Tag: Forestry Commission Scotland

Letter to Strathy 15th March 2001 courtesy of Badenoch and Strathspey Conservation Group

My apologies to readers that in my post on Curr Wood (see here) which highlighted the importance of the wood to the pine hoverfly, I had missed an article from the Strathy the previous week making this very point and providing some of the history to the site  Strathy 17.4.20 Curr Wood felling concern.   Taken together the articles  raise some serious questions about how species which have been agreed by government as priorities for conservation are being protected in the Cairngorms National Park.

 

Controversy about the management of Curr Wood, which is situated just south of Dulnain Bridge on Speyside, dates back at least 15 years (see letter from Adam Watson above), i.e before the CNPA was created in 2003.   The importance of Curr Wood to wildlife appears linked historically to a sparse  felling regime which has allowed Scots pines to grow older and larger than elsewhere and left much of the ground undisturbed.  Curr Wood hosts the largest population of the twinflower in the UK and is the last remaining refuge of pine hoverfly.  Both are priority species under the UK and Scotland’s Biodiversity Action Plan, although strangely the site itself has not been designated a Site of Special Scientific Interest (SSSI).   The site therefore, although of obvious importance to conservation, is not protected as such.

 

Pine hoverfly larvae have very specific habitat requirements.  They develop in rotten pine stumps, usually in association with the pine butt-rot fungus, which are 40 cm in diameter – this is thought because smaller stumps do not provide a sufficient area for the larvae to develop.  After about 8 years, rotten stumps dry out and the hoverfly needs to move on. http://www.snh.gov.uk/docs/A1849928.pdf    What this means is if smaller trees are chopped down too early , the stumps are no use for the pine hoverfly, while if too many are chopped at the same time, there is nowhere for them to move on to.   Pine hoverfly are still l found in Curr Wood precisely because the felling has been so selective.   Forestry Commission Scotland (FCS) in their statement to the Strathy last week, claiming to have protected pine hoverfly by putting machine exclusion zones in place, appear to have missed the point – for the pine hoverfly its the felling regime that matters.  What FCS has not explained is the likely longer term impact of the felling license on the remaining population of pine hoverfly, and in particular, the likelihood that the pine hoverfly will colonise the areas being felled in future.    If we want to save the pine hoverfly, restricting it to one area of one wood looks a high risk strategy.

 

Both the pine hoverfly and twinflower are  also listed in the Cairngorms Nature Action Plan as being priority species for the National Park.  This was confirmed in the new draft Cairngorms National Park Partnership Plan, to which FCS is a party.   One of the priorities of that plan is “Safeguarding species for which the Cairngorms National Park is particularly important” – which includes the pine hoverfly.    It is legitimate therefore to ask how FCS thought it good enough, after sending a formal consultation to CNPA and RSPB about Curr Wood, to proceed with the felling license when they received no reply.    Did no-one in FCS think of picking up the phone to ask the views of others on the “mitigation measures” it had decided?   This is a failure in Partnership working by public agencies – just what the Partnership Plan is supposed to prevent.

 

Ten years ago (see SNH document above) there was a serious attempt to conserve the pine hoverfly and indeed to re-introduce it to areas such as Rothiemurch, which included the appointment of a dedicated member of staff.   These re-introduction attempts appear to have failed and the pine hoverfly appears to have disappeared from its other refuge, Anagach Wood, so is now confined to Curr Wood.  Even more reason one might have thought for FCS to have worked in partnership with all the parties, including the pine hoverfly Biodiversity Action Plan Steering group, to work out a joint approach for Curr Wood.   That doesn’t seem to have happened so far.  Its time therefore for the CNPA to take a lead here, in terms of partnership working, and to call on FCS to work with other parties, including local people.   One might have hoped that, 14 years after the National Park was created, agencies would be working together more effectively.

 

The unstated issue and challenge behind all of this is land-ownership.   There is something wrong when private landowners can still more or less do what they want on sites vital for conservation in our National Park without considering the wider good.   While the failure to designate the site as a SSSI has no doubt contributed to this, there have been at least four different owners since 2001:   Seafield Estate sold the wood to BSW timber 2001 who sold to Henry Becker in  2002 who then sold on to Billy Martin.   That is not a good way to manage a prime wildlife site which needs a consistent approach.  Instead, Curr Wood has been subject to different owners with different objectives.   More evidence of the need for a new approach to landownership in our National Parks.

 

One option would be for FCS to buy Curr Wood – after all it did stump up £7.4m to buy up part of Rothiemurchus, so why not other woodland of conservation importance in the National Park?

 

The strongest advocates for this site though, as with other areas of woodland on Speyside, appear to be the  people who live near it.    The CNPA in its Partnership Plan included some positive commitments to empowering local communities without saying how it might do this.  So why not engage with the local community about the future of Curr Wood?     While resources to buy the wood might be an issue, why not think ahead?   How about the CNPA  sponsoring a common good fund for the Cairngorms which could assist communities to buy up land in the National Park?    As with the Victorian common good funds, people might even bequeath money for the benefit of the National Park and the people who live in it and enjoy it.

 

A wider perspective on why the CNPA needs to intervene in Curr Wood is given today in an excellent piece by their Chief Executive, Grant Moir, in the Scotsman (see here).   Nature is good for people, so why are we destroying it?    And, Curr Wood even includes a core path!

By Ross MacBeath

Perhaps, after all the publicity even Loch Lomond National Park Authority have conceded that many of the camping permit zones they created in the Trossachs are not suitable for camping.  This may explain why certain zones have been temporarily removed or do not appear on the permit booking system with the consequence that the LLTNPA has failed to deliver the 300 “new” places it promised within the camping management zones.


Forest Drive ‘C’ was removed on a temporary basis but has now been reinstated this is very unfortunate as the area has a high conservation value and should not be a campsite at all.

Forest Drive Zone ‘C’  Encouraging people to trample an ecologically sensitive area in a futile search for non existing campsites is as destructive as it contradictory to the term conservation.
This  zone is part of a greater area favoured as a breeding ground for lizards and through it’s wet aspect and vegetation, midges and ticks.

 

 

Forest Drive Zone ‘D’   – 24/02/2017

This zone has been removed from the permit booking system, a previous article on parkswatch having shown  zone ‘D’ as a wholly unsuitable area for camping being located in a recently clear-felled forest, with all the charm of a landfill site.  It has no viable pitches in an area no one would ever chose as a destination, never mind pay to do so, this is an affront to visitors.

 

 

Forest Drive Zone ‘K’ The 14 camping pitches credited to this zone have all been removed from the permit booking system.  This was a ridiculously extended zone with no viable pitches on the long narrow section to the side of Forest Drive, an area any self respecting camper would avoid in any case. The LLTNPA wrongly claimed that toilets were available at this zone.   The provision of parking for 14 vehicles was never described, other than to declare it was limited.

Forest Drive Zone N

I have not yet been able to find any details for Zone N.  It was shown on a LLTNP Map but it’s not clear how many pitches were allocated.  Working backwards the total for Forest Drive was supposed to be 72 and there are 62 at other zones giving us 10 pitches missing which are presumably accounted for by Zone ‘N’ and Zone ‘A’ if there is one – it has never appeared on any map.

Altogether this gives a total of 26 Pitches missing from the booking system at Forest Drive alone and of course their are a significant number of other zones just not suitable for camping.   Significantly, not a single one of the zones for Trossachs Rd includes photographs of what the ground looks like, unlike other areas of the National Park.

 

Other non-functional permit zones identified so far

 

Loch Achray South – has owner’s permission been given to use this site?

 

Tripple Locked Gate excluding visitors from 4 PitchesPotential campers and visitors have been locked out of the 4 pitches at south Loch Achray with a triple locked metal gate.  The clear message is access for visitors is not permitted at this time and its fair to conclude this zone is Out of Service.   Whatever the case,  it should not be locked.  The locks raise questions about the right of visitors to access this area.

Loch Venacher North, Zone A, also locked

Loch Venacher North Zone A is also locked, another 4 pitches denied to campers on top of the 30  described above.  Its possible therefore there has been no agreement with the landowner however it may also be due to the zone being unfit for use.

Photo on left from LLTNPA website 4/5/17 showing how attractive the zone is for camping – you can just see the locked gate.

 

 

Locked gates and the Right to Roam!

This raises the question of what is going on with greater access to the National Park.  It was never anyone’s understanding that Permit Zones were for paying customers only nor that they were intended to undermine the general right of access for other activities.   Now all visitors are being excluded with locked gates without explanation – a clear denial of access rights which the National Park, as the statutory access authority, was set up to uphold.

 

Which ever way you look at it the required 300 pitches have not been provided!

 

Add these pitches to the unusable ones on West Loch Lomond and the disaster at Loch Chon and its quite clear that the LLTNPA has failed in its commitment to Scottish Ministers to provide 300 new camping places by the 1st March.   Roseanna Cunningham, SNH and the LLTNPA auditors at West Dunbarton Council take note!

 

A number of organisations and public bodies only supported the camping byelaws on the basis that sufficient camping places were in place BEFORE the byelaws came into effect.   When are those organisations going to start speaking out?

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
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.
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.

By Ross MacBeath

Camping Forest Drive Zone B – 19th March 2017

Nothing more than Viewpoints pretending to be camping pitches.

 

This Forestry Commission map above details the path (green dots) through what is now Permit Zone ‘B’. It doesn’t refer to any camping locations, but hosts three viewpoints. With the lack of any other viable places to camp in the Lochan Reoidhte section of Forest Drive, it appears the  LLTNPA has effectively re-designated these viewpoints as the 3 camping pitches it claims to have created in this zone. In point of fact view point 2 is outside the permit zone, so if you camped there you would be risking a criminal record and £500 fine.

 

 

Camping Spot 1

 

Forest Drive Zone B - Viewpoint 1 Previous viewpoint compacted hardcore platform won't take tent pegs.
Hardcore standing  picnic area available for camping?

 

At first glance, Viewpoint 1 appears suitable as a camp pitch however it is an extension to the path, formed as a raised platform with the same compacted hardcore surface covered over with moss where tent pegs are unable to penetrate over most of the site.  Unable to stake out and secure the tent to the ground disqualifies this as a viable camping pitch.

Not family or group friendly

 

Though the largest of the 3 spots, an area this size can barely fit the footprint of a pop up tent or a self standing 2 man tent.  For an experienced wild camper (in the real sense) walking through the uncampable terrain round about, this pitch might be manna from heaven, but these pitches are supposed to meet the demand for camping out of cars and this site is not family or group friendly nor does it offer privacy or solitude.  This may be a reasonable picnic site with it’s fire ring and log seating seen as a welcome bonus, but its very poor for camping.

 

View to the North over the enormity of the roundabout at start of Forest Drive View South West spoiled by debris and forest cutting in the foreground.

 

Its the only pitch in Zone B with some views, but the one looking north takes in the enormity of forest drive and it’s huge roundabout and the other is spoiled by forestry operation waste wood.  While we have all grown to expect the Forestry Commission just to leave everything they cut down that has no monetary value, It would be reasonable to expect when they are charging access they should at least make an effort to clear the site of debris and even more so now it’s designated a paid for camping pitch..

Camping Spot 2, it’s illegal to camp here, it’s outside the permit zone.

 

Camping spot 2 and Camping spot 3 in reality are no more than the end of hard core paths which at onetime offered views over the surrounding area.  Now the forest has grown around them and there are no views to be had.   Camping here would be the equivalent of camping in a cupboard.  The two areas shown are at the end of the paths where they level out. They are both narrow and the second one too small to hold anything larger than a kids tent. Like viewpoint 1,  due to the hardcore path tents cannot be pegged out disqualifying both areas as suitable for camping.

This area is outside the permit zone and it is illegal t camp here. Viewpoint is just too small to take a tent, it's on hard core and has no views.

There seems to be some disconnect from reality in the minds of National Park staff who are selecting these permit zones.  It’s highly unlikely that anyone would visit this site and every consider camping here as it exhibits none of the desirable qualities that the National Parks website promotes as typical park camping areas, “Loch Side Views” and “Sunsets over Water”, “Grassy Knolls in Woodland Settings” and what we might expect here , “Mature Trees with expansive Leafy Forest Floors” between.

The Park Authority should know the requirements for recreational camping

 

Recreational Camping pitches by definition require space around them to allow human occupancy for cooking, relaxing and just playing around by the tent.  The LLTNPA terms and conditions state that a 5 x 5 metre area is the maximum a visitor can occupy having purchased a permit.  Yet on Forest Drive campers  are expected somehow to enjoy a wonderful recreational camping experience in something between 2 and 5 square metres.

 

The Park Authority needs to stop using the footprint of the tent as the sizing criteria for a recreational pitch – claiming that any small gap in the brambles or heather counts as a camping place – and take on board that 5 x 5 metres of usable ground is the minimum required.

The designation of “Camping (Permit) Zone” to this area is a fantasy

 

As with so many of the other camping permit zones created by the LLTNPA, the Greater Area of Zone B just does not have any places suitable for pitching a tent

 

The maps provided by LLTNPA  misrepresent the situation on the ground. They show what appears to be a forest location with an open grassy space or flat ground to the north and east of the tracks and a wider area at the start of the zone nearer the gate.This all gives the impression of choice for a would be visitor but in reality there is not.

 

So as elsewhere the scale of the camping provision is greatly exaggerated misleading visitors into the false impression they have the ability to choose a pitch anywhere within the boundary of the Zones.

 

The so called camping zone is on a hill side and the entire area between the Forest Drive up to the almost parallel track through the forest is a slope too steep or too rough for camping. This photograph of the quarry that is now a designated Motor Home pitch – is this a place you would want to stop off in a campervan? – give a good idea of the slope steepness.

Going north beyond the forest track the ground levels out a little however the entire area is the remains of a previously harvested forest that nature has reclaimed. The video gives a view of the real situation in the entire zone including the forested areas.

 

The areas to the side of the track are overgrown, rough in places and unsuitable for pitching tents with views only in a couple of places.   In any cases these paths are promoted for day visitors and while camping right by such a path offers the camper no privacy it also intrudes on the experience of the day visitor who is forced to walk right by the tent.   The LLTNPA has claimed that shore camping prevents day visitors from visiting the loch shores when actually there is space on the loch shores for all, unlike here.

The Permit Booking system refers to limited parking being available for the 3 camping places in Zone B or the two further places across the drive in Zone C.     Apart from the site for a campervan at the end of Zone B (photo above) there is nowhere else to park.  Moreover the Park’s terms and conditions state you must not park on the verge so it’s a bit of a mystery where, if 5 groups ever camped here, where they are going to park.

No new camping provision, no new facilities, price hike 250%

Before the Camping Byelaws it cost £2 to access Forest Drive and was free to camp in Zone B and C if you were determined to do so.  It now costs £5 pounds to camp from your car, two and a half times more for no added value. This is a ridiculous considering their are no facilities,  there are no viable pitches nor any choice of places to pitch a tent.  This is not an attractive location in National Park terms and does no even guarantee your right to park within the permit zones.

The Park Authority have failed to provide the requisite number of pitches in Zone B

 

The LLTNPA’s attempt to take control and manage access in the National Park is a disaster.  It’s difficult to categorise  Forest Drive as failure, as that would imply that some remedy was possible.  The LLTNPA clearly understands nothing about camping – its staff really need to get out and do it – and have made no effort to provide any positive experience for campers.   This is despite inviting people, some of whom will have never camped before, to camp here.
It has without doubt been a conscious decision, fully underwritten by the LLTNPA board, to create a customer facing web presence and a network of signs that misdirects visitors and con Government Ministers and other stakeholders into believing that 300 “new” camping places have been delivered.   Clearly, they have not.

 

All this is being done with slight of hand, using those age old propaganda devices maps,  pamphlets and press releases (fantastically designed – who would ever think they were a pile of mince?) to mask their continuing breaches of trading standards, advertising standards, even on occasion, health and safety standards.  How is this ethical and how does it meet the standards for services that the public has a right to expect?  Why is Forestry Commission Scotland going along with this?

