Tag: Tourism

January 8, 2018 Nick Kempe 1 comment
Cairngorm Mountain Logo – screenshot 8th January.  There is nothing in the Behind the Scenes section of the website to explain the changes which are happening at Cairngorm and the website is poorly maintained: Nic Bullivant, the Head Ranger in the central photo, retired six months ago.

Following the split of the US and UK parts of Natural Retreats, the company that ran Cairngorm Mountain, and the transfer of the UK part of the operation to the UK Great Travel Company Ltd (see here) further re-organisation of the group of companies controlled by hedge fund manager David Michael Gorton is continuing.   While its unclear at present why this is happening it appears unlikely to be for the benefit of people who enjoy Cairngorm or the wider economy on Speyside.

Sometime in the last few weeks reference to Natural Retreats has been removed from the Cairngorm Mountain logo.  Compare top left above with how the logo appeared in July 2017:

Screenshot Credit Internet Archive Wayback Machine

The Cairngorm Mountain Facebook Page though still retains the reference to Natural Retreats:


So has someone just made a mistake?  The evidence from the Natural Retreats website (see here) suggests otherwise.  All references to Cairngorm Mountain have been removed and it appears that Cairngorm is no longer being marketed under the Natural Retreats brand.  This would fit with Cairngorm Mountain Ltd advertising for their own Marketing Manager towards the end of last year (see here).

How long will it be before the Natural Retreats logo is removed from Cairngorm Mountain?

The changes raise  yet more serious concerns about the justification HIE gave for selling Cairngorm Mountain Ltd to Natural Retreats back in 2014 (see here for full news release):


“With over 100 years of relevant international and regional leisure and tourism experience, Natural Retreats’ senior management in both Europe and the US bring a wealth of expertise to the Resort. The UK’s largest and busiest skiing destination will be led by Natural Retreats’ market-leading operational team, who have over 65 years of experience within Ski Resorts worldwide. The brand currently operates in close proximity to four world-renowned US ski destinations and Cairngorm Mountain is the perfect addition to their portfolio.”

  • Gone is the US part of the operation
  • Gone is any expertise they claimed to have had in skiing (the fact they never used the experience of US ski resorts suggest this was perhaps not as strong as claimed)
  • Gone is the brand

So what justification does HIE have for allowing the rump of Natural Retreats to continue to operate Cairngorm?

The recent changes to the way Cairngorm Mountain Ltd is being operated also undermine any arguments that the local community on Speyside, who are preparing a takeover bid through the Cairngorm and Glenmore Community Trust, do not have the experience necessary to operate Cairngorm.

Whether the recent changes will affect the large amounts of money that Cairngorm Mountain Ltd has paid to what is now the UK Great Travel Company for services remains to be seen.  It was good in this respect to receive confirmation from HIE just before Christmas that the Outfitters Shop at Cairngorm was not connected with another of the Natural Retreats group of companies, Natural Outfitters at John O’Groats:

“The Outfitters shop at Cairngorm is managed by Cairngorm Mountain Ltd.  Natural Outfitters at John O’ Groats is a separate entity”


How HIE should be judged over the next year?

I have made no secret of my view that the current disastrous management at Cairngorm will not change until ownership of the ski area is transferred from HIE and that the most likely way this will happen is through an asset transfer to the local community under the Community Empowerment legislation.   While few politicians openly support this at present,  here are some criteria by which they should judge HIE during 2018:

