Tag: landscape

January 21, 2018 Nick Kempe No comments exist

Returning from a great day on the hill yesterday, I stopped at Inverarnan at the head of Loch Lomond to have a look at the Eagle Falls.  I wanted to check how much ice had formed.   While on past experience the temperatures we have had over the last ten days would not have been cold enough to freeze the falls, I was interested in the impact of the Ben Glas hydro scheme.  This siphons off water from above the falls and I wondered if the reduced flow of water might have aided ice formation.

In fact, as you can see from the photo above, the hydro scheme has had the opposite effect.  The volume of water is so small (you can see what is left of the Eagle Falls running down the side of the left hand gash) that there is nothing to splash on the rocks aiding ice formation.

Eagle Falls January 2010.  While the volume of water used to reduce in a hard freeze, it was still enough to splash over all the rocks in the great gash in the hillside aiding ice formation.

One wonders, with the hydro scheme, whether people will ever again be able to savour the experience of the frozen waterfall.  This is not just about ice climbers and outdoor activities, its about scenery and landscape and people coming to the National Park to experience what was a great spectacle.

While generally I believe hydro schemes are compatible with National Parks, albeit in far too many cases poor design and construction has resulted in unnecessary adverse landscape impacts, Ben Glas provides a good example of a scheme that should never have been built.  The Eagle Falls are no longer worthy of that name, the wild area above no longer feels wild due to the intakes, track and a bridge (see here), while the track up from Glen Falloch is far too steep and forms a great scar up the hillside.

The Ben Glas hydro therefore should be a prime candidate for removal once the construction debt has been paid off.  I would like to see the LLTNPA admitting a mistake has been made at the Eagle Falls and committing to redress this in the longer term, say in 20 years time.

January 16, 2018 Nick Kempe 1 comment
Speyside Way extension along line of former powerline between Lynwilg and Alvie – Photo credit Peter Crane

Following last week’s post on the undergrounding of powerlines in Glen Tromie (see here), in which there was a photo showing how they had blighted the Speyside Way extension, Peter Crane from the Cairngorms National Park Authority sent me a photo of how it looks now, after the powerlines have been removed.   Thank you Peter.

You can judge for yourself the difference by comparing to a couple of my photos below from December 2015 but in my view, with the removal of the powerlines, the Speyside Way is far more worthy of a planning award than it was in 2016 (see here).

The Speyside Way extension will be a much better walk with the removal of the powerlines

Following this improvement I would, though, still like to see the CNPA promoting a variant to this section of the Speyside Way along the fine section of river at Kinrara which has been avoided by the extension.  This would also make it far more obvious to people that they could do circular walks using this section of the Way.   The challenge is getting landowners to agree to this – time, as Dave Morris proposed in his interview with Scotland Out of Doors at the weekend, for Public Authorities to be given Compulsory Purchase Powers to put paths in place.

January 12, 2018 Nick Kempe 2 comments
The powerlines which blighted the Speyside Way extension south of Aviemore have now been removed

While the Beauly Denny has been a blot on the landscape, as a consequence of the visual impact of the pylons and the poor restoration of ground around (covered in my last post (here)), elsewhere in the National Park a very different approach is being taken.   The powerline infrastructure is being modernised but to the benefit, not at the expense of, the landscape.

Much of this is due to the Cairngorms National Park Authority which, while failing to stop the Beauly Denny, did win support for the associated rationalisation scheme for the the removal of c93km of existing LOW voltage or redundant tower lines from Etteridge, through Boat of Garten,  Tomintoul, the Lecht and Strathdon towards Tarland – a great arc around the north of the National Park.   The Report on the Beauly Denny at the December planning Committee reports this is now complete:

 

The scheme started in 2014 and completed in the summer of 2017 with the removal of the last towers between Ruthven and Etteridge. Much of the new low voltage line has been undergrounded using a mole plough for cabling so there has been relatively little disturbance of vegetation. CNPA officers have undertaken site inspections and advised upon some technical matters relating to natural heritage. There have been modifications to wayleaves and some tree removal during the project but the work has been undertaken in a satisfactory manner and with minimal disturbance so has been successful

 

There are many positive consequences of this for everyone who lives in and visits the Cairngorm National Park (see photo above and here) and this should be seen as a great success story.    What particularly interested me from the report, however, was CNPA officers positive assessment of how the work was done, by mole plough.  I had come to similar conclusions about the benefits of using this technology to bury powerlines from two visits to Glen Tromie in November.  The rest of this post will use what is happening at Glen Tromie to illustrate the benefits of using this technology before arguing it provides a great opportunity to enhance the landscape throughout both our National Parks.

 

 

The current work to underground the Glen Tromie powerline starts at the hideous Lynaberack Lodge in Glen Tromie. The ground here, where the undergrounded line joins with the overhead powerline, is more disturbed than almost anywhere else along the route.

In November, as part of my visit with Dave Morris to discuss hill tracks (see here), Thomas McDonnell, the Conservation Manager of Wild Land Ltd, took us up Glen Tromie to look at tracks there.  On the way we stopped off at Lynaberack Lodge, a planning disaster which thankfully the estate intend to remove, so Thomas could have a word with a team who were about to return to Germany with their mole plough (sorry no photos!).   It was as a result of this that I became aware that part of estate’s programme to re-wild the landscape is to underground powerlines – work which is basically being paid for by Anders Povlsen, the billionaire owner.  Two weeks later I went back myself to take a proper look at how the work has been done.

Evidence of the amount of new electric cable which has been undergrounded

The work is not yet complete.  While the contractors have buried the new cable,  it is not yet connected and removal of the existing powerline and clear-up has still to happen.  The advantage,in terms of the timing of my visit, was I could record the landscape impact of the existing powerline.

The road is just to the right of the photo

Imagine the difference, when this section of powerline is removed.  While there is still a road running up the glen, to the person walking or cycling along it the view  will feel significantly wilder.

The new powerline, which lies beneath the vehicle track starting bottom centre, will replace the pylons.
Few people would know, just a couple of week after the work had been carried out, that the reason for this ground disburbance is an electric cable had been buried  unless it was for the sign
You can however see some evidence that a mole plough has been used. In places boulders have been excavated  to allow the passage of the plough and cable.

Apart from the removal of boulders, the vegetation has been little disturbed and on the grassy floor of the glen should recover from the passage of vehicles very quickly.  I suspect by next summer, when the grass has had time to grow again, it will be very hard to detect the line of the buried cable.

The buried cable is under the disturbed heather on the left side of the road

I was most impressed that the mole plough could also be used on heather moorland and cause so little destruction to vegetation.  Again, I think the vegetation here should more or less fully recover in a season.

There was a section further up the glen where I had great difficultly following the line that had been taken and wondered whether I had reached the end of the work.

The worst area of ground disturbance/destruction of vegetation on moorland

I then came across the patch of very disturbed ground in the photo above.   I was unable to ascertain the cause of this – it may have been a consequence of the land being very boggy – but in the context of several kilometres of buried cable it just served to illustrate in general how well the work had been done and the potential of using mole ploughs.

The line of the Glen Bruar power cable runs along the line of disturbed vegetation on the left of the road to the powerhouse which you can just see top right

The advantages of using the mole plough can be seen by comparing the powerline burial in Glen Tromie with that to the new Glen Bruar scheme.  While parkswatch has given extensive coverage to the Glen Bruar pipeline restoration above the powerhouse, below it several miles of new electric cable was required to connect it to the grid.  The work for this was generally to a high standard – and hence I have avoided comment – but the methodology used was to excavate a ditch, bury the cable and then refill it.  Despite the care taken, over two years on the line of the cable is more visible than that in Glen Tromie two weeks after the work finished.   The lesson, I believe, is that burying cable with a mole plough, if done well, does significantly less damage that any methods that involves removing vegetation, excavating a ditch and then trying to restore this work.

I had seen one example of excavation in Glen Feshie – the hole appeared for connection purposes.  It is very difficult – and incidentally far more labour intensive – to restore the ground caused by such digging.  Compare this to the impact and work involved in using a mole plough.  Thomas MacDonell told us, if my memory is correct, that it had taken just five days to bury the cable in Glen Tromie and, from I saw, very little further work or monitoring will be needed.

Sign marking where cable crosses the track leading up to the upper Allt Bhran hydro intake – the track below the moraine leads to the Gaick

I left the line of the buried cable to head further up the Allt Bhran and look at tracks there (to be covered in further post) convinced that mole ploughs are the way forward and wondering why there is a paucity of contractors using this technique in Scotland.

 

What needs to happen

While I hope in due course to visit sections of the powerline that has been undergrounded in the Beauly Denny restoration scheme (any photos from readers of before and after would be welcome), from the evidence I have seen at Glen Tromie, there is no reason to disbelieve the statement by CNPA staff that the use of the mole plough there has been very effective.  I think there is an opportunity for the CNPA to advertise and build on that success with a view to ensuring that as much low voltage cable as possible is undergrounded in the National Park.  Among the ways the CNPA could help this to happen are:

  • to commission research/publish a  study on the impacts and costs of the mole plough compared with traditional ditch digging techniques to underpin a future action plan in the National Park
  • to share this experience with other planning authorities, including the Loch Lomond and Trossachs National Park Authority, and with landowners.
  • to encourage other private landowners to follow the brilliant example set by Wild Land Ltd and to consider what other opportunities there might be for enhancing the landscape through burial of further powerlines in the National Park
  • to develop planning policy in this area, as part of its consultation on the new National Park Development Plan, with a policy presumption against any new overhead powerlines and guidance on how any new powerlines can be buried
  • encouraging contractors to purchase the appropriate equipment and develop the expertise to use it effectively

That then would leave for the future the big challenge, how we can undergound the HIGH voltage powerlines which blight our National Park landscapes, like the Beauly Denny or the many that cross the Lomond and Trossachs National Park.

January 11, 2018 Nick Kempe No comments exist
The Drumochter, a fine landscape forming a gateway between north and south, marred by development – the line of the “restored” Beauly Denny construction track is marked by the scar behind the pylons

Over the last year Parkswatch has featured a number of posts about the destruction of the landscape at Drumochter, including:

  • the unrestored Beauly Denny construction track between Dalnaspidal and Drumochter (see here);
  • the failure of Scottish and Southern Electric to restore the ground at Drumochter as required by the Beauly Denny planning consent from the Scottish Government  (see here for example);
  • progress on the restoration of the Beauly Denny construction track from just south of  Drumochter Lodge to the end of the A9 shelter belt opposite Dalwhinnie (see here)
  • and, the continued proliferation of hill tracks and inappropriate use of All Terrain Vehicles around Drumochter (see here for example).

Two of these issues were considered by the Cairngorms National Park Planning Committee in December (see here for papers) and will be covered here.  While welcoming the CNPA’s continued interest in Drumochter and the actions taken, this post will argue they do not go far enough and suggest some alternative measures to restore and enhance the landscape and its wildlife.

The North Drumochter Estate Beauly Denny track restoration

In February 2015 the CNPA gave consent to the North Drumochter Estate to retain a section of the Beauly Denny construction track outwith the Drumochter Hills Special Area of Conservation  and Special Protection Area (above in red) on the condition that the track was narrowed and a belt of native trees was planted alongside it.  The restoration, with the exception of the shelter belt was due to be completed by June 2016.

The start of the northern section of the Beauly Denny construction track (as indicated by arrow in map above) as it appeared in February 2016. Note the ridge of vegetation covered spoil running along the left side of the track.

A year ago the restoration had not started but sometime between then and August 2017, when I next visited, the northern section of the track (above my arrow) was restored.  The work was done by McGowan, who provided the specification for the track which was submitted to the Planning Committee, and has generally been completed to a high standard, much higher than is usual for hill tracks or for most of the Beauly Denny restoration work to date:

The northernmost end of the track. Note how the low angle of the embankment above the track has enabled vegetation to recover quickly while stored turfs have been effectively used to restore the ground below the track.  October 2017.
Before restoration, the track extended almost to the edge of the culvert. The bare banks on either side of the culvert appear the consequence of insufficient turf being stored for restoration purposes and are at high risk of erosion.  October 2017.
Looking back down a line of new grouse butts – which appear to have been installed without the appropriate consents and have caused significant damage to vegetation – to the restored section of track which starts to the right of the first pylon. The track is hardly detectable from this distance compared to the unrestored section to the left of the pylon. August 2017.

While generally McGowan has done a very good job, their ability to restore the track to the standards set out in the specification appears to have been affected by a number of factors.  Throughout its length the section of restored track is broader then specified by the planning conditions:

While generally the sides of the track have been well restored in places there appears to have been insufficient vegetation to do this: here there is an unvegetated section of ground to the right of the track while the unnecessarily large passing place appears to be another solution to this lack of material (which was not their responsibility).