View over An Camus Mor, the site that Rothiemurchus estate wishes to develop into a 1500 place new town opposite Aviemore Photo Credit Badenoch and Strathspey Conservation Group

Chris Townsend’s post on Friday  on the destruction of trees at Loch an Eilein is well worth a read  (see here).    Chris highlights  the hyprocrisy of some of the people responsible for managing our natural environments, who on  the one hand lecture visitors about the damage they do  (which is  tiny in the scheme of things),  but then blithely ignore the extensive damage caused by land owners and managers.  The Rothiemurchus estate sign featured in his post is a classic:   after the swathe of destruction created by “foresters” chopping down trees, and destroying the ground cove,r the visitor is asked to stay on maintained paths to care for the area (contrary to the Scottish Outdoor Access Code) while the sign also claims, “If this area is not disturbed or trampled, heather and blaeberry will grow back and wildlife will move into this area”.   The clear message is visitors are a problem for wildlife but forest operations aren’t.

 

Rothiemurchus Estate, whose staff tried to stir up hatred against campers because of a fire which burned one granny pine (see here),  is now lopping down pine trees that have regenerated naturally.   One could also add that its the same Rothiemurchus Estate which is behind the An Camus Mor development (photo above) and is trying to circumvent the planning permission which recently lapsed (post coming soon).    The same double-think of course pervades the approach of the Loch Lomond and Trossachs National Park which judges any impact associated with camping as unacceptable (and the reason why it needs to be banned) but ignores the far greater problems that pervade the National Park.   The Cairngorms National Park Authority by contrast appears to have had no say in what is happening at Loch an Eilein and indeed the estate refused to participate in the Glenmore Plan, leaving a gaping hole in that strategy.

 

So, why is the tree felling being allowed to happen at Loch an Eileen?

 

In April 2014 the Forestry Commission bought a great swathe of the Rothiemurchus Estate from John Grant joining up the publically owned land at Invereshie and Inshriach with the Glenmore Forest Park.

Map from FCS Rothiemurchus sale papers obtained by Rob Edwards by FOI

This was done without consultation and cost £7.4m, the largest single investment that Government has ever been made in our National Parks, although the main benefit appears to have been to the private landowner rather than to conservation or public enjoyment of the Park.  The shores around Loch an Eileen and where the tree felling has been taking place were however excluded from the sale.

 

Rothiemurchus receives ongoing public subsidy for managing the Rothiemurchus Estate so, after the sale of upper Rothiemurchus to FCS, a new Forest Plan was required to cover the remaining parts of the estate.  It was produced in 2016 (see here) and provides the framework under which woodland is managed on the estate.   It is this plan which has been used as the justification for the tree felling around Loch an Eilein    

 

This work will remove areas of trees to enable the forest to regenerate naturally, thin out the remainder to give them room to grow as well as removing some of the non-native species.  (https://rothiemurchus.net/wp-content/uploads/Tree-cutting-at-Loch-an-Eilein.pdf)
Comment  The trees here, as Chris pointed out in his post, had regenerated naturally – in fact the Forest Plan states that this natural regeneration took place after a large fire in the 1920s.   After the ground was burned, pine trees reseeded but then shaded out further new saplings – that has resulted in the even age of the pine trees, which result in pole forests of tall straight stemmed trees.  So, the foresters want to remove trees that have regenerated naturally to allow trees to……… regenerate naturally and give the remaining Scots Pine “room to grow” – or in other words to assume the look we would like them to have.
What this highlights is just how reluctant our public authorities are to allow natural processes to determine what happens in an area – natural processes might result in something that doesn’t fit with our ideas of what is natural.
Extract from Rothiemurchus Forest Plan – note the commitment to structural diversity and a “more even spread of age classes”.
In the case of the Caledonian Forest, the latest orthodoxy appears to be that naturally the Caledonian pine forest would have had diverse age structures – beautiful granny pines (and they are beautiful) surrounded by trees of varying ages.   The evidence at Rothiemurchus suggests otherwise but lets not allow that stop the “managers of the natural”, who intervene in order to create something which appears more natural.  In doing so they are blind to the destruction described by Chris Townsend.
Now I am not against woodland management in general – and indeed believe our National Parks should be demonstrating how to manage woodlands more sustainably.  Nor am I totally against the idea that because of its limited extent the Caledonian Forest, and species within it, are potentially vulnerable.   However, all but a small part of the Loch an Eileen forest felling is taking place within the Cairngorms Site of Special Scientific Interest and Special Area of Conservation (the other side of the Loch, on the north west shore is not so protected).  The SAC is supposed to be the designation offering greatest protection to the Caledonian Forest.  The public interest question is whether our most protected areas should be managed areas, where humans intervene and cut short natural processes in order to secure certain defined objectives, or whether we should allow nature to take its own course – what I would regard as re-wilding?
An alternative means to ensure we have trees of varying ages is NOT to chop down existing ones but to expand the extent of the forest at its fringes through natural regeneration – but that would mean tackling intensive moorland management by private landowners, including Rothiemurchus, which elsewhere on the estate undertakes muirburn which of course prevents the Caledonian Forest expanding through natural regeneration.

The recreational perspective

 

Its time that the people responsible for managing “conservation” in our National Parks started to take far more account of the recreational perspective.   I believe Chris Townsend’s gut reaction, informed by knowledge of what is natural, was right – the destruction of natural woodland at Loch an Eilein within a protected area should not be allowed.  Instead of trying to improve what is there, why not celebrate it as an area where natural processes have predominated for almost a 100 years even if this has resulted in the “wrong-shaped” trees?

By Phil Swainson

General view of Badaguish (taken 17/3/17). You can see mounds of material, left background, sitting on the new, additional car park given retrospective planning permission. The still unplanted area in the foreground was meant to have been planted with trees a year ago.

As stated at the end of my last post on Badaguish in Glenmore (see here), Speyside Trust has made yet another planning application, this time to convert a toilet block into a site base for staff.  Like many previous applications, it is full of false or misleading statements, and as pointed out in my previous post, a very basic mistake.

 

 

But first we must ask why the Cairngorms National Park Planning Authority has not called this application in.  In their response to Highland Council they state:

 

“The decision of the Cairngorms National Park Authority is that the above planning application does not raise any planning issues of general significance to the park aims and as such No Call-in is necessary in this case.”

At the same time the CNPA has called in the planning application to extend the temporary planning permission for ten wigwams for another three years and this is being considered by the Planning Committee on Friday  (see here).

 

The proposed toilet conversion is in fact part of a major development of a six hectare site which goes against all previous local plans.

Because Badaguish  is close to the Special Protection Area for birds, one of the concerns about increasing numbers of people is potential disturbance to capercaillie and Badaguish has been required to put in arrangements to manage access as a condition of previous planning consents. This sign went up long after required by planning conditions and is not helpfully situated – few people are likely to walk through the clear fell.

If agreed the toilet conversion would become a permanent residence in an area with a presumption against such a building. I feel we can see the decision not to call in this application as an abdication of responsibility on the part of the CNPA.  So nothing new then.

The press cutting says it all.  In their supporting statement Badaguish says that the Care Inspectorate:

 

“have advised that an additional resident on-site Warden is now an essential requirement to ensure 24 hour cover to support visitors to the centre.”

I  e-mailed the Care Inspectorate asking if they had, and the response was:

 

“Thank you for your email. I have queried this with relevant colleagues who have advised that no such recommendation was made to the service from the Care Inspectorate.”

 

One has to ask if the Care Inspectorate or any of our public authorities will take this up with the Speyside Trust?

 

In the past when commenting on the Speyside Trust and its planning and funding applications I have used phrases such as “misleading”, “untruthful” or “inaccurate” as descriptors of claims made by the Speyside Trust.    On this occasion, it goes further than that.  Highland Council, as planning authority should take note and reject the proposal.  What a precedent it would set if Highland Council agreed a planning application which is based on what appears to be a lie?

 

The basic problem at Badaguish is that the planning authorities and the public cannot rely on any of  the information provided by Speyside Trust without external verification and the development of the site has been  based on fundamentally unsound foundations.

 

Under access rights, Badaguish has no more right to tell people to keep off mountain bike courses than they would a golf course.   The land though is still to the best of my knowledge owned by the Forestry Commission and therefore not private.
The Beauly Denny – aside from the visual impact of the powerlines, is ground “restoration” like that in the foreground acceptable, let alone in a National Park?

The entire edition of Out of Doors on Saturday was devoted to National Parks, in the USA and Scotland http://www.bbc.co.uk/programmes/b087tgv4#play.   This gave critical coverage of our National Parks, in which the presenters Euan McIlraith and Mark Stephen were, in their inimitable style, raising questions about what National Parks should be for.  This is to be welcomed.   There are interviews with Loch Lomond and Trossachs National Park Authority Chief Executive,  Gordon Watson, at 7mins 50 secs, a discussion on east Loch Lomond from 1 hour, 5 mins and 50 secs and an interview with Grant Moir, Cairngorms National Park Authority Chief Executive, at 23 minutes.

 

The photo above is to illustrate the excellent question to Grant Moir by Mark Stephen who observed that in travelling up the A9 corridor on entering the Cairngorms National Park you “are hit” with pylons and asked whether this gave the wrong message?   While Grant explained the CNPA had adopted a policy of no large wind turbines in the National Park, and that national priorities had overriden the objections of the CNPA to the Beauly Denny powerlines, he said nothing about whether the CNPA was happy with the quality of the work.    The standards of ground restoration in the Drumochter appear all to similar to those in Glen Bruar (see here) and (here).   A question for another programme maybe?

Our National Parks in context

 

The programme raised questions about what is perhaps the primary reason why our National Parks struggle so much at present, landownership. The contrast was made between Scotland, where much of the land in our National Parks is privately owned, and other countries where most land in National Parks is in public ownership.   The programme did point out that in the USA rights of access are very different to Scotland and therefore part of the need there for public ownership is to enable public access.   It also described the very interesting case of Point Reyes National Park in California, where in order to save land from development, it was purchased from farmers and then leased back to them.   While suggesting this might be a model for Scotland, it did not explore the implications – too “political”  for the BBC – indeed while a comment on Facebook that our National Parks are managed for landowners was read out it was accompanied by the comment “oh that’s rather political”.

 

Why not though nationalise all the hunting rights in our National Parks and then only lease back hunting rights to owners who were prepared to meet targets for deer culling and change the way grouse moors are managed?     The programme also gave lots of other ideas that could be considered for our National Parks such as the way the US parks manage “visitor density”.  Instead of making it up as they go along, as is happening in the LLTNPA, they could be learning from abroad.   Neither interview with our National Park Chief Executives gave any suggestion that this was on their radar.  If we want proper National Parks they need to be far less insular.

The usual parkspeak

 

Gordon Watson has got away with misleading statements to the media ever since he became LLTNPA Chief Executive and repeatedly claimed that the east Loch Lomond byelaws were responsible for an 81% reduction of irresponsible there when the police statistics were for a wider area.    In a recent interview  on Good Morning Scotland he claimed that the Loch Chon campsite was all about providing facilities for lochside camping when its quite clear that the campsite has been specifically designed to stop people camping by the lochshores (see here).   The best example on Out of Doors was his statement that the “measures we are taking are purely about heavily used areas”.  How then Mr Watson can you explain why you extended the camping byelaws to areas which are not so heavily used, as shown by the maps that were presented to the secret Board Meetings in September and October 2013 (see here) or why the LLTNPA are now building a large campsite at Loch Chon, where currently very few people camp?      Gordon Watson also ducked a number of key questions including why the LLTNPA is trying to get FCS to raise its camping prices at Sallochy from £5 to match the £7 it wants to charge to pay for its development at Loch Chon.

 

“No National Park is anything without the people who visit them” (Mark Stephen)

 

While the presenters did not pick up on the detail of Gordon Watson’s claims – another was “it has to be realised that access can be damaging to the local environment and communities” (where is the evidence for this?)what they did very effectively was to describe what its like on east Loch Lomond nowadays:

 

“We drove up from Drymen, just about every space where conceivably you could park, had a sign saying “no parking””.

“You know you are in a National Park by the number of signs saying no”

 

They then  effectively mocked the current rules for managing visitors at Sallochy where they pointed out there are NO signs everywhere, no parking, no camping, no alcohol, no fires right next to signs that say but you can camp here, you can have a fire if you pay etc.   They point out this is “very draconian”.   Its worth a listen.  Then, when Mark Stephen put to Gordon Watson there are lots of no signs, after first trying to dispute this he came up with the extraordinary statement that “some signs are put up by landowners that shouldn’t be there”.  And whose job is it to ensure that there are signs that shouldn’t be there are taken down – the National Park Authority?!   I enjoyed some of Gordon Watson’s other comments too, on wear and tear caused by visitors, including there is a “lot of human waste, however much you dig it in”.   Gordon Watson keeps repeating this stuff when it appear to have been his decision to stop the programme of toilet installation planned for the Five Lochs Area.     The mockery of the presenters was completely justified.

 

Knowing the LLTNPA  I suspect what they will now do is submit a complaint to the BBC – I learned recently that when the Guardian ran a piece by Patrick Barkham against the byelaws the Park’s bloated media team submitted  a complaint – so I hope readers interested in the byelaws will listen to the programme and let the BBC know what you think.  You can also, if you believe any of Gordon Watson’s statements are misleading, submit a formal complaint to the LLTNPA.

 

A couple of other things that struck me from the programme

  • The first clip with Gordon Watson was about what National Parks are for.  His answer was primarily visitor management and then he referred to development and promoting tourism related businesses.  What is interesting is that conservation was not mentioned.  I think that is an accurate reflection of where the LLTNPA is – conservation, which is supposed to take precedence over other National Park aims, is only considered in relation to visitor impacts which are minor compared say to all the hydro tracks that have been created in the National Park
  • Grant Moir was much better at putting development planning – the question he was asked about – into the wider context of the statutory aims of the National Park.  However, what struck me was how accepting of the rules he is so he explained clearly that most housing in the National Park is being delivered by housing developers who have bought up land and that a quarter of this is for affordable housing because “that is the standard”.   But hang on Grant, I wanted to say, your own Park plan clearly shows wages in the CNPA are well below the Scottish national average (which is low enough as it is) so how on earth will abiding by this standard address the need for affordable housing in the CNPA?

At the Lomond and Trossachs National Park Authority Board Meeting on 12th December Bob Ellis, the Board Member on the Local Access Forum, reported he had been to visit the Loch Chon campsite and suggested other Board Members might also visit.  Having visited last Sunday to look at the work in progress I recommend they do so, to understand where “camping in the park” is going wrong.

I am not sure why the Local Access Forum needed to visit – unless it was to take a look at the gate in the photo above, which Forestry Commission Scotland had installed and had stopped canoeists from accessing the loch.  I guess the Park was trying to persuade access forum members that it was worth sacrificing access rights for this campsite.

 

The former car parking area. Large amounts of aggregate have been imported to create a path network and new car parking areas in anticipation of all 26 pitches being full at the same time.  Photo Credit Louise Brimelow

If I was a member of the LAF the first question I would have asked is why with all this space is there not provision for a single campervan place in the new campsite?   Indeed why are campervans being banned completely from the Strathard Camping Management zone Strathard?  There is no rational reason for this.   As Strathard is relatively remote and has no public transport at least people with campervans might be able to get to Loch Chon, unlike the campers who have no car, and might even be able to afford the £7 per person per night camping fee, income which the Park desperately needs to pay for this unwanted campsite.   I predict the Park will be forced to allow campervans to stay at Loch Chon sooner rather than later.

Photo credit Louise Brimelow

The second question I would have asked the Park is why, when the rationale for this campsite was to prevent campers causing damage, is so much destruction taking place?

Trees have been chopped and cleared………because……….of all the damage uncontrolled camping is apparently doing to trees

The new car parking area where the toilet block will be situated. Note the large quantities of aggregate dumped on the ground in the foreground to create a surface for vehicles and more chopped trees on left.,

Compare the damage to ground vegetation that has been caused here by these works compared to all the damage that has ever been done by campers, responsible or not.

Photo credit LLTNPA planning committee report September 2016

This photo gives an impression of how the area looked before the LLTNPA started work on the new car park.   I am not against new campsites, indeed I have argued for them, but a campsite of this scale was never needed for this location.  The destruction is therefore unjustifiable.

The new car parking area and site for toilets

Its ironic that the National Park which claims it was against roadside camping has extended a road into the woods in order to let people to park their vehicles close to the fixed camping pitches.  There is a reason for this of course, the pitches are singularly unattractive for camping and if you could not park your car relatively close to them no-one would even have visited the campsite.

 

New track up to camping pitch. This track is almost certainly too steep and the aggregate is likely to wash away.

An extensive new pathwork, with side paths to each pitch has been created.  Paths were  needed because without them no-one would be able to find the “pitches” which in the the places where people have camped here up to now being up the hill and away from the loch.  Still, on the Park’s logic, what was the justification for this type of path which would be more suited to an urban park than an area which the Park now claims is for “wild camping”?