  • Will HIE ensure that Cairngorm Mountain Ltd engages with local and national stakeholders – as they have failed to do so far – about how the Cairngorms Ski Area will be managed?
  • Will a draft of the Cairngorm Management Plan, as promised to the Cairngorms National Park Authority under the Cairngorm and Glenmore Strategy, be produced? (Natural Retreats was identified as the lead partner for this).
  • Will the current review of the ski uplift infrastructure take an objective look at the potential for skiing on the mountain or will it turn out to be fig leaf for decisions already taken behind the scenes?
  • What steps will HIE take to ensure that there is complete transparency about monies currently being extracted out of Cairngorm in payment for “services”?
  • What steps will HIE take to ensure that expenditure at Cairngorm benefits the local economy rather than the ultimate owner of Cairngorm Mountain Ltd, David Michael Gorton?
  • Will HIE hold “Natural Retreats”/Natural Assets Investment Ltd to account and ensure they invest the £6.2m over 5 years which was promised in the News Release on their appointment?
  • Will HIE ensure that Cairngorm Mountain Ltd formally adopt and adhere to the former environmental standards which were formerly governed all management operations at Cairngorm (off road use of vehicles etc)?  The CNPA asked for this 18 months ago but so far there has been apparently no response.
January 4, 2018 Nick Kempe 7 comments
Sign at junction south Loch Earn Rd with road to Edinample House 27th December.

Commenting on Tuesday’s post (see here) Dave Morris, former Director of the Ramblers Association and one of the architects of our access legislation, wrote:

"As we approach the 15th anniversary of the passage of the Land 
Reform (Scotland) Act 2003 it is worth reflecting, to Scotland's 
eternal shame, what is happening on the bonnie, bonnie banks of 
Loch Lomond and elsewhere in this national park. Nobody associated
with this legislation, which secured our right to roam, ever 
anticipated that it would result in the sort of thuggery now been 
practised against campers by this National Park Authority".

Both Dave and I are strong supporters of National Parks but neither of us anticipated either that visitors to the countryside would still be faced with signs such as that in the photo above.  The Loch Lomond and Trossachs National Park Authority was also set up 15 years ago and has had responsibility for access matters since its creation.   That an Access Authority and National Park to boot still tolerates such signs – and the field behind the sign is clearly land covered by access rights – is a disgrace.

While the LLTNPA could be excused for not knowing about every sign about access within the National Park, during the byelaw season their  Rangers must drove past this unlawful sign on a daily basis looking out for “rogue” campers on their way to or from the south Loch Earn camping permit zone.   That says a lot about what is wrong with this National Park.   In other areas countryside rangers would be involved in resolving problems caused by landowners but not in the LLTNPA.

Judging by my experience of trying to report unlawful signs, this is probably not the fault of either the Rangers or access staff.  I have, for example, not even had an acknowledgement to my email of 4th December to a member of the LLTNPA senior management team reporting the signs near Ardlui saying “Keep Out High Velocity Rifles in use”  (see here). Quite a contrast to the Cairngorms National Park Authority who not only acknowledge reports of access problems but tell you what they intend to do and who is responsible for doing this.

While at best there would best appear to be no join up between the LLTNPA Rangers and their access team, given the attitudes of senior management I suspect that any seasonal ranger complaining about signs such as this risks not having their contract renewed.   Whatever the explanation, the LLTNPA is failing to uphold access rights while it claims to value the “Visitor Experience”.

The 27th December was a lovely day and we passed the Edinample sign on the way from Glasgow for a walk up Ben Vorlich.  Needing a pit stop, we had stopped off at Callander, marketed as a gateway to the National Park, to find the toilets locked.  At Loch Lubnaig, it was not just the toilets which were shut, the gates to the car park were locked too,  although there was a sign on the back of the gate saying they would be locked at 4pm!  What justification is there for a National Park trying to prevent people travelling in cars from stopping off here in winter and enjoying the loch?  In the five minutes I was taking these photos, two cars pulled in in front of the locked gates and then drove away.  What an appalling message for a National Park to give out.

What’s the point of referring people to gate closing times if the gate is locked?

The above sign is pure parkspeak.  How can people respect the environment when access to that environment is barred by locked gates much of the time.  Why, when parking is being charged for, cannot the car park be kept open 365 days a year 24 hours a day?   Why does the LLTNPA act as if only summer visitors are important?

