Tag: Litter

June 16, 2017 Nick Halls No comments exist

By Nick  Halls

Remains of fly tipped mattress, Cuilag

As a resident of Ardentinny, I routinely travel between Ardentinny and Glasgow by road.   I make it a practice of stopping on Loch Lomond side to visit the camping places, for which permits are required, at Suie Field and Cuilag, situated on the shore between Inverbeg and Luss.

 

Access to both camping areas is from laybys off the A 82 [T] road, which follows the line of the Old Military Road, sometimes directly on it. There are a number of places where the old road still exists, used as laybys or closed for vehicles and used as part of the cycle and pedestrian way. They are often loops taking cars away from the side of the main A 82.

 

In respect of the management and conservation of the National Park environment, I monitor the litter and refuse left, the ‘long stay’ caravans and mobile homes, the litter and soiling left by heavy goods vehicles parked up overnight and the state of the camping places. I chat to campers, and people using caravans and mobile homes.

 

In the past, my approach and engagement in conversation seemed welcome, and taken as just a part of a Scottish experience, garrulous, old locals coming up and talking rubbish. I do this partly to entertain but also to gather ‘intelligence’ about strangers, as is the country way.

 

In previous reports, I have expressed concern about the ubiquitous litter problem, fly tipping in parking places, the state of camping sites and a failure of the part of the NP Authority to tidy camping places, maintain safe and cleared access and to generally make the places for which people have to pay welcoming and worth the money.

 

Overgrown path Suie field – photo Nick Kempe

The path, from the lay-by, used for access to Suie Field beach is still overgrown, with historic litter strewn amongst the undergrowth, with trip hazards, and the beach and camping sites usually show signs of litter – it is obvious to me that the responsibility for the squalor is shared between campers and day visitors, both of whom have a penchant for fires, and eating food with a lot of packaging, and leaving plastic bottles.

 

Judging from the position of litter everybody using the location contributes to the litter, and many use the locality as a toilet.

 

In the past I have seen mattresses, garden rubbish and soft furnishing dumped on the shore of the Loch from this lay by – they are difficult to photograph due to the steepness of the bank, and my infirmity. They can sometimes remain for 6 months or more.

 

It is not clear to me who has the legal responsibility for removing the rubbish, Argyll & Bute Council, the NP Authority, the land owner or Transport Scotland as the organisation tasked with managing trunk roads.   What is clear to me is that the NP Authority, if it has any integrity, has at least a moral responsibility to maintain the amenity of the NP for which it is responsible. I cannot believe Park Rangers do not see what I see!

 

A new issue addressed in this report is how Camping Management arrangements are souring relations between visitors and residents.

 

The latest evidence from Cuilag

The sign indicating the camping area, showing the path to the beach, and the parking place and big burn that goes underneath the main road in a culvert, draining onto the beach.

I have reported previously on the squalor, garbage and fly tipping evident at the car park, from which the camping places on the beach at Cuilag are accessed.    I have attempted to stimulate action to clear up the car park, enhance the landscaping and clear the rubbish from the burn. I visit it at least fortnightly to assess if ‘feed-back’ from the public results in any action.

 

During a visit on 06/06/2017, I took up to date photographs of the fly tipping and visited the beach, it was coarse weather, following the pleasant spring.

 

 

The initial tipping is garden rubbish, the subsequent tipping seems to be household waste, some might have been added by either; campers, day visitors after a picnic, passers by or by people staying in caravans or mobile homes.   Without a forensic examination, it would be hard to know.

 

I avoid taking photographs that include, tents, cars, caravans or mobile homes, especially if they are occupied, because it is an invasion of privacy and also because showing the category of those present suggests that they are responsible [as was done while assembling the propaganda evidence to scapegoat campers]. In all drama presence is assumed to be evidence of guilt!

 

While taking photographs, the resident of a caravan present on site, stormed out shouting and screaming for me to ‘f… off’, assuming I guess, that I was gathering evidence of their responsibility. There was a threat of violence!   Having lived in Glasgow this was not outside my experience, but the show of aggression is very unusual in the countryside.   What struck me was that they asserted the rubbish was nothing to with them, it had been left by campers. Indeed, I could accept that some of it might have been, but garden waste and what looked like nappies were unlikely to originate from campers, of the type who might use Cuilag beach in unpleasant weather.

 

I visited the beach, by the degraded muddy path, which is eroding into a gully by drainage from the parking place, which is washing minor litter down to the beach. It is a ‘trip and slip’ hazard for visitors carrying camping equipment and picnic materials.

 

There were no campers or picnickers because the weather was vile, and the level of the Loch rising, inundating the preferred camping location. Along the back of the beach was a line of litter, concentrated where I assume people picnicked, during the preceding good weather, because a lot of it was heavy alloy used for disposable BBQ.s and BBQ food containers, and there were signs of places where they had been used.

 

My conclusion is that the accumulation of litter is contributed to by all and sundry, but the ‘sign’ that made it seem acceptable is fly tipping that had nothing to do with visitors. Evidence for this surrounds the parking place, slightly camouflaged by spring growth.

Accumulated tip obscured in summer by undergrowth.

 

I took a look at the bed of the burn, it confirmed what I have observed elsewhere, that nearly every accessible culvert, bridge and drain, seem to be used as convenient garbage disposal points.

 

The burn has been almost completely obstructed with garbage, the majority of which is garden waste, which is being washed down onto the beach and into the Loch.   It seems very unlikely that the majority of this rubbish is dumped by visitors, but an urban visitor might assume if a place looks like a dump it probably is a dump, and might add to it.

 

The garbage (above) has been dumped from the cycle way onto ground above the culvert shown in previous photograph.  The amount does not suggest that it originates from visitors, and implies local knowledge.

 

To validate the observation above, a picture of tractor tyres dumped in a drain in Glen Finart. The most casual observation would confirm that this sort of dumping is ubiquitous throughout the Scottish countryside, and very long lasting. These tyres could have been dumped before the creation of the National Park, by a contractor during the last clear fell, decades ago.

 

Responsibility for sorting out the mess

 

When I knocked on the caravan door to explain my purpose, I was confronted by anger, lack of understanding of the issues which concerned me, and a feeling that they were being accused falsely of being responsible for the state of the car park. It took me some time to calm them down and persuade them that I did not believe they were responsible, but the Local, NP and Roads Authority jointly shared responsibility for garbage collection and maintaining the amenity of a beauty spot.

 

The response was to blame me, because there is no garbage receptacle of any description into which to put rubbish, pointing out that it might be alright for me, [I drive a van] but they only had a crowded car and had no way of removing rubbish. There is some validity in both these observations.

 

“Take your litter home” may be responsible behavior but when some of the flytipping appears from local residents, is it really practical for either day visitors or mobile campers?  The evidence suggests people dump stuff because there is nowhere to put the garbage.

 

The evidence of Duck Bay, is that the garbage disposal facilities are insufficient, because they are usually over flowing after a nice weekend, and relative to the amount in and around bins, the amount left lying by picnic tables is relative minor, however unsightly it may be.

 

Placing a skip in carparks where fly tipping and litter is a problem, would at least enable anybody to place litter in a receptacle, whatever its origins, and permit a speedy and routine tidy up.   The cost of such provision would still come from the public purse, whichever Authority were to take responsibility – to which everybody contributes in one way or another.  If the cost fell on a Local Authority it would be met from taxation harvested from the whole population, not just Council Tax payers.   No cost of a public service is met solely by the resident of the NP, least of all the cost of NP Authority itself which is funded also entirely by grant from central Government.

 

The lack of positive action suggests that each authority operates in isolation, without any coordination, and there is no ‘buy in’ to NP Policy which seems to be developed in a ‘silo’. There just seems to be a reciprocal denial of responsibility from those who have a duty to sort this out.

 

I assumed that the creation of the NP would produce an authority to coordinate the activities of all public bodies, commercial interests, resident and visitors, to conserve the valuable qualities of the Loch Lomond and Trossach National Park and enhance them for all concerned; not to foster discontent between residents and visitors, and animosity between categories of visitors, by scapegoating some and catering for others, with no over-arching policy.

 

Everything I observe is redolent of incoherent ‘ad hoc’ activity, with no plan or strategy, in a culture of blame and denial, identifying scapegoats, and shifting responsibility. Other reports suggest the authorities are incapable of taking effective enforcement action, even against a tiny minority of campers!

 

The situation is quite shocking, probably very expensive, and exposes an NP Authority that is just not up to the job.  There is a serious risk that in the current political, social and economic turmoil the suggestion will be made to do away with National Parks. Now, I would be ambivalent about supporting such a proposal!     I would support public condemnation of those involved in the Governance of the LL & T NP, and designating them as unfit for public office.

June 3, 2017 Nick Kempe 2 comments
Strangled hare beneath Cas Gantry at Cairngorm 2nd June  – Photo Credit Badenoch and Strathspey Conservation Group

Parkswatch received information that there was a strangled hare under the Coire Cas t-bar gantry (see here) and is very grateful to members of the Badenoch and Strathspey Conservation group who visited the site today and confirmed this (above photo, which has had coverage on twitter).  Natural Retreats’ staff then turned up, presumably to check on what was being photographed, and stated they would inform the manager.   What the manager should have done then was inform the police and leave the hare as a potential crime scene – we will see.

 

Tnere appear two potential explanations for what has happened.  The first is that this was an accident.  That a hare, taking shelter on the piles of rubble under the gantry became entangled in this string/twine and strangled itself.   If so, I think Natural Retreats and Hightlands and Islands Enterprise still bear a high degree of responsibility.  They are meant to be custodians of Cairngorm but instead have failed to adhere to basic standards of good stewardship and have caused environmental destruction and  left rubbish – which harms wildlife (as this case might show) – all over the mountain.   These failures have been epitomised by their actions at the Cas Gantry where Natural Retreats bulldozed a far wider area than necessary for the “de minimis” emergency repair work that Highland Council agreed could go ahead without planning permission.

View of Cas Gantry August 2016

What’s more despite all the publicity on parkswatch Natural Retreats have still not restored the landscape properly, as you can see from the soil and boulders which still lie dumped below the gantry, on which the hare was found.

 

The second possible explanation is that this was deliberate and the string/twine was used as a snare.  This would need expert investigation to establish.

 

There is a possible motive for the hare being killed which has nothing to do with their alleged role in transmitting ticks to red grouse.   Natural Retreats took a long time  before it made any attempt to restore the slopes around the gantry and because they had failed to store any vegetation had to re-seed it, usiing a fertilised seed mix.   This did nothing for a while (see photo below) but now in the growing season is extremely attractive to hares – a large area of rich grass.   The hare/s therefore may have been threatening to destroy the re-seeding and, rather than fence off the area, perhaps someone thought it easier to set a snare?

 

Whatever the explanation of the strangling, accident or deliberate or something else,  the likely scenario is the hare was attracted to the re-seeded area before taking shelter under the gantry.

 

Erosion on the slope to the right of the Cas Gantry January 2017, with blue fertiliser pellets washed away.

