Tag: Scottish Enterprise

December 3, 2017 Nick Kempe 3 comments
Flamingo Land is proposing more buildings the height of the Drumkinnon Tower along the shoreline at Balloch and to develop Drumkinnon Woods behind

There has been a lot of community activity in Balloch since Scottish Enterprise announced Flamingo Land had been appointed developer for the Riverside Site.  You can follow this activity and thinking through a number of Facebook Groups including “Balloch Responds”, “Friends of Drumkinnon Woods” and “Alternative Balloch – A Productive United Village”.

Recently people have been using these pages to articulate alternative visions for the future, complex arguments rather than social media soundbites.  To me, this is incredibly exciting.    While much of the thinking is not explicitly about National Parks as such and its focus more about an alternative vision for the area, the relationship between people and the natural environment is central to it.  As such it is helping to develop an alternative vision for the Loch Lomond and Trossachs National Park which should be of interest to anyone who is interested in the future of our National Parks. .

Bruce Biddulph on Balloch and Tourism

Below is what Bruce Biddulph, who contributed a post on Drumkinnon Woods in the summer (see here), wrote on the “Alternative Balloch FB page” on 22nd November.  It is published with his permission.

“Here is, I believe, a fair summary of what is missing in Balloch, certainly from a visitor point of view:

History: Visitor’s receive practically no idea of Balloch’s history. In fact, none. Even although Balloch sits at the centre of Scotland’s entire history, and has a wealth of historic world class interests in this regard, little is evident to them, and it is not capitalised on. This is an area that is ripe for exploitation – and there is nothing wrong with exploiting that resource for a market value – tourists expect it.

Local Produce and Provision: Sadly Balloch’s stock has gone down over the past few decades.  More and more provision is ‘standard’. Its two hotels and the new inn are now part of groups. there is only one boatyard in the village and no sense of Balloch as an open harbour, which is perplexing to the visitor who sees the river filled with boats but no engagement for them. The supermarket dominates to the extent it has now taken in footfall and has not spread the benefits, worsened by its taking of the post office into its back wall.

Tourist mementos: Lacking. One high end gift shop. Lack of truly Balloch branded stock elsewhere. No “Scottishness” as expected by the visitor. Little in the way for the day tripper to take away or find curiousity about. Linked to lack of historical interest in village’s wider realm.

Accommodation: There may be issues with accommodation but from what I have heard it is that it is a struggle for B&B owners most the of the year Easily addressed if Balloch is made more attractive and has seasonal events created by its community of residents and businesses in co-operation with each other.

All of the above is easily achieved with no great masterplan required. Scotland has many government agencies tasked with assisting communities to grow organically and to be more sustainably productive. The missing ingredient in this is people coming forward as a community to demand their rights as a community to being enabled.

Balloch’s prime disadvantage is Lomond Shores itself. It brings people into Balloch by car, but not to Balloch village itself. Therefore people going to Lomond Shores tend largely not to go any further than the retail area and leave via their cars by the same route. There is no meaningful through route or encouragement to do so. This is why Riverside and Pier Road could have been used as extensions of Balloch village.

There is so much that is positive about Balloch it makes it the envy of all other places in the Loch Lomond area. The lack in Balloch is the community of residents and businesses working together for the common good and for the fostering of other businesses Balloch requires. The above does not even bring into the equation the sheer numbers of related business scattered in its environs and the Vale of Leven that could be accommodated in a linked up and sensitively created expansion of Balloch’s thoroughfares that enhance the village and riverside and protect its beauty and its open access to all. Alongside public realm that has at its heart the spirit of honest  provision for local and tourist alike. Balloch’s success lies in its fusion of free space, its location, and its history of largely providing what visitors want and expect. That provision is going down, its diversity is becoming threatened by homogenisation and the proposal from Flamingoland does nothing to address the main opportunities nor does it do anything whatsoever to grow a future in the hands of Balloch and Balloch-born businesses.

Friends of Drumkinnon Woods

I have not asked to republish this so have just included the link:

The Economics of Free Wild SpacesIt's a sad reflection of our times that to make a case for almost anything now,…

Posted by Friends of Drumkinnon Woods on Tuesday, November 28, 2017

 

Imagine the potential if our Public Agencies, instead of supporting large businesses, started to support local people and local businesses to develop proposals for the Riverside site based on the Park’s statutory objectives of conservation, public enjoyment, sustainable economic development and sustainable use of resources.

November 20, 2017 Nick Kempe 7 comments
Extract from Flamingo Land/Iconic Developments consultation display

On Friday I went to the first of the Flamingo Land consultation events at Lomond Shores in Balloch.  I was not sure what to expect partly because the proposals have been developed in secret (see here) but also because – like many people I suspect – I don’t think like a developer.   The display of the proposals – they are now all online (see here) – made it clear Flamingo Land want to develop ALL the land they and we/Scottish Enterprise own to create a holiday resort.  This is encapsulated in their portrayal of the “site wide experience” (see above) but there was already a big clue in the name of their development vehicle, “Iconic Leisure Developments”.

 

I left Lomond Shores thinking that the only way the Loch Lomond and Trossachs National Park Authority can only approve the development of this holiday resort if they ignore all four of their statutory objectives, conservation, public enjoyment of the countryside, sustainable economic development and wise use of resources.

 

The “consultation”

Extract from Flamingo Land/Iconic Developments consultation display

While the detailed design plans for each component of the development may well be at an early stage,  Flamingo Land’s statement that it will submit an application for Planning Permission in Principle (see here) early in 2018 means the main elements of the proposal have already been decided.  If an overwhelming majority of consultees object to one or more elements of the proposal, there is no time to develop alternatives.  In addition, most parts of the Environmental Impact Assessment must either be well developed or complete by now but all of these have been withheld until the planning application is submitted.   So much for the Scottish Government’s commitment to “co-production”.  On the one hand they support community planning events, which included the Balloch charrette (see here) earlier on this year,  but at the same time they allow developers and “the market” to carry on as they always have.

