bonanza promised by the camping byelaws – hence the sign (top right) in the photo.    Unfortunately, any motorhomer handing over their cash to Loch Lomond Holiday Park has been committing a criminal offence!

 

The second missing campsite is even more extraordinary,  the Loch Lomond and Trossachs National Park Authority’s own campsite at Loch Chon.   Loch Chon, is a campsite, not a permit area.  The need for LLTNPA to exempt its own land is demonstrated by the fact that the other campsite it owns, the Cabin at Loch Lubnaig, is included in the list of sites it has exempted.    So,  people forking out £7 a night to stay at Loch Chon have been committing a criminal offence!   I trust that the LLTNPA will now issue a public apology and write to all people who have a booked a place at Loch Chon with a personal apology and providing assurances that they will not be prosecuted under the camping byelaws.

 

If you think that is bad,  the LLTNPA has also decided on a whim to exclude other land from application of the byelaws without any applications for examption at all.   Evidence for this is found in the excellent newsletter of the Buchanan Community Council, the Communicator (see here).   The May issue contained an update on the camping byelaws, the last sentence of which reads:

 

The Camping Bookings Team at the National Park have recently confirmed that as long as camping takes place within the curtilage of your home then it isn’t affected by the new Camping Management Byelaws.

The east Loch Lomond byelaws exempted land around buildings from their provisions in order to prevent local residents  from being criminalised for allowing people to camp or stop off overnight in campervans in their own gardens.   The provision was removed from the camping byelaws approved by Aileen McLeod, the hapless Scottish Government Minister responsible, and instead an exemption was introduced for landowners and their close relatives:

 

(12) These byelaws shall not apply to any: landowner; tenant; or connected person authorised by the relevant landowner or tenant using land within a Management Zone owned or leased by such landowner or tenant for any of the activities listed in these byelaws.

 

The point about this exemption is it only applies to particular people, not the land: the landowner themselves, their tenant or “connected persons” who are basically defined in the byelaws to mean the landowner’s spouse, parents or children.  Under the new byelaws therefore landowners have no power to authorise other people to camp or stay overnight in vehicles on their own land.   That means if you are resident in a camping management zone and invite people to camp in your own garden that those people would be committing a criminal offence.  YET the LLTNPA are now saying in effect no, allowing people to camp on your land will not make them criminals if this takes place within the curtilage of your property.  The LLTNPA staff have NO legal authority for doing this and again are acting ultra vires.

 

The reason why the LLTNPA is not enforcing the byelaws against caravans

 

While it is  right that the LLTNPA does not try to enforce the byelaws about caravans parked in laybys – as a caravan like a campervan is legally a vehicle and the byelaws allow people to stay overnight in vehicles on roads – any touring caravan parked off road is committing a criminal offence.

 

The issue for the National Park is that businesses house many of their employees in such caravans and, if the LLTNPA took legal action against the people occupying these caravans, there would be chaos.  Hence its decision not to apply the byelaws to caravans – perfectly sensible but it undermines the whole basis of the byelaws.  The fact though that the LLTNPA are still trying to enforce the byelaws against campervans by trying to claim there is no right of passage over certain roads exposes the byelaws as rotten to the core.

 

If the byelaws cannot be enforced equitably, they should be revoked

 

I have heard recently that the LLTNPA has now referred at least 5 cases to the Procurator Fiscal involving breach of the byelaws.   I do not know why these cases have been referred but, whatever the reasons, the PF should reject the referrals on the grounds that it would be totally unfair to take action against some people who have breached the byelaws but not others.   Justice requires the law to be enforced equitably and its clearly unjust that the LLTNPA is trying to enforce the byelaws against some people but not others.   As Martin Luther King said,   “injustice anywhere is a threat to justice everywhere” .

 

Before people think I am condoning irresponsible behaviour, if the referrals to the PF include cases of antisocial behaviour, littering or damage  the PF should take action under the existing law which deal with these issues, not the camping byelaw.  If they don’t, if for example they concern people who have refused to apply for a permit or who have camped/stopped outwith a permit area they should just be dropped.

 

There is now abundant evidence that the byelaws are not being enforced on an equitable basis.   This comes as no surprise as they are fundamentally flawed, not just because of the way they have been worded (the definition of “road”, “vehicle” etc)  but because they are fundamentally misconceived.      The LLTNPA appears incapable of sorting this out, of admitting the terrible mess and inequity it has created, and as long as its allowed to remain unaccountable will continue to act ultra vires, as it has done with the latest signs, and bring the law into disrepute.

 

When is the Scottish Government going to act?  Or is a judicial review the only way to sort out this stain on Scotland’s reputation for fairness and equitable application of the law?

Thanks to the reader who submitted this to Parkswatch

The chaos at Luss (see here) on the first weekend in May, was experienced at several other visitor hotspots in the Loch Lomond and Trossachs National Park, but most notably and predictably at Balmaha.  The LLTNPA has an opportunity to reflect on what happened when its Planning Committee considers draft Supplementary Planning Guidance (SPG) for Buchanan South  (see here) at its meeting today.  The SPG is also very relevant to the controversial proposed housing development in the Balmaha Plantation (see here).   This post considers whether the new SPG will help address the issues at Balmaha in a way fitting for a National Park.

 

There are strict rules on what can be included in Supplementary Planning Guidance, which can only expand on, not change Development Plans.

What the LLTNPA Development Plan, approved by the Scottish Government earlier this year,  proposed for Balmaha (see above)  was however extremely vague.   It allowed considerable scope therefore for the Supplementary Planning Guidance to draw on the Park’s policies, and explain how these would be applied to the area.

SPG map

In the event the SPG only covers three of the policies set out in the Development Plan, Housing, Economic Development and Visitor Experience.   The reason for this is not explained but the SPG  does not cover over policy areas which are very relevant to Balmaha such as Transport and Natural Environment, the village being bordered  by the Loch Lomond National Nature Reserve and the Highland Boundary fault.

 

Visitors and visitor management at Balmaha

 

While Balmaha is not readily accessible, it is the easiest place to get to on the east shores of Loch Lomond and, with Conic Hill providing one of the best viewpoints in Scotland for a hill of its size and with the West Highland Way providing a walk along the loch shore, its not surprising the village is a popular tourist destination.    With a poor bus service most people arrive by car.  With just a hundred odd places in the carpark, and the road north of the village designated a clearway, its hardly surprising that cars overwhelm the village on sunny weekends and bank holidays.

The Park has recognised this in its new draft National Park Partnership Plan (above), which rightly states the “the road network can become very busy at peak times” but then in usual fashion partly blames this on visitors “problems can be exacerbated by illegal and irresponsible parking of vehicles”.  Actually, this “problem”  is what the LLTNPA was set up to address and its challenge I would suggest (its not easy) is the provision of infrastructure to support visitors, including alternative means of transport to get to popular places like Balmaha.

 

The Supplementary Planning Guidance, disappointingly, says almost nothing about this.

SPG diagram

 

There is a reference to improving water transport (light blue arrow) and the Sustrans cycle path (dark blue arrow) but nothing on how the issue of too many cars for too few car parking places with no alternatives will be addressed.  For once I agree with Gordon Watson, the LLTNPA Chief Executive, who stated to the Stirling Observer that “additional overflow” car parking places are  required.  Such provision used to be available.  A farmer opened up a field to provide for parking but was given no support to manage this – people set up tents to stay the weekend – so stopped doing so.   This is the obvious solution, one that is used successfully in England’s National Parks, and one that should be revived, but there is no mention of this in the SPG.   I suspect this is because it would require resources from the LLTNPA (such as its Rangers helping to manage traffic rather than spending time chasing away innocent campers).

 

The lack of join up with the East Loch Lomond Visitor Management Plan 2014-19 – which the SPG interestingly refers to as “draft” even though it is published – is glaring.  That plan recognised the pattern of visitor pressure and committed to:

 

Establish a multi-agency peak period management regime that puts in place procedures for staff across organisations
 
 That commitment appears to have been abandoned.  Why?  And who decided this?
 
Meantime, the transport policies in the approved National Park Development Plan would appear not to be worth the paper they are written on:
 
 “Land will be safeguarded for, and support will be given to, the transport infrastructure proposals identified within Town or Village proposals maps”
 
 and:
 
 “Modal change from private car to more sustainable transport modes within settlements including the provision of integrated new or improved transport infrastructure,”

The SPG contains no hint of this vision, or of the aspiration of  past plans, yet alone how land might be used to achieve this.   Another opportunity to make things happen, make things better, lost.   It should not be difficult.  On the continent many places, not just National Parks, use school transport at weekends and holidays to provide public transport to rural areas for visitors.   Balmaha and east Loch Lomond is an obvious place to start given the road is not a through route.

 

The SPG contains almost nothing outdoor recreation in its broadest sense, the reason most people visit Balmaha in the first place – what the Park calls “Visitor Experience”.    This is illustrated by the Balmaha strategic principles diagram  (above) which includes nothing about how, once people have parked their cars in the car park, they leave the village.   The green lines on the diagram indicate views to the Loch should be maintained but nothing about how people might access the loch shore and the National Nature Reserve, which is supposed to be a place people can enjoy nature.  There is no obvious way to access this at present.  The thinking of the LLTNPA appears to have gone backwards since the proposal, several years ago, to create a path along the loch shore south of the village (abandoned I understand because the ground is very boggy).   To the north, the West Highland Way to Rowardennan offers brilliant walking but with no way to get back unless you are prepared to retrace your steps or go the full way and try your luck with a waterbus.    A hop on hop off shuttle bus would open up the West Highland Way for far more people to enjoy.

 

There is also nothing about the lack of camping provision, the major issue being backpackers along the West Highland Way have nowhere to stop off at the natural stopping off point of Balmaha because of the camping management zone.   This is the National Park’s welcome to walkers who come from all over the world.  The LLTNPA in response to comments on the draft Development Plan saying a campsite was needed at Balmaha, indicated that there was nothing in the Plan to prevent this:  the failure of the LLTNPA even to mention the need for a campsite in the SPG tells you I think that the LLTNPA has no intention ever of trying to make this happen.  There is an obvious place for this:  the former playing field, marked development site, within the pink circle in the diagram above and adjacent to where the West Highland Way enters the car park.

 

Developments in Balmaha

 

The focus of the Supplementary Guidance is on the LLTNPA’s Housing and Economic Development Policies which I believe confuses rather than clarifies matters:

 

New development within Balmaha should reinforce its existing development pattern and be of appropriate (generally small) scale.

 

What the LLTNPA means by “small-scale” however is not the same as what most people would understand by the term:

 

All new development should be of appropriate scale. It will be site dependant but generaIly groupings of 3-8 dwellings should be the most easy to set comfortably in more open landscape. Small groupings should be based on existing development patterns where one (generally larger) property faces onto the road, with other smaller properties behind. If there is a need for larger development (i.e. more than 5 houses) it should be divided by robust landscaping and areas of open land to reduce the impact of development

 

The Strategic Principles diagram above includes some grey lines on either side of the road (the dark blue line with arrows), increasing in density as they approach the centre of the village.    This looks like the LLTNPA is proposing to allow ribbon development either side of the road even though this was not part of the Development Plan.   This would explain why, unlike other settlements, the LLTNPA has not demarcated the village boundary.   It also could explain why the people who I understand are the two main landowners, the Duke of Montrose and Sandy Fraser of the Oak Tree Inn, responded so positively to the draft Supplementary Guidance (see here) about opportunities for development.

 

The clarifications in the Supplementary Planning Guidance that the LLTNPA will  allow more new build at Balmaha raises questions about why the Balmaha Plantation site (which is still waiting to go to Committee) ever needed to be earmarked for affordable housing.   LLTNPA’s recently approved policy on Housing in small rural developments is that  “Development on these sites should provide for 100% affordable housing”, so by allowing more housing at Balmaha, the need for affordable homes could be met without destroying what appears to be an area of ancient woodland.   Except that, in Balmaha the SPG now qualifies that Park Policy: “Some open market housing will be supported where this is demonstrated as necessary to help fund the provision of affordable housing on site.”    I expect the landowners will claim they can afford to construct very little affordable housing and that therefore the Balmaha Plantation site is still needed while very little affordable housing will be provided along the ribbon development.   The effect of the SPG therefore will be to reinforce the current trends towards social segregation of people and housing in Balmaha.

 

Setting aside the question of how else to provide affordable housing, the Balmaha plantation proposal still appears to be a glaring anomaly within the context of the Development Plan and SPG.    The SPG fails to refer to the LLTNPA’s Natural Environment policies – a chance to explain the claim, made by some, that the plantation is not really an Ancient Woodland site.  It also fails to explain how the size and density of the Balmaha Plantation proposal fits with the definition of the type of small scale development the SPG wishes to see in the area, 16 rather than 3-8 units, with density decreasing as you move away from the village centre.

 

What needs to happen

 

The LLTNPA needs to start joining up its various plans and to start implementing actions it proposed to do in the past but has since, without explanation, abandoned.

 

The LLTNPA needs to revive the east Loch Lomond Visitor Management Group (which did not meet last year) but make this both representative  (recreational organisations were not included) and accountable (it is not clear who signed off or agreed the last plan and the LLTNPA failed to provide any resources to make it happen).

 

The LLTNPA needs to start implementing its development plan policies on a consistent basis, rather than changing them so soon after they were adopted.   If the LLTNPA won’t abide by its own planning policies, there is no reason why anyone else should.

ON THE SPOT REPORT

Thank to James McCleary for his permission to reproduce his experience as an “On the Spot Report”

A great example of leave no trace camping and a good looking Spot on Loch Venachar.  This area is a natural campsite and long time favorite with campers.

Report begins: 13th May 2017 Loch Venachar North,  Camping Zone ‘B’


Well I was a good little boy and paid my permit for Loch Venachar on Saturday night. Thanks to Wattie for the suggestion and Sharon for the reminder for the permit (apologies if it wasn’t you two! 🙃).

 

However, about 20 17-23 year olds rolled up and pitched their stuff about 30 meters to the left. Apart from one visit from a crying teenage steaming girl about no one liking her they kept to their own wee patch. A bit loud as you’d expect.

 

In the morning I said ‘Mind tidy your stuff up!’
‘Aye, nae bother mate’ they said as they jumped in their cars and disappeared.

 

After a few minutes of cleaning their stuff up in the car park I went over to see what they’d left!

 

 

My wee camp in the first three pictures and their mess in the last two! Pictures make it look better than it actually was as you can’t see all the used condoms, food, and drink lying everywhere!

 

Sigh 😢

 

Not a Ranger in sight all night!


End of Report

Additional comments by Ross MacBeath and Nick Kempe

Failure to Stop Antisocial Behavior in Management Zones.

This is by no means an isolated incidence (see here)

It appears from the last two images that this group of youths have camped before.  It’s highly likely that much of the mess caused by abandoned tents and camping equipment (fly tipping) as well as environmental damage takes place in the National Park can be attributed to a few groups such as this.  It is clear to park users that the Loch Lomond and Trossachs National Park Authority and its Rangers need to focus ALL their efforts on the groups who create most havoc and not waste time in their  “engaging” and “education” of responsible campers.  “Education” of people new to camping, who may unwittingly cause minor impacts, while unobjectionable in principle is hardly a priority until the major offenders have been stopped.

 

The early bird catches the worm!

When it became apparent the group were leaving without clearing up, park rangers and Police Scotland responded arriving on site around 10:30 ish on the Sunday to find of course those responsible for the mess already gone. Another camper had a photograph of their tent with vehicles in the background.

So what is going on, it would have been reasonable to expect a standard Ranger patrol to arrive at this site well before 10.30 am as a priority on a Sunday morning, so it seems the claims of intelligent patrolling are a sham when a twelve year old knows if he’s made a mess he should scarper before he’s found out, why can’t the Park Authority appreciate this?

 

Too much time engaging with responsible visitors not enough time patrolling

How can the LLTNPA with it’s large ranger force and new powers to report offences directly to the Procurator Fiscal, fail to stop anti-social behaviour across the Park?

It’s pretty simple:

  1. The byelaws will not deter anti-social groups unless they are likely to get caught.   The Byelaws duplicate existing laws relating to these offences and only serve to devolve powers to rangers who can directly report to the procurator fiscal with a threat of higher penalties in some cases.  If you can still turn up late evening, party, jump in a car early morning and escape authority (whether Rangers or Police) it seems nothing has changed..
  2. The rangers are spending far to much time micro managing visitors and collecting data for their ranger reports, no doubt in some misguided attempt to justify the introduction of byelaws when what they should be doing is targeting the problems.  If the LLTNPA needs to employ rangers to work after 8.30pm, when problems are most likely to occur, or early morning to catch them so be it.
  3. Instead of wasted hours checking permits of responsible park users, the LLTNPA should task Rangers to identify the tell tale signs; groups drinking; messy pitches and excessive noise are all indicators of potential problems, identify those people (its easy, photograph  the car and number plate – people without cars almost never cause problems) and make it clear to them, if there is any mess left the next day they will be reported to the Procurator Fiscal.    This is what the police did on east Loch Lomond, it worked there and would be equally effective across all Management Zones.
  4. Instead of trying to ban and control responsible campers, the LLTNPA should be empowering them to help take action against anti-social visitors. The best way to change behaviour is to lead by example.  A case in point is dog fouling where over the last ten years attitudes and behaviour  of dog owners has completely changed, not due to enforcement of the law but to a change in social attitudes and it’s the attitudes of “responsible” dog walkers that have been key in this process.  They are the people on the ground most likely to see and infulence what other dog walkers were doing.  Its the same with campers.  The LLTNPA however have treated all campers as potential criminal elements and in doing so alienated their greatest potential source of support.

 

Clearly if rangers had identified the group of 20 youths at some time during their stay this criminal offence of fly tipping, which did not in fact occur until the group left in the morning, could easily have been prevented.

The Park Authority confirmed their rangers did not patrol that evening (13th May) because they were involved in another incident, They would however have caught them in the morning had their patrolling schedule started early enough. It did not, and that is the reason this particular group and so many others are free to re-offend. It’s just not good enough.

If the perpetrators were caught after the police sped off down the road after them, the fact remains LLTNPA Rangers failed to identify the issue and any success is thanks to a number of responsible campers who in fact provided the initial report of the incident with details and photographic evidence of vehicles involved. The byelaws will never succeed without the support of those the park have chosen to penalise in every conceivable way

What the Park Authority Need to Do

 

  • Abolish the camping permit system, free up Ranger time, and use patrols to identify potential problems and pre-empt
  • Set up a 24 hour response service, with the police, to respond to problems (local people and responsible campers deserve nothing less).   This could be easily paid for out of resources wasted managing permits
  • Start working with recreational organisations to identify how responsible campers could be encouraged to report problems to the LLTNPA and how people like James, who cleared up some of the mess, could be supported.  Bins for the rubbish would be a good start – its one thing to pick up someone else’s rubbish, another to take it away with you (as we are sure the LLTNPA appreciates as their ‘Rangers are not allowed to put rubbish into the backs of their vans for Health and Safety reasons).
The flat headland opposite Ledard House, at the start of the southern path to Ben Venue.  Proposed campsite was to be located right of photo

That campsites can become “political” issues is demonstrated in Strathard where Fergus Wood, the Loch Lomond and Trossachs National Park Authority Board Member, lost his Council seat on 4th May (see here).  On 11th May he withdrew his planning application for a new campsite by the shores of Loch Ard on Ledard Farm (see here).

 

The Interests of Board Members of the LLTNPA

 

The day before I received a very interesting letter from the LLTNPA EIR 2017-039 Response Ledard farm refusing to disclose correspondence between the National Park and Fergus Wood about this application.   The reasons cited for this are “commercial confidentiality” and data protection:

 

Correspondence in relation to pre-planning requests for advice typically includes personal information and information that in its nature relates to commercial interests of an individual or business. The provision of a pre-application advice service helps in the delivery of an effective planning system, and it is important that such advice is provided confidentially. The practice of providing confidential pre-application advice to all planning applicants as required is common place across Scottish planning authorities and prospective planning applicants engage in the pre-application advice process with a reasonable and legitimate expectation of confidentiality
.

Note how the LLTNPA avoids saying whether the application contains personal information or commercial interests in this case.   In fact, if there was personal information such as phone numbers on correspondence, normal practice is simply to redact this.  Moreover, the fact there are commercial interests behind most planning applications is not the same as saying this is “commercial” information which might be exempt under our Freedom of Information laws.   While the public may not expect every piece of correspondence they have with the National Park or other public authorities to be publicly available, Fergus Wood is not an ordinary member  of the public but a Board Member.  What should be important in terms of ethical standards in public life is there is complete transparency where Board Members make planning applications.  Indeed the Scottish Government and Cosla has issued guidance on this http://www.gov.scot/Resource/0044/00444959.pdf.  

Procedures should be conducted in a consistent and transparent manner to avoid
suspicions that councillors may have prejudiced their positions

 

While this statement was written about councillors taking the decision, rather than making an application, the principle should apply to both.  Its quite clear the LLTNPA does not understand this at all:

 

“This individual would have had no expectation that correspondence regarding a proposed business development would be released into the public domain.”

 

The problem is there has been no transparency, Fergus Wood managed to fail to declare he was a Board Member when making the application, failed to engage with people (including neighbours who objected to the application) and he paid for this locally.   Local people do not like the way this case has been handled.    I am pretty certain the Park’s response to the information request will only make them even more suspicious should Fergus Wood submit a new application once he has stepped down from the LLTNPA Board.