We saw something like 40 people while walking up the north ridge of Ben Vorlich – people getting out taking exercise doing the healthy sort of thing our politicians exhort people to do.  And that was just one hill.    Most visitors people come from outside the Park, some will want to take a break from driving and many will need to go to the toilet at some point in the day but the LLTNPA acts as if the National Park is closed.

The National Park needs to get back to basics.   Remove anti-access signs and provide infrastructure for visitors, jobs it was set up to do and has failed to deliver on.  Unfortunately, judging by its current advert for a new Visitor Experience Manager it is still embarked on a very different course:

Job Title: Visitor Experience Manager
Contract: Permanent
Salary: £35,495 – £42,193 (Band E)
Working Hours: 37 hours per week – we support the “Happy to Talk Flexible Working” campaign
Location: Balloch
Reference: NPA/Dec/2017/02

You will provide leadership, co-ordination and inspiration in managing and delivering the tourism functions and commercial partnership activities of the National Park Authority as set out in the National Park Partnership Plan and Corporate Plan. These functions include delivering new tourism products, ensuring consistent communication of destination brand and information, working with destination businesses, and delivering commercial partnership activities which will deliver income for the Park Authority.

Degree qualified in related discipline, you will have a proven track record in the tourism sector. As someone who has strong project management skills who demonstrates sound independent judgement you will understand how to approach, advise and influence both internal and external stakeholders. You will be confident, credible, proactive and creative when driving quality improvement and good practice (see here for full advert).

The whole emphasis of the Visitor Experience role is on commercial tourism rather than countryside management or helping people enjoy the landscape and wildlife, on raising income rather than on delivering the facilities that are needed.   While the person appointed will be expected to work with businesses there is not a mention of them working with the people who visit the National Park or the organisations that represent them.    While the sooner both our National Parks get rid of the terrible term the “visitor experience” the better, the more fundamental issue is the LLTNPA needs to re-focus on what it was set up to do rather than trying to turn itself into a second rate tourist board.


September 24, 2017 Nick Kempe 1 comment
Herald Thursday. There was a further article and leader comment on Saturday.

The debate about visitor numbers, which started this summer with reports of visitors “swamping” Skye and the North West Coast, has moved to the Outer Hebrides and the current focus is on “motorhomes”.  However, unlike in the Loch Lomond and Trossachs National Park where the numbers of visitors are treated as a problem,  in the West the increase in visitors is generally seen as a good thing.  The challenge, as Alasdair Allan the local MSP said, is that infrastructure has been unable to keep up with demand.   In suggesting that a levy be imposed on campervans to fund the infrastructure, he has opened up the debate.  The Herald, at the end of their leader on Saturday, reflecting on that debate concluded, rightly I believe:  “Getting the infrastructure right is the solution: who pays for it is the problem”.


What the Herald failed to say was that if our National Parks had been working and being doing the job they were set up to do, they would now be providing a model of how to do this.  Moreover, the case for further National Parks, including that mooted for Harris, would be unanswerable.


Unfortunately, there is almost nothing that people on Skye and in the Outer Hebrides can learn at present from our existing National Parks.  Both seem keener to ban visitors than welcome them.  The Cairngorms National Park Authority has suggested byelaws to restrict access could be used to allow the An Camas Mor development to go ahead (see here), while the constant refrain of LLTNPA  Chief Executive Gordon Watson over the last year when asked to justify the camping byelaws has been  that the numbers stopping off in campervans and tents are too great.  The LLTNPA’s original provision for campervans under their camping permit system was a measly 30 places, with not a single campervan allowed at their new Loch Chon campsite despite all the parking space there.   The LLTNPA’s attempt to limit the number of campervans has now fallen apart because of the legal right people have to sleep in vehicles by the road but this has left a policy vacuum.


The policy vacuum  provides an opportunity for the LLTNPA to change direction.  Instead of trying to stop and control visitors,  they should be focussing on what infrastructure is needed to support them.   There was no open discussion of this at the Board Meeting earlier this month, although a reference in the Your Park update report that staff were looking to upgrade facilities at Firkin Point and Inveruglas suggests they may now be moving in the right direction.