If this was an accident, its an accident for which our public authorities bear some responsibility.  They have regularly been made aware of the destruction which has happened at Cairngorm since Natural Retreats took over.  Under the Glenmore and Cairngorm Strategy HIE agreed to produce a Cairngorm Estate Management Plan, which could be used to ensure Cairngorm was managed to the highest standards.  Instead, they have tolerated Natural Retreats continued mis-management of the natural environment, from rubbish dump to off track use of vehicles.

Diesel tank adjacent to funicular station – note dead vegetation centre and left

A recent example – ignore if you can the half-hearted attempt to hide the tank behind a wooden fence – what has killed the vegetation here?   A diesel spill which was then cleared up, is one explanation – but perhaps Natural Retreats can offer an alternative?   (which Parkswatch would be happy to publish).  Whatever has happened does not appear good for either wildlife or habitats.

 

Meantime, there is no sign of the set of standards for environmental management which the Cairngorms National Park Authority recommended Natural Retreats adopt last year.   I would recommend their senior managers and Board Members go and take a look for themselves before parkswatch publish further photos – including how the Sheiling Track which they retrospectively approved is eroding as predicted.   The strangled hare is symptom of a deep malaise, more evidence that the way Cairngorm is being managed is not fit for a National Park, that Natural Retreats are not fit to be leaseholders and HIE is not fit to own it.

 

The solution is for management of Cairngorm to be taken over by a community consortium which includes conservation interests.

May 20, 2017 Nick Kempe No comments exist

Thanks to Nick Halls for these photos and for information which has informed the commentary.

Southern entrance to torpedo station site 15th May               Photo Credit Nick Halls

The area around the former southern entrance to the torpedo station remains in a very poor condition with concrete barriers now replacing the plastic barriers across the broken entrance gates.

 

The gates, which were installed to prevent vehicular access to the former torpedo station following an amenity notice issued by the Loch Lomond and Trossachs National Park Authority  (see here) and were then broken open (see here), appear to have had very little impact.

Close up of left side of gate, there is litter everywhere and this is the side of the public road. Photo Credit Nick Halls
Photo Credit Nick Halls

Inside the gate is even worse.  There has been a fire, whether this was an attempt to burn off rubbish or burn down the gate is unclear.

Photo Credit Nick Halls

And there is yet more fly tipping down the bank.

 

Clydebank Developments, who as far as I am aware are still owners of the torpedo site, have now  had 9 months to clear up the site since the LLTNPA issued the amenity notice last year.   The problem is that no-one is monitoring the site, the developer appears to have no presence, there are now far fewer police based in rural areas and the LLTNPA has devoted all its energy to chasing innocent campers rather than fly tippers who cause far greater problems.  There is clearly no proper enforcement taking place.  The local community and National Park deserve better.

 

It was good to see the head of Loch Long, which suffers from a massive litter problem – the worst in the National park – in pristine condition 10 days earlier.  What a contrast to the torpedo site just down the road.   Local community pressure to address the marine litter problems has clearly had a positive effect.  They have been involved in clearing the litter themselves and received grant funding, which has recently finished, to pay for the litter to be removed.    The problem is there are no adequate long term budgets to address the issue and, as the March meeting of the Arrochar and Tarbert Community Council noted, while Argyll and Bute allocation of £200k to clear up litter from beaches is very welcome, the Council’s coastline is as long as France!

Photo taken 5/5/17                                                                          Nick Kempe

Another small step forward is that the LLTNPA has recognised there is a marine litter problem in its new draft Partnership Plan – the word “marine” failed to appear in the last plan at all!  This is what the new draft plan has to say about it:

 

The volume of marine litter affecting communities on Loch Long is a long-standing issue which requires innovative thinking to resolve. (P28).

“Innovative thinking” is another example of parkspeak, whose real meaning is that the LLTNPA is not proposing to spend any resources on the marine litter problem which blights the National Park over the five years of the new Partnership Plan.

 

While it would be great to be able to address the causes marine litter in the Clyde,   which would require much greater enforcement action than happens at present (yes, that word enforcement again),  when litter is washed up at the head of Loch Long it needs someone to pick it up, just like it needs someone to pick up the litter at the torpedo site or at Luss (see here) or Balmaha on busy weekends.   The problem is the LLTNPA is so obsessed with the litter left by a few irresponsible campers, it cannot see the litter problem as a whole despite all the evidence on the ground.

 

What needs to happen

 

  • The LLTNPA needs to develop a proper litter strategy, as it promised to do several years ago and has never delivered – there is no mention of this commitment in the new Partnership Plan.  Without a co-ordinated plan, its target, to see a reduction of litter in the National Park over the next five years, is meaningless and will never be met.
  • The LLTNPA also needs to start telling the truth.  In the new Partnership Plan the LLTNPA claims “Much public investment has already been targeted in raising the quality of visitor facilities in the  busiest areas improving car parks, toilets, information points, litter facilities, viewpoints and campsites”.   Yes, its spent money on carparks, viewpoints and campsites – whether this has been well spent is a separate issue – but litter facilities and toilets??   So what is the gap between what is needed and what is provided?  The Partnership Plan is completely silent.   The LLTNPA continues to avoid the real issues facing the National Park.
May 11, 2017 Nick Kempe 3 comments
Photo credit Luss Estates – from last weekend

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

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

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

 

“Call to Get Back to Basics

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

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

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

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

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

What needs to happen

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

 

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

May 3, 2017 Nick Kempe No comments exist

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

 

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

 

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

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

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

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

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

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

 

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

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

 

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

 

What needs to be done

 

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

 

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

April 28, 2017 Ross MacBeath No comments exist

By Ross MacBeath

The new directive for Countryside Rangers – enforce the byelaws above all else.

 

Secret slide released under FOI

While the Loch Lomond and Trossachs National Park made a great hullabaloo claiming success with their byelaws on the East Loch Lomond shore, what they failed to explain was that to achieve this as yet unsubstantiated claim, they had to increase ranger patrols in the area.    The problem now for the LLTNPA is the area covered by the extended byelaws covers over ten times the length of road – a vast area – and they don’t have 10 times the resources.

As a result they have had to remodel the Ranger Service.  Education and conservation have gone as priorities, the focus of Rangers is now on enforcement and engagement.

 

“Take Your Litter Home” is not a strategy.

.

Meantime “Take your litter home” is not a strategy nor is it a policy for preventing  littering.  It’s an educational program designed to raise awareness of littering issues in the long term and as such requires to be supported with litter bins, a litter collection and pick up strategy if the National Park is ever to be made litter free.

 

After over a decade watching litter polluting the park the LLTLPA still look on

 

Spent Barbeque left at Carpark Loch Venacher North Zone B 10th April '17The LLTNPA blinkered insistence that ‘Take your litter home’ IS the only contribution they have to make to litter management is itself the prime driver for the increasing mess in the National Park.

 

What a welcoming first sight for visitors, a spent barbeque in the car park.  How long will this and the rest of the litter pictured in this post remain, damaging the reputation of the Scottish Tourism before the Park Authority arranges for it to be cleaned up.

 

I was taught to put litter in a bin, my children were educated to do the same and undoubtedly their generation are teaching children the same thing. Changing that entrenched mindset is not only undesirable, it could also take 5 -10 generations to accomplish, so what the LLTNPA need to do is get a workable park cleaning strategy in place meantime and get the decades worth of rubbish they have allowed to accumulate cleaned up.

It’s somewhat ironic the LLTNPA, who berate campers for leaving litter in a bag,  are themselves guilty of fly tipping at Loch Chon.  I trust they paid the £200 fine or reported themselves to the Procurator Fiscal.

 

Loch Lomond and the Trossachs, the dirty National Park

 

The National Park Board really need to get out of their Ivory Tower, stop listening to the tripe related to them at secret board meetings and see what’s going on in the Park.for themselves.  The LLTNPA have not made any effort to clean up many areas before the byelaws commenced on the 1st of March 2017 so there is no frame of reference for the success or failure of the byelaws to be measured against (though the LLTNPA promised this would be done), while leaving the park in a mess for this season’s visitors.

 

Click images to zoom

 

This is the state of the loch side adjacent to the Loch Venacher North permit Zone A.  It is clear from the degradation on the cardboard that the above 3 images are historical.

 

Littering still taking place on 8th and 9th April ’17 in management zones

 

By contrast, the two images below show litter left by visitors on the weekend of the 8th and 9th of April despite the byelaws.    How can this be when policing the byelaws is now the Rangers first and main priority?  One would expect extreme effort at the start of the season where the Ranger to visitor ratio is high.   When the rangers can’t even cope in the low season, with  only a handful of visitors using the permit and management zones, this counts as abject failure.

 

 

It would appear the rangers just don’t have the manpower to stop this, making the byelaws superfluous.   So far It is clear the byelaws are having little effect on the negative impacts of the few.   Does this result from too much talking and not enough doing?!  With the claimed 4 million visitors to the park it is impractical to interact with them all – a ranger presence which focusses on problems is more important than endless time checking permits.

 

Serious littering, fouling and other criminal offences allowed to go on unchecked

 

After visiting 6 sites over a couple of weekends 3 of them showed serious littering, 2 toilet fouling and 2,  instances of “fire raising” (see here),  all of them criminal offences under the byelaws.    There were also two instances of landowners locking gates preventing reasonable access to 2 of the permit zones.

 

The only possible “success” the Park has had so far is in making it harder for well behaved visitors and their families who are now unable to exercise their access rights to enjoy camping in the popular areas of the Park.

 

March 19th Loch Chon Shelter erected in management zone

Under the byelaws it is a criminal Two visitors committing criminal offencesoffence to erect a shelter overnight, which means any time between 7pm or 7am.   On these light evenings, its mad that its legal for fishermen to use shelters, which  are after all a piece of personal protection equipment necessary to prevent hypothermia on bad weather days, at 18. 59 but at 19.01 they are criminals.  Two visitors had put up this shelter and 2 Rangers were in vicinity – I wonder how they advised the fishermen?    This rule is impossible to enforce.  It would require signs at every place used by fisherman in the camping management zones.

 

March 19th Loch Chon Campsite

 

At the Loch Chon camp site I witnessed two day visitors light a fire using wood collected from surrounding area.   Rangers were present and did nothing (just like at South Loch Earn) (see here).  Impossible to enforce for non-campers because none of the Park’s signage tell you about this and the wording of the byelaws is not clear – you need to cause damage.  However, campers when they apply for a permit agree to terms and conditions that clearly state you cannot use wood you have collected and say that breach of these terms is itself a criminal offence.  The byelaws are thus potentially enforceable against campers who apply for permits but no-one else.

 

April 2nd Tents pitched outside permit zone but in a management zone

 

Two weeks later in Forrest Drive down by Loch Achray, I had a chat with a family of 4 adults and 2 kids who were all enjoying a bright warm spring day on the 2nd April ’17 at an illegal camping pitch on the South side of Loch Achhray,

The family were experienced campers and with three tents, a shelter and a toilet tent they were certainly well prepared.  All in all the kids were having a wonderful time fishing with plenty of space to run around the tent and on the loch side where large grassy expanses abound. They seemed blissfully unaware the 4 adults were committing criminal offences by just pitching here outside a permit zone.  However, as they intimated rangers had stopped by the day before and again today, Sunday 2nd, when they should have been made aware of their crime.  However they were not asked for a permit or moved on.   The reason why is perhaps explained by  the image to the right.  The Forestry Commission sign states this IS a permit zone when the actual permit Zone ‘L’ is on the opposite side of the Drive.  Not even FCS know where people are allowed to camp!