The reason for this appears to be that insufficient turves were stored for restoration purposes so that there wasn’t enough material available to restore the track to the required width.  I don’t think matters too much here because the track is hidden from a distance and because of the proposals to plant native trees to help conceal it.  However, it provides yet more evidence of why planning authorities need to monitor very closely any requirements that developers store turves properly when restoration of construction tracks in required. This in my view has been the key failure of the Beauly Denny construction.

Poorly finished culvert which is fairly typical of this section of track – the dry stone finishing in the photo above was the exception. Note the grouse tick mops in the background.

My main grouse – an appropriate word here as that is the main wildlife you are likely to see? – is that most of the culverts have not been properly finished.  This I hope is something which will be pursued by the CNPA.

Another more minor grouse is that vehicles continue to be driven over areas which have been “restored” adversely affecting vegetation recovery.

Its within the context of this work that the North Drumochter estate made a further planning application to remove the requirement from the planning consent to plant native trees alongside the track.   I am pleased to say that CNPA officers recommended that this be rejected  (see here) and the Planning Committee endorsed that recommendation.   Both the North East Mountain Trust and Badenoch and Strathspey Conservation Group had objected to the removal of this condition and I suspect that helped the CNPA to stand its ground.

On the north section of the track, the main short-term landscape impact of the continued requirement to plant a 5m strip of native trees between it and the existing shelterbelt will be to soften the edge of the line of trees.  If the shelterbelt was ever to be felled, however, it would then be the only thing screening the track.  It is therefore a good decision in landscape terms.  Its good too for ecological reasons.  While there is generally too much emphasis on planting native trees, rather than reducing deer and sheep numbers and seeing what grows (trees will grow in some places not others),  here the trees will provide an alternative to the intensive grouse moor management which dominates the landscape.  They should provide a home to other forms of wildlife and maybe even a partial refuge to some of the creatures which are persecuted on the grouse moors.

To construct this section of track Balfour Beatty as the main contractors allowed imported material to be dumped on the moor without any apparent attempt to save the vegetation beneath (there is no evidence of vegetation being stored

Further south, along the section of track which remains to be restored, the native trees will fulfil a far more important landscaping function as the track runs higher across the hill away from the existing A9 shelterbelt and is highly visible.    The restoration of this middle section of the track poses considerable technical challenges as it has basically been floated across the moor.   In my view the best solution would be to remove all the excess aggregate from site – rather than trying to bury it under vegetation – and use it for the construction of the new A9.  Perhaps the CNPA could persuade Transport Scotland and the north Drumochter Estate to work together on this?

 

The restoration of the Beauly Denny by SSE

The second “Drumochter” item considered by the December meeting of the Planning Committee was an update report on SSE’s restoration of the Beauly Denny Item10AABeaulyDennyUpdate.

This represents a breakthrough as SSE had previously been claiming the restoration of the Beauly Denny was nothing to be concerned about and that the destruction caused to the landscape could be repaired through natural regeneration alone.      CNPA staff are to be congratulated in getting SSE, who are a very powerful organisation, to accept this officially after doing nothing for two years.

SSE provided a summary report of this year’s survey results (see here) for the Planning Committee.  This contains no analysis of what caused the problems while the solutions its proposing to pilot in 2018 – some re-seeding and fencing off of ground – are minimalistic.   The entire focus of the report is on vegetation.   There is no mention of the landscape issues and more specifically of the failure of SSE to ensure that where the track was removed, the land was restored to its existing form as required by the original planning consent.  This has left large “benches” cut across the hillside (photo above) which are still being used as estate tracks (below) and have a considerable landscape impact:

 

By contrast, although I was disappointed the CNPA report did not cover SSE’s failure to restore landforms as required, the report does explain why re-vegetation has been so poor:

There appear to be two main reasons for this. Firstly, in some areas, the soil management and handling during construction as well as restoration was poorly executed, leaving little soil material or very wet ground and secondly, there has been no clear management for grazing sheep and deer. It is clear that even where some regrowth has occurred it is heavily cropped by mammals.

Its good to see CNPA recognise that for effective restoration to take place vegetation and turf has to be set aside and stored properly from the beginning.    Evidence that SSE failed to do this can be seen everywhere:

A great swathe of moorland just north of the track as “restored” under SSE’s aegis. There has been no apparent attempt to keep vegetation separate from the stony substrata with the result there is now a boulder field just like the one created by the Glen Bruar hydro

The CNPA and SSE reports differ too on their assessment of the seriousness of the situation.  The SSE survey claims that:

“Of the sites monitored throughout the CNPA area, 41% are assessed as being in Good or Excellent condition for revegetation and a further 20% are showing demonstrable improvement.”

and then classifies the remaining 39% as being of concern.  The CNPA by contrast are sceptical about the improvements claimed and conclude

“59% are mediocre or sparse and more than half of these were also sparse last year, with no significant improvement so are likely to required additional mitigation measures to ensure full revegetation within the five year period”

Having walked the entire Drumochter section of the Beauly Denny I have to say I have strong doubts that the sites SSE chose to survey are representative – it would be in the public interest the full survey is released – and that the CNPA’s assessment of the situation is far nearer the mark.  My view is that at least 2/3 of the “restoration” is not fit for purpose.

Tower south of Dalnaspidal. Some revegetation has taken place but because soils have been so disturbed and not replaced properly grass and rush have replaced heather (as seen beyond the tower).

While  I don’t doubt that grazing is having an impact on the ability of vegetation to re-colonise bare ground, this is not the fundamental issue.   Because of the way the ground has been disturbed, SSE has created more mineral soils which will promote vegetation that is good for animals to eat. Couple that with the large number of deer in the southern part of the National Park and you have a problem.  The proposed solution to fence off areas, avoids the issue.  It would be far better for SSE to be asked to finance deer culls and compensate the estate for removing sheep from the area and aid vegetation recovery that way.

Even better would be for the CNPA to advocate the solutions which have been developed in Glen Bruar, where a failure to store vegetation properly during the hydro pipeline construction (see here) created a landscape scar several kilometres long just like through the Drumochter.  Those scars have now almost disappeared due to the application of different techniques, which involve careful robbing of vegetation, and in a very short timescale (see here) with McGowan again the contractor.  So why not at Drumochter?

 

What needs to be done to make the Beauly Denny restoration happen

While I very much hope that CNPA staff keep up the pressure on SSE, I would like to see them encouraged by their Board and Planning Committee to go several steps further than they have at present and:

  • Consider the Beauly Denny restoration from a landforms perspective and more specifically how to heal the scars that have been left by the poor removal of the construction tracks.  A first step  on this would be for SSE to commission an independent report on what needs to be done to restore the landscape to its original state (as required by the Scottish Government planning consent).  A plan could then be developed to implement this prior to any further vegetation restoration work.
  • Press for SSE to adopt a similar approach to landscape and vegetation restoration at Drumochter as was taken at Glen Bruar.
  • Reject the proposal to deal with grazing impacts through fencing and instead focus on how to reduce the number of grazing animals at Drumochter (which would also support the Board decision to require the retained section of track on the north Drumochter estate to be screened by trees)
  • Create a Drumochter landscape steering group which would bring together SNH, Highland Council, SSE and Transport Scotland (due to the A9 dualling) in order to ensure a holistic approach is taken to protecting the landscape, with a view to amelioriating/remedying past damage and mistakes and ensuring that these are not repeated when the A9 is dualled.

Most of this should be financed by SSE and would cost them far more money than their current meagre proposals.  As a consequence I expect SSE to be resistant to it despite their self-proclaimed mission to set an example as a responsible business  The most likely way to achieve change, will be if the wider public starts calling on the Scottish Government and SSE to fulfil their responsibilities and not leave everything up to the CNPA who, in the wider scheme of how this country is run, are not a particularly powerful public body.

November 27, 2017 Nick Kempe No comments exist
Looking back along the Allt na Beinne track to the central Cairngorms. The movement of heavy vehicles along the track in wet conditions has caused significant damage and helped destroy its quality as a recreational route

Following my post on the new and “upgraded” hill track in Glen Banchor  (see here), the Cairngorms National Park Authority has informed Dave Morris and myself that they will fully investigate what has happened and feed back to us what action they can take. This is most welcome.  I also reported to them that works had taken place on the Strone/Allt na Beinne hill track on the same estate.  This post considers the issues this raises for the planning system and then makes some proposals for how the planning system could be reformed. (There is an ideal opportunity to change the current failed system in the forthcoming Scottish Planning Bill)

 

The Strone hill track

There has been a hill track by the Allt na Beinne, which is directly north of Newtonmore, for many years.  Its marked on my OS Map which dates from 1980.   Existing tracks, just like footpaths, need to maintained and therefore when a landowner decides to undertake maintenance work that should be welcomed.  However, two issues arise from this.  The first is the quality of the maintenance, with poor work having the potential to increase environmental damage and landscape impacts as well as negatively impacting on the recreational experience (see top photo).   The second is when does maintenance turn into an alteration, now that all alterations to hill tracks fall under the planning system?

Although there is Scottish Government Guidance on the distinction between maintenance and alteration under the Prior Notification System  (see here), when Forest Enterprise Scotland tries to pass off major alterations to tracks as maintenance (see here), you can see there are major challenges to the system.  What has happened to the Strone track provides a further illustration of the issues but also got me thinking about potential solutions within the National Park.

Looking across the moor from near Strone towards the Allt na Beinne.

The track starts at Strone and is clearly partly agricultural in purpose, therefore falling into the category of a permitted development right which did not require any form of planning approval before the creation of the Prior Notification System.   The first section is of good quality,  has blended into the surrounding ground and being on  flattish ground has very little landscape impact.  Its good for walking and well used.  It shows its possible to create good quality tracks outwith the planning system.

The creation of the drainage ditch has not solved the problem of water accumulating on the lowest section of track while there has been no attempt to landscape the excavated materials.

There was, however, evidence of some recent work on this first section of track.  The estate appears to have taken the opportunity of having diggers available for work higher up the track to try and improve the drainage on dips in the track.  There are several of these at present which either are filled with water (above) or are crossed by burns (below).  I think most people would class work such as this as maintenance rather than an alteration to a track and therefore not requiring any form of planning consent or prior approval (which Planning Authorities give under the Prior Notification system).   The problem is the work is of poor quality and not in my view fitting for a National Park.  Its storing up problems, not solving them.

Burn flowing across road with excavated material dumped in foreground

Its quite predictable that the burn flowing across the road will erode it in due course.  A solution to this was pioneered in Scotland almost three hundred years ago with the Wade and Caulfield Military Roads.  Where culverts would not work – as here because the road is too low relative to the surrounding land – they used paved cross drains.  There are plenty of stones here which have recently been unearthed and dumped by the side of the track that the estate could have used to line the cross drain but they have not done so.  What this shows is we need to find a way to ensure that maintenance work, whether of paths or tracks, is to an appropriate standard.

Once a track starts getting churned up, vehicles start creating alternative routes, spreading the damage.  Caterpillar track visible bottom right of photo.

Undertaking maintenance work in wet conditions – much of the initial damage in the photo above appears to have been done by heavy caterpillar tracked vehicles – also causes damage.  High quality maintenance is not just about appropriate design or the skill of the contractor, its about the timing of the work.

Towards the far end of the moor, before the track begins to rise, a borrow pit has been created (or extended).   While borrow pits for forestry tracks are classed as permitted development rights – so if the road is created lawfully, so is the track – for agricultural roads they are not.  Because of the size of the borrow pit my understanding is the estate should have applied for planning permission.

 

Further up the track there is evidence of other small borrow pits, with material dug out from the side of the track, without any attempt to restore the ground.  I suspect Planning Authorities would see small borrow pits as part of maintenance work rather than an alteration to the track and therefore not requiring planning permission under the current system.  Even if right, however, this leaves the question of whether poor quality work such as this should be allowed, particularly in a National Park.

Unfinished culvert and new drainage ditch

The extent of the track work increases as it enters the lovely small glen taken by the Allt na Beinne.   When does maintenance, which does not require any type of planning consent, become alteration which does?

The edge of the existing track appears to have been excavated to facilitate ATV access to land on the left creating a new track

The work in the photo above may not be finished but to my mind the excavations here are far more than maintenance, they are alterations.  Whether an alteration comes under the Prior Notification System or needs full planning permission depends on whether or not the track is for agricultural or forestry purposes.  The moorland above the steep section of track is covered with signs of intensive grouse moor management so I believe these tracks are clearly non-agricultural in purpose and therefore the alterations should have been subject to full planning permission from the start.