 

Something is very wrong when consultation and involvement for what is an extremely large development in a National Park – and remember the emphasis now is on consultation prior to any planning application being submitted – is limited to a handful of days when the public can view an exhibition and are given the opportunity to comment on this.    Those attending were hit with a chocolate box of  new proposals from a mono-rail and aerial walkways to outdoor swimming pools and, while given the opportunity to ask questions of the team of consultants present, after this tasting were asked to give an immediate response.  While I overheard and took part in a number of very interesting discussions, there was no real opportunity to think or talk through the implications let alone offer alternatives.

 

There is another, and final, consultation event Monday 4th  December but at least the consultation questionaire is now online which gives people a little longer to consider how to respond.

 

The main elements to the proposals

Extract from map showing proposals for Riverside site

The two key big ideas developed in the Balloch Charrette, for a walkway along the River Leven connecting the town to Lomond Shores (about which I was sceptical) and a bridge across the mouth of the River Leven to connect Lomond Shores with Balloch Country Park (and therefore the countryside) have both been dropped.   Both proposals were about improving the public realm but neither would have brought financial benefit to the developer and its almost certain money is behind this raising the legitimate question as to what appointing a private developer will bring to Balloch.

 

Instead, the proposals appear to about using every available inch of space on the site to make money for Flamingo Land.

Greenspace 

While Flamingo Land are claiming to be preserving this, every element is to be intensively used, as you can see by the number of lodges in the proposals map above.   Just why this number of holiday lodges are needed at Balloch is not explained.

Drumkinnon Wood

This is very well used by the local community, but the proposal is for it to become one of the gateways to the development via an aerial walkway (4) which conveniently by-passes Loch Lomond Shores, as well as providing (from a count) 31 holiday lodges, some of which apparently may be up in the trees.  Along with this is a Forest Adventure Area” (3) and Children Area’s (5).   How this will leave any room for nature in what is an Ancient Woodland Site is not explained.

The parkland along the River Leven

This is to be filled with another 39 (again my count) Holiday Lodges (that makes 70 Lodges in all) but is also site for a new monorail linking the station to the Flamingo Land visitor hub.  This is private transport to take people to a private development,  quite a contrast to when the public railway took people to the edge of the loch in Balloch’s heyday.  While Flamingo Land are saying that none of the lodges will be fenced off, I think people will be left feeling intensively uncomfortable about intruding on private space if they step off the path which forms part of the John Muir Way.  The proposal changes what was a path through parkland into a path through a glamping site giving people every incentive to take the monorail.

The pierhead

The land at what is described as the pierhead (7 in diagram above), which currently offers the best views over Loch Lomond, is being proposed for intensive development which may be as high as the Drumkinnon Tower.  This includes a 60 place luxury hotel and an indoor water sports development.

Viewing Tower

For those who who not want to pay for the resort facilities to enjoy the views, the proposal is for a viewing tower behind the development so people can pay to look out over the hotel and watersports facility to see Loch Lomond.   This is I believe privatisation of a public good, made even worse because the design of the resort is such that there is nowhere else people can go to enjoy the views and nature.  This might have still been possible if a bridge was constructed over the River Leven into Balloch Country Park and if Drumkinnon Woods had been left as a space for informal recreation.

Transport

While the proposal claims to put walking and cycling at the heart of the development,  current roads and parking are basically to remain as they are, except for the Lomond Shores overflow carpark which is to be taken over for people staying in Flamingo Land accommodation despite current shortages.  Locals and visitors can therefore expect parking to get worse at peak periods.

The Ben Lomond Way behind the Drumkinnon Tower separating Lomond Shores from Drumkinnon Wood (photo from day of consultation event).  The lack of people tells you everything.

There are currently two roads to the the Pierhead area, Ben Lomond Way and Pier Rd. These see little traffic except when people are trying to access the Park operated public boat launching slipway, the only one left on the loch, and a parking area which is distinctively suburban.   The roads and carpark segment the site with the result that walking from Lomond Shores to the River Leven is not a good experience.   With a bit of radical thinking, consultation with boat users on their needs and alternatives and some expert input there must be opportunities to remove one of the roads  and the parking area improved.  Instead, the suburban blight is left at the heart of what is supposed to be an iconic development.  Another opportunity missed.

 

Are there any good elements to the proposals?

I thought there were two elements to the proposals that might enhance the National Park, rather than undermine its core purpose, and both were well away from the loch shores.

Extract from Flamingo Land/Iconic Developments consultation display – Station Square

 

The charrette identified the space by the bridge over the River Leven as needing improvement and the ideas Flamingo Land has produced appear informed by this (helped I think because there has been some involvement in other stakeholders such as Sustrans in how this part of the site might be developed).   Is a big developer needed to do this?  It seems to me the sort of proposals being made for this space could, with a little vision from our public authorities, be implemented by a Community Development Trust.   This could, for example, provide a bridge between people in the local community and effective use of the proposed outdoor performance space.

The other part of the proposal I liked was for the land in front of Woodbank House, basically a public space for people to enjoy themselves without having to spend money.   Not a natural landscape but not incompatible with the objectives of the National Park.

 

How do Flamingo Land’s proposals fit with the statutory objections of the National Park?

Conservation

The proposals are to jam pack the areas of ancient woodland on the Riverside part of the site with developments so they became a version of Go Ape.   That was not appropriate for Pollok Park in Glasgow and is not appropriate for a National Park.

