Tag: Forestry Commission Scotland

July 21, 2017 Nick Halls No comments exist

By Nick Halls, resident of Ardentinny

This is the fourth in a series of articles about the Argyll Forest part of the National Park where I live (see here).

Sligrachan Hill and Beinn Ruadh from the North West across Lock Eck, showing how Sligrachan Hill is cut off by forestry. The forestry continues round into Glen Finart on the far side of the hill.

Recently, as a stage in forestry operations, fencing seems to have proliferated. In the past fencing was usually used to exclude stock from the forest, as sheep purportedly damaged trees, but benefited from using the trees as shelter during bad weather. Apparently, sheep able to shelter in the forests maintain their weight and are more robust at lambing time, increasing the probability of raising twins.

 

When I first arrived in Ardentinny, there was an ongoing squabble between local sheep farmers and the Forestry Commission about maintaining fencing.  Outdoor instructors were caught in the cross fire as scapegoats, accused of damaging fencing by both parties. In practice, wherever fences were crossed regularly styles were constructed, but in many cases fencing was old and decayed.

 

After the great storm in 1968, the issue evaporated as Forestry trees were blown over destroying stock enclosures, throughout the forestry estate. I assume the Forestry Commission was liable because it was forestry trees that did the damage!

 

Ordinary stock fencing does not impede access very much, it’s annoying but not insurmountable, and can usually be negotiated without damage as long as a fence is in reasonable condition. Informal styles can be erected.  Now it seems that as stock rearing declines the beasts to be excluded are deer and people.

 

There seemed to be a resident Red deer and Roe deer population [often interbreeding with non-native Sika deer] but there was also long range migration of Red deer during bad winters.  For years, the local Red deer population migrated from pasture to pasture virtually unobstructed. They were informally described as ‘bed and breakfast’ deer as they lived in the woods and grazed on open hillsides.   Due to this way of life they were often bigger than the deer on stalking estates, and more akin to the forest deer of Europe. It was once suggested that there were two species, one a forest species and the other an upland, open hillside species [a distinction might have arisen due to interbreeding with Sika deer].

 

This seems to suggest that fencing, whether to keep deer out of forests or on an open stalking estate, has an impact on the condition of beasts, and interbreeding with a dilution of the pure bred native species. Bread and breakfast deer tend to do well, and the open hillside deer often fail to survive severe winters, underweight and starving, especially in over stocked localities from which they have difficulty migrating.

 

Recently I have seen far fewer Red deer, and those observed seem to be single deer rather than part of a group. The red deer population may have been culled.

 

I recall being told how important ‘wildlife corridors’ are to maintaining wildlife populations and bio diversity.

 

‘A wildlife corridor is a link of wildlife habitat, generally native vegetation, which joins two or more larger areas of similar wildlife habitat. Corridors are critical for the maintenance of ecological processes including allowing for the movement of animals and the continuation of viable populations’ ‘separated by human activities or structures [such as, roads, development, or logging].’

 

The increasing use of deer fencing to parcel out areas of forest or rough grazing effectively reduces access to much of the land, particularly the open hill, for both man and beast.  I seem to recall the aspiration of the Forestry Commission in Scotland was once a fenceless forest estate.

 

The bealach between Glen Finart and Loch Eck side is called the Larach [presumably because there was once a homestead or shieling on the Larach Hill].   High ground connects the open hillsides of Sligrachan Hill with the open hillside above Cnoc Madaidh, during two cycles of forestry activity it remained, intentionally or otherwise, a ‘corridor’ for deer migrating to the open hillside to the north, and back to the more sheltered forestry edge, which is sheltered from the prevailing westerly gales.

 

The public road and forestry access roads did not constitute significant obstructions to deer movement as traffic is light during the day and almost absent at night.   The following photographs, all taken from public or forestry roads, show how the corridor has been obstructed by deer fencing,

 

This fencing is to protect an area of natural regeneration or planting with native trees, but it has only two access points. I am not sure how effective it is for excluding deer, as I have observed deer clear such fencing from the uphill side by an almost standing jump, but it certainly excludes me from whichever direction I approach it.

 

Informal crossing is obviously difficult, but extended lengths of fencing with no robust straining posts implies attempts to cross by climbing over is likely to damage the fence.

 

 

The grazing pressure does seem greater outside the fence but it effectively excludes access by humans. It also makes one wonder whether, if the habitat inside the fence needs to be protected at this stage, how natural the regeneration will be if it will eventually have to survive grazing by deer.   It seems incoherent to try to create an ecological community, that will eventually include deer, by initially excluding them from it!     I seem to recall that such fencing is to be removed, but have not noticed any sign of older fencing around more mature forest planting being removed.

 

Other examples in the same area, probably less than a square kilometre.

Recently created deer fencing, replacing decayed stock fence.

This very new deer fencing replaces a stock fence, it’s not clear why if a stock fence has sufficed for half a century or more. It is not immediately obvious whether it is to keep deer in or out, but it encloses a big area that used to be part of an orienteering map, used for National Competitions.

 

The enclosed area used to be informally called the ‘Park’, and used for seasonal grazing of sheep gathered from the hillside between Glen Finart and Loch Goil, and farmed jointly by farmers from the same family at Sligrachan and Carrick.

Camouflaged fencing, quite deep within recently planted woodland

This fencing excludes access to very closely planted Scots Pine. I am not conversant with its original purpose, but one would imagine it is about time it was removed.  I am not sure why planting has to be so close, but presume it must be so that ‘survival of the fittest’ allows some trees to ‘reach for the sky’ growing straight and thin, with few side branches, while others are shaded out and die off. In the Sitka plantations, such dead and dying trees are not thinned, but fall and further obstruct access.

 

Looking at this hillside, compared with nearby remnants of mature Scots Pine groves [on the sky line], it seems likely that as many as two thirds of the trees will never reach ‘economic’ maturity, and substantial mortality will occur to get a viable crop of similar sized trees. If such a high proportion of trees are going to die or be thinned, one wonders why bother to fence it as beasts are unlikely to do the equivalent amount of damage. There seems no obvious difference between the grazing pressure within and outside the fencing, one would imagine that the economic value of the eventual crop will be similar, inside and outside the fencing.

Note lack of any sign of forestry rides, which used to exist in this area in previous forestry cycles.

I am not sure why this fence was emplaced, but it excludes access directly from the road, but more significantly obstructs access to the road for someone coming off the hill, on a winter’s day in poor light. Circumnavigating it might add a kilometre or more of additional travel.

 

The combination of impenetrable forest and deer fencing could pose a serious hazard for an unwary visitor, descending from Beinn Ruadh via Sligrachan Hill, by increasing the risk of being benighted, injury and exhaustion/exposure. Such obstructions are not shown on a GPS or OS 1:50,000 map.

 

Post script

Soon the poseur, ‘survivalists’, given unwarranted promotion by the media, who have encouraged much of the egregious recreational behavior witnessed today, e.g. campfires, disposable BBQ’s, fragile folding seats, and semi disposable popup tents, will be recommending naïve urban adventurers to carry a bush knife and wire cutters, with their multi tools, folding saws and GPS.

 

‘The leave no sign, do no damage, and pass as if you have never been’ philosophy has been undermined by a marketing operation and commercial imperative to turn outdoor recreation equipment into a mass consumer market at considerable cost to the environment.

 

Between 1965 and 2000, thousands of children journeyed through the area and camped, during expeditions from the formerly numerous outdoor education establishments – they left so little ‘sign’ they might never have existed. A similar thing could be said of the School camps, summer camps for children organized by churches and Scout Groups who used the area from the 1930’s onwards. It is equally true of youngsters currently involved in Duke of Edinburgh Award Expeditions, who are now restricted to Forest Roads and manufactured paths, rather than being ‘impelled’ into an experience of wild countryside.

 

Little wonder visitors may think they can arrive in a car, walk ten steps and have a wilderness experience, but this lack of real connection is fabricated by a progressive removal of possibilities to do anything much more adventurous, than ‘Park & Pitch’.   Already over used and abused sites do not encourage respect, but confirm urban values and an expectation that it is somebody else’s responsibility to tidy them up after use. This is evident at the Duck Bay picnic area.

 

I am persuaded that influences are interactive; distorted media presentations of outdoor experience that are hard to distinguish from marketing, sales of useless fragile outdoor equipment, restriction of access causing concentrated use of ‘honey pot’ sites, destructive behavior by people unused to handling themselves in the countryside and land managers deciding to exclude them from their land.

 

This is re-inforced by the disinclination of the operators of caravan and chalet parks, developed on the site of former camping grounds, to cater for campers at all.  The result is ‘exclusion’ of temporary visitors of all descriptions, with a reduction of ‘visitor experience’ to an urbanized familiarity, against a back drop of hills, forests and lochs.

 

This discourages access to the NP, other than day visits, by people barely able to afford a social rent, or who are saving for a deposit for a first home, or intermittently have to resort to food banks, but favors ‘exclusivity’ for second home owners [a residential caravan apparently costs about £39,000, plus site rental and Council Tax].

 

I feel this is not what a National Park should be all about!

July 14, 2017 Nick Kempe No comments exist
A road to nowhere? How would anyone know that this road led to the former Tarbert Isle campervan area and still existing tent permit area? There are no signs

Following my posts on the unlawful application of the camping byelaws to campervans (see here)  this week I took a look at the Tarbet Isle permit area.   This is one of the areas where the Loch Lomond and Trossachs National Park Authority has refunded campervanners who had purchased permits – an admission that they had done so unlawfully.