The westernmost pitch is about the nearest to the lochshore and has traditionally been used for camping. Compare the old path with the end of the new path which you can just see on the far left.

The Park didn’t even think of using the tracks that were already there and which blended into the environment.  Instead it decided to create new paths which are totally out of keeping with the environment and unnecessary.

Same view from 50m further east. You can just see line of old path on right through the coppice. Photo Credit Louise Brimelow
This is the claim the LLTNPA made in their Committee Report

Most of the old narrow paths people used to use have been obliterated by the new construction.  Is any of the new pathwork or carparks really “sympathetic to the rural setting”?    In my view most of the work was completely unnecessary and very costly.

By the time we visited most of the path construction was complete.  The final bit of path to be constructed will follow the line between the red netting up the hill. This is to access two camping pitches, one where the path bends and another up the hill.   Photo Credit Louise Brimelow

It appears the Park planners prefer aggregate to grass.   That’s not the right choice in what is supposed to be a National Park.

Proposed camping pitch on hillside, it slopes and no camper in their right mind would choose to camp here.  Photo Credit Louise Brimelow

Whoever has selected the camping pitches appears to knows nothing about camping. This site is sloping.  The LLTNPA Committee Report stated that “To form the camping pitches, apart from some light scraping of the ground no ground works are required”.    The Park is though proposing to cover the pitches in bark and on this one its likely to slide down the hillside.

 

There was no evidence – and I looked at every pitch  – that anyone had ever camped there except in one case.   Most of the pitches are  singularly unattractive for camping.

The stakes mark the site of the proposed pitches

Would you choose to camp here even if the polytrichum moss is scraped away and replaced by bark as the Park is proposing?

Another sloping pitch at top of sloping section of path still to be constructed.  The evidence of the woodland clearing that has been necessary to create this unsuitable camping pitch is obvious.

Another pitch, prior to scraping

This is about as close to the park shore as campers will be allowed to camp

Pitch after scraping and before bark is laid

 

While several of the pitches on the hillside are sloping, many of those on the lower ground while flat are not  well drained and would never normally be chosen by campers.

  It appears that in order to make this “pitch” campable the Park has dumped aggregrate onto the ground by the tree to firm it up.

 

The basic problem is the thinking of the Park.  They want to stop people camping by the loch shores at whatever cost so most of the pitches are up the hill or – if you look at sign in first photo – on the inland sign of the path where it goes close to the shore.   The places where people currently camp – chosen because they are good places for camping – are by the lochshore and on well drained ground with grazed turf.  Its also worth noting that many people go camping to be sociable, they want to camp in groups and talk round a fire.  The Park wants to segregate people – Simon Jones Director of Conservation at the Board indicated pitches in permit areas would be 5m x 5m maximum, too small for several tents to camp  – and if this is applied to Loch Chon, why would groups, including families, ever come?

The remains from fire in foreground is less than 5m from loch shore. You can see how Park is not going to allow people to camp here in future, despite this site being adjacent to the path, but instead will force people to camp on inland side of path off short spur rear right.

In the BBC coverage of Loch Chon (see here) the Ranger was filmed talking about the damage done by fires.  The two fire pits in the  photo above (the only ones on this section of shore) are contrary to Scottish Outdoor Access Code which states you should leave no trace of the fire.  However, putting it into perspective almost as much ground has been affected by mole heaps and this is nothing compared to the new path behind.

The fire pit referred to by the Ranger in the BBC interview – if this was so objectionable why did not Gordon Watson, the Chief Executive or the Ranger bother to clear it up after the interview? I left it there.

The Ranger in the BBC interview referred to the damage done by tents.  The only bare patches that I spotted along the whole of Loch Chon were in this and the succeeding photo and the only patch that was almost certainly caused by a tent was that on the right of this photo.  One patch of bare ground compared to the 26 new pitches the Park is creating covered by bark.

 

Looking along the shore line you can see that there were not many areas good for camping – in fact there are just half a dozen spots like this along the whole shoreline.  The lack of many suitable camping areas plus the remoteness explains why not that many people used to camp here.   It was mainly fishermen that came – will they continue to visit if they cannot camp near to where they want to fish?

Looking back to fire pit from the Loch shore.  This was the most popular area for both camping and day visitors at Loch Chon.  Photo Credit Louise Brimelow

The Park has extended the new path to down near the area in the photo but no camping will be allowed here.  The bare patch in the earlier photo is behind the red firepit.  While the ground is eroded here its likely this has been as much through feet as tents.   Does this small area of eroded ground really justify the opinion of the Park’s landscape adviser below?

Opinion quoted in the Planning Committee Report

 

 

Finally, for the sake of completeness, its worth saying that we saw no evidence of human crap or toilet paper in the entire area covered by the campsite or along the shore of Loch Chon.

What’s gone wrong?

In my view the Loch Chon campsite is a disaster:

  • Gordon Watson made the misleading claim on BBC out of doors that the Loch Chon campsite enabled lochside camping – the reality is the Park has designed this campsite so people cannot camp on the shore or even close to it (with the exception of one pitch).  Why would people come here if they cannot camp by the shore?
  • The construction of the campsite has caused far more damage than campers have ever caused here and is completely overspecified – this should never have happened in a National Park
  • Most of the pitches are badly located and unsuitable for camping and would never be naturally chosen by campers.

I think the reason this has happened is because:

  • The Park has completely failed to consult with campers about the campsite design.  If it had done so this development would never have gone ahead.
  • The Park Planning Committee failed to make a site visit – the one great strength of the CNPA planning committee is it quite often makes site visits.  I think if Committee members had visited the site they might have rejected the whole proposal.
  • Park staff and Board Members are so obsessed with the impacts of campers – at the Board Meeting Petra Biberbach asked Park staff how they were going to monitor impacts of tents on vegetation so they can adjust the number of permits they issue – that they literally cannot see the wood for the trees.   If they visited Loch Chon they would see that the current impacts of camping are minor, tiny compared to what the Park is doing, and could have been fixed for a tenth of the price.

I supported the proposal in the Your Park consultation to create more campsites but until there is a fundamental change in thinking – which I think will require regime change – I don’t think the Scottish Government should allow the LLTNPA Park to develop any more campsites itself.  Community organisations working with recreational organisations could create much better infrastructure to support camping for far less money than the £345k that the LLTNPA is spending at Loch Chon.

The Board rightly told staff there need to be signs telling drivers not just when they are entering a camping management zone but also when they are leaving it.

The implementation of the camping byelaws dominated the Loch Lomond and Trossachs National Park Authority Board meeting last Monday, with discussion taking place across a number of different agenda items.  This is a reflection of what is happening to our National Park, its allowed all its resources and efforts to focus on one issue, and because its taken the wrong path its now perched on a big cliff.     There was an indication some on the Park Board now recognise the dangers, when they elected James Stuart at the end, 9 votes to 8, as the new convener. James in his election statement (see here) had said it was time to start looking at wider look at what the Park is doing (a veiled criticism of how the Park is currently run).

 

I am not sure though James Stuart or most of the rest of the Board fully appreciates what a mess the Park has got itself into.   I sent the questions I believe the Board needed to answer (see here)  before going ahead with the new byelaws to Linda McKay, the current Park convener, and Gordon Watson before the meeting.   I have no idea if McKay and Watson shared them at the secret meeting the Board appears to have held that morning.    (The evidence that there was was a secret meeting is first that the visitor register showed most of the Board had signed into the building about 10am that day and second that Martin Earl – good for him for being open on this – made a reference to a Board discussion earlier in the day.  That the Board continues to have secret discussions though in the morning about items it is going to discuss in the afternoon is I believe totally wrong).

 

Will the permit system be ready for the start of the byelaws on 1st March?

Two questions I had identified were explicitly asked about this under the Your Park agenda item:

  1. David McKenzie asked if the permit system would be up and running on time?  Staff gave assurances it would, and what is more said it would be fully tested, even though the the IT developer was only given the contract on 1st December and staff said that the detail of the permit system was in the process of being handed over (another 12 days lost).
  2. The second question, also from David McKenzie, was whether there was a date for fixing broadband gaps in the Park to enable campers to book permits.  The answer to this was a feasibility report is due early in January along with an estimate of the costs of fixing this.   While there was then discussion about how good this would be for local communities many of whom cannot access broadband or mobile phone coverage at present, there was no discussion of what will happen if there is not comprehensive coverage by 1st March.

Now I  think its fair enough that Board Members should accept staff assurances that the electronic booking system will be fully up and running and accessible from all the campsites and permit places in the camping management zones by 1st March.  Staff had already stated very clearly in the presentation on the Board paper that the project is “on track and on budget”.   However, if it turns out that this is not the case, staff need to be made responsible and heads should roll.

 

How will campers, campervanners and drivers know where they can sleep overnight?

The Board Paper proposed 3 types of signage:

A crucial weakness in this proposal was revealed when a Board Member asked staff what signage there would be to show drivers they had LEFT a camping management zone – this is a critical question (which I had missed in my critique of the proposed signage(see here)).     The initial response from staff was that there was no money for more signs and they did not want to add to clutter.   A number of Board Members then made the point that this was unacceptable and drivers  needed to know when they had left a camping management zone (otherwise for example people driving up the A82 could end up in Fort William still not knowing if they would become a criminal if they camped by the road).   This meant placing clear signage that drivers could read that would indicate that they were leaving the management zones.   Well done the Board!   Unfortunately, as I understand it, no clear decision was then taken and it was left that staff would go away and reconsider.

 

After this excellent start, there was limited further discussion of other signage issues and the following key points were not addressed:

  • How will people who realise they are in a camping management zone but decide to walk to the edge of it to camp know when they have reached the boundary?  None of the proposed signage appears to have maps showing the boundaries as the illustration (left) for Inveruglas shows.  The sign is legally wrong because it implies the whole area pictured is in the camping management zone whereas access rights I believe apply top left and is misleading unless the boundary is depicted.  It appears designed to try and force people into permit areas where they will be charged to camp.
  • How will people know that stopping overnight is banned?  The signs for drivers simply say you are entering a camping management zone – that tells you nothing – its only the signs for walkers on the zone boundaries (left) which clearly tells the public they can only camp where permitted.   There is no signage proposed which says “stopping overnight here is a criminal offence”.  Unless the “area signs” showing where you can camp are placed in every possible camping spot in the management zones people will not know they will be committing a criminal offence by stopping off overnight.
  • Conversely, there is no signage proposed telling people with vehicles where they CAN stop off legally (since staying overnight on the public road network including laybys, is exempt from the camping byelaws).  How will people in vehicles know which laybys are exempt.  There needs to be a sign by every one where camping is allowed.

 

While I was encouraged the Board picked up on the need to know when one is leaving a management zone,  the problem is far far greater than they identified at the meeting.   People have a right to know exactly where they can and cannot camp or stop off overnight in vehicles but the proposed signage doesn’t tell the public this.   As long as it doesn’t, the byelaws will be unenforceable.  All anyone has to say is that the signage wasn’t clear and any Court case would collapse.    The Board’s failure to understand this goes back to the flawed review of the east Loch Lomond byelaws, which attributed all improvements there to the camping byelaws.   This took no account of the impact of the road to Rowardennan being a dead-end, which limited the amount of traffic, or a clearway, which prevented vehicles stopping day or night under road traffic legislation.   Provision of adequate signage in new management zones is a far more complex matter and this has been neither properly considered nor budgeted for.

 

The byelaws are unaffordable

While staff claimed the byelaws are on budget, the Board papers and questioning by Members revealed a rather different situation:

 

  • The £100,000 signage budget is all earmarked so there is no further money to provide the signage that is needed.
  • There is no cost as yet for plugging the gaps in mobile phone reception to enable people to book permits on their phone.  There doesn’t appear to be a budget either.
  • The Scottish Government has given a further capital grant of £85k towards a budget of £120k to scope the installation of further facilities at South Loch Earn and Forest Drive.   This indicates the Park has not the funds to do this.  Unfortunately no-one on the Board asked why £60k had been needed for south Loch Earn when they had previously seen at secret Board briefing sessions on more than one occasion a campsite design for Loch Earn (see here) – but perhaps that was just an artists impression?   In fact why the Park spends anything like this money on a feasibility study when when a top of the range composting toilet can be installed in a remote location for £30kl I am not sure but the Park’s insistence of putting all its resources (£245k this year) into the campsite no-one wants means it has no money to develop resources where they are needed.
  • What Board Members did uncover though was that while giving with one hand the Scottish Government is likely to take back with the other c£45k that the Park had earmarked to be spent on cars – so what you might think?   Well, this budget was for vehicles to enable Rangers to patrol the camping management zones as promised to local communities!    Since the byelaws are unenforceable anyway, the Government would be well advised to take this money back to stop further waste.
  • Then there was  the budget line that showed that professional fees were £138,233 compared to budget of £75,900.  How much of this related to the camping byelaws?
  • In fact the Your Park budget was overspent and is under considerable budget pressure.  The only reason the Park’s overall budget is balancing is because of a large underspend on staffing.  Now I had revealed previously the Park’s Commercial Director had gone (he was on a big salary, c£60 from memory)  and under the organisational update item Colin Bayes asked why under the Human Resources heading why there was no reference not just the commercial director going but all the Project Manager for Your Park!  Gordon Watson, the CEO, replied that it was not usual to deal with staff matters under the organisational update – so why then Gordon have a heading on Human Resources?    I think Colin Bayes was absolutely right to reveal this and also that the Park had put in what he thought was adequate cover.   Whether this is the case or not I think time will tell but to me it looks as though the Park is being pressed and the pips are beginning to squeak.
  • The financial pressures I believe explain the recommendation in the papers that the charge for camping at Loch Chon and Loch Lubnaig should be £7 per person over 16 per night.  No-one on the Board questioned the impact of this of people from Glasgow with very little money who have previously camped for free.  That was very disappointing.  What then happened surprised me.  Linda McKay, the convener, asked staff if Forestry Commission Scotland were going to raise their charges at Sallochy to £7 as she expected uniform pricing for similar facilities provided by partners.  In fact Sallochy will have cost lots less to construct because it has composting toilets and there is no reason to penalise campers because the Park is incapable of producing affordable infrastructure.     Board Members did though question Gordon Watson how much money they would raise from the permit system – he, rightly this time, said this was impossible to predict.  I suspect the financial sustainability of the whole Your Park system hangs in the balance.

The questions that were not asked or discussed by the Board

For the record, here are some  the questions which I think the Board should have, but failed, to discuss.

  1. What consultation has taken place on the permit systems with the Local Access Forum, a statutory consultee?
  2. Will personal data be held on campers?
  3. If so, how will personal data be used?
  4. If so, what procedures are in place for people to correct that data and appeal against any actions taken by the Park?
  5. What will be in the terms and conditions that apply to permits?  How will this be enforced?
  6. Given the Park’s claims they don’t want to discourage campervanners, despite providing only 20 places across all the management zones, what is the Board going to do about this by 1st March?
  7. What procedures are going to be put into place to enforce the byelaws fairly and transparently?
  8. Why are there no procedures to govern how staff will vary the number of camping permits in camping management zones?

 

While I welcome the fact that Board Members have become more prepared to speak out and think for themselves, as is evidenced by some of the debate and contributions last Monday, they have allowed themselves to be corralled on the edge of a big cliff and show little sign as yet that they need an alternative plan.

 

cimg9118
Photo of Natural Retreats’ dump at former Fiacaill T-Bar loading area taken 4th December 2016 and sent to me after my post yesterday. Cuts in costs by Natural Retreats are making the management of the mountain environment even worse, though standards had been dropping well before they took over. The dump now appears a semi-permanent feature of Coire Cas but is it a sign of investment?

Ewan Kearney, Director and the public face of Natural Retreats/Natural Assets claimed in the Strathy article last week that:

 

“Natural Assets has invested £1.3m into CML [Cairngorm Mountain Ltd] at Cairngorm over the last two years.   In addition to this any profit generated through CML as a result of the operation is invested back into the business”. 