In landscape shores, what can be seen from a sixth storey hotel bedroom, will equally be seen in the opposite direction.  Since the 1980s the woodland setting on the west side of the mouth of the River Leven has been progressively destroyed, first with Lomond Shores and now by the Pierhead Proposals.   The most intensive part of the development is in the wrong place.

 

Public Enjoyment

While the shoreline between Lomond Shores and the Maid of the Loch does not offer a quality experience in terms of the immediate environs, the public have a right to walk along most of shore and enjoy the views.  This space, if the proposals go ahead, will effectively be privatised while the ability of local people to enjoy Drumkinnon Woods will be severely compromised.

This is part of a wider process about control of space:  the camping byelaws for example, which prevent people from camping where they always have done in direct contact with nature, have been used to channel people to commercial campsites.  The commercial success of the proposed camping pods at Flamingo Land will depend on the continued ability and commitment of the LLTNPA to the camping ban.

Moreover, the Park’s statutory duty is to promote enjoyment of the special qualities of the Park, not to promote indoor leisure developments or intensively used tree top walkways.   I have been to Landmark in Carrbridge a couple of times, and while I have never much wildlife there,  at least you get the feeling that you could step outside the centre, away from the crowds and aerial walkways, and see something in the neighbouring woods.  At Flamingo Land there is no space left for nature or for people to enjoy it.

 

 

Sustainable Economic Development

Without detailed design plans, its not possible to tell yet whether the development will be sustainable in terms of issues such as use of materials and energy or how many and what type of permanent jobs it will create.     One can at this stage question other elements of sustainability.    Apart from the claim that Abellio is interested in improving the train service, all the indications are that the development will increase traffic to an area which already groans under the number of cars. The bigger issue though is about sustainable tourism and why people would wish to stay in a Flamingo Holiday Lodge or hotel at Balloch for a week?

The idea of promoting Balloch as a gateway to the National Park makes sense but people tend not  to linger in gateways for long (unless forced to do so, for example by the camping ban) and the  pattern of tourism to the countryside is changing to short stays.   There is not one element of the proposal that I can see that is about enabling people who book accommodation to travel out to experience and enjoy the National Park.  Instead, its about keeping people in the resort and getting them to spend money, not on enjoyment of the natural qualities of the National Park but on amusements.   How it contributes to the development of sustainable tourism in the National Park is something therefore the LLTNPA needs to answer.

 

Sustainable use of resources

Again, its too early to tell but to me the outdoor swimming pool area, no doubt heated, tells a tale.

 

What needs to happen

We need to remember that the Riverside element of the proposed development is publicly owned.   Our Public Authorities however are so wedded to the tenets of neo-liberalism – that only the private market can and should deliver developments – that they are happy to promote a development which is, judging by how it matches the National Park’s statutory objectives, to be in the private not the public interest.

A different approach is possible starting from the idea that publicly owned land should be used to deliver public goods in partnership with local people and other stakeholders to meet the statutory objectives of the National Park.   There are two ways this could happen.  The first is if the LLTNPA were to start upholding its statutory objectives rather than promoting/acting as a facilitator for inappropriate development.  The second would be if the local community were to launch a bid to takeover some or all of the site (just like the Aviemore and Glenmore Community Trust intend to do at Cairngorm).  Combine the two and you could develop a much better alternative to Flamingo Land’s offering.

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

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

Its still them and us

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

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

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

 

 

 

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

Its also a recipe for conflict:

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

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

Community Empowerment and planning

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

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

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

 

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

 

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

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

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

 

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

 

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

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

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

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

January 16, 2017 Nick Kempe 1 comment
The plan of Scottish Enterprise and the Loch Lomond and Trossachs National Park is to develop the greenspace next to Loch Lomond Shores and at the head of the River Leven. Is this what National Parks are for?

I was as shocked as the 33,000 people who signed the public petition after Scottish Enterprise announced the appointment of Flamingo Land (see here).   To find out more about how this had  happened I submitted Freedom of Information requests to the Loch Lomond and Trossachs National Park Authority and Scottish Enterprise in September and then a follow up to SE in November.    While it has taken SE two months to respond to my last request Scottish Enterprise FOI response 170114, the information provided is very clear compared to that provided by the LLTNPA EIR 2016-051 Response.   In November I showed that the claims made by the LLTNPA about their involvement in the appointment of Flamingo Land were totally misleading  (see here).  Together, the two responses from Scottish Enterprise  show the LLTNPA’s claims are a travesty of the truth and what’s more that the LLTNPA has been involved in selecting a developer which scored less on the design objectives which it helped develop.

 

Here’s what Scottish Enterprise has said about LLTNPA involvement:

 

“Loch Lomond and Trossachs National Park Authority (LLTNPA) endorsed the ‘SE Design Principles’ set out in the scoring document and were fully engaged in developing the marketing strategy as well as being part of the process to award Flamingo Land preferred developer status at West Riverside”

“The design principles were set out fully within the original marketing brochure  and both this and the scoring document were endorsed by the LLTNPA.”

 

Contrast this with EIR 2016-051 Response where the LLTNPA failed to mention they had been involved in the marketing strategy or the scoring document and claimed their involvement had been about planning advice.

 

Correspondence and meetings with Scottish Enterprise
Scottish Enterprise sought informal pre planning application advice and met with a member of the Park Authority’s planning team in March 2015. Email correspondence to arrange this meeting is attached in Appendix A.

 

A totally different view to SE.    What is more, according to SE FOI response 161017, the marketing strategy  in which LLTNPA was involved  “divided West Riverside into five development areas and stated that Scottish Enterprise (SE) would fully consider any interest in individual plots 1 – 5 as well as whole site interests.”