 

Zone ‘L’, opposite, is however unsuitable for camping as there are no viable pitches

 

Had the family purchased a permit for the adjacent zone L they would not have been able to camp there. Images showing why can be seen in the Zone L gallery or the full report is here.  Perhaps the Rangers allowed the illegal camp on the shore because it is impossible to camp in Zone ‘L’ another complete failure as a camping zone claiming 9 pitches.

 

Zone  ‘L’ is however being used for toileting and the rangers of course are powerless to prevent it.  Now, while having a crap is not covered by the byelaws for the general public, it is covered by the camping permit terms and conditions breach of which is a criminal offence.  There is a clear breach here – toilet paper for example has to be carried out – but I just wonder just what is the LLTNPA’s modus operandi for catching people in the act of shitting in the woods.  That would surely make an interesting read.
This incident is recent, possibly a week ago, certainly within the management season.   It would be impossible to attribute this to any individual permit holder without photographs or witnesses and of course it’s just as likely to be a day visitor (its not just campers who need toilets).   So the byelaws  themselves fail to make any material difference to this illegal fouling. They are no more than an unwelcoming threat and intrusion on every visitors day in the park, compounded by the inevitable attempt of a pair of rangers to engage is a 10 minute dialogue.     What can they do with the nearest toilets 45 minutes away by car (round trip) from any permit zone on Forest Drive?

 

 

Rangers attend an incident April 1st  ’17  Loch Achray Youth Site

The same family told me  of a fracas in the Chopped down tree for firewood, 2nd April '17adjacent camping area a bit further along the loch on Saturday night, the 1st of April, where some live tree chopping had taken place.     They explained that rangers attended at an incident at the loch side and some raised voices followed.   Hopefully we will see a report sent to the Procurator Fiscal for this damage but it will be interesting to see if the report is for breach of permit terms and conditions or under the existing law of damage to property.

 

The important point here that the presence of Ranger patrols failed to stop the damage occurring in the first place again confirming the Ranger Patrols are ineffective and just a huge revenue expense that would be better invested in infrastructure such as provision of wood for fires.

 

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10th April Loch Achray South.   No change here with black plastic bags left at the gates and water bottle left by the campfire, the byelaws clearly making no improvement.   What is and always has been required of course is litter bins which would prevents bag like this being ripped open by foraging animals.  The LLTNPA have failed to elucidate how this mess will be cleared up without a litter management policy.

 

Gates Firmly Locked, so is this zone even active?

 

Somewhat strange for an advertised camping zone that can be booked on the permit site, these gates are locked like no other, with two padlocks through heavy duty chains and 3 bike locks with additional rope loops and a barbed wire fence to boot.

 

Quite clearly access is being denied to visitors however on entering the zone it is also clear it is this zone is currently being used by visitors.

Why this is listed as a camping zone at all is a mystery when the gate is obviously permanently locked.

So how can this be allowed to happen at such a prominent site.

 

Illegal toleting at Loch Achray SouthThere was also evidence off toileting at Loch Achray South, which would be illegal if done by a permit holder although strangely enough not illegal if done by someone without a permit (though they of course would have been committing a different criminal offence if they had pitched a tent here without a permit.  Perhaps the Rangers, in cases like these,  check names and addresses of recent permit holders and then contact them to ask if they are responsible?    How can the Rangers ever know if its a camper or day visitor responsible, as was the case for most of the fire, barbeque and toileting incidents described above.

 

Against all reason the LLTNPA accost visitors with their futile byelaws.

 

The LLTNPA has added a dozen or so new criminal offences for campers and campervanners through the back door by making breach of their permit terms and conditions a criminal offence.  One rule for campers applying for permits, another for everyone else.   It has reduced their credibility to that of a petulant child. It’s just embarrassing.
The main tool at the Ranger’s disposal now is fear and threat of prosecution.  While that may very well be a useful and perhaps even an acceptable way to prevent  serious criminal offences its scandalous this could be applied to pitching a tent or staying 4 nights in a zone instead of 3

 

The LLTNPA were advised from people who understood outdoor recreation and criminal behaviour that the byelaws were never going to be an effective deterrent and affect the wrong people.  It should be clear to all now that other than some reports to the Procurator Fiscal when Rangers just happen to be in the right place at the right time, the majority of contraventions of the byelaws will go undetected because Ranger cover is just too infrequent.   While this frequency is inversely proportional to the time Rangers spend pestering visitors with their visitor engagement, its still unlikely to be enough, even if rangers did stick to patrolling and adopted the policy for all petulant children of being seen and not heard.

April 21, 2017 Nick Kempe No comments exist
Tents at the St Fillans end of the Loch Earn south camping permit zone – much of the camping is on shingle beaches.

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

 

 

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

Loch Earn Leisure Park

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

 

 

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

 

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

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

The enforcement of camping permits

 

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

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

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

 

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

 

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

 

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

 

 

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

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

The impact of flytipping was greater than anything left by campers

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

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

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

 

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

 

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

 

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

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

 

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

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

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

 

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

 

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

 

The real failure in enforcement

 

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

 

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

The implications of the permit zone for access rights

At the end of our walk, both Dave Morris and I agreed, that really the introduction of the permit zone on Loch Earn has so far, changed only one thing.   It has introduced charging for access.   The permits have done nothing to address the litter or other basic infrastructure issues that the LLTNPA should be addressing.
So what, it might be argued, people appear to be accepting the £3 charge.   Well, so would most people faced with the choice of a charge or a ban from staying in a place you have been visiting all your life.   That doesn’t make the charge right – people are getting nothing for it except bureaucracy and intrusion – and of course what is likely to happen is that sometime in the next year or so a report goes up to the LLTNPA Board explaining openly for the first time the enormous enforcement costs and suggesting these should be recovered from campers.   If people accept the principle of permits and charges,  our access legislation will be in tatters.
What needs to happen – and the LLTNPA is currently consulting on its new Five Year Partnership Plan – is the resources currently being spent on enforcement of the permit system (which means almost the entire time of Park Rangers) should be redirected to other tasks.  High on my priority list would be removal of litter – including Rangers encouraging campers and other visitors to take part in litter picks – and provision of wood for campfires.    Ranger services were never intended as quasi – or is that Stasi?  – type police forces  and the Park Ranger service should be allowed to return to its educational role, which should include leading by example.
April 17, 2017 Nick Halls No comments exist

By Nick Halls

Damage to the new gates at the Torpedo station put in place to stop flytipping. Outside the gate fly tipping down onto the shore seems to be continuing.

 

In my last post (see here) on the torpedo station, I stated that the gates blocking the old main road were both locked, thereby preventing vehicles entering the area.    Recently, the southern of the two gates has been burst open and badly damaged. It was ajar for a period and it was not clear whether this was ‘official’, and signified that fly tipping was being cleared, or that it had been ‘unofficially’ opened to allow further tipping to take place.  The photographs here, taken on Saturday 15th April,  give some impression of the current situation.  The evidence seems to indicate that both situations seem to prevail.

 

The right-hand side of the southern gate has been more or less destroyed, and the left-hand side is off the hinges. It does not look as if this ‘official’, and adds to the impression of dereliction of the site, but in a very public place, right next to the main road.

Southern gate view east from main road

 

The previous obstructions, which seem to be water filled road barriers, remain together with an old concrete post from a dismantled building. Again, this gives the impression of dereliction, destroying the landscape quality of what could be an attractive outlook to the opposite side of the Loch.

View from inside the gates

Inside the destroyed gate it would appear that either pedestrians or the occupant of a vehicle has thrown down litter as if in an urban street. It is very depressing to see this type of littering but it is in accord with how such derelict spaces are treated whether in an urban environment or the countryside. It is characteristic of the state of many of the parking places along Loch Lomond side and elsewhere in the National Park.  Again, the whole scene destroys the quality of the outlook behind.

 

Immediately beyond the gate it appears that fly tipping from vehicles has taken place recently.

Fly tipping down the bank onto the sea shore.

One gets the impression that fly tipping at this site is regular and is generated locally, and one would imagine that someone in the community is aware of the culprits. Only some sort of enforcement action is likely to reduce the progressive degeneration of the whole area.

 

 

Further along the road walking towards the derelict torpedo station there is further evidence of  fly tipping of building debris – which suggests that this might be commercial tipping. See photo above and two below.

 In the two photos above, the fly tipping along margin of the old main road leading north towards the derelict torpedo station appears to be very recent, since my last visit.

 

On the section of the old main road on either side of the bridge over the Allt a’Bhalachain, where two dumps of corrugated iron were shown in a previous report, these have now been cleared – in a pretty crude fashion – the scars of which will probably take some time to recover.

Sites where where dumped material has recently been cleared from the verges of the old main road.

However, the material seems simply to have been transferred to the fly tipping area within the derelict industrial area of the torpedo station.

 

There is evidence of a rather crude and superficial attempt to clear fly tipped material from the what was formerly the main dumping ground. The work seems to be ongoing as there is a container, presumably awaiting to be used to remove material from the site.

However, while material is being cleared the amenity of the area is hardly improved, and the whole process gives the impression of doing the barest minimum to conform to the demand from the Loch Lomond and Trossachs National Park Authority to clear the site.

Main dumping ground on the derelict industrial site of Torpedo Station

The quality of the work, whether complete or still in progress, gives the impression that the owner/contractor is doing the barest minimum and could not care less about the amenity of the area or that it lies within an area of outstanding scenic quality within a National Park.

 

Repeated visits to understand the situation that prevails brings it forcibly home that the derelict torpedo station will be very costly to clear up, as a brown field site, and equally costly to develop into the sort of tourist development presented in the planning application (see here).

 

It is hard to avoid the conclusion that this site will remain in a similar state for decades to come and that the M.O.D. should be compelled to tidy up the mess they left.

 

Despite the recent work to clear up the site the corrugated asbestos, featured in my last post, remains untouched so far.

 

There are two dumps of what appears to be asbestos in fairly close proximity

 

 

 

The LLTNPA’s priorities are all wrong: it  should be focussing its efforts and resources on environmental dereliction, fly tipping and the litter problem in the National Park instead of trying to ban innocent campers.

April 7, 2017 Nick Halls No comments exist

By Nick Halls

Northern Gate, preventing access to old road and former Torpedo range site. The gate was recently installed, apparently under a road closure notice which was related to the planning permission for the development of the site. That planning permission has however lapsed.   All photos Nick Halls.

Following the post about the planning blight at the site of the former torpedo factory and range on Loch Long  (see here),  I went to take a look for myself.  I wanted to take a look at the impact of the gates that have blocked off the old road and check if any of the flytipping had been removed as required by the Amenity Notice.   This was served last August and  gave the owners four weeks to clear the rubbish from the site.  Since then, the minutes of the Arrochar, Tarbert and Ardlui Community Council Area Forum held in March  (see here) have not just confirmed that Loch Lomond and Trossachs National Park Authority is giving the owners four to five more months to remove the flytipping (on top of the six months since the Amenity Notice deadline expired) but also that there is asbestos on site.