The signage – now redundant – only appears when you reach the edge of the so-called permit area

The first thing that strikes you about the area is there is no signage to it (see photo above) from the main road.   If you  are travelling north along the A82 from Tarbet, you might just notice the track up to the left, but there is nothing to tell the anyone who has heard of the byelaws and knows that the Park is trying to force people to stay in permit areas, that you could stay – or have stayed in the case of campervanners – without fear of prosecution.    In fact there is no signage to any of the permit areas along the A82.   While that was a failure in terms of the byelaws, its a welcome failure as if people don’t know where the permit areas are, its almost impossible to stop them from stopping off somewhere else.  Its a failure the Park would be best not trying to remedy, otherwise its likely to waste yet more money on signs, such as that at Tarbet Isle, which then become redundant (left).

At least at Tarbet Isle the former gates across the track have been removed.   Why Forestry Commission Scotland has no gates at Tarbet Isle but has gates and locks them at Forest Drive is a mystery.    Perhaps its to prevent a right of passage being created?   You only have a right under the byelaws to sleep overnight on roads where there is a right of passage.

The former campervan permit area, where you can now once more stay for free, is hardly inspiring, the sort of high quality experience the Park says it wants to promote for visitors, but its ok.  Its big pluses are its flat and being slightly above the road its much quieter than by the lochshores.   There are no views and no facilities and some people might feel a bit vulnerable here.

I suspect most campervanners, like most people, would prefer to stop off by the loch shore even because it is noisier because it has great views and the bumpy shoreline is very interesting.  It feels like you are in a National Park – the campervan permit area could have been almost anywhere.

The map of the permit area (close up above) shows the former campervan permit area by a dotted red line, the wider permit areas in dark green and the flatter part of the permit area in light green.  The path by the sign, marks the boundary, and shosw just how steep and tree covered much of the permit area is.   Why the Park spent lots of money delimiting wider permit areas where it is absolutely impossible to camp I am not sure.   Maybe though this wider area is where people can sleep in hammocks slung between trees without committing an offence so long as they pay £3 for the privilege?

 

Its a good five minute walk through the permit area before you reach anywhere you could possibly consider camping.   That’s not much good for cycle tourers or canoeists, worried about being prosecuted for camping by the road or on the lochshores.  The woodland was lovely in the sun but sloping and covered in vegetation, again unsuitable for camping

There was one obvious camping area, which had been used by campers, and where some kind person – possibly from FCS – had left a couple of logs.   Highly commendable.  There was no obvious source of water though and so to me, while its good the potential for camping up in the woods here is being advertised, this should not be seen as compensation for banning  people from camping on the lochshores.   I am awaiting the breakdown of the Park’s statistics (which show numbers of tents booked on West Loch Lomond but not by permit area) but I suspect the demand for camping here will not be high.

What is the justification for the remaining campervan permit areas?

The LLTNPA and FCS need to explain why they still trying to charge campervans for staying at Forest Drive – indeed they have increased the number of permits for campervans there – while dropping permits at Tarbet Isle.

The LLTNPA also needs to explain why its now saying campervans can stop off in the parking area at the end of the short forest road at Tarbert Isle but to do so without a permit at the similar turning area at Firkin Point is still according to them a criminal offence.

The campervan permit places at Firkin Point are in the no parking area – which raises more legal questions than I care to cover here!

Tarbet Isle provides more evidence, as if more was needed, that the legal basis for the decisions made by LLTNPA staff need to be made public.

July 7, 2017 Nick Halls 1 comment

By Nick Halls,  resident of Ardentinny

Cleared rhododendron Glen Finart                                                                               All photos by the author

This is the third in a sequence of reports (see here) and (here) on the impact of Forestry Commission Scotland practices in the Argyll Forest Park, which forms the south western part of the Loch Lomond and Trossachs National Park.

 

Rhododendron ponticum, an invasive species, was apparently introduced to the area by the Victorians, to provide shelter for game birds. DNA analysis suggests that most if not all invasive bushes originate from the Iberian Peninsula. Rhododendron ponticum seems to be a hybrid species, particularly suited to acidic soils in areas of high humidity.

 

It has been shown to reduce the number of earthworms, birds and plants, but also the regenerative capacity of a site. In fact, where I live, there seems to be no wildlife at all.

Slope from which rhododendron branches from a sequence of cutting campaigns have been cleared and burned, illustrating the lack of regeneration

Eradication of non-native invasive species, Rhododendron ponticum.

Racks of cut rhododendron, left in banks obstructing access, note the regrowth in the background, as it appears that no follow up spraying has taken place.

Wild Park 2020, the National Park’s plan for nature conservation, included measures to eradicate non-native species one of which is:

 

Management to eradicate Rhododendron ponticum, from 50% of the National Forest Estate within the National Park has been put in place and clearance programmes are underway and on schedule for completion

 

Nothing wrong with the objective, its the way its being done which is the problem.   When I asked, I was informed that burning the cuttings was not an option due to the fire hazard to the trees, and chipping would be too expensive. It was asserted racks of branches would soon decay, and in the interim, would harbor wild life. I have seen no evidence of either happening.

This has been described by visitors as a dark impenetrable wet desert.

The racks of recent rhododendron cuttings, overlay two layers from previous campaigns of cuttings, separated by about a decade each. Note the regeneration of rhododendron through the cuttings, making it difficult to spray the regrowth effectively. In another decade, the area will be as bad as ever, but even more impenetrable!

 

Note also the relative sparsity of the surviving trees.  One would have imagined that the rhododendron cuttings could have been burned and stumps exposed to be treated, by spraying with a herbicide.

One can only come to the conclusion that the process is so poorly implemented and ‘quality’ checked, that public money is being wasted year after year, and no consideration at all is given to recreational use of the Forest estate.

The outlook from this area is spectacular.

Before the most recent campaign of cutting I had never explored the area, had no idea how interesting and varied it is, and was inspired to clear paths through obstructions in order to make access possible for neighbors, particularly visiting children.   However, these are just ‘desire lines’ and it is Forestry policy that such informal routes will not be conserved.

 

The linguistics are interesting and bluntly affirm that what the public might ‘desire’ is sacrificial if it inconveniences forestry operations. It treats local residents and visitors with contempt.

 

I no longer accept this order of precedence, not in a National Park and on land held and managed in trust for the public, by a body whose founding objectives included sustaining the rural population and encouraging recreational use if the forest estate.

 

In a country trying to promote active lifestyles, plagued by obesity and heart disease, where children seldom have access to places where they can explore, gain self-confidence and become self-reliant in their own countryside, it makes no sense.

 

It speaks to a lack of coordination of public policy and/or lack of accountability of a public body, both to its original constitutional purpose and the public interest.

 

What needs to happen

 

The Loch Lomond and Trossachs National Park Authority was set up to promote and enable public access, for visitors and local people.  It appears to have  ignored the impact of FCS “conservation practices”, whether these are achieving their objectives and their impact  on the public’s right to enjoy the outdoors.   A new objective should be added to the new draft National Park Partnership Plan, that FCS should to develop new and more effective ways to clear invasive species such as rhododendron and engage with local people and recreational organisations to re-establish access in the Argyll Forest Park.

July 3, 2017 Nick Kempe No comments exist
Are the symbols for the National Outcomes the LLTNPA claim to be delivering useful?

The third and final section of the Loch Lomond and Trossachs National Park Authority Partnership Plan (the official consultation (see here) closes today) is entitled “Rural Development”.  The statutory objective of the National Park is rather different, to promote sustainable use of natural resources and sustainable economic and social development of the area’s communities.  Its quite possible to have rural development which does not achieve either of these aims, whether this is continuation of unsustainable land uses or new development such as the Cononish Goldmine.

 

The LLTNPA’s vision

The Park’s vision for rural development is infused with neo-liberal values and thought processes:

 

“In the National Park businesses and communities thrive and people live and work sustainably in a high quality environment”

 

Implicit in this vision is that development is dependent on business, there is no mention of the role of the public sector despite the fact that Forestry Commission Scotland, a public authority, is the largest landowner in the National Park.   There is no vision at all about what the public sector, including the National Park Authority – whose staff incidentally are paid far more than most people who work in the National Park (a good thing, reasonable pay) – have to play in sustainable rural development.   Significant amounts of research is undertaken in the National Park – for example by the SRUC’s research station in Strathfillan – but this, like other evidence is simply ignored.    I would suggest that any consideration of sustainable economic development that does not put the public sector at the heart of the vision is meaningless, its simply a charter for business.

 

There is no recognition either that the interests of business owners and local communities may not be the same.    So, the LLTNPA’s main focus is on tourism businesses which may deliver good returns to their owners but are dependent – perhaps exploit would be a better word – a low paid workforce who earn so little they cannot afford to live in the National Park.   There is no discussion of what is basically a rentier economy, which is based on the provision of tourist accommodation (all those chalet parks) or the financial subsidies paid for by the public for hydro power which are flowing to the City of London.  Most of the income generated within the area provides no benefit to the National Park or the people who still manage to live there.   In the Cairngorms National Park Authority Plan there was at least implicit recognition of this in the statistics which demonstrated average pay in the Cairngorms National Park was well below the Scottish average.  The LLTNPA plan is devoid of evidence and the only indication that this might be an issue is a reference to the total population and population of working age in the National Park declining.

 

The vision also says nothing about sustainable development.  The vision is of people working IN a high quality environment, which just happens to be there, there is no recognition this natural environment has been moulded by people andthere is NOTHING about sustainable land-use.  This fits with the conservation and land-use section of the plan (see here) which similarly has no vision or plan for how land-use could become more sustainable.  The natural qualities of the National Park are simply there to be used: the  “Park’s unique environment and special qualities provide many opportunities for economic growth and diversification.”     I couldn’t find a single proposal about how land-use or wider economy could be diversified in this section of the plan – its all being left to the private sector, the miracles of the market.