The basic elements of the infrastructure the LLTNPA needs to provide for campervans should be quite obvious – chemical disposal points, places to leave rubbish and drinking water.  When asked for a list of chemical disposal points in the National Park earlier this year, the LLTNPA knew of none outside formal campsites (see here) and could not even say which campsites had chemical disposal points.  The LLTNPA needs to start acknowledging that the lack of facilities for campervans and the lack of public information about this as a problem and also that it has the primary responsibility to sort this out.


The contrast in levels of understanding and understanding between the LLTNPA and  the west is striking.   Alasdair Allan MSP was able, without apparent difficultly, to identify the lack of facilities, chemical disposal points and capacity on ferries as a challenge.    Imagine what the Western Isles could have learned if the National Park had installed chemical and waste disposal points for campervans at the toilet facilities along the A82,  (Luss, Firkin, Inveruglas, Crianlarich, Tyndrum) and made these available 24 hours a day.  Imagine too what the Western Isles could have learned if the LLTNPA had used its large communications and marketing team (there are at least 8 staff) to engage with campervanners about the infrastructure they would like to see in place and then disseminated the results across Scotland?  That could have informed provision of infrastructure everywhere but instead the LLTNPA uses that team to produce glossy materials telling people what they are not allowed to do and where they cannot go.


To take the contrast further, tourism chiefs on the Western Isles have criticised Mr Allan’s proposals for a ferry tax on motorhomes because it might put people off visiting.  In the Loch Lomond and Trossachs National Park tourism businesses piled in to support the byelaws banning visitors in the mistaken belief that you could force people to use commercial sites.   Funny how all those free marketeers want to constrain choice.    A study by Outer Hebrides Tourism has found that people in motorhomes, who are not forced to go anywhere in the Western Isles, on average spend £500 per visit.  Both the tourism chiefs and Mr Allan know that the increased number of visitors in motorhomes is good, the debate is just about how to fund the infrastructure and whether tourism taxes would put off tourists.   The contrast with the LLTNPA  is that in all the papers that were developed to try and justify banning campers and campervanners, there was no tourism impact development and never once did the LLTNPA consider the impact on the local economy.  The LLTNPA should acknowledge in their report to Ministers on the byelaws in December that this was a mistake as has been their attempt to limit the numbers of tents and caravans to 300 (which was an arbitrary figure which has never been justified).


The final contrast between the west and the Loch Lomond and Trossachs National Park about the infrastructure debate is the level of political involvement.   Its not just Alasdair Allan that is involved, Kate Forbes the Highland MSP has facilitated meetings on Skye with local councillors and the tourism minister to discuss what needs to be done to support visitors (see here).  In the Saturday Herald Leader of the Western Isles Council, Roddie Mackay, was quoted as saying “The council is exploring all options that could increase investment in infrastructure required as a result of the undoubted success of RET (the Road Equivalent Tariff which has reduced ferry charges) and tourism”.  Contrast this with the LLTNPA where local MSPs and councillors, including those on the LLTNPA Board, have been notable for their silence on the need for improved infrastructure and investment.


A recent example of this political silence came at the LLTNPA Board Meeting last week when a Board Member referred to visits from large cruise liners which come to the Clyde and then send busloads of passengers to Luss.  This was interesting – same issue as in the Hebrides – and helps to explain why visitor infrastructure at Luss is creaking.  Not one idea was proposed however on how to rise to this challenge and opportunity.  Instead, there was a bizarre discussion about how difficult it was to get agreement from Luss Estates, the Park and the local Council about who should pick up litter where around the Luss carpark.   


What needs to happen

Our National Parks should be aspiring to provide models of excellence for how to support visitors, not ban them, and focus the resources which they have, which are far greater than are available on the west coast, on getting infrastructure right.