While the Plan for the campsite was in name Mrs F Wood, the application was in both names, and the Code of Conduct for the National Park requires members to be transparent about the interests of their spouses/partners

 

 

Context for the objections to the Ledard Farm campsite planning application

 

There is a shortage of campsites in the National Park and, as been stated in previous posts, its positive that Fergus Wood, as a Board Member, has been prepared to cater for campers, if not in his backyard at least in view of his front garden.

Ledard Farm, home of Fergus Wood, just across the B829 from the proposed campsite

The unprecedented number objections to this planning application can, I believe, be accounted for by the camping byelaws.  The Friends of Loch Lomond and Trossachs, who rightly have long been arguing the need for new campsites across the National Park, in their letter of support for this application said they did so because it would make “a positive contribution to the Your Park Initiative”.   The problem in Strathard, however, is “Your Park”, the contorted “vision” the LLTNPA has for camping.

 

As partial compensation for the camping ban across most of the lochshores in the National Park, the LLTNPA needed to show it was doing something.  It therefore promised 300 new places to Scottish Ministers but to help meet this promised  decided with Forestry Commission Scotland to develop a campsite on Loch Chon, a little further west along Strathard, where very few people had previous camped.  The local community made representations about people being encouraged into the area without suitable infrastructure (the narrow road, supervision of the campsite etc) which the LLTNPA in its usual way said would all be addressed.    What’s become clear in the last couple of  months is that most of the re-assurances the LLTNPA made about that development are meaningless:  the Park has failed to adhere to its own planning conditions and just a couple of weeks ago I found out that the warden appointed to supervise the site had left and a Ranger was driving in each day, a one hour trip, to manage the campsite (and presumably provide the bottled water which was needed because the water supply had failed – as predicted (see here).

 

So, the context to the large number of planning objections to the Ledard Farm campsite was that local people were worried that large numbers of irresponsible campers – and the LLTNPA has spent the last three years selling a myth to local communities that campers account for all the ills in the National Park – would all end up around Kinlochard at the Loch Chon and Ledard farm campsites.  These places being where people could still camp in the National Park and far more attractive for camping than the “permit zones” on Forest Drive (see here).   Had Fergus Wood taken up local concerns about the Loch Chon proposal, and used these to inform his own proposals, he might have avoided the backlash.   Like other Board Members, however, it appears he had become complacent because all the complaints to the Scottish Government had fallen on deaf ears and he therefore believed the National Park could continue to bulldoze through whatever it liked.   He had forgotten about democracy, the unfair consequence of which in this case is only that the Tory Councillor and LLTNPA Board Member Martin Earl, who like Fergus Wood endorsed the ill-thought out Loch Chon campsite, appears to have benefitted at the SNP’s expense.

 

Merits of the objections to the Ledard Farm campsite

 

Despite this context, very few of the objections to the Ledard campsite application (see here) appeared based on NIMBYISM and most in my view were well argued.  Here are some of the main points made:

 

  • People referred to the Development plan context (which was also ignored at Loch Chon) stating that the size of the development was too large for the area
  • People pointed out that the development was on a flood plain – contrary to National Park policy
  • People argued that because of the open landscape character of the lochshore it would be much more appropriate to site a campsite on the north side of the A827.
  • People were concerned about an influx of campervans along a narrow road (a concern that is now probably unwarranted as its become clearer the LLTNPA will be unable to enforce the camping byelaws against campervans and there is little risks therefore of large numbers being driven into Strathard).
  • People were concerned about increased light pollution at night (the LLTNPA keeps promoting dark skies)

 

What the objections add up to is that this was a tourist development in the wrong place – I have to say that I tend to agree.  While in many ways the planning application was positive (provision for staff to stay on site)  it was still a development and would have introduced a high profile building close to the lochshore in a open situation:

 

 

 

There are plenty of better places for campsites in Strathard and if, as is rumoured, Fergus Wood intends to re-submit a planning application for a campsite once he has stood down from the LLTNPA Board, location will be all important.   I would hope that both recreational and local interests would welcome a campsite in the right place.

 

A wider plan for the area

 

While Fergus Wood’s proposed campsite has created massive controversy, on the other side on Ben Venue, the LLTNPA  consented on 3rd May to a small new campsite at Trossachs Pier, at the east end of Loch Katrine, just outside the camping management zone (see here for planning application).    There were just two representations against the proposal demonstrating that local communities are not against all developments, but this one is small and located in woodland.  It includes water and electric hook ups and an effluent disposal point for campervans in the car park, upgrade of public toilets to include shower/wet room, 8 low cost camping pitches and 8 camping pods.

 

The trustees of the SS Walter Scott (who include the chair of Friends of Loch Lomond and Trossachs, James Fraser, who like me is on the Committee of the Scottish Campaign for National Parks), who made the application, have developed the proposal from its initial concept in a short period of time and also raised the funds to build it.   This  puts the LLTNPA to shame and highlights their failure to deliver all the basic campsites they had promised to deliver in the Trossachs as part of the 5 Lochs Management Plan (which now effectively appears to have been dumped) (see here)

 

There is now the potential to develop a network of small campsites around Loch Katrine and Strathard which would enable people to make more use of the cycling and walking routes there.

Path which runs parallel to shores Loch Arklet between Inversnaid and Loch Katrine by Corriearklet

The path which was created to connect Inversnaid to Stronachlachar Pier, at the west end of Loch Katrine, is sadly unused and the camping byelaws (which takes in all the land between the path and the Loch despite the small numbers of people who ever camped here – its even more remote than Loch Chon)   make it useless for backpackers who don’t want to risk becoming criminals.  Meantime while Stronachlachar Pier is just outwith the camping management zone, campers are not welcome:

 

While this is yet another unlawful no camping sign in the National Park, the request is not unreasonable.   What is needed is a sign which directs people to a good camping spot locally.

 

If there was a small basic campsite at Stronlachar or Loch Arklet, this would create a network of  campsites in the west Trossachs (in addition to those at Trossachs Pier, Loch Chon and maybe in future Ledard Farm) which would allow lots of opportunities for short backpacking and cycle tours, for example at weekends.  In my view that is what the National Park should be about and I would hope that people in the local community would agree.

What needs to be done in Strathard?

 

The basic problem in Strathard is that the LLTNPA has tried to impose ill-thought out proposals which suit its agend but no-one else.  Fergus Wood has paid a price for that.   Strathard was never included in the 5 Lochs Management Plan but I believe what is needed first and foremost is a visitor management plan for the whole area.   Unfortunately, the LLTNPA instead of building on the  work for the rest of the Trossachs started by Grant Moir, now Chief Executive of the Cairngorms National Park Authority, Kevin Findlater, former Chief Inspector with the police and others, has let that go and has nothing to replace it.   Visitor Infrastructure and management is therefore a shambles with all resources being diverted to policing the unenforceable camping byelaws.

 

The way forward therefore is the creation of a stakeholder group for Strathard – which in my view should be independent of the Park Authority who at present cannot be trusted on anything but be supported by it (in terms of staff time and resources) – whose mission should be to develop a plan for Strathard.   Such a group needs to consider the infrastructure and other issues identified by local residents as well as wider interests.

 

I would hope that such a plan included the following as starters:

  • proposals to develop a network of small campsites linking across the area (within which any proposal for a new campsite at Ledard farm could be judged)
  • the potential to introduce public transport at weekends and holidays (using school buses) to enable some increase in visitor numbers without encouraging more traffic
  • a reduction in the number of formal pitches at Loch Chon (which would be easy to achieve since many are already being overrun by vegetation) and abandonment of the current rules banning campervans from staying in the carpark or tents from pitching by the lochshore

By Ross MacBeath

This post, following previous posts on the Loch Chon campsite in Strathard (see here) and (here) for example, looks at recent damage caused to the environment at Loch Chon by the Loch Lomond and Trossachs National Park Authority.  The photos in this post were taken before the recent dry period.

Two new vehicle tracks have been created that are not on the plans

The Plans for the campsite at  Loch Chon specifically state  that  environmental damage to the site will be kept to a minimum and anything that is likely to cause such damage will be vetted by the Environmental Clerk of Works, part of whose role is to prevent any work likely to cause unnecessary damage to the fragile environment and eco system of the ancient wood. National Park Planning conditions (click to expand)

Topsoil and Excavations

Protection of Vegetation

Protection of Ecology

That said, where was the Clerk of Works when contractors decided to access the site from the B829 main road directly onto the hillside of the development. It should have been prohibited as promised by the LLTNPA’s Chief Executive Gordon Watson, who told us at the Strathard Community Council meeting on 4th July 2016 that pitches would be hand scraped.  This lead people to believe no machinery would be used on the hillside. Instead the LLTNPA contractor has created  two new tracks, the first down the full length of the hillside to the loch side path, the second joining the first at the new path just below pitch 19. Together these machinery tracks have caused serious environmental damage to the whole ecosystem. . This is a failure of the LLTNPA and their Clerk of Works to adhere to proper procedures put in place to prevent contractors from encroaching and damaging the fragile boggy environment within the ancient wood where their development is centered..

Tract 1 from the B829 down the hillside to the shore path

The creation of these tracks by the unwarranted use of vehicles  has disrupted a long swathe of the eco system stretching  down the the entire hillside forming some deep channels encouraging water to flow down the hill and creating new water courses in the process.  What should happen is that the Planning Authority should intervene and instruct the applicant to restore these areas to their original state.   However, the National Park Authority, as the body which applied for planning permission, have not set aside vegetation for restoration works as was stipulated as a planning requirement.  So it will be interesting to see how the Gordon Watson the Chief Executive of the Planning Authority will enforce the restoration on Gordon Watson the Chief Executive of the Park Authority.  How can there be anything other than a conflict of interest in this unhealthy arrangement.

 

Vehicle Track 1:

The image on the left shows Vehicle track 1 which runs down the entire slope to the lower transverse path by the shore.

Vehicle Track 2:

The image and track on the right side continues down to the path between pitch 19 and 20, a tree has been lopped off to clear the way for vehicles to pass.

There is also evidence of minor tree damage caused by vehicles:  another broken promise by the NPA who promised to safeguard trees

 

Are contractors acting on their own or has the Clerk of Works sanctioned this damage?

 

Besides taking vehicles onto the hillside, outwith the scope of the planning permission granted, the contractors have also made modifications to the layout of the camping pitches.  It is not clear if this has been agreed with the planning department or whether the Clerk of Works, who is supposed to be the intermediary and to vet all such operations, agreed to these changes in writing.     This is because the NPA does not, following a planning decision, publish information about whether any changes have been made to the planning permission they granted, as one might expect.   So, its not clear if the paperwork exists, but if it does, why are the documents not available for inspection?

 

 

For an organisation who claim conservation drive everything they do, the NPA have failed dramatically.  It would seem the need to keep the development within budget has a far greater value than the conservation of the ecosystem they swore to protect and care for during this unwarranted development.

 

The two vehicle tracks meet just below the road then continue independently down the hillside to various locations.

 

Vehicle Track 1

The disruption to the vegetation and underlying peat structure at root level is evident.

 

Environmental Damage - Track one of two hill track running down the full slope of the hill.

 

Vehicle track 1 branches off to the top of pitch 19

 

 

At each branch, or turn of the vehicle, a more intensive area of damage is found. The major problem this creates is not limited to the scars that will take years to heal but the creation of vertical groves that will allow water to enter and move more rapidly down the hill in new channels with a danger of forming new water courses.  This poses real risk to the soils and may wash them down the hillside forming a new stream..

Looking down Hill track 1 to the transverse “high path”

 

It is clear these two tracks have been used in the construction of pitches 19 and  20, as well as the paths used to access them, and other areas at this end of the campsite. In fact track 1 continues further down the slope to the path running along the shore.  It appears the vehicle tracks are being used to deliver materials for modifications to pitch surfaces, which were unsuitable for camping,  and in the process inevitably causing more damage.

 

There appears to have been no attempt either to protect the vegetation and little if any attempt to restore the damage.

 

 

Looking down the track from above pitch 19

 

The environmental damage is easily traced by the disturbed peat and the rust coloured remains of damaged mosses deprived of their water supply due to mechanical disturbance.and the churned up peat now waterlogged in many places.  This is  causing water to flow on the surface to collect In many locations where it did not do so before.

The track at this point diverges.  The branch straight ahead crosses the new transverse path and continues downhill.  The other branch, veering off to the left of the image above, is to the corner of the path where the vegetation and ecosystem around the corner has been churned up.  This has formed a collection basin for water which flows both under, across and down the sides of the path. making the path unstable (spongy) and diverting water from the natural water course down the sides of the path.

There is also evidence here of another tree being sacrificed to allow the vehicle to pass as well as  cross contamination of materials on the path sides, which extends far beyond the specified width of the path.

The vehicle track crosses over the path and continues on downhill

 

Hill Tract 1 leaving shore path

This environmental damage should have been avoided in the first place and it is obvious that the National Parks has failed in it’s duty of care. I wonder what the National Park, as Planning Authority, will do to enforce the reinstatement of the environmental damage created by the National Park itself?

 

When you build a transverse path across the hillside, this disrupts the natural flow of water downhill, with the potential to disrupt the whole ecosystem further down the slope.   Evidence of this redirection will be covered in a future Post on paths.

 

It is clear that Hill Track 1 has been created by vehicles accessing the upper hill path and pitches  in the campsite both from the B829 road above the campsite and from the lower shore path.

Vehicle Track 2

 

Vehicle Track 2 again starts from the B829 above the site and travels down hill to the junction below the road. Track 2 then cuts off to the North side.  The impact appears slight at first (top photo).

Track 2 continues down the hillside

As the ground gets wetter the impact increases.

 

The tree in the foreground has been lopped of to allow the vehicle to pass. contravening  planning and environmental protection conditions.    Its fine apparently that the National Park and its contractors chop down trees but not if occasional rogue campers do this.

 

Hill track 2 meets up with the path between pitch 19 and 20.

 

The track has had a significant impact on the vegetation and the boogy soils within the woodland.   There is something very wrong about a National Park Authority, which is supposed to be protecting the environment and  who claim to have procedures in place to prevent such damage, have caused this damage themselves.  The NPA appear to be incapable of setting up effective damage prevention procedures even where its paying for the works and the photos show vehicles have driven around the site at  will.

 

There is now a distinct possibility that there will be follow on problems with changes to the ecosystem caused by diversion of water courses by these tracks and other LLTNPA created water channels.

Photo credit Luss Estates – from last weekend

Contributors to Parkswatch have, over the last 15 months, regularly highlighted the failures of the Loch Lomond and Trossachs National Park Authority to provide basic facilities for visitors.  We are not the only people who have been saying this of course but in an extremely welcome development, Luss Estates, who I understand have been trying to influence the LLTNPA behind the scenes, have gone public.   Their press release, about what went wrong at Luss over the weekend, is very powerful.

A link was also provided to a number of further photos (see here) which every politician in Scotland should take a look at and then start asking questions.

The problems, which were entirely predictable given the spell of fine weather we have been having,  did not just affect Luss but were evident in other hotspots in the National Park.   This point was well made in another welcome press statement from the Friends of Loch Lomond and Trossachs:

 

“Call to Get Back to Basics

The Friends of Loch Lomond and The Trossachs Chairman, James Fraser has made an urgent call for local public sector agencies to get back to basics to tackle litter, toilet and traffic management issues in a more effective way at popular lochside visitor hotspots such as Luss and Balmaha.
He said: ” Over the past weekend both locations were overrun with visitors and were unable to cope and it was evident public bodies such local authorities and the National Park Authority are not geared up to deal with the basics such as emptying overflowing litter bins and  resolving traffic management problems at busy times. The current arrangements are wholly  inadequate and urgently need to be addressed to ensure there is no repeat of the shambles which took place last weekend.”
He added:” I understand new arrangements are supposed to be in place for different parts of the area with Councils taking on more responsibilities for traffic management and parking from the police but it is evident from the chaos with road blockages and indiscriminate parking at the weekend the Councils are ill prepared and  have not staffed up at busy weekends to deal with the problems.”
A flood of complaints were lodged by visitors and local residents over the weekend and many were ashamed by the dreadful state of the areas which fell well short of what is expected in a National Park.”
What is great is the public are now also complaining, as you can see from this post on Walkhighland about litter at Inveruglas.  Its also well worth a read and it would be hard to beat the patronising attitudes in the LLTNPA response to the complaint:
“It is unfortunate that more education needs to be done with the users of the park in terms of how they deal with their waste when in such beautiful locations.”
This shows just why the LLTNPA is failing, everything is someone else’s problem.
 

Visitors to the National Park are being ripped off by our public authorities and getting nothing in return

Meanwhile, as Magnus points out the LLTNPA charged him £4 to park his car while he was out hillwalking,  fees to pay bureaucrats to patronise the public.
And its going to get worse – the LLTNPA is at present trying to lease the carpark at Balmaha from Stirling Council where it plans to install another Automated Number Plate Charging system (three were originally planned, one at Inveruglas) so it can charge visitors – again without them getting anything in return.
Photo Credit Fiona Taylor
Argyll and Bute Council are doing the same in Luss.  If you want to go for a hill walk in the Luss Hills, a healthy activity which the National Park should be encouraging, and and use the car park you are likely to end up paying £7 for the privilege.   No-one in the LLTNPA seems to care – they would prefer people to park on the kerb so that they can then patronise visitors for not showing enough consideration for “beautiful locations”.

The connection between the LLTNPA’s  failures to provide infrastructure for visitors  and the camping byelaws

Illegal tent snapped from passenger seat of car west Loch Lomond Saturday 6th May
Contrast the photo above with the photos in the Luss Press Release.   Yes, the photos above was from the car and its not possible to tell if the campers were adhering to the Scottish Outdoor Access Code, but ask yourself what is the problem the LLTNPA should be tackling?
Should they be devoting a huge proportion of their human and financial resources to trying to chase campers away from the loch shores, whether or not they are camping according to SOAC, or should they be tackling the problems highlighted by Luss Estates and Friends of Loch Lomond and Trossachs?
What neither Luss Estates or FOLLAT have been prepared to say publicly as yet – and both supported the camping byelaws, albeit far from unconditionally – is that the camping byelaws account for many of the failures of the LLTNPA, including a failure to co-ordinate work with Local Authorities on everything from litter collection to car park charging.     While the evidence shows the byelaws are unravelling anyway – see yesterday’s post (see here) – as long as they continue to direct their resources towards managing what they are not fit to manage, the National Park will continue to disgrace Scotland.

What needs to happen

James Stuart, in his speech to become convener, hinted that the LLTNPA need to change focus.  He did not go far enough but his challenge now is to reverse the parrot like statements from the Park and the Scottish Government officials that the byelaws are here to stay, admit the LLTNPA has made a serious error which is preventing resources being spent where they are needed, and start engaging with organisations like Luss Estates, FOLLAT and the recreational organisations, as well as local communities,  to develop a new approach.

 

The new National Park plan is the obvious place to start.   The LLTNPA needs to “get back to basics” as FOLLAT puts it and stop pretending that they are some sort of business whose main purpose is to raise income for itself rather than cater for the needs of visitors.  Parkswatch will feature a number of posts on the new draft Partnership Plan in the next few weeks and would encourage all those who have complained to the LLTNPA, to respond to it in due course.

Caravan on South Loch Earn Road 14th April 2017

One of primary justifications the Loch Lomond and Trossachs National Park Authority made for camping byelaws was that they were needed to address the problem of encampments on laybys by caravans and motorhomes over the summer.

Extracts from Your Park consultation on the camping byelaws

In their news release (see here) about the approval of the camping byelaws the LLTNPA included the following statement:

 

New seasonal camping management byelaws (which come into force in March 2017 and will apply 1 March – 30 September each year) to regulate camping, tackle antisocial behaviour and make it an offence to cause damage to the Park’s natural environment. They will also prevent inappropriate use of public laybys as encampments by caravans and campervans; (my emphasis).

 

This point was repeated, word for word, in the news release that followed the LLTNPA Board’s approval of their so-called  camping “strategy” last October which included provision for just 20 campervan permits.

 

Its fair to conclude from this that part of the purpose of the camping byelaws was to prevent campervans and caravans using laybys in the four camping management zones.   Now, a caravan, like a campervan, is classified as a type of vehicle under the Roads Traffic Act and, as I have previously pointed out on parkswatch, since its not an offence to sleep overnight in a vehicle on a road within the camping management zones,  the camping byelaws are in effect unenforceable as far as campervans are concerned (see here).   I had not considered the case of caravans but exactly the same considerations should apply.

 

I was surprised to discover therefore on my trip round Loch Earn on 15th April that the LLTNPA appeared to be treating caravans completely different to campervans and in effect had told their staff to tell people with caravans that the byelaws do not apply to them.

 

The evidence from Loch Earn

 

When I met up with fellow campaigner Dave Morris on the south Loch Earn Rd on 14th April (see here) there was a caravan parked on the verge of the road (top photo) and, after spending a couple of happy minutes pushing one of their children who was swinging from a rope (cut off far right of photo!), we went over and asked the occupants if they knew about the camping byelaws and had had any hassle from Park Rangers.    They told us that they had been coming to Ardvorlich for years but we were slightly surprised when they said that estate staff had informed  them the byelaws did not affect them.  Both Dave and I thought this must have been some local arrangement due to the good offices of the Ardvorlich estate.

One of the laybys with caravans on North Loch Earn

We only realised what was going on when, after visiting a number of the laybys on the north side of Loch Earn which had caravans parked in them, we spoke to a family in the last caravan in permit zone D who were about to have their tea.