 

My last post, which showed Natural Assets cut what was spent at Cairngorm by over £400k in the first year it owned CML while increasing administrative expenses by over £300k  and thus sucking money out of the company, casts serious doubt on the second part of the statement.  Its common practice these days for companies to hide and move profits through internal administration charges – Amazon is a well known example.  If Ewan Kearney stands by what he has claimed, then it would be easy for him to prove it:  he could simply make public the management accounts (which give details of all transactions) for Cairngorm and agree that all internal transactions between CML and Natural Assets/Natural Retreats could be open for public scrutiny.  Moreover,  he could release data on types and levels of staffing at Cairngorm, such as appeared in the CML accounts to March 2014 before Natural Assets bought the company:

 

staff
It would be in the public interest to know how many staff are now employed at Cairngorm and what they do to understand the relationship between staffing and the collapse of standards at Cairngorm.

 

What about investment then?

 

The figures from the accounts indicate there has been little or no investment in operational costs, such as staff, so I think we can take it most of Kearney’s claimed £1.3m over two years has been into capital.  The CML accounts tell us how much investment there has been into assets and of what type.  What they do not say directly is whether this is enough.

 

First another proviso.   Investment means different things to different people and Mr Kearney’s claimed investment into CML could include the £231,239 it cost to purchase it.   Unfortunately we won’t know the truth for another year because Natural Assets has changed the accounting year and the new accounts for CML will just be for 9 months until December 2015, 18 months after they bought it.      You can however see some of what happened in the the first 10 months Natural Assets owned CML.

 

investment
While the net book value of CML was £615,562 or thereabouts prior to purchase Natural Assets were able to buy the company for £231,239 because of “negative goodwill” – see previous post.

Line 2 under the Note on Tangible Fixed assets shows “additions” in the year to March 2015 of £616,544.  Double that and you are not far off Ewan Kearney’s claim of £1.3m of investment over two years.

 

However, all is not as it appears.  Look at the line below, “disposals” and you can see that Natural Retreats sold plant and machinery originally valued at £844, 715 which after “depreciation” (3 lines below) was worth c£140k.   Now if the disposal sold for a sum anything like that, Natural Assets realised a gain which it could use to help buy the £616k of additions.  That would mean a net investment of say c£480k.  Moreover, the note at the bottom of this section on Tangible Assets makes it clear that recorded under the “additions” is the full value of items held under finance leases or hire purchases agreements.  The value of “assets” held in this way increased between March 2014 and March 2015 by over £150k.  Assume a three year hire purchase agreement and that knocks another £100k off what was actually invested, meaning the real investment was c£380k or only just above what was invested in the  previous year’s accounts before Natural Assets bought CML.

 

It appears then that for Mr Kearney’s claim to be true Natural Assets must have invested c£920k in the succeeding financial year.   While we don’t have the accounts from March 2015-December 2015 we do know from a Freedom of Information Request, that was quoted in the Strathy article, that HIE has invested £601,286 into the assets CML operates since Natural Assets takes over.    (Thanks to George Paton for this cairngorm-hie-response-to-foi-on-cm-spend-17-august-2016  its well worth a read)  Now most of this expenditure to my knowledge appears to have taken place since March 2015 which raises the question of whether Ewan Kearney’s claimed investment of £1.3m over 2 years includes this support from HIE or not.   Now, as a result of my concerns about the unlawfully bulldozed track in Coire Cas (see here for example) and the extremely poor standard of work on the new Rope Tow.  I contacted HIE who said that Natural Retreats was responsible for the contractors, i.e had the contract with them.   This shows that HIE funded CML to do these works.  The key question therefore is whether Natural Retreats has included grant funding in their claimed investment of £1.3m at Cairngorm or whether the grant funding is on top of this.  Ewan Kearney and HIE should come clean now and release all the figures relating to capital investment.

 

While the answer will be interesting, whatever the case its clear the investment has not been  enough.  This is shown by the collapse of the Cas Gantry just over a year ago through lack of maintenance.

gp-gantry-works-in-snow
The initial works to “save” the Cas Gantry – Photo Credit George Paton

 

The FOI response shows HIE paid £73,377 to “fix” this.  Given the appalling standard of the work you wonder why HIE ever agreed to hand-over the money.  Indeed you could ask the same question about the installation of the Sunkid rope tow and associated works which HIE funded to the tune of £160, 596 or the replacement of the electrical cabling to the tows where they have  paid £315,641.  This expenditure has been the opposite of Best Value.  One wonders what else HIE is going to pay for and what else remains their responsibility (I have not been able to work this out from the lease yet).

 

I guess HIE saw these as trifling matters because the big prize in its view was redevelopment of the Day Lodge into a mountain conference centre which Natural Retreats claimed might cost £15m to complete http://www.bbc.co.uk/news/uk-scotland-highlands-islands-34651446.   This development was totally inappropriate for Cairngorm and has now collapsed.   Replacement of the Day Lodge was however so central to HIE that it was made a condition of the lease and therefore HIE could now, if they wanted, terminate this.  I think they should do so.

 

I believe the agenda of Natural Retreats is not about investing at Cairngorm but taking what money they can from it.   While the controlling interest of the Natural Assets/Retreats group of companies, is held by David Michael Gorton (http://parkswatchscotland.co.uk/2016/11/21/will-natural-retreats-bring-decently-paid-jobs-cairngorm/), who has sufficient funds to invest whatever was needed at Cairngorm and indeed a swathe of the Highlands, he has not chosen to do so so far.  His investment vehicle in holiday businesses, Natural Assets,  last year incurred losses of £5,734,703 and is £20,715,910 in deficit overall.   It has no money to invest and a bank would be mad to lend money to it.  What happens therefore entirely depends on the goodwill of Mr Gorton and whether he keeps taking money out of Natural Assets.    HIE should never have sold Cairngorm to such an organisation and should get out while it can.

 

These problems have arisen because HIE is still looking for the big fix at Cairngorm – the funicular was the previous attempt to do this.  What is needed is a totally different approach to development which respects the mountain environment while coming up with creative ways to enable people to enjoy it.    This needs to involve people with ideas, like the Save the Ciste Group, like montane shrub zone enthusiasts, the local community, recreational and conservation organisations.  I think this could happen if the lease with Natural Retreats was terminated, the land transferred from HIE to Forestry Commission Scotland and serious discussions started about creating a community consortium to manage Cairngorm.  It also needs a different form of finance but I think if HIE had funded a community organisation to the extent they have funded Natural Retreats there would have been much better outcomes for all who care about Cairngorm.

img_1442-copy
Walking the Aviemore to Kincraig section of the Speyside Way on 30th December 2015. Much of the walk was then marred by pylons which I understand are due to be removed.

The Cairngorms National Park announced last week it has won a planning quality award for the extension of the Speyside Way from Aviemore to Kincraig (http://cairngorms.co.uk/planning-award-for-speyside-way-extension/):

 

“The judges praised the Park Authority for its partnership working, community consultation and sheer determination over a decade to develop the best off road route to connect Aviemore to Kincraig.

This included the first use of a Path Order in Scotland to secure rights to develop the path on the preferred route”

 

I think the staff involved do need congratulating on their persistence but the time taken to deliver this path and the walking experience demonstrate that our access legislation is still very weak when it comes to creating new paths and that our landowners still have far too much power.  The basic problem was that the Kinrara Estate objected to the Speyside Way crossing its land, even under an electricity wayleave, and it required two consultations in 2005 and 2007, approvement in principle by Scottish Ministers in 2009, then a path order which required a public inquiry before being approved in June 2012.  Three and a quarter years later the extension opened in September 2015.

 

No wonder the Ramblers Association cited the Speyside Way extension in its submission to the Land Reform Review Group in 2013 in the part of its submission which dealt with “Failure to expand path networks”:

 

“While core paths plans are now drawn up, that does not mean they are being
implemented on the ground – and core paths comprise just a small proportion of the
entire path network. As noted above, access authorities seem reluctant to use the
powers they have within the Act, and this includes powers to use compulsory purchase
or path orders. Just one path order has been used in Scotland, to extend the Speyside
Way, and this followed many years of fruitless discussion with the landowner
concerned. Much time is spent on negotiating with landowners across Scotland who
are resistant to public access, with the public becoming increasingly frustrated with
plans for path networks that they have helped to develop but which produce no change
on the ground. It is inconceivable that transport departments would spend so long
negotiating routes for new roads and yet paths do not have the same status despite
potentially being of huge public benefit.”

 

Now I don’t believe the ten year delay in getting the path off the ground was either the fault of SNH (who had started on plan for the path) or the Cairngorms National Park Authority who took on the work c2009.  However, neither highlighted the case to the Land Reform Review Group (indeed from a trawl through the responses the CNPA did not even make a response).  I think this is wrong.  Our National Parks should be trailblazing when it comes to new paths and if they do not have sufficient powers to do this effectively they should be highlighting the issues to the Scottish Government.

 

img_1445-copy

The extension also raises significant issues in relating to the quality of the walking experience which the CNPA has simply not mentioned.  Indeed in their news section they claim “we built the path on the best route for both visitors and local communities”.   That is a matter of opinion but I think if the CNPA asked the public they would disagree.  As one foreign visitor said, the trouble with the Speyside Way is that it avoids the river and this is very true of the  new section.   Of the c8 kilometres of new path, only c2 km, near Kincraig, are by the Spey.

 

speyside-way-extension
Speyside Way, the thick brown line.                                                          Map Credit CNPA

The problem was and still is that the Kinrara Estate did not want people walking along the river, despite having a right to do so, or Bogach, the loch north of the Duke of Gordon’s monument which is a great place to watch ospreys fishing.  Unfortunately our public authorities were not strong enough to stand up to the estate and the result is the Speyside Way avoids all the best things places to visit in the area.  A missed opportunity.  I would advise anyone who wants to experience the best that Speyside has to offer should find their own route rather than follow the Speyside Way until close to Speybank.

 

Apart from the route it takes, the path provides a good illustration of a number of access issues.

img_1435-copy
While Network Rail don’t actually say here you will be prosecuted for crossing the line the message is unwelcoming. Railway crossings are a problem across Scotland but surely our National Parks should be trailblazing solutions with Network Rail which facilitate access rather than stopping it?  The new gate and sign looked to me like a response from Network Rail to the creation of the Speyside Way.
img_1439-copy
While the wooden fencing has been done to a very good standard the overall experience is one of being hemmed in and kept away from nature. Compare this to walking along a river bank.  Openness is important to walkers and rarely have I seen such a constricted path.
img_1447-copy
The landowners concerns, however ridiculous – they appear to believe that cyclists or runners risk colliding with wildlife – show why all the fencing is in place.
img_1452-copy
Another  ridiculous sign. Note the two dog proof fences on either side of the path – there is  nowhere for a dog or people to go. Arguably, because of the new fencing, the creation of this section of path has made access worse not better. What is the point of access if you cannot step off the path and go and sit under a tree?
img_1448-copy
Nature beats planning!

 

 

img_1453-copyOur access legislation means that people can walk the Speyside Way extension and all the land around it whether the landowner agrees or not.  Unfortunately the CNPA had not for whatever reason managed to get the owner of this wood or the Forestry Commission to remove this sign which is not compliant with the Scottish Outdoor Access Code.

 

What should the Cairngorms National Park do about the Speyside Way extension?

Despite my criticisms, the extension is a new path and that is a plus. I think it is important though the CNPA does not in any way suggest that the Speyside Way is the only or main walking route between Aviemore and Kincraig.  I would suggest the CNPA:

 

  • Removes the signage which is not compliant with the Scottish Outdoor Access Code
  • Produces a plan to reduce the fencing along either side of the path to improve the quality of the recreational experience
  • Signposts alternative routes, including how to follow the Spey itself
  • Stops the spin and say how it really was for the staff involved
  • Use this example to argue the need for Access Authorities to have stronger powers to create new paths in the places people want to visit

I also suspect that if the CNPA had treated organisations representing recreational users, Ramblers, cyclists and horseriders as true partners, many of the problems with this path could have been avoided.  The Ramblers, for example, have long campaigned again signage such as is evident on the Speyside Way extension and I believe if they had been involved it would not have been tolerated.

loch-chon-original-camping-proposalA few hours after yesterday’s post on the Scottish Information Commissioner’s Decision (see here) and the Loch Lomond and Trossachs National Park’s failure to provide me with the slides presented at the secret Your Park Briefing Sessions,   I received them by email (see here for accompanying letter).   This is not a coincidence as the Park have monitored everything I do and say for quite some time.   The power of social media!     I don’t believe though that the Park have sent the slides because they are concerned about what the public think about them taking over 4 weeks to send a set of slides as ordered by the Scottish Information Commissioner, its that they are worried their minders at the Scottish Government might ask them questions.   If asked, the Park will simply shrug off the delay as a minor oversight on their part rather than part of a systematic attempt to deprive the public of information.

 

A quick look at the content of the slides though has shown me why the Park did not want them in the public realm.   They provide further proof that the Park’s proposed camping ban is not based on any rational evidence, of its complete inability to deliver basic facilities like camping places and of the way it has systematically tried to manipulate public opinion (and the withholding of information is part of that).

 

The slide above on the plans for Loch Chon, which have been covered extensively on Parkswatch, (see here) and (here) provides a good example.  This slide was presented to Board Members at secret briefings on 13th and 15th April 2015 two weeks before the Board formally approved the “Your Park” recommendations at the Board Meeting on 27th April.  The discussion at the open Board Meeting which is where the Park is supposed to take decisions was over in half an hour – I know because I timed it.  I realised then that the Board had already made their decision on the byelaws in secret beforehand and this slide is just one example of how thoroughly Board Members had discussed the Your Park proposals before they went public.   The Board had nothing to discuss on 27th April because the decision had already been made in private at Briefings such as this.   This is a fundamental failure in democracy and accountability.

 

The numbers on the slide tell a tell.  Regular readers will recall that the planning application the Park submitted to itself to build a campsite at Loch Chon earlier this year was originally for 33 places but, after community protests, was reduced to 26 places with Gordon Watson, the Park Chief Executive, claiming this number of places was necessary to make the campsite financially viability.

loch-chon-october-2016

 

So, the Park has cut the numbers of people it was prepared to allow to camp at Loch Chon from 50 in April 2015 to 26 now.  Ignore the fact that there is not even the demand for 26 places at Loch Chon (see here) and think about what this shows about the Park’s claims that the National Park can only sustain 300 more camping places above those provided in formal campsites.   The National Park claims there are too many campers, but one moment is prepared to accept 50 at Loch Chon, the next 26.   The Park also claims it needs to reduce campers  to sustainable levels and has fixed on 300 as the total number of places it would allow, in addition to pre-existing campsites, across the four management zones.   This raises questions not just about how the Park decided one moment that the natural environment around Loch Chon could  sustain 50 places and the the next 26, but also why the areas the 24 “surplus” places were transferred to could suddenly sustain this extra number of places.   The truth, as this slide demonstrates (and you might also wish to note that the permit area at Loch Ard has changed from 5-6 places) is that the number of places is based on prejudice, the NIMBY interests who dislike people camping on popular lochs, and political expediency (so when the Strathard Community Council objected the Park simply transferred the places to the Forestry Commission land at Forest Drive because they knew FCS could not object publicly).

 

The even more worrying thing shown by the slide is the extent to which the National Park is exercising its powers arbitrarily.   For everyone who cares about access rights the choice is whether to oppose the byelaws or subject yourself to the arbitrary authority of the Park.    No-one should trust the current propaganda from the Park on its camping plans that numbers are not fixed because they want to be flexible.   This is code for saying if we get a complaint from a NIMBY, we will simply change the area where people are allowed to camp.  The recreational movement needs to re-assert that access rights and the Scottish Outdoor Access Code are the only appropriate way to manage informal camping in the National Park.

Following the Loch Lomond and Trossachs National Park Authority’s planning approval of the Loch Chon campsite  (http://parkswatchscotland.co.uk/2016/09/26/loch-chon-con-goes-planning/) I submitted further FOI requests to try and understand  better what I believe is a stupid decision and a waste of resources.

 

For a long time now been treating all my queries about the management of the National Park either as Freedom of Information/Enviromental Information requests or as complaints.  Their normal practice has been to divulge as little information as possible but sometimes they add commentary in order to justify what they are doing (which to me shows they are misusing the FOI/EIR rules to suit their own purposes).   Both approaches are evident in their latest FOI/EIR response on Loch Chon eir-2016-054-response. 

 

On the one hand the Response says that the Park hold NO information about why the LLTNPA  rather than Forestry Commission Scotland are developing the Loch Chon campsite.  I must say I find this incredible.  There must have been some discussion with FCS about the use of their land by the LLTNPA but the Park, rather than being open about their discussions with FCS, have chosen to interpret my question in the narrowest possible sense as being about why FCS chose not to develop the campsite.   I will ask again for all correspondence between FCS and LLTNPA about the development of Loch Chon and also ask FCS.  I believe its in the public interest to know what FCS think of the development of a 26 place campsite on their land where there is no evidence a campsite of this size is needed and believe its unacceptable that our public authorities are not being open about this.