 

The complacency of the LLTNPA and its unwillingness to look at the real issues is staggering:

 

“Overall, our rural economy in the Park is performing well with growth in accommodation, outdoor recreation, infrastructure improvements, and food and drink offering over recent years. We have also seen a notable rise in development activity, particularly in renewables, housing and tourism investment. However, we are still facing significant challenges for the rural economy of the National Park.”

 

If the economy of the Park was really thriving one would expect there to be an increase in population, not a decrease.  There is no proper analysis of what the challenges are or that the economy in the Park is benefitting the few, not the many.

 

The LLTNPA’s priorities

 

The very first action point under Rural Development shows the Park’s true priorities:

 

“Delivery of the key sites and infrastructure in Arrochar, Balloch and Callander, as well as villages identified as Placemaking Priorities identified in LIVE Park, the National Park’s Local Development Plan”.

 

This is parkspeak for the delivery of Flamingo Land at Balloch (see here) and the development of the torpedo site at Arrochar (see here).  Neither has anything to do with sustainable economic development.

 

The other main development priority appears to be hydro schemes – the number of new hydro schemes being a measure of success.  Nowhere in the plan is there any indication of the impacts of such schemes on landscape or river catchments.

 

Almost all the other action points either re-inforce the Park’s development plan, are so vague as to be meaningless or miss the point.

 

Outcome 1 is basically a repeat of the Local Development, which (apart from the Flamingo Land and Torpedo site) is about matters such as enhancing the environment in existing settlements.

 

Outcome 2 is about providing support for business, from improving broadband to provision of workshop space – there is not a proposal in it about how the Park could help businesses based on the National Park’s special qualities (eg timber businesses) or how the LLTNPA could use its purchasing power to assist local businesses (e.g it has purchased shipping containers for toilets rather than commissioning local businesses to provide buildings fitting for the local environment).    The Park says it wants to increase the number of business start up when the reality is that a few businesses are actually increasing their grip on the economy in the National Park particularly in the tourism sector  (see here).

 

Outcome 3 sees the answer to population decline as training young people and getting more affordable housing provision.   Actually, its investment in the economy that creates jobs and the problem in the LLTNPA is that while there has been investment (eg construction of hydro schemes) this has been short-term and generates very few long-term paid jobs.   Requiring a proportion of new housing to be “affordable” will do nothing to address the basic issue.

 

Outcome 4 is about empowerment of local communities.  There is no mention of the Park’s track record on this (when it matters, they have consistently ignored view of local communities (e.g giving the go-ahead for new housing by the LLTNPA HQ in Balloch and ignoring the Strathard Community Council’s concerns about the size of the Loch Chon campsite).   As with the CNPA Partnership Plan there is no mention of supporting those communities to take over control of land, which is the main resource in the National Park, not even in areas where the FCS is the main landowner.  Until our National Parks grapple with Land Reform, claims to be empowering local communities should be taken with a large dose of salt.

 

What needs to be done

 

Here, in a nutshell, is an alternative agenda for rural development in the National Park:

 

  1. The public sector and public sector investment needs to be put at the centre of sustainable rural development but everything the public sector does (from new roads to land-use) should be tailored to the National Park’s conservation and recreational objectives.
  2. There should be no place for large scale tourist developments which destroy the special qualities of the Park (Flamingo Land) and the focus within tourism should be on improving pay and conditions (including living conditions) of those who work in the sector.
  3. The National Park Plan should be driving forward changes in land-use from large scale intensive conifer forestry, sheep farming and hunting to alternative uses.    This could start with the Forestry Estate and the production of a plan to change the way the Argyll Forest Park is managed, so landscape and biodiversity are put first, and new community models of forestry which would create new jobs locally.
June 26, 2017 Nick Kempe 2 comments
Recent clearfell at the Rest and Be Thankful. The conservation section of the draft NPPP fails to address the issues that matter such as the landscape and conservation impacts of industrial forestry practices in the National Park Photo Credit Nick Halls

This post looks at the Conservation and Land Management section of the draft Loch Lomond and Trossachs National Park Partnership Plan (NPPP) which is out for consultation until 3rd July (see here).  It argues that the Outcomes (above) in the draft NPPP are devoid of meaningful content, considers some the reasons for this and outlines some alternative proposals which might go some way to realising the statutory conservation objectives for the National Park.

 

Conservation parkspeak

 

Call me old fashioned but I don’t see why the Loch Lomond and Trossachs National Park needs a vision for conservation – “An internationally renowned landscape where nature, heritage, land and water are valued, managed and enhanced to provide multiple benefits for people and nature” – when it has a statutory is duty a) “to conserve and enhance the natural and cultural heritage of the area” and b) to promote sustainable use of the natural resources of the area.   The statutory duty to my mind is much simpler and clearer, the vision just marketing speak.

 

Indeed, the draft National Park Partnership Plan is far more like a marketing brochure than a serious plan.  This makes submission of meaningful comments very difficult.  Feel good phrases such as “iconic wildlife”,  “haven for nature”, “stunning and varied wildlife”, “vital stocks of natural capital”  are peppered throughout the document.  The reality is rather different, but you need to go to the Strategic Environmental Assessment (SEA) to find this out:

 

  • The Park has 27 designated sites assessed as being in “unfavourable” condition due to grazing pressures
  • Three river and 12 loch waterbodies in the Park still fail to achieve “good” status in line with Water Framework Directive (WFD) objectives.
  • The Park has 25 designated sites assessed as being in “unfavourable” condition due to pressures from Invasive Non-Native Species.

 

In other words progress during the period of the 2012-2017  Plan has not been what one might have expected in a National Park.    Instead of trying to learn from this and set out actions to address the issues, the LLTNPA is trying to bury failures under the table and to conceal its lack of a clear plan with marketing speak.  There is no need to take my word for it, the problems are clearly spelled out in the SEA:

 

The main weakness of the new plan over the extant plan is its lack of specificity combined
with its with its very strategic nature: given limited resources and the framing of the priorities in the
draft plan, it is unclear how intervention will be prioritised. For example, in the extant NPPP [2012-17], waterbody restoration and natural flood management measures are focussed in the Forth and Tay catchments. The new plan does not appear to include any such prioritisation and it is unclear if there will be sufficient resources to deliver the ambitious waterbody restoration measures across all catchments during the plan period. This key weakness is likely to be addressed by using the new NPPP as a discussion document to formalise arrangements and agreements with partner organisations on an individual basis (e.g. using individual partnership agreements as per the extant NPPP). However, it would be preferable if resource availability (and constraint) is articulated clearly in the plan document to help manage expectations;

 

Or, to put it another way, the NPPP outcomes are so “strategic” as to be meaningless, the LLTNPA has failed to consider resource issues and is planning to agree actions in secret with partner bodies once the consultation is over.     It appears that all the failures in accountability which took place with the development of the camping byelaws (developed in 13 secret Board Meetings) will now apply to conservation.

 

Economic interests are being put before conservation

 

This failure in governance – about how plans should be developed – conceals a skewing of the National Park’s conservation objectives towards economic interests (in spite of the duty of the LLTNPA, under the Sandford principle and section 9.6 of the National Park (Scotland) Act to put conservation first).     The best example is the beginning of the conservation section where the LLTNPA outlines the main threats to the “natural environment” the Park faces:

 

  • Impacts on freshwater and marine water bodies from problems such as pollution from surrounding land uses [ e.g algal blooms in Loch Lomond];
  • Unsustainable levels of wild and domesticated grazing animals in some upland and woodland areas, leading to reduced tree cover and the erosion of soils, which are important carbon stores [the 27 sites according to the SEA];
  • The spread of invasive non-native species which displace our rich native wildlife; [we are given no indication of how much progress has been made tackling this over last 5 years]
  • The impacts of climate change leading to warmer, wetter weather patterns and a subsequent
    increase in flood events, major landslides and rapid shifts in natural ecosystems.

 

Omitted from this list are the many threats to the landscape of the National Park which is being destroyed by “developments”:  Flamingo Land, the Cononish Goldmine, transport routes and over 40 hydro schemes with all their associated tracks.

Netting above the A83 in Glen Croe has further trashed visual amenity in the glen while not stopping the problem of landslides.   The problem is the A83 takes the wrong route – almost anywhere else in the world this route would have been tunnelled but not in a Scottish National Park.
Scotgold has permission during its trial at Cononish to store 5000 tonnes of spoil in bags – think what 400,000 tonnes would look like.
The Beinn Ghlas hydro track in Glen Falloch – the whole of Glen Falloch, which runs between the two prime wild land areas in the National Park, has been trashed by hydro tracks which planning staff agreed could be retained (originally they were to be removed) without any reference to the LLTNPA Board.

In the world of parkspeak however all these developments will be classed as successes.  The reason?   One of the measures of success is “Planning & Development:  The percentage of the Park and/or number of sites with landscape mitigation schemes”.    The developments in the photos above have all been “mitigated” by the Park as Planning Authority – an “unmitigated bloody disaster” would be a more accurate description of what the LLTNPA is allowing to happen. 

 

Many of these developments also impact on the ecology of the National Park.  For example, despite all the fine words about water catchment planning and flood prevention there is NO consideration of the impact of the 40 plus hydo schemes being developed in the National Park on flooding (send the water through a pipe and it will descend the hill far more quickly than in a river) or the ecology of rivers.

Beinn Ghlas hydro scheme – the LLTNPA appears uninterested in evaluating the impact of channelling water off the hill through pipes

A more specific example is conservation Priority 11 which says the LLTNPA will “Support for land managers to plan and deliver multiple environmental and social benefits, alongside economic return, through the creation and delivery of Whole Farm and Whole Estate Management Plans”.  This is the same LLTNPA which, while claiming  28% of the National Park is now covered by such plans, has recently refused to make them public on the grounds they are commercially sensitive(see here).  If this is not putting commercial before conservation interests, I am not sure what is.