After telling us that the camping byelaws did not apply to caravans they also told us that the campervan parked next door to them had to get a permit, while their son, who was camping in a tent by the loch shore, had also been forced to buy a permit.  They seemed as bemused as us by how the LLTNPA was applying the byelaws but very happy with their good fortune..

 

Last week Nick Halls, during a visit to the Loch Chon campsite,  spoke to a Ranger who said to him “that the people who park their caravans in lay-bys and then occupy the space throughout the summer, could not be required to pay for a permit because the management zones can not include stopping on a highway”.    Official confirmation of my view, that the byelaws are unenforceable against people staying overnight in vehicles.   So why then are the LLTNPA still insisting that campervans apply for permits when they accept the same byelaws cannot be used control caravans?

 

Such discrimination is obviously wrong – though the absence of  moral scruples on the part of the LLTNPA will not surprise regular readers –  but the reason this farce is continuing is that if the LLTNPA were to admit publicly that the byelaws could not be used to control either caravans or campervans, they would lose all credibility not just with the public but with Scottish Ministers.

 

Misinformation, incompetence and squandering of public resources

 

Judging by how the byelaws are being applied on North Loch Earn, it will not be long before they unravel completely.

 

The first layby is described as Permit Zone A and is for tents only (see tents  symbol left).  Why the Park has made no provisions for campervans, when it now appears to be allowing caravans to stay here for free (we saw one) is something that Gordon Watson, the Park Chief Executive, should be asked to explain before a Committee of the Scottish Parliament.

 

The second layby, Zone B, is a permit zone for campervans (photo right).   We came across a man standing outside a campervan who had flown across from Germany, hired the vehicle, arrived at the layby, seen the sign and had tried to book online only to find no permits were available.  The layby was almost empty and he did not know what to do.  What type of tourist message is this?  We told him that in our view as the layby forms part of the road network he could stay there overnight – but trying to explain rights to a foreigner, even when their English is excellent is not that easy and we left him wondering what to do.  If he had driven into either the layby before (Zone A) or after (Zone C) (photo below) he would have never known he needed a permit because the signs say nothing about campervans.  It would be hard to invent such a shambles or a more disastrous message for tourism in Scotland.

 

What is not clear at present is what action the Park is taking against campervanners who try to spend the night on roads outwith the two official permit areas on Loch Earn, zones B and D, or what would happen if a campervan staying in a permit zone, insisted that like the caravans they should be able to stay there without a permit for free.

 

The wording on the signage, which cost the LLTNPA according to its figures £100,000, is wrong.  Its not true that people in campervans require a permit if they wish to sleep overnight in a vehicle in a permit area in the camping management zone.  There is no need to take my word for this.  If caravans, are exempt from the byelaws, because they are vehicles (so long as they are on a road) so should campervans, whether they stop off within a permit zone or outside it.   Any campervan owner who has paid for a permit should try asking the LLTPNA for their money back.

 

The bigger problem though is the information on the National Park website for campervans (see here).  The introductory part of the information sheet has not been changed DESPITE Rangers being told the byelaws cannot be applied to caravans:

 

On 1st March 2017 new byelaws are being introduced to manage the environmental impact of camping on some of the busiest lochshores in the National Park. These byelaws will affect those wanting to stay on and around some lochshores during the summer season in the National Park, whether they are in a tent, motorhome, campervan or caravan.

 

The Q and A information goes on to say:

 

Some of these permit areas allow for motorhomes and campervans to stop off overnight in the Camping Management Zones with a motorhome permit.

 

The clear implication is you can only stop off in a campervan in a permit area – this is wrong and totally hyprocritical of the LLTNPA who are not applying this to caravans. The LLTNPA is clearly trying to direct campervans to formal campsites and permit areas:

 

  1. Where can I go in Camping Management Zones with a motorhome or campervan?

Certain sites within the Camping Management Zones are well suited to providing places for visitors in motorhomes to stop overnight. There are both campsite locations and permit areas within the Trossachs North and West Loch Lomond Camping Management Zones, with suitable off-road locations to accommodate motorhomes. (See map below.)

There are plenty of places within the National Park to stop and rest on your journey.  These are unaffected by the new camping byelaws.

 

Only the last sentence hints at the truth – note it uses the words “you can stop and rest”, though this includes sleeping overnight, because if it explained where the plenty of places were that you could sleep overnight in a campervan, no-one would book a permit.

 

So what is the explanation for this farce?

 

It appears the LLTNPA senior management they failed to consider the implications of people being allowed to sleep in vehicles overnight – a basic safety requirement – and thought they could still ban caravans and campervans.    However, at a late stage, perhaps even after the byelaws commenced – and after these issues were raised on parkswatch?   – the LLTNPA appear to have decided that they could not apply the byelaws to caravans, hence the instruction to staff.  The LLTNPA have consistently refused to provide any information about enforcement about the byelaws, saying to do so would prejudice their operation.  That is clearly nonsense and the LLTNPA now needs to explain publicly why it has abandoned trying to enforce the byelaws against caravans but is still suggesting to campervans that they need to apply for permits like campers.

 

My fear though is that the LLTNPA is  desperately trying to retrieve the ban on caravans and campervans by getting Transport Scotland to ban vehicles from stopping off overnight in laybys on trunk roads and possibly by turning all the main roads in the camping management zones into clearways.    The only way Transport Scotland could do this however is if they could prove that overnight stops were creating safety issues while any new clearways would, as on east Loch Lomond, also impact on the ability of day visitors to stop off.    Transport Scotland should resist any pressure from the LLTNPA – its not their job to sort out the shambles the LLTNPA has created.

 

The LLTNPA also needs to apologise to local communities – NOW!

 

The main reason why so many community councils supported the byelaws is they were told by the LLTNPA that these were necessary to stop caravans being parked for the whole summer in laybys: the worst area for this was the north Loch Earn Rd.   Here are some examples:

 

Response 399) BLS Community Council.  “there seems to be a misconception, amongst a minority of visitors, that they can bring a caravan to the lochside and leave it parked up for the whole ‘fishing season’.  This ruins the opportunity for other genuine visitors………”

Response 460) East Strathearn Community Council “We absolutely support any measures that will discourage any semi-permanent occupation of our loch shores”.

Response 394) Crieff Community Council  “we are aware of the problems and difficulties caused at St Fillans and the adjacent area of Loch Earn by rogue campers and caravaners, anti-social behaviour and rowdyism, and drink related problems and litter” and “ask if the proposed changes will tackle the particular and regular problems of caravans being left in lay-bys and authorised parking places for weeks at a time”.

395) St Fillan’s Community Council.  Referred to a meeting August 2014 90 people re anti-social behaviour, litter and obstruction of lay-bys:   “something needed to be done to address the problems”   “With this in mind the Community Council………………………..supports the proposals of the National Park”.

 

A number of us told the LLTNPA at the time that byelaws were not needed to address encampment by caravans because this was covered by Section 61 of the Criminal Justice and Public Order Act 1994.   Guess what signs appear at the start of each layby on north Loch Earn?

 

Note the absence of LLTNPA livery and that the signs, while claiming to be a joint initiative, were clearly put up by Drummond Estates

So when it the LLTNPA going to come clean on this with local communities and admit it was wrong?

 

As those of us who were involved in negotiating access rights have always said, the camping byelaws were never necessary as there are alternative solutions to all the problems they claim to address.   What we could never have predicted is the resources  that a NIMBY National Park Authority would devote  to conning local people and the Minister that byelaws were the answer to problems or the resources that they are now wasting on trying to enforce the unenforceable.   The LLTNPA should stop trying to enforce the byelaws now, before the situation unravels further, and instead invest resources where they are needed such as public toilets, litter bins and litter collection.

The results of the Local Government elections last Thursday are likely to lead to a significant change in the composition of both National Park Boards over the next few months which provides an opportunity for all who care about how our National Parks operate at present.    The headline is that eight of the thirteen current nominees from Councils appointed by the Scottish Government to sit on the National Park Boards either lost their seats or failed to be re-elected last week and their term of office on the National Park Board is due to finish soon.

 

Loch Lomond and Trossachs National Park

  • Hazell Wood (Lab) West Dunbartonshire Council – lost seat
  • James Robb (SLD) Argyll and Bute – lost seat
  • Fergus Wood (SNP) Stirling – lost seat to Tory
  • Bob Ellis (SNP) Perth and Kinross – did not stand
  • Martin Earl (Con) Stirling – re-elected
  • George Freeman (Ind) Argyll and Bute – re-elected

Cairngorms National Park

  • Jeanette Gaul (SNP) Angus – lost seat to Tory
  • Fiona Murdoch  Moray – did not stand
  • Kate Howie (SNP) Perth and Kinross – did not stand
  • Gregor Rimmell (SLD) Highland – lost seat
  • Bill Lobban (Ind) Highland – re-elected
  • Peter Argyle (SLD) Aberdeenshire – re-elected
  • John Latham (SLD) Aberdeenshire – re-elected

 

Two individual results will stand out to regular readers of Parkswatch.

 

Re-election of Bill Lobban

Bill Lobban was re-elected to the Speyside Ward of Highland Council at the first count (along with a Tory) with 1,189 votes.   It appears that local electors have not agreed with the Cairngorms National Park Authority that local councillors allegiance should be to the National Park Board rather than their local electors or their own Council (see here).   I hope that strengthens the ability of more Board Members to speak out like Bill on important matters and forces the CNPA to re-think their current doctrine of corporate responsibility which means they require Councillors to agree with decisions even when their own Council has adopted a diametrically opposed viewpoint.

 

Whether they will do so is less certain.  On 18th May the CNPA is running corporate social  media training which “includes ‘rules’ for how to use your personal social media accounts as a CNPA employee / Board Member”.    The trend in our National Parks, as with other public bodies, is that it is being made ever harder for Board Members to speak out or disagree.   The Board needs members like Bill Lobban who are prepared to speak out and I hope Highland Council will nominate him again and the Minister will appoint him.

 

Fergus Wood

 

Fergus Wood, the former SNP Councillor for Strathard, received, 776 votes, significantly less than his colleague Evelyn Tweed who received 1090 votes and far less than the Tory Martin Earl on 2027 votes.  Earl’s fellow Tory, who gained 662 first round votes, benefitted from the STV system and replaced Fergus Wood.

 

While there has been a general swing to the Tories,  I believe much of the explanation for Cllr Wood’s defeat appears to lie in his proposals for a new campsite at Strathard (see here).  There have been a large number of local objections to the proposal (see here) which basically argue that this is not the right location for a campsite.  Many are not against camping, and indeed a number of objections suggest the campsite would be better located closer to Mr Wood’s own house to preserve the open fields by the lochshore.

However, I believe the perception locally is that Strathard, which was formerly very quiet, is being made to pay for the camping byelaws and the shortfall in the places where people can now legally camp in the National Park through the creation of an excessive number of campsite places: both the Park’s Loch Chon campsite and now the Fergus Wood campsite.  Added to that there appear to be concerns Fergus Wood may be putting his private interests before those of the community.  He appears to have paid the price for those perceptions.   It will be interesting to see whether Martin Earl, the Tory Councillor who is not on the planning committee, now speaks out against the National Park consensus if officers fail to listen to what the local community are saying – as they did over Loch Chon.

 

The overall picture

 

While legally Councils are not bound to nominate elected members to the Minister to sit on the National Park Boards (they can nominate members of Community Councils or local residents), it appears unlikely they would nominate someone is not a Councillor (sitting on the Board provides a significant income to councillors who are generally underpaid for the work they do).    Hence, there is likely to be a clearout in the next few months.

 

While the Tories generally gained in all the Councils concerned – mainly at the expense of the SNP -and within the Council Wards that cover the National Park, whether the political make-up of the National Park Boards change will depend both on power deals in local councils and on whether the Minister, Roseanna Cunningham then accepts their nominations.    This could involve some interesting political twists.  Generally the Tories have been far strong advocates of National Parks than the SNP (see here) but they are much closer to landed interests which wield so much power within our National Parks.

 

The  clearout of existing Board Members provides an opportunity to reform the way our National Parks currently operate such as:

 

  • putting an end to secret Board meetings in the LLTNPA
  • recording all Board Meetings as webcasts to enable more members of the public to find out what is going on in our National Parks and in the case of the LLTNPA returning all past minutes of meetings to the National Park website
  • refocusing the work of the Board Audit Committees so that these tackle fundamental issues of governance (such as failures in planning enforcement and failures to declare interests)
  • holding chief executives to account e.g ending the practice of complaints against the Chief Executive being investigated by staff managed by them
  • ensuring that there is proper consultation and engagement with recreational interests and visitors to the National Park, instead current practices which favour landowners and business interests

 

Local Councils, before nominating anyone to serve on our National Park Boards, should first ensure that those people publicly commit to improving the way our National Parks operate.  It would be a bonus if they also nominated people who were prepared to speak out on matters such as raptor persecution, the recreational importance of our National Park and sustainable economic development (instead of the current large scale developments driven by business interests).

By a happy coincidence, just as Dave Morris’ fine letter about how investment in the outdoors can benefit landscapes, people and the local economy appeared in the Herald, I received EIR 2017-037 Response Chemical Disposal points from the Loch Lomond and Trossachs National Park.   From the sublime to the ridiculous – but its an indication of just how far the LLTNPA are failing to provide basic infrastructure for visitors compared to Councils who have far fewer resources.

 

If you apply for a campervan permit you have to agree to the LLTNPA’s permit terms and conditions MHome-permit-Ts-and-Cs-07.03.17.    This includes the following clause:
“Toilet waste cassettes or grey water tanks must not be emptied within the permit area other than at authorised disposal points”.
I think its fair to say anyone reading this might expect there to be a number of chemical disposal points in the National Park – hence my information request – but it turns out there is just ONE, at Loch Lubnaig, and the LLTNPA does not even know if there are any others which might be available for use by campervans.     I’d describe this as a disgrace.
I have been out and about in the National Park a number of times recently and what is blindingly obvious is the large number of campervans staying in the camping management zones, lots of people out enjoying our countryside.   The fact that the LLTNPA has created just 20 permit places for campervans across its four camping management zones is I think totally now totally irrelevant, its basically being ignored, but what does matter is there is nowhere for all those people to dispose of their waste.

 

The LLTNPA has so far completely failed to install the basic infrastructure that is needed to support people in campervans.  On West Loch Lomond, it has missed an obvious opportunity as all three of the campervan permit areas on West Loch Lomond already have public toilets (even if these are shut for much of the time year) with the infrastructure for disposal of sewerage already in place. .
At Inveruglas there are toilets at the back of the cafe which currently can only be accessed when the cafe is open.  This means they are shut for much of the year and during the evenings.
The toilets are located at the back of the building by the far window. It should not be difficult to add an external chemical disposal point outside and even better, the LLTNPA could create an external entrance allowing campers and other visitors to access the toilets when the cafe is closed.

Last week I went to check the site and the toilets could easily be made available 24 hours a day, 365 days a year through a few basic alterations to the building (which the LLTNPA owns).

Having gone out of its way to attract more visitors to the site through the Scottish Scenic Routes Initiative, the aim of which was “to enhance the visitor experience of Scotland’s landscape: by creating innovatively designed viewpoints in selected locations in areas of outstanding scenery;” the LLTNPA has done nothing  to enhance visitor facilities.    Instead its wanting to raise the amount of income it gets from the site by introducing an Automated Number Plate Recognition system (see here).   The LLTNPA spent over £8k installing the current parking ticket machines at Inveruglas (see here) – that amount of money would have gone a long way to adding, or might have even paid for, a new chemical disposal point and 24 hour entrance to the toilets.
The LLTNPA’s priorities are all wrong.   It need to devote its resources to providing for people instead of trying to control them and making money out of this.      There is some excellent advice available on how to do this for campervans – http://www.all-the-aires.com/aire_construction.shtml – and a good starting point for the LLTNPA Board at its next public meeting would be to discuss how to develop such facilities in the National Park.

The current state of the camping and campervan permit area at Inveruglas

Motorhome permit place – you can see the sign on the right behind the mound of gravel

Meanwhile, the permit places at Inveruglas share uncanny similarities with those at Forest Drive albeit in a different environment.   Is this what the LLTNPA calls a quality visitor experience?   For anyone unwise enough to book for a campervan permit, I would ask for my money back.

 

Most of the camping permit area which lies behind the campervan in the first photo looks like this – completely unfit for camping.

The LLTNPA have, however, just like at Forest Drive, strimmed an area (below) which back in March (see here) was covered in brambles.

 

Its unclear if the LLTNPA expect people to pitch tents between the trees or whether this is their attempt to improve the amenity of the site for anyone camping in the foreground.   I walked all over the site and there was space at most for two tents.  The LLTNPA has totally failed to provide the number of camping places it said it would, but far more important the way its selected and is managing those places tells you that as a body its totally unfit to manage campers or indeed any other type of visitors.

 

What needs to be done

 

The Scottish Government need to appoint someone to the LLTNPA Board who has an understanding of the basic needs of visitors and is committed to providing these.   It should also ask all current Board Members and members of their senior management team to go out and spend a night in a tent in a permit zone and report on the experience and then publish this.  It would make interesting reading.

 

The Scottish Government also need to tell the LLTNPA Board that they need to stop wasting money on policing the unenforceable and start investing that money in basic visitor infrastructure which is worthy of a National Park.

By Ross MacBeath

It is now clear that much of camping provision intended as replacements for camping by our loch shores banned under the Loch Lomond and Trossachs National Park Authority Byelaws is little more than a collection of undesirable areas with little or nothing to offer families or groups of visitors as a camping experience.

 

With the exception of the yet unfinished site at Loch Chon and pitches at Rowardennan little else if anything is new.  The Park Authority is just issuing paid for permission slips to camp in the same areas that were free to campers previously, without the benefit of toilets or drinking water, or in the case of many permit zones,  places you would not want to camp, or even be able to pitch a tent.

 

Forest Drive Zone ‘E’ – no more than a collection of broken down pitches

 

Forest drive Zone ‘E’ supposedly providing  4 camping pitches, has a trio of broken down  pitches, created by the  forestry commission many years before with the 4th to be selected from the greater camping zone.

 

 

The first formal pitch has been destroyed by a forestry vehicle crossing it to access active forestry operations in the permit zone. The pitch is unusable.

 

As you might expect from an existing Forestry Commission site, this location is rather desirable at least as a view point and picnic spot. It has a true feel of a mature forest with pine needles softening the lines of the car park.  However forestry operations and tree  felling is putting this at risk.

 

The area overlooks the westerly reaches of Loch Drunkie. It is therefore a very popular spot with drive through visitors for both photo stopovers and extended stops for picnicking which means there is high demand for the limited space at the view point overlooking Loch Drunkie, marked ‘P’ on the map.

 

It is clear these pitches have not been used for camping in recent years and resurrecting them brings 8 to 16 additional visitors who will remain on the site with their vehicles.  This number of visitors using such a small area is as detrimental to the forest drive experience, as it is to the camping experience where a continuous flow of drive through visitors in search of picnic spots, disturb peace and quiet of the 3 pitches sited at the car park. The campers in turn block the use of the desirable location at the view point with  their own picnics and recreational use.

 

No work has been done in this zone other than the erection of a sign and some posts

 

The Forestry Commission’s original 3 camping pitches   have over the years fallen into disrepair through lack of maintenance and other damage.

That said, the LLTNPA have adopted this site as a camping permit zone and seen fit to do no remedial works whatsoever leaving the area in a state not fit for pitching tents.  Toilets for this zone are a 14.4 km round trip by car taking around 45 minutes.

 

The second of three pitches has a tree stump in it’s centre making it impossible to use as a viable camping pitch. How does the Park Authority expect anyone to sleep on this?

 

Again the National Park Authority have show their utter contempt for visitors at this site

 

 

The third pitch is a little better insofar as it is undamaged and you could pitch a small tent, but it does have borderline issues with slope which makes it undesirable from a comfort and sleeping perspective.  It would also be far more flexible without the wooden border and like the others, it is somewhat overgrown and does not provide a good ‘paid for’ camping experience.

 

The fourth pitch does not exist in any  formal form  and it appears you are expected to select a place to camp in the greater area that forms Zone ‘E’.  Some of the pine needle covered spots near the car parking looked promising but they turned out to be on hardcore that has become overgrown meaning there is no way to pitch a tent.

 

 

Looking back into the zone from the boundary opposite the car park we find what has now become a typical LLTNPA NON-solution,  with active forestry work  in progress within an area that is generally unsuitable for pitching tents. Wet, un-even ground with vegetation and forestry debris makes it an impossibility for camping as well as undesirable for visitor access.  Could another tent pitch be found? Yes if the debris from forest operations was removed, but the question remains, why would anyone want to?

 

Besides the one place identified above, could 3 other pitches be found to camp?  That’s a definite no at the moment. So the LLTNPA need to remedy the problems with the existing three faulty pitches and clear the ground for a fourth.

 

Another failure to provide the required number of pitches advertised

 

Like so much of the camping provision this zone is not family friendly due to pitch size which are too small for 4, 6 or 8 man tents. a lack of space to host 4 families and the drive through visitors at this popular spot with a likely conflict for both seating and car parking spaces.

This makes  zone ‘E’  unsuitable as a replacement for the previous camping provision by our loch shores and with the limitation on erecting only one tent per permit it is difficult to see how a family could use this area even if the pitch issues were resolved.