 

The suggested uses for each of the five development areas which went beyond anything contained in the LLTNPA  Development Plan and included development of Drumkinnon Woods.     It appears therefore that LLTNPA staff have been closely involved in deciding how the site should be used and what uses would be acceptable BEFORE any consultation with the local community.   This raises further questions about the extent to which the LLTNPA manipulated the Balloch Charrette (see here), where the local community were not told about the appointment of Flamingo Land or, it now appears, the proposals that the LLTNPA staff had been engaged in scoping for each section of the West Riverside site.

 

There is reason to believe LLTNPA involvement goes further than this.   In EIR 2016-051 Response Appendix A the LLTNPA only made public emails which date from March 2015 though I had asked for  all written information about the development of the site without time limit.  Its hard to believe the Park hold NO information about their close engagement with SE on the marketing of the site or that none of this took place before 2015 or indeed that they hold no other information about communications with SW about the site apart from that .   The more probable explanation is the Park has decided to try and cover up the extent of their involvement in what should happen on the site.   Why?

 

The LLTNPA’s second claim was that:

 

“Scottish Enterprise invited the Park Authority’s Head of Visitor Experience to be involved in the process of reviewing the submissions for the West Riverside site. This involvement was in an advisory capacity in relation to tourism considerations and separate from, and without prejudice to, any consideration of planning issues. The decision regarding a preferred developer was for Scottish Enterprise as landowner to make.”

 

This is disproved by SE’s two responses.

 

All the proposals were scored by a panel comprising of representatives from SE, LLTNPA and SE’s Property Advisors (Bilfinger GVA) in accordance with the issued evaluation criteria and methodology outlined in the attached development brief.

 

Moreover, the Developer’s brief WR Interests – Dev Brief – Final  starts by saying:

 

Introduction
Scottish Enterprise, in partnership with Loch Lomond and Trossachs National Park Authority, are promoting West Riverside and the undeveloped sites within Loch Lomond Shores for tourism and leisure-based developments

 

Being in partnership with SE and scoring the developer’s submission, as described by SE, is very different to “reviewing” the applications and acting in an advisory capacity.    What’s more LLTNPA were involved in a follow up meeting with Flamingo Land prior to the appointment being confirmed:

 

SE & LLTNPA had one meeting with Flamingo Land prior to progressing the award of preferred developer status. This meeting took place at the end of September 2015.

 

I believes this information confirms beyond doubt that LLTNPA were very involved in selecting the developer and therefore in selecting one set of proposals over another.

 

It gets worse than that however.  The submissions were scored according to certain evaluation criteria, which rightly included design objectives , which LLTNPA was involved in developing.

 

While four developers made submissions for this site two were very close:

Scoring of Flamingo Land bid (the information here and below  comes from the scoring matrix supplied by SE under FOI)

In fact Flamingo Land scored just ten points more than the other developer although the scores are made up very differently.

 

 

The scoring of the rival front-runner, who name has been withheld under FOI

 

 

 

The unsuccessful bid scored more than Flamingo Land on the design objectives, experience and track record but less on financial viability and funding strategy and deliverability.     What this tells us is – leaving aside the question of whether the design objectives which LLTNPA had been involved in developing were the right ones – that the LLTNPA has been involved in selecting a developer whose design proposals were  second best.   Now, if there had been huge differences with the other developer on deliverabiltiy or financial viability, this might have been justifiable but there weren’t.  The two developers were separated by just 10 points in all and the biggest difference between their scores  was on design, what should have mattered most to the LLTNPA.

 

There are further questions you could ask about this.   We now know from SE that “there was no provision for a score to be assigned for payment of the Scottish Living Wage”.  Wages rates could have affected the financial viability of the proposals.    Flamingo Land’s accounts suggest that while it is a profitable company it also appears currently to pay many staff rates at or around the UK statutory living wage, i.e below the Scottish Living Wage.  Now of course the other Developer might have been no different and there are many other factors which affect financial viability, but its also possible that the other Developer scored less on financial viability because it pays its staff more.   It would be very interesting to know therefore whether LLTNPA staff, before they endorsed the scoring matrix, made any representations about the need for better paid jobs in tourism in the National Park and how the scoring matrix supported their statutory duty to promote “sustainable economic development” in the Park.

 

The consequences of all this are huge and undermine  LLTNPA’s claim that their involvement has been “without prejudice” to the planning decision and indeed to their wider statutory objectives.  Supposing Flamingo Land submits planning proposals which accord with the submission the LLTNPA scored, I cannot see how the LLTNPA could possibly now refuse such an application – even if much better alternatives are obviously available – as to do so would open up the possibility of Flamingo Land suing the Park for all their development costs.   Their grounds for this would be that the LLTNPA had already endorsed what they were proposing, through approving their development bid,  and that as a consequence they had been led up the garden path.

 

The converse of this is that it was very much in the interests of Scottish Enterprise  to avoid a situation where they appointed a developer and agreed proposals which the LLTNPA then knocked back.     It was in their interests therefore to involve the LLTNPA as far as possible and it appears they have done this very successfully.    The LLTNPA  should have never allowed itself to get into this position and its hands are now very dirty.

 

What is happening and what needs to happen

 

Based on experience of how they worked the camping byelaws,  there appears a high likelihood that the LLTNPA are now working behind the scenes to win over selective stakeholders  to what has already been agreed with Scottish Enterprise before any planning application is made.   There has for example been a follow up consultation on how to develop the “cycling hub” proposal.   The LLTNPA  will then  try and present Flamingo Land’s proposals as the only option and one that has sufficient enough support for politicians to be wary of intervening.