 

On the other hand while the Response confirms that the shipping containers which will be used for the toilet blocks at Loch Chon had been bought PRIOR to the decision about the planning application, the Park adds the comment that if the planning application had been refused, the containers would have been used elsewhere.  The LLTNPA are obviously keen to avoid any legal challenge that the planning decision was prejudiced because the Park Board had already decided that this campsite should go ahead.    To cover their back the Park have also written into their  Board report on the camping plan that the shipping containers could be moved in future if better used elsewhere.   It is not clear though from the Response whether  the Park has bought other shipping containers than those destined for Loch Chon for £16,512 but I think this prior purchase explains why the Park refused to consider alternatives to shipping containers for this site as suggested by the Strathard Community Council.  As importantly there has been no consultation at all with the people who actually camp on the lochshores about what they think.

 

The LLTNPA is about to convene a stakeholder group to consult on future camping plans.  I hope that that group insists from the start that the LLTNPA needs to be transparent about all decision making on their camping plans and engage with the people who actually camp in the National Park.

lltnpa-jpg
The LLTNPA figures

The Loch Lomond National Park Authority Board is considering their long-awaited camping plan, which they are now gracing with the title “Camping Development Strategy” at their meeting this afternoon (see here) and (here).    Its 27 pages, full of pretty graphics and based on assertions for which there is no evidence (as I have established through FOI requests).  While I will come back to that in further posts, its worth looking at the numbers:

 

  • The paper refers several times to the number of existing camping places (504) but makes no reference to the current numbers who camp.  According to the Your Park consultation records shows over 800 tents camped on the lochsides on busy weekends in the summer (outside of the campsites which are generally full).  Ranger patrol records do not show the number of campervans as opposed to caravans but you could safely add another 100.   The “provision” of 322 “places” therefore leaves a shortfall of about 600 places.  Nothing is said in the strategy about this but the clear effect of the plan, if successful, will be to cleanse the National Park of campers and campervaners.
  • The number of new camping places being delivered is not 73, as claimed, but 34 (26 at Loch Chon and 8 at Rowardennan Youth Hostel).  The Sallochy campsite has now been open for three years and Loch Lubnaig two.  The LLTNPA has totally failed to deliver new campsite places since the Your Park consultation – which as it says almost everyone believes is what is needed – and there is NO sign in the strategy that this is going to improve.  There is no mention of its failure to deliver the campsites proposed in the 5 Lochs Management Plan.
  • The provision of just 20 permits for motorhomes – the term is the Park’s – is a complete disaster.   Campervans have become increasingly popular and on most days this summer I reckon at least 40 campervans pull off the A82 for the night on the way north.   The Park is proposing to provide just 9 places for campervans on West Lomond.   There are NONE in the West Trossachs Management zone despite the Park’s claim its trying to balance provision across 4 zones.   The Park have done no tourism impact assessment but its obvious this is going to be a disaster for the National Park.   Local businesses should be calling for the resignation of the Park Board if they approve this.
  • The LLTNPA has justified the provision of 26 places at Loch Chon costing c£250k  (where there is only demand for around 10 places (see here)) on the grounds that it wishes to achieve  balance across the four management zones.  This is complete rubbish.  Originally there was just one Trossachs Management zone and the lack of camping places in Trossachs West is simply a consequence of the way the boundaries have been withdrawn.   Any talk of balance is meaningless without discussion of numbers camping and the facts are that the West Trossachs zone is the least popular place for camping in the Park at present.   This number of places is simply not justified.  The only reason for the Loch Chon campsite is that the Park has failed to deliver campsites elsewhere.
  • Even more staggering though is the creation of 72 places under permit along the Forest Drive, on Forestry Commission land, north of the Duke’s pass.  The LLTNPA claims this is a popular place for camping.  A look at their ranger patrol records for July and August 2015 shows the maximum number of tents recorded there as 8!!!    In other words its an even less popular place to camp than Loch Chon but the Park is proposing three times as many places.  They are clearly wanting to cleanse the lochsides and send campers to the backwoods.   The only reason for the 72 places under permit here is because the LLTNPA needs to be able to say to Government that it has met its commitment to provide 300 places within the proposed management zones.   The LLTNPA paper which approved the byelaws listed all the places suggested for camping provision – Forest Drive was NOT included; that says it all.
  • There are also places where the number of campers who will be allowed to camp lawfully is precisely nil:
    • the A82 North of Inveruglas all the way to the Ben Glas farm campsite.  This is popular with fishermen, cycle tourers etc.   The Park has justified this complete ban by claiming that pulling off the road here is dangerous but why this should be so for campers but not day visitors is not explained.   The Park also ignores the fact that not all campers arrive by car but by bike, canoe etc, ie the type of lightweight camping the Park claims to support.
    • east Loch Lomond south of Milarrochy.   The Park’s map of existing campsites is simply wrong.   There is no campsite in Balmaha, though there is a site on Inchcailloch which is not shown.  There is no campsite in the area between Drymen and Balmaha (the nearest is at Drumquhassie Farm) south-east of Drymen.   There is a campsite at Cashel which is not shown.   This is an important issue because backpackers on the West Highland Way arrive at Balmaha after a long first day and find they have nowhere to camp and the Park has done absolutely nothing to address this issue.   So much for the West Highland Way being a world class walk!
  • The only consolation I could find in all of this is that some camping is going to be allowed under permit on the Invertrossachs Rd, the location of Loch Venachar House, the home of the Park Convener, Linda McKay.   None will be allowed at Loch Venachar Weirs and Dam (which is on the north side of Linda McKay’s property) where 25 tents were recorded in 2014 and which would make an excellent campsite.  Four permits however will be allowed on the Invertrossachs Rd.  In 2014 Ranger Patrols recorded 69 tents at Loch Venachar Quay, directly adjacent to Linda McKay’s House on land owned by the Park – camping is now impossible there because the Park has planted prickly scrub and trees all along the quay which had been gifted to the people of Callander.  The permits are therefore likely to cover the area further down Invertrossachs Road from Linda McKay’s house at Beetle Bay where a further 68 tents were recorded in 2014.
p1000223
Rubbish in the field opposite Park Convenor, Linda McKay’s House, at the east end of Loch Venachar 8/10/16

On Saturday I went rock climbing on Ben An, the first time in many years, with my friend Mike who had never climbed there.   En route from Callander I checked whether anything had been done about the farm litter beside the road opposite Loch Venachar House, home to the Loch Lomond and Trossachs National Park Authority Convener, Linda McKay.   As you can see, its still there, 18 months after I first photographed it  (and there is more of it than is in the photo).   To my mind this is worse than any of the photographs of abandoned tents that is being used to justify the camping ban and would take a lot more effort to clear up.

 

However, to the LLTNPA this rubbish is a non-issue.  Its rangers, who patrol the shores of Loch Venachar on a daily basis, pass this festering pile every day during the summer but two summer seasons have gone by and nothing has been done about it.   The Park Convener must have seen it too, but her only concern appears to be to stop the campers camping on the loch shore near her house.    What counts as a problem, is ideological and the LLTNPA has made political choices about this.   Rubbish left by campers is photographed to justify the removal of access rights, while rubbish left by farmers is simply left to rot and has no consequences for them at all.   The LLTNPA could be making the argument that we should stop paying public subsidies to farmers who dump rubbish in our National Parks but its not, it would rather focus on getting rid of campers.

 

A couple of miles further on  we dropped in to look at the second north Loch Venachar site, owned by the LLTNPA.   The two carparks provide the best bases for roadside and lochside camping between Callander and Loch Katrine, being located away from houses and with a number of good spots to pitch a tent.    The LLTNPA had been going to provide a campsite here, under the visionary Five Lochs Plan, but those plans appear to have been scrapped without explanation  (see here)  and I will be very surprised if the site features on the camping plan which will be up for formal approval at the next LTNPA Board Meeting on Monday 24th October.   It should be.

 

 

p1000193-copy

As I wanted to take a photo, we walked over to the campers to have a word with them.  They turned out to be fishermen, who go camping all over Scotland and who were out to enjoy themselves.  One had come to camping through Fairbridge Drake, as it then was, which helped inner city young people to enjoy the countryside.   A success you might have thought

 

p1000190-copy
The fire pit in this picture was caused by earlier visitors. The campers had brought their own wood.

 

I asked the fishermen if they knew about the proposed byelaws and this could stop them camping here in future (if they wanted to camp before 30th September).   There was a chorus of no-one will stop us camping!   I was then asked why someone who was English – I am afraid I have not lost my accent in 25 years – was taking an interest in this and when I said I was from Glasgow, rather than Glesga, I was given a right ribbing!

 

There was a pile of empties on the ground, which the  campers unprompted said they would clear up afterwards,  and besides the logs the campers had brought pallets for burning.    Now I am not naive enough not to have wondered where the logs might have come from, although they were definitely not from around the campsite, but it seemed to me that the pleasure these guys were getting from being out in the countryside far outweighed the impacts they were having, and in any case these should be easy to manage.

 

Worried that rubbish might be left?   I took the guys at face value, but things can happen, people can drink a bit too much and feel hungover, it starts to pour with rain and people rush to their vehicles without clearing everything up.  The solution is simple.  Get the Rangers to take a photo of the vehicle, as the police used to do, as insurance and evidence that could be used to impose a fixed penalty notice.  You can guarantee the place would be spotless the next day.

 

Worried about the source of the wood?   Well the original plans in the Five Lochs Plan were not only to create barbecue pits at these carparks but also create wood stores which would have removed any temptation for people to cut down trees.    The wood store was not included in the revised plans although Forestry Commission Scotland has a huge supply of wood just down the road by Ben An.

p1000199-copy
The FCS has been removing alien conifers from Ben Avon and leaving whole tree trunks on the ground to rot. It would be very simple to provide some of this to allow people to enjoy campfires.

The solutions to problems that can be caused by people camping are very simple.    First you put in infrastructure and for north Loch Venachar the best starting place would be to implement the  5 Lochs Plan (see below) instead of abandoning.   Second, the Park’s Rangers need to talk to anyone, whoever they are.  The focus of this needs to be on what people are enjoying (we talked to the fishermen about their fishing) rather than focussing on might they might be doing wrong.  But that I am afraid requires tolerance, a quality that the LLTNPA Board and senior staff appear to be lacking.

 

loch-venachar-north-plan
Extract from original Five Lochs Plan showing the North Loch Venachar camping area and toilet

 

img_6130
The problem and the potential: signs of neglect and mismanagement with montane scrub behind

A week ago,  on the same day that the consultation on the new Park Partnership Plan closed, the Cairngorms National Park Authority approved the Cairngorm Glenmore Strategy (see here).  This had been subject to public consultation earlier this year.

 

All the detailed visitor management proposals which were in the consultation draft have been stripped out of the strategy and will be worked up into a Glenmore Visitor Improvement Plan and Cairngorm Masterplan.  The final strategy is much shorter, simpler and easy to understand.   A great plus compared to the morass of documents and plans that made up the draft Partnership Plan and it has avoided being competely dummed down too.

 

In my view there are two glaring omissions.  The first is that Rothiemurchus Estate is not included, although its an integral part of Glenmore.  I am afraid the presentation of the strategy as being about public authority owned land is simply an attempt by the CNPA to put a good spin on this.  The fact is Rothiemurchus declined to join and the CNPA was powerless to make it do so despite the Scottish Government having agreed that Forestry Commission Scotland should acquire part of the estate for £7.4m last year.   The sad fact is landowners in the National Park are a law unto themselves.

 

One could also say that too of the Speyside Trust who run Badaguish and who have consistently ignored planning requirements.  The Strategy has nothing to say about Badaguish.  Its not on the map of sites identified for visitor infrastructure development, unlike Glenmore Lodge, the Youth Hostel and campsite despite far more development going on at Badaguish.  This omission is quite extraordinary and conspiracy theorists will note Badaguish is named on every other map in the Strategy document apart from the visitor infrastructure one!   This undermines the credibility of the Strategy much as I hope the CNPA Board has now decided to take a firm stand and use its enforcement powers to prevent any further unlawful development on the site.

 

On the positive front, the Strategy contains a number of actions for the Cairngorm ski area which I believe most people who cares about the place would agree with:

 

  • Safeguard the plateau habitats and species by actively managing recreation pressures
  • Develop action plan to enhance the ski area by improving storage and removal of disused items
  • Ensure enhancements within the ski area are implemented to high quality standards appropriate to the sensitive environment
  • Develop agreed best practice standards for development and enhancement works in the ski area [actually good practice standards have existed since the early 1970s, they just need enforcing]
  • Expand montane woodland establishment within and around the ski area
  • Support enhancement of the wintersports experience and year round activity provision

 

I was particularly pleased to see the commitment to clean-up the ski area and expand montane woodland within it – suggestions which have been made several time on Parkswatch.

 

However, the problem is that the strategy bears no resemblance to what is actually going on on the hill at present.    Natural Retreats simply ignore all planning requirements (further photos proving this will appear soon!) and Highland Council and the CNPA as planning authorities have so far failed to do anything.

 

What does ensuring “enhancements with the ski area are implement to high quality standards appropriate to the sensitive environment” mean when Highlands and Islands Enterprise, CNPA and Highland Council are not prepared to speak out, condemn Natural Retreats for their mis-management and intervene to stop this?

p1020852-copy
The destruction around the Coire Cas Gantry – Photo Credit Terry Smith 23 September 2016

So what are CNPA, Highland Council and HIE going to do to meet the management aspirations set out in the Strategy?

 

Management interventions will improve the natural environment, landscape and visitor experience and retain the sense of wildness and space found in the area.

 

How does letting Natural Retreats get away with the destruction they have caused ensure that “Cairngorm and Glenmore will be a high quality mountain and sports destination”?

 

How can our public authorities claim that “Cairngorm and Glenmore will be at the heart of collaboration with neighbours to protect the mountain plateau”  when they are allowing Natural Retreats to destroy part of that very same plateau?  (see here)

 

The worst though is at the end of the Strategy where after saying that “Natural Retreats and partners to develop and deliver masterplan for Cairngorm Mountain” – a step forward – that “Natural Retreats and Forest Enterprise Scotland will lead on delivering spatial plans that set out the detailed actions focused on improving facilities at Cairngorm Mountain and Glenmore respectively. These plans are expected to be completed in the next year.”     How Natural Retreats can be trusted to lead on anything is beyond my ken.

 

Now this is not all the fault of CNPA.  HIE as landowner have primary responsibility for ensuring Natural Retreats as their leaseholder maintains the highest environmental standards and they have completely failed to do so.  Its about time that CNPA repeated the call they made on 7th November 2006 for the ownership of the Cairngorm Estate to be transferred to Forestry Commission Scotland:

 

“The board of the CNPA considered its response to the consultation on the transfer of the estate from current owners Highland and Islands Enterprise (HIE) to FCS at its monthly board meeting on Friday 3 November.

David Green, Convener of the CNPA board said: “We fully support this transfer subject to the delivery of an inclusive approach to the estate’s management and the delivery of a wide range of public benefits.

“It seems sensible that Forestry Commission Scotland should assume ownership of the estate, rejoining it to its holding at Glenmore, and the organisation has a proven track record in managing land to deliver public benefits and ensuring that local and national interests are fully involved.”

Among the other points raised by the CNPA in its response to the consultation are:

  • An early priority should be the production of a management plan to steer the future of the estate and this should be done following consultation involving a wide range of interested parties. Such a plan should include ways of delivering the priorities emerging in the Cairngorms National Park Plan as well as incorporating integration with neighbouring land holdings.
  • Short term environmental improvements, such as the removal of some ski-ing infrastructure, should not be carried out at this stage. Decisions on these proposals should be deferred and instead considered through a full management planning process and through consultation with all those interested in this aspect of the estate.
  • Bureaucracy should be minimised and all meetings relating to the management of the estate should be open to the public.

Fiona Newcombe, the CNPA’s Head of Rural Development Strategy commented: “Forestry Commission Scotland is the obvious organisation to take over the Cairngorm Estate. As an enabling organisation, the National Park Authority is not best placed to own land, but rather positively influence land management by others. We are fully supportive of this move and welcome the principle of wide stakeholder engagement in the management of the estate.