The track above the steepest section, showing a broad strip of disturbed ground on the right

We did not have time to get to the end of the track  but noted in many sections the total width of track plus disturbed ground appeared to be up to 20 metres and included piles of rocks and boulders.  Again the scale of this is such that it should be treated as an alteration to the track rather than maintenance and there are issues both about the longer term landscape impact but also the quality of the track (which is currently a peaty morass in places – as you can see in left of photo).

Its also clear the work is not finished though the end product is not relevant to the question of whether planning permission should have been applied for, only about whether the CNPA needs to take enforcement action.

ATV track heading round to the newly upgraded Glen Banchor hill track, which is visible just below the left horizon

The final issue was that lower down you could see how ATVs or tracked vehicles are being driven from the Strone track, apparently around to meet the new Glen Banchor track.   Where tracks are created by such use the question of maintenance and alteration is complicated by the fact that such tracks are not subject to any planning approval.  In this case they represent a major extension of the track network in the Glenbanchor/Strone area.

 

So what are the lessons for our National Parks and the planning system?

I believe the photos illustrate there is a fine line between track maintenance, which does not need any approval from the Planning Authority, and alterations to tracks which do.   The quality of both, however, matter, especially in our National Parks.  The situation is then further complicated because alterations to Forestry and Agricultural tracks – such as the lower section of the Allt na Beinne track – come under the Prior Notification system while those for other purposes such as deer and grouse moor management – upper section of the Allt na Beinne track – come under the full planning system.

While I believe the failure of the new owners of the Glen Banchor and Strone estate, who have owned the adjacent Pitmain Estate for several years, to consult with the Cairngorms National Park Authority before starting any work on the Allt na Beinne track (or Glen Banchor track covered in my previous post) is inexcusable – and they need to be held account – I think we need to recognise the current rules creates  a nightmarish situation for both land managers and planning authorities.

On one track the work being proposed could. for different sections, be classed as:

  • maintenance not requiring any approval;
  • alteration to a forestry or agricultural track requiring prior notification and possibly approval;
  • alteration for other estate management purposes requiring planning permission;
  • an extension for agricultural or forestry purposes needing prior notification;
  • an extension for other purposes needing planning permission.

I started thinking about this after my post on the Glen Feshie tracks, questioning why the CNPA had allowed them to go ahead under the Prior Notification system without approval  (see here).    Dave Morris and I went to see Thomas MacDonnell, the Conservation Manager for Wild Land Ltd who manages Glen Feshie, a couple of weeks ago.   He was extremely open about what the estate was trying to do and the fifteen or so miles of new tracks that had been given the go-ahead under the Prior Notification system.  He was clear – and the planning documents reflect this – that the track were not just about forestry (which comes under the Prior Notification System) but also deer management and recreation (which don’t) and that it was not the estate’s decision to deal with this as a Prior Notification.   What came out of this for me though is that dealing with some parts of the proposed tracks under the Prior Notification system and some under the full planning system would have been a nightmare for both the estate and the planning authorities.  It made me understand therefore why staff in public authorities might have wanted to deal with this as one single type of application.  The trouble – which I will come back to – is it did not fit into any single classification.

 

The work though that Thomas MacDonnell has been leading at Glen Feshie, points I believe, to some of the answers.  Thomas took us out to look at some of the work the estate is doing to upgrade and repair existing tracks as well as the locations for the proposed new tracks.

The work to upgrade existing tracks is generally of very high quality and its very hard to tell that extensive work has been done to improve this track

The work to existing tracks has been treated as maintenance, and not gone through the planning system., although in may cases badly eroded existing tracks have been transformed in appearance.   How the work has been done though has been governed by a standard specification for tracks (on dry ground) which has been developed by Wild Land Ltd.  It has used the same specification as part of the Prior Notification for the new tracks.

Extract from Prior Notification – note how Wild Land Ltd is able to extract timber using narrower tracks than those specified by the Forestry Commission.In other words, Wild Land Ltd is applying the same set of standards to all the work they do, whether track maintenance, track alterations or the creation of new tracks.  Now while its possible to question some of the details of that specification – the North East Mountain Trust for example would like to see a vegetated strip being included down the centre of all tracks (which are in place on some but not all Feshie Tracks) – the existence of a specification that delivers high standards seems to me to point to a way forward for hill tracks.

If all estates undertook track work according to agreed standards, the current distinctions between maintenance and alteration, and forestry/agricultural versus other tracks would become far less important.

The way forward

Working from the basis that all work on hill tracks should meet certain standards (and these could be higher in National Parks), the Prior Notification system could be adapted to be used where a landowner had agreed a set of standards with the Planning Authority.  Whenever the landowner was planning maintenance or track upgrade works it would notify the Planning Authority of the location of such works (so they could monitor that the adhered standards were being adhered to) but no planning consent would be required.  Alterations to the line of an existing tracks could also be dealt with under this system if the agreed standards included how unused/redundant sections of track would be restored.   This would simplify the system for responsible landowners.

If the agreed set of standards/specification also included provisions about off-track use of ATVs, whose purpose was to prevent tracks being created by default, that would help address the impacts such tracks have on the landscape and to bring them under control.

A full planning application, which gave the public and other stakeholders the opportunity to comment on (and object to) proposals, would still be required for new tracks (including those for agricultural and forestry purposes) and for any works on tracks which were not covered by the set of standards which had been agreed between the Planning Authority and landowner.  This would incentivise landowners to adopt and work to certain standards.

Planning Authorities would then be able to endorse certain existing model standards for hill tracks in their planning policies which could be adopted by landowners where they so wished.  For example while Wild Land Ltd has developed its own set of standards for most of the tracks on the estate – which are in my view much better than those of the Forestry Commission which were designed for industrial forestry and not for National Parks or other protected areas – for areas of deep peat it has chosen to adopt the SNH/Forestry Commission Standards for “Floating Roads on Peat 2010.

While changing the system in the way I have proposed here would require changes to hill track regulation nationally – hence the need for discussion in the forthcoming planning bill – the CNPA could also set and promote the adoption of approved standards for hill track work in its new development plan.  The Main Issues Report for this has just been issued for public consultation and provides an ideal opportunity for the CNPA to strengthen its policy in this area.

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

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

The Prior Notification System and the track upgrade

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

In response I sent them some photos:

View of track extension from below

FES response to photo:

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

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

 

Another view of the track extension

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

FES response to photo:

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

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

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

FES response to photo:

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

 

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

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

 

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

FES response to photo:

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

FES response to photo:

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

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

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

 

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

 

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

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

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

 

What needs to happen

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

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

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

Addendum – correspondence with FES

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

 

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

 

November 21, 2017 Nick Kempe 6 comments
New track, slopes Creag an Loin, Glen Banchor looking towards Creag Dubh on the Pitmain Estate, behind Kingussie. You can tell this is intended as a track, rather than just caused by ATV use, by the bouldes lining the right hand side

Earlier this year, the owner of the Pitmain estate,  who appears to be Abdul Majid Jafar, bought the Glen Banchor and Strone Estate behind Newtonmore.   I say “appears” because the information on Pitmain Estate Ltd at Companies House fails to declare who has significant control over the company.

While  Abdul Majid Jafar resigned as a Director in June 2015, to be replaced by an Indian Accountant also based in the United Arab Emirates, it appears he is still the owner.   Its not only our landownership system which is opaque, our company system is too and there is abundant evidence for this in our National Parks.  Abdul Majid Jafar’s family run Crescent Petroleum, the Middle East’s oldest private oil and gas company, so not short of a bob or too and well able to afford to do things properly if he so wished.

Map credit Cairngorms National Park Authority estate maps

The previous owners of the Glen Banchor and Strone estate were the Lindt Family, of chocolate fame.  They appear to have managed the estate for purely private pleasure (for example the internet has stories about how you could not pay to stalk there).   This had its disadvantages, in that deer numbers were very high, but otherwise estate management appears to have been low key and unintensive.   That appears to have changed since Pitmain took over, with significant consequences for land-management.   This post will consider the new track works in Glen Banchor.

The section of newly engineered track above the esker – you can see one of the sheep dog trial gates on the left. The track bends left after about 700m to a sheep pen.

The boggy moorland where the road bends west into Glen Banchor (GR 702998) and lower slopes of Creag an Loin have long been used for sheep dog trials and there was a rough track along the fabulous esker – a deposit laid down by the glacier –  that snakes across the moor.  This then led up the slopes to a sheep holding pen.   Unfortunately I don’t have photos of the old track (photos gratefully received!), so you can compare then and now, but it was little more than two wheel ruts and much used by walkers.

The esker provides a dry passage across the moor but its character has been totally changed.  The top has been lopped off to create a track with no consideration given to the landscape impact.

Under the Prior Notification system, any changes to existing agricultural or forestry tracks which increase their footprint or new ones should be notified to the planning authority (see Scottish Govt statutory guidance Page 11 onwards).  There is no sign on either the Highland Council or Cairngorms National Park Authority planning portals that this has been done at Glen Banchor (I have written to the CNPA to double check and report the track works).

There is evidence all along the former landrover track that major upgrading works have taken place. Note the large lumps of turf in the foreground which could have been replaced down the centre of the track reducing erosion and the landscape impact.

While full planning permission is not needed for agricultural tracks, the point of the Prior Notification system is it is “an important tool in preventing inappropriate construction of private ways” (Government Guidance).   In this case there are plenty of signs of inappropriate construction (including above) which are not fitting for a National Park and do not meet SNH’s Best Practice Guidance on hill track construction.

The upper section of the track is too steep and already eroding away, not helped by the lack of vegetation down the middle and an absence of drainage bars which means water runs straight down the line of the track.

Start of track 7th November
Start of track 18th November

Since I learned about the track I have been twice, first time to have a quick look and then last Saturday when I walked along the track and beyond.  While it has been very wet, the two photos show there has been a considerable deterioration in the track over the intervening 10 days and much of it has been churned into a quagmire.

The turning circle at the top of the old section of track, sheep holding pen for the sheep dog trials in the background

The problem is even worse at the top of the old section of track.  I don’t think this mess has been created by sheep dog trials, the problem is the old land rover track is now being used for other estate management purposes and far more intensively than previously.  It links to a new estate management track (see top photo) which has been created without any planning permission.

The new track contours round and down the hillside from just below the sheep holding area. You can see the excavated boulders and vegetation dumped on the right of the track.

The new track leads to another turning circle and borrow pit:

The turning circle with hummocky moraine and Creag Dubh behind
The borrow pit below the turning circle

While the newly constructed track, which comes under planning law, ends at the turning circle beyond is an ATV track, if the quagmire created can be described as a track:

Behind the moraine on the right, the ATV track forks, one part linking to constructed tracks on the Strone part of the estate, the other heading up the hillside to a feeding station:

 

Red legged partridge in cage at feeding station

In terms of planning law, all this is important.  The new section of track is clearly for game management purposes and therefore does not come under the Prior Notification System.  Full planning permission was required, it has not been applied for and therefore this is yet another case of disregard of the planning system within our National Parks by landowners.  The ATV eroded track beyond, however, because it has not been constructed falls totally outwith the planning system.

 

What needs to happen

While I understand (from an update they provided) that the CNPA are still working on the enforcement action they have agreed against  the Cluny Estate for unlawful track on Creag an Leth Choin (see here), the basic problem the CNPA faces is that until they have taken effective enforcement action, landowners won’t see planning law as being important.  Generally landowners see themselves as having the right to manage land as they wish and not as custodians for it, even in the National Park.    The result has been that unlawful tracks continue to proliferate across the National Park.  The CNPA needs to be seen to take action (just as East Ayrshire has recently done for breach of planning conditions at a windfarm).

 

Determined and rapid enforcement action would I believe, make a great difference.  This track, being so recent, would be a good place to start.  In addition, while I appreciate the Prior Notification system is very weak and not fit for purpose, the creation of an unlawful track linked to an “upgrade” of an existing track, should make it easier for the CNPA  to argue that the “upgrade” of the existing track is more than that and not fit for purpose.

 

However, at present the CNPA has NO powers to address ATV created tracks, such as the featured here leading from the second turning circle to the feeding station.  While SNH has powers to control ATV use on protected sites, only the western half of the Glen Banchor and Strone estate is designated as a Site of Special Scientific Interest, so there are at present no controls in this part of the National Park.  In my view this has to change.  I would like to see all ATV use on the open hill in National Parks being subject to consent through farm/estate management plans.  The CNPA could do this through the creation of byelaws for conservation purposes.

 

This leads to the wider issue of estate management and landownership.  On the landownership side, no additional checks are required before someone buys a large area of land in a National Park, either to establish whether they are fit to manage the land or what their intentions might be.    While the Gynack hydro schemes on the Pitmain Estate are in many ways exemplary (see here) , step beyond them and the tracks further up the hill are a disgrace to the National Park:

Massive turning circle on Meall Unaig, south of Carn an Fhreiceadain. This is visible from Glen Feshie.