 

The few specific “conservation” objectives are not about conservation at all

 

The photo that appears on the page on Conservation Outcome 2, Landscape conservation

While there are very few specific conservation objectives in the NPPP, those that do exist are clearly driven by other agendas

 

Conservation Priority 4
Supporting projects that enhance opportunities to enjoy landscapes particularly along major transport routes and around settlements and also that better meet the different travel mode needs of visitors, communities and businesses. Priorities include:
– Implementing a strategically planned and designed upgrade to the A82 between Tarbet and Inverarnan;

-Continuing to review landslip management measures on the A83 at The Rest and Be Thankful.

 

Landscape conservation has been reduced to ensuring that people can enjoy the view from the road.  There is no consideration on the impact of those roads (visual, noise etc):

 

It is important that we ensure that key areas of the Park where people experience the inspiring vistas found here are recognised and enhanced. This means that key transport routes,  such as trunk roads and the West Highland railway line, along with the settlements in the Park, continue to provide good lines of sight to the stunning views of the iconic landscapes found here.

 

Biodiversity in the National Park

 

The new NPPP actually represents a considerable step backwards from Wild Park 2020 (see here), the LLTNPA’s biodiversity action plan, which is not even referred to in the NPPP.    The vision set out in Wild Park (P11), which is about restoring upland and lowland habitats, enriching food chains (to increase numbers of top predators) woodland re-structuring etc, is worth reading – a far clearer and coherent vision than in the NPPP.  That should have been the NPPP starting point.

 

Wild Park  contained 90 specific actions, which were due to be reviewed in 2017 – “the Delivery and Monitoring Group will undertake a mid-term review in 2017 of progress overall on the projects and programmes in Wild Park 2020” .  There is no mention in the NPPP about what has happened to that when it should have been central to developing the new plan.   Part of the problem is the LLTNPA has taken very little interest in conservation over the last three years – there are hardly any papers to the Board on conservation issues  as all its focus and the Park’s resources have been devoted to camping management.

 

The weakness in Wild Park was that while it included many excellent projects, these were mostly limited to small geographical areas and many were located on land owned by NGOs (eg a significant proportion of all the projects were located on NTS land at Ben Lomond and the Woodland Trust property in Glen Finglas).   There was nothing on a landscape scale and very few contributions from Forestry Commission Scotland, by far the largest landowner in the National Park.   The draft NPPP claims  (under conservation outcome 1) to want to see conservation on a landscape scale but contains no proposals about how to do this apart from setting up a network of partnerships.   This begs the question of why these partnerships will now work when we know over the last 15 years similar “partnerships” have failed to address the main land management issues which affect landscape scale conservation in the National Park, overgrazing and blanket conifer afforestation.

 

What needs to happen – biodiversity

 

First, the LLTNPA needs to have some ambition.    On a landscape scale this should include a commitment to a significant increase increase in the proportion of forestry in the National Park which is managed in more sustainable ways.   The SEA describes this as “there is an opportunity and interest in increasing the amount of woodland under continuous cover forestry (CCF) systems. This would reduce the amount of clear fell and associated soil erosion and landscape impacts”.  So, instead of failing to mention the Argyll Forest Park, why is the LLTNPA not pressing the FCS to change the way it manages forestry there?      How about aiming to convert 50% of that forest to continuous cover forestry systems over the next 10 years?  

 

And on a species level, there is no mention of beavers in either the NPPP or SEA.   Amazing the lack of join up:

Why is FCS building artificial dams when beavers could do the same job?

Wild Park described one indicator of success in 25 years time would be that “The Tay catchment beaver population has expanded into the National Park at Loch Earn and Glen Dochart and is managed sympathetically to prevent damage to fisheries and forestry production, whilst also providing a significant new attraction to tourists and habitat benefits such as coppicing and pond creation in acceptable locations.”   The LLTNPA should bring that forward and actively support beaver re-introduction projects now.

 

Second, there needs to be some far more specific plans (which the Park should have consulted on as part of the NPPP to guage public support) which are both geographical and theme based.  Here are some examples:

 

  • So, what exactly is the plan for the Great Trossachs Forest, now Scotland’s largest National Nature Reserve, which is mainly owned by NGOs?  (You would have no idea from the NPPP).
  • How is the LLNPA going to reduce overgrazing?
  • What about working to extend the Caledonian pine forest remnants in Glen Falloch (which would also hide some of the landscape scars created by hydro tracks)?
  • What does the LLTNPA intend to do to address the widespread persecution of species such as foxes in the National Park?
  • What can the National Park do to address the collapse of fish stocks in certain lochs or the threats to species such as arctic charr (whose population in Loch Earn is under threat from vendace).

 

I hope that people and organisations responding to the consultation will add to this list and demand that the LLTNPA comes up with a proper plan for the next five years and argue for the resources necessary to deliver such objectives.

 

What needs to happen – landscape

 

First, the LLTNPA needs to start putting landscape before development and state this clearly in the plan.    There should be no more goldmines, large tourist developments (whether Flamingo Land or on the torpedo site at Arrochar) and improvements to transport infrastructure (which are needed) should not be at the expense of the landscape.   Tunnelling the A82 along Loch Lomond – which has been discounted by Transport Scotland as too costly – should be put back on the agenda.

Powerlines at northern end Loch Lomond dominate much of the landscape of what is supposed to be a world class walk, the West Highland Way

Second, I would like to see the LLTNPA have a bit of ambition and make an explicit commitment to restoring  historic damage to landscapes.   What about burying powerlines as is happening in English National Parks (there is one small initiative at present in the LLTNP)?   How about restoring damage to the two wild land areas on either side of Glen Falloch, particularly the old hydro infrastructure south of Ben Lui, the largest area of wild land in the National Park?

Alt nan Caoran Hydro intake south of Ben Lui and Ben Oss – you can just see pipeline above centre of dam

The LLTNPA Board should also commit to a complete review of how it has managed the impact – “mitigated” – the construction of hydro schemes, engaging the people and organisations who have an interest in this.   The big issue here is the hydro construction tracks, which the LLTNPA now allows to remain in place, and which have had a massive deleterious affect on the more open landscapes in the National Park.   The LLTNPA’s starting point in the new NPPP is that there should be a presumption against any new tracks in the uplands and therefore that all hydro construction tracks should be removed in future.  There should be a review of the tracks which have been agreed over the last five years and a plan developed on how these could be removed (the hydro scheme owners, many of whom are based in the city, are not short of  cash and could afford to do this – that would be a demonstration of real partnership working).

 

Finally, as part of any plan to restructure conifer forests in the National Park, the LLTNPA also needs to develop new landscape standards for Forestry which should include matters such as track construction and felling.   There should be a presumption against clearfell.

 

What needs to happen – resources

 

Just like the Cairngorms NPPP, the LLTNPA NPPP makes no mention of resource issues.  Instead, the underlying assumption behind the plan is neo-liberal.  The state should not provide – in this case the National Park cannot expect any further resources – and the priority of government is to enable business to do business, which (according to the theory) will all some  benefits to trickle down to the National Park.

 

This is totally wrong.  We need a proper plan which sets out what needs to be done, how much this will cost and how this will be funded.    The Scottish Government could of course and probably would say “no” but things are changing politically and proper financing of conservation (and well paid rural jobs) are key to the third part of the NPPP which is about rural development.

June 24, 2017 Nick Halls 1 comment

Gross, poorly managed, temporary quarry on Forestry road at head of Glen Finart. NB apparently no regard for H&S or Mines & Quarry Legislation.  All photos, save one, by author

By Nick Halls

Following the post on the destruction of a core path and right of way in the Loch Lomond and Trossachs National Park (see here) I thought a bit of wider background, based on experience, of how the area has been managed over the last 50 years might be relevant.

 

I arrived in Cowal in 1969, and worked as an outdoor education teacher, at Benmore and Ardentinny Outdoor Education Centres. I am now retired but remain a resident of Ardentinny.

 

During work and leisure, I wandered throughout the area, looking for attractive places and interesting geomorphology. As an aspect of work and personal interest I became fascinated by the detail of the environment; geographical, biological, historical and recreational.

Industrial forestry and recent clearfell dominates Glen Croe – Photo credit Nick Kemp

I was quite shocked at the way significant historical features were trashed by industrial forestry practice; fermetouns, sheilings, charcoal burners platforms, water mills, bloomeries, shearing pens, transhumance routes etc. In fact, nearly all the evidence of life in the past. Anything that impeded forestry operations seemed to be sacrificial.

 

 

Eviction and emigration has been a continuous process from before 1745 up to the present day. Cowal was not a depopulated wilderness even in the recent the past, it has been created by socio-economic forces which still operate, current expressions of which discourage even visitors.

 

The area exemplifies the disappearance species due to destruction of habitat – in this case homo sapiens.

 

I used the locality for teaching map reading and how to navigate in all types of terrain. The area is particularly suitable, as wayfinding in restricted visibility, in forests, at night and in bad weather, depends on interpreting fine contour detail, slope aspect, drainage patterns and detailed route finding. It is particularly important for orienteering which takes place in woodland, because of the restricted visibility.

 

Access to and through the actual woodland and out onto open hillside, and back through woodland important. The techniques of wayfinding are not only applicable to open hills.

Impenetrable windblown, which has accumulated over decades.

I arrived after the great storms of the late 1960’s, when vast areas of wind blow occurred, to both commercial timber and natural woodland, destroying enclosures and blocking access to beauty spots.  Less violent but exceptional storms have recurred frequently since, contributing to the damage, mature woodland being particularly vulnerable. Enclosures, watercourses, paths are consequently very at risk of damage and obstruction.