See also

 Forest Drive Zone B
 Loch Lomond Suie Field & Cuileag
 Forest Drive Zone C
 Loch Lomond Inveruglas (2nd half post)
 Forest Drive Zone D
 Forest Drive Zone E (this Post)
 Loch Lomond Firkin Point (1st half post)
 Forest Drive Zone F (to follow)
 Loch Earn South
 Forest Drive Zone G (to follow)
 Forest Drive Zone H (to follow)
 Forest Drive Zone L (coming soon)
 Forest Drive Zone M

On Wednesday, James Stuart, new convener of the National Park had an agenda piece in the Herald to promote the consultation on the Loch Lomond and Trossachs National Park draft plan (see here).  It included a commitment to engage properly recreational organisations – a implicit indictment of the way the LLTNPA bludgeoned through its camping byelaws – but a welcome step in the right direction.    The response from Dave Morris (above) shows the disastrous consequences.

 

The wider point though is the LLTNPA did not just fail to consult with representative organisations, they failed to consult any of the people who actually camp and stop in campervans along the loch shores.  I saw a good illustration of this yesterday morning driving up the A82 to climb on the Ben.  There were campervans everywhere, in the Transport Scotland laybys which are exempt from the byelaws, on road verges (which are also exempt although the LLTNPA has not recognised this), in car parking areas where they are not (unless covered by the permit system as at Inveruglas and off-road.

 

campervans at Tarbert

 

 

 

 

 

Anyone who actually slept the night in the campervans in the above photo were committing criminal offences although I doubt any of the owners knew it.   What the photo illustrates is the byelaws are completely unenforceable – for campervans anyway.  If challenged by a Ranger all the campervan has to do is move onto a road verge or into a layby.    Complete nonsense.  The LLTNPA would have never got itself into this mess if it had actually talked to the people who use campervans.    So, how about some proper visitor surveys – instead of the latest dumbed down ones that say nothing – asking people what they need?  I suspect the answers will include “be left alone to make our own decisions” and Chemical disposal points.   Where are the chemical disposal points in the National Park (I have asked) and what are the plans to increase them?   Err……………..

 

And over to the Cairngorms National Park Authority

 

Following its lengthy coverage of National Parks in January, Scotland Out of Doors on Saturday included an interview Hamish Trench from the Cairngorms National Park Authority.  Its right at the start BBC out of doors.    Mark Stephen asked some searching questions about what partnership actually means and whether some partners have more power than others – highly recommended.    While Hamish Trench’s answers were carefully worded, the really important thing is that CNPA staff appear prepared now to articulate a vision for the National Park integral to which is large scale conservation.   While I don’t believe this can be achieved through the current ways of partnership working, which favour landed interests over everyone else, the fact that the CNPA is promoting this vision in public is in a sense a challenge to those interests.  Intelligent questions from the media, such as those put by Mark Stephen, can only help  change the parameters of the debate.

Tents at the St Fillans end of the Loch Earn south camping permit zone – much of the camping is on shingle beaches.

Parkswatch has, since the camping byelaws came into force on 1st March, documented how the Loch Lomond and Trossachs National Park Authority Park is trying to force campers into areas totally unsuitable for camping.  Relatively little coverage has been given to how the LLTNPA is managing the permit areas which are being used by campers.   Last Saturday, as part of a walk over hills east of Ben Vorlich, four of us walked through the South Loch Earn camping permit zone, the largest in the Loch Lomond and Trossachs National Park.   It provided plenty of evidence of the incoherent thinking behind the camping management zones.

 

 

The first thing that struck me was that people were enjoying themselves, despite the biting wind.     Yes, there were a few beer bottles out – we were offered a couple after helping a child to swing from an old rope hanging off an oak tree – but people were fishing, using their ingenuity and natural materials to construct shelters,  socialising, cooking on the camp fire, foraging for wood (a criminal offence now under the byelaws), taking a short walk up into the woods to find a place to have a crap, out for walks.  Lots of families, not just adults, many of whom had been coming for years, giving lie to the Park’s claim that the byelaws were needed to encourage families back to the lochshores.    Examples of connecting with nature in way that is just not possible for most people in their day to day lives.

Loch Earn Leisure Park

The contrast with the sanitised environment of the Loch Earn Leisure Park which sits between the camping management zone and St Fillans was striking.   Now, I am not disputing caravan parks meet a demand – the Leisure Park is enormous and it would appear more people go there than to camp –  but in terms of connecting with nature, what offers the better experience, staying in a chalet or camping by the loch shore?     What has the bigger impact on the landscape – the suburban style chalets or the tents on the loch shore whose presence is temporary (even if abandoned)?

 

 

Whatever the LLTNPA may have claimed in the past about roadside camping not being wild camping, the campers on south Loch Earn were out enjoying nature in a way that is just not possible in a chalet park.     This surely should be at the centre of what our National Parks should be about – “connecting people with nature” – but in the whole development of the camping byelaws the LLTNPA never once articulated the value of camping by the lochsides.  If it had done so, it would have wanted to encourage more people to camp, instead of trying to restrict numbers and confine campers to a few permit areas.

 

South Loch Earn is the only extensive permit zone the LLTNPA has created (all the others are very restricted) and the only place therefore where camping could carry on anything like it did previously with people turning up and having a wide choice of places to camp.   Its therefore atypical.

The reason for this became clear from discussions with campers.  Many have been coming for years – there would have been a riot if the LLTNPA had tried to ban them – and the Ardvorlich Estate appears to support their presence, not least because of the income it derives from fishing permits.   Hence, the LLTNPA had very little choice but to allow camping to continue here.

The enforcement of camping permits

 

We talked to some campers who had been advised by the estate to buy permits beforehand and others who had just turned up, and bought a permit online when requested to do so by Rangers.  Most saw £3 a night as a small price to pay to be able to continue to camp as they had done previously.  The big issue I believe will arise on popular weekends when 100 tents turn up, most of whom will be regular visitors, in a zone where the Park has allocated places for 38 tents (this is an arbitrary figure decided by Park staff).   I don’t envy the Rangers who are tasked with sending these people away.   The LLTNPA is going to have to work very hard indeed if its going to turn people who have been lucky enough to get a permit against those who haven’t.

The bureaucracy and cost of enforcing the camping byelaws was only too apparent on our visit.  We heard from the campers that there had been one round of Ranger visits in the morning to check permits – that’s when some people applied for them online.  The campers had then received a visit from the water bailiff, checking that those fishing had fishing permits.   Then,  late in the afternoon, the Rangers visited again.

We watched them for a time, referring to note books after getting out their vehicle and then walking down to each tent to ask campers for their permit.  They appeared to be having long conversations with campers and I would say it took 5-10 minutes to check each tent.    Now I don’t know what the Rangers were saying because the LLTNPA have refused to provide me with what they have briefed rangers to do stating this would prejudice enforcement of the camping byelaws:

 

“Release of this information is likely to have a negative impact on the ability of the Rangers to perform an effective role in working with the police, interacting with the public and, where required, submitting byelaw contravention reports”   (see EIR 2017-029 Response)

 

What is 100% clear though is that the new permit system has resulted in three check up visits in one day for people who go to camp to escape from the rules and regulations of everyday life!    An intrusion into our freedom to enjoy the outdoors, an attempt to bureaucratise the experience in the name of social control.  The costs are enormous – for whose benefit is this?   Where will it go next?

 

While people may be buying permits when requested, its quite clear that the permit  are having little impact on either the quality of the environment or the behaviour of campers.

 

 

At the St Fillans end of the zone, there was a significant amount of rubbish which has been blown against the boundary fence.   We got talking to the people camping there – they had been coming for 12 years – and they told us the area had been like that before they arrived.  What this highlighted is that the introduction of camping management zones is not going to do anything to reduce the amount of litter along the loch shores unless there is actually someone employed by the LLTNPA to pick it up.

Unlike other Council areas within the National Park, Perth and Kinross provide bins the whole way along the road and they are well used – and not just by visitors.  As a result the Loch Earn shoreline has far less litter than other areas in the National Park.
Where litter is dropped though – whether by visitors, residents, people passing through or campers – it appears the LLTNPA Rangers are not picking it up – and from I previously established from talking to them is they are not allowed to put litter in vans.  This has three consequences.   First, its unlikely that the permits will have much impact on litter in the Park – the only thing it might prevent is people who have applied for a permit abandoning their campsites as they can be traced.  This however was only a tiny part of the problem.

The impact of flytipping was greater than anything left by campers

Second, the permit system does not help identify the sources of other litter along the loch shores, much of which does not come from campers, so will do nothing to prevent it.  Third, the sensible solution to all of this would be for Rangers to get their hands dirty, set a lead – and invite campers to help them to clean up the lochshores.  Whether people will do this now they are being forced to pay is less certain:  if people are paying for a permit they have the right to expect the LLTNPA ensures the area is clean before they arrive.

An example of a camper occupying more than the 5 x 5m area allowed for by the Park in each permit

During our visit we saw plenty of evidence to show that the Rangers at present are failing to enforce the terms and conditions associated with the camping permits.  Among the camping permit terms and conditions, breach of which is a further criminal offence with fine of up to £500, are the following:

 

  • Ancillary items must be kept to a minimum and limited to items reasonably necessary in connection with recreational camping activities; e.g.toilet tents, gazebo, fire bowl/bbq
  • The total area occupied by your tent and ancillary items must not exceed 5 m x 5m

 

The toilet tent in the above photo is allowed under the permit system but  it and the tent occupy an area greater than 5 x 5 square metres, the maximum allowed by the Park.  So, a criminal offence committed but it appears the Rangers have done nothing to prevent this.  One cannot blame them – what a stupid rule!   Who would want to sleep right next door to the toilet tent?

 

The daft rules associated with the permits are also illustrated by the photo which featured at the top of this post and shows a shelter hanging between two trees (again, with the tent, occupying an area greater than 5m x 5m).  Now, under the byelaws, while the public can put up a shelter during the day, its an offence to leave one up overnight unless its an umbrella.    So, will these campers be told to take the shelter down each night?  The rules are daft – an inevitable consequence I believe of trying to control every aspect of campers behaviour rather than leaving people with the right to make their own decisions.

Contrast the stultification of the Park bureaucracy with the ingenuity of campers making use of natural materials.

 

The most obvious failure in terms of enforcement however were campfires (as in photos above), which were everywhere, and in a number of cases clearly breached the byelaws.

The things people do – Dave Morris, veteran access campaigner, with firewood which someone had thoughtfully disposed of in the bin!

While a number of campers had brought their own wood, others were collecting it locally – an offence under the byelaws.  Whether they were doing harm of course is another matter – there were large amounts of wood available in the plantations above the road – and the estate had been busy chopping down trees.  People were carrying felled off-cuts back down to the shore to burn.

 

Now, I believe the way the provisions of the byelaws in respect of fires – collection of wood is an offence – is both wrong and is well nigh impossible for Rangers to enforce.  As a society do we really want to criminalise an eight year old who collects a twig to add to a fire on which they are cooking or to prosecute an adult who has picked up a log to burn (both of which we saw happening)?  The focus of the LLTNPA should be on preventing live wood being felled for fires – otherwise Rangers are being given an impossible task.

 

The basic problem on Loch Earn at present is not the quantity of dead wood – lots has been felled – but rather what wood the estate is happy for campers to use and what not.  There are no messages about this and as a result people forage.    To ensure damage is not done inadvertently or wood, intended for another purpose, is not burned, the solution is surely for the LLTNPA to provide wood to people who want it for a small price.  Indeed, under the original Five Lochs Management Plan the idea was to provide wood stores at campsites, a proposal  that has since disappeared without trace.   It would be far better use of Rangers time to spend a small portion of it providing wood to campers than checking up on permits.

 

The real failure in enforcement

 

Unlawful camping notice in the management zone – the camping ban applies from 1st March to 30th September and general notices such as this are thus contrary to access rights.

 

The most significant failure of the LLTNPA Ranger Service however to enforce the law, has nothing to do with campers.  The Park Ranger service drive by these signs, which are contrary to access rights and go beyond anything agreed by the byelaws, every day.  For some reason they don’t see it as their job to take enforcement action – or rather I suspect they have been told by the Park’s senior management to do nothing.  One rule for campers, another for landowners.
I first noticed a no camping sign here in May 2015 and reported it to the LLTNPA with a number of other access issues  access issues LLTNP identified May 2015.   At the time I thought there was only one sign here but on this visit counted over ten signs on a 100m stretch of road just before St Fillans – could you get more unwelcoming than that?  At first the LLTNPA responded positively to my report of the issues and Claire Travis, the member of staff responsible, told me Park staff had been to see the sign at Auchengavin and it was then removed.  Senior management then banned her from speaking to me – I know because I obtained the information through data protection – and provided me no further progress reports on what action the LLTNPA was taking.  It appears the LTNPA senior management decided not to take any action, a fundamental failure in their responsibilities as an access authority.
This is further evidence that this National Park is being run in the interests of landowners – good for the Ardvorlich Estate and the few other landowners who still tolerate campers but shame on Forestry Commission Scotland which has gone along with this whole charade – not of ordinary people.  If any readers are willing to report the signs at the east end of the south Loch Earn Rd as being contrary to access rights – best to use your own photos –  parkswatch would be delighted to publish any responses from the LLTNPA.

The implications of the permit zone for access rights

At the end of our walk, both Dave Morris and I agreed, that really the introduction of the permit zone on Loch Earn has so far, changed only one thing.   It has introduced charging for access.   The permits have done nothing to address the litter or other basic infrastructure issues that the LLTNPA should be addressing.
So what, it might be argued, people appear to be accepting the £3 charge.   Well, so would most people faced with the choice of a charge or a ban from staying in a place you have been visiting all your life.   That doesn’t make the charge right – people are getting nothing for it except bureaucracy and intrusion – and of course what is likely to happen is that sometime in the next year or so a report goes up to the LLTNPA Board explaining openly for the first time the enormous enforcement costs and suggesting these should be recovered from campers.   If people accept the principle of permits and charges,  our access legislation will be in tatters.
What needs to happen – and the LLTNPA is currently consulting on its new Five Year Partnership Plan – is the resources currently being spent on enforcement of the permit system (which means almost the entire time of Park Rangers) should be redirected to other tasks.  High on my priority list would be removal of litter – including Rangers encouraging campers and other visitors to take part in litter picks – and provision of wood for campfires.    Ranger services were never intended as quasi – or is that Stasi?  – type police forces  and the Park Ranger service should be allowed to return to its educational role, which should include leading by example.

First impressions count for a lot – I think “utter contempt” would describe what I thought on first viewing this site.  That’s the utter contempt shown to visitors by the LLTNPA. They have the gall to suggest that this constitutes a replacement camping place to those now banned to visitors on our loch shores. Quite frankly it’s preposterous to suggest any visitor would consider camping in Zone D as a valuable life experience in natural surroundings.  It has all the charm of a landfill site.

 

Plus points: parking for 2 cars.  Minus points: everything else!

 

Zone D represents everything we despise in the forestry industry

 

Utter devastation is wrought on the landscape when forests are clear-felled, leaving a wasteland of fallen branches and cutoff tree trunks. Although the clear-fell in Zone D did not happen yesterday it should serve as a reminder that Forest Drive is an active working forest and forest operations are continuing at many other camping zones in the area rendering some of them unusable.

 

 

On viewing a Satellite Image I expected a forest location – nothing prepared me for the vista in the photo above. The location map is not fitted in the correct position ( the map is not drawn correctly) and the two posts on the other side of the river which would normally demarcate the zone limits, are side by side, outside the permit zone and on the wrong side of the stream. It would seem even those laying out this zone could not fathom where the zone begins or ends.

 

Just Commit a criminal offence if you can’t find a camping spot!

It’s so bad that the LLTNPA “Get a Permit” website even encourages visitors to commit a criminal offence by camping outside the permit zone.  They seem to be well aware there are no viable camping pitches within the zone.

 

 

The fact that other side of the burn is outside the permitted area is however somewhat academic as its hard to imagine anyone would want to camp there and secondly, felled forests do not hold much hope for finding camping pitches, as well as which they are quite hazardous areas to enter.  I can confirm there are no camping spots in the immediate vicinity of the two marker poles on the south of the river as after stumbling on them I searched the area before realising they were positioned in the wrong place.

 

The zone map is somewhat confusing as it shows what appears to a fork in Forest Drive with a large car parking area right on the junction.  At first glance there would appear to be a path running around the southern perimeter of the zone.  On comparing the map with the terrain it is a stream not a path.    The main camping area marked with the tent symbol looks like an open grass area bounded by the stream.  However the  presence of zone markers in the wrong location on the other side of the stream makes initial orientation impossible until you can accept the fact they’re wrong. .  This isn’t acceptable, the zone boundary only became clear when the path of the river was traced out on foot and even then I doubted I was in the right location because of the unsuitability of the location as a camping zone and lack of any obvious pitches. The trees shown in the permit zone map and the area beyond are fictional as the entire area has been harvested.

More phantom camping provision, 2 pitches claimed for this site?

The zone is another fantasy, there is no choice of camping pitches as there are no  pitches.

 

The only spot in the entire zone in which you could fit a tent.

 

It’s on rough grasses growing over previously felled wood and not suitable.

 

Looking from the far end of the zone towards the zone map post (top right)

 

Zone D is yet another example of phantom camping provision from the LLTNPA and supposedly provides 2 camping pitches to replace those on the areas of our loch shores where campers are now banned. This area has zero amenity.  There is no good reason to be here, let alone camp, it has no redeeming features and the presence of the stream  holds only false  promise. It is a thoroughly.unrewarding location.

 

Camping on the side of Forest Drive is not desirable

 

The drive-by location  highlights another issue.   Zone D is at the bottom of a long downhill section of Forest Drive where would-be boy racers just can’t help themselves trying to get close to 50 mph, despite the 10 mph limit, thus causing a dust storm, not conducive to sitting by a tent good.

The LLTNPA’s abject failure to fulfill their promises

 

Anyone being duped into paying for this site or other similar permit areas should seek compensation from the LLTNPA. Not just a return of the the permit fee but compensation for the loss of a weekend, the travel expenses and any other ancillary costs incurred  getting to this ridiculous camping zone.  The National Park is quite clearly misrepresenting the nature of this site and a visit to the small claims court should surely see compensation awarded despite their denial of liability in their terms and conditions  (See Permit Terms and Conditions here).

 

Meantime, perhaps the LLTNPA could explain publicly just how many viable camping places  are actually available?   Its promise to the Minister to deliver 300 “new” camping places by the 1st March was clearly never met if you take account of all the unusable permit areas and the non-functioning Loch Chon campsite.

Extract from secret Board Meeting about implementation camping byelaws. The claimed antisocial behaviour has been grossly overstated as has its popularity as a camping destination – too inaccessible for most.

By Ross MacBeath

What differentiates a campsite from wild camping?   Most people would say at the very least the existence of  services such as the provision of drinking water and toilets.  The evidence from my visits to  Loch Chon the Loch Lomond and Trossachs National Park Authority cannot even provide a reliable water supply for the £7 a night charge  (see here for post and here for a set of photographs of wider issues with the campsite).

 

The reasons why the water supply at Loch Chon is defective

 

One of the first principle of designing a private water supply it to ensure the availability of water from the source stream by carrying out a year long study of peak water flow. What follows below shows that  these investigations were either not carried out or ignored but its worth considering first why the LLTNPA has behaved in this manner..

 

Gordon Watson at a Public Meeting with Strathard Community Council on the 4th July 2016 stated that the Loch Chon campsite was chosen for it’s suitability and merits as a campsite rather than its availability.  The slide above, which was obtained subsequently through FOI, shows that this is not true and that Loch Chon was the ONLY option  that would allow the LLTNPA to deliver the  number of pitches they had promised to Scottish Ministers by 1st March to enact their byelaws.

 

What this shows is that the LLTNPA intended to build a campsite at Loch Chon no matter what.  For how the LLTNPA dealt with its planning permission to itself (see here). This is reprehensible behavior on all counts and LLTNPA are quite clearly paying the price with a defective water supply. But ultimately it’s visitors and communities who will pay the real price for this unwarranted development going forward.

 

Peak water flow and the LLTNPA Loch Chon water supply

 

An unsightly installation with loops in blue water pipe makes a poor impression.  When taken together with the positioning of the intake manifold, which is partially out of the water, unsecured and likely to be dislodged the first time the stream is in spate, it provides a rather damming but realistic indication of what was initially installed.

 

Just while we’re looking at this image, you can see that the concrete floor of the culvert under the bridge is smooth and curved.  This is done intentionally to stop materials collecting on the surface.  When the stream is in spate, large boulders are transported in the torrent of water and the smooth culvert base ensures they can roll right through preventing them from  causing an obstruction under the bridge. We will see why this is important later in the article.

 

Another important factor in providing a water supply is water pressure

 

One measure of the effectiveness of the water supply is determined by the water flow from the taps, which is of course dependent on the water pressure.  Water pressure in turn determined by the difference in elevation between the tap and the intake manifold.  The greater the height between the two the greater the pressure.

 

At this development the Park Authority have chosen to place the intake manifold almost 2  metres underground just by the road bridge over the stream  though it is still above the level of the taps which are further down the slope.  Not sufficiently high though to provide a sufficient head of water which is responsible for many of the issues with the water supply.   It would seem clear then that the intake manifold is in the wrong pace. It’s a basic design flaw and still goes uncorrected even though the LLTNPA is aware of the fact.

An essential requirement is that the intake manifold is always underwater

 

You would think that making sure the intake manifold is always under water would be a given. Yet here we are at Loch Chon on the 12th  March 2017 with the manifold almost completely uncovered  drawing air into the system.