I have always wondered why an estate can do one thing well and another so badly.  However, it appears from other new track works above Strone (which I will cover in a further post) that the estate is importing and applying its poor practice standards to Glen Banchor.   While the CNPA has tried to encourage estates to produce management statements for their land, neither Pitmain or Glen Banchor have done so.   The CNPA is therefore left in a position that when a new landowner takes over an estate, it has no idea what that landowner is planning to do in terms of estate management.  That cannot be right in a National Park.

 

What is clear from the new Glen Banchor track is that the new owners are wanting to produce more game for shooting on the estate – hence the feeding station for Red Legged Partridge.   This has implications beyond hill tracks and how they are designed.  The Red Legged Partridge, which is of Mediterranean origin, does best in the wild on dry sandy soils and so, in the wild, is normally found on agricultural land.  Increasingly though it appears to be being bred on moorland within the National Park.  This requires intensive game managements methods akin to farming.  On moorland, however, it is very exposed to predators, especially at feeding stations such as that featured here, and would provide the perfect food for hen harriers if they had not been persecuted close to extinction.  With feeding stations like this, we should expect the number of hen harriers to increase significantly.   Will that happen?

 

Leaving aside wider ecological consideration, feeding stations in our National Parks should only be allowed if estates can prove they are committed to protecting raptors.  In this case,  it would be in the public interest if that the Pitmain/Glen Banchor Estate were to clarify whether they are committed to this and whether clear instructions have been issued to staff telling them that if most of the Red Legged Partridge at the feeding station get predated by raptors that that is fine by the owners.  It would be good if the CNPA, which states it is committed to improving grouse moor management, started to ask the estate these questions and to make the responses public.

November 17, 2017 Nick Kempe 23 comments
The Cononish gold mine as it looked on a dreich day in May – the same day as the pre-consultation event in the Tyndrum Village Hall

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

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

 

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

 

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

 

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

 

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

 

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

 

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

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

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

 

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

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

 

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

 

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

 

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

Extract planning application

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

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

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

 

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

 

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

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

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

 

 The Landscape impact of the tailings stacks

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

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

 

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

 

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

 

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

 

The wider implications of this application

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

 

What needs to happen

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

 

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

 

November 14, 2017 Nick Kempe 2 comments

A few weeks ago I learned that someone had nominated me for the TGO Readers’ Award under the category Campaign or Campaigner of the year.    I am really grateful that someone appreciated parkswatchscotland sufficiently to nominate me for this.   I also think its great that TGO values campaigning and through the awards and its coverage makes more walkers aware that the outdoors is not just somewhere to enjoy but also a politically contested space.  For campaigning is politics with a small “p”.

 

I am not, however, canvassing for votes and am not interested in competing against other campaigns or campaigners.  The truth is parkswatch – and the whole outdoor movement if it can be described as such – supports most of the aims of those nominated for the TGO awards.   We need to work together.

 

And that is fundamental part of what parkswatch is about, working with other people.   While presently I write many of the posts, I have always hoped more people would do so and am particularly grateful to other contributors.   Behind the scenes however there is now a large number of people and organisations keen to promote critical debate about our National Parks in Scotland who support parkswatch in all sorts of ways:  providing information, making information requests, tipoffs about what is going on and what needs investigation, suggestions for critical analysis, drafting argument/pieces for potential use, sharing posts on social media etc.   Not only this, but people are taking action, everything from submitting complaints and contacting politicians at the individual level to working through organisations.   My thanks to each and every one of you.   I suspect similar stories could be told for the other campaign/ers nominated for the TGO awards.

 

While this gives reason to be optimistic about the future,  it is worth considering how successful all these campaigns – and the many others not nominated for the awards – have been to date.    The truth is there is a long way to go.  Yes, all the campaigns listed have had their successes but none has achieved the type of fundamental change that is needed.  So, Mend our Mountains and Fix the Fells have addressed some footpath erosion but the issue of how we get sufficient funding for path maintenance work across the British Isles remains.  Mark Avery, backed by wonderful organisations like Raptor Persecution UK and a whole network of bird recorders etc, has done a huge amount to raise awareness of raptor persecution but meantime raptors continue to be killed and disappear on grouse moors, particularly in our National Parks, with depressing regularity.  Lots of people, like Get Outside, are doing great work to try and re-connect people with nature, but poverty and the slashing of outdoor education provision as part of austerity, not to mention the camping ban in the Loch Lomond and Trossachs National Park, offsets all of this work.   JMT has done fantastic work on raising awareness of the importance of wild land, but this hasn’t prevented the Scottish Government giving the go-ahead to the Creag Riabhach windfarm in a Wild Land Area in Sutherland.

 

And parkswatch is no different.  Certain changes in our National Parks over the last 18 months – from alterations to camping permit areas to restoration of hill tracks –  may be partially attributed to critical coverage on the blog.  But on the really big issues, such as land-use, whether intensive grouse moor or forest management, or major developments, such as An Camus Mor, Flamingo Land or the Cononish goldmine expansion, there is everything still to go for.

 

It would be great if next year there was a standout campaign which had achieved fundamental change, whether in Scotland or anywhere else in the British Isles.  For any such change to happen however will require change at the political level and in Scotland at present there is very little sign of this happening.

 

There is a significant contrast between the radicalism of the early days of the Scottish Parliament (the first Land Reform Act, the creation of National Parks, the Nature Conservation Act) and how it and the Scottish Government now operate (with some significant exceptions of course).  Resources that might have assisted the  implementation of that early legislation and promoted progressive change in the countryside – whether access officers, countryside rangers or staff monitoring biodiversity – have been slashed. There is very little challenge to the way the Scottish Government is micro-managing and centralising public authorities with organisations such as our National Parks and SNH  told what they can and cannot do by civil servants – with loss of even more funding the consequence of non-co-operation.   Even the simplest of decisions, such as the re-introduction of beavers, can only be taken after years of bureaucratic obfuscation.  The Scottish Government’s response to public pressure to change – such as over raptor persecution – is yet more bureaucracy, with handpicked working groups which deliberate for years and achieve nothing.  That it has taken over six months for the Scottish Government to announce the membership of the grouse moor review group tells you everything about the current failures of government.

 

I am optimistic though that this can change.  The ideological consensus behind how Scotland and the countryside, including our National Parks, should be managed is breaking down and that provides a great opportunity.    To exploit that opportunity campaigners will need to work together and see everything is connected.  So, on grouse moors for example, the way they are being managed affects not just wildlife but the landscape.  Behind this its the power of landowners which is the fundamental determinant of how land is used, whether for pylons, windfarms or intensive rearing of grouse and its only when campaigns get together and start to address these fundamental issues that we will get real change.

 

Within this context our National Parks should be demonstration sites for how things could be done differently and a measure of success for parkswatch will be when they start fulfilling that role.

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

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

Its still them and us

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

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

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

 

 

 

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

Its also a recipe for conflict:

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

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

Community Empowerment and planning

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

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

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

 

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

 

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

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

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

 

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

 

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

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

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

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

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

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

 

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

 

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

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

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

 

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

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

 

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

 

The track which is supposed to be a footpath

Unfinished culvert

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

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

 

Landscape and Visual Impact

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

 

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

 

Impact on Wildland

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

 

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

 

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

 

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

 

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

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

 

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

Track October 2017 – is this really a path?

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

 

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

 

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

 

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

 

What needs to happen

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

 

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

 

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

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

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

 

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

 

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

Powerhouse is wooden building right of centre

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

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

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

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

 

 

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

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

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

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

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

 

Could the track have been granted planning permission?

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

 

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

 

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

Implications for the planning system

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

 

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

 

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

 

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

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

 

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

 

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

 

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

 

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

Addendum

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

October 17, 2017 Nick Kempe No comments exist
The “restored” construction track just south of Balsporran Cottage forms a gash across the hillside which will remain highly visible even if the vegetation does recover because the “bench” which was created across the hillside by cut and fill construction to provide a flat track has not been re-landscaped.

This post will consider the failure of Scottish and Southern Electric to date to restore the landscape caused by the Beauly Denny construction works in the northern section of the Drumochter.

 

A central planning assumption behind the Beauly Denny was that once the construction phase was complete the land would be restored to it original condition.   Initially the main exception to this was  the agreement by the Scottish Government that some existing tracks which were “upgraded” for construction purposes would be allowed to remain, including approx 7km in the Cairngorms National Park.  Such tracks were described as “permanent” access tracks. (This, I have learned from helpful communications with SSE, includes the section of track on the Dalnacardoch Estate between Dalnaspidal and Drumochter (see here)).  Subsequently, the Scottish Government decided that landowners could also apply to local planning authorities to retain “temporary” construction access tracks but these would require full planning permission. All other tracks, compounds and construction areas around the transmission towers were supposed to be restored to their original condition.

View of north Drumochter Lodge and Beauly Denny from Geal Charn.

The Cairngorms National Park Authority has granted planning permission to the North Drumochter Estate to retain the section of track from North Drumochter Lodge to near Dalwhinnie (section of track to left of lodge behind shelter belt) on condition it is narrowed and the landscape impact reduced  (see here).  The northern part of this track (outside frame of photo) was restored in the summer but the North Drumochter Estate has subsequently applied to remove the requirement for native woodland planting around it – this will be considered in future post.  The section considered in this post, where full restoration is required, lies between the south (right) of the north Drumochter Lodge policy woodlands to Drumochter summit. The line of the former construction track is still clearly visible in the photo above from a distance.

In my view the main reason for this is that the attempt to restore the former access track along this section has been risible.   The photo above shows the bench that was cut across the hillside through cut and fill (the upper slope was cut and the lower filled in with the material excavated) remains.  In effect the only restoration that has been carried out has been to break up the former track surface.   The material which forms the line of the track should have been moulded back to match the contours of the hillside, with the “fill” material shifted uphill to cover the “cut” ground and banks on the upside of the track.

The consequence of leaving the track foundations in place is not only that a permanent line has been left across the hillside but as should have been quite predictable, the North Drumochter Estate has continued to use the line as a track.  This will prevent full vegetation recovery even if the current plan, which is to leave restoration up to natural regeneration works.

The boundary between the unrestored section of track just south of North Drumochter Lodge policy woodlands and the restored section.

The photos shows vehicles are still being driven from the section of track granted planning permission by the CNPA (which still requires to be narrowed) onto the section “restored” by SSE’s contractors creating a churned up motorway.  This “restored” section is in the Drumochter Hills Site of Special Scientific Interest and off-track use of vehicles here needs consent by SNH.  (I will ask if it has been granted).  Unless the CNPA, SNH and SSE work together to stop vehicles being driven here the vegetation will never recover.

The first section of the restored track opposite Balsporran Cottages is a quagmire due to inappropriate vehicle use

 

For almost 2.5km there has been no attempt to landscape the ground of the former track into the contours of the hillside with the result that it will form a permanent landscape scar even if vehicle use was stopped

 

 

Access point opposite Balsporran Cottages has been used to create a shortcut to North Drumochter Lodge

The use of vehicles has been facilitated by the creation of access gates from the A9 enabling vehicles to be driven up onto the line of the Beauly Denny construction track, creating more erosion and preventing vegetation recovery.

 

The former track as it approaches the Boar of Badenoch from the north – in what sense is this a “temporary” track?

While the CNPA, to its credit has been very concerned about the poor restoration of this section of the Beauly Denny and the landscape scar which can be seen from the A9,  so far its focus has been on the quality of the vegetation reinstatement.

Some peat has been restored around the tower base but a far wider area has been left to “natural regeneration”.

Some of the poor restoration around the tower bases has been explained by CNPA staff as being a consequence of a failure to store vegetation properly during the construction phase leaving insufficient peat and vegetation to re-cover the area and of inadequate construction method statements 250615trackrestorationSSE (obtained through FOI).  This appears correct and the result is that more mineral soils are exposed and this will promote natural regeneration by different plant communities.  CNPA staff have suggested alternative solutions (see peatland restoration advice in link above) which so far appear to have been resisted by SSE.  One suspects the underlying reason for this is SSE does not want to incur more costs.

Section south of previous photo looking north

Its only as the former construction track approaches the Drumochter pass that the restoration work has attempted to remove the line of the cut and fill and mould the former track materials into the contours of the hillside.   While a short section of bank (on right) has been left exposed, other restoration on this short stretch has been more successful with the horizontal bench across the hillside effectively removed, making it much harder for vehicles to drive here.  Unfortunately the failure to store and replace vegetation means it will still form a very visible scar for some time.  Vegetation reinstatement, rather than landscaping, is the main issue on this short section of the former construction track.