Debris left, immediately behind private garden, left after campaign of Rhodo clearance

I experienced at least two full forestry cycles, with replanting of clear fell areas, almost inaccessible due to stumps, waste timber and branches, followed by close planted trees maturing into at first impenetrable saplings then into more mature young trees, and eventually into woodlands reaching ‘economic’ maturity. During the whole cycle the land remains virtually inaccessible, commonly made worse by the spread of non-native species such as Rhododendron, which invade wherever there is sufficient light filtering through the canopy.

Showing the dense patchwork of cycle of forestry operations all dense and impenetrable

I took all this for granted, the changing patch work of forestry operations, as camping sites, pleasant, natural traditional routes, significant historical sites used for environmental studies, areas of mature woodland mapped for orienteering courses were trashed, often with little if any consultation with the local community. None at all with representative organisations of recreational activities.

 

Catering for recreation seemed not to matter at all, and visitors seemed to be treated as an inconvenient nuisance.

Water pouring through garden from forested slopes above Ardentinny

During the cycles water courses were clogged with trees and branches, avoidable local floods did damage to property and public infrastructure and the locality became less and less attractive to visitors. I looked on with dismay.

I slowly came to the conclusion that it should not be happening, and that the Forestry Estate, which is held in trust for the people, but managed by Forestry Commission Scotland (FCS), is being appallingly mismanaged.

 

Visits to Regional and National Parks throughout Western Europe reinforced the impression that Scotland’s rural environment is poorly managed, but the commercial forestry practice is destroying the ‘amenity’ and potential recreational value of a tremendously valuable ‘public asset’ in a fashion that is largely avoided elsewhere.

 

Other countries factor in scenic quality, economic return, retaining indigenous industry and employment, catering for recreation, in an environmentally sensitive way, into forestry practice. The imperative across Europe seems to be to retain rural communities and slow down emigration to cities, and as far as possible encourage people to return.

 

Scotland’s forests seem to be managed in a way inspired solely by financial considerations, by ‘philistines’ who put every other consideration in second place. I believe the current culture of Forestry practice fundamentally betrays the public interest, in numerous ways.

 

Practically everybody I know who has lived in the area for a similar length of time shares my opinion. Like mine, their children have left, and more and more property used as holiday or second homes, or for retirement.

 

FCS and local communities

 

Over recent decades I have tried to engage with ‘here today’ gone tomorrow foresters, all of whom seemed to be decent guys, but who seemed powerless, ‘mouth pieces’ of a distant and unresponsive, autocratic, senior management. The internal culture appeared to be command and control orientated, and quite abusive of more junior personnel.

 

A practice developed of moving staff around on a migratory posting basis, and employing transitory sub-contractors. There is now no connection between the community and Forestry workers or managers. I was told some decades ago that this change was initiated to prevent Forestry personnel going ‘Bush’ and identifying more closely with the community than the employer.

 

When the Cowal Office closed, management moved to Aberfoyle, and local connections weakened even further. Clerical support staff lost jobs. Now occasionally, the first point of contact does not even know where Glen Finart is!  

 

The state of the forest floor, throughout areas of mature woodland.

When I arrived in the 1960’s, forestry personnel were semi-permanent, and members of the local community, this included forester, ranger/game keeper, fellers and extractors, and a permanent general labour force, employed ditching, maintaining forest roads, brashing, planting etc. Most people occupying the former Ardentinny Forestry village worked in the woods. The community were pretty well informed and I knew personnel as friends. Forestry operations were the background to everyone’s lives. It was done by them not to them!

 

Now as a consequence of ‘outsourcing’, ‘right to buy’ and retirement/death of former forestry workers, most properties are occupied by incoming residents with no connection to land management. More recent incoming residents accept current Forestry practice as a given, it is just a ‘back drop’. In some cases, they are even tentative about entering the woods, unless there is a way marked path!

 

When I propose to engage with the forestry about an issue of concern to my neighbours, the uniform response has been that they want nothing to do with the Forestry, because their experience of engagement has been so frustrating and unsatisfactory.

 

As former professional people themselves, they resent being treated with ‘top down’ patronising, disrespect, by unaccountable public servants. They are particularly irritated by having to deal with very personable young staff, who seem to be no more than ‘messengers’ from a higher command.  They tend to prefer to deal with issues themselves hoping that whatever is done will remain ‘out of sight and out of mind’, which is usually the case.

 

There seems to be a disconnect between what is written, information provided verbally, and what is happening on the ground.   From the perspective of somebody who has been resident in the area for decades there seems to be no coherent, long term consistency in practice, or local quality control of operations. Everything seems to be done at the lowest cost and poorest standard

Debris left after felling diseased larch trees, obstructing access to mature woodland.

The FCS and NP ‘blurb’ pays lip service to access and conservation, but the reality is an increasingly industrialised, impenetrable wasteland, with depleted bio diversity and loss of wildlife, due to habitat loss.

 

Within a National Park, and The Argyll Forest Park, created in the 1930’s from land bequeathed to the people of Glasgow as a place for recreation and escape from industry and unhealthy city life, one would like to think facilities for recreation might have a special place. Especially in the context of lack of activity among children and increasing obesity throughout the adult population. Such a facility is as much needed today as it has ever been.

 

Cowal and the National Park

Run of the river hydro works in forest estate, at headwaters of River Finart. The usual LLTNPA requirement that all pipelines should be buried has simply been ignored.

The Loch Lomond and Trossachs National Park Authority appears to take almost no interest in what goes on in Cowal, but treats the Argyll Forest Park as an enormous industrial site, where Forestry Commission Scotland can do what it likes.

 

The contrast between how FCS is managing forest in the Argyll Forest Park and elsewhere, for example the east shore of Loch Lomond, is striking, though I am not sure their consultation with local communities is better in other places.

 

The LLTNPA needs to call for FCS to develop an alternative vision for the Argyll Forest Park, one that puts people, whether residents or visitors, the landscape and wildlife before industrial scale forestry.  The draft National Park Partnership Plan, currently out for consultation, which fails to refer to the Argyll Forest Park, would be a good place to start.

June 20, 2017 Nick Kempe 1 comment

Following the downpour at Cairngorm (see here and left) the photo above taken last week shows the impact of such flood events.  While Natural Retreats and HIE’s recent mismanagement of Cairngorm has contributed to this, the problems go back much longer and the large car parks for example contribute to the rate that water runs off the hill.  The motor car (which most people including this writer rely on for transport much of the time) has been central to the unsustainable development of Cairngorm ever since the ski road was constructed.  As part of the Cairngorm masterplan (see here) Natural Retreats included a section on transport.   The analysis and proposals in it are far more sensible than the Ptarmigan re-development or installation of snowflex artificial ski slopes above the Coire Cas carpark but do they offer a way forward?

 

Natural Retreats’s brief summary of the transport situation at Cairngorm, if you read past the marketing speak, is pretty damning:

Extract from FOI

Poor public transport, no imaginative solutions such as those used in the Alps (where school buses are used to transport people up valleys in the holidays), no bike or ski racks, a lack of path connections.   So what are Natural Retreats’ solutions?

While there are some good ideas here the package has a whiff of self-interest.    The short-term proposals should be easy to do, as they are all minor improvements, but could be read as a smokescreen for implementing parking charges at Cairngorm (which is one of HIE’s objectives).  There is no information about how they, or more importantly the medium and long term proposals, could be financed despite the owner of Natural Retreats, David Michael Gorton, being extraordinarily rich – but then the way his companies are operating currently at Cairngorm is to take money out of the area rather than invest in it.  Its not surprising therefore that the proposals such as hybrid buses, which the owner of Natural Retreats could afford to pay for now, have been scheduled as “Medium to Long Term”.   There is no indication that he is going to invest anything that does not guarantee large immediate returns (like car park charges) or will not rely on the public sector to pay for everything while NR take the profit.

 

The proposals have been developed without any consultation.  Under the Glenmore and Cairngorm Strategy, approved last year, Natural Retreats were supposed to be part of a Cairngorm & Glenmore Transport Working Group involving Highland Council, HITRANS, Forest Enterprise Scotland and the Cairngorms National Park Authority.  Its not even clear whether this group has ever met let alone been and its telling that Natural Retreat’s refer to a slightly different group of stakeholders in the transport section of the masterplan  including “the Glenmore Masterplan” (is this the same as the Cairngorm and Glenmore Strategy?), the CNPA, Cairngorms Connected and  Active Cairngorms.  In other words HIE’s and NR’s proposals don’t appear joined up with the plan developed by the CNPA.    There are a couple of specific examples of this.

 

NR’s proposals make no reference to the action point in the Glenmore Strategy that there should be a  “Feasibility study for improved public transport and park and ride approach”.    So, does Natural Retreats support a feasibility study or not and will it contribute to the cost?

 

There is also no reference to the proposal for a new cycle route up to Cairngorm, the cycle link, as set out in the map below:

On the other hand, HIE and NR have plucked out of a hat a new proposal for a “tourism train like that seen at Chamonix or York”.  I am a fan of the Chamonix train  – its free if you are staying in the valley – but to treat a back of a fag packet idea as a proposal without any consultation or working with other people on how it will be financed tells you everything you need to know about how NR and HIE operate.

 

What needs to happen

 

While some of NR’s proposals could support the objective of the Glenmore Strategy that, there should be “Improvements to transport and access infrastructure will increase public transport and non-motorised access to the area from Aviemore and beyond; and walking and cycling within the area”, they are unlikely to “Make a significant change in the way people access the area to increase the proportion of non-car access” because of the way they have been “developed”.   Natural Retreats needs to start consulting the local community, business, visitors, conservation organisations and other stakeholders and to support structures set up in the National Park before it does anything else.

June 19, 2017 Nick Halls 3 comments

 By Nick Halls (resident of Ardentinny)

This is the first of a sequence of reports focused on access around Glen Finart in the Argyll Forest Park, which is part of the Loch Lomond and Trossachs National Park.