 

Water intake pipe is aove the water level of the river drawing air instead of water.
Image 12th March 2017 lying on surface at water level

 

The problem is clear that the stream does not have sufficient water flow in dry periods.  This was evident during a dry spell starting before March 1st and through 12th March when the water supply failed intermittently when the intake pipe was not fully submerged causing air to be drawn into the system. In this location there is sufficient depth of water the intake is just not positioned properly.

 

 

Of course once the air lock is in the system it won’t self clear easily as water won’t flow up hill.  So many basic principles have just been overlooked cumulatively resulting in poor system design. This is a contributory factor together with the failure of staff, the clerk of works and the contractor to understand the basic requirements for implementing such a water supply.

 

One must ask who is managing this project, clearly the people involved with the development at Loch Chon have little or no understanding of stream feeds to private water supplies or their design. This lack of capability is worrying in an organisation which claims to wish to provide more campsites.   The LLTNPA is evidently not up to the task.

 

One week later the water was partially on, there was drinking water but no toilets

 

One week later on the 19th March 2017 the intake pipe was submerged once more, after some rainfall, however the water to the toilets and wash hand basins was still off.  You can see here the pipe had been removed from the clips removing the ridiculous upward loops in the water feed pipe.

 

Recent rainfall has caused the stream level to rise and cover manifold The Intake Manifold under the surface of the stream after rainfall

The water supply was still causing issues, drinking water was  available but toilet flushing was not.

Two weeks later there is still no effective water supply

 

On the 2nd of April the water supply was again only partially functioning the intake manifold was submerged  and there was water.   This time while one toilet was working the drinking water wasn’t.  3 of the 4 toilets remained locked.  The disabled toilet wass open and functioning with wash hand basins.

 

Another week on engineers were working on the system and some water was flowing

 

10th April 2017 – Water was now available from the outside taps though pressure was so low the auto shut off taps fail to operate correctly.  Well at least there was drinking water on site.  Although container filling took a while, it was better than nothing.

 

Again only one toilet was unlocked but I am pleased to report  it was flushing and the wash hand basin was operational. The other three toilets remain locked and strangely it was not the disabled toilet that was open.

 

It had taken the LLTNPA well over a month since the date the campsite was officially open to get even a basic water supply in place.  This was my first visit where toilets and drinking water have been available together but it is clear the LLTNPA are not out of the woods yet with low flow rates and intermittent supply. The test will be when all 4 toilets are in operation and water still comes out of the taps.

 

The engineers were working on the system when I arrived and allowed an opportunity to see whats inside the container next to the toilet block. It does look like there is a leak in the container roof.

 

The confusion over the hot and cold taps had also been sorted and there were now neutered tap tops both supplying cold water.

 

The  LLTNPA have been busy correcting some of the issues above and creating others

 

My visit on the 10th of April 2017 showed some changes.  The main visible differences one week on were  up by the intake manifold.  They had cut the pipe back and fitted a black sheath which is far less  intrusive.  The had also removed the old stainless steel manifold and fitted a cage to cover the end of the pipe.  However the pipe end is open and directly facing into the water flow with nothing to prevent  pebbles and smaller items being transported down the stream from finding their way into the system, so anything smaller than the mesh can also enter the intake pipe.  I think this may pose a problem for the future, potentially causing blockages in the intake pipe and significant costs and disruption to clear it. Some form of strainer or baffle is surely required.

 

Cage fitted over intake pipe, small stones of dam will be washed away with first rains In dryer weather the water level fails to cover the intake pipe

Click on images for zoomed view

 

The second and most important is the placement of the intake port on to the surface of the culvert, these images are very telling considering the recent weather has been wet followed by a short dry spell, the level here has dropped 20 cm since last checked.3 weeks ago.

 

This indicates the Peak flow of the stream may be very small in dry weather.

The problem is clear, the peak flow of the stream on dry days is so small that the water level in the culvert is no more than a centimetre or so and doesn’t even cover the intake pipe.  To solve this a small dam, and I mean small, has been created with stones and gravel where the depth of water behind this is sufficient to cover the intake pipe.

 

Culverts are designed to prevent debris collecting

As we discussed already, the smooth curved floor of the culvert is designed to prevent debris collecting in this location.  The Debris (dam) (photo above) will be removed by fast water flow.

Even with the current level of water flow the smaller stones and gravel around the intake pipe will be washed away eventually breaking the dam causing the water level to drop below the intake pipe and the water supply to fail.

 

In Spate the stream will remove all debris

With any heavy rain storm the stream will be in spate, the force of water will clear all of the rocks forming the dam in the culvert.  When in spate the stream can also carry branches and fallen trees down through the culvert but now with the fixed obstruction of the mesh cage there is a possibility that these will damage the cage or more likely get jammed on it causing a build up of debris in the culvert. This is not good practice and I would think it should be avoided.

 

The arrangement of the pipe has changed, now entering the river bank at a much lower level, the pipe is not secured on it’s traverse across the culvert and the gap underneath will most likely collect sticks and other vegetation then a build up of debris will possibly  occur.

 

Two months on and no further forward.

 

Around 2 months since the water problems became public and it would seem we are right back where we started with an intermittent supply determined by rainfall.   The National Park Authority really have to get their act together on this and stop penny pinching.  There is a problem with the water supply and it’s clear what it is.  In dry spells there is no water.  Get it sorted!  The solution is simple providing the stream does not dry up altogether, and only time will tell if that’s going to happen.

 

One thing remains clear, the LLTNPAs current solution is unlikely to work effectively even in the short term.

The real problem here is systemic failures within the LLTNPA

 

The LLTNPA Board should have been well aware of these problems as some apparently visited the campsite but have denied their existence in almost every public forum, even at their own board meetings.  I’m aware of one occasion where their spokesperson stated “As with any new site, there have been some snagging issues such as the running water which was unavailable for a few days due to a temporary problem with the new connection”  at least finally giving a nod to a problem everyone knows exists.     41 days of no water, limited water or intermittent water supply is hardly reflected by their “temporary problem”.   I believe it’s clear from the series of images here that the  problem has existed from the beginning and the vagaries of Scottish weather has determined if water was available or not. The solutions created  just promise more of the same – an ineffectual, intermittent water supply.

 

See here for video on the 19th March and here for the 2nd April

 

In the strange world of infallibility the LLTNPA inhabit even when they’rere wrong, they say they’re right and put out statement claiming all is well, whether it’s true or not.  This was certainly what happened at their board meeting on the 13th of March when numerous board members patted each other on the back for a job well done at Loch Chon and for getting the site finished on tiime.   This was witnessed by seven members of the public but should have been recorded for all to see.   Quite a surreal experience to see a National Park Authority  behave in this way.

By Ross MacBeath

Three Lochs Forest Drive Camping Permit Zone M

Following my visit to Forest Drive and posts on Zone B and Zone C, I thought I would cover zone M at the other end of Forest Drive because there was actually a family camping there when I visited on the 10th of April ’17.

 

Misleading information about the permit area

There are according to the Loch Lomond and Trossachs National Park Authority website no facilities in this permit zone, “no drinking water available” but “There are toilets half way along Three Lochs Forest Drive, up to 3km away.” 

* click map to zoom
  • The distance back along the drive to the toilets is 5.6 Km, if walking this would give a round trip of 11.2 km, not the maximum of 3 km implied, taking between 2.5 hrs to 4 hrs depending on pace.
  • Forest drive is a one way system, therefore to drive from any camping zone on Forest Drive to the toilets and return to your permit zone is a 14.4 km round trip taking about 45 minutes drive within speed limits

 

A Family with young children and a dog sold a pitch for a two man tent

The family of 5, 2 adults and 3 children, with a dog,  had purchased a permit for Forest Drive zone ‘M’: a site suitable only for a three man tent in a location wholly unsuitable for a family camp. The LLTNPA’s “Get a Permit site” misled them by not explaining the nature of the site or it’s capacity for tent size. The result is their 8 man tent had to be shoehorned into the only level space in the entire zone leaving them precariously close to an overhanging river bank.

 

8 man tent shoehorned into 2/3 man pitch
Pitching an 8 man tent on a 3 man pitch

Problems posed for these campers

It’s impossible to tension the guys properly due to the river behind and dense vegetation to the front so with high winds the whole lot could end in the river or collapsed with pole damage. Without space between the tent and the river, the central pole hoops each side of the door could not be pegged at the river side at all, leaving the tent unstable in the 26 mph winds experienced on 10th April when this camp took place.  Being so close to river,  the weight of an adult on the bank fixing guy lines could cause a collapse with at best a soaking, at worst a serious injury.  .

 

The door as you can see opens into the gap in the vegetation making entry and exit limited if not problematic, forcing entry to be made by a corridor in the vegetation. The greater area around the tent is a nightmare, it’s tick heaven and puts those in this area at some risk of tick bites. The nature of the vegetation also makes it likely that adders are present and care should be take especially in April when they come out of hibernation.   The use of sandals or even shorts would be ill advised due to the blanket of brambles prevalent in this area of the zone.

 

LLTNPA sells a product that fails to meet requirements then refuses a replacement.

 

The family in question were new to camping and oblivious to some of the problems they may face which could turn their first camping experience into a camping nightmare. They had identified on arrival that zone G by the loch side would have made a more suitable location for the family to camp. but there was no indication of this on the permit booking website as there are no photographs or descriptive text to the suitability of any zone.at Forest Drive.

In any case changing zones is not allowed under the parks  terms and conditions, which states “Permits cannot be transferred to other permit areas…” considering  they have been  mis-sold the camping experience that is no more than a cynical attempt by the LLTNPA to absolve itself from the need to provide a more suitable pitch which should have been identifiable during the booking process in the first place.

 

The LLTNPAs map for Three Lochs Forest Drive Zone M shows a long zone bounded by the river to the north and Forest Drive to the south  It details some trees at the western limit of a large semi oval camping ground becoming narrower corridor as it stretches east to the wooded area just below the gate. This area is expected to provide two camping pitches with visitor choice from the greater zone area. The image of the tent is placed over a location which in reality is a sink hole that drains runoff from the road in wet weather.

 

LLTNPA’s map fails to represent the true nature of Zone M

 

The Map of course does not represent what we find on the ground.  The shape of the zone follows the north and south bounds of the river and road making the true area of the zone similar in size but the narrow area between each end of the zone is filled with trees and scrub.  There is also a discrepancy with post position at the east end sign and yellow topped marker by the river.

 

The whole idea of a zone is misused here to con the public, stakeholders and ministers into believing something has been delivered when it has not.  It is clear the true extent of the camping zone is virtually  no larger than those areas shown in green and marked as pitch 1 and pitch 2 (on map below) and even then pitch 2 is not viable for camping due to the nature of the ground vegetation cover and it’s location in surrounding vegetation.

 

Diagram showing the poor access to Camping Zone M
Vegetation is dynamic and the diagram represents summer / autumn seasons.

Pitch 1 – a Natural “found” pitch by the river bank

 

As stated before, good camping pitches are found not made.

Pitch 1 is the only natural camping pitch in the  zone.  Its a small, level, dry grassy patch to the west edge of the zone. The pitch is longer and not much than wider than the path it sits on so will only suit a 1 or 2 man oblong footprint tent.  The presence of a mature fire ring indicates that this area has been used for camping in past seasons. This is not a new provision but an existing site. Being on a path into the rest of the oval area its not well situated as people and their pets pass looking for the second pitch or just exploring the area.  While at present there is another route down from the road it’s likely to be cutoff with brambles when the growing season begins. .

 

A natural pitch, used prior to byelaws but counted as new provision
Pitch 1 Long and Narrow and suitable for a two/three person tent.

 

Pitch 2 is not a viable camping pitch

 

The second pitch is just beyond the first, on the same path.  It is no more than a strimmed area of vegetation (bracken) on ground which is raised slightly above the surrounding area.  It is dry, even and fairly level.  The problem is the underlying vegetation has been cut back to provide the so called pitch in the middle of what is a dense patch of Bracken and Brambles.   When the growing season restarts it will quickly be come unusable without regular strimming and very undesirable when the surrounding vegetation reaches waist height.

 

 

Pitch 2 is not viable as a camping pitch, the cut down vegetation will re-establish itself and its location in the middle of bracken is wholly unsuitable.  The location is adjacent to brambles and will suffer encroachment if not already present on the pitch. Locating tents in .bracken is undesirable as it’s a preferred habitat for ticks.

The location of two pitches such in close proximity is also undesirable with the potential for mutual disturbance and the lack of surrounding space in this side of the zone make multiple occupancy undesirable.   The remainder of the half oval end of Zone M is not inaccessible to humans because of dense vegetation and brambles.

 

The west end of the zone is largely inaccessible.

 

The ground cover in the oval area of zone M, designated the camping area by the tent symbol in the Parks Map, in reality, like the rest of the area, offers nothing in the way of recreation.  It is both rough and bramble filled, where access to the rest of the zone is down slopes only if they are not overgrown and so blocked by vegetation. The central section where the zone narrows to a steep slope and with an almost vertical drop to the river it is not accessible.  The areas immediately to the west and east of the narrows are overgrown and bramble filled.

The Central Narrowed Portion of Zone M is Completely inaccessible

 

The central potion from the east of the zone to the west is impassable due to steep slope and tick vegetation. There is no connection path between the West and East side of Zone M’ The Bramble and dense vegetation covers almost half of the semi oval area shown with the tent symbol.

 

Thick brambles covering large areas of west side of Zone M, vertical slopes down to river.

The East end of Zone M

 

The east end of Zone M is somewhat inaccessible due to slopes and thick bramble entangled vegetation, There are three or so locations where access is possible down rather steep slopes there is nothing more in the area than a path through to one of the other exits.making entrance pointless as there is no viable camping locations or other reason to come into this end of the zone.other than to search fruitlessly for a camping spot or exploration.

 

These images were taken before the start of the growing season

The LLTNPA attitude towards visitors is shocking and their terms & conditions and regulations for the park are draconian:  “You must arrive at your permit area after
1pm on the first day of your permit and leave before 11am on the last day of your permit”  under threat of a £500 fine and a criminal conviction.

 

See terms and conditions here

 

The LLTNPA also take the view through their zero liability clause that it is your responsibility to decide on the safety of their product, that is the “camping experience” that they have sold you, which of course you can only do once you arrive on site.  Then, if the location is dangerous and unsuitable as is the case above, they expect you to put up with a poor experience or cancel your weekend and return home.

Ledard Farm, owned by Councillor Fergus Wood, situated by the start of the popular southern approach path to Ben Venue (heads up by Ledard burn to left)

At the beginning of March Councillor Fergus Wood, owner of Ledard Farm and a member of the Loch Lomond and Trossachs National Park Authority, submitted a planning application to develop a small camp and chalet park on the shore of Loch Ard.   Some of the documents associated with the application were published on the LLTNPA website in the second half  of March (see here).   While there is a need for more campsites in the National Park and there are several positive aspects to this application, it does raise a number of serious questions about the relationship between Board Members personal interests and the public interest and how this is being managed by the LLTNPA.   This posts explores the issues.

 

The positives

The proposed campsite will be accessed off layby (right of photo) and be located by line of trees which are growing by the Ledard burn

On entering the Trossachs West “Camping Management” zone, what is striking is that most of north shore of Loch Ard is uncampable – though not in the mind of Park officials who are so divorced from reality that they believe people can camp on rocks and in water,  About the only good place for camping on the north shore is in the fields in front of Ledard Farm which are owned by Cllr Wood.

Most of the north shore of Loch Ard is uncampable and was hardly ever used for camping – it did not stop the camping ban being extended to cover this area though, more evidence irrationality of the LLTNPA proposals.

Cllr Wood, unlike other Board Members, is obviously not against camping.  Indeed, the proposed campsite will be in full sight of his house.  What is more the LLTNPA, who claim they have been trying to persuade private landowners to develop new camping provision within the National Park, have had almost no success in doing so.  Cllr Wood, therefore, by submitting this application is setting an example to other landowners.   He is clearly not part of the NIMBY brigade – the contrast between what he appears to want to happen on Loch Ard and the exclusion of campers from the area around Loch Venachar House, the residence of the former convener Linda McKay, is striking (see here).

The Trossachs West management zone runs from Loch Ard to Loch Arklet and contains only two official places to camp and no campervan provision

 

What is also the case, if you accept the logic of the camping byelaws and the LLTNPA’s attempt to ban camping under access rights from the lochshores, is that Cllr Wood’s proposal addresses a serious shortfall of places to camp in the Trossachs West “camping management zone”.  Apart from the con at Loch Chon – where the LLTNPA has made no provision for campervans – the only other place people are allowed to camp (campervans can stop off as long as its on what counts at the verge of a road) is the permit area on the southern side of Loch Ard (which according to someone who visited and commented on parkswatch was not fit for use on 1st March).   Under the logic of the camping ban therefore, and I expect the LLTNPA to make this argument in their evaluation of the planning application, the proposed site helps reduce a shortfall of places to camp in Strathard.

In landscape terms there are questions about developing a campsite here – its a more open site than the site plan (above) illustrates suggests – and yet another chalet development would appear inappropriate.  However, the use of the word “chalets” appears misleading if the photos on the plan illustrate what is intended (camping pods would be a more appropriate term) and there are, in planning terms, a number of positive aspects to this development.   First, Cllr Wood has included accommodation for a site manager in the reception building, a contrast to the tourist developers in Balmaha who have failed to provide sufficient staff accommodation (see here).   This is also something the LLTNPA made no provision for at Loch Chon, their 26 place campsite just up the road.    Second, the planning application states the proposed toilets will be available for public use – a boon for walkers setting up Ben Venue – and a positive step to addressing the lack of public toilets in the Park – the number one issue that came up on visitor surveys until the LLTPNA stopped asking about this.   It would be good if the toilets could be open all year, unlike the LLTNPA’s own facilities.

 

Cllr Wood also set an example to other Board Members when, at the Board Meetings in both October and December 2016, he declared an interest “as a result of a potential future planning application” (the one that is now being considered by the LLTNPA) and then left the meeting for the “Your Park” items.   This was the first time I had heard a Board Member declare an interest and then decide they should not take part in discussion.  Cllr Wood’s actions contrast with those of his former convener, Linda McKay, and Board Members Martin Earl and Owen McKee, who not only failed to declare they owned property in a management zone at the meeting in April 2015, which approved the camping byelaws (Cllr Wood was not present at that meeting) but appear never once to have left a meeting.    What is highly ironic is that the one Board Member who has shown himself NOT to be a NIMBY has excluded himself from meetings but other Board Members who live in the camping management zones have contributed to the LLTNPA narrative on campers (irresponsible louts who always leave a mess) which has fed NIMBYIST views and never once recognised this as a conflict of interest. In my view, Cllr Wood’s action rather shows up the corruption at the heart of how the camping byelaws were developed.

 

Private interests and the public interest

 

Although Cllr Wood appears to be well ahead of most of his fellow members on the LLTNPA Board in being open about his interests, the planning application provides a number of reasons for the public to be concerned.

Extract from planning application for Ledard farm campsite as it (still) appeared 10th April

First, the application clearly does NOT state Cllr Wood is a Board Member.  Now I am sure this is just a mistake, but the whole point about including this section on all planning applications is to ensure transparency.  Board Members should be checking what is submitted in their name – it appears Cllr Wood has failed to do this and what’s more LLTNPA staff have failed to pick up the error in the ten days it took for them to publish the form.    Board Members have had endless training in declaration of interest over the last year and still neither they nor Park officials appear to be able to get even the basics right.  I am afraid its yet more evidence about basic failures in governance at the heart of the LLTNPA.

 

Second, and I believe significant, the application shows that that LLTNPA staff provided pre-application advice to Cllr Wood back in September 2015.

 

This raises two questions.

 

First transparency.  There is no information on the LLTNPA planning portal about what advice was given to Cllr Wood prior to this application (despite the reference number) but its not unreasonable to suppose the current application reflects advice from Park officials and they are therefore likely to recommend to the Planning Committee (all applications by Board Members have to be decided by the Committee rather than officials) that the application be approved.   Its in the public interest therefore that all communications from Cllr Wood or his agent and the LLTNPA’s responses should be publicly available to ensure Cllr Wood, as a Board Member, was not being favoured in an way.    Related to this, any consideration of the application also needs to state clearly whether there has been any discussion between the LLTNPA and Cllr Wood about financing the costs of this proposed development, whether this Cllr Wood was asking for financial assistance from the LLTNPA or conversely if the LLTNPA put any money on the table.

 

Second, the date of the pre-application advice, September 2015, tells us Cllr Wood has been considering this application for sometime.   While the two public Board Meetings which considered the camping byelaws pre-date that, in 2016 there were no less than six secret Board Meetings, four of which considered the byelaws and camping development plan.   As a result of an FOI request I have ascertained that the LLTNPA did ask for declarations of interest at these meetings (see here for example) BUT, because the LLTNPA claims no minutes are taken of these meetings, its not possible to tell either who attended or if they declared an interest.   This is wrong.   It also betrays the double think  behind how the LLTNPA operates,  on the one hand they claim these secret Board Meetings don’t take decisions but then at the same time they ask Board Members to declare interests at those meetings.   There is no way of the public knowing therefore if Cllr Wood took part in the secret Board discussions about campsite plans about which he had an interest or not.   This should be a matter of public record.  It would show either that Cllr Wood did the right thing from the start, and did not take part in these discussions, or else that his departure from public meetings was for show and that behind the scenes he had been contributing to discussions which impacted on his private interest.   There is therefore a serious issue here about the public interest, which while in this case is about Cllr Wood, is actually much wider than that, its about all Board Members and how the LLTNPA Board should operate.