View south down the old main road towards derelict Torpedo factory.

It is possible to by-pass the gate on foot which, in respect of the danger from asbestos renders the gates ineffective, and, although the gate prevents fly tipping from vehicles, it does not prevent people disposing of bags of garbage which are being thrown down towards the shore line.

Garbage thrown down from within the northern gate from shore side of old road

Stuart Mearns, the Park’s Head of Planning, spoke too soon when he stated (as recorded in the  Forum minutes)  “that at least there would be no more fly tipping” on the site.

The southern entry to the site and the old A83  has also been blocked off with similar style gates

Dumping from vehicles is still possible also at the southern gate and is still happening.

Building materials and general garbage tipped down bank by vehicles on the main road side of the southern gate

The next photos are of tipping and garbage disposal within the gated area, on the area that was the former torpedo factory, on a road that leads from the old main road into the decayed industrial ruins.

View south
View south east

There are a series of dumping spots on the western side of this road (see below) mostly containing what appears to be builders/commercial rubbish.

View west

Two of the fly tipping sites contain what appears to be corrugated asbestos.  Both of these sites are east of the old road on what was the site of the torpedo factory.

View north west

 

Note: the old main road runs behind trees in the background, so the asbestos risk is well away from the former public highway.

View north west, site immediately beside the one shown above

If this is the asbestos and it influenced the decision to close the old main road, it would have cost less to remove than to install the gates!  It is also situated on the grounds immediately beside the industrial ruins of the former torpedo factory – not particularly close to the old main road.

 

The industrial area of the former torpedo factory is a potentially heavily polluted ‘brown field’ site, which should have been cleared by the M.O.D., as they constitute the polluter/previous owner. On the basis that the ‘polluter should pay’ it seems likely that the responsibility still lies with the M.O.D. even if the site has been sold to a possible developer.

View south along the old main road

There is much less evidence of fly tipping along the southern section of the old main road, beyond the access loop leading through the ruins of the former torpedo factory.

Fly tipping and garbage along the northern part of the old main road

The quantities are not large and appeared to be fairly straightforward to remove. Again, clearing the roadside might have involved less effort than placing the gates – with an unnecessary restriction of access.

Parts of a broken-up fiber-glass boat, in three parts thrown off bridge into stream passing through site. The stream above the ruined factory site looks as if it is quite natural, and constitutes quite a scenic view, were it not for the dumping.

 

Remains of demolished building, which might have been residential or administrative. Note also the remains from what appears to be some sort of forestry operation involving stripping bark and branches, which presumably took place elsewhere, and then disposed of along the roadside.

Much of the fly tipping along the sides of the old road is fairly easy to remove, or does not pose a particular health risk.

 

The forestry operation debris, although unsightly will eventually break down and become over grown – but it still constitutes fly tipping – always assuming it was carried outout with the owners consent.

Most of the unsightly material seems to be the remains of demolished buildings, which have not previously given rise to concerns, whether on health and safety or amenity grounds, and have been in this state for decades.   The blight at the former torpedo testing site is far greater than the flytipping and while the LLTNPA needs to address the flytipping, a much bigger challenge is to clear the site up and make it fit for public enjoyment again.   Its a prime site in the heart of our National Park, a disgrace, a challenge and an opportunity.

March 31, 2017 Nick Kempe No comments exist
Former bunkhouse at Balmaha transformed into a private residence for Wayne Gardner Young. Planning permission for change of use was applied for in 2011 but has still not been agreed.

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

 

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

 

The site of the former Highland Way hotel

Luxury Lodge in construction November 2016

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

 

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

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

 

 

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

 

 

 

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

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

 

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

 

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

 

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

 

The Oak Tree Inn

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

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

 

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

 

Balmaha Waterfront

 

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

 

The cumulative impact of “luxury” tourist accommodation in Balmaha

 

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

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

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

 

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

 

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

 

Balmaha – a tale of developing social segregation and exclusion

 

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

 

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

 

 

 

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

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

 

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

 

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

 

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

March 17, 2017 Nick Halls 1 comment
Loch Lomond and Trossachs National Park Suie Field camping permit area – all photos taken 14th March 2016 two weeks after the permit areas were “open for business” Photo credit Nick Halls

The LLTNPA is discouraging camping at designated sites.

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

 Suie Field

 

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

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

Photo Credit Nick Halls

 

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

Photo Credit Nick Halls

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

 

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

 

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

Photo credit Nick Halls

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

 

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

Photo credit Nick Halls

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

 

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

Photo credit Nick Halls

 

 

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

 

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

 

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

 

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

 

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

 

Cuilag

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

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

 

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

Photo credit Nick Halls

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

Photo credit Nick Halls

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

Photo credit Nick Halls

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

 

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

Photo credit Nick Halls

 

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

 

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

 

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

 

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

 

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

December 27, 2016 Nick Kempe No comments exist
The second letter, while not about explicitly National Parks, could be – our National Parks are failing both wildlife and visitors

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Following my post (see here) on the discussion of litter at the last Loch Lomond and Trossachs National Park Board meeting, it was good to see Peter Jack’s lead letter to the Herald.  I hope this will help bring the failures of the National Park to the attention of a different audience.  (And if you didn’t see the excellent letter from Dave Morris the previous week on the VisitScotland initiative to promote wild camping just as the Loch Lomond and Trossachs National Park Authority is trying to ban it………….. (see here))  

After my post, a reader gently reminded me that a few years ago the LLTNPA had made a serious attempt to tackle litter.   This was when Grant Moir, now Chief Executive of the Cairngorms National Park Authority, was at the LLTNPA and Kevin Findlater was Chief Inspector of the police for the Trossachs Area.  Their efforts culiminated in the Five Lochs Visitor Management Plan in 2012.  It had a whole page on actions to address litter which is worth reading in full.
While I have covered on several occasions the LLTNPA’s failure to implement the (excellent) plans for campsites contained in the 5 Lochs VMP,  I have not covered LLTNPA’s abandonment of other aspects of that plan – litter was one of them.  Actions originally planned for 2012-13 – the first Keep Scotland Beautiful Litter Audit was one of them – were generally delivered but after that almost nothing:
  •  Litter strategy for 5 Lochs Area – planned 13/14; never delivered
  •  Implement new powers rangers to award fixed penalty notices – planned 13/14 – delivered June 2016
  •  Creation of recycling points – apparently abandoned e.g Loch Venachar north carpark constructed without recycling point which was on original plans
  • Litter signage; never delivered (thought Park now spending £100k on no camping signs)

 

There appear two explanations for why the 5 Lochs Visitor Management Plan appears to have ground to a halt in 2013.  First, Grant Moir, the driving force in the LLTNPA behind the 5 Lochs Plan left the Park Authority in that year.  He was replaced by as Director of Conservation and Visitor Management by Gordon Watson who is now Chief Executive.  Second, in September 2013 the Board started its secret discussion of camping byelaws.   Whether the change in direction was decided by the LLTNPA Board or its senior staff, I am still trying to find out, but it does seem clear is that in 2013 the Park abandoned its plans to tackle litter and instead started to focus on how it could ban campers.

 

Since my post on litter and the Board Meeting, the LLTNPA has responded  to questions I asked about the long delayed Keep Scotland Beautiful litter audit (see here).   While the LLTNPA published the litter report soon after receiving it on 18th November, EIR 2016-063 Response date KSB litter report received, what’s interesting is that the LLTNPA had three meetings with Keep Scotland Beautiful about the Report in April, June and September.  Its hard to see how LLTNPA could have met KSB about the report unless it had been provided with some documentation, and harder still to understand why there was 3 months between meetings unless KSB had been asked to undertake extensive re-writes.  If this is right, the fact the LLTNPA holds no drafts – as stated in the letter – suggests that it has deliberately decided to destroy them.  This suggests that the first draft of the report may have contained some inconvenient truths LLTNPA did not wish to see in print.  (If this interpretation is wrong I would be very happy to publish a response from the Park explaining how it could have three meetings about one report and not hold any information on it).

 

All of this adds further support to Peter Jack’s theory that in order to restrict camping rights, it has suited the Park not to have tackled the litter problem.   Unfortunately I think it is unlikely the Scottish Government will order a full inquiry into the Park’s failure to tackle litter because any objective look at litter would involve an examination of the failures of its own agency, Transport Scotland, to keep the verges along the trunk roads in the National Park clean.   Keep Scotland Beautiful was not apparently asked to look at that.

December 14, 2016 Nick Kempe 1 comment

Most members of the Loch Lomond and Trossachs National Park Authority appear to have spent Monday morning in yet another “Board Briefing session” before the public Board meeting, but had they walked round the riverside area in Balloch it might have helped them inject a sense of perspective into to the discussion of camping byelaws in the afternoon.  Both photos featured here are  part of the site Scottish Enterprise has appointed Flamingo Land to develop and in the National Park.

I do not condone the chopping of trees by campers or day visitors – its stupid – but within the context of all the trees being chopped down in the Park for “management reasons”, whether here by the head of the River Leven (with the property used by Maid of the Loch) or to clear road verges the “problem” is tiny. Yet, once again in the afternoon staff cited campers chopping down trees (they have never said how many!) as a justification for removing access rights

The Board meeting and litter

 

To be fair to the Board for six months now they have recognised that the litter problem is much wider than campers and litter is less frequently cited these days as a reason for the camping byelaws (the justifications at the meeting in the afternoon were framed in terms of environmental damage such as chopping of trees, vegetation eroded by tents etc).   The problem, evidenced at Monday’s Board discussion, is the Board have not yet managed to get their staff to act effectively to ensure basic litter infrastructure is in place, such as install bins and ensure they are emptied and even perhaps installing notices to warn the public about fines for littering..

 

The first and strangest thing was that under the organisational update there was no mention of the Keep Scotland Beautiful Litter Audit which had recently been published a year late (see here) and no reference to this in discussion.   It was impossible to tell therefore if the Board has simply not been told about the Audit, which casts serious doubt on the alleged miraculous impact of the east Loch Lomond byelaws, or whether they had decided to ignore inconvenient truths.  What the organisational update did say is that Park staff had issued one Fixed Penalty Notice for litter since these were introduced in June and this had been paid.  There was no comment on whether the threat of using Fixed Penalty Notices has had any impact on littering.

 

Colin Bayes, in his verbal update from the Delivery Group, which he chairs, told his fellow Board Members that the Park receives more complaints about the lack of lack of toilets and litter than anything else.  I think this was deliberate – he now appreciates what the real issues are.  His  comment sparked a discussion by Board Members on litter.  Cllr Fergus Wood asked officers what was the last time officers had sat down with colleagues in councils to discuss the issues – the question was spot on.  He was told the lead on this Claire Travis was not in the room, there had been meetings and support from some councils and not others.  Officers did not say which.  They did not explain either why these discussions had been delegated to middle managers.   It should be obvious to anyone that sending a relatively junior manager to go and talk to council opposite numbers about their failures to collect litter could not achieve anything.  Instead, it was announced that senior management had arranged for Keep Scotland Beautiful (the authors of the audit report which was not discussed) to facilitate discussions between roads authorities, other Council departments and the Park on litter collection.    This quite frankly was bizarre but perhaps the Park has so upset Council colleagues that they have refused to communicate directly with senior management?