There is one section between pylons near the Boar of Badenoch where no access track was constructed.

This photo shows what the hillside would look like if restored properly and provides a benchmark to judge the restoration.

The responsibility for restoring the damage to the landscape and what needs to happen

When planning consent was granted to the Beauly Denny the condition was that the section of ground covered in this post should be fully restored.   The CNPA to its credit has been very concerned about the standard of restoration and I have been able to tell from correspondence obtained through FOI (eg Mr D Bryden CNPA Response 26 August 2015) that the CNPA were not properly consulted about the original mitigation measures and that after a Board Visit they raised issues at a senior level in SSE.  This has had some effect and the CNPA is now involved in annual monitoring of the restoration.    Unfortunately however the 2016 restoration monitoring report, which I obtained through FOI (see here), seems to show that Scottish and Southern Electric had managed to confine discussion of the issues to vegetation recovery and not wider landscape issues:

 

2 RESTORATION
2.1 THE DEFINITION OF FULL RESTORATION
The definition of “full restoration” is not necessarily straightforward, particularly for complex vegetation communities. Totally subjective or objective approaches are likely to be problematic and it is likely that it will be necessary to utilise a combination of both subjective and objective techniques for monitoring affected locations.
The broad definition of full restoration is more straightforward than the specific detailed approach to establishing that it has been achieved. In simple terms, following construction of the overhead line, it would be reasonable to expect that the habitat should be restored to one that is of similar type, structure, species composition and of at least equivalent quality/value to that which was present prior to construction. In achieving this, certain changes to the vegetation, that may occur as a result of the construction, restoration procedures, or through natural change (or anthropogenic change) and which may be either beneficial or adverse; need to be fully taken into account.

 

Now vegetation is important, and I don’t want to minimise in any way the importance of the inputs from CNPA staff on this or the SSE classification of vegetation recovery to date as adequate when it is clearly not.  However, what appears to have been missing so far is full consideration of the landscape issues.

 

In my view both CNPA and SNH should now be calling on SSE to produce a proper landscape plan to restore the scar across the hillside caused by the failure to re-landscape the cut and fill track.  Such restoration should make off road use of vehicles along the line of the former construction track very difficult, while specific action should be taken to prevent the estate from driving vehicles onto the flatter area of moorland between north Drumochter Lodge and Balsporran Cottages.

 

SSE have the money to pay for this.  Moreover, where estates have gained permission for tracks to be retained, as north of Drumochter Lodge, this has saved SSE large sums which they would have had to spend on removing the tracks  At the very least they should be using these savings to re-invest and ensure proper reinstatement of other sections of track.  The landscape of the National Park deserves no less.

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

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

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

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

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

 

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

 

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

 

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

 

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

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

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

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

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

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

 

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

 

Hill tracks and protected areas

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

 

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

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

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

What needs to be done

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

 

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

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

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

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

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

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

 

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

September 8, 2017 Nick Kempe No comments exist
The concrete foundations of ski tows removed by truck from Coire na Ciste

The work funded by HIE to remove the ski infrastructure from Coire na Ciste, using trucks, has progressed apace in the last week.  The sheer amount of rubble pictured above provides evidence of the number of truck journeys that have been made up and down the mountain to the West Wall area without protective measures being taken (see here).  The Cairngorms National Park Authority were told hand tools would be used to undertake this work (judging by the amount of concrete this was never a remote possibility) and that the material would be removed by helicopter.

 

Further evidence has now become available to show the removal of the ski infrastructure has nothing to do with the need to clear up Cairngorm.  In their response to a Freedom of Information request on what they planned to spend at Cairngorm (which has been forwarded to Parkswatchscotland)  HIE included this:

 

Demolition of the Coire na Ciste café subject to funding; no price or programme yet.

 

In other words the £267k which HIE appears to have secretly awarded to McGowan to remove former ski lifts and snow fencing does NOT include the demolition of the Ciste Cafe, the biggest eyesore on the whole of Cairngorm.

On Tuesday HIE, which had up till now remained silent about the destruction going on at Cairngorm (I have still not even had an acknowledgement from their new Chief Executive, Charlotte Wright, asking for the “work” to be halted) put out a news release headed “CairnGorm Mountain clear up works” (see here).    This claimed that  “The removal of disused and decaying installations will enhance the appearance of the Mountain during the majority of the year when there is no snow.  In turn this will improve the experience of non-skiing visitors, an important market in making CairnGorm a year-round visitor attraction.”       So why then, if the experience of non-skiing visitors is so important, has HIE prioritised the removal of former ski infrastructure from Coire na Ciste?   This is hidden from the mass of visitors who go to Coire Cas  whereas the former Coire na Ciste Cafe blights the Ciste car park and is the one bit of Ciste infrastructure visitors are likely to see.

 

HIE has tried to defend the indefensible by saying they are leaving the lift wiring in Coire na Ciste in place.  This is undermined by their statement that  “The potential reinstatement of mechanised ski uplift in Coire na Ciste is to be one of the options examined in the review of the infrastructure at CairnGorm due to be commissioned by HIE once the tender process has been completed.”   So, why would HIE want to remove ALL the ski infrastructure (except the wiring and some of the fences in better condition) from Coire na Ciste BEFORE it completed a full review of infrastructure at Cairngorm?

 

What’s more the news release states:   “Other remnants including concrete bases at the former White Lady T-Bar, Aonach Poma and Fiacaill T-Bar lift lines are also being removed with the project set to be completed in Summer 2018.”   This strongly suggests that the old infrastructure in Coire Cas, which really does blight the visitor experience and can be seen by anyone on HIE’s white elephant funicular, is not going to be removed until next year.

The former White Lady t-bar base and associated mess as it appeared in August 2017 can clearly be seen from the funicular (top right).

 

 

In response to public criticism of the removal of snow fencing in the Ciste – which makes off-piste skiing there possible for much longer periods – HIE claims that “The stretches of snow fencing that are still in good condition will continue to serve skiers and the programme of fencing renewal will continue”.   They make no mention of the fact that the one thing Natural Retreats is supposed to be responsible for funding at Cairngorm is the replacement of the old chestnut ski fencing (this was confirmed in an FOI response to George Paton last year  “o/ All Fencing Timber.  Tenant’s responsibility”).    So, why then would HIE be paying McGowan to remove snow fencing from Coire na Ciste when it appears that Natural Retreats could have been replacing this?

 

All of this provides yet more evidence that the most likely explanation for the destruction of the skiing infrastructure at Cairngorm is that HIE and Natural Retreats wish to try and undermine the alternative proposals that have been developed by the Coire na Ciste group STC Statement 25 Aug 2017.docx.     In other words,  the alleged “clear-up” at Cairngorm is purely about the self-interest of HIE and Natural Retreats and has little to do with the interests of the local community or recreational visitors, let alone the landscape.

 

The evidence shows HIE cannot be trusted to undertake a proper review of the uplift infrastructure at Cairngorm.  Its unclear at present how much money they intended to spend on this but luckily there is now an option to spend it differently.

 

Yesterday, members of the local community in Aviemore and Glenmore launched an ambitious bid to buy the Cairngorm Estate from HIE under the Community Empowerment legislation  (see left).  The Scottish Government says it supports Community Empowerment – well, here is a test for them then.  Why not instruct HIE:

a) to give the money they would have spent reviewing lift infrastructure to the local community to undertake an independent review in conjunction with downhill and off-piste skiers

b) halt the proposals to develop a dry ski slope at Cairngorm (the proposed development would in any case pre-empt the review of ski infrastructure)?

 

The launch of a local community buy-out at Cairngorm will also be a test of the mettle of the Cairngorms National Park Authority.  In the new National Park Partnership Plan agreed by Ministers earlier this year, were some fine words about empowering local communities which however contained no concrete commitment to assist local communities to take over land.   The launch of the Aviemore and Glenmore Community Trust provides them with an opportunity not only to show they are prepared to put words into action, it would also allow them to address the ongoing destruction at Cairngorm.

 

The problem the CNPA faces at present is not just that the convention is that public authorities should not criticise each other in public, whatever the behaviour of the other agency (which might explain some of their silence about what is going on at Cairngorm) its one of Ministerial power.  Fergus Ewing, the Minister responsible for HIE and Rural Affairs, has until now appeared all powerful and has been a strong supporter of both the funicular and the An Camas Mor Development.    By comparison, his ministerial counterpart, Roseanna Cunningham, who is responsible for the environment and National Parks has appeared weak.  However she has in the past made strong noises about supporting community buyouts and this might just provide her, the CNPA and everyone who cares about the future of Cairngorm the means to put an end to HIE’s mismanagement.

September 3, 2017 Nick Kempe No comments exist
Letter Badenoch and Strathspey Advertiser 31st August

This letter in response to the current destruction of ski infrastructure in Coire na Ciste provides an excellent summary of how downhill skiing has been managed by HIE at Cairngorm.  It raises much wider issues of what are National Parks are for.

 

Also this week on BBC Highland there was a feature on HIE and Natural Retreats proposed dry ski slope above the Coire Cas carpark.  HIE’s vision for Cairngorm appears to have nothing to do with outdoor recreation.  At its centre is a dry ski slope and an expanded restaurant at the top of the mountain where people are isolated from the natural environment by built structures.

 

By contrast the Coire na Ciste group’s vision appears founded on the understanding that what is important to skiers at Cairngorm is the quality of the skiing and enjoyment of the natural environment.   Their proposals – which HIE appears hell bent on thwarting – are in essence an attempt to develop a vision which fits the National Park’s objectives:  conservation, enjoyment of the outdoors and sustainable economic development.

 

Now there are questions about whether downhill skiing at Cairngorm is sustainable in the face of global warming, questions that the Save the Ciste group has been trying to address.   However, I think they should be the starting point of public discussion about the future of Cairngorm.  If they turned out not to be sustainable, we should then move on to a debate about alternative uses which met the National Park’s objectives and are based on the natural environment.

 

The CNPA should be leading this debate and helping facilitate the development of a vision for Cairngorm.   Instead, it appears completely subservient to HIE.    The only way this is going to change is if the recreational and conservation organisations get together with the local community and develop an alternative plan for Cairngorm.

September 1, 2017 Nick Kempe 6 comments
Hydro construction track in Glen Affric, a National Scenic Area and Special Area of Conservation because of the Caledonian pine forest. No designation at present can stop a hydro scheme and in the Lomond and Trossachs National Park not a single area has been designated as important enough for there to be a presumption against hydro developments.

While the impact of windfarms on landscape make front page news – the latest being the predictable decision by the Courts to uphold the Scottish Government’s decision to give the go-ahead to the Creag Riabhach scheme in Sutherland  (see here) – hydro schemes rarely receive any coverage at all.   For a long time, most people who care about the landscape, appear to have been blinded to their impacts.  Hydro sounds such a good thing it must be.   More and more people I meet and talk to however are now beginning to believe the evidence of their eyes, particularly the blighting of the landscape with new tracks.

Looking south from Aonach Shasuinn, May 2017

Parkswatch has been highlighting the destructive impact that hydro schemes have been having in our National Parks and, after my post on Ledcharrie http://parkswatchscotland.co.uk/2017/08/31/whats-gone-wrong-ledcharrie-hydro-scheme/ its seems an appropriate time to inform readers how they can help monitor and document what is going on.  This is important because our politicians and decision makers will I am afraid put the wishes of landowners and developers first unless they are confronted with evidence they cannot ignore (and remember most decision makers hardly visit the hills and have probably never walked round a hydro scheme).

 

Following my walk with Members of the Munro Society to look at the Ledcharrie scheme (see here) I have been working with them to develop a hydro scheme reporting form. The idea is to assemble information about hydro schemes, the good, the poor and the unacceptable, which can then be analysed and used by the Mountaineering Council and others.   Munro Society Members have now visited three hydro schemes in the Loch Lomond and Trossachs National Park which I had not seen and sent me their report forms.

 

The Inverlochlarig hydro scheme

To give an example of how the form can help, here is an example for Inverlochlarig, in the heart of Rob Roy country.  Its well worth reading and I found it incredibly informative.   When working on the form we had not thought of inserting photos into it – reporters don’t need to do this – but Derek Sime had the good idea and in my view they  illustrate his  report brilliantly.

 

While no two people are likely to have the same response to a hydro scheme, whether they see it on the ground or recorded in a form, its good to be able to give publicity to what I think is a good hydro scheme in the Loch Lomond and Trossachs National Park (there are others).  The intake is discrete, the pipeline hard to detect and because an existing track was used for most of the construction, without any widening, there has been little further landscape impact, even from the tops of the hills.  The hydro scheme is not perfect though and the report form records some oversteep banks which are not revegetating, a short section of new track which is too broad and some abandoned pipes, still there three years after the scheme was completed.   I hope the LLTNPA will address these outstanding issues and have agreed with the Munro Society to send the form to the them but overall I agree with Derek, this appears an exemplary scheme.