I think the CNPA were right in 2006.  Until the Cairngorm Estate is transferred from HIE to FCS (and Natural Retreats replaced as operator of the ski area) the actions set out in the Cairngorm Glenmore Strategy will remain aspirations.

In fact, its three leaves, that’s right in just 3 pages (at the bottom of this post) the New Forest National Park lays out its entire litter management plan in terms even a layman can understand.  It’s cost effective and keeps the park clean. It does all this without access restricting bye-laws or management zones or the destructive negativity Loch Lomond &TNP exhibits towards its visitors. It is a positive approach which just gets the job done.

 

Small but perfectly formed

 

At only 220 square miles the New Forest National Park is less than one third of the area of Loch Lomond and the Trossachs’ 720 square miles. However, its network of roads and 150 forest car parks handle 13,555,400 visitor days per year which dwarfs the Loch Lomond &TNP in all respects [circa 7m visitor days]. Despite these huge numbers they provide unprecedented access through their network of car parks each one with that most essential of items, a litter bin, ensuring the best chance of keeping the Park spotlessly clean as part of an effective litter management policy and a shared £250k annual bill for collecting/picking up litter in the countryside.

 

Surprisingly they have only 5 full time rangers supported by another 5 from The Forestry Commission and 70 volunteer rangers so it’s easy to see it’s not brute force of patrolling that makes a difference. So what’s their secret?  In truth, it’s all down to having implemented a proper litter management strategy.

 

Smaller still, but out of touch

 

img_5203-small-2
P & K litter bin Loch Earn – Photo Credit Nick Kempe

Loch Lomond and the Trossachs National Park with much of its area inaccessible to the litter dropping public has identified only 3.7% of the park as problem zones or 27 square miles. The cost of collecting/picking up litter in this area would equate to £ 31 K on a pro-rata basis with the New Forest.  Given that household litter collection is already a feature in many areas it should be possible to do this for a similar amount  to be shared between local Councils, Forestry Commission Scotland and Transport Scotland. Indeed Perth and Kinross Council already do this.  However, 10 years on, the Loch Lomond &TNP has spectacularly failed to deliver any effective infrastructure for visitors or rural sites in most of the National Park.

 

Meetings about meetings as the Park Authorities failure to act continues

 

Loch Lomond &TNP admitted this in their first conclusion reached at a meeting in June 13th 2016 to discuss litter management

rossIt’s obvious to all that a litter bin to contain this bag would have prevented this situation.

Innovative Approach or just good Management?

 

The New Forest are to be congratulated on their approach which involves the public in a very constructive manner. The park authority takes their own responsibilities seriously by coordinating public awareness of where to report litter problems and the Councils and Forestry Commission are fully on board understanding what is expected of them. The innovative use of technology to allow easy reporting to be carried out using an app directly involves the public encouraging them to take ownership of the problem.

A stark and damning contrast

In stark contrast to the New Forest, LLTNPA employs lots of rangers with 30 full time rangers (some water-based), 30 seasonal rangers supported by a further 150 volunteer rangers.  In addition, there are 3 forestry Rangers assigned to duties on the East Loch Lomond shore and where their schedules permit, access is available to 3 more park wide.   Historically the role of “Ranger” has been educational rather than about policing and Rangers have been viewed with respect through their love and knowledge of the countryside and our National Parks. The Park Authority is undermining that position by turning them into parking wardens and a quasi police force and not providing the infrastructure that would make their jobs possible.

 

Polar opposites

 

It can be seen  the two management strategies is polarised and comparing them it is clear which one comes out on top; do away with the regulation, enforcement, bylaws and other unnecessary distractions and get on with the job of managing the National Park is the clear message.

 

Loch Lomond &TNP’s failure to implement a litter strategy makes them complicit in littering through their failure to act.  Instead they capitalise by taking images of the very mess they are responsible for creating to justify the byelaws no one wants. They continue to waste taxpayer’s money on ineffective campaigns, enforcement and ranger patrols when it is clear that without the infrastructure in place they will fail. The requirement for litter bins and a man with a van to empty them is not so difficult a concept to grasp, so why year after year are we presented with another set of excuses and round of blame shifting to another group of visitors?   Meanwhile the litter management strategy is still in draft.

 

No Consensus on any Litter Management Strategy but full agreement on fines.

 

Their meeting agenda to try and convince the public that they are on top of litter management is a distraction to convince those who monitor that some progress has been made. It refers to initiatives from 2014 and ends with a second conclusion which says it all, another tranche of fixed penalties and enforcement to penalise a beleaguered public is the only way forward:

 

7.2. The Park Authority has made progress on the public information and awareness aspects with the litter emphasis of the RESPECT Your Park campaign and also the enforcement aspect with the use of Fixed Penalty Notice Powers being introduced this summer.

Appendix 1 – Fixed Penalty Notice Policy

Appendix 2 – Fixed Penalty Notice Scheme of Delegation

 

The truth is the introduction of Fixed Penalty Notices is creating confusion among visitors who want to put rubbish in its place but are confounded by the fact in large areas of the Park there is simply no place to put it.

 

New Forest Litter Strategy

(see http://www.newforestnpa.gov.uk/info/20096/unspoilt_landscape/44/litter )

new-forest

The New Forest’s unspoilt natural beauty is one of the things that people value most about the area. In general, the air and streams are clean and away from the roadsides and car parks there is very little litter.

Sadly, a minority of people deliberately throw food packaging from their cars, allow pieces of plastic to blow from open-backed vehicles, leave litter in parking areas and even deliberately dump quantities of waste materials if they think they can get away with it.

We work with partner organisations, especially the Forestry Commission and New Forest District Council, to raise awareness of the problems caused by litter and to tackle them.

If you see excessive litter in the New Forest, please report it. This can now be done using the New Forest In Touch mobile app which can be downloaded for free.

 

Reporting litter and fly-tipping

 

The sooner litter and fly-tipped material is cleared up the better. Some roads are checked and cleaned on a regular schedule, but most are done when needed, so your help in telling us when there is a problem is appreciated.

The New Forest National Park spans a wide area in which different organisations have responsibility for collecting and disposing of waste, removing litter and following up reports of fly-tipping on public land. Public land includes roads, pavements, council-owned car parks, parks and recreation areas, laybys etc.

New Forest District Council is responsible throughout much of the National Park although, as land owner, the Forestry Commission has responsibility for the Crown Land. In Wiltshire (between Landford and Redlynch) responsibility falls to Wiltshire Council, and around Canada and West Wellow, Test Valley Borough Council is responsible.

Further information is available on the websites of these organisations and some have online reporting forms.

Please be ready to give as much information as you can, such as:

  • your own name and address, contact telephone number or e-mail address;
  • the location and description of litter or fly-tipping;
  • any information on perpetrators.

Contact details:

New Forest District Council
023 8028 5000
Report litter and fly-tipping using the New Forest in Touch mobile app which can be downloaded for free.
customer.services@nfdc.gov.uk
www.newforest.gov.uk

Wiltshire Council
0300 456 0100
www.wiltshire.gov.uk

Test Valley Borough Council
01264 368000
environmentalservice@testvalley.gov.uk
www.testvalley.gov.uk

Forestry Commission
General enquiries (office hours): 0300 067 4601
enquiries.southern@forestry.gsi.gov.uk
Urgent enquiries (24/7): 0300 067 4600
www.forestry.gov.uk/newforest

 

What is being done

Although we are not directly responsible for litter in the National Park, we do work with local organisations to try to reduce the amount of litter dropped and to increase the effectiveness of litter collection.

This work is coordinated through the Joint Litter Working Group which is attended by staff from the National Park Authority, Forestry Commission and New Forest District Council.

As the Principle Litter Authority for most of the National Park, New Forest District Council has a team of people who are tasked with regular waste collections and a range of other litter-related activities. However, much is also done by land owners, especially the Forestry Commission which is responsible for the Crown Lands, and illegal activities are followed up by the Police and Environment Agency.

The estimated cost of litter removal in the New Forest is over £250,000 per year.

Recent joint initiatives include:

  • Each year, staff visit schools across the New Forest to talk at assemblies and to individual classes about why it is so important not to drop litter. These are specially themed sessions that appeal to the age of the children and link to their curriculums.
  • Rangers and education staff often talk with people who might not normally think about litter through public events and at local fetes. Some of these are ideal for the topic – for example an annual Marine Wonders event at Lepe Country Park is a great place to talk about the effects of litter on the sea.
  • Each year, litter picks are organised in a variety of places, ranging from beaches to Open Forest. Usually these are instigated by local community groups but equipment such as litter pickers and tabards can be supplied on loan. Guidance on organising a litter pick is available from the District Council, which is able to call by to pick up bags at the end of the event. Following the success of the Clean for the Queen event in March 2016 we intend to promote an annual ‘spring clean’ – please let us know if your group or organisation would like to get involved.
  • Litter bins are provided at key locations throughout the Forest. Specially designed litter bins have been installed in villages where ponies graze. Not only are the bins pony-proof, but they have a routed ‘message’ saying how important it is not to leave litter where the animals might try to eat it. The Forestry Commission’s car park litter bins are also pony-proof and carry the same message; some locations have double-sized bins to cope with the demand.
  • Each year, posters are put up at key locations across the New Forest including car parks and windows of local businesses. To catch the eye of regular visitors, posters are changed at regular intervals, and rotated with posters about other important topics.
  • Increasingly, social media is used to encourage people not to drop litter. Through Facebook and Twitter we can reach a very wide local and visiting audience.
  • Roadsides are regularly litter picked by NFDC contractors, either at a regular frequency or when excessive litter is reported. This currently includes a contract with the Forestry Commission to cover Crown Land roadsides.
  • Hampshire County Council and Highways England are both committed to liaising with NFDC to ensure that where possible litter picking is coordinated with verge maintenance activities.
  • Please visit our webpage signposting people to the best ways of reporting litter. No single organisation is responsible for litter across the whole of the National Park, and it really helps those who are responsible to be quickly informed when there is a problem.
  • New Forest organisations have joined Tidy Britain Group’s Love Where You Live campaign. This encourages people to take pride in their local area and inspire them to get out there and make it the kind of place they want to live and work. It is planned to be a 10-year national campaign with widespread advertising and we welcome this additional publicity.
  • There are some good examples of local businesses that actively encourage their customers to take litter seriously and, for example, staff from the McDonalds restaurant at Picket Post regularly litter pick nearby roadsides. We hope to work with other local businesses to encourage best practice wherever possible.
img_7877-shieling-track
The “spruced up” unlawful Shieling hill track                                   Photo Credit Alan Mackay

Thanks to Alan Mackay for this photo, taken on Monday 4th September, which shows the new hill track by the shieling rope tow.  Its doesn’t look too bad does it unless you appreciate that the track has been spruced up to impress the planners – if you look carefully you can see the right line of the track is eroding, the third time this has happened since the track was put in.

 

I am delighted that a number of well reasoned objectives to the retrospective planning application have been submitted including from local people, the Mountaineering Council of Scotland and the North East Mountain Trust among others.   Rather confusingly they are not included under the comments section of the planning application but under “documents” (see here)  but are worth reading.    I particularly liked this one, which happens to be from furth of Scotland, because the respondent does not mince her words:

 

A company who flagrantly ignores original planning laws should not be able to apply in retrospect when the damage has already been done. They need to be stopped (not just fined, as a fine is peanuts to a large company and acts as no deterrent to them or any other company/organisation in the future). The only way to stop such environmental damage is to ignore their planning application as being too late, insist that the damage is put right (by very harsh fines or even enforced closure of the company at a time that will hit their purse and profits). Finally this way some of the companies who flout planning laws and the environment will start to listen. If you fail to act, then expect the destruction of the very countryside which draws in money and tourism to the area (kill the golden goose and you will kill the golden eggs it lays for your economy).

 

As I have said elsewhere, the failure of the CNPA to use its planning enforcement powers is bringing the whole planning system in the Park into disrepute.   The key long-term issue is that if the CNPA accept this planning application, rather than requiring the track to be removed, this sets a precedent for new tracks being created alongside every ski lift within the ski area.    The CNPA will have no grounds then to refuse any further planning applications that follow, whether retrospective or not.   I have asked Highlands and Islands Enterprise, the owners of the land, for all the information they hold about the need or plans to cover Cairngorm with more tracks.   If they don’t hold information on the need for hill tracks, this will help  demonstrate the current application is unjustifiable but if they do, this will indicate they have a secret agenda at Cairngorm.

 

The wider problem is there appears to be NO proper plan to manage the Cairngorm ski area from a recreational and environmental perspective.  This is illustrated by both the evidence on the ground and paperwork.

 

The latest evidence on the groundimg_7887-cas-gantry

Cas Gantry 5th September                                                             Photo Credit Alan Mackay

 

img_7892-alan-mackay-cas-gantry
Cas Gantry 5th September Photo Credit Alan Mackay
img_7889-alan-mackay
Photo credit Alan Mackay

While Natural Retreats has been busy sprucing up the shieling ski track for the planners, they have done nothing about the bullodozed stones and soil at the Cas Gantry which sits just above the top of this slope and been there for months.   The reason why?  Highland Council stated that this did not need planning permission because it was part of emergency works last year to make the gantry safe.  The Cairngorms National Park Authority Planners appear to have accepted this BUT if so they have their head in the sand.   The CNPA is also responsible for the conservation of the area, whether particular earthworks are deemed to require planning permission or not.    And unless the CNPA can force Natural Retreats to abide by planning requirements its going to have NO ability to prevent any of the other destruction that is going on at Cairngorm.

The remains of the old gantry that Natural Retreats has simply cut off rather than removing properly – everywhere you look there is evidence to disprove Natural Retreats claims to be undertaking high quality re-instatement work. Photo Credit Alan Mackay 5th September

 

 

The paperwork

There are a number of mechanisms in place or being developed that in theory should have been able to prevent the destruction that is going on at Cairngorm.   The problem is that all so far are deficient.  This is a major problem for the National Park and a key reason why ownership of the land at Cairngorm needs to be transferred from Highlands and Islands Entrerprise to Forestry Commission Scotland.

 

Earlier this year the Cairngorms National Park Authority consulted on a plan for Cairngorm and Glenmore which said nothing meaningful about future plans for the Cairngorm ski area because Natural Retreats had not supplied them with the necessary information.   There is still as far as I know NO plan for Cairngorm.   This plan would be the right place to set out an overall vision for the ski area which included both upgrades to the ski infrastructure but also how the adverse landscape impacts from the past could be mitigated (from removal of all the abandoned rubbish to planting of montane scrub to screen some of the infrastructure and improve the recreational experience).

 

The other documentation which relates to the care of the natural environment at Cairngorm consists of the lease  between HIE and Natural Retreats and Natural Retreats’ Environment Management System.  The current lease includes the Visitor Management Plan which was developed to enable the funicular to go ahead but that is about the only environmental provision.   While all the land in the Cairngorm ski area is included in the definition of the “Premises”, almost all the clauses about the premises are about buildings and infrastructure and how this will be paid for.   There are no specific clauses about protecting or restoring ground vegetation or wildlife and while there are some very general clauses its hard to see how HIE might invoke them to stop the destruction at Cairngorm.   To put it another way, HIE’s contractual relationship with Natural Retreats has allowed this destruction to happen and HIE bear responsibility for this.   The fact they have done nothing to remedy this deficiency – their negligence – is  evidence that they are not fit to manage Cairngorm.

 

Natural Retreats’ Environmental Management system is one of the those bits of paperwork that  enables boxes to be ticked but avoids the main issue.  There is nothing in it about how the land at Cairngorm will be managed.   Nothing to indicate if their management of the ground and external environment was better or worse than what has gone before.  Instead, like the lease, it is buildings focussed ( a necessary but minor part of the issue at Cairngorm).

 

Their Environment Policy demonstrates this clearly:

 

To minimise environmental impacts concerning our activities, products and services, we shall:
 Comply with applicable legal requirements and other requirements to which the Company subscribes which relate to its environmental aspects
 Prevent pollution, reduce waste and minimise the consumption of resources
 Educate, train and motivate employees to carry out tasks in an environmentally responsible manner
 Apply the principles of continuous improvement in respect of air, water, noise and light pollution from ourpremises and reduce any impacts from our operations on the environment and local community
 Encourage environmental protection among suppliers and subcontractors
 As far as possible purchase products and services that do the least damage to the environment and encourage others to do the same
 Assess the environmental impact of any new processes or products we intend to introduce in advance.
About the only part of this they have breached in relation to all the destruction of the external environment is the requirement to educate employees to undertaken tasks in an environmentally responsible manner.