 

Councillor Board members again made the excellent point that with bin lorries passing laybys for domestic collections it should not be hard for them to stop and empty bins if only they were provided.  The Councillors, again offered to help broker discussions with their own local authorities.  They had made this offer at the June Board Meeting and I guess none of them wanted to ask directly in public why senior management had not got back to them since then.    Its a question that Gordon Watson, the Chief Executive, needs to answer.   To date  NO progress has been made on improving litter bin provision and collection and there was no mention of the long awaited litter strategy.  It will be interesting to see whether this appears in the new Park Partnership Plan or whether Chief Executive Gordon has decided to ditch it, along with other plans such as the Five Lochs Management Plan which would have addressed litter and the lack of toilet provision, and focus all his efforts and that of the Park on trying to manage camping.

 

The Board discussion showed that while Board Members are showing an increase grasp of what the real issues are, they have still not managed to get staff to put their efforts where these are needed.   LLNPA has got its priorities all wrong and while that remains the case it will continue to fail as a National Park and waste huge amounts of resource (which I will cover in a second post on the Board Meeting).

 

November 29, 2016 Nick Kempe 2 comments
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Overflowing litter bin Balmaha 12th November 2016

Last year, between June and August, the Loch Lomond and Trossachs National Park Authority commissioned Keep Scotland Beautiful (KSB) to undertake a litter audit in the four proposed camping management zones.    I have been asking for the audit report ever since under FOI and last week, 13 months later, after another enquiry was told it had been received and published on the Park website (see here).

 

The Report consists of two documents, the first summarises the findings and the second contains a report for each of the 58 sites visited along with comments.  The LLTNPA appears to have intended it as providing a baseline to assess the impact of  the camping byelaws.   I will deal with the methodological issues and general context at the end of this post but will first focus on the two findings that I found most striking.

 

What the audit tells us about visitor management and the east Loch Lomond byelaws

 

litter-2
The percentage totals are based on the total number of visits ie 58 sites x 8 visits = total sample of 464 visits

The audit is very helpful in putting visitor management issues into perspective, something that the LLTNPA has lamentably failed to do:   on well over half of all visits sites were in an acceptable condition.  This is despite the fact that most of the sites were selected because the LLTNPA had identified them as hotspots, or more particularly camping hotspots, within the four proposed camping management zones and despite the fact that many of these sites have no facilities.

 

Even more significant is the evidence allows a comparison to be made between east Loch Lomond, where a whole package of measures, including camping byelaws, has been in place for three years, and the other three zones.

litter

What this shows is that while  a higher percentage of the six sites audited in east Loch Lomond were in acceptable condition than the other zones (and indeed it had not a single site in Category D) the difference is less than you might have thought if you believed the LLTNPA’s claims that the camping byelaws had solved all the problems on east Loch Lomond  Indeed,  if you remove one site,  the small inaccessible beach below the metal bridge round from Balmaha pier (another of the sites chosen) where no litter was found, the difference disappears.   In other words the environment on east Loch Lomond does not appear that much better than the other areas despite the package of measures that has been in place there (one would for example expect the alcohol byelaws to have an impact on the number of drinks bottles counted by KBS, while the banning of camping has clearly had an impact on the number of abandoned tents – nil).

 

Furthermore, east Loch Lomond has has much better infrastructure than many places in the National Park.  The audit sites for East Loch Lomond also included the Sallochy campsite and visitor car park at Rowardennan both of have which toilets:   so its hardly surprising less human excrement was found for the audit sites there.   There are toilets at Balmaha too though this did not prevent human excrement being found at Balmaha pier – obviously nothing to do with campers as camping is banned.

 

What the KSB Audit clearly shows therefore is that the types of impact covered by the report and  not just about campers as I and others have claimed on a number of occasions on Parkswatch (see here) and (see here) for example.    This is the sort of evidence that the National Park should have included in its review of the east Loch Lomond byelaws which it and the Scottish Government then used to justify the extension of the camping ban to other areas of the Park.  It didn’t, that review report was totally flawed and so is the justification for the proposed camping byelaws.   Because the litter audit provides no basis for distinguishing between impacts of campers and general visitors (see below) it does not even provide a baseline to evaluate any impact of the camping byelaws.

 

Abandoned tents are a very minor problem

 

The most striking “finding” in the report is the number of abandoned tents.    I must confess I looked at the table below and was initially surprised by the numbers.    Out of 146 tents recorded 40 were abandoned.  That sounds terrible.   Aren’t campers shocking?  Over a quarter of campers in the National Park are dumping their tents after use…………you can hear the outrage from the Daily Mail and that is certainly how the LLTPNA I believe want people to read this.  Remember they asked for this to be reported and their main evidence for the byelaws consisted of a large number of photos of abandoned tents taken from different angles.

litter-table-8

 

A little analysis though puts the numbers of abandoned tents in context.   We don’t know how many abandoned tents were ever cleared up:

litter-9

 

The Audits were in the weekday so the tents in use column tells us nothing about the total number of campers compared to abandoned tents.  For that you would need to look at the information in the LLTNPA Ranger patrol data of the total number of tents recorded.  Its possible though to do a quick estimate here.   On a popular weekend according to the LLTNPA there can be over 800 tents recorded on the most popular loch shores.  It was a poor summer so let’s halve that to 400 a weekend, add another 100 during the week and multiply that by 8 weeks.  That comes to 4000 tents.  The Audit found 40 abandoned tents.   That shows 1% of campers abandon their tents.   If you think the 4000 figure is too high, halve it, its still only 2% of campers abandoning tents.   Add to that that it was a poor summer and some campers abandon tents – I know they shouldn’t but it still happens – when they get flooded etc and it really does put this “problem” into context.   The LLTNPA and the Scottish Government have agreed to the creation of camping byelaws and the removal of access rights from the majority of people who camp because of the activities of the 2%.

 

IMG_6616
Even if campsites are installed, it does not stop the tiny minority from abandoning tents (photo previously featured of abandoned tents at Ben Glas farm).

Added to this one needs to ask about the time and effort required to clear up abandoned tents.  Yes, sometimes, there is a wrecked campsite which might take a couple of hours to clean up but often as in the photo above, it would take less than five minutes for someone to pack up an abandoned tent and either put it in the bin or recycle it.   That’s all it took Nick Halls and I earlier this year at the Ben Venue car park.   We took far longer discussing with the Park Rangers whether they would take the tent or not.  They wouldn’t and since there was a hole in it we put it in the bin on the way home.

 

Methodological and other issues in the KSB Audit

 

I will come back to look at the implications of some of the other findings from the audit, much of which is quite helpful, in due course but think its worth highlighting here a number of methodological and other issues which reduces the Report’s  usefulness.  These include:

  • the sites are limited to the four management zones so the Report does not tell us anything about the extent of “litter” within the management zones compared to outside
  • 27 of the sites were chosen because they were included in the 2012 KSB Audit which the LLTNPA used as evidence for the need for camping byelaws.  This would allow a comparison between then and now but strangely no comparison has been made.
  • The audit visits (there were 8 to each site) all took place during weekdays when we know the time of greatest visitor numbers is at weekends.   This means the report is unable to draw any conclusions between the litter reported and the number and type of visitor, i.e who left the litter and how great a problem this is within the context of the numbers who visited.  For example the report makes clear abandoned tents were often not cleared up for weeks (and therefore  the same abandoned tents and other litter was presumably counted week after week).  The LLTNPA does hold data on total visitor numbers from its ranger patrol records, which appear to cover almost all the sites covered in the audit, but there is no mention of this or how it might enable the KSB findings to be seen in context.
  • The report contains limited analysis of the relationship between the type of “litter” found and the type of infrastructure provided to enable visitors to enjoy the National Park.   For example,  KSB was asked by the Park to record fire sites and incidences of human excrement as well as litter but this is not related to whether barbecue sites or toilets  were available on any one site.   There is plenty of anecdotal evidence about this in the report – you can see that sites that have toilets are the ones least likely to have human excrement reported – but none of this is drawn out.   While the report, in the summary for each area, lists the number of sites with litter bins and records the number of overflowing bins, there is no analysis of the relationship between litter bin provision and litter.      I think if an analysis of the relationship between infrastructure and issues had been undertaken,  it would have shown up the failure of the LLTNPA to provide the type of infrastructure that is needed. Instead the Report  recommends that “the Park Authority undertakes an audit of bin provision”.     This is strange because KSB appears to have this information and I find it incredible that the LLTNPA, which has repeatedly claimed it has tried for ten years to solve the litter problem on our loch shores without success and has used this to justify the camping byelaws does not even appear to know where litter bins are provided and who should be emptying them.
  • The Report does not consider the incidence of litter within the context of other visitor management measures, ranging from the alcohol byelaws in place on east Loch Lomond and around Luss (how did this impact on the numbers of alcoholic drinks cans and bottles found?) or when litter bins were emptied or even if the people who empty the bins where they exist also have responsibility for cleaning up the area.

 

While the Report therefore is in some ways quite limited, and the recommendations it contains appear to bear little relationship to the content, there is an opportunity to relate the evidence it provides to other data held by the LLTNPA and for more systematic analysis.

 

What needs to happen

 

  • The LLTNPA Board should discuss in public how it intends to respond to the KSB audit findings and more specifically commit to commissioning independent analysis of how the information from the audit relates to other information, including ranger patrol records, held by the Park
  • The Scottish Government should use the information from the KSB to scrutinise the LLTNPA review of the east Loch Lomond byelaws (which the civil servants accepted without any apparent scrutiny)  and review its findings (which would in my view undermine the case for the camping byelaws which the Scottish Government has accepted)..
  • Its time the Scottish Parliament scrutinised the so-called evidence which has been used to justify the removal of access rights in the National Park
  • The LLTNPA and Scottish Government need to refocus their efforts and the resources that will be wasted in trying to ban campers on provision of basic infrastructure in the National Park and targetted educational messages

 

There is a great opportunity for some independent research to be undertaken about the relationship between the information in the KSB audit and the data patrol records held by the Park but in the public realm and looking at how this relates to basic infrastructure.

 

October 13, 2016 Nick Kempe No comments exist

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Last week I received a reply from the Loch Lomond and Trossachs National Park to my question about how much the new parking meters at Inveruglas had cost.  I made the mistake first time of asking how much it had cost the LLTNPA to install these meters and was told (eir-2016-040-response-car-parks-and-charges)  £562.20 plus two hours labour from National Park staff.  So, I had to ask again but now know   (eir-2016-050-response-cost-inveruglas-pay-and-display) they cost £7846.   However, because the LLTNPA  tendered for an Automatic Number Plate Recognition system for this car park  (see here) almost as soon as it had installed the meters,  this money has been wasted as new equipment will be required.

 

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Leafield recycled litter bin £145

Its a bit like dreaming how you might spend the lottery but I would have spent the £8408.20 on litter bins for the west Loch Lomond laybys and then asked (or shamed if necessary) Argyll and Bute Council to get their bin lorries to empty them as they drive past.   On the internet and heritage litter bins cost somewhere between £150 and £350.   Purchase through a public sector contract and maybe the National Park would get a discount and the delivery thrown in.   Even 24 high quality bins would be a start.