 

I don’t think this should be allowed to happen anywhere, let along in the National Park.   Rather:

 

  • The LLTNPA ‘s Board should initiate a transparent review of its staff’s involvement in the  process that led to the selection of Flamingo Land as preferred developer for the Riverside site and the implications for it as planning authority
  • In order to re-establish public confidence the LLTNPA should commission a proper independent consultation –  not the biased charrette which failed to put it and SE’s plans on the table – on the type and intensity of  developments that would be appropriate for the West Riverside Site given its in a National Park.   Until this happens any further work on developing Flamingo Land’s proposals should be suspended.

 

November 16, 2016 Nick Kempe No comments exist
p1000761-copy-2
The West Riverside site at Balloch which Scottish Enterprise and the LLTNPA wish to develop is currently a greenspace

A month ago I received a response from the Loch Lomond and Trossachs National Park Authority about their involvement in the west Riverside side and Flamingo Land.    In their letter eir-2016-051-responseb the Park have tried to defend their integrity as a planning authority and their ability to make an independent judgement on the Flamingo Land proposals:

 

“Scottish Enterprise invited the Park Authority’s Head of Visitor Experience to be involved in the process of reviewing the submissions for the West Riverside site. This involvement was in an advisory capacity in relation to tourism considerations and separate from, and without prejudice to, any consideration of planning issues. The decision regarding a preferred developer was for Scottish Enterprise as landowner to make.”

The documents which accompanied the letter eir-2016-051-response-appendix-a however contradict this claim –  and shows the Park were on the selection panel which appointed Flamingo Land.   Here are some relevant extracts which prove this:

west-riverside-1
So if the decision was for Scottish Enterprise to make, why were the Park involved in appraising the bids? Scottish Enterprise of course wanted to be certain the in selecting a developer and proposal for west Riverside the LLTNPA would not later on object to this.

 

west-reverside-selection
This email makes it clear that LLTNPA were not just providing advice on the implications of each Developer’s bid, which would have maintained the Park’s claim to be neutral in this, they were involved in scoring each bid. In agreeing to score bids the Park made themselves a party to the selection of the developer.
west-riverside-selection-4
The emails about this meeting – the subject is deleted from the response – show both Stuart (Stuart Mearns, Head of Planning) and Mairi Bell attended this meeting. This meeting appears to have taken place soon after Flamingo Land had been appointed. It shows the Park are involved in every aspect of the proposal including land price.

While the FOI/EIR response is far from complete – there are references to other written material/meetings about which no information has been provided – they provide enough information to show that the LLTNPA was deeply involved in the selection of Flamingo Land.

 

What they also show is that the LLTNPA made a number of false claims in their flamingo-land-news-release issued on 26th September:

 

“Scottish Enterprise recently appointed Flamingo Land Limited as the preferred developer of their 20 hectare site at West Riverside, Balloch, in Loch Lomond & The Trossachs National Park.”

Comment:  this is far from the full truth, the LLTNPA was clearly involved in the selection process

“Scottish Enterprise kept the National Park Authority’s tourism team informed at each stage of the marketing of the site and the process of selection of their preferred developer.”

Comment: this wrongly implies that LLTNPA were not involved in the selection process.  The Park have bent the truth as far you can without actually lying.  Yes, the Park were informed but they were also INVOLVED.

I am afraid this disregard of the facts and bending of the truth is what I have come to expect from the National Park Authority.  Its how they got Government Ministers to approve their proposed camping ban.   Perhaps before the same process is repeated with Flamingo Land, the LLTPNA Board could start to insist that its staff start working to some basic standards of governance.  Perhaps they could also explain how in  light of this level of involvement by their staff they can take an independent decision on any planning application from Flamingo Land?

 

I fear though that following all the bad publicity on Flamingo Land, the LLTNPA/Scottish Enterprise are working together intensively behind the scenes to win people over to the proposal and put propaganda into the press through their bloated communicationss team http://www.dailyrecord.co.uk/news/local-news/community-council-back-flamingo-lands-9189747.   I am pretty sure Murdoch Cameron, chair of Balloch and Haldane Community Council, was not the person who contacted the media about this.  Indeed, from the article its unclear whether the Community Council actually met to agree a position or whether the views expressed were personal but have been taken to reflect those of the Community Council.    I say this because there are lots of people in Balloch concerned about the proposals and I would be surprised if the Community Council had been able to take such a clear position.

 

What might we learn from Flamingo Land in Scarborough?

 

Meantime, for those concerned about what Flamingo Land might do on the site, thanks to the reader who sent this press article from Scarborough.   Although it dates from 2014, it is well worth a read as its very relevant to what is happening in Balloch.  It provides further evidence of where Flamingo Land’s expertise lies – bling!

 

” Made up of three distinct environments – ‘Subterranean’, ‘Coastline’ and ‘Sky’ – Flamingo Land Coast will feature an iconic glass roofed botanical gardens, roller coaster, 55 metre iconic lighthouse structure and Space Shot Tower, walk through aviary, sea view bar, restaurant and a new town square.”

 

In both cases, Flamingo Land was appointed in secret.  In Scarborough the Council were forced to reveal the mystery bidder to redevelop the Futurist Theatre site.  In Balloch, Scottish Enterprise appeared to have appointed Flamingo Land back in September 2015 but they and the Park kept the appointment secret  until after the Balloch Community Planning event.

 

In both cases the Flamingo Land development involves destroying something else.  In Scarborough, for the last two years there has been a campaign to save the building and in effect prevent the Flamingo Land development but this appears recently to have failed (see here)   In Balloch, it will involve the destruction of what is currently greenspace.