What needs to happen

 

I  believe the evidence and paperwork shows neither HIE nor Natural Retreats are fit to manage Cairngorm.   What needs to happen is the CNPA needs to use all the powers available to it to stop the destruction at Cairngorm and develop a proper plan but I doubt this can be effective until Scottish Ministers transfer the land from HIE to FCS and the lease with Natural Retreats is terminated.   Instead  I would like to see a community led business appointed to run the Cairngorm Ski Area.

IMG_5831 - Copy
The countryside around Loch Chon – the Park’s plans don’t support large developments in the countryside

I have been asking the Loch Lomond and Trossachs National Park Authority what criteria it would use to decide the planning application it is making to itself for a campsite at Loch Chon.  Among the issues is that the Your Park proposals to develop new campsites is not consistent with  the Park’s proposed Development Plan (see here)   Just over two weeks ago I received this reply which is far from clear:

 

“With regards to your request for advice regarding the determination of the planning application for Loch Chon, this will be determined in accordance with the development plan, taking relevant material considerations into account, as is the case when determining any planning application. The Adopted Local Plan and the Proposed Local Development Plan, which will eventually replace the current adopted plan (following the outcome of the current examination and including any modifications required by the Reporter) can both be found on our website.”

 

My guess is that in saying any planning application “will be determined in accordance with the development plan” the LLTNPA are referring to the Adopted Local Plan NOT the Proposed Local Development Plan and I have asked the Park to confirm this.   If so they have wasted money preparing an application which uses terminology from the proposed Local Development Plan (£100k spent last financial year with nothing to show as yet).

 

Now I can find NOTHING at all about campsites or camping in the current Adopted Local Plan.  This is a historic omission which has enabled the LLTNPA, since its creation, to grant planning permission to one former campsite after another to convert to caravan parks or “luxury tourist lodges”.  At least the proposed Local Development Plan mentions camping, although its provisions are so unclear and so muddled that it is unlikely it will do anything to help remedy the lack of campsites in the National Park.

 

The Adopted Plan though  does contain policies about developments in the countryside, which are relevant to the Loch Chon Planning application, including:

a) ” Proposals for medium to larger scale tourism development within the countryside will generally be resisted unless there is demonstrable evidence of:

(h) Strong market demand for the development that is currently not being met, and

(i) the benefits that development would bring to the local economy.”

b) A map which shows Loch Chon  in an area designated suitable for  “moderate increases in outdoor recreation”

 

The LLTNPA is proposing over 30 places in the Loch Chon campsite – if this is not a medium to large scale development what is?  Moreover, the Park’s Ranger records show there is very little camping in the area at present.  This suggests there is no market demand for such a large campsiten so it should “generally be resisted”.  Moreover if it were to be approved and did create new demand this would breach the Park’s policy on this being an area that is only suitable for moderate increases in recreation.

 

What’s as  interesting is that the policies in the proposed Local Development Plan, as they apply to Strathard and Loch Chon, are very similar to the current Adopted Plan.  Its designated an area of “smaller scale tourism potential”.  The proposed plan states that recreational developments should be where existing demand is – in other words the Park should only develop larger campsites such as that at Loch Chon where they are needed – and generally says quieter areas of the countryside should be conserved as such.   So, the Loch Chon campsite planning application contravenes both the current Adopted Local Plan and the proposed Local Development Plan.

 

Gordon Watson, the Chief Executive, as the former Director of Planning should have known this but the LLTNPA was desperate to announce it had some plans for campsites when the Minister approved the camping byelaws.  The only place the Park and Forestry Commission Scotland – the key partner who was supposed to deliver new campsites – had agreed on was Loch Chon.  My suspicion is that the original proposal here was for a much smaller campsite but Gordon Watson was either told or decided to increase the numbers to 30 to make the Park look better.  This was despite him knowing it contravened the Park’s own planning policies.   The whole proposal has been unravelling ever since and I trust that if it ever goes to the Planning Committee – and their meetings for July and August have been cancelled – members of that Committee will take an objective look at their own policies and do the right thing.

 

What needs to happen

The sooner the Park abandons the proposal for such a large campsite at Loch Chon the better.   The proposed site is great for camping – I was walking with someone at the weekend who had camped there and just seen a couple of other tents – and no-one would object to installation of a toilet and litter bin (for day visitors as much as campers).  But the mad ideas of using shipping containers for toilet blocks, trying to get people to camp on wooden platforms and forcing people to camp in designated places away from the lochside just need to be dropped.  The LLTNPA needs to go back to basics.

 

What the LLTNPA should do  is create a network of small campsites through the Trossachs.  In Strathard there could be small sites (just toilet and tap) at Loch Ard (e.g in the area being considered for camping permits) Loch Chon and Loch Arklet.   This would enable cyclists and walkers to make far better use of the path network that was created a few years ago and is sadly underused.  Such a network would be totally compatible with the vision of small scale tourism developments in the area which is contained in the Park’s plans.

 

The £345k allocated to the Loch Chon campsite this year should be easily enough to achieve this.   For £10k you could buy and install very high quality composting toilets and if the rest of the money and money current spent on ranger patrols was given to the local community they could invest it to maintain both campsites and manage the impacts of day visitors.

Approaching the abandoned ski tow in Coire na Ciste two weeks ago, partially concealed by the rows of abandoned chairlift seats, three men in flak jackets, each with a camera whose lense was the size of a telescope, were reclining on the ground.   Two of them had come to Speyside from the south east of England to watch birds and had spent half the day are the Coire na Ciste carpark getting to know the Ring Ouzel.   On an average year I see a few Ring Ouzel, but always around boulderfields and often under crags, although these birds are normally associated with montane scrub zones.   Cairngorm is a good place to see them because the forest is growing back.

 

An hour later we had wandered up into Coire Cas where we saw first an adult then the chicks

Photo credit Dave Morris
Photo credit Dave Morris
Ring ouzel chicks
Photo credit Dave Morris

 

 

 

 

 

 

 

Brilliant, ring ouzel in montane scrub!    It got us thinking.    What an opportunity missed.  It would have been perfectly easy to put a camera on the nest and relay the photos to the Day Lodge.  Do that and suddenly tourists would have a reason to be there, even when the cloud was down as on our visit.  Something far better than the funicular – it had us grinning for the rest of the day and not just because we had got better views than the men with enormous cameras.  Visitors might go into the cafe afterwards to have something to eat or even a drink to celebrate.   Travel to Speyside to see Osprey at Boat of Garten, Peregrine at Aviemore (this summer you can watch them by video link from the Youth Hostel), Ring Ouzel at Cairngorm and, here’s hoping, Hen Harrier at Newtonmore.      Better still though, imagine the whole of the lower part of Coire Cas was covered in montane scrub, the numbers of Ring Ouzel – which are in serious decline nationally – might increase and people could just wander along paths or up through the pistes and see them like we did.

 

Now in general I am opposed to planting on the edges of forest which are relatively natural and capable of regenerating naturally as the Caledonian pinewoods are doing on Cairngorm.   Speeding up rewilding is likely simple to create habitats the way we, or the powers that be, think they should be.  A form of gardening, however sophisticated.  But Cairngorm I think is different.

 

It is ecologically different because the soils and ground vegetation have for a long time been affected by intensive human use and now in places, as in the bulldozing done by Natural Retreats,  in effect destroyed.  In destroying these soils and the ground cover, erosion is bound to increase and the chance of a major catastrophic event, such as the whole slope failing, more likely.      Planting trees that will develop into montane scrub won’t do any more damage on areas which have been extensively modified and could help stabilise them.  There is even guidance on how to do this http://highlandbirchwoods.co.uk/UserFiles/File/publications/Montane-Scrub/guidance.pdf

 

Cairngorm has also been subject to a number of tree planting experiments which provide precedents, the latest of which show that a montane scrub zone could probably be well established in 10 years.IMG_6127

These lodgepole pine – non-natives – were planted by an employee of the then Cairngorm ski lift company.  Guerilla gardening!

IMG_6063
These native trees originated from a grant awarded by the then Nature Conservancy at the end of the 1970s to demonstrate to the chairlift company that trees would grow in Coire na Ciste. Subsequently there has been some natural regeneration

 

 

 

 

 

 

 

 

IMG_6088
These trees were planted when Ben Humble’s Alpine Garden was relocated uphill at the time of the funicular construction.

Trees here are unlikely ever to grow to full height, unless global warming ends the harsh winters and wind speed decreases, but the photos show that a planted montane Alpine scrub zone in Coire Case could become well established in relatively short periods of time.

 

IMG_6132While there is some natural regeneration in the ski area, this has been limited, probably in part due to accidental destruction by ski machinery and skiers.    Planting trees behind the solid new fences would offer them protection from this threat but in time soften the harsh linear lines of the fencing improving the landscape.  In time, the trees might provide an effective alternative to snow fencing.

 

There is nothing revolutionary about this idea.   Look at similar ski areas in Norway and Canada and the runs are often through forest or montane scrub which help trap the snow and look much better.   Imagine if trees had been planted at the time of the construction of the funicular, this area would have been transformed.

 

The potential attraction of a montane scrub zone is not just limited to the Ring Ouzel and trees.   At present there is very little montane scrub in Scotland due to the long history of overgrazing and the best such habitat at Inshriach is inaccessible to the general tourist.   If a montane scrub zone was planted here it would provide an attraction for the general tourist which they could not see anywhere else.

 

Indeed, at the time of the funicular construction, the staff at Cairngorm made a serious attempt to promote understanding of montane scrub zone.   While a lot of the interpretation that was developed then is now sadly neglected, it points the way and some of it could still be used.IMG_6046

One of a number of signs in the “viewing” station on the edge of the Coire na Ciste carpark

 

 

IMG_6087
No sign of the alpine bistort among the dwarf cornel

 

 

 

 

 

 

IMG_6081
A once great idea undermined by neglect
IMG_6082
Wildlife of montane scrub in Norway

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

IMG_6103
Info from James Hutton Institute on fungi
IMG_6104
Cloudberry growing on the ski slopes

 

 

 

 

 

 

 

There are still some very informative signs, including ones comparing Cairngorm with similar mountains in other parts of the world.  At present almost all the interpretation is in the neglected “Alpine” garden above the Day Lodge.  There is scope to extend this onto the ski slopes in Coire Cas where its possible even now to see plants that the general tourist is unlikely to see anywhere else.  Some further planting of  Alpine plants in suitable places along sections of the existing paths and tracks in lower Coire Cas could create an attractive trail like some of the Alpine gardens on the continent which are much larger in scale than the current one in Coire Cas.

 

The creation of montane scrub habitat in Coire Cas could help counter the steady drop in the number of visitors using the funicular.   This has approximately halved since it was constructed and continues to threaten the whole financial viability of Cairngorm which, on the current model, depends on visitor numbers.  Visitors coming to the ski area to see the wildlife won’t in themselves rescue what is a white elephant but it could be part of a different model of sustainable tourism which is based on recreational enjoyment of  the natural environment.   It might even  put the “natural” back into “Natural Retreats”.

 

In the past the primary concern about attracting visitors to Cairngorm has been about the serious threat that large numbers of people would have to the uppers parts of the mountain and the Cairngorms plateau.  This is why the funicular is to all intents and purposes a closed system in summer.   Attracting people to visit a montane scrub zone in Coire Cas though is  unlikely to have any impact on the plateau.  The vast majority of people would be what I would loosely describe as “general tourists” who tend to do short walks.  It should not be difficult to keep them in Coire Cas through path signage and interpretation.  Hillwalkers who wanted to see the montane scrub would proceed up the hill anyway and for those wanting longer walks, walking back into Glenmore will most of the time be the more attractive option.  I don’t think there is much more likelihood of the general tourist heading for the plateau after seeing the montane scrub zone than there is now of then general tourist travelling to the top of funicular and liking the view so much that once they have been taken back down they decide to walk back up on their own two feet.

 

I have tried in this post to put the argument for the creation of a montane scrub zone in Coire Cas through planting trees and some plants.  This would reduce the impact of the ski development on the landscape, improve the skiing, improve habitats for wildlife and create a reason for summer visitors to come to Cairngorm.  The evidence of the destruction in Coire Cas suggests then neither Natural Retreats nor Highlands and Islands Enterprise are fit to deliver such a vision and that there is a strong argument to integrate management of the ground in the ski area with that in Glenmore below.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

The inclusion of a paper  Agenda Item 9 – Reducing litter in the National Park  for discussion at the Loch Lomond and Trossachs National Park Board  Meeing on Monday (13th June) is welcome.  The paper makes a number of welcome statements, which are very relevant to the issues which have been raised on Parkswatchscotland by myself and Nick Halls (e.g http://parkswatchscotland.co.uk/2016/05/17/accommodating-needs-visitors-loch-lomond-trossachs-national-park-nick-halls/).  Unfortunately  though the paper fails explore the full implications of these and the Park still has some way to go to articulate a comprehensive plan to address litter..

  • The paper states that litter is a problem almost everywhere in Scotland and makes the implicit acknowledgement (which was absent during the whole of the Your Park consultation process on the camping byelaws) that litter is a far wider and greater problem than something caused by inconsiderate campers.  What it fails to say is that the then senior management and the Park Board claimed to Ministers that the camping byelaws had solved the litter problems on east Loch Lomond: if Roseanna Cunningham had visited Balmaha last weekend she would have seen litter strewn throughout the village due to the numbers of day visitors dropping rubbish or having nowhere to put it.
  • The paper states that at the heart of the National Litter Strategy, published in 2014, is the idea of prevention, of getting individuals to acknowledge responsibility and that education is the key to this.   What the paper does not say is this conflicts with the claim made in the Your Park consultation that education had not worked and the only way to solve litter was to ban campers.  I am delighted the paper is putting education being put to forefront again but it begs the question of why the Park ever proposed camping byelaws
  • The paper describes the inconsistencies in litter collection arrangements by Local Authorities through the Park:  Stirling does not provide litter bins, West Dunbartonshire and Argyll and Bute do so, but only in some places, while and Perth and Kinross (which only covers a small area of the National Park) is the only Local Authority that does provide bins consistently.   What the Park does not say is that the 5 Lochs Visitor Management Plan back in 2012 was supposed to have produced a litter strategy by 2013/14 which would sort this out for a large part of the Park.  This was never done and now there are not even timescales for action.
  • The paper reminds Board Members that in the Partnership Plan 2012-17 there was a vision for litter recycling throughout the Park that people would use. What has not been stated is that this has clearly failed, not because people are failing to use litter bins (they are overflowing where they exist) but because they have not been provided.    What the paper does not say is WHY local authorities have failed to install litter bins or indeed why it has failed to do so on its own land.   The paper clearly states the LLTNPA is responsible for clearing litter on the land it owns, which is to be welcome, but does not explain why there are no bins at the carparks on the parcels of land it owns around Loch Venachar
  • The paper clearly states that local authorities have a duty to keep our roadsides clear of litter but makes no mention of their failures to clear litter alongside the main roads through the National Park (now partly covered by growth of vegetation because its summer) which have been highlighted on Parkswatchscotland
  • The paper refers to the Scottish marine litter strategy but makes no mention of the litter at the head of Loch Long, which is a blight to both the local community there and visitors,  that has been highlighted on parkswatchscotland and is again nothing to do with campers.
  • The paper provides background to the LLTNPA’s new policy and procedures on Fixed Penalty Notices (fines) for littering which are included as appendices to the report.  The paper makes the welcome statement that fixed Penalty Notices should be a last resort, that education should come first.   The irony is that if this approach rather than the NIMBY one had been used for problems associated with campers the camping byelaws would never have been proposed.  Unfortunately the paper and the accompanying policy and procedures do not explain how education first might work in practice.   The reason why Countryside Rangers should have the power to issue Fixed Penalty Notices is not to turn them into a quasi police force (which is what will happen if the camping byelaws go ahead and which is why the Scottish Countryside Rangers Association objected strongly to them) but to give them “authority”.   It would allows Rangers to explain, when they come across evidence of people dropping litter or picnicking or camping next to a pile of rubbish, not just to explain to people why they should not do this but to ask  them to clear it up then and there.  If the person/people ignore them, then they can issue the fine but, with the right communication skills, I believe this should rarely be necessary.
  • The biggest omission in the paper is the failure to mention the role of the Forestry Commission Scotland, the large landowner in the Park, and its role in addressing litter.  So just what is it planning to do?    Nor is there any mention of the role of other landowners, the positive things they are doing at present (eg Luss estates does regular litter pick-ups) but also, most importantly their role in creating litter.   Farm litter in the National Park or the litter associated with some of the current industrial developments in our countryside is arguably a greater problem than any litter left by visitors.
  • The paper mentions but makes no proper evaluation of flytipping, which is mostly undertaken by local people or businesses, not visitors.  The huge dump on Loch Loch is another national disgrace but there are many smaller examples.  Its great the LLTNPA now has powers to address this through fines but what actually is it going to do?
  • The paper also fails to mention the role of local tourism businesses in generating litter.  Now many businesses in the National Park have been at the forefront to clear it up but there are some businesses that generate much of the litter that is dropped, particularly in the tourism hotspots where people buy their ice creams on a sunny day and then drop the wrappers.   There is no mention of what these businesses could do either to provide litter facilities or give out messages (“please put all packaging in the litter bins we have provided”.
  • There is also no mention of the role of the Park’s own Ranger service in collecting litter.  In the absence of litter bins, if they are not allowed to put litter in the Park’s vehicles for alleged health and safety reasons and are forced to put this by the roadside for collection, any member of the public seeing them will do the same.   And we all know what happens to rubbish left out for collection, wildlife has a feast and in doing so scatters it once again.
  • The paper makes no mention of the Keep Scotland Beautiful Audit of litter in the National Park which was supposed to be published shortly after the meeting of the Board in October last year