 

There was a very good article on the management of litter in the Voice, the magazine of the Friends of Loch Lomond and Trossachs, which came out this week.  Along with a photo of overflowing litter bins at Balmaha, it pointed out that every layby along the A9 has bins, unlike the A82, and there is no litter problem.

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Layby between Ballater and Balmoral

The Voice might have added that the A93 on the other side of the Cairngorms National Park is the same and what’s good enough for Royal Deeside should also be good enough for Loch Lomondside.

 

The level of waste at Inveruglas is paltry compared to the £345k that the LLTNPA budgeted to spend this year on creating camping places for which there is no demand at Loch Chon  (see here).  And that is likely to be dwarfed by the resources the LLTNPA will have to devote to trying to police the proposed camping byelaws.

 

I believe the main explanation of this waste of resources is less management competence than the LLTNPA getting its priorities wrong.  If instead of trying to police campers the LLTNPA were to focus on basic infrastructure such as toilets (the Voice has another excellent article on the impact of staff cuts on the public toilets at Luss), litter bins and barbecue pits, it would have far more chance of success.   This infrastructure would cost far less than the extension of camping byelaws and would remove the need for the National Park to start charging for everything, which is what led to the stupid decision to install car parking meters in Inveruglas in the first place.

October 11, 2016 Nick Kempe No comments exist
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Rubbish in the field opposite Park Convenor, Linda McKay’s House, at the east end of Loch Venachar 8/10/16

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

 

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

 

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

 

 

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

 

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

 

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

 

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

 

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

 

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

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

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

 

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Extract from original Five Lochs Plan showing the North Loch Venachar camping area and toilet

 

September 21, 2016 Nick Kempe 4 comments
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Lochs and Glens buses appear to regularly park overnight at the Inveruglas car park

If you have passed up or down the A82 this summer you may have noticed Lochs and Glens buses parked overnight in the Inveruglas car park – I have several times.   This is one of the car parks where the Loch Lomond and Trossachs National Park Authority want to introduce parking charges which will be enforced through number plate recognition technology (see here).  I was intrigued about what arrangements might be in place now between Lochs and Glens, which is a prominent business in the park and is a member of Love Loch Lomond, and the Loch Lomond and Trossachs National Park Authority.  So I asked and at the end of last week received this response.

 
The Park Authority has no agreement with Lochs and Glens for the use of Inveruglas car park. Therefore I have to advise you under Regulation 10(4)a of the EIRs that there is no relevant information held.

 

I believe this gives a further insight into the warped priorities of this National Park Authority.    Here is a business which appears to be using Inveruglas as a free depot to park its buses on a regular basis and the LLTNPA has simply allowed this to happen.  It’s a business encampment!   However, while the LLTNPA was using encampments in car parks to justify the proposed byelaws, it does not appear too worried about this one.  Indeed I don’t recollect any mention of business encampments during the byelaw consultations –  but maybe this was not happening back then.

 

What I find particularly interesting is the LLTNPA, whose rangers must know better than anyone from their daily patrols how often the buses are parked here, appears to be doing nothing about it.   If they think its a problem, why not act?   While there are specific remedies for encampments (see here) its much simpler with a business, you simply take out an interdict preventing them from ab/using your property.

 

If its not a problem though, what a missed opportunity.   Lochs and Glens – and I have nothing against it as successful bus tour business – is a member of Love Loch Lomond, which represents local tourist businesses.  Now while Love Loch Lomond supported the introduction of camping byelaws in its formal response to the Your Park consultation it was also in favour of more camping places, including new campsites, and specifically mentioned the  need for improvements to toilet and litter infrastructure.  Inveruglas is an ideal stopping off point on west Loch Lomond, its not close to houses and there is space for people to camp behind the scenic routes viewing tower.  However, while Inveruglas has a toilet, you can only access it at present through the cafe which closes.  So why not ask Lochs and Glens to install an additional toilet or a new external access to the existing one in return for free parking.   This would enable people to camp or stay in their campervans overnight with minimal impact.

 

Unfortunately, the agenda of the LLTNPA is to restrict access to the shores of our lochs, not just through the camping byelaws, but by installing gates across all its car parks and introducing parking charges wherever they can.   The LLTNPA is far too busy planning for this disaster to do anything creative like talk to Lochs and Glens and other businesses to come up with creative solutions to the issues.    I suspect local businesses could even be persuaded to pay for the installation of litter bins on every layby on the A82 (its not a lot of money) – which would have a far greater impact on litter than the camping byelaws –  if only the LLTNPA could persuade Argyll and Bute Council to get its bin lorries to stop as they trundle up the A82 and empty them.

 

September 9, 2016 Ross MacBeath No comments exist

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

 

Small but perfectly formed

 

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

 

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

 

Smaller still, but out of touch

 

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P & K litter bin Loch Earn – Photo Credit Nick Kempe

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

 

Meetings about meetings as the Park Authorities failure to act continues

 

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

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

Innovative Approach or just good Management?

 

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

A stark and damning contrast

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

 

Polar opposites

 

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

 

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

 

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

 

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

 

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

Appendix 1 – Fixed Penalty Notice Policy

Appendix 2 – Fixed Penalty Notice Scheme of Delegation

 

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

 

New Forest Litter Strategy

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

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

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

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

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

 

Reporting litter and fly-tipping

 

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

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

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

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

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

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

Contact details:

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

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

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

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

 

What is being done

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

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

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

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

Recent joint initiatives include:

  • Each year, staff visit schools across the New Forest to talk at assemblies and to individual classes about why it is so important not to drop litter. These are specially themed sessions that appeal to the age of the children and link to their curriculums.
  • Rangers and education staff often talk with people who might not normally think about litter through public events and at local fetes. Some of these are ideal for the topic – for example an annual Marine Wonders event at Lepe Country Park is a great place to talk about the effects of litter on the sea.
  • Each year, litter picks are organised in a variety of places, ranging from beaches to Open Forest. Usually these are instigated by local community groups but equipment such as litter pickers and tabards can be supplied on loan. Guidance on organising a litter pick is available from the District Council, which is able to call by to pick up bags at the end of the event. Following the success of the Clean for the Queen event in March 2016 we intend to promote an annual ‘spring clean’ – please let us know if your group or organisation would like to get involved.
  • Litter bins are provided at key locations throughout the Forest. Specially designed litter bins have been installed in villages where ponies graze. Not only are the bins pony-proof, but they have a routed ‘message’ saying how important it is not to leave litter where the animals might try to eat it. The Forestry Commission’s car park litter bins are also pony-proof and carry the same message; some locations have double-sized bins to cope with the demand.
  • Each year, posters are put up at key locations across the New Forest including car parks and windows of local businesses. To catch the eye of regular visitors, posters are changed at regular intervals, and rotated with posters about other important topics.
  • Increasingly, social media is used to encourage people not to drop litter. Through Facebook and Twitter we can reach a very wide local and visiting audience.
  • Roadsides are regularly litter picked by NFDC contractors, either at a regular frequency or when excessive litter is reported. This currently includes a contract with the Forestry Commission to cover Crown Land roadsides.
  • Hampshire County Council and Highways England are both committed to liaising with NFDC to ensure that where possible litter picking is coordinated with verge maintenance activities.
  • Please visit our webpage signposting people to the best ways of reporting litter. No single organisation is responsible for litter across the whole of the National Park, and it really helps those who are responsible to be quickly informed when there is a problem.
  • New Forest organisations have joined Tidy Britain Group’s Love Where You Live campaign. This encourages people to take pride in their local area and inspire them to get out there and make it the kind of place they want to live and work. It is planned to be a 10-year national campaign with widespread advertising and we welcome this additional publicity.
  • There are some good examples of local businesses that actively encourage their customers to take litter seriously and, for example, staff from the McDonalds restaurant at Picket Post regularly litter pick nearby roadsides. We hope to work with other local businesses to encourage best practice wherever possible.
August 1, 2016 Nick Kempe 1 comment
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Why do none of the LLTNP’s new landscaped parking areas in the Trossachs have litter bins?

Following my post on the LLTNPA’s unfortunate decision to use National Park’s week to launch its new litter enforcement powers, when other National Parks across the UK were celebrating the theme of adventure, there was an excellent letter in the Herald today from James Fraser, Chair of the Friends of Loch Lomond and Trossachs.   (While I have got to know James over the last year as we now both sit on the Executive of the Scottish Campaign for National Parks my post and his letter were written independently).    He made a number of points that are worth repeating:

  • the contrast between provision of litter bins in laybys on the A82 and A9 (both major arterial routes) is striking.  That the laybys along the A9 have much less litter is not a coincidence.
  • asking visitors at busy attractions to take litter home does not work (this was one of main themes of the Park’s press release covered in my post)
  • there are significant inefficiencies in litter collection with different authorities emptying different bins even with the bounds of one location

Yet more arguments for why the National Park, following its paper to the last Board Meeting on litter, needs a proper litter strategy in which all four constituent local authorities and Forestry Commission Scotland play their part.    The good thing though is that both the Park’s publicity and the public debate has moved on from campers being the source of all litter.

 

38 Degrees and National Parks week

 

Yesterday I received an email from 38 Degrees about National Parks week.  Now I think its great 38 Degrees are trying to support National Park’s week, and I have every sympathy for what is going on in England where the Government is threatening to turn National Parks into fully commercial organisations which have to fully fund themselves.

 

38 Degrees, which have a Scotland team, don’t seem to realise though what is actually going on in the LLTNP and instead put out the type of spin that they should be trying to combat:

 

“It was amazing! From all over Scotland, 38 Degrees members were out enjoying our national parks in Loch Lomond and the Trossachs and the Cairngorms yesterday”

Well yes they were, as people on every day of the week, but not thanks to National Parks week.  The comment that followed “with events happening in every single national park in England and Wales” said it all.   They could not include Scotland in the message as LLTNPA, unlike CNPA, had not done anything to encourage people out adventuring.

 

I am delighted though that 38 Degrees have set a new challenge for themselves with the following quote:

 

“My parents met during the great trespass of Kinder Scout. So if it wasn’t for the campaign that created national parks, me, my sons and my grandchildren – we wouldn’t have existed!” – Trina, at Loch Lomond & the Trossachs

I don’t know whether 38 Degrees have quoted Trina correctly but the Kinder Scout mass trespass in 1932 was not about creating National Parks but rather about securing access to open countryside.  It was pressure for access that created the demand in England for National Parks – places where access would be secure.   Its therefore rather ironic that Trina stated this in LLTNP where the National Park Authority has been leading the charge to reverse access rights in Scotland with its proposed camping ban.  But then, perhaps like many other people, she was simply unaware of what the Park has been proposing.   I was reminded of this today when I asked someone at work what they had done at the weekend – I was surprised to hear she had gone camping on Loch Arklet.  There was only one other tent there – quite predictable from the Park’s own data.  She had no idea Loch Arklet was included in the camping ban and her response on hearing this was “that’s rubbish”.