As part of this the LLTNPA should be committing to develop a proper plan for the infrastructure needed to support campervans in the first year of the forthcoming National Park Partnership Plan 2018-23.  This should include a commitment to engage openly  people using campervans and local communities  to the right type of infrastructure and in what places.  Some of this should be easy, for example adapting existing facilities, some more challenging, for example installing new public toilets and disposal points (eg at the carpark at the foot of the Cobbler).  I will consider how this could be funded in a future post.

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

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


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


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


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


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


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


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


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


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

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


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

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

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


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


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


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


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

August 18, 2017 Nick Kempe No comments exist
Photo from Luss Gathering Facebook page 2017 (it took place Saturday1st July) – count the tents and shelters!

The Luss Gathering takes place each year on Luss playing fields which now form part of the west Loch Lomond camping management zone.   Since last year the camping management byelaws have made it a criminal offence to erect a tent in a camping management zone without explicit authorisation from the Loch Lomond and Trossachs National Park Authority.   Mostly such authorisation is granted through the camping permit system the Park has created but this only allows tents to be put up in specified permit areas.   Luss is not one of them, no doubt because some local residents had blamed camping for all the problems of anti-social behaviour the village was experiencing and so no camping under permit is allowed close by.


The other way permission to put up a tent can be obtained is to apply for an one-off exemption to put up a tent or tents.   Decisions about such exemptions are, under the Park’s procedures supposed to be advertised on the Park’s weekly planning list which I have been monitoring for some time now.    Most of the applications are from Duke of Edinburgh and Scout Groups, with hard-pressed voluntary Scout Leaders and teachers,  no longer able to organise expeditions which stay overnight in the camping management zones without the Park’s permission.   The bureaucracy and additional workload is signficant and I feel for the (mainly youth) groups involved.  They were, just like other responsible campers, never part of any problem – indeed being supervised, the chances of such expeditions causing any damage were minimal – but nevertheless the Park has required them to apply for permission to camp.


I tend to recall applications from other bodies for exemption from the camping byelaws – that from the Loch Ard Sailing club comes to mind – but don’t remember seeing one for the Luss Highland Games.    I have double-checked all planning applications decided for the Luss and Arden Community Council since April on the Park’s planning portal and cannot find any appllcation to exempt the Luss Gathering either.  I am thus reasonably certain that the Luss Gathering did not apply for and were not granted permission to pitch the tents that feature on the photo above.   If I am correct,  all those responsible in putting up these tents have committed a criminal offence.   Ridiculous I know, as common sense tells us that these people have done no wrong.


But neither has Mr Trout, the angler who is being prosecuted simply because he broke the byelaws for doing what he has done for years (see here), just like the people who organise the Luss Gathering.  Neither has done any wrong.  Mr Trout told me that the police officer employed by the National Park, PC Barr, when cautioning him, had told him the law is the law and has to be enforced.  It would be interesting to know how many events PC Barr or other police officers have attended over the summer – I cannot believe that there was no police presence at the Luss Gathering – and what action they have taken.  My guess is none but I would be more than happy to publish information from the police or the LLTNPA if I have got this wrong..


The camping byelaws are daft but since during the Your Park consultation both Luss Estates and  members of the local community in Luss strongly supported them, there is an argument they should be made to live by the rules they have created for everyone else.   I would prefer it if they now joined those of us who believe the camping byelaws were never justified, are completely unfair and a complete waste of resources and call publicly for them to be dropped at the earliest opportunity.


Meantime, there was a helpful reminder of the real problems which the National Park Authority should have been addressing at Luss in this letter which appeared in the Herald on Monday.   It is significant that it is from someone who is in the tourism industry.   The new National Park Partnership Plan needs to completely change the focus of what the Park is doing, from wasting money and resources on trying to chase off responsible campers to the provision of the basic infrastructure the Park needs.




July 3, 2017 Nick Kempe 1 comment

Apologies to readers but due to problems with internet connectivity I was not able to get this post on (or next on rural development) out last week as intended.   The consultation on the National Park Partnership Plan (see here) closes today.