I will cover other reports of hydro schemes from the Munro Society in due course.  Meantime…………

If you want to get involved…………….

The Munro Society is looking for more volunteers to report on hydro schemes across Scotland.  They have a list of schemes they have prioritised for reports and if you would like to help with these, you can contact them through their website – just put in the subject line Hydro Scheme survey.   There is nothing though to stop people reporting on schemes they come across in the hills and if want to do so there is a blank report form Hydro scheme survey v3.  You can return this to the Munro Society or if the scheme is in a National Park you can send it to nickkempe@parkswatchscotland.co.uk  (we have agreed to share information about schemes in our National Parks).      Don’t worry if you cannot fill in all the form, or only fill in part of it – even partial information will help the Munro Society prioritise sites for full surveys.  And photographs are as important, if not more important than words………….

 

The form that we have created came about because of the walk I did with members of the Munro Society to look at the Ledcharrie scheme.  We realised we needed to do something to capture information on the impact of hydro scheme and I am sure this will evolve over time.  Learning what to look out for though is greatly helped by walking round schemes with other people.  I am hoping to arrange another such walk, probably in the Loch Lomond and Trossachs National Park in the next month or two.  If you would be interested in this, please contact me at the parkswatch email with your contact details and indicating which day/s of the week are most suitable for you.

August 14, 2017 Nick Kempe 1 comment
On Day 2 on the Alta Via 2, one of the great walking trails of the world, we met three path workers, one with a pick axe and the other two with shovels, employed by the Puez Odle Nature Park, conducting routine path maintenance. In three weeks in the Dolomites I came across two other teams of pathworkers doing path maintenance, something which is unimagineable in Scotland. Local jobs for local people.

I have just returned from the Dolomites to find extensive media coverage on how Scotland is failing to provide the infrastructure necessary to support visitors.  On Skye, there are claims that the island has reached the limit in terms of the number of visitors it can sustain (see here), while in Orkney suggestions of a tourist tax (see here) on luxury cruise liners to fund infrastructure have been predictably dismissed under the neo-liberal mantra that all tax is bad.    I suspect most Italians would be astonished by the way these debates are framed in Scotland.   The evidence on the ground from the Dolomites is that far more money is being invested in tourism infrastructure than in Scotland and there are far more visitors, with consequent benefits both to people and to the economy.   We saw signs saying tourism in the Dolomites is worth £50bn a year and, while this is considerably boosted by downhill skiing, it dwarfs the latest figure for tourism spend in Scotland of £8.9bn.   In this post I will consider how investment in footpaths in Scotland compares to the Dolomites.

 

Back in July, in a very welcome article in the Scotsman (see here) Grant Moir, Chief Executive of the Cairngorms National Park Authority, raised the need to think about how we pay for paths in our National Parks.   This in my view is exactly what our National parks should be doing – instead of pretending all is rosy and that they are managing on ever decreasing budgets – they should be articulating a new vision for the future and how this could be funded, which could then incidentally be adopted by other places like Skye and Orkney.

 

Unfortunately the heading of the article (which was no doubt inserted by a sub-editor)  – “freedom to roam is a costly business” – reflects the prevailing negative stance towards access in Scotland by the establishment, which sees everything in terms of cost not opportunity.    In fact, the amounts Grant Moir referred to are tiny.  So, the CNPA has spent £10m on paths in 15 years – that’s just £666k a year – and requires at least £500k a year to maintain paths.   Compare that to the £3bn that the Scottish Government has committed to pay for the dualling of 80 miles of the A9.   If just 1% of that – £30m – were spent on paths along the A9 corridor over the next ten years the CNPA and neighbouring local authorities would be awash with money to spend on paths.  Instead, the CNPA at present has to rely on Heritage Lottery funding, the £3.2m awarded in 2015 over 5 years for the Mountains and People project which covers both our National Parks.

 

Paths in the Dolomites

 

The path network in the Dolomites is far more extensive than what we have in Scotland and this is partly for historical reasons.

Military path in the Belluna National Park

 

Most people are probably aware that the Dolomites was the setting for major battles in the first world war in which 750,000 Italians died and which saw an extensive network of paths/tracks and via ferrata constructed high up in the mountains.    These now form the base for the mountain path network.   By contrast our own military roads, with a few notable exceptions such as along the West Highland Way, tend, because of their location along the floors of straths, to have become part of the trunk road network.

Path in woods above Predazzo – still used to extract timber.

The Dolomites also, however, have far more paths lower down.   I was based for a time in a lovely small town called Predazzo which is surrounded by forest.   I had no map to the area but no need of one.  Whatever way I left the town – and I did four runs in four different directions – I came across a multitude of path options.   The paths in the woods appear to exist because local people have worked the forests for centuries – the commune that runs Predazzo is 800 years old – a contrast to Scotland where people were cleared from the land and few paths were needed for work purposes, the main exception to this being our fine stalking paths.  These are thin on the ground however in comparison to the historic path legacy in the Dolomites.

Mule track onto Pale San Martino, reputedly constructed by a Count so his disabled daughter could experience the amazing scenery

The Dolomites, and indeed many other places in Europe including England, have had a head start over Scotland in terms of path infrastructure.   This was recognised in the discussions which led to our access legislation which identified a need for a more extensive path network: hence the provisions of the Land Reform Act about the creation of core path networks.   Unfortunately due to neo-liberal thinking, in which it is held a self-evident truth that nothing should be provided for free, and austerity the aspirations for a comprehensive path network have never been delivered (despite the efforts of many good people).     Instead our National Parks and other access authorities are left scrabbling for money.   This is quite a contrast to what I saw in the Dolomites.

Path, held together by logs, up scree slope south of Mulaz Hut – the nature of the ground in the Dolomites means that many paths would not exist without human ingenuity and engineering
An additional expense in Italy is the protection of paths with cabling – we have no equivalent in Scotland – but the creation and maintenance of such paths requires investment
A constructed log path from Rifugio Firenze/Regensburger Hut leads up this gully onto the Stevia plateau

While in the Dolomites I stayed in the Firenze Hut twice, the first as part of the Alta Via 2 when I walked up this path.   On my second visit to climb we found it closed, part of the path had been swept away in a great storm.    However, unlike the Cairngorms where – as Grant Moir states – people are still trying to find money to repair the damage from the great floods on Deeside, signs had gone up immediately saying what had happened and there was evidence the path was being repaired.   What I think this demonstrates is that path maintenance is a priority in Italy in a way that is unthinkable in Scotland.

Evidence of recent maintenance work could be seen along many paths: here a drainage hole has been created in order to create a sump for water running off a path

So why is this?  Part of the explanation I think lies in the power to make decisions and budgets to implement them being far more devolved than in Scotland.  In most of the huts we stayed in we paid a small tourism tax which is used to fund infrastructure locally.   Behind this though is a general appreciation that people want to experience the fantastic landscape of the Dolomites and what this requires is for people to be able to get out into those landscapes in the way they want.

Walkers coming off the lift from the summit of the Sas de Pordoi to walk over the Sella Plateau.  Many walk from here over to the summit of Piz Boe one of the 3000m peaks in the Dolomites and a superb viewpoint. The photo  illustrates the sheer numbers of people walking in the Dolomites and while the rocky terrain here can support these numbers, it also provides an illustration of the potential impact on the Cairngorm environment were the funicular ever to cease to be a closed system.

One of the best ways to do this is by providing paths.     This is backed by some interesting research (see here) which shows that satisfaction with the landscape is the biggest single factor influencing tourism spend:

 

 

 

 

A warning to the Loch Lomond and Trossachs National Park Authority who are allowing much of the landscape of the National Park to be trashed through the creation of unnecessary new and poorly constructed forestry and hydro tracks.  What they should be focussing on is the creation of a quality path network.

An example of our failure to invest from the Loch Lomond and Trossachs National Park

The contrast between Scotland and the Dolomites is illustrated by these photos from Arrochar, which I received from reader Stephen Pimley, on arriving back in Glasgow.   Its only a tiny section of path, funded by multiple agencies, but I believe it tells an important tale.

 

Photo credit Stephen Pimley

 

Here is the problem in Stephen’s own words:  “I see tourists standing in a state of puzzlement in front of the overgrown brambles and conifer hedge.  They stand at the side of the road and move on………………I have raised a work request on the Argyll and Bute council but previous requests have been ignored.   Hopefully the fact that there are multiple ‘partners’ involved won’t lead to one of those desperate “its not my job!” situations”.

Photo Credit Stephen Pimley

The basic problem is that there is almost no money available for basic path maintenance.   Most of the paths through dense vegetation like this in the Dolomites are strimmed to keep them clear for walkers.   By contrast our public authorities seem to expect that volunteers should do this and, while there is a very active and committed group of volunteers in Arrochar – where the Community Council has been long trying to improve the local amenity of the area and without whom its doubtful whether any of the attempts to clear up the beach at the head of Loch Long would have happened – I have been informed most of these volunteers are now in their seventies.     They should not be having to do this.

 

Is it really too much to aspire for that there should be one part-time footpath maintenance worker available to every community in the National Park?    This would help keep young people in the villages, as happens in Italy.  It could even provide all the pathwork trainees on the Mountains and People project jobs in the longer term.   Instead, what is happening in our National Parks, is that pathwork is funded by one source of temporary funding after another rather than being treated as a core function of National Parks.

What needs to happen

  • I would like to see our National Parks learn and compare themselves to places in other countries, whether National Parks or not (only a small proportion of the Dolomites are designated as National Parks).
  • Grant Moir was right, a permanent solution to how we invest in paths in National Parks – and elsewhere in Scotland – needs to be found.   Both our National Parks should be taking a lead on this and this should include consideration of what investment needs to take place to enable Scotland to catch up in terms of path provision as well as how paths can be maintained.    Both our National Parks have made tentative steps in this direction but they should be using the evidence from places like the Dolomites to articulate a far more comprehensive vision.
August 2, 2017 Nick Halls 1 comment

By Nick Halls, resident of Ardentinny

This is the fifth in a series of articles about forestry in the National Park near where I live (see here)

The impact of windthrow

Forest ride obstructed by windfall.

 

The value of the trees relative to the difficulty of extraction and the dangers posed by windblown trees makes harvesting from areas like this problematic. In what seems to an amazing piece of ‘double talk’ these areas are to be retained as ‘amenity’ woodland.

 

During preceding forestry cycles, clear linear gaps were left between blocks of woodland. They are referred to as ‘rides’. Techniques of felling and extraction have become more mechanized so these no longer seem to be necessary, so current replanting is denser and without any equivalent means of access.

 

During previous cycles, the forest rides were an important means of informal access, to the open hillside above.

Managing woodland open space for wildlife – according to Forestry.gov.uk

What is a ride?

For the purpose of this document a ride is a linear open space within a wood derived from the need for access. Rides may have a hard surfaced track making up part of the width or more commonly are unsurfaced. The ride is usually made up of several zones. Most commonly ride consist of a central grass zone with a mixed herbaceous and shrub zone on one side or both sides.

 

The benefit of managed rides and open spaces

Sensitive management of open habitats introduces greater habitat diversity.

This encourages a larger range of species, adding diversity and additional interest for all types of recreation and sporting activities. Many species make use of the edge habitats for feeding due to higher herb layer productivity and larger invertebrate populations. A greater number of species inhabit the first 10metres of any woodland edge or ride edge than inhabit the remainder of the woodland’

 

Rides commonly became invaded by rhododendrons, fallen branches and wind blow, but it was possible to find a way through or around obstructions.

 

Obstructed water course, in a deep gully, where Rhododendron will reinvade. The debris has accumulated over decades, and demonstrates how little is done to develop the amenity value of the forest estate. Areas like this are not really suitable for modern mechanized clear fell and extraction methods.

Obstructed scenic water course

I have experience of impenetrable natural woodland, from trying to access open hillside in Canada, Brazil, Japan and Patagonia. This sort of scene seems natural, but it is within 300 m from a public road, and five minutes from my home. In the midst of a State managed forestry plantation, in a National Park, in an area designated as amenity woodland.

 

“[A woodland managed primarily for amenity rather than for timber, often with public access for outdoor pursuits such as walking, mountain biking and orienteering, or alternatively managed for game.]”

 

It could be a very scenic, all age and abilities walk, that would economically enhance the visitor experience.  Investment in such projects, during the 1980’s, gave employment, if only temporary and seasonal, and restored access to Pucks Glen, now one of the visitor attractions of Cowal.