 

The challenge for 38 Degrees I think is help make their members aware of the serious restrictions to access rights being proposed by the LLTNPA and to help mobilise their members to get these reversed.  I hope this includes a mass campaign of civil disobedience as at Kinder Scout if necessary.

 

 

July 26, 2016 Nick Kempe No comments exist

Yesterday was the start of National Parks week, an annual celebration of National Parks in the UK.   The theme of National Parks week this year is adventure.  The Cairngorm National Park Authority has responded to this with a positive press release press release about celebrating National Parks, announcing a number of events and encouraging people to share ideas for adventures.   Quite a contrast to the LLTNPA whose press release http://www.lochlomond-trossachs.org/looking-after/national-park-visitors-encouraged-to-respect-your-park/menu-id-483.html makes no mention of adventure.

 

Instead the LLTNPA have used National Parks week to announce the implementation of their new powers to fine litterers ( see http://parkswatchscotland.co.uk/2016/06/11/way-forward-litter-loch-lomond-trossachs-national-park/) and a number of other initiatives to ensure everyone visiting the National Park behaves responsibly under the banner of “Respect your Park”.  Now I am not against any of these initiatives but I think the fact that the LLTNPA has simply ignored the theme of adventure, which is about people have positive experiences in our National Parks, and instead focussed in this week of all weeks telling people what they should not be doing tells us something.  If the Park started to promote adventure, this would conflict with its proposed ban on lochside camping, which is one of the most important ways people have adventures at present.   Think of Duke of Edinburgh expeditions, backpacking, cycle touring, canoe touring, all activities which involve adventure.  Better then simply to ignore the adventure theme to National Parks week.

 

The LLTNPA Press release contains another interesting statement relevant to the camping byelaws from Chief Superintendent Stevie McAllister, Divisional Commander for Forth Valley and Police Scotland Lead for the Loch Lomond & The Trossachs National Park:

 

“For the best part of a decade, officers based within the Loch Lomond and Trossachs area have worked closely with the National Park to deter offences such as antisocial behaviour and identify those responsible.

“This has already proven extremely successful with crimes of this nature now significantly reduced, particularly within the East Loch Lomond and other lochshore areas and the vast majority of visitors behaving responsibly during their stay.”

 

I am delighted that Police Scotland are now publicly acknowledging that anti-social behaviour crimes are much reduced and most visitors behave responsibly in the National Park – why then did they support the proposed extension of camping byelaws?   Readers may recall that in trying to justify the camping byelaws the LTNPA continually asserted that it was camping byelaws that had led to an 81.5% reduction in ASB on east Loch Lomond, when in fact the statistic was for a wider area and represented a reduction from 27 to 5 crimes.  Police statistics showed that there had been a 42.4 reduction in ASB in the rest of the central Scotland Police division of the National Park where no camping byelaws, alcohol bans or other special measures were in place.   Well done the police but how can Stevie McAllister now continue to justify the removal of access rights from “the vast majority of visitors behaving responsibly during their stay”?
Each time the LLTNPA publishes anything on visitor management, they provide yet more evidence of  the incoherence of the proposed camping ban.   While I believe the timing of this education campaign is extremely unfortunate, with anti-social behaviour tackled, and with its new powers to tackle litter, what further justification has the Park and Ministers got for proceeding with the camping byelaws?

July 18, 2016 Nick Kempe No comments exist

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Dear LLTNPA,

 

I know that the LLTNPA is very pre-occupied with branding, so that every signpost has to be in your corporate colours, but I really wonder if this is the best way to get messages across?   I have been a few time to the Carrick Nature reserve and never seen any litter.  There is a bin by the entrance, which helps, but I think this small notice is more powerful than anything our National Parks have ever produced.

 

I am reminded of the old message – which had nothing to do with our public authorities – “take nothing but photos, leave nothing but footprints”.   Instead of deciding everything centrally, why not fund local communities and people who visit the National Parks to produce their own signs?   It might just be more effective.

 

Here’s to a litter free Scotland

 

 

June 14, 2016 Nick Kempe 2 comments

I have now been observing Board Meetings for 18 months and the one on Monday was twice as long as usual (the shortest has been over in 45 minutes), all because there was some debate in public.  A welcome development even if the meeting again demonstrated much of what is wrong about how the Loch Lomond and Trossachs National Park Authority is run.

 

The meeting started with the Governance and Legal Manager reading out a statement quoting sub-clause of this and clause x of that to justify why item 17 on the agenda, on Vacant Assets, was being held in private.   The statement will no doubt be quoted at length in the minute to demonstrate the transparency and superb governance of the LLTNPA.   No reference was made of course to the secret Board Briefing session which had taken place that morning or how many other such secret meetings had taken place since the last Board but since these are never minuted, we will never know whether it was legally justified to hold them in secret.   The Park seems incapable of grasping that the concerns of transparency campaigners, like myself, is not that the Board discusses the occasional item in private – I’ve been on a Board, I know its necessary on occasion ,even if I often think the outcomes of such meetings could often be made public at a later date – but the majority of this Board’s business takes place in private, including the dozen or so meetings that developed the camping byelaw proposals.

 

As I expected, there was then not a single mention of the Owen McKee case in the discussion of the annual accounts – the LLTNPA is indeed trying to airbrush the glaring failures in how it handled Owen McKee’s trading in shares from its history.   Why the Board might get away with this was eloquently explained by  Lindsay Morrison, the convener of the Audit Committee, later in the meeting when he said that Audit Scotland had never once highlighted to him any issues of concern about the governance of the LLTNPA.  This is the same Audit Scotland who have confirmed in writing to me both that they were never informed by the LLTNPA about the Owen McKee case and also that they would have been expected to have been told.    While in my professional life I worked with staff from Audit Scotland and had nothing but respect for them, in this case it appears that the lead auditors have failed in their professional duties and the Annual Report is not worth the paper it is written on.  I didn’t have much sympathy therefore when it was revealed in the meeting that the Scottish Government has decided that Audit Scotland will be replaced as external auditors of the Park.  Whether Grant Thornton, a private firm, will be any better remains to be seen but just to get them going here is a list of the serious governance issues concerning LLTNPA which I raised with Audit Scotland and which they apparently failed to discuss with Lindsay Morrison Letter to Kevin Boyle151221

 

The Board failed to question other aspects of the annual report, which is full of photos and very little content, and formally approved it.   Some of the spin is enough to make you laugh or cry:

 

    • From the Forward, entitled “Welcome”  – whoever welcomed people to a document rather than a place? – Linda McKay, the convener, and Gordon Watson, the Chief Executive “Our Your Park initative to enhance the camping experience on our most heavily used lochshores took a significant step forward with the approval of the camping management byelaws by Dr Aileen McLeod, Minister………….”    The use of “our” and “your” almost says it all but  the claim that banning campers is the best way to enhance camping is Orwellian newspeak at its best.
    • Then there is this photo to illustrate the work that has been done on the West Highland Way between Rowardennan and Rowchoish

Buachaille

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

It left me wondering whether any Board Member has walked the West Highland Way or knows where the boundary of the National Park is.

Linda McKay, the convener, then raised (under the section of the annual accounts where the LLTNPA reports on gender equality) concerns that the Park’s Board is predominantly composed of men.  Councillor George Freeman challenged her on this, pointing out that most of the Board were democratically elected (unlike Linda McKay) and ultimately it was up to the electorate to take these decisions.   Unfortunately, he did not have the temerity to point out that it was this same Linda McKay who sat on the interview panel which selected the most recent Government appointee to the LLTNPA, one Major James Stuart,  and that she was the one member of the Board who actually had any power to change this.   The quiet effrontery of Linda McKay never ceases to amaze me but then she was playing to the national politicians.   What Linda McKay did not say was that though the senior management is presented as balanced within the Annual Accounts, within that team the men have the best paid and the women the lowest paid jobs.   She of course has had the chance to influence the structure of that team more than anyone else.  Hypocrisy and more spin!

 

The meeting then started to improve.  First there was a report on progress on the Park’s camping management proposals which I will deal with in another post.   There were no decisions taken and still too much secrecy but reporting on progress in public was still a step forward.

 

The discussion on litter though was a revelation, a view shared by Peter Jack of the Loch Lomond Association who has been attending Board Meetings with me for the last 18 months.  It would be nice to think that some of the debate was spurred by my post  two days ago but Board Members made a number of points that added signficantly to that analysis:

  • Cllr George Freeman set the context of litter being a national problem, that roadside verges and that of the A82 in particular, were a disgrace and pointed out that Transport Scotland have a major role to play here as they manage trunk roads in Scotland.   Spot on!
  • Cllr Freeman also asked if the Fixed Penalty Notices for fly tipping which the Park was about to implement would cover landowners (a clear acknowledgement that landowners are a major source of the problems).  They will not, but Gordon Watson I think it was stated that the Park could report these cases to Local Authorities who could take action.   No-one asked about the obvious failures of the Park to do this
  • Cllr Fergus Wood though expressed great disappointment at the lack of progress with Councils about litter collection facilities which had been talked about for years – and which have been highlighted on Parkswatch.  Several other Board Members strongly agreed with this.  Cllr Wood pointed out that he had never been asked to liaise with his Council to help sort this since he had been on the Board – amazing as this is why I thought Councillors were on the Board but good for Cllr Wood for raising this as a concern –  and also that as bin lorries pass all the popular stopping off places in the Park anyway it should not be difficult for the Councils to install litter bins and uplift the litter.   Spot on again!
  • Someone then had the temerity to suggest the LLTNPA should maybe suggest to the Scottish Government that throwing litter out of cars should become a Road Traffic Offence.  I thought this was a great idea but it was quietly deflected by the Convener.
  • Colin Bayes, the one Scottish Government appointed Board Member who avoids Government speak (outcomes, governance, missions etc) then reminded the Board that lack of toilets and litter facilities are the two concerns that have been consistently raised in the LLTNPA’s visitor surveys.
  • David McKenzie raised the issue of litter at the head of Loch Long (again featured on parkswatch) and pointed out that after one storm half of the 3500 items of rubbish collected by the local community originated in adequate sewerage facilities along the loch (tampons etc).  Part of the answer therefore should be to engage with Scottish Water.  Spot on!
  • David McKeown, the local rep for Luss, then asked if the Park rather than just talking about this did something, took the bull by the horns and started to pick up litter.  He made the very interesting suggestion that funds be diverted from education to pay for litter collection and justified this because he had done litter picks and found that where places are clean, litter is far less likely to be dropped.   While greeted initially with amazed laughter, he kept going and then Colin Bayes came in to support him saying all the research shows there is less litter in clean places.  Unfortunately, no-one suggested one way to reconcile education with litter picking would be to allow the LLTNPA’s very own Ranger service to remove litter rather than simply leave it at the side of the road.
  • Councillor Martin Earl raised questions about how new technology, such as remote cameras, could be used to prevent flytipping in the worst spots (an obvious solution to the huge fly tip on Loch Long at the old torpedo station)
  • Various members asked about how Fixed Penalty Notices for littering would be enforced and were strongly supportive of the educative rather than punitive approach.