 

If the Scarborough development now goes ahead,  it raises interesting questions about Flaming Land’s capacity to develop so many sites at once.   This should have been considered as part of the tender evaluation and I wonder how the LLTNPA member of the panel scored this?   (The answer is exempt from the Freedom of Information Act unfortunately).

 

And for those of us who are interested in the manipulation of public opinion and claims made that as Gordon Gibb is a Scot the development should be supported, the following quote should be of interest:

“Flamingo Land boss Gordon Gibb said:

“Scarborough is my home town so it gives me great pleasure, both personally and on behalf of Flamingo Land Limited, to be associated with developing a major visitor attraction on the old Futurist site.”

 

 

October 15, 2016 Nick Kempe No comments exist

west-riverside-copy-2

As the gateway to Loch Lomond and the unofficial capital of Scotland’s first National Park the village of Balloch should be the jewel in the crown of Loch Lomond and one of Scotland’s top tourist destinations. However, it has it has failed to live up to this billing for some time now which, in part, is due its industrial past, fragmented land ownerships and various abortive attempts by the private and public sector to realise its full tourism potential. Is this all about to change with the emergence of the £33 million plans for the former derelict land at West Riverside and the derelict and unsightly  Grade A Hamilton House  site between Loch Lomond Shores and the A82? Will this turn the village and the nearby £45million Loch Lomond Shores  into a year round holiday resort destination instead of a dislocated village dominated by Loch Lomond Shores where there is predominantly an 11.00am-4.00pm day visitor economy separated from the ‘old village’ by the partially reclaimed West Riverside site? Will more much needed year round jobs be created with decent wages to replace some of the large number of jobs lost in nearby Vale of Leven? It is difficult to say at this stage due to the scant information that has been announced by Scottish Enterprise who have kept their ‘preferred developers’ at arms length from the local community and other interested parties such as the Friends of Loch Lomond for more than 9 months now despite the Balloch Charrette (a supposedly dynamic and open community planning  consultation exercise) providing a golden opportunity for the developers to sit in and obtain a flavour of what the local community wants as well as sharing their preliminary plans.

 

Unwittingly, the secrecy of Scottish Enterprise and the clumsy way they have handled the PR so far has proved to be a major setback for the ambition to realise Balloch’s tourism potential with several petitions and reams of negative press emerging over the past month or so to try and block any plans that the Scots owners of Flamingo Land have for the village. This is a great pity and probably could have been avoided if SE officials had engaged in a more open and meaningful consultative process at a much earlier stage and hadn’t hidden behind  ‘commercial confidentiality’ screens. Hopefully the situation can be retrieved and there will now be more open and meaningful dialogue with the local community and interested parties to help shape plans that could be of major benefit to the village as it seeks to realise its tourism potential in a way that greatly enhances its status as the gateway to the National Park and the unofficial capital of the National Park. Time will tell.

 

In the pre and post Second World War era Balloch was a hugely popular destination with a large section of the West of Scotland population being regular visitors when the factories shut on a Friday night and thousands of workers and their families made a break for the clean air of nearby Loch Lomond with its  range of simple  and largely free recreational opportunities. This began to change in the 1960s and 1970s with the advent of the cheap sun package holidays which, for decades now, has seen tens of thousands from the Greater Glasgow area taking flight overseas resulting in the Glasgow Fair fortnight being one of the quieter periods in Balloch. Notwithstanding this, Loch Lomond (not Balloch) has remained  the number one countryside day visitor destination in Scotland largely due to its close proximity to large concentrations of population. There have been some notable tourism investments by local companies such as the long established and family owned Sweeney’s Cruises and more recently by some national pub and hotel chains.

 

Scottish Enterprise and House of Fraser spent close on £45 million on the phase 1 Loch Lomond Shores development which opened in 2002 to coincide with the establishment of  the National Park. The central feature of this development, Drumkinnon Tower, which cost the taxpayer around £14 million, quickly failed and had to be re-invented  following a costly conversion into a Sealife Centre. However, in recent years Loch Lomond Shores has begun to flourish largely due to the hard work and dedication of the small management team led by Clare Gemmill who has introduced a strong and very successful events led programme. A number of businesses have stuck with Loch Lomond Shores through leaner times and are now hopefully in a  much healthier position trading wise. The Park Authority has encouraged some outdoor activity and birdlife operators to locate there too in recent years and has also directly invested in much needed boat trip pontoon facilities connecting the loch and the shores development for the first time. Plans are also being progressed to convert the National Park Gateway Centre into a restaurant and events venue. This publicly funded facility has sadly lain empty for several years now despite still being signposted on the main road network.

 

It has been interesting to see the five or so articles on ‘Parkswatch’ relating to the outline plans for the land at West Riverside linked with a good dose of agency bashing. I don’t believe the National Park Authority  deserves a bashing in this instance as they have not been leading the efforts to interest developers in the site-this has been the sole responsibility of Scottish Enterprise as landowners on behalf of the Scottish Government and  taxpayers.  Makes for good copy though but factually incorrect, particularly in some of the earlier articles regarding issues such as the  non- advertisement of the site . It has been widely advertised in publications like the Herald and the potential range of site uses has been listed on a large hoarding prominently displayed next to the Balloch end of the site and adjacent to the tourist information centre for several years at least. Various schemes for the site have come and gone over the past 30 years or so. There have also been several preferred bidders over the last 7  years but they have never quite made it over the line for various reasons including, allegedly, Scottish Enterprise’s unwillingness to fund further land remedial works.  However, you are correct in mentioning the site was formerly derelict . Going back to the 1980s much of the site was a no go area with contaminated land linked to its former uses as a silk dye works factory, extensive railway sidings and sand and gravel workings. Much of the site was abandoned derelict land which had been neglected for many years by the owners of three separate pieces of land.