The LLTNPA’s visitor priorities are wrong


The second section of the Loch Lomond and Trossachs National Park Authority’s National Park Partnership Plan (NPPP) is titled Visitor Experience.  I hate the term (it was also used by the Cairngorms National Park Authority) because its being used to change what National Parks should be about.  Instead of enabling people to enjoy the landscape for itself, and being free to do so, our National Park Authorities now appear to believe their role is about giving people an experience – often it seems something to be paid for – whether or not that experience has anything to do with outdoors.  This is a distortion of our National Park’s statutory objective in respect to visitors which is “to promote understanding and enjoyment, including enjoyment in the form of recreation, of the special qualities of the area by the public”.   Note the statutory objective relates to “the special qualities” of the National Park, not to the promotion of developments such as Natural Retreats or Flamingo Land.    Many of the failures of the LLTNPA and draft NPPP result from a departure from that statutory objective.


A good example is VE3, which is about the visitor economy:


“Businesses and organisations in the Park have taken great strides in adapting and innovating to better provide for the dynamic and ever changing tourism demand. The accommodation offering has seen many positive investments while the quality of food and drink has improved significantly. We have seen a strong increase in the number of people coming to the National Park for food and drink, up from 15% in 2011 to 44% in 2015. There has also been a rise in visitors using of self-catering, managed campsites and hotels from 2011 to 2015.”


Ignore the fact that there are now fewer places to camp in the National Park than ever before, ignore the failure of the NPPP to consider low pay and precarious jobs in the tourism industry, the LLTNPA appears to see promoting food and drink as important, if not more so, than enabling people to enjoy the Great Outdoors (and is it really credible that the numbers of people visiting the National Park is up from 15% to 44%?).   The photo in this section, (left) speakers louder than words.


Tourism, whether appropriate or not, has become a substitute for sustainable economic development (the third statutory objective of the LLTNPA and subject of my last post on the NPPP).   This is the wrong starting point.   As the NPPP states, the vast majority of visitors to the National Park are day visitors from the Clyde conurbation.    Those people – I am one of them –  and overnight visitors visit primarily to enjoy the scenery and undertake recreational activities such as walking, cycling, boating or fishing.  We may of course spend some money – many hillwalkers for example enjoy a meal or a drink at the end of the day and this helps explain the success of enterprises like Real Foods at Tyndrum, while other people enjoy sitting out in pleasant surroundings (hence the success of the Oak Tree Inn at Balmaha?)  – but for most people this is a consequence of their visit, not a reason for it.


What appears to be happening though – and the Visitor Experience framework and the NPPP is an attempt to promote this further – is that the LLTNPA is prioritising the small minority of high spend visitors over the mass of people who visit the National Park:


“Our visitor profile has traditionally been characterised by high numbers of predominantly day visits that coincide with good weather. Historically this has meant a highly seasonal, weather dependent visitor economy that can give us very high volume visitor pressures in some of the most popular areas of the Park. These pressures can affect the quality of environment, visitor experience, economy and community life.”


Note how the LLTNPA claims that the high number of visitors on a few days of the year affects “the Visitor Experience”.  This is a version of the same old chestnut that there are too many people on the hill – the presence of other walkers destroys the experience.  Its elitist and the solution is obvious:  if you don’t like other people go somewhere else when its busy.    I am sure I am not the only person who avoids west Loch Lomond on public holidays but the large numbers of visitors at these times is an opportunity for the people who visit (to promote their own physical and mental wellbeing).    The LLTNPA however appears to see numbers as a problem rather than a challenge and so is trying to restrict visitors through the camping byelaws (300 places under the permit system instead of maximum counts of 850 tents previously), gating off and reducing the size of car parks (e.g on Loch Venachar) and introducing charges for visiting (car park charges, toilet charges etc).  There is no attempt to analyse the implications some of which are touched on the in the Strategic Environemental Assessment:


“the new more stringent visitor management measures may erode certain personal freedoms (population and human health), negatively impacting the image of the National Park.”