The path was a traditional route, and Right of Way, that has existed since at least the 1940’s, but possibly much longer.

An indication of the permanence and investment in the route, possibly dating back to when the bay was a camp used for training Beach Commandos, and subsequently by Forestry Workers recruited from the unemployed of Glasgow.

This can hardly be regarded as a dispensible‘desire line’ that does not need to be preserved if it causes inconvenience to felling operations.

The track is signposted, part of the core path network, and is the route from the bay carpark to Loch Goil, following the shore of Loch Long. It joins two communities.

 

The pedestrian sections  are scenic, and relatively non-strenuous. It is a popular and historically important ‘transhumance’ route, that used to connect farms and holdings, now disappeared due to forestry operations.

The path ascends through pleasant natural woodland, and is well established but not over engineered and badly aligned as is the current practice. It has the gradient of a route that was used for carrying goods and probably used by pack animals.

Then this! Despite years of use and in an area of heavy rain, with almost no maintenance, it shows almost no sign of erosion. The resilience of the path testifies to the poor understanding of those responsible for aligning and constructing recreational paths today.

Leading to this. Over the years, I have cleared the path on a number of occasions of wind blow, minor obstructions arising from the growth of commercial forestry, and encroaching Rhododendron, but clearing this would be a monumental task.

 

And, to add insult to injury, this!

 

Needless to remark nothing has been done to clear the path, presumably its open for access, but users will need to clear the route and re-establish a viable track, as if it were merely a ‘desire line’.

 

There is no indication that the path will be reinstated, just that access will be restored, if one can find one’s way.

The obliterated path runs up the shoulder between the two burns above the end northern end of the beach.

The scenic impact of the clearfell, with the progressive degradation of the landscape quality by the patchwork of ‘industrial’ forestry operations, that will continue as the cycle progresses. Scenes like this are very unusual in other Western European National Parks.

 

The Loch Lomond and Trossachs National Park Authority, as Access Authority, at the very least needs to ensure Forestry Commission Scotland restores this path.

June 18, 2017 Nick Kempe No comments exist
Coilessan Glen. Glen Douglas nuclear weapons store is scar in distance on far side Loch Long.

Back in March, hillwalker Rod McLeod, wrote an excellent report (see here) on Walk Highland about new track work he came across in Coilessan Glen,  west of Loch Long, in the Loch Lomond and Trossachs National Park.   The glen is an important recreational route, being taken by the Cowal Way, and has recently become even more popular since Cnoc an Coinnich, the hill south of the Brack, was promoted to Corbett status.

 

Forestry Commission Scotland owns the land and also promote a cycle ride here:

You might think therefore FCS would have an interest in improving the landscape and amenity in the area.  The Argyll Forest Park is the oldest in Britain, created in 1935 and in its blurb the FCS exhort people to  “Discover this beautiful, tree-cloaked corner of Scotland to walk, ride and relax in Britain’s oldest forest park.”

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The upgraded track below the “Dukes Path”, the Coilessan burn is just beyond the Duke of Edinburgh Group centre right and the Brack behind

Instead  FCS has upgraded part of the existing track network in Coilessan Glen by dumping aggregate on the earlier track.  There is no planning application on the Loch Lomond and National Park Planning portal and the LINK Hill track group (see here) was not aware of the track through the prior notification system.   While its possible the LINK hill track group missed the notification, its also possible that because this was an “upgrade” to an existing track the Loch Lomond and Trossachs National Park Authority did not have to be notified (I will try and find out).

A sizeable new quarry has been created to source the new material for the track (the boulders in the middle ground are large) and gives some idea of how much aggregrate has been dumped on top of the existing tracks.  In my view this should have required planning permission in the National Park.

The quality of the finishing – there was no evidence that machines are still  on site or that the work is not regarded as complete – is extremely poor.  It might be more accurate to say non-existent in places.   Its does not appear likely that the FCS will try and extract trees up this corner so what is the argument for leaving it like this, apart from cost?   This should not be acceptable in a National Park, whatever the commercial imperatives to extract timber.

The Dukes path looking north. The turn off to lower track is just beyond the transit, while that to the upper track is just behind the viewer.

The Dukes Path has been spared the upgrading work so far and gives an idea of what the tracks looked like previously.   The silt trap is to catch the silt that is being washed down from the new track just above.   The crushed schist forms a very fine material which is likely to continue to wash out of the new track surface for some time.

The Dukes path and Loch Long from start of the track as it heads up the glen

The lack of care for the landscape at the micro level is demonstrated not just by the abandoned pipe and decapitated cone but by the spoil heap at the side of the “new” track.   The lack of care at the landscape level is demonstrated by the conifer replanting either side of the Dukes Path.   This was one of the few sections of the Dukes Path where the walker is not hemmed in by forest on either side but but instead of using the felling as an opportunity to create a more diverse landscape, the replanting will have obscured the view completely in another 20 years.

Section of Cat Craigs track north of Coilessan which offers no views.

This photo also illustrates difference between repairing a track surface compared to the upgrading work at Coilessan (below). The bare bank on left appears to date from original construction.

The history of a lack of care here is also demonstrated by the spoil to the left of the new track which has partly revegetated.  It may date from earlier tree felling.  Material from the new track will erode down the hillside.

The surface of the track is now firmer than two months ago, when Rod McLeod took his photos, and appears to have consolidated to an extent.   I passed the Duke of Edinburgh Group shortly after taking this photo and asked them to rate the track and the walking experience.  “Terrible” was the response.

Is this the way we would be treating what was a fine section of burn?

Compare the size of the former track on left with the upgraded one.  Are bends this size really necessary?

In order to widen the track, further excavation of banks and ditches has been undertaken in places.   The vegetated area bottom right represents former bank, a section behind appears to have been scraped bank behind that vegetated.   I could see not evidence that any attempt had been made to store and replace turf over excavated areas, even in places such as this where there are native trees behind which one would hope will be left in place during the felling.   The LLTNPA rightly requires vegetation to be restored in hydro track construction – even if it does not happen much of the time – and similar standards should be applied to forest track construction.

 

 

Will FCS do anything to improve this once the trees are extracted?

They have done very little to improve this section where felling is complete and indeed appears to have pre-dated the track.  So, if the new track was not need for felling (top left) why is it needed now? Forest tracks have become larger and larger to accommodate bigger, heavier vehicles – just as in hydro track construction.  The bigger the machines we use to work in the countryside, the bigger the tracks and the impact on landscape.

The contrast between the footpath construction in the upper part of the Glen and the track are quite stark.  How can the FCS apply such difference standards?  My 1980 1:50,000 map shows just a footpath, no track, up the Glen but now there is only a path in the upper part.  A relief.

 

You can hardly see this plastic culvert under the path.

The care taken with the path contrast with the final section of the new track which finishes not far above.

 

The felling and replanting in background (slopes of Brack) all took place without this track “upgrade” demonstrating that there was no need for works of anything like the extent of those that have been undertaken.

Looking down Coilessan Glen – footpath in trees on right

How does this compare with the FCS blurb:   “Ardgartan (meaning the High Garden in Gaelic) is at the heart of an area of vast natural beauty. The forest of Sitka and Norway spruce is an ideal habitat for red squirrel, roe deer, buzzards and owls. Mixed woodland along the many small rivers and burns is home to otters, kingfishers and bats.”

Lower sections of Coilessan Glen track from the Brack, Long Long behind

Even in the dense part of the forest, the upgraded track is visible from afar.

What needs to happen

The FCS needs to apply consistent standards of practice and up its game in our National Parks.  In places, such as on east Loch Lomond, its doing some fantastic work to remedy past mistakes, in others, like here, it appears nothing has changed.

 

The LLTNPA meantime needs to start focussing on stopping any further destruction of landscape quality in the National Park through track construction, whether hydro schemes or forestry.    In my view landscape protection and enhancement should be the  number one priority in the new National Park partnership plan – instead of visitor management.   Its not visitors that are destroying the landscape – their impacts are temporary – but how the land is managed.  If the LLTNPA does not act, the very reason why people visit the National Park will disappear.

 

The LLTNPA and FCS need to start working together on these issues and start engaging the public about the quality of the “visitor experience” in conifer forests and how this might be improved.

June 5, 2017 Nick Halls 4 comments

By Nick Halls, resident of Ardentinny

The LLA has given extensive coverage to the impact of the byelaws on Loch Lomond in its annual review available online (http://lochlomondassociation.co.uk/LLA17WEB%20-%20Rev1.pdf)

The changing landscape of the National Park

 

I monitor the evolution of the Bye Laws and the incoherent manner of the implementation, by means of observation, talking to campers, visiting designated sites, reports contributed by ‘Parkswatchscotland’, and articles in magazines of Representative bodies of the physical activities in which I engage, which include camping associated with watersports and terrestrial activities.

 

I supported the creation of a National Park and worked to have Argyll Forest Park included.  I have lived in the area of the LL&T National Park since 1969 and experienced nearly half a century of change, much of which has degraded the environment, depopulated communities of young people, reduced indigenous economic activity and local job opportunities. Not all of which lies at the door of the NP Authority, but it has done little to either slow or reverse the processes, despite the objectives of the NP. In fact, the NP Authority seems to reinforce the destructive impacts from which I imagined it would protect the area.

 

I observe daily the destructive impacts of motorists, near roadside camping, day visitors and egregious behavior of residents. I live amongst the land management practices of farmers, estates and Forestry Commission Scotland(FCS) and observe the degradation of the scenic quality of the National Park with dismay.

Conifer afforestation cutting off access to the hills and taking over former habitations that once provided places to camp – photo Nick Kempe
Deer fence and gate, Stob an Fhainne, north of Loch Arklet    Photo Nick Kempe

I have also noted the restriction of pleasurable free access, arising reversion of farmland to scrub and the ‘clear fell’ practices of FCS, encroachment of invasive non-native species, and enclosures designed to exclude deer. The hills are almost inaccessible other than by over used ‘popular’ routes – creating obvious landscape scars.