 
The attached photo above, which was taken around 1960, provides a birds eye view of the site which is currently the subject of so much controversy. Hardly a picture postcard extolling the scenic qualities of Loch Lomond! Admittedly, much of the dereliction no longer exists but the site doesn’t have high scenic qualities and is still generally in a poor condition. You can clearly see the extent of the land covered by railway sidings and the former rail link with the pier where Maid of the Loch is moored awaiting restoration. In the middle foreground you can see the steam beam engine house and slipway. This has been restored by the Steamship charity with funding support from HLF, Scottish Enterprise and others (£600k plus) and they organise popular steam days throughout the main tourist season. Interesting also to see part of the site next to the disused gravel pits was used as a caravan park with more than 60 static caravans in view. You can also see part of the former silk dye works site in the middle right of the picture which has largely been covered by a housing estate now. This used to be dominated by large chimney stacks which acted as a navigation beacon for boat users on the loch.

In the mid 1980s the Area Tourist Board tackled some of the dereliction on the edges of the site with the use of 100 or so unemployed people from the Vale of Leven with the help of Manpower Services Commission funding as part of ‘Operation Bonnie Banks’. This resulted in a safe beach area being created, the removal of the remains of dangerous and unsightly brick walls as part of the main gated entrance to the silk dye works and much more as part of an effort trying to provide some useful jobs for the long term unemployed and addressing  civic pride issues. A great success with limited resources .

 

At that time the Scottish Tourist Board also joined forces with Bredero to have a comprehensive look at what could be done longer term if the piecemeal land ownerships were brought together. A major development options study was undertaken and concluded there was scope to develop an indoor leisure centre (similar to Rhyl Sun Centre in North Wales) and housing. Some time later Cala Homes came forward with an ambitious plan to cover the site in luxury housing with those on the loch front having their own private boat moorings. Dumbarton District Council planners in their wisdom recommended approval but thankfully Councillors refused the development planning permission after listening to the strong representation from the Friends of Loch Lomond, the Area Tourist Board and the Balloch community who argued that this was too important a site for recreation and tourism to be allowed to be developed for housing. An expensive public inquiry was then held and the late Hannah Stirling, the then Chairman of the Friends of Loch Lomond contributed a substantial sum to hire a QC to fight the case along with local Councillors and the Area Tourist Board. Fortunately the case was won by the objectors and Scottish Enterprise was encouraged to purchase the site and to progress plans primarily for tourism and leisure development.

 

This is the background to what led to the phase 1 Loch Lomond Shores development and there was always an intention to develop a phase 2 to link the centre of Balloch with the lochshore more effectively. Much earlier In the early days of the Joint Committee which preceded the creation of a National Park the then Scottish Development Agency was encouraged to purchase the West Riverside site which was owned by British Rail. They worked with the Joint Committee and the Area Tourist Board to restore the derelict former railway station building in the centre of Balloch which was converted into a tourist information centre and offices. The land between the Station building and Balloch Pier beside the River Leven was also restored and extensively landscaped with a new path. Derelict moorings and sunken boats were also removed from the West Riverside edge of the River Leven with the help of Loch Lomond Association.

 

Various attempts have been made over the years to market all or part of the site for hotel and leisure development with mixed success. Occasionally Scottish Enterprise have mooted the idea of part of the land being used for housing but this has been strongly resisted by the Friends and others. There was also previously a couple of preferred bidders to develop the site which fell by the wayside for a variety of reasons. In previous cases and this case the site was well advertised by Scottish Enterprise. The site has also appeared in local Development Plans as an area with tourism and recreation development potential.

 

Given this site history (apologies for the level of detail but I think it is important to set the context) the Friends and others have been consistent in their desire to see the site being developed for a range tourism and recreational uses. However, this doesn’t mean we will accept anything and we will be reviewing the latest plans very carefully though it does appear the general thrust of what is planned is entirely consistent with what has been proposed for the site for many years with strong riverside boardwalk links between the centre of Balloch and a mix of family orientated tourist accommodation and recreation facilities.

 

I wonder if the company selected to work up a scheme for this former derelict site hadn’t been called Flamingoland if there would be such a furore? Had Forest Trails come forward with a scheme here I doubt it. Pleased to see glamping and a much needed youth hostel featuring in the emerging proposals given the loss several years ago of Loch Lomond Youth Hostel to a private house and the emergence of Balloch as a key location where the John Muir Way and Three Lochs Way Great Walking Trails merge. It will be interesting to see in due course what the eventual mix of accommodation is by type and price point. Sounds as if they are aiming to serve a wide range of socio-economic groups which would be very welcome as not everyone can afford to stay at the up market Cameron House and neighbouring timeshare lodges.

 

The detail of the preliminary plans have not yet been made public, apart from the scant information in the poorly pulled together news release issued by Scottish Enterprise, so let’s not pre-judge their plans and prematurely question Flamingo land’s ability to deliver a quality  tourism development along the lines of a possible mini-Center Parcs with a blend of accommodation and indoor and outdoor recreation facilities that are potentially a ‘good fit’ at this location. Scottish Enterprise needs to remove the shackles now from the preferred developers so that they can meaningfully engage with the local community and other interested parties. The Friends are on the case and following an approach to a local businessman who is involved in the project a preliminary exploratory meeting with the owner of Flamingoland has now been held. Direct communication channels have also been established with the Community Council. There is much work still to be undertaken investigating ground conditions, traffic management issues and more before a revised master plan for the site is finalised. However, a preliminary viewing of the outline plans suggests the developers are taking account of the sensitivities of this important site at the southern end of the loch and the plans are far removed from what has been suggested in the press and elsewhere. Hopefully there will be an opportunity to influence the final plans as they are worked up into a detailed masterplan prior to a detailed planning application being submitted to the National Park Authority.