In summary, while the paper is a useful indication of how a strategy might be developed – and therefore a step forward – it unfortunately it has been produced under a Board which up until now appears to have thought that camping byelaws would be the Park’s answer to everything.  The paper is welcome because it does provide an alternative to the flawed logic which led to the proposed camping byelaws – if banning camping is the answer to litter left by campers, then banning drivers would be the answer to the litter thrown out of car windows along the A82 – and has started to suggest alternatives.  If this leads to a change in approach, it is very welcome but to do so the Board will need to endorse a change in direction.  Here are some suggestions about how this could be made to happen:

  • The new Minister for the Environment, Roseanna Cunningham, who chairs the annual review of the Park’s Partnership Plan, should call a special meeting of the Park and Local Authorities to review the lack of progress they have made on installation of litter facilities and set clear timescales for production of implementation of a litter strategy.   She should also insist the Park develop a proper plan – the Five Lochs Management Plan had a section outlining the actions needed on litter which have sadly never been progressed but would provide a good starting point.
  • The new Minister of the Environment should now acknowledge that campers only account for a small proportion of litter problems in the National Park and littering is not a justification for the removal of access rights.
  • The LLTNPA needs to be told that its litter strategy must  include a plan for addressing marine litter (including exploring the implications of the National Marine Litter strategy), farm litter, dumping and rubbish left by developers
  • The LLTNPA, instead of imposing education messages on people, should engage with visitors about what messages might influence them to take even more care because it’s a National Park.  It should also consider how it can use people who care about the countryside most, which includes walkers and campers, to spread the message.  This means engaging with the recreational organisations such as the Ramblers and all the activity organisers who use the Park at present and whose activities are now threatened by the Park’s proposed bye-laws.

The Herald yesterday (8th June) carried a story that has now been recycled several times about the Mountains and People Project which is investing £6.1m in footpaths in our new National Parks.  The new angle was hillwalkers are being asked to report footpath problems, far from a new idea but good stuff.

What was new was the quote from Roseanna Cunningham, the new Minister for the Environment, who said that no-one cares more deeply about conserving our landscape “than those who walk our hills and countryside regularly”.   She is to be congratulated for saying this, but having said this I hope she will now ponder the logic of her predecessor, Aileen McLeod, to approve the Loch Lomond and Trossachs National Park’s camping bye-law proposals.  These will of course these very same people from enjoying the landscape in what is the best way possible, by not just walking through it but by staying in the outdoors.

The story was also, as is often the case, as interesting for what was not said as for what was:

  • Our National Parks were set up in part to improve infrastructure for visitors, such as paths, so why is Heritage Lottery Funding needed to do this?   If National Parks are not funded sufficiently well to do this themselves, what hope for the rest of the country?
  • The majority of the Heritage Lottery funding for the Loch Lomond and Trossachs National Park is going to Forestry Commission Scotland to fund pathwork on hills such as Ben A’An and Ben Venue in the Trossachs and the Arrochar Alps.   While FCS is making a financial contribution, far more money will be spent on FCS paths by the Mountains and People Project than what it has put in.  Why does FCS not have the funds to do the jobs its needs to do?  Is it misspending its resources, buying places like Rothiemurchus for £7.4m, or does it simply not have enough to achieve its objectives?
  • Arising from this lack of public finance, are questions about the project itself?  How will all the people who are to be trained in footpath work – and who were pictured in the paper – get jobs at the end of it?   Is the project training yet more people who will end up without a job due to a lack of finance, austerity?    Is there any point in getting hillwalkers to report problems if in three years time there is no-one left in the Park able to fix them?

 

Now, I intend no criticism here of the staff who have put this proposal together and obtained the funds.  They are having to work in very difficult circumstances, where due to the prevailing neo-liberal ideology, proper funding is not available for mountain paths among a multitude of other things.   So they have to scrape funding together and all credit to them for doing this.  We kid ourselves though if we fail to consider and alert people to the  wider implications.

 

So, the first thing that needs to be said is that we need far more investment in footpaths across Scotland and the Scottish Government needs to find ways to enable this to happen.   Walking is accepted as the single most effective way of people remaining health and getting people walking more is a national priority.   You would have thought therefore that investment in footpaths would be a political priority but its not.  In this respect walking now lags behind cycling where there is now a national commitment to increase levels of investment (even though this is far from enough).   Cycle funding though has benefitted our National Parks, for example the new cycle path between Drymen and Balmaha which is funded through Sustrans.  In the footpath world though there is no pot of money and no mechanism to channel public funds, hence the need for the Mountains and People Project.  I realise public finances are difficult but nationally believe we neecd to see a proportion of the roads budget, to increase year by year, spent on footpaths.

 

There are though also solutions at the National Park level and our National Parks could take a lead on this.  While I know Board Members have bemoaned the lack of funds for footpath work at Board Meetings, none are prepared to speak out and instead allow their staff to issue congratulatory press releases which only tell a small part of the story.    If Board Members are not prepared to criticise the Scottish Government, they could nevertheless put their own house in order and clearly state that there is not nearly enough funding going into footpaths and other visitor infrastructure and then lead by example.   They have a solution to hand and that is through the introduction of a tourist tax in the National Park (see previous post tourist taxes).

If they did this now, there might just be enough money available to provide jobs when the money runs out in three years time to some of the people who have been trained through the Mountains and People project.

On 27th May the Loch Lomond and Trossachs Park Authority advertised a planning application to create a new 30 place campsite at Loch Chon.  You can find all the papers through the Park planning portal http://eplanning.lochlomond-trossachs.org/OnlinePlanning/applicationDetails.do?activeTab=dates&keyVal=O79O0SSIJ6T00.

 

It is bizarre that the LLTNPA is applying to itself for planning permission when the land is owned by Forestry Commmission Scotland.   In their response to the Your Park consultation the FCS stated it would support new campsites but had no money to pay for them.  Leaving aside the fact that FCS appears to have plenty of money to lavish on private landowners, rather than the public  (it paid John Grant £7.4m to purchase Rothiemurchus), it now appears that FCS are basically taking nothing to do with campsite provision and are leaving LLTNPA to do everything.   This is totally wrong.  FCS are a public body with a recreational remit and should be serving the public.  Instead the FCS seem to have the Park wrapped round their little finger and, now they are no longer able to introduce their own camping byelaws, using the LLTNPA to do this for them as at Forest Drive by the Duke’s Pass

 

The Planning application contains no justification for this campsite.  I had previously asked the Park for all information they held about why they had decided to construct a campsite here and they have refused it (and that case is now with the Freedom of Information Commissioner)   The background was given in a previous post http://parkswatchscotland.co.uk/2016/03/27/con-loch-chon-proposed-trossachs-west-camping-management-zone/ which showed there is no demand for a campsite of this size in this area and called on the LLTNPA to publicly justify their plans.

 

Objection from Local Residents

A similar point has been made in a objection from two local residents who have questioned the size of the campsite and the proposals for managing it (there are now three objections from residents on the planning portal).   Put simply, the proposed campsite will either be a white elephant and not used or, if used, will have attracted far more people into the area without any plans for how this influx will be managed.     While I am against the NIMBYISM which is so evident among some people who are fortunate enough to live in the National Park, I thought this letter and the other letters of objection lodged on the Park’s planning portal have made some excellent points:

  • The residents question the proposal to use old shipping containers for the toilets, store and equipment room.  The Park says the containers will be plated with aluminium and painted – their illustration shows trees painted on the sides.    I think the residents are right, these will look dreadful from the start.      At present there is a glut of old shipping containers across the world  and they are now being used to provide housing in places like Africa.   So, they are cheap.  While I am sure the Park will justify their use as their contribution to recycling what about  supporting the local wood products  industry and constructing  toilet blocks which are in keeping with the National Park?
    IMG_5829
    The forest plantation on the southside of Loch Chon which was being harvested earlier this year. Neither FCS nor LLTNPA have given any consideration to using this wood to construct toilets on the proposed campsite.

    Is it really so hard  to construct buildings out of locally sourced natural materials land help sustain local employment?    If the LLTNPA really does want to make a contribution to world recycling, it could use these containers as temporary toilet blocks, like portaloos, and install them in the places most popular for camping over the summer. 

  • How is the Park going to hire out firepits when there is no warden on site?  To which I would add, why cannot this Park Authority provide anything for free?    If fires are such a problem as claimed by LLTNPA, surely every camping place should have a fire pit?     But then, given the lack of demand for camping here, this would be throwing more good money after bad.
  • Why is the Park wanting to install gates?  An excellent question.  A reader of parkswatchscotland recently pointed out to me that the gates that had been installed at Loch Chon made it very difficult for canoeists to access the loch.   Throughout the National Park the LLTNPA, which has a statutory duty to promote access, has been busy installing gates at carparks, the only purpose of which can be to stop access.  This NIMBY culture in the LLTNPA  affects the rights of local people as much as visitors.

Other reasons why the application should be rejected

The Park is proposing to provide some of the 30 proposed places – its unclear how many – on wooden platforms.     Now, I don’t think any camper in their right mind would want to camp on a wooden platform (I know it happens on sand dunes in Australia) and this illustrates two serious issues.   The LLTNPA has simply failed to consult with campers about fire pits, places or anything else.   Either none of its staff have ever gone camping or more likely senior management in the Park have simply failed to consult their staff who do camp and could tell them what makes a good camping place.      The second issue is that there is simply not enough ground in the area the Park has identified for a campsite to support 30 camping places.

IMG_5825
The path that goes through the proposed camping area. As the site plan states, much of the area is too boggy or steep to provide good places to camp but the Park wishes to fit 30 tents in a place that could sustain a third of that number.  The only reason for doing this is so it can say its delivered some new camping places.
IMG_5826
The area to the east of the current carpark is unattractive for camping and, while its been left out of the plans, similar areas have been included.

 

 

At present,  the area around the lochshore close to the proposed campsite is  the most popular for camping around Loch Chon, although people do use several other places (often to fish).  However, the Park wants to stop all this and herd people onto an area of slightly higher ground above the loch.   One reason there are not more people camping at Loch Chon at present is simply that the number of good places to camp is limited.  Creating camping platforms is not going to change this.

 

The design of the campsite is shown in the .Loch Chon 2016_0151_DET-Engineering_Layout-100262476 and there is an accompanying design statement produced by the consultants Loch Chon 2016_0151_DET-Loch_Chon_Design_Statement-100262485

 

Remains of fire Loch Chon
The best places to camp, by the loch shore, are NOT included in the campsite area

The Design Statement states that are no camping places by the shore as  “this will minimise visual impact on visual receptors such as canoeists on Loch Chon”.  Its great to know the views of canoeists are so important but I am sure neither the consultants or the LLTNPA bothered to consult the Scottish Canoe Association.   The SCA strongly opposed to the byelaws precisely because their members need and like to camp on the loch shores.   The statement is doubly ironic given that canoeists have been prevented from accessing Loch Chon  by the gating of access tracks which prevent anyone getting the vehicles or trailers that carry their canoes close to the water.

 

The Design Statement claims that “camping pitch locations………will allow for a range of experiences loch-side, burnside, high level”.   Ignoring the fact there are no lochside places planned, this is patronising drivel but it illustrates the mindset of the LLTNPA.  You need to remember the Park is intending to try and force people to book places:  “I am sorry Mr Kempe but the burn-side places are not available tomorrow but we suggest that if we allocate you a high level place that might expand your horizons”.    Petty bureacracy to replace access rights.   I really don’t believe this is coming from frontline staff.

 

The  Design Statement describes the Loch Chon con as a semi-formal campsite.   One of my objections to Park’s Development Plan was it used totally different terminology to the Your Park Plan which produced the byelaws Response – Development Plan and Camping.   A case of two parts of the LLTNPA bureaucracy failing to talk to each other .  Your Park used the terms “basic” and “limited” facilities, while the Development Plan – which is still to go to a Public Local Inquiry – used the terms “formal”, “semi-formal” and “informal” campsites.   A semi-formal campsite, according to the draft Development Plan approved by the Board, appeared the same as an informal site except it could have low level lighting.   Informal sites were defined as having no water or drainage, while both informal and semi-formal sites could have temporary or composting toilets.    From the Design Statement it appears the definition of semi-formal campsites has changed so semi-formal campsites will now include waste water treatment and a water supply while the toilets can be permanent as well as temporary.  It is good the LLTNPA  has made the definitions clearer, even if it is unclear who authorised this change or if they have replaced the Your Park terms – but then the LLTNPA takes lots of decisions behind closed doors.   .

 

The new definition of a semi-formal campsite however has had the consequence that such campsites now require formal planning permission, which in turn means the LLTNPA has to meet not just its own but other public authorities rules.  This has created a whole set of new problems.   Stirling Council’s Flood Officer has even objected formally to the application due to a lack of information on drainage culverts.  The risk of flooding may be an additional factor which explains why there are no camping places proposed by the loch shore where most people  want to camp.  Indeed part of the application includes a proposal by the LLTNPA to operate the Scottish Environmental Protection Agency’s flood warning system only for SEPA to point out that their system does not cover the area!  To add to the planning shambles, the Stirling Flood Officer has pointed out the road to Loch Chon, the B829,  floods regularly  so there would be difficulties evacuating campers.

 

 

All of these bureaucratic problems could have been avoided if the LLTNPA simply allowed people to camp as at present under access rights and take their own decisions about where it was sensible to camp.   To minimise the impacts of people camping here, the LLTNPA could have recommended to FCS that it should take responsibility for its own property and install couple of composting toilets and some litter bins.       FCS could have done this for under £20k instead of the £345k or so the Park has budgeted.  I am sure would have been welcomed by local residents.   To address the concerns about anti-social behaviour raised by local residents, the LLTNPA  should have been talking to Police Scotland about their role and how they could respond.    As the letter from two local residents clearly states  anti-social behaviour can take place in campsites just like anywhere else.    Only good policing will address that.

 

The amount of money the Park has devoted to the Loch Chon proposal could have been far better spent.   According to the Park’s end of year budget report to the Board it was aiming to spend £100k by the end of the financial year 2015/16 year  on the proposals.   I had previously wondered if this money had been spent because there had been no signs of work on the ground.  Its now clear now from the papers appended to the planning application it must have been spent on consultancy to produce plans for the campsite and environmental assessments.   The environmental assessment took place in January – not a good time for surveying wildlife and not surprisingly came up with a list of common birds.   I intend no criticism of the consultants but this was a bureaucratic exercise for what?   A poorly designed campsite for which there is no demand and on which it is planned to spend another £245k this financial year.

 

What the LLTNPA should have been doing, is what it should have been doing across the National Park, and that is to consider what basic facilities would help those exercising access rights (not just campers) to do so responsibly and to do so in consultation with both local communities and recreational bodies.    It could even have allowed local communities to make bids to install new camping facilities in their area – I am sure they would have spent the money being wasted on Loch Chon far more effectively.

 

If you want to comment on or object  to this proposal you can do so on the Park’s online e-planning facility or send an email to planning@lochlomond-trossachs.org   If you are objecting make sure you head whatever you say “Objection”.  The reference for the application is 2016/0151/DET