 

 

 

I am an ‘immigrant’ to the area but note with concern the progressive emigration of the indigenous population, for education, employment and improved life chances. My son who attended Dunoon Grammar, has only one or two school friends left in the area – he is now working in Canada. The indigenous population is progressively concentrated in suburban localities, while much of the more desirable property is used as either second or holiday homes or occupied by elderly retired incomers.

 

I believed naively the creation of a National Park would mitigate the damaging impacts arising from residents, land managers and visitors. I have been profoundly disappointed.

 

I have concluded the Governance of the National Park Board exemplifies the manner in which established vested interests, that actually have their ‘hands on the levers of power’ in Scotland, operate to secure influence by attaining appointments on the Boards of arms-length government agencies, that purport to serve the wider public interest, and then betray ‘people’s’ trust by subverting them in their own interest.

 

The eradication of space for camping from the National Park

 

It seems incredible that charging for camping, and by extension access, for a legal recreational activity in a National Park could ever have received endorsement by an SNP Minister of the Scottish Government. It discredits the very existence of the Scottish Parliament – and devalues the legislation it passes.   Justifications presented in support of Bye Laws were flimsy at best, but could be presented as blatant misrepresentation to secure a predetermined outcome.

 

Provision for any sort of camping has been eradicated from the area progressively from the time I first arrived in 1969 – as camping sites evolved into first caravan parks then chalet developments – both much more intrusive than temporary camping. As confirmed by reference to OS and Bartholomew Tourist maps published prior to 1989.

Ribbon chalet/caravan development Ardgoil with conifer afforestation blocking access to hillside above – Photo Nick Kempe

These concentrated seasonal residential eyesores impose more pressure on public infrastructure, particularly sewerage and waste disposal, than any number of transient campers. They also degrade the natural qualities of the NP by a progressive urbanization, and pollute the aquatic environment surreptitiously – the shores of Loch Long, Loch Goil & Loch Lomond reveal plenty of evidence – fly tipping, cotton buds, toilet paper & sanitary towels are not dropped by shipping!

The enclosure of Loch Shores – Loch Lubnaig Photo Nick Kempe

 

 

Significantly, under current legislative conditions, land that was once accessible has been converted into curtilage by close spaced semi-permanent temporary residences – a surreptitious usurping of what was once a ‘common good’ into exclusive compounds.

 

 

The architecture of these developments contrast with the vernacular building style, stimulating images of beach front caravan sites of a coastal resort or over-crowded chalet developments in an alpine resort. They fundamentally erode the integrity of the ‘uniquely  Scottish’ nature of the Loch Lomond and Trossachs, so admired by artists of the 19th and 20th Century.

Painting of Ben Lomond from shore at Balloch, Hunterian Gallery, Glasgow Uni – a great illustration of the philistine destruction implied by Flamingoland

 

Overgrown former entrance Suie Field – photo Nick Kempe

When I first arrived ‘wild’ camping was easy, but progressively every spit and exploitable piece of lower land has been either privatized, trashed by industrial forestry practice or over grown by non-native invasive species, such as Japanese Knot weed, Rhododendron, not to mention windfall, bracken & scrub.

 

A contributing factor has been decline in cattle & sheep farming, so formerly grazed areas are now overgrown. Suie Field and Cuilag exemplifies this feature, where the residual preferred camping options are now on the shingle beach.

 

The current situation is that there are very few accessible spaces to camp, and those that remain are intensively used by day visitors and campers. Progressive ‘privatization’ of accessible spaces and increased use of private cars for short visits to the NP have concentrated use, but the services to accommodate the use have not been provided.

 

All of this has been made explicit by numerous reports, press comment and user groups. It is not a recent ‘discovery’, it is as plain as the ever-lengthening noses on the faces of spokesmen for the NP Authority.

The bins originally proposed for the north Loch Venachar car parks included recycling facilities but LLTNPA staff cut bin provision and toilets from the original plans contained in the 5 Lochs Visitor Management Plan Photo Nick Kempe

Many former informal sites have been converted into car parks/picnic sites – in favour of motorist and day visitors, at many of them camping is frowned upon. This exemplifies considerable public investment for one category of visitors at the expense of low cost provision for another. The necessary infrastructure for such concentrated use by day visitors has not been provided, such as bins, garbage disposal and toilets. There is no coherent provision to accommodate the requirements of visitors of any sort.

 

North Loch Venachar, where informal campsites were proposed just 5 years ago in 2012 were redesigned to make camping difficult before the camping byelaws banned camping here completely and instead there are permit places in a muddy field on the other side of the road. Photo Nick Kempe

It escapes me as to why picnic tables proliferate, while being less than essential, while nice camping spots are eradicated. What ideology of visitor management validates this preference?

 

Evidence indicates campers are to be progressively driven from the Camping Management Zones and LL & T NP more generally.

 

The real problems faced by the National Park

Fly tipping of garden and other waste at Cuilag – unlikely to have been done by visitors – photo credit Nick Halls

The actual problems the NP has to confront are not ‘visitors’ but egregious land management practice, rural decay and the reversion of uneconomic farmland to marsh and scrub and fly tipping by residents. This ignores the vast tracks of land rendered inaccessible by industrial forestry practice, within which were farm towns with improved walled enclosures, charcoal burners platforms & hut platforms – reasonably drained and near water. All of which used to provide opportunities for camping.

 

This destruction of amenity is substantiated by pictorial evidence supporting reports – but to designate this sort of terrain as desirable camping locations, and charge for using it, is incomprehensible. There must be issues arising from Trades Description and Fraud legislation.

 

I cannot understand why Scottish Sports Association has not put pressure on both Sport Scotland and Ministers to review the operation of the Boards of both NPAs? The lack of consultation with representative bodies for sports and recreational activities is itself a disgrace, [except sporting estates] but the complete indifference to representations from bodies of all categories of users of the NP’s in preference to a spineless subservience to the interests of landowners/managers and influential residents surely cannot be tolerated any longer.   Particularly so, as private interests seem to be obscured by the practice of holding unrecorded ‘pre-agenda’ meetings to ensure outcomes of subsequent Public Meetings, during which interests of Board Members are not declared or recorded.

The newly “restored” hydro track to the top of the Eagle Falls, Glen Falloch. The original planning permission by the Board required the track to be removed but this was overturned by staff

Specific concerns arise in the case of hydro works in Glen Falloch, unrestricted construction of intrusive estate infrastructure on wild land, appallingly unaesthetic commercial forestry practice, and to top it all the, proposals for ‘Flamingo land’, as if a Scottish National Park is the equivalent of Center Parks or a Funfair, or in the case of Lomond Shores, Blackpool!

The LLTNPA want to develop the shoreline on right into Flamingo Land, Ben Lomond left – photo credit Nick Halls

It makes one wonder if the Board/Authority can distinguish between a Regional Park recovered from an industrial wasteland in the midst of a conurbation and conserving an iconic area of wild land, the history of which underpins the Scottish national identity.

 

I note the CV of James Stuart, it will be of interest to see whether he is just another ‘safe pair of hands’ appointed to protect vested interest, or whether he can change the culture of the LL & T NP Board. It will also be interesting to see whether the new councillors serving the constituencies within the NP boundaries, will treat the NPA as just another local authority and a vehicle for promoting their electoral interests.
Whatever emerges I fear it will not enhance the reputation of NP’s in Scotland, or enhance the environmental quality of the land for which the NP Board have planning responsibility. It will demonstrate how Scotland is ‘actually’ governed, and how little real concern exists for a ‘Fairer and more Equal’ Scottish Society.

 

Attitudes of Park staff

 

Recently, I was informed by a Ranger that the bye laws were necessary to exclude ‘travellers’ from the NP [by which I assume he meant Tinkers/Gypsies] who annually made a mess of camping places – to co-opt my sympathy on the assumption that I would naturally agree that such lower order socio-economic scum should not be allowed use the NP, or upset the largely middle class ‘blow ins’ who have replaced the indigenous population. There is no evidence whatever that the mess left by visitors both day and overnight can be attributed to any particular sector of society, other than highly subjective guesswork. There is ample evidence that the fly tipping, of which there are examples everywhere, is the responsibility of residents.

 

He also mentioned that tidying up the NP, by exclusion of campers, was an imperative because foreign visitors, particularly those traversing the West Highland Way, remarked on the quality of the Scottish Scenery but bemoaned the litter everywhere. This underlines the lack of a litter management strategy, but hardly validates the exclusion from preferred camping sites nowhere near the West Highland Way.

 

It is hard not to conclude that training of NP personnel involves reinforcement of social prejudice, that evidence they see every day must throw open to question.

 

Politics and the national interest

 

In the context of the lead up to an election in which constitutional issues will be influential, opinion about the detail of the ‘actual’ governance of Scotland is relevant.
It is appropriate to comment on abuse of position and influence and disregard for Scottish Law, in pursuit of objectives that reinforce social exclusion and private interest at the expense of the ‘common good’.

 

There is such dissonance between political pronouncements and the reality that it raises concern that Ministers of the Scottish Government consciously collude or are out of touch!  One wonders whether civil servants, parliamentary secretaries and constituency workers, who presumably monitor the press and other media, are keeping Ministers properly informed – or colluding in misrepresentation and abuse of power and due process – because they are in sympathy with it!


This raises the issue of ‘who actually governs Scotland’ and whether the declared social aspiration of the SNP  is being subverted or are just hollow. Strong & Stable [actually indecisive and floppy] versus Fighting for Scotland’s interests [actually weak and ineffective] while incapable of implementing any change worthy of notice, and presiding over socially regressive initiatives reinforcing the least palatable aspects of the Scottish social scene, of which they seem blissfully unaware.