Four things struck me about this discussion:

  • All the ideas and the debate came from Councillors and locally elected representatives, not the Scottish Government nominees.
  • That the implications of the discussion are that camping byelaws are not the answer to anything (the answers are about education, infrastructure and targetted enforcement directed to people who do not respond to an educative approach).  The question is when will the obviously knowledgeable Board Members who are able to think critically realise this and say enough is enough, there are far better and more effective ways to deal with irresponsible campers/litterers?
  • It did not lead to a single new decision.   I was left unclear at the end of the discussion what if anything would happen apart from staff being asked to go back to Councils and try harder to work with them (which is very difficult when as Cllr Freeman pointed out West Dunbartonshire Council is facing £11m of cuts this year and next).  Linda McKay resisted a couple of suggestions that the LLTNPA should write to the Government suggesting what they could change – which to my mind is exactly what our National Parks should be doing.  Acting as advocates for the changes needed in the way our countryside is managed.
  • That part of the reason for the Park’s inability to address litter issues is that there is no proper budget for this and without budgets, nothing happens.

The final revelation in the meeting was that the secret Board Briefing session that morning had been about risk.  The camping byelaw proposals were identified on the Park’s risk management register as the single greatest risk facing the LLTNPA so this was almost certainly an indication that yet more secret Board discussions are taking place on camping.  It probably explains too why there was so much less discussion at the meeting on litter than on the Your Park proposals (which should be the subject of my next LLTNPA post).

June 11, 2016 Nick Kempe 2 comments

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

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

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

  • The new Minister for the Environment, Roseanna Cunningham, who chairs the annual review of the Park’s Partnership Plan, should call a special meeting of the Park and Local Authorities to review the lack of progress they have made on installation of litter facilities and set clear timescales for production of implementation of a litter strategy.   She should also insist the Park develop a proper plan – the Five Lochs Management Plan had a section outlining the actions needed on litter which have sadly never been progressed but would provide a good starting point.
  • The new Minister of the Environment should now acknowledge that campers only account for a small proportion of litter problems in the National Park and littering is not a justification for the removal of access rights.
  • The LLTNPA needs to be told that its litter strategy must  include a plan for addressing marine litter (including exploring the implications of the National Marine Litter strategy), farm litter, dumping and rubbish left by developers
  • The LLTNPA, instead of imposing education messages on people, should engage with visitors about what messages might influence them to take even more care because it’s a National Park.  It should also consider how it can use people who care about the countryside most, which includes walkers and campers, to spread the message.  This means engaging with the recreational organisations such as the Ramblers and all the activity organisers who use the Park at present and whose activities are now threatened by the Park’s proposed bye-laws.
May 25, 2016 Nick Kempe 1 comment

Following my  contribution concerning the condition of Duck Bay picnic area at 09.30 on Monday 16/05/2016.  On returning to Argyll from Glasgow on the evening of Wednesday 18 May 2016 I looked at the area again. I was impressed, the bins were all empty and the overflowing garbage cleared up, the litter that had been scattered across the area meticulously removed.

 

The people who cleared the debris after the weekend deserve the thanks of both residents and visitors of the National Park.

 

Duck Bay is the first public space that is seen by visitors entering the National Park via the A82, and warrants special measures in respect of accommodating the needs of visitors and maintaining the appearance of the National Park.

 

Views of picnic area from Loch side road.

 

Photo Nick Halls Empty bins with overflowing garbage meticulously cleared.
Empty bins with overflowing garbage meticulously cleared. Photo Nick Halls

 

 

 

 

 

 

 

 

 

 

 

 

View of people using the area, showing low intensity of use during week and usual weather. Photo Nick Halls
Dog walker using area, previously strewn with garbage. Photo Nick Halls

 

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View of people using the area far middle left, showing intensity of use during week and usual weather. Photo Nick Halls

A concern remains that the facilities do not seem to accommodate concentrated use during good weather days and holidays while being sufficient for average or low use periods.  It matters because for obvious reasons most people visit the National Park during holiday periods and good weather, and this may be their only visit. I believe it is important that all visitors at any time of year get the best impression of the National Park.  While it is important to clear up after the egregious behaviours of visitors after a busy weekend it is equally important to ensure the facilities are sufficient to accommodate the requirements of people during periods of maximum pressure.  In order to maintain the reputation of the National Park the facilities and performance of the custodians of the area needs to be exemplary when most visitors are present. If visitors experience a tawdry mess it is little compensation that it will all be cleared up after they leave.

 

Another concern is that provision is made to accommodate visitors using motor vehicles, wishing to picnic and use disposable barbecues, using bicycles and water craft all of whom contribute to the litter problem, some of whom leave more evidence of their visit than is acceptable. However, of all the recreational visitors to the National Park no similar effort seems to be made to accommodate the needs of those wishing to camp.  While it is apparent that some campers leave an unacceptable mess at some locations, the impact of visitors who camp elsewhere does not seem any greater than that of other categories of visitors. The majority of camping probably goes unnoticed as the evidence assembled by the National Park Authority indicates that it is a relatively minor activity, even if egregious behaviour at particular locations is very obvious during holidays and good weather. Clearing up the concentrated debris of egregious road side campers does not seem to require any more resources than needed to restore Duck Bay to a fit state.

 

It seems incoherent that in the locations visited that will eventually fall within the Trossachs Camping Management Zone there do not seem to be any facilities that might mitigate the impacts of egregious camping behaviours or facilitate removal of garbage. The lack of bins and toilet facilities seems extraordinary, as it is not just people who stay in the National Park overnight who need to use a bin or toilet.  At the age of 73, a lack of toilets is a cause of anxiety & discomfort. The ubiquitous toilet paper indicates that I am not alone.

 

The lack of facilities and the introduction of bye laws seems to be an expression of prejudice against campers, and while this may originate from perceptions about the impacts caused by some people who camp,  this is no more than the impacts of other visitors.  Wherever I go in Europe during good weather picnickers arrive, light fires, leave litter and generally trash the area in which I may be staying. The only place I have been where thousands of visitors leave no litter is Japan, where there seems to be a religious respect for the environment.

 

As has been observed in the contribution of Nick Kempe, I have adopted the practice wherever I go throughout Europe & further afield, and stop overnight of ‘obsessively’ picking up every bit of litter, partially to make the area acceptable to my myself, but also as a ‘payment’ to the Creator (or the outcomes of geological processes and natural selection) for the privilege of being able to visit and stay in a beautiful place. I am familiar with how much time and effort is required to keep an area pristine. (I have a collection of second hand tent pegs, camper mats, pans cutlery & guy line second to none).

 

The impacts of visitors, however egregious their behaviour, seems ephemeral compared with the far more gross and permanent impacts of residents & land managers within the National Park, and it seems irrational to introduce bye laws to regulate camping in areas that are already under considerable pressure from other categories of visitors for whom provision is made.   If Duck Bay can be restored within a day, one would imagine the dozen or so locations that provided the evidence to support the introduction of Camping Management Zones can be provided with suitable facilities and maintained in a similar way.

May 17, 2016 Nick Halls No comments exist

On the way to pick up Nick Kempe from Balloch Station to look at proposed Trossachs Camping Management Zones I passed Duck Bay picnic area at about 09.30 on Monday 17/05/2016, after a very pleasant and presumably busy weekend.

duck bay 1
Photo credit Nick Halls

I do not know who is responsible for maintaining the picnic area, but it does represent the first public area after the entrance to the National Park.

duck bay 2
Photo credit Nick Halls

As the pictures show the waste bins were overflowing, litter was strewn around picnic tables, together with tin foil disposable barbecues and old coals.

The surface of all the picnic tables were charred to near destruction. Visitors from England walking their dog were appalled at the condition of the area, but immediately recognised that facilities were wholly inadequate.

duckbay 3
Photo credit Nick Halls

 

I imagine that sometime during the day the garbage would be scheduled for collection, but I doubt whether this would include a thorough clean up of the area. At this time of year garbage collection probably needs to be almost daily.

What struck me was the lack of adequate facilities to accommodate the use that visitors regularly make of the area, the bins are insufficient for the quantity of garbage that is generated. The picnic tables do not seem to be fit for purpose or hygienic to use and the hardstanding area under the tables does not seem to be sufficiently extensive to accommodate the concentrated footfall of users, or allow visitors who do not wish to damage the tables with hot barbecues to use an area of hardstanding close to the table.

Duck Bay 4
Photo credit Nick Halls

 

My impression was that the appearance of the area was in large part due to the inadequacy of the facilities created to accommodate visitor needs. In this particular locality tables constructed of concrete, positioned on extensive areas of hard standing, with bins with a substantial capacity close by would enable visitors to both enjoy themselves, have picnics and to dispose of litter adequately.

There are no toilets, but there must have been hundreds of people.

 

During our subsequent exploration of the Camping Management Zones it became more evident that there does not seem to be a coherent Visitor Management Strategy that accommodates the actual behaviour of the visitors to the National Park.   As an artefact of accommodating visitors in vehicles, the carparks concentrate people.  This makes accumulation of litter foreseeable.  At places were people congregate they commonly require toilets and if carparks are proximal to scenic visitor attractions then litter will be distributed around.   Some carparks in the National Park have bins, others do not, one or two have toilets but the majority do not, some areas seem to have regular litter collection others do not. Litter & toilet paper seems to be ubiquitous.

 

Responsibility for facilities to accommodate vehicles & leisure activities are operated by different bodies, Forestry Commission Scotland (FCS), the Loch Lomond and Trossachs National Park Authority (NPA), Charitable Trusts and the Councils that provide the public services within the National Park.

The responsibility of each of the agencies that contribute to the upkeep of the National Park seem to be rigidly delineated with a division of labour that can only be counter productive. One example we witnessed on our tour (see previous post by Nick Kempe) being that although Park Rangers use an FCS carpark, they do not, even as a part of casual public responsibility for the environment, pick up litter; but 10 metres away litter is apparently their responsibility, although if a member of the public innocently makes the mistake of moving it to the FCS car park, NPA Rangers suddenly have no responsibility for it! It also emerged that NPA  Rangers are not allowed to transport garbage in their vehicles, which I suppose must be a Health and Safety at Work issue.

 

For a visitor or resident of the National Park this apparent lack of coordinated activity of the public bodies that are responsible for the National Park is frankly shocking, and the inadequate manner in which the behaviours of visitors are managed and impacts mitigated seems almost a denial of responsibility.   I am embittered by the thought that much of the employment created within the public bodies is funded from general taxation and the people involved are public servants. I took the litter away myself fuming with disgust.

It is my understanding that the trajectory of National Park Authority thinking is towards increased enforcement, with Rangers empowered to impose fines for littering.  The NPA has a long way to go to demonstrate that it has done everything possible to establish the facilities the visitors need and expect to be available, and which mitigate the impacts of visitor numbers by facilitating their capacity to behave responsibly, before introducing such an expedient.

 

NB In spite of the imminent introduction of Bye Laws restricting camping within the Management Zones, there was no evidence of any efforts to accommodate camping within the Management Zones, even with informal provision, so walkers & cyclists will be obliged to travel considerable distances and actually leave the areas they came to experience without the option of an overnight stay. It all seems so utterly inappropriate and a denial of the purpose of the National Park.