 

I hope this note helps bring some balance to the current debate on the future of what is the last major site for tourism and recreation development in the Loch Lomond area . I am hopeful that a scheme emerges which meets the aspirations of local residents and visitors from all backgrounds and socio economic groups. Incidentally, great news that West Dunbartonshire Council has recently committed  £1.4 million for two village squares and public realm works in the centre of Balloch which emerged as community priorities during the recent planning charrette exercise. Just goes to show the agencies do sometimes take on board community wish lists. Shame though about loss of land next to NPA HQ for housing instead of much needed car parking. The recent announcement on the planned £33 million investment by Flamingoland reinforces the folly of this decision by the NPA Board members based on the recommendation of planners who failed to recognise the importance of providing more parking at key locations such as this close to the main street in the village and the entrance to Balloch Castle Country Park. Not convinced the Balloch Charrette final report or the preliminary study terms of reference for work on the village square at the former railway station have fully grasped the scale of future car and coach parking requirements to ensure Balloch flourishes as a year round quality tourist destination but that is another story.

September 22, 2016 Nick Kempe 1 comment

flamingo-land-copy-2

By coincidence, the above article appeared in the Sunday Herald (in their towns supplement) just a few days after Flamingo Land had been announced as the preferred developer for the west riverside site at Balloch (see here).    The contrast between what Kevin Stewart is saying and what Scottish Enterprise announced is stark:

    • The “solution” to the west riverside site has NOT been developed by those who live and work in Balloch apart from the aspiration that the site should link the Loch Lomond shores development to the town centre by means of a riverside site.   The actual use of the rest of the site has not been subject to consultation.
    • The decision to make Flamingo Land the preferred developer was not made by the local community but by Scottish Enterprise and could well have involved another member of the Scottish Government, the Business Minister.
    • A Development Trust, the Scottish Government’s apparent preferred solution for re-invigorating towns like Balloch, appears not to have been considered.

 

Announcements that the LLTNPA was in discussions about the development of a theme park on the shores of Loch Lomond were made back in 2011 (see here)  (thanks to a reader for the link!).  It appears very likely that the secret site referred to by Wayne Gardner Young was west riverside.   Meantime, Government policy has changed so cosy deals with developers are no longer supposed to happen and the community should be put in the lead.     Scottish Enterprise and the LLTNPA however have just blundered on (I don’t blame the staff, just the senior management and Boards) with an approach that is now discredited.

 

I have submitted a number of Freedom of Information requests about this, such as whether the LLTNPA has assessed  the likely impact this development could have on existing local businesses or if Scottish Enterprise advertised the opportunity.   (I have not been able to find any contract advertisement on the Scotland Contracts Portal – that may just be me – but the public sector is now supposed to advertise all such opportunities there).  In terms of public policy, following Kevin Stewart’s piece, I believe the local community should have been given a chance to bid for the development or alternative use of the west riverside site.

 

So why the gap between rhetoric and reality?

 

The main reason I believe lies in neo-liberal thinking, which accepts there is no alternative to private finance to make things happen and indeed believes private enterprises do everything best.   The problem is that despite all the evidence for the failure of neo-liberalism, the Scottish Government has not worked out any solutions to make Kevin Stewart’s vision a reality.  This I believe needs to involve local sources of finance (in German local banks finance local business and development) and more public expenditure (which is about our tax system and most pressingly tax evasion).    However,  Scottish Enterprise has hardly started to think about this, despite it having a co-operative development team,  and it still operates as if  large developers and developments are the only option.

 

Added to that,  Fergus Ewing, the Scottish Goverment Minister responsible for tourism and enterprise from 2011 until earlier this year, has always been on the right wing of the SNP.   He was responsible for both Scottish Enterprise and Highlands and Island Enterprise and I don’t think its a coincidence that outside developers have been brought in to develop two prime sites controlled by them,  Natural Retreats at Cairngorm and now Flamingo Land at west Riverside.    Its the way he thinks and he was never going to say to Scottish Enterprise “hang on a moment, is this the only option?”

 

At the same time the LLTNPA adopted an explicit neo-liberal path under their previous Chief Executive, Fiona Logan, who saw business as the answer to everything (this is well illustrated by her flirtation with Wayne Gardner Young – see link above).   She then got her Board to adopt an explicit Commercialisation Policy in 2013 which covers every aspect of what the National Park does, from how to develop tourist facilities to charging for toilets and carparks (which I will cover further in due course).    Part of this involved the Board getting big developers to pay for their planning section by increasing charges – a conflict of interest if ever there was one – as  the future of the planners’ jobs at the National Park in part depends on developments such as Flamingo Land going ahead.

 

While the LLTNPA still claims to put the conservation and public enjoyment of the National Park first, the reality is that commercialisation is driving everything in the Loch Lomond and Trossachs National Park.   This is bad for local communities and bad for the people who visit the National Park.    While we cannot expect our National Parks to address all the ills of neo-liberalism and the austerity that goes with it,  if our National Parks are not about other values such as protecting landscape and nature from the excesses of capitalism and enabling people to enjoy these things, then they are not worth anything.

 

I think the organiser of the petition to stop Flamingo Land was right (see here) The Scottish Government should intervene, tell Scottish Enterprise and the LLTNPA to scrap the Flamingo Land proposal and start work with the local community and other organisations to develop alternatives.  I would hope Kevin Stewart, the Minister, will publicly support that as a way forward in accordance with his thinking.