The Governance of the NP Authorities and the accountability of senior officers is the issue under consideration, but the devious unaccountable nature of HIE, SNH, MOD, SEPA, FCS & the landowning interests with which they apparently closely identify is also becoming explicit.


The question has to be asked, ‘who disinterestedly speaks for the actual benefit of the majority of Scottish people’, and whether their voice should be heard?   The evidence seems to suggest that democratically organized representative bodies, charities and voluntary undertakings are treated with contempt.

June 1, 2017 Ross MacBeath 4 comments
By Ross MacBeath

Camping provision without parking spaces, pitches you can’t find never mind camp on, and camping permit zones comprising bogs, scrub, briar, rough heath and felled forest all add to the growing list of failures in the Loch Lomond and Trossachs National Park Authority’s claim to have provided  new camping places, not just in Forest Drive but Park wide (as illustrated in Nick Kempe’s post yesterday on Firkin Point)

 

Then consider if Forest Drive is suitable at all as a location for 72  of the 300 camping pitches the Park promised to provide when the gates are locked at 4 pm and don’t open again until  9 am the following morning.   In effect none of these pitches are available to anyone who has not taken an extra half or full days leave on the first day of their holiday or weekend.

 

This is repeated at Loch Chon and other gated sites where the very few toilets available in the Park are locked when Rangers go home in the evening if there have  been no bookings.  This can be as early as 4pm,  forcing all visitors to go in the bushes, a criminal offense if they are not in possession of a trowel.

** Currently  26 Forest Drive  pitches are missing from the booking system!

 

Forest Drive Zone L, replacing a desirable loch shore as a place to camp

 

In past years, before access rights,  the Forestry Commission provided an excellent permit zone for a number of tents just opposite what is now Permit Zone L

The grassy loch shore was perfect for camping and suitable for families and multiple groups.  A small portion of it is shown here.

 

That is all gone as far as camping is concerned – camping along the shore is now banned, though there is a bay for a motorhome on the shore side of the road, and has been replaced by a zone located within the forest.

 

The First view of Zone L is not really encouraging with rough ground and slopes

The LLTNPA claimed 9 places were available to camp here from 1st March.

Damage to sign perhaps by some disgruntelled visitor who was mis sold this site

 

Large areas of debris cover the forest floor, steep slopes and rough ground with thick vegetation, all make this area unsuitable for camping. As hard to believe as it might be, this is a accurate description of the entire zone ‘L’

It would appear already that some disgruntled visitor has taken offence at being duped by the LLTNPA into paying for this site and took it out on the sign.

 Click here to review the full image set

Misleading maps, poor parking provision and no where to go

 

The map shows a large camping area which one might have thought offers plenty of places to camp but this bears no resemblance to the truth. The 9 pitches claimed simply do not exist, and the motor home space at the parking opposite takes up to 8 meters of the lay by, allowing space for a further 2 cars, 3 at a push if one noses in off road.

The shore frontage here is popular with Forest Drive day visitors and fishermen so it and the layby fills up quickly.  Quite where the additional 9 cars that campers require are going to park is a mystery..

 

Apart from lack of parking at this site, if nine camping groups ever did book permits, forced to come here by the National Park, they would be driven onto the lochshores as the camping zone itself  provides no incentive to remain in forest after perhaps an initial exploration or search for somewhere to go to the toilet.

 

New disruption to the forest is likely to worsen if operations continue

 

Vehicular entry into forest from track above zone The start of what promises to be a disruptive forestry operation Selective felling means vehicular access to all areas required

Click images to zoom and enter gallery

 

The tracks are an unsightly muddy mess that can be crossed with care you would not really want to get this mess on your feet before entering your tent.

 

While the forestry felling operations are a noisy and destructive intrusion when in progress, they are not really any cause for concern at Zone ‘L’, other than the aftermath of churned up ground, felled wood and trimmings cumulatively denying access to the zone over time as well as other multiple issues with the site:

 

Forest floors in commercial forests are not suitable locations for camping

 

This zone, being part of an active forest, is affected by the usual rotating pattern of felling,  self seeding and natural regeneration which takes place over many years.  This has resulted in a rough inaccessible forest floor across the entire area, often hazardous and strewn with debris from the tree felling and trimming operations.

 

Tree trimmings deny access and interfere with tent pitching The natural reclimation of the previous debris results in and uneven floor Trimming of self seeded growith results in unusable and quite hazerdous areas

 

Hill side locations often hold little camping pitch gems, but not this one

 

Being a hill side location above the loch means the area is predominantly sloping northwards meaning any sun entering has to filter through the canopy  The slopes themselves are unsuitably steep with the areas below them generally wetter with standing water and mosses due to run off from the slopes.

 

Entire slope along the length of forest drive is too steep for camping The zone is undulating and slopes in the zone mossy wet areas below The west border od the zone is the river with steep inaccessable banks

Click on images to zoom

 

Again the question of why these areas are included in a camping zone can only be explained by the Park’s  need to deceive the public and other stakeholders into believing that they have delivered sizable camping provision when in fact the total size of the permit zones in general is much much larger than the miniscule areas in the zones which are suitable for pitching tents (and in this particular zone, which the Park claims provides for 9 tents, has nowhere suitable).

 

Flatter areas are unsuitable with standing water or dense vegetation

 

The slope levels out a bit towards the forestry track, the southerly border of the zone. with some more areas just to the top of the slope from forest drive.

 

Sections of the level floor have self seeded and are inaccessable Typical flatter area where mosses and wet areas abound Flatter areas by the track are exposed to light where bracken and thick grasses can florish

 

The now familiar red paint ring around trees marking them to be retained for self seeding while others are harvested.  This is a very successful method of forest growth and much of the forest floor has self seeded with the result they are unsuitable for tents.  This, in combination with wet mosses and other thick vegetation where sunlight penetrates the forest canopy, make the greater zone unsuitable for access, never mind camping.

 

Mosse, standing water and ouht ground unsuitable for camping Rough round and debris prevent pitching tents It's just impossible to camp in this zone, in seasom it will be a midge ridden hell hole

 

Standing water and shade makes this an ideal breading environment for midges, the dense vegetation, high humidity and detritus from trees provides insulation for the overwintering of midge larvae and nymphs ensuring a thriving population the following summer.

 

Popular loch shore locations are “popular” because of the short grasses and sunny aspects which in themselves give some some relief from the midge during warm sunny or windy days, especially where tree cover is minimal. But the main reason they are so popular is because they are pleasant places to spend a weekend,  particularly if you want to do no more than throw a Frisbee, run around the tent with the kids or cool off in the loch.

 

I love forests, even commercial forests such as this.  To me they are as interesting as they are beautiful.  What’s more there are many locations throughout the country where forest camping can be enjoyed on a dry flat forest floor with a carpet of leaf or pine needles, with great views or in sunny clearings.  This is just not one of them.

 

The LLTNPA’s war against visitors continues

 

It seems the LLTNPA have continued to wage war against visitors by providing the most atrocious areas for pitching tents available in the National Park, claiming they match the camping zone selection criteria.  This zone matches a few:

 

  1. It’s Forestry Commission Land so it’s available,
  2. It has no adverse impact on the environment as it’s a commercial forest
  3. It has fishing close by as a recreational activity

 

It matches no other criteria.  In fact the National Park don’t even list “suitability for camping” as a prerequisite for choosing a site and that fact is aptly demonstrated by Zone L.

 

There are no suitable areas in this entire zone that would constitute a worthwhile camping experience.  The evidence here (and at Loch Chon (see here)) gives the lie to the latest propaganda video from the LLTNPA which tries to portray itself as pro-camping and doing positive things for campers. The LLTNPA appear to think by inventing their new term the “wild camping experience”, to further muddy the waters for Ministers, then by reclassifying abysmal provision as some sort of innovative wild challenge, that the public will accept what they are offering as an alternative to camping on the loch shores.  That is just not going to happen.. Taken together with their failure to create new parking spaces for the 14 or so cars that could use this site speaks volumes for the LLTNPA’s contempt for paying customers.

 

In the end it’s not just Forest Drive that’s going to suffer, though the Forestry Commission Scotland  is in danger of losing it’s reputation built up over the past 40 years.  The Forest Drive permit area is starting to damage the reputation of our National Parks System and the Scottish Tourist industry itself.

 

It’s high time Sports Scotland, Visit Scotland and Scottish National Heritage intervened and stopped the rot.

 

What the National Park Authority needs to do!

 

Remove the zone as it stands from the booking system and let people camp once more in the original camping zone on the loch shore opposite provided by the Forestry Commission where the old signs are still in place. This has space for 3 or 4 tents to camp comfortably but needs further parking to allow campers, day visitors and fishermen to enjoy the loch shore.

 

Original permit zone provoded by the Forestry Commission

May 8, 2017 Nick Kempe No comments exist
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!

May 5, 2017 Ross MacBeath No comments exist
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?

April 25, 2017 Ross MacBeath No comments exist
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
April 21, 2017 Nick Kempe No comments exist
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.
March 31, 2017 Nick Kempe No comments exist
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.

March 30, 2017 Ross MacBeath 1 comment

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?

March 27, 2017 Nick Kempe 7 comments
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?

March 24, 2017 Phil Swainson No comments exist

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.
January 9, 2017 Nick Kempe No comments exist
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?
December 24, 2016 Nick Kempe 2 comments

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.

December 18, 2016 Nick Kempe No comments exist
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.

 

December 6, 2016 Nick Kempe 3 comments
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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:

 

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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.

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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.

November 15, 2016 Nick Kempe 2 comments
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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.

 

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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.

 

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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.

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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.
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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.
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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.
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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?
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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.

November 9, 2016 Nick Kempe No comments exist

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.