 

The reason why its important to know about Cllr Wood’s involvement in Board discussions about the camping byelaws is they have an obvious impact on the financial viability of his proposed campsite.  Demand for the campsite will be influenced by where people can camp nearby and, while the planning proposal can be seen as a way of meeting a shortfall in provision locally, the converse to this is the way the West Trossachs Camping Management zone has been designed means that, if approved, people will in effect be channelled by the LLTNPA into Cllr Wood’s campsite.  This is most clearly seen in the case of campervans, where there is NOT one permit place for campervans in the whole of Strathard.  This means that any campervanner who did not know their rights would be likely to end up using one of the four motorhome places proposed for the Ledard Farm campsite, benefitting Cllr Wood.

 

Again, to give credit to Cllr Wood, he recognised this in respect of the planning application the LLTNPA made to itself for the Loch Chon campsite last year:

 

FW declared an interest as a landowner within a camping management zone in respect of item 4 North Car Park off B829 Loch Chon as he has an interest in loch shore campsite provision on his land. FW advised that he would leave the meeting for Agenda Item 4

 

While the minute shows Fergus Wood left the meeting, it also shows not a single other Board Member questioned the lack of motorhome provision at Loch Chon.   This I find very strange:  the effect will be to channel motorhomes to Cllr Wood’s campsite if his planning application is approved.   It seems to me that in order for the LLTNPA and its staff to avoid any suspicion of collusion in favour of Cllr Wood – and I am not suggesting he has had any part in this, indeed being pro-access the decision at Loch Chon might have been better had he remained at the meeting! – the LLTNPA need to open up the Loch Chon campsite to campervans.

 

The conflict of interest issues are even broader than this and concern Board Members contributing to the development of policies which have a direct impact on their own interests.   Whatever stage he decided he needed to leave meetings, Cllr Wood would appear to have taken part in policy developments that will facilitate his proposed campsite at Ledard Farm.  This is not just about the camping byelaws, although if he took any part in the development of the idea of camping management zones (before considering whether he should develop a campsite) that could be seen to have contributed to his private interests.  Its also about the development of the  Park Development Plan which was approved last year.  In that plan, planning applications for developments in the countryside will be considered in certain circumstances, one of which is if they contribute to the National Park Partnership Plan – which includes new camping infrastructure.   I somehow doubt Cllr Wood excluded himself from every Board discussion which has resulted in the current policy position of the LLTNPA which will be used to determine this planning application and which might benefit him.

 

Does this matter?   While I am sure Cllr Wood would claim at the time of those discussions he had no idea that he was going to propose a camping development at Ledard Farm, once he did start to think about this, it seems to me that a conflict of interest was created and the question then should have been not just about whether Cllr Wood would absent himself from specific discussions, but whether he should have continued to take part in more general policy development which impacted on his interests.

 

In a Public Authority with a different ethos, other Board Members might well have started asking questions and Cllr Wood might have, for example, stepped down from the Planning Committee.  This is the second major planning application Cllr Wood has made to the LLTNPA – the first was in 2013 for the Ledard hydro scheme.   Again, while he took no part in the meeting which determined that application, Cllr Wood had, as a planning committee member, been involved in developing LLTNPA policy and practice around hydro schemes.   Its possible to see this either as Cllr Wood setting a good example, doing himself what the LLTNPA was asking others to do, or as a conflict of interest.

 

In my view, its fine for Board Members to start practicing what they preach but, in any case where they might then benefit from this financially – in other words their business interests are clearly impacted on by the decisions being taken by the National Park Authority –  the only way they can remain squeaky clean is to step down.  While I respect Cllr Wood for his lack of NIMBYISM and preparedness to welcome visitors who may not spend lots of money, his business interests appear so entwined with what the National Park is doing that I don’t believe his current position is tenable.

 

With the local elections coming up, there is an opportunity for Cllr Wood to stand down voluntarily and for Stirling Council to replace Cllr Wood as one of their two nominees on the LLTNPA Board.  The much bigger issue however is how do establish a National Park Board which has a clear moral compass and sound governance.

Camping byelaw 10 and 11 provides for exemptions from the camping byelaws in the Loch Lomond and Trossachs National Park.  Camping byelaw 10 is for land (e.g campsites) and byelaw 11 for people.   The Loch Lomond and Trossachs National Park Authority has used byelaw 11 to set up permit areas within the camping management zones  (except that many of these places are unfit for camping (see here) and (here)).   Byelaw 11 also allows people to apply for exemptions in other areas in the camping management zones.   At present though the  LLTNPA has only advertised this facility on its camping pages to groups  (see here) such as the Scouts and the Duke of Edinburgh Award Scheme.

 

The reason for this, I believe, is not because the LLTNPA cares about young people being able to experience the countryside  – under the terms and conditions for the Loch Chon campsite people under 16 are banned from staying unless there is an adult with them while young backpackers walking the West Highland Way have been hit hard by the byelaws on east Loch Lomond –  but because the Scouts and D of E were very concerned about the proposed byelaws and the Park wanted to buy them off.  In fact the LLTNPA does not charge them for permits.  A clear case of divide and rule among recreational groups.

 

The camping permit areas created by the LLTNPA are of limited use to the Duke of Edinburgh Award Scheme and the Scouts.  This is partly because one of the points of going on expeditions is to encourage young people to be self-reliant and being herded together with other campers in permit zones is little different to being on a campsite.  Its also because the permit zones may not fit with expedition routes.   The LLTNPA, having removed the right to choose somewhere to camp on the lochshores where no one else is present, if that is what you wanted to do, or to suit your journey (eg if you are backpacking the West Highland Way) has in effect reinstated this for formal youth groups.   If this is the right thing to do for youth groups though, and I think it is, it should be right for everyone else too.   The way the LLTNPA is managing exemptions for formal groups just exposes further the unfairness of the byelaws.

 

LLTNPA officers have, however,  set up a system where organised youth groups need to apply for exemptions at least four weeks in advance and each application is then advertised on the weekly planning list (though its not clear if anyone can object – under the Scheme of Delegation approved by the Board at its December meeting its up to officers to decide).   What the system does is extend control over youth groups even beyond what was explicitly stated in the byelaws.   Its also hugely bureaucratic – if you don’t believe this read the form that groups have to fill in Group-permit-application

 

The planning list shows there have already been two exemptions approved for Duke of Edinburgh expeditions and two more are in the pipeline.  Here is an example:

The application form states that the LLTNPA may apply further terms and conditions to exemptions over and above the provisions in the standard terms and conditions for permit areas.   Since breach of the terms and conditions under byelaw 11 creates a new criminal offence, what this means is Park staff can create even more criminal offences for youth groups – or in other words increase control over them.   Its like creating an anti-social behaviour order for youth groups (rather than individuals) which controls what they do and when.   While NO terms and conditions have been applied to the  exemption above,  they have  been applied to the other application which was approved – see left – although what these conditions are is not stated.  They should be.  Another case of Park staff developing controls in secret.

 

In terms of the fairness about how applications for exemptions are decided, I have not  been able to find anything on the LLTNPA website which says how they will do this, although procedures are meant to be in place:

Extract from Board Paper December 2016

The criteria should be public to ensure that the LLTNPA is not discriminating in favour of one recreational group against other recreational groups or users.

 

The criteria also need to be made public because local residents and businesses need to apply for exemptions (see here) if they want to avoid friends or staff committing criminal offences, such as where they sleep in a tent overnight a garden or in a caravan within the camping management zones.  Local residents need to know what criteria will be used to decide applications they might make and also to ensure there is not one set of criteria for local residents and another for visitors.

 

Before the end of March there had been more applications for exemptions (I know of at least five) than happened in any year of the east Loch Lomond byelaws.

Extract from Review of east Loch Lomond byelaws

Its quite predictable that the number of exemption requests under the new byelaws is going to escalate and it appears the LLTNPA has not thought through either the cost implications of managing this or how it will manage this fairly.  I don’t think it can.   Access Rights were and are fair.  They allow you to camp as long as you do this responsibly.  There never was any need for the LLTNPA to add to this, the existing criminal law was quite sufficient but the Park is now trying to micro manage people’s behaviour.

 

That they are doing so should, in my view, be seen as part of a wider programme of social control.   I have just been reading George Monbiot book of essays, “How did we get into this mess?”.  This has many has interesting things to say about the increasing social control of young people and the impact of their increasing exclusion from nature.   The camping byelaws and the way exemptions are being managed, with ever more controls being put in place, are a good example of this.   The National Park should have been a breathing space for people from the Glasgow conurbation, instead its becoming a highly controlled place.

By Ross MacBeath

 

On the 13th March at the Board Meeting at the Loch Lomond and Trossachs National Park HQ in Balloch, the Your Park update report (see here) stated the “Loch Chon campsite is on course for completion and handover………….for 1st March” .   At the end of the meeting, in what appeared to be an orchestrated statement, it was reported  that the Board had made a site visit and all was found to be in order.    It will be interesting to see if this is recorded in the minutes when they eventually appear.
Having visited the campsite on the 12th March ’17, the day before the board meeting, I knew the statement to be untrue and have published  over a hundred photographs which are proof of this fact.  Its very worrying that Board Members who visited appear to have so little knowledge of camping that they were oblivious to the multitude of obvious problems and then that senior staff and the  entire board have colluded to hide the fact that all was not in order with the completion and handover of the development at Loch Chon.

 

Now, over a full month after Scottish Ministers were promised 300 new pitches were to be provided, allowing the Byelaws to be brought into force, the Loch Chon site has still not been delivered and many of permit zones are unsuitable for camping (see here) and  (here) for examples.  The majority of pitches at Loch Chon remain both unusable or undesirable as camping pitches – as of 2nd April 2017

 

General Conditions of site

The area remains a building site with tracked vehicles, tippers and aggregates at one end of the toilet block and an unwelcoming mess at the entrance container known as the site office and bin store. We are into April and the only pitch that’s truly serviceable is pitch 21 which is coincidentally the only pitch on the entire campsite the LLTNPA did not create.

 

The Park Authority’s hypocrisy knows no bounds

After chastising Campers and Visitors for leaving black bags of rubbish by overflowing bins and  handing out penalties, here we have the Park Authority leaving their own bags of rubbish by the bin store, the entrance to which is strewn with various building materials creating a great first impression for visitors.


This is typical of what we now see in the undesirable culture created by the National Park Byelaws,  where the law makers and their landowner or business partners don’t have to comply with any laws they have created for park users.

 

Drinking water issues continue to plague Loch Chon campsite

 

No Drinking water or dish washing facilities available at site.

Although the site is claimed to be fully operational, there is no treated drinking water to the external taps, preventing container filling and dish washing. 3 of the 4 toilets remained locked.  The 4th is open with flushing cistern and working wash hand basins. I suspect a re-plumbing exercise has diverted the drinking water to the toilet block, though the  LLTNPA still insist the issues only lasted a few days despite the almost weekly video reports to the contrary.


The promised sympathetic integration of containers into the site has been greatly exaggerated, this solution for buildings in a National Park is just tacky, it’s not appropriate for a National Park and ruins the aesthetic of the entire development.

 

Cross contamination of materials used on site.

 

The uncontrolled spread of construction materials beyond the confines of paths and roads is a major concern at this development and this will be the subject of an environmental post shortly.  What’s going on now is the cross contamination of finished works with a new quartz aggregate material introduced to the site.  The use of quartz aggregate in an ancient forest needs to be avoided. It’s an alien material and grates at every view but when it’s spread through the environment in this manner it should be a crime.

 

How is this possible when there is an appointed clerk of works with responsibly for overseeing all variations to the original planning application and agreeing and documenting all construction work meets environmental standards? The need for a remedy is clear and mixing of this aggregate with vegetation can only be restored by picking it up stone by stone rather than the heavy handed machine operation that has damaged the site unnecessarily in other locations.

Environmental Damage created through attempting to clear contamination by alien materials

 

These images show an attempt to clean up hardcore.deposited on a slope.

Cross contamination with hardcore, perhaps the original rout of the path? Attempt to clean off hard core contamination by scraping with excavator.

The original contamination on the left and the disastrous attempt to remove it effectively  has caused destruction to the hillside in the process. It remains unclear why  the hardcore was deposited on vegetation in the first place, given the area, probably a path placement error.

 

Pitch problems and solutions

 

The LLTNPA has introduced grit to camping pitch surfaces: grit is a disaster for camping as it’s carried into the tent sleeping area and sticks to everything – what are they thinking?!

 

Many of the proposed pitches were covered in rough grasses, mosses and rushes:  successive cutting of the coarse grasses have removed the rough edges but the reality is they are still not suitable as a surface for pitching a tent and will deteriorate rapidly through the growing season.

 

Uneven surfaces and slopes: inappropriate aggregates and graded building materials have been spread over peat and moss to even out the ground but fail to to make it level.

 

Wet areas: with the exception of Pitch 8 and 10, wet areas remain untouched, I guess it’s a wait and see and hope summer weather will dry them out.   It probably won’t,  they’re built on natural water courses, as was pitch 10.

 

Brambles: still pose a great threat to the pitches it looks like they are just being covered over rather than removed.  It won’t work, brambles need intensive management.

 

Access to popular camping spots denied by the National Park Authority

 

The image below shows a typical and popular loch side camping spot now banned by the bylaws. It’s high amenity, provides a level, short grass surface over firm ground, the surface is even with sufficient depth to take tent pegs. it also covers a large area and so provides for cooking  and sitting around the tent to eat.  The proximity of the loch shore and open areas allow for play and other activities making for a good visitor experience.

This is a former Forestry Commission camping pitch where camping is now banned. It is sited within view of the useless ‘Three Lochs Forest Drive Zone L’ by Loch Achray

 

Pitch 1 just not up to scratch

 

12th March Sowing the nature of the surface that is pitch 1 Superficial cutting does not change anything it will grow back in a few weeks when the growing season starts.

In stark contrast the National Park’s  paid for replacement is just not suitable.  These low lying areas are sited well back from the shore on wild tussock grass which, by it’s very nature, is unsuitable for camping.  It is uncomfortable if not impossible to sleep on.  There is no firm ground to light a stove, place a seat or even sit or lie down on a beach towel.  Then consider these photographs were taken in the dormant season (March 12th/April 2nd) after winter die back, when new growth takes hold matters will rapidly worsen.   The old adage, good campsites are found not made holds true and if you insist in making them them they take years to create and require much more work than than a brush over with a strimmer.

 

Pitch 4

 

Pitch 4 has been trimmed leaving the solid core of tussocks with depressions of 8 to 10 inches the pitch remains unsuitable.

Pitch 5 fares only slightly better over a confined area.

The crux of the problem is the Park Board and senior staff clearly know nothing about camping and  the vision the Park Authority has for its camping provision is far from the expectation and previous experiences of visitors who have enjoyed camping at popular loch side spots for decades.  The most used camping places were popular for a reason, they were good for camping.

 

Pitch 6 – improvements or just hiding the problem?

12th March 2017 - before improvements 2nd April - after improvements            Pitch 6 -19th March compared to modified pitch 2nd April

Pitch 6 has been covered with grit. It’s not a material you want inside the tent and yet that’s exactly what’s going to happen here.

 

A bright quartz aggregate overlaid with a graded building material, it is not constrained at the edges and so is likely to spread out over the adjacent areas.  It is also likely that the finer materials will be washed into the aggregate with rain leaving an inappropriate bright quartz aggregate finish to the area.  This pitch surface requires to be a natural material in an ancient wood and where works have been carried out that should be grass  This grit is going to cause no end of aggravation to campers as it’s carried in to the tent and deposited in the sleeping area, wholly inappropriate.

 

The evidence of bramble stalks showing through the surface indicates the underlying ground cover of brambles will remain an issue as the removal of a bramble infestation can take up to 2 years of concerted effort of cutting back and digging out roots. Simply burying the problem out of sight will get you through the site handover but they will grow through in a matter of weeks.

 

Pitch 7

Pitch 7 19th March

Pitch 7 has been reworked

 

Disabled sites 8 and 9 have had a makeover

 

The two disabled pitches were an embarrassment see video of pitch 8 here.

 

The NP have attempted to constrain and divert the water course around pitch 8 while raising the finished surface of the pitch and that should solve the water problem. It is unclear whether the hardcore layer extends below the entire pitch.  If it does we can only hope the soil depth remains around six inches otherwise pegging out the tent base will be an issue. As to the brambles, these will almost certainly grow through the hardcore layer to the surface once more unless the entire subsoil was removed.

Park Authority re-sites pitch 10 and Pitch 12

Pitch 10

This is typical of the area of the former pitch 10, obviously not a good choice for camping. The former Pitch 10 a site of environmental destruction which was totaly avoidable if anyone at the NP Authority gave a shit.

Unbelievable but true, the site of the former pitch 10 was a peat bog.   Unfortunately when the Park Authority designates a pitch a mechanical digger drives across it for good measure.  The whole area should never have been selected in the first place, it’s just incompetence and results in a large area of unnecessary environmental damage.

Pitch 10  re-work

 

The new pitch is undoubtedly drier but unfortunately in the middle of a bramble patch with the trees to one side and the bog to the other.

 

New Pitch 10 Created on Bramble Patch Close up of Pitch 10 showing brambles and bracken

 

Brambles, an invasive species.BBC Life of Plants - Brambles

While it should be obvious with ground sheet piercing thorns, brambles and tents don’t mix and are to be avoided. It is unacceptable to construct a pitch containing or even adjacent to brambles as they will cause both financial loss to the camper and possible injury.

Pitch 11

 

Pitch 11 remains an uneven wet mess.

 

Pitch 12

 

The old Pitch 12 leaves a scar on the environment

 

Pitch 12 is re-sited from a slope to a more suitable area near by.  All that is now required is to reinstate the environmental damage to the old site (see LH image) and trim up the new site removing moss and grass clumps.

Pitch 13

Pitch 13 remains unusable even after trimming

N.B. Pitch 14 and 15 are reversed on site

Pitch 14 re-work includes surfacing with quartz aggregate infilled with fines

 

Having decided to do something about the problems at some of the pitches the National Park Authority has still failed to take on board the issues with their camping provision.  It’s simple.  Pitches require to be level, even, dry and able to take tent pegs with area of about 5 m X 5 m as a minimum to allow for cooking and other activities by the tent.

 

Pitch 14 showing slope to side of slope and down towards path.

 

The problem with Pitch 14, as with so many at Loch Chon, is size and the slope.  It’s just too steep to be a viable camping pitch.  In an attempt to make the pitch surface even, the Park Authority have covered the area with their inappropriate quartz aggregate / gravel mix and while it is now even they have completely failed to correct the slope which is far too steep to be used as a camping pitch.This is a double slope, across the hill and down the hill, and will cause campers to role into each other and  push the tent sides into the fly, letting water penetrate.

 

The second problem is that the topping used to provide an even surface is not constrained and will inevitably spread out over the surrounding area, reducing effectiveness and contaminating a far greater area.

 

Pitch 15

Marked 14 on post in error!

 

Similar solution to pitch 14 with grit.  Recent works have made the pitch level but the surface is not constrained so very quickly the whole of the aggregate will spread down the slope leaving the pitch back where it started.   The size of this pitch has been confined to around 5 square metres from the 25 or more square metres available.   A tent pitch requires to be at least twice the size of a tent footprint giving a desirable minimum of around 12 square metres  and an optimum minimum of 25 square metres for a two/three man tent.

 

The site selection is again poor with the lower point of the first image in a water course.

This project was doomed to failure but no one expected it to be quite so dramatic

 

The sad fact of the matter is that the Loch chon site was selected not on its merits as a camping site, nor due to demand for camping in the area.

 

It has been created for one reason, and one reason alone, to enable the LLTNPA to be able to say to the Minister that it had created a new campsite  by the 1st of March.and in doing so the environment of the ancient woodland at Loch Chon was no more than collateral damage.

 

How has this happened?

 

To create the Loch Chon campsite it is my opinion that the National Park Authority have engaged in a willful deception of the public and other stakeholders at every stage of this unwarranted development.

 

The LLTNPA have exaggerated the numbers using the area and any environmental concerns arising from that use.

 

They have deceived local communities and interested parties as to the care and attention they would exercise on the site to protect the greater environment while providing a sympathetic development.

 

They have intentionally misconstrued their own ranger figures making claims of equivalence of this site to the Forestry Commissions site at Sallochy.

 

The balance of the pitches and financial aspects of the project will be covereD in part two of this post…

Former bunkhouse at Balmaha transformed into a private residence for Wayne Gardner Young. Planning permission for change of use was applied for in 2011 but has still not been agreed.

The planning application for social housing at Balmaha on a site designated as Ancient Woodland raises some major issue (see here) which I hope to return to before it is considered by the Loch Lomond and Trossachs Planning Committee.  Meantime, in order to understand the application, it needs to be considered within the wider context of land-use at Balmaha.

 

Since the National Park came into existence in 2002 Balmaha has been transformed into an upmarket tourist accommodation village rather than a place for people to live or, indeed, somewhere that people with less money in their pockets can stay.    This is happening because of planning decisions by the National Park.