Pucks Glen path.
Attractive exposure of rock revealing underlying geology

Created in the 19th Century, completely blocked by accumulating wind blow in the mid 20th Century, cleared and restored, by young local unemployed supervised by foresters during Y.O.P. schemes of the 1980’s

Impenetrable nature of the forest floor, replicated throughout the woodland close to habitation. Nobody, except the fit and determined, are likely to enter the forest, but anybody not used, or unable, to walk off tarmac roads is unlikely to try. Neighbors seldom venture into the forest, if at all, they are too fearful of getting lost or slipping and injuring themselves.

 

The underfoot conditions and obstructions distorts visitor feed-back, by eliciting from visitors requests for tracks to enable them to enter the woodland. I suspect this does not mean artificial, over engineered circular tracks, with deep boggy side drains and overgrown banks, but ‘brashed’ [side branches removed to above head height] woodland and clear forest floors in the immediate vicinity of parking places and scenic areas. This would allow people to go for a wander through the woods.

 

Clearing the forest floor and making it more accessible would probably be cheaper, and keep people more permanently employed, than creating circular tracks, which are difficult to get off, and are then not maintained.

 

Acidification of aquifers.

 

It was established in Scandinavia some time ago that acidification of the aquifers draining into lakes and rivers, arising from planting conifers close to the banks of streams, eventually resulted in the decline of fish stocks. The acid flushes resulting from heavy rain washing through foliage and forest floor litter, causes fish eggs to become toughened resulting in failure to hatch.

 

This has been recognized, but not acted on except at the headwaters of some tributories to major streams and rivers draining into waters popular with anglers. Little has been done locally, so angling seems to be less and less popular as there are so few fish. Migratory fish like salmon and sea trout have disappeared from the River Finart [other factors may have contributed to this such as netting the migratory fish as they swim up the coast].

 

A small experiment in restoration

An attempt to clear historic wind blow, to improve the quality of water contributing to a garden pond, which is so acid nothing seems to live, and toad and frog spawn never hatches. The effort has apparently improved the situation, as this year for the first time in thirty years, mallards visited the pond and found something to eat!   Note improved bio diversity along cleared stream edge.

Clearing the stream of debris and obstructions permitting the flow speed to increase, deepening the stream bed, lowering the water table and dried out the surrounding area, which is no longer an acid sphagnum bog. This improved the water quality of the pond, and improved bio diversity of the banks of the stream. It also restored access to the woodland.

 

The experiment convinced me that the manner in which forestry operations are carried out fundamentally damages the micro environment and degrades the full potential bio diversity. It is not necessary to watch a program about loss of habitat in some equatorial forest, it is happening in the artificial wet desert on our doorstep.

 

Post script

Current forestry practice has abandoned any activity that might encourage informal access within the woodland, between cycles of planting, thinning and clear fell. Access to the actual woodland, and possibilities of finding a way through it to the hillside above, has deteriorated.

 

Woodland in the immediate vicinity of habitation, or surrounding visitor attractions and facilities, described as ‘amenity’ woodland is virtually inaccessible and uninviting. Little if any attention is paid to the potential for informal active outdoor recreation.

 

View south from sandy bay to Ardentinny village

In many localities, the bio diversity is artificially restricted, and access possibilities of any description deteriorating, and in no way compensated for by walking along industrial forestry road infrastructure, from which it is difficult to escape.

 

The dense forestry is treated as a scenic back drop for visitors, rather than an opportunity to encourage recreational activity!

July 17, 2017 Nick Kempe 2 comments
The black line marks the approximate line of the proposed construction track which the developer wishes to be retained permanently seen from the upper slopes of the walkers path from Benmore farm to the summit of Benmore

On 7th July, an application for a new hydro scheme on the slopes of Ben More by Crianlarich, one of the highest and best known Munros, was validated on the Loch Lomond and Trossachs Planning Portal  (see here) (or if the link does not work go to http://www.lochlomond-trossachs.org/planning/planning-applications/find-an-application/ and search for application Ref 2017/0119/DET or on Benmore farm).    On Friday I went to have a look and have now submitted an objection to the application as currently proposed (appended to end of this post).  This post is about why the new Benmore farm proposals are very different to the hydro scheme on Benmore burn which was completed  last year and why  I have objected.  I hope people reading this will be encouraged to consider doing so too (its easy to do, just look up the application and go to the comments tab which allows people to support, object or comment on an application).   The application is open for comments until 28th July.

 

The Benmore burn hydro scheme

This hydro scheme, which became operational in 2016, is one of the best I have seen in the National Park.

View of the intake from north west shoulder Ben More.

The “track” marks the line of the buried pipeline but generally the vegetation is recovering well. The burn was diverted to build the intake dam and the vegetation on the ground above the diversion channel has already recovered to the extent you would not know it was there.

The construction track was along the line of the pipeline and was removed completely. The ground is recovering well. The existing hill track – bottom right – was not used for the construction although it runs round the hill not far from the intake.

One thing I really liked about the intake was that instead of the normal concrete retaining wall, the development has embedded boulders in concrete.   This creates a far more natural form.  You can also see the browner rock below the intake which appears to mark the former “normal” flow levels of the burn.  The hydro schemes are having a significant impact on river flows which will affect their ecology.    I don’t believe we really know yet what the permanent impacts might be.

When you approach the intake though the most obvious feature is the metal fencing – contrary to Park guidance on use of natural materials (but is it really necessary?) –  and the Lomond blue pipe.  Its a shame that the left side of the intake has not been finished like the right had side but it does show, I think, what can be done.   Well done somebody!

The recovery of the ground above the pipeline and construction track is not as good as it might have been because vehicles have been driven over land which is far too wet to support them.

It was good too to see that the dyke through which the 7m wide construction track had been taken had been narrowed (a contrast to the Falloch and Ledcharrie (see here) tracks) and restored to a high standard.  It is possible to construct things of beauty in the hills!   I must say I am not sure about the gate, even if its not used by vehicles its likely to encourage – and there were a fair few boot marks – a more direct walking route up the glen over what is very wet ground.     So, some reservations, but generally this is a high quality scheme with very little snagging left to do – if only all schemes in the National Park were like this!

The new proposal

The map shows – more accurately than my amateur attempt in the top photo! – the two sections of new track, the powerhouse, the location of the pipeline and the intakes

What prompted me to visit the location the scheme was the proposal to retain the new access tracks.    Having removed the construction tracks to the intake in the Benmore Burn scheme, I wanted to understand why Benmore Farm were proposing to retain the construction tracks to the new intakes.   Part of me reckons that this is because since 2013, when the first scheme was approved, the LLTNPA as Planning Authority have moved from a position of assuming tracks should be removed to allowing them to remain everywhere.

Part of the Allt Essan hydro scheme on the north side of Glen Dochart – powerhouse centre

So, if other people are getting away with it, why should Benmore Farm follow best practice?     That’s why people need to take a stand.   The proliferation of hill tracks is destroying the landscape in the National Park – and indeed across Scotland – and those who care about the landscape need to put a stop to this.

 

The Design Statement gives two reasons for keeping the track, the first to help the shepherd/ess, the second to “provide for walkers who may wish to climb Ben More along Sron nam Forsairean”.   The second claim is nonsense.   Anyone wanting to walk up the Sron would normally do so from the north east side of Ben More, not from Benmore farm, and in any case walkers don’t need a 2m wide track (for that is what it is proposed to retain) which stops half way across the hillside.   In relation to the first, shepherding is being cut like everything else and shepherds are under pressure to do more in less time.  However, the Design Statement states the cost of scheme is approx £530,000 and annual revenue estimated at c£75k and the scheme to operate for 100 years.    In other words it could make over £6m profit in its lifetime, ample to pay for reinstatement of track and to pay the shepherd to walk up to the intakes occasionally

Having visited the site I have become more concerned.  The construction track will cut across the hillside from just after the top of the last zigzag on the existing track to just above the top of the plantation.  This is steep ground.   It means cutting a great bench into the hillside.  There are diagrams illustrating this in the application but no indication of how long each steep cross section will be:

The applicants state that they will set out in the Construction Method Statement which would follow approval being given to this scheme how this track will be constructed.   I don’t think the Park should accept this.  The landscape impact of tracks across steeper slopes is all too evident on the other side of Benmore Glen.

Forestry track Creag a Phuirt

There are huge challenges as to how to store the soil and rock excavated to create a track across steep ground and then restore them.   I am concerned one reason why the developer may be  proposing to retain the track is they know it will be very difficult to restore such ground.

 

This is not just a landscape issue.  The top section of new track and intakes are within the Ben More Site of Special Scientific Interest and all works affecting the soils and vegetation are what are known as operations requiring consent – for complete list of Ben More  SSSI ORCS site190-doc28.   That is an additional reason to be concerned about the upper access track.

A very rough indication of location of track and intakes. The four intakes are situated on burns which flow into the two plantations (the central burn is not part of the scheme).

While four intakes are proposed, and the plan states they will be small, there are no photomontages in the landscape assessment of how they may look like in the landscape.   This seems to me to be a failure. The landscape assessment says the intakes will not be seen from the summit of Ben More, but that is because its just over the brow of the steep slope, they are likely to be visible for much of the way up both the north east and north west shoulders of Ben More.    The current plan is for concrete intakes – no mention of incorporating stone as was done on Ben More burn.  Another step backwards.

 

Why its important to comment on this scheme

I started to look at hydro scheme planning applications after most of them had been approved and what is striking is that I have not yet come across a single objection to an application – not even the heart of Glen Affric!     Ordinary people have just assumed hydro is good while our public agencies, including the National Park Authorities, are under pressure from the Scottish Government to do nothing which gets in the way of the hydro gold rush (most of the financial benefits of which end up in the City of London and nowhere near the people struggling to make ends meet in the Highlands).  If no-one objects, our planning authorities, who are under great pressures, simply approve what is put in front of them.   We are now reaping the consequences of poorly conceived and poorly executed hydro schemes across Scotland.

 

Its time therefore to make a stand and what better place than in a National Park which is supposed to have special regard to our landscape and wildlife.    I am not against hydro schemes but this must not be at the expense of the landscape and at the very least, in this scheme, the construction track should be fully restored but I think the Park as Planning Authority should be seeking more information about how the track could be constructed and then restored on this ground.   A copy of my objection is pasted below.

 

NB My objection should appear on the Park’s website BUT a previous comment on this scheme, dated 4th July (also appended), which pointed out that there was no mention on that date of this proposal affecting a SSSI, has not been published, although that omission has been rectified.   Instead I was told:  “Please be assured however that I am aware of the constraints on the site and all relevant consultees were consulted when the application was validated.”   I guess if the LLTNPA  had published my comment, someone might have used their failure to list the “constraints” affecting the site as a reason to invalidate the application, or maybe the just don’t like it when parkswatch picks up on mistakes?

Commenter Type: Member of Public
Stance: Customer objects to the Planning Application
Reasons for comment:
Comments: Unlike the recently completed hydro scheme on Benmore Farm where the construction track was removed, in this case the applicant wishes to retain it which would have an adverse impact on the landscape of Glen Dochart. The justification for keeping the track is it would help the shepherd and provide for walkers who may wish to climb Ben More along Sron nam Forsaireana – actually walkers wanting to walk up the Sron do this from the north east and with £75k a year income the farm has plenty of money to employ the shepherd/ess to be a little longer on the hill. There is no proper assessment of retaining this track – eg no photomontage – which would be highly visible from slopes below Ben More summit. It is important therefore that the LLTNPA adheres to its policy guidance on renewables and insists if this hydro goes ahead the track is restored.
There are other issues with the scheme though: there are views from the summit down the north slopes of Ben More to the intakes (and to proposed track) and, while relatively small, they may be visible from above. Impact should be properly evaluated and could be reduced if intakes clad in natural stone (instead of plain concrete as proposed). In order not to impact on the landscape these schemes need to be as near to proper run of river schemes, with small intakes, as possible. In addition, the line of the construction track is across what is a steep hillside – as depicted in steepest cross section. For a construction track to be created here will require major engineering which is likely to be very challenging to restore (both to restore the materials which have been removed and then replace them). The Developer is suggesting this should be dealt with by Construction Method Statement post planning permission, I believe the Park needs to be confident the land can be fully restored before granting any consent.

 

Comments were submitted at 11:52 PM on 04 Jul 2017 from Mr Nick Kempe.