 

The site of the former Highland Way hotel

Luxury Lodge in construction November 2016

The former Highland Way hotel, situated across the road from the Oak Tree Inn, closed in 2006 and a planning application for a Bar Restaurant and 13 holiday cottages on the east part of the site was approved in 2008.  The McKever Group, which owned it,  went into administration in 2009 but only, as far as I have been able to ascertain, after demolishing it  – leaving a wrecked site.  Wayne Gardner Young, the entrepreneur who moved into the former bunkhouse (top photo) and who had had grand plans with the LLTNPA for the West Riverside site in Balloch then acquired the eastern part of the site for a bargain price (see here).

 

In 2011 Wayne Gardner Young joined forces with Sandy Fraser, the owner of the Oak Tree Inn, who owned the land to the west of Balmaha House (where there is still a 14 place bunkhouse, the last place in the village providing basic accommodation).   Sandy Fraser had previously had a planning application for a shop and bunkhouse on the western part of the site approved but this had lapsed in 2009.   Together they submitted a planning application for a single development including 24 chalets covering both parts of the site in 2011.  This then stalled, although this did not stop Wayne Gardner Young from building foundations for a number of buildings and erecting a luxury lodge in 2014, all without planning permission being approved.

The very high specification storage shed – or as the LLTNPA described it Lodge No 15

 

 

Mr Gardner Young then applied for retrospective planning permission (2014/0238/DET) for this building – photo above – describing it as a storage shed. There is a good explanation of all of this in the report to Planning Committee in 2016:

 

 

 

In 2016 Sandy Fraser and Wayne Gardner Young submitted a revised application for the site, which included a restaurant, smokehouse and micro brewery and  20 Lodges, four less than the previous application.

The Buchanan Community Council objected, for a number of reasons, including:

 

Its worth reading the Committee Report (see here) to see just what convoluted arguments the LLTNPA used  to try and show that the development was in accordance with its development plan (pages 14-25).   None of the negotiations that took place with Wayne Gardner Young and Sandy Fraser are published on the planning portal so its only conjecture what happened but it appears that LLTNPA officers did try (they had got the development slightly reduced in size and also agreement to create a public path going through it) before recommending approval.

 

I won’t dwell here on the failure by the LLTNPA to take enforcement action in this case.  Development in Balmaha increasingly appears to be a free for all and a significant percentage of all planning applications appear to be made retrospectively (there is a fantastic project to be had on the history of planning in the village since the creation of the National Park).    The key point  in relation to housing and use of space in the village is that the development includes 20 new holiday lodges and just two flats for staff accommodation above the restaurant.  The Committee Report failed totally to consider whether these were sufficient for all the new staff required for the business and the LLTNPA made no requirements for residential accommodation to be provided on site.  There are parallels with the even bigger Torpedo site development at Arrochar which was supposed to create 300 jobs (see here) also without adequate provision for new accommodation for workers to live in the village.   The situation in Balmaha has been made worse because the LLTNPA  made it a condition of the planning approval that none of the 20 tourist lodges could be occupied permanently, in other words none could be used to house staff or people working in other businesses.   A great lesson in how to create an instant housing shortage.

 

The decision at the Highland Way Hotel site though simply worsens what was already a severe housing shortage, to which at least two other tourist accommodation developments have made significant contributions.

 

The Oak Tree Inn

The Oak Tree Inn, which is run by Sandy Fraser’s family, does not just provide accommodation in the Inn – certain modifications to which had planning permission agreed retrospectively in 2010 – it also provides accommodation in a number of houses on the south side of the B837 which is currently advertised at between £80 (for a single room) and £165 a night.

Info on Oak Tree Inn associated businesses and accommodation from their website

 

It appears this accommodation is in effect an adjunct to the Inn and, while I cannot find any planning applications that cover this, perhaps planning permission was not required?   Whatever the case, another section of the village appears devoted to the provision of luxury holiday accommodation.

 

Balmaha Waterfront

 

The third large existing tourist development in Balmaha is called the Waterfront and provides another 11 Holiday Lodges as well as a function centre (on what used to be a garden centre there).  Planning permission for this was agreed back in 2004 on condition that the site was concealed behind new woodland planting.   The owners have recently in 2017, having apparently failed to deliver the conditions of that planning permission (the site is highly visible from the road), applied to have it varied.

 

The cumulative impact of “luxury” tourist accommodation in Balmaha

 

As well as the three developments described above, the LLTNPA in 2011 approved the development of 19 holiday chalets behind the National Park Visitor Centre subject to a legal agreement.  Had this gone ahead it would have altered the proportion of tourist to residential accommodation even further.   Local objectors to the proposal to build social housing on the designated Ancient Woodland Site believe this should be used to provide the  social housing.   The site is, however, not on the market and strangely it did not appear in the Local Development Plan unlike the Ancient Woodland Site.  Its not clear therefore what plans, if any, exist for it.  A case for a community buyout perhaps?

As a consequence of all these tourist developments, none of which appear to have made adequate provision for the workforce which services them, there is a housing crisis in Balmaha.  The LLTNPA half acknowledged this this back in 2014 in its charrette report for Balmaha (see here) which informed the local development plan:

The community at Balmaha are concerned about development of holiday accommodation and do not want to see an imbalance created between local inhabitants and transient visitors. There are strong and active tourism based businesses in Balmaha, and there is a feeling that there is potential to manage existing visitor numbers better whilst improving the visitor experience and generating more local income

 

This acknowledgement did not stop the LLTNPA approving the Highland Way site development, creating further imbalance,  but by then they knew Forest Enterprise and the Stirling Rural Housing Association were riding to the rescue with the woodland site.    Because of the local housing shortage its not surprising that there has been strong support from people who work within the area that they should be provided with somewhere to live locally.   Its these people who appear to have turned up to the Buchanan Community Council meeting earlier this year and got them to agree to support the proposal to build social houses on the ancient woodland site.  One wonders, if they had been given a choice of site, whether they would have still supported the proposal currently on the table?

 

What appears to be happening in Balmaha in terms of spatial planning is that the provision of social housing is being shunted to the fringes of the village, rather than being integrated with tourist accommodation and other housing.  Maybe rich visitors and residents prefer most of the workforce to remain out of sight?   The Park’s decision making process however has also benefitted the new lairds pockets.  Instead of having to make provision for housing the workforce they need to service their developments on their own land, which would incur significant costs, the public sector is doing this for them.    Another case of the “taxpayer” subsidising business.  This happens in towns too of course but, in a small place like Balmaha, which is geographically isolated it becomes much more obvious.

 

Balmaha – a tale of developing social segregation and exclusion

 

What’s happening in Balmaha is not just about segregation of workforce and visitor, its about the type of visitor the village caters for too.   Balmaha is a prime stopping off point for walkers on the West Highland Way, the natural end point to the first day for fitter walkers setting out from Milngavie.  Yet it has no campsite, and despite all the flat ground, and representations to the LLTNPA, there are NO plans for one.  Bunkhouse accommodation is now minimal.  To make matters worse, the camping byelaws have been extended on east Loch Lomond, making it even harder to camp.  LLTNPA Rangers now, not surprisingly, spend much time chasing campers away from the village.

 

Meantime Sandy Fraser has been one of the most vocal public supporters of the camping byelaws on east Loch Lomond (see here).  In that interview he claimed campers intimidated other visitors when actually, most campers did nothing of the sort and those that did could have been moved on or charged by the police.   A few more may have left litter but how did that compare with the eyesore on the land he owned in the centre of the village?   One law for the lairds, another for everyone else.

 

 

 

The entrance to the site Sandy Fraser owns tells another tale.  Park Rangers walked past this for years – its clearly against the Scottish Outdoor Access Code – but they and their bosses did nothing.

I don’t know if the caravans in the upper photo are still there – they might have been removed once work started on the development – but if anyone was still staying in them, they could now be committing a criminal offence under the camping byelaws.   I am not sure Sandy Fraser or others in the local community appreciated this when they agreed to remove their opposition to the repeal of the existing Loch Lomond byelaws at their meeting in January:  the old byelaws had allowed locals to put up tents and sleep in vehicles within the curtilage of their buildings.  Still, the Park Chief Executive, Gordon Watson is recorded in the minute of that meeting as saying the new byelaws were better and it appears people believed him.

 

The new version of the byelaws makes sleeping overnight in a vehicle – and a caravan is classified as a vehicle as I understand it – in a camping management zone a criminal offence unless its on a road or is done by the landowner, their immediate family or a tenant with a lease of a year or more.   Landowners can no longer allow people to sleep in vehicles or put up tents in their own gardens.   The gate sign appears to indicate Sandy Fraser thought there was no public right of passage here (a private road is only classed as a road under the Road Traffic Act 1984 if there there is a public right of passage along it).  So, anyone apart from Sandy Fraser and his family, or a long term tenant, staying in a caravan on this development site would be committing a criminal offence unless they been granted an exemption by the National Park.

 

One good thing perhaps about the camping byelaws?  They could highlight which tourism accommodation providers are not housing their workforce properly.  (They should be checking every caravan in the Park that appears to be being used for housing purposes and forcing them to apply for exemptions).The likelihood of the LLTNPA ever enforcing this though appears small – the byelaws would probably collapse

 

The whole story of the Highland Way Hotel and other tourist accommodation sites in Balmaha shows how little power the LLTNPA has over the new lairds.  Or perhaps its the other way round?  It maybe shows how much power the new lairds have over the Park Authority.

Slide presented to Stakeholder Forum November 2016 – the clear priority for the Park is to enforce the byelaws, but how?

Back in November I submitted an FOI request to the Loch Lomond and Trossachs National Park Authority intended to enforce the proposed camping byelaws:

 

“all information relating to any intention to prosecute whether internal, discussions or communications with the police, procurator fiscal, Forestry commissioner anyone else who might be involved in enforcing the byelaws.”

 

The Park  refused my request (see here), stating that it  was too general but committed to producing an enforcement policy and, on 24th March, I received an email to say that it had been published  (see here).

 

What is the status of the Enforcement Policy?

 

The first thing to note about the Enforcement Policy is that it has not been considered or approved by any public meeting of the LLTNPA Board.  In my view its the National Park Board that should decide policy, not staff – though its possible the Enforcement Policy was considered at a secret Board Briefing session earlier this year.   This contrasts with the LLTNPA’s litter enforcement policy – which is referred to in this new policy – which was considered at a Board Meeting, in June 2016.   However, even in that case Board Members were only asked to NOTE the contents of the policy, not to APPROVE it:

 

This is yet another governance failure.   Can anyone in the LLTNPA explain why, when the Board was asked to endorse the approach to signage about the byelaws in December 2016,  they have not been asked to endorse or approve the enforcement policy?   It appears the main decision-making power left with the Board now is to approve financial expenditure and formal plans, all other decisions are left to staff.    This is wrong and way below the governance standards of local authorities.

So what does the Enforcement Policy tell us?

 

I had hoped the Enforcement Policy would say how the LLTNPA proposes to deal with certain situations which I believe make the byelaws all but unenforceable:

 

  • the thousands of visitors who will camp, light fires, put up shelters, try to sleep overnight in their campervans off a road who are completely unaware that they are committing a criminal offence
  • local residents, apart from the landowners and immediate family who are exempt from the provision, who put up tents and bivouacs  in gardens within the management zones or occupy a form of shelter overnight
  • people who know they are contravening the byelaws but do so for safety reasons (eg cycle and canoe tourers who stop because of exhaustion or bad weather)
  • and, on the definitions front, what activities relating to lighting of fires are seen by the LLTNPA as likely to cause damage?

 

The Enforcement Policy does not answer any of these questions.  Perhaps the answers are contained in the procedures referred to at the end of the policy (which I have now requested under FOI):

 

 

 

What the enforcement policy shows is the LLTNPA is sitting astride two horses which are about to gallop off in opposite directions.   The dilemma for the LLTNPA is they would really like everyone to just accept the byelaws, and not to have to refer anyone to the Procurator Fiscal, but at the same time as soon as it becomes known the Park is not enforcing the byelaws people will simply ignore them.   For this reason, while the Enforcement Policy says a number of sensible things about the need to engage visitors, it also states:
 
“the Park Authority will always reserve the right to proceed straight to legal sanction should the Park Authority consider that, in the circumstances, this is the most appropriate course of action.”
 
What are these circumstances?   The LLTNPA refuses to say.
 
The dilemma for the Park is illustrated by the action taken by David Lintern and friends,  which David covered in a fine piece on Walk Highland (see here) – essential reading for anyone who cares about access rights.    I fully support David’s deliberate testing of the camping byelaws – unjust laws are just that and deserve no respect – and no-one breaching the byelaws who is camping according to the Scottish Outdoor Access Code should be prosecuted.   So, have the LLTNPA referred David to the Procurator Fiscal?    If they have, I predict a storm of protest.  The risk for the Park is that a very public prosecution of someone for challenging the byelaws will show up how unjust they are, treating  responsible camping without the Park’s permission as a more serious offence than dropping litter or using a mobile phone when driving.
 
If on the other hand the LLTNPA haven’t referred David to the PF,  its going to be very difficult for them to take action against anyone else who deliberately breaches the byelaws in future as a precedent has been set.
 
As the LLTNPA Enforcement Policy says:
 
 While the enforcement policy highlights the need for consistency, it says nothing about how this will work, i.e in what circumstances the LLTNPA will actually refer people to the PF.  Its just yet more parkspeak.    So, any camper who faces prosecution, should just ask the Park what has happened in similar cases.
 
The explanation for this lack of clarity is I believe contained in the policy:
The byelaws need our implicit consent to succeed.   What that means is the LLTNPA needs wild campers to know what areas are covered by the camping management zones and apply for permits in advance.  If the LLTNPA was clear about when it was going to try and criminalise people, it would be easy for people to get round the byelaws.  However, if people don’t respect the rules the Park is trying to create and don’t give their consent to them,  if people simply turn up and camp responsibly (whether inside or outside a management zone or permit area) what is the Park going to do?   Their enforcement policy can’t tell us but I am not sure there is that much they can do anyway.
 
A primary reason is most people won’t know about the byelaws.   The LLTNPA could put up more signs, spelling out what activities are banned, and then prosecute people who ignore these signs.   This may yet happen – there are indications that a second phase of signage is planned to add to that approved by the Board.
Sign from Secret Board Briefing session 19th September 2016. The no camping sign on right was not included in the suite of signs approved by the Board in October 2016.
The LLTNPA has however already spent  £100k on signs that tell the public very little and the cost of installing a no camping sign in every possible camping place along the loch shores is likely to be prohibitive.
Slide from secret Board Meeting September 2016.

 

The “Threshold” signs are those at the entrance to the management zones.  No wonder staff were not keen when Board Members suggested there should be signs telling people that they were leaving the camping management zone – that might have cost another £60k.  It appears that if the Park was to install small “no camping” signs it would cost £500 apiece – there must be at least 200 good places to camp outwith the camping permit areas so that’s another £100k.   Not good use of public money, but without signs it will be almost impossible to enforce the byelaws because most people won’t know and if referred to the PF can use this as a defence.  It won’t look good if a visitor stopping off to camp overnight in a car is prosecuted – in fact I suspect the PF will regard this as a waste of Court time.  The LLTNPA has ducked this issue, in fact its head is in the sand, about how it can ensure everyone stopping off knows about the camping byelaws.

No camping sign mock-up presented to Secret Board Meeting September 2016.    This glossy mock-up illustrates the Park is all about style, not substance.

The problems are illustrated by the proposed no camping signage which was never put to the public Board Meeting in October.   Imagine approaching this layby with a campervan.  The sign says nothing about sleeping overnight in campervans being a potential breach of the byelaws.   Its hard though to see how any sign could accurately convey the legal position.   Legally, roads are exempt from the provisions of the byelaws and the legal definition of a road includes its verge.  So,  if you pull off this road onto the flat verge between the two signs, or behind the one on the left, that’s quite legal.  However,  if you could drive the campervan down towards the loch shore, as soon as you left the verge if you slept in that position overnight that would be an offence.    The LLTNPA is never going to be able to convey that message by signage and the byelaws are as a consequence unenforceable for campervans.  Interestingly the enforcement policy says NOTHING about the different enforcement approaches Rangers might take depending on whether someone is camping, in a campervan or has put up a tent in the garden of a house they are renting.

 
The enforcement policy describes two general approaches to people breaching the byelaws, which it describes as the Preventative Approach and the Escalated Approach.  The first is mainly about informing people:
What’s interesting about this is that the Park classes the effect of negative behaviour on the environment as being the same as contravening the byelaws.  In fact the byelaws do almost nothing to tackle “negative behaviour” – that is a myth put out by the LLTNPA – as this is already fully covered by other laws. All the byelaws do is ban people who are camping responsibly.  The Park however wants to try and persuade responsible campers that by the very act of camping they are being irresponsible.  This won’t work.   It requires people to abandon all their critical faculties and specifically to accept that the LLTNPA is a better judge of where to camp than you are.   All the evidence shows the Park is totally incompetent to manage camping and nothing they say should be trusted (see here) or (here).
 
The second approach will be taken to people who breach the byelaws, whether inadvertently or deliberately:
The important words here is that the Park is in these cases going to try and stop people doing what they were doing.  So, if you inadvertently camp in a management zone, the Park Rangers are going first of all to ask you to leave – what they call a voluntary resolution of the breach.    It appears therefore that as long as a camper is generally co-operative with Rangers,  in other words agrees to move their tent or apply for a permit, there is little chance of them being referred by the Park for prosecution.
 
However, the enforcement policy does not cover what happens in specific circumstances, such as:
 
  • the camper is exhausted or ill or otherwise in a position which makes it unsafe to move
  • what happens if this is a repeat breach of the byelaws, in other words the person camped previously, agreed to move on, but has returned to camp on another occasion

The second point is crucial.  Under the byelaws the LLTNPA has the right to take the name and address of people breaching the byelaws.  It has not said what it will do with this information (this is something else which should have been decided by the Board), how long it will store it or whether it will record other information such as whether the camper has been informed about the nature and extent of the camping byelaws and the implications of breaking them again).    One way to find out if you provide this information is to submit a  Subject Access Request under Data Protection legislation to find out what information is being held about you.

(to be continued)

By Ross MacBeath
View from 1 of 3 existing pitches in Zone B. This overlooks roundabout at entrance to forest drive Zones B and C.
Entrance to Forest Drive Zones B and C

Forest Drive

In order to stop people from camping by the loch shores and to meet their commitment to Scottish Ministers to deliver 300 “new” camping pitches, the LLTNPA had to find somewhere else for people to camp – so they leaned on Forestry Commission Scotland to use their land and have “created” no less than 76 permit places (just four of which are for campervans) along Forest Drive north of Aberfoyle.   In the past, the camping here has been mainly by Loch Drunkie, which has a few places close to the loch side which are good for camping, and the south shore of Loch Achray.   I went to have a look at the “new” areas and this post focuses on “Zone C”  so readers can understand the implications of what the LLTNPA is doing to campers.

Forest Drive Camping Zone C

The National Parks new maps of Zone ‘C’ indicate large expanses of open ground in a woodland locations with what looks like ample opportunity to choose a camping place by the waters edge or in among the trees.

 

Arriving just after 4 PM I  found locked gates, a now common occurrence in part of a park wide policy of denying access to visitors outside office hours.  Worse, it seems the code for exit is only granted if payment has been made through their permit booking system, effectively making access to our National Park on a pay as you go basis. Information on the Three Lochs Forest Drive page  states that “The drive is open to vehicles from Easter to October, daily from 9am”  The byelaws however started on of 1st March so this means there is a denial of access to 72 camping and 4 motorhome places until the 16th of April this year. Surely not!   Or maybe the LLTNPA just  need more time to get some camping provision in place at Forest Drive.

 

Access to Forest Drive and other gated facilities is in disarray

 

The Three Lochs Forest Drive page tells us access will be available until 4 pm and the exit gate locked at 5 pm after which a code is required to exit.  Other locations have different opening and closing times and the T&Cs for Loch Chon contradicts itself.  Confusion reigns and the National Park and Forestry Commission need to get their act together because at the moment it is the visiting public that is suffering through wasted journeys and uncertainties.  It is unacceptable to lock out visitors after encouraging them them  to drive for an hour and a half gain access to forest drive only to be turned away by a locked gate. Quite clearly visitors are being excluded from this area of the National Park at a time when access is most desirable, in the evening after work or as in this case, Sunday afternoon.

 

Camping Zone C

A Camping Zone without camping pitches

Camping Zone C is a short distance along a wider than expected compacted hard core road, not what the the term “Forest Drive” conjures up, more of a  superhighway.  The vista beyond the boundary sign, though beautiful, was clearly not the camping ground expected. The description on the LLTNPA  booking site warns of some “uneven terrain in places” but nothing like this.  In point of fact the entire zone is uneven in the extreme, except for a path that’s not indicated on their map. It’s is not an area one would choose to enter or cross if it could be avoided never mind to search out and use a camping pitch. A clear case of false advertising and  LLTNPA will find themselves challenged legally about this and many similar misrepresentations that comprise their  so called “camping provision”.

 

North West corner of permit zone 'C' with first perimeter post back right.
First view of Camping Zone C – a shocking place to camp

This entire zone is unsuitable for recreational camping

 

Not seeing anything that resembles a camping place from the road, I walked around the perimeter marked out by a line of yellow topped wooden posts.  This gives a view from the perimeter in to the Camping Zone and I hoped I would be able to identify potential camping places along the way. You can view progress by clicking on the grid below and scroll/ click through the gallery to view each image in turn.

.

Zone C view from North perimeter towards loch View from First perimeter marker pole towards South East View west to secon perimeter post View to centre of Zone C sowing nature of wooded area. Looing back to post 2 showing density of wooded are on north perimeter View west to the west end of loch South westerly boundary post, view alomg loch side toward east Loch shore line prone to flooding. Continuation of shore line towards the east showing slope and rough gound. Shoreline further towards east, very rough and slope down to lochside First sight of Pitch 1 from perimeter walk round Boggy area to the west of Pitch 1 Boggy area to the west of pitch 1, showing water depth.

No natural pitches and the two created are not suitable as they stand

 

In the absence of any natural pitches big enough to take a tent, the National Park Authority have been forced into a botched attempt to create them to meet their requirements to deliver at least two pitches in permit zone C. Form a visitor perspective, you would expect to have a choice of at least 6 to 10 prime locations in a zone of this size

The two pitches are concentrated is a small area beside the path and it's true extents are shown in green.
Camping Zone C showing location of two pitches in green

The National Park Authorities Camping Permit Conditions state:

  • “Avoid pitching your tent on ground that is already trampled or has dying vegetation cover. Pitch on durable surfaces, such as gravel, and grasses.
  • Choose a safe place to pitch your tent.  Your choice of where to pitch your tent is at your own risk.”

Zone C – camping pitch 1

 

Pitch 1 is a semi natural pitch on at a loch side location. The pitch is bounded by the loch to the south, a bog to the west and a slope to all other aspects.  The area is constrained and was too small for a tent.

A small loch side area on a gentle slope, has been enlarged by cutting back heather to accomodate small tent with hazards.

Ground work in the form of cutting away a heather patch has been required to increase the area to allow pitching a small tent.  The works have been botched insofar as they have not removed the heather roots so regrowth will occur this season but more importantly, in cutting back the heather, the Park Authority have left sharp heather stalks which will hole any tent floor pitched upon it, not to mention the possibility of stabbing injuries to humans. The site slopes to the loch and is waterlogged.

Sharp spikes left after heather cut back to enlarge pitch - puncture hazard Heather spikes causing hazard

The water level is 2 inches below the camping surface making it wet and the shore line is soft and in danger of collapsing under human loads at the edge.  The loch is deep at this location and this poses a threat especially to children. The lack of level space to manoeuvre around any camping pitch is a issue.  This pitch is just not suitable for recreational camping except perhaps for the smallest of tents in dry weather and if  ground cover issues were resolved.  However this camping pitch breaches advice in the Camping Permit Conditions insofar as it does not constitute a safe area to camp.

Zone C – Camping pitch 2

 

It’s hard to understand who would believe the mere strimming of an area in this location would result in a serviceable camping pitch.  The Park Authority have chosen an area beside the existing path down towards the loch shore view point just off the main track.

Branch off path to pitch 2

They have cut a the heather back to form line through the dense vegetation which its easy to walk past.  It is not a path with a hard surface nor is it a typical worn path only a gap in the vegetation, it’s highlighted above with flash.

Pitch 2 - Heather cut back leaving 4 - 6 inch spikes in the middle of pitch

On reaching the end in this short ‘path’ there is a second area that has been trimmed back to reduce the height of vegetation in the mass of moss, heather and thick grasses that blanket the zone. It remains 6 – 8 inches thick and is not a suitable surface for pitching a tent and securing tent pegs to the ground is problematic. As before, the cut heather stalks have been left 4 to 6 inches long which would cause injury to any person and tent using this site.  The site is small and there is nowhere to erect a seat , use a stove  or lie down to relax.

Heather spikes pitch 2 Thick vegetation covering on pitch 2 - unsuitable for pitching tent or recreational camping

Cooking, even with a stove would pose a real fire risk and without firm ground as as stated in their own Camping Permit Conditions, recreational camping cannot take place.

Tick and Midge Haven

The nature of the vegetation cover interspaced with standing water makes this Zone an ideal breading ground for midges and ticks, the dense vegetation provides an insulated layer at root level that allows insect eggs, larvae, pupae, nymphs, or adults to overwinter in all but the severest conditions thus guaranteeing large insect populations in the summer months.  Not a place you would want to spend time.

Spectacularly failed, even when doing nothing.

 

Loch Lomond and the Trossachs National Park Authority and their board are responsible for misleading the public and other agencies on a massive scale.  It is clear they have failed to provide equivalent camping pitches for those camping out of cars.  The very campers they have banned from all their management zones. Its hard to imagine camping of any type being viable anywhere in Zone C.

 

Besides double counting existing pitches as new provision (Loch Lubnaig and Sallochy to meet their target of 300 new places) the LLTNPA are trying to muddy the waters by renaming out of car camping style as a wild camping experience both at Loch Chon and elsewhere.  They are doing this so they can justify the poor provision at Loch Chon, their failure to provide new facilities and for doing absolutely nothing to ensure there are viable places to camp in the locations they have decided to allow camping by permit.    We can see this from the images for zone C and the many other camping zones that are devoid of any places which it is feasible let alone good to camp.

 

It’s time for the Scottish Government to scrap these byelaws, the LLTNPA have spectacularly failed to meet their commitments and are not competent to manage camping.

By Ross MacBeath

 

For the last year parkswatch has been covering the development of the con at Loch Chon, the campsite the Loch Lomond and Trossachs LTNPA has created in a place few people go, in order to meet its promise to the Scottish Government to provide new camping facilties in the National Park (see here), (here)(here) and (here) for example.  So, what is the truth in the LLTNPA’s claim that this unwanted campsite was up and running on 1st March?

Toilet flushing and the lack thereof.

Sunday 19th March 2017: there was still no water to the toilet blocks even after the recent assurances by the National Park in the press and at their 13th of March Board meeting.

Click image to view video!

The Park’s claim that the campsite is fully operational is no more than a blatant attempt to hide the facts and misdirect ministers overseeing the terms for implementation of the Byelaws.  The Park Authority claim a contingency is in place, which I believe means the Park Rangers may have to manually flush with a bucket of water before they leave at 5 pm.  In any case all of the toilet cisterns were empty and two of the toilets had been fouled.  Human excrement will collect overnight in the toilet bowls, a disgusting sight and health risk to bedraggled visitors to this site.  The lack of hand washing within the toilet block forces visitors to use the drinking water taps providing cross contamination and a further risk to public health.

 

The National Park Authority claims there has only been an interruption in water for a few days is untrue.  This is the 3rd consecutive week of on site checks that show no water at all on the 5th and 12th March, and then on the 19th March there was drinking water from the outside taps but still no toilets or wash hand basins. It is time the Authority took care of it’s responsibilities to public health and closed this site until these issues are remedied.  The contrast between the Park’s attitude at Milarrochy, where it is closing the slipway allegedly for health and safety reasons and this campsite is striking.

 

Camping Pitches

 

No additional works have been carried out on pitches apart from a trimming to pitch one where the grasses have been shortened and a central stake removed. This has made no material difference to it’s serviceability as a camping pitch and around 22 remain unsuitable.

 

Disabled camping pitches are a disgrace

 

The National Parks recent statement that disabled facilities within the park are to be a focus of future developments fail at the first hurdle. Printing a blue sign on the map does not make a camping pitch suitable for disabled use. There are two designated pitches and both fail to come up to basic standards. They have been selected for their proximity to parking and toilet facilities and are positioned on a level area of the site and in that respect they comply with requirements providing the rise of the path can be negotiated by wheelchairs.

Click image to view video! – Disabled Pitch 8

Disabled Pitch 8 is sited on a natural water course which tends to flood in wet weather.  This leaves a portion of the pitch in standing water, and the remainder, though level and relatively even, is a former briar patch with brambles covering the site andwith evidence of bracken having been cut back to the ground surface without removing the roots.

 

Further down towards the Loch is Disabled pitch 9. This is a drier area and ground cover is formed by tussock grasses giving an uneven pitch surface, though not the worst example, it is unsuitable for pitching a tent especially at £ 7.00 per night.

Pitch 9 – Disabled Pitch

Visitor lock outs and lock ins.

 

The gates to the Loch Chon campsite are being locked on a daily basis in what has become standard practice and denies access by visitors to campsites and many camping zones. The on site ranger explained this now happens at 5PM not the 4 PM we experienced on the 12th of March.  The ranger went on to explain that toilets would remain locked if there were no Loch Chon Gates Closed no access for drop in campsers.campsite bookings.  I expect it also follows if there are no campsite bookings, the Park Authority will  fail to honour it’s commitment to the Strathard Community to provide staff at the site 7 days a week well into the evening. Leaving day visitors and others to their own devices.

 

This is all very confusing, and makes a mockery of  the Park’s own terns and conditions for using campsites and permits, which clearly state that access to the campsites and camping zones will be available until 6 pm. How they ever expect someone to leave work at 5pm on a Friday and arrive before their Rangers lock up at 6pm will remain a mystery to all but the fools who write their terms and conditions.  The whole policy is in disarray, sites close at different times, Forest Drive gates close a 4 PM, campsites at 4 pm, 5pm or 6 pm.   No one appears to be managing this but what is clear, it will be visitors who are out of pocket making wasted journeys and not getting access.

 

It is clear the National Park Authority are opening and closing campsites and camping zones to suit staffing availability and not the needs of the visiting public.  .

See Full Terms and Conditions here.

 

Terms and Conditions – unable to comply

 

Due to the fact the Park Authority has not provided the necessary facilities on site it is impossible at present for visitors to comply with their terms and conditions.   The Park insist, on penalty of a £200 fine, that litter, refuse and dog poo is deposited in the bins provided.  The bin area is still housing a Diesel Generator – quite why when they destroyed the ecology of the hillside opposite running a mains cable up to a a transformer on the grid system is not clear – but there has not been a bin in sight on my visits.
Having failed to provide the services advertised, toilets and proper camping pitches, the Park’s terms and conditions state the Park has no liability whatsoever for the state of the site and will only offer a refund if you can prove their negligence or responsibility for your loss. If you are considering pitching a tent on the pitches at Loch Chon, you have a high possibility of puncturing the ground sheet because of the state of the ground vegetation in the pitches provided, and it appears that the Park is trying to avoid having to pay compensation while at the same time threatening to fine people £500 if they camp off pitch.

 

 

Part of torpedo range dump, Ben Lomond far distance

Thanks to reader Fiona Mackinnon who sent me this link about crackdown on fly tipping at the former  torpedo range on Loch Long by Arrochar (see here).   While I welcome this belated attempt to tackle rubbish in the National Park (the torpedo site has been used as an unofficial dump for years) – a far greater problem, incidentally, than has ever been caused by campers – the way this is being done appears wrong and it will not deal with the real problem, the derelict site.

 

In August 2016, following the June Board Meeting where Loch Lomond and Trossachs National Park staff told Board Members that the new Fixed Penalty Notices for litter could not be used to tackle flytipping, but that other powers were available to do this, an amenity notice was served on the owners of the former torpedo site (see here).  This gave the owners, Clydebank Developments Ltd, 4 weeks to remove all the flytipping, level the piles of rubble on the site (but NOT the ruined buildings) and implement a road closure to the standard required by Argyll and Bute Council.  The required actions do not appear to have taken place within the required timescales.

Torpedo range road, a public road, which had now been blocked off to vehicles.

 

I was not aware of this road closure when I suggested in a post that the torpedo range road was one of the places in the National Park camping management zones where people could legally stop off and sleep overnight in campervans (see here).    However, I can find nothing on the Argyll and Bute website (see here) to indicate that, as Roads Authority, they have agreed this a road closure  although, back in 2013, they did agree for temporary traffic restrictions on the road  to enable the proposed development of the site to take place (see here).  It appears therefore that the road closure may be unlawful.

Much of the fly tipping on the site is likely to have been done by local people a consequence of the charges imposed by Argyll and Bute Council for bulk uplifts of domestic waste (£59.70 for ten minutes collection)

I have not re-visited the site since the gates went up to see if the flytipping has in fact been removed and the piles of rubble levelled.

 

Even if the Amenity Order is properly implemented, the site will remain strewn with materials from the demolition that has taken place and the upright buildings will remain.   The torpedo range closed in 1986  (for an excellent history compiled by the Ardlui, Arrochar and Tearbert Heritage Group (see here)).   Demolition on the site, which included housing for the workforce, did not start until over 20 years later in 2007 but soon after it commenced a major fire occurred and site clearance never re-started.  The site has been a dump and eyesore ever since.

 

The major responsibility for this planning blight lies with the Royal Navy which operated the site.   Instead of restoring the site once the torpedo testing stopped, it abandoned it and then eventually sold it to a private developer.   I cannot find the date for this but in effect this handed over the responsibility for the site clearance from the Government to private business.   The Royal Navy that spends £billions on weapons, was not prepared to find the relatively small sums needed to restore this site – what does this say about how much it cares about the environment?

 

This failure by the state to restore the land itself but instead transfer it to the private sector to do so, in my view inevitably resulted in a large-scale development proposal.   It was the only way to pay for the clear-up of the derelict site.  The National Park was basically handed a big bomb:  either agree the development or accept responsibility for the site being blighted for evermore.   There are strong parallels with the situation at Balloch where Scottish Enterprise, having owned the Riverside site for many years, expect Flamingo Land to restore any polluted land there as part of the development of the site and the LLTNPA has gone along with this.    Anyway, back in 2013 the LLTNPA  granted planning permission for a 130 bed hotel, 36 holiday lets, 16 houses and a chandlery.  This was only part of the development.  The other part, which was the responsibility of Marine Scotland to approve, was for a 245 place marina.

The site plan which was granted planning permission

 

Work was due to have started three years ago but never did and the planning permission lapsed last year.   This did not prevent the LLTNPA including the site once again in its Development Plan, which was approved last year,  as a major tourist development (V.E1).

This was a major opportunity to undertake a re-think for the whole site and to consider a use which would be appropriate for a National Park – an opportunity missed.

 

The original site proposal approved by the LLTNPA illustrates to me what is going wrong in the National Park:

 

  • The idea that large-scale private business investment will be the saviour of places and people.  Once again its failed to deliver.
  • The focus on the luxury market – the 130 bed hotel was seen as being the core attraction – no doubt linked to the yachting community who tend to have lots of money – rather than the people who actually enjoy the area at present.
  • The failure to consider the housing implications of job creation.   The Developers promised 300 new jobs in all, 260 on site, but no consideration was given to where all these people would live.   House prices in Arrochar are expensive and opportunities to rent almost non-existent.  Most of the workforce therefore would probably have had to commute in from Balloch, or further afield, spending a significant proportion of their low wages (and of their lives) on travel to work.   If there was a case for this development, there needed to be a plan to house the workforce:  instead, a requirement of the LLTNPA’s planning approval was that the holiday accommodation on site could not be turned into permanent accommodation
  • The 500 car parking places and heliport which tells a story about unsustainable travel.

 

The development proposal was all about money (from saving the Royal Navy from picking up the restoration tab to someone becoming rich).  It appears to me to have been parachuted onto the shore of Loch Long Arrochar without any consideration of the people who live there (how many would work in the development if it had taken place?),  the people who now visit and most importantly the place – and as a place it it should be very special, for the thousands who live within the Clyde conurbation and who enjoy the wonderful combination of hill and loch, as well as for visitors from further afield.

View from the Cobbler to Clyde Estuary November 20

 

 

The problem at present is that, despite good work on hill paths, the potential of Arrochar is not being realised:

 

  • basic tourist facilities, suited to the people who visit at present, are almost non-existent.  The consequence is the local community gets very little benefit from the hundreds of people who go hill walking in Arrochar
  • the creation of a camping management zone and the conversion of the campsite at Ardgarten into luxury holiday lodges epitomises this.   If people cannot stay locally, they won’t spend money, and its the campers who will visit pubs and cafes.
  • there are obvious opportunities to make more of the nearby public transport links, so people could hill walk or come camping, after taking the train or bus to Tarbert……………..
  • there is still far too much plantation forestry, which makes for a poor walking experience on low ground, and has had an adverse impact on wildlife
  • the place has an interesting history – as the torpedo range illustrates – so why not make something of this?

 

What should the LLTNPA do?

 

Its time the LLTNPA should develop a new vision for Arrochar, that should be fitting for a National Park and built around public investment in the area:

  • So why not compulsorily purchase the old torpedo range and call on the Royal Navy to do the right thing and restore the land it has blighted?
  • A community development trust could then provide a much needed campsite and some basic holiday accommodation (eg wigwams) on the site as well as transport links from Tarbert.
  • The proposal, in the original plans, for a path linking the site to Arrochar should be retained
  • Forest Enterprise should be called on to take out the conifer forests as it is doing on the east shore of Loch Lomond with a view to enabling native woodland (atlantic oakwoods) to develop
Loch Lomond and Trossachs National Park Suie Field camping permit area – all photos taken 14th March 2016 two weeks after the permit areas were “open for business” Photo credit Nick Halls

The LLTNPA is discouraging camping at designated sites.

Following the implementation of the Loch Lomond and Trossachs National Park Authority  Management Zones on 1st March and the requirement to purchase a permit for the use of designated sites or risk a criminal conviction I revisited two sites to refresh my recollection of the environmental condition of the areas.

 Suie Field

 

Photo credit Nick Halls
The Board in October agreed there should be permits for four tents at Suie Field        Photo Credit Nick Halls

Notices informing potential campers of the designated areas and requirement for a permit, are in place. However, nothing has been done to enhance the amenity of the area and it remains in a similar state in which I found it in the Autumn of 2016 – with un-cleared fire sites, litter stuck in the bushes and bramble under growth, and access obstructed by moribund damaged wire fences, strands of brambles, mud and debris.

Photo Credit Nick Halls

 

The remnants in the fire places seem to be from last season.

Photo Credit Nick Halls

The site and access to it has been left as unappealing as possible.

 

People responsible for much of the litter appeared to be day visitors using the nearby parking area and accessing the beach. There is evidence of undergrowth near the lay-by being used as a toilet, but surprisingly none very evident in the vicinity of the camping area.

 

The lay by is littered with bags thrown down on the shore and evidence of fly tipping. Much of it is food wrappings and drink cartons disposed of by people parking in the lay by, but there is also evidence of burning industrial rubbish (below).

Photo credit Nick Halls

Some of the litter on the beach might be wind-blown from the opposite shore, but the prevailing wind would suggest that far more litter ends up on the Eastern rather than on Western shore.

 

The litter in the photograph below was immediately next to the newly installed notice marking the southern limit of the camping zone.

Photo credit Nick Halls

No effort seems to have been made to make the area accessible or attractive or to enhance the quality of the environment in preparation for implementing charging for camping permits. Most visitors would wonder what they were paying for!

 

The zone identified on the notice as the camping site is mostly overgrown with brambles and scrub and is virtually inaccessible and very little of it is suitable for camping – yet with little effort and no detrimental impact on the environmental quality the whole area could be restored to rough permanent pasture and meadowland.

Photo credit Nick Halls

 

 

It is hard to avoid concluding that the LLTNP is deliberately trying to make camping at the site as unappealing as possible, and is doing nothing to facilitate camping with or without a permit.

 

It raises the suspicion that the NP is allowing the brambles and undergrowth to overtake the whole area thereby making camping impossible.

 

It is becoming blindingly obvious that the camping management arrangements are more to do with social exclusion than protection of the environment or making ‘non-campers’ feel safe. Nor are they anything to do with maintaining the amenity for other categories of visitors.

 

It appears to be discrimination against a category of visitors who behave no better or worse than any other group.

 

In fact, if the evidence of abuse of the environment in the National Park were to be presented fairly, campers, even irresponsible ones, would probably be shown to be relatively innocent of the worst and most widespread impacts, which appear to arise from activities of residents.

 

Cuilag

The LLTNPA also allocated four places for tents at Cuilag in October. Photo credit Nick Halls

I was depressed by Suie Field but Cuilag hammered the message home.

 

The carpark from which the access track leads is disgusting, with evidence of fly tipping of building and garden waste, and burning of industrial rubbish. It is a disgusting place, which could be made quite pleasant and welcoming.

Photo credit Nick Halls

There is building and garden waste tipped into the burn running alongside, which threatens to obstruct the flow of the burn.

Photo credit Nick Halls

Actual camping on the beach is practically impossible and likely to be pretty uncomfortable, but looks as if it is easy to erect temporary shelters to provide overhead cover while fishing – so it seems that fishermen are the group being discriminated against at this location. The beach is not particularly extensive or attractive and there was surprisingly little litter, although there are active fire sites, among the rocks on the beach, the impact of which are ephemeral compared with the fly tipping.

Photo credit Nick Halls

There is also a memorial to somebody’s parents, which suggests that the area is regarded as special by at least one family.

 

Along the beach, beyond the zone designated for camping with a permit, there was evidence of either extraction of gravel, or using beach material to reinforce the bank of the loch to protect the field above.

Photo credit Nick Halls

 

Further along a large oak tree has been felled and the branches used to reinforce the bank for what appeared to be a similar purpose.

 

In terms of environmental impact this activity by a land manager dwarfs any impact arising from camping, the felled tree probably represents more wood than all the campers using the western side of the loch have cut during the last decade.

 

What is becoming increasingly evident is that there is one rule for the residents of the National Park and a totally different one applied to visitors.

 

Anybody concerned about the urban populations right to access and seek enjoyment in a natural environment, or anybody concerned with equality, a fairer society or maintaining the quality of our joint environmental heritage should be hanging their heads in shame, that a public body should be permitted to introduce the arrangements that now apply to camping in a Scottish National Park. Also, any official with a true commitment to the conservation of the environment and encouraging understanding and respect for it, who colludes in this arrangement should be questioning their own integrity.

 

If this is representative of the future of Scottish society, whatever its constitutional future, it’s something about which we should all be very concerned.