Application Summary
Address: Benmore Farm Crianlarich Stirling FK20 8QS
Proposal: Construction of a run of river hydropower scheme
Case Officer: Julie Gray

 

Comments Details
Commenter Type: Member of Public
Stance: Customer made comments neither objecting to or supporting the Planning Application
Reasons for comment:
Comments: There are no constraints listed against this application at present although the upper pipe and track appear to be within the Ben More SSSI. Could you please confirm whether this is case or not? Among Operations Requiring Consent for the SSSI are alterations of watercourses and construction of new tracks and drainage both of which are included in these proposals
July 4, 2017 Nick Kempe No comments exist
The new track runs round the head of Glen Prosen – here looking towards Bawhelps

During a round of the Glen Prosen watershed 10 days ago, I came across a bulldozed track on the plateau at the head of the Glen which appears to be just inside the boundary of the Glen Isla Estate and therefore created by that estate.    The lack of vegetation on the surface – on what is a relatively fertile soil – and the state of the turves which have been piled by the track suggest the track is relatively recent.   There is nothing about this track on the Cairngorms National Park Authority planning portal and it therefore would appear to have been constructed without planning permission.

The new hydro tracks in Glen Prosen viewed from Mayar. The boundary of Wild Land Area 16 is at Kilbo, centre right, where the track meets a burn flowing in from the right

I had not realised when blogging about the Glen Clova and Glen Prosen hydro tracks (see here)  that the head of Glen Prosen was within Wild Land Area 16 “Lochnagar and Mount Keen”.   There is a presumption against development in wild land areas – even more reason, if more were needed, for the CNPA to taken enforcement action and ensure the “temporary” hydro access tracks are removed.

Glen Prosen runs parallel and left of Glen Clova. Most of the new track across the plateau appears to be in Wild Land Area 16.
View to Dun Hillocks from east of the Mayar Burn. Lochnagar is on the right.

After crossing Driesh and Mayar, we met the track near the Mayar Burn.  While I was tempted to follow the northern section towards Dun Hillocks and Finalty Hill, I was not sure my legs would take it (first longer run of the year!).   It was difficult to see how far the track goes because of the rolling nature of the landscape here which is well described in the Wild Land Statement (see here) which was published last year:

 

At a broad level, the landform tends to be convex, limiting visibility up and down slopes. This means that, from the hill tops, neighbouring glens are screened and there is a horizontal emphasis of open views directed over successive tiers of ridges and tops extending far into the distance and contributing to a sense of awe.

 

What is clear is that it penetrates well into the Wild Land area 16.  I couldn’t tell either if it enters the Lochnagar and Deeside National Scenic Area, the boundary of which runs in a straight line between Mayar and Finalty Hill  (any information on this, particularly photos, would be welcome).

The plateau, the head of the Mayar burn is the lower ground on far right of photo, the track just to the left of the photo.  While the grouse butt is well disguised, it indicates that this track was created for “sporting” purposes and therefore should have required full planning permission.

The creation of the track has removed much of the challenge of navigating across what was a featureless area of plateau.  If you have ever tried to walk between Tom Buidhe and Mayar in the mist you will know what I mean.   This quality of the plateau, so important to adventure, is also well described in the Wild Land statement:

 

Despite a mixed composition of hills and undulations, the simplicity of the landform and land cover at a broad level means individual peaks do not tend to stand out and it can be difficult to estimate vertical scale or distance within the landscape. This makes navigation challenging upon the hills and plateaux, especially in low cloud, thus increasing risk.

Looking towards South Craig at head of Glen Prosen.  The track is intermittent in the sense that it is a mixture of track eroded by regular vehicular use and new sections where the turf has been completely removed.

Because its intermittent, although the constructed sections predominate, its possible that the track was not created all at once but over time.

View across track to Mayar.  The creation of drainage channels adds to the mess and impact on vegetation.

The track has been created by a digger scraping off the turf and dumping it by the side of the new track.  The positive thing about this is it should make restoration of the track quite simple.  All the estate would have to do is replace the turves and soil onto the bare surface.

 

Intermittent section of track up Bawhelps

The older vehicle erosion shows that its not just constructed tracks which are the problem – its vehicle use.  The CNPA should be addressing the issue of vehicular use on higher ground.    A start would be to restrict the type of vehicles that can be used, ban heavier vehicles like landrovers and just allow quad bikes which are much lighter and, if used carefully, cause much less damage to vegetation.  This could be done through the creation of conservation byelaws.

Looking southwest from Bawhelps, Badundun Hill and Mount Blair in distance.  The track comes up to Bawhelps over Midhill from Glen Isla.

We didn’t follow the track over Mid Hill and so did not ascertain where it started (again photos would be welcome) but it appears most of it lies within the Cairngorms National Park boundary.

View along new spur to track which runs south east along Broom Hill, Craigie Thieves behind.

There is a short spur to the track down Broom Hill, which unlike other sections of track has been created by importing aggregate and dumping it on top of vegetation.  This section of track will be much harder to restore.

The spur then turns into a vehicle eroded track before ending completely before the bealach between Broom Hill and Craigie Thieves

Had I not stopped to take photos, we would have made fast time from the Mayar Burn to the bealach with Craigie Thieves.  After that, the going was much slower and although the hills were much lower, they provided a wilder experience even after we had crossed out of the National Park.

Looking towards Eskielawn outside the National Park boundary.

Although there was a fence, the absence of track made a huge difference to the experience,  altogether wilder and hard on the legs, and not just because I was forced to play the role of aged deerhound trying to keep within sight of my mate!

 

Until, that is, we came to this monstrosity on the Hill of Adenaich, well outside the CNPA boundary, and the responsibility of Angus Council to fix.     Sadly, whether these tracks are created or not appears to have very little to do with the Planning Authority, its all determined by the landowner: most create tracks, some don’t.  It would be good though if our National Parks became exemplars of good practice and the CNPA by its actions inspires Angus Council also to take action.

 

What needs to happen

 

I have reported the track featured here to the CNPA, asked them to confirm whether they were aware of it not and stated that it appears to have been constructed for sporting purposes and therefore should have required full planning permission.    In my view the track should be removed.   The CNPA in their new Partnership Plan, to their credit, have stated that there will be a presumption against new hill tracks within upland areas in the National Park.  This one enters a Wild Land area to boot so there is every reason for them to take action.   If the CNPA act fast, much of the damage could  be restored quite quickly (because the turves removed to create the track are still usable) so I would urge them to do so.

 

Whether the Glen Isla estate, which straddles the National Park Boundary, will co-operate remains to be seen.   While the Glen Isla estate appears on the CNPA map of estates which lie within the National Park (see here) there is no estate management plan.  The CNPA initiative to get estates to publish management plans was a good one but has been ignored by many landowners.  In my view the publication of management plans for all estates within the National Park should be compulsory and such plans should include maps of all existing tracks (and where they end) as well as a statement from each estate about what vehicles they use off track.  This would it much easier for the CNPA to take enforcement action in cases like this.

June 27, 2017 Nick Kempe 1 comment
Start of Clova hydro track which cuts back right to two hydro intakes, one on the Corrie Burn and the other on the Brandy Burn.                                                                                                                   Photo Credit J Neff

Glen Clova Hydro Construction Track

 

A week before taking action against the Cluny Estate track (see here)  the Cairngorms National Park Authority issued a planning contravention notice against the owners of the Glen Clova estate for failing to remove the temporary hydro construction track behind the hotel.  This is another very significant action from the CNPA and should be welcomed by all who care about the landscape.   First, because the CNPA approved the hydro scheme on the basis that the track should be temporary – its permanent access tracks which cause the greatest landscape impact with hydro schemes – so well done to the CNPA for putting the landscape before profit.   Second, because the CNPA are now prepared to enforce the conditions of the original planning application, unlike the Loch Lomond and Trossachs National Park Authority who caved in to the Glen Falloch Estate when they applied to make the temporary construction tracks there permanent (see here).

 

My thanks to Jojo Neff, who has been monitoring hill tracks and passed on some photos (above).  Dismayed by what these showed, on Saturday I took the opportunity to have a look myself as part of a run round the Glen Prosen watershed.   In the course of that I came across another  temporary hydro track at the head of Glen Prosen which has also not yet been re-instated.

View from North East ridge of Coremachy. The track forms a large zig zag before traversing across the hillside to join the path to Loch Brandy and the second intake located there.

The track is visible from many points along the 8km ridge between Coremachy and Driesh.   I was too far away – and without binoculars – to be able to tell if the horizontal scar across the hillside is still a track (would welcome information on this) or has been re-instated but to a very poor standard.   The uphill section of the track is far more prominent than the lower part of the footpath to Loch Brandy.

A close-up shows that while the uphill section of the track has been narrowed – there was no planning permission for this – the quality of work has been poor
The pipeline, which you can just make out centre of photo is not an issue and will have blended into the landscape in a couple of years.

The planning application was approved by the CNPA planning committee in 2010.   There is no information on the CNPA planning portal at present following the decision letter.  As a result there is almost no information about the construction track.   All I could find was a reference to “temporary access tracks” in the Committee Report and this map which shows the pipeline, not a track, and indicates therefore there was no proposal for a permanent track:

The Decision Letter from the CNPA required the developer to produce a Construction Method Statement, which would have provided information about where the temporary access track was to be sited and how it was to be constructed and the ground then re-instated, but this information is not public.   Nor is there any information on the planning portal about when the work started, when it was “completed” or subsequent correspondence between the CNPA and the Developer.    I will ask for all this information under FOI but in my view the CNPA’s reasons for taking action should be public (and should not be limited to a one line entry on their Planning Enforcement Register).  It would also be in the public interest to know just how long negotiations had been going on before the CNPA decided to take enforcement action.

 

The owner of the land and developer of the hydro scheme appears to be Hugh Niven, who runs the Glen Clova Hotel, the Glen Clova farm – which has been supplying Albert Bartlett with potatoes for over 25 years (see here) – and Pitlivie Farm, near Carnoustie in Angus.  This according to information on the internet is the site of one of Scotland largest agricultural roof mounted PV installations.   An interest in renewables then.

 

Mr Niven had a run in with Angus Council Planning in Glen Clova just before the Cairngorms National Park was created.   In 2000 (see here) Angus Council initiated enforcement action against Mr Niven because he had created a new loch in the Glen without planning permission and there were sufficient safety concerns about the earthworks that the public road was closed for a time.  Two years later Mr Niven applied for, and was granted, retrospective planning permission for the works (see here).

 

There are lessons for this for the CNPA.  First, this is not the first occasion Hugh Niven has ignored planning law.  In this he is not unusual – many landowners still see planning authorities as imposing unwelcome restrictions on their ability to manage land any way they wish.  Second, back in 2000 it appears that Hugh Niven argued that what he had done was justifiable and the risk is that he will now do so again which will lead to years of wrangling.    While the creation of a loch might have been acceptable on landscape grounds, the permanent retention of this track is not and the CNPA therefore needs to avoid drawn into negotiations about how this scar could be ameliorated and take a stand.   This track needs to be removed and like the Cluny track, is therefore a fundamental test for the CNPA.  They deserve the support of everyone who cares about the landscape in our National Parks.

 

As in the Cluny case, it appears that the developer does not lack resources: the latest accounts for Clova Estate Farm Ltd doesn’t show income (because they are abbreviated accounts – a fundamental issue in terms of business transparency) but does show the business has total net assets of £8,037,710.   Hugh Niven therefore has the resources to pay for the re-instatement of the hydro construction track.

 

Glen Prosen hydro track

The hydro construction tracks are on left half of photo with the bare ground behind resulting from clearfell of a forest plantation which appears to have taken place at the same time the hydro scheme was constructed

After completing the ridge on the west side of Glen Clova to Mayar and after coming across  a new bulldozed track on the plateau leading from Bawhelps to Dun Hillocks (which I will cover in another post) the head of Glen Prosen is scarred by new tracks and clearfell north west of Kilbo.

View from Broom Hill, Driesh in background

On returning home I checked the planning report from 2013  which made clear that the construction tracks would be temporary:   “Beyond the powerhouse there will be a temporary access road for construction to reach both intakes.”   Again well done to the CNPA for putting landscape before profit.

The Committee Report also concluded:

Landscape and Visual Effects
40. The landscape impacts of this proposal are minor, given the scale of the development and the location in the upper Glen Prosen. Conditions relating to the construction phase of the development have been proposed to minimise any short term impact. In addition, the set of mitigation measures proposed are likely to have a positive impact on the development site in the long term.

 

The trouble is at present the landscape impact is anything but minor, as the photos show, and this is mainly because the construction tracks have not been removed, although the clearfell has added to the destruction.  There were no signs of machinery on site and it appears therefore that the Glen Prosen estate, like the Glen Clova estate, thinks the work is finished and simply hopes to avoid the expense of re-instating these tracks.    It will be much easier for the CNPA to take action if they show resolution in addressing the Glen Clova track.  The message to landowners will be then loud and clear:  you cannot afford to ignoring the planning rules in the National Park.

June 26, 2017 Nick Kempe 4 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 2 comments

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.