Instead of attacking access rights, the LLTNPA should be addressing the shortfall in infrastructure  needed to support visitors, at both peak and non-peak periods.  This includes addressing the shortfall in  basic facilities which parkswatch has covered many times in the last year, particularly litter bins and toilets (no mention in the NPPP that this comes out as top need in all visitor surveys in the National Park), as well as more challenging improvements such as to transport infrastructure as recommended in the LLTNPA’s own Strategic Environment Assessment:


the vast majority of visitor journeys to the Park continue to be made by car. There remains a need to promote public transport options and encourage visitors to travel by alternative modes. There are also opportunities to make travel to and within the Park “part of the experience” (e.g. linking longer distance cycle routes to public transport, investing in the seasonal waterbus service).”

The only improvement to public transport mentioned in the NPPP is the waterbus.    While the CNPA are committed to improving public transport in Glenmore, the LLTNPA has no plans to encourage the provision of public transport to Rowardennan, despite Ben Lomond being completely inaccessible to the large proportion of people who reside in the Clyde conurbation who don’t have a car.   This should be a national scandal.




The Visitor Experience section is peppered with parkspin, which is made possible from the lack of evidence in the plan and the failure to review progress in the previous plan (see here). This is a post-truth neo-liberal world full of soundbites and where evidence doesn’t count.  Here are a few examples:


  • “focus on raising the level of ambition, to ensure that the quality of visitor experience in the National Park is truly world class.”

Comment: actually, what most visitors want the National Park to do is provide basic facilities such as toilets and ensure litter is picked up.  The scenery doesn’t need ambition, it needs practical protection (there is no consideration of how all the new hydro tracks in the National Park contribute to the world class visitor experience).


  • “Boating and fishing continue to be popular and the availability of boating facilities (publicly-accessible piers, pontoons and moorings) continues to fall short of demand”. (VE2)

Comment: this is the same National Park that shut the Milarochy Launching pad without consultation just a few months ago.


  • “The West Highland Line offers an outstanding rail experience but opportunities to come here via local stations are currently under-promoted” (VE3).

Comment: last year (see here) the LLTNPA failed to respond to the reduction in cycle places on trains on the West Highland Line. Perhaps its now seen the light?   The West Highland Line though needs more than promotion for people to use it.  A timetable that worked for day visitors and a bus link for hillwalkers to the Arrochar Alps would be a start.


  • “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. This approach has achieved transformational improvements to East Loch Lomond and parts of The Trossachs through the 5 Lochs Visitor Management Plan.”(VE4).

Comment: the reality is that there has been some (not much) public investment, much of which has been wasted (for example £150k to date on camping management signs), the toilets the Park operates are closed for much of the year and most of the excellent proposals in the Five Lochs Visitor Management Plan have been dropped (eg for new toilets, camping areas, litter bins and wood piles for people to use) without any public explanation.

  • “There is scope for us to further develop the role of the National Park to engage with a wider range of groups in society and support recreational enjoyment, responsible behaviour and stronger appreciation of the need to look after the environment.” (VE5)

Comment: the reality is the LLTNPA has a long history of failing to engage with recreational groups, who have been excluded from decision making processes. There is not a single proposal in the plan about how recreational and landscape interests could be given a real say in how the Park is run.


Commentary on Visitor Experience Outcomes and actions

VE1  Recreation opportunities

This heading is misleading, the content is about path provision.   There are outdoor recreational opportunities everywhere, the issue is what infrastructure is needed to support this.   There are some good practical proposals in this section – unlike most other sections of the plan –  which are about what the LLTNPA will do over the next five years to improve the path network.      Whether the investment is enough, however, is not considered – its not nearly enough – and all the financing is dependent on other bodies.


In my view what the plan should have done is evaluate the recreational infrastructure – is it sufficient to meet demand, what state is it in? – and then set out a case for what resources are needed.    The Mountains for People project is great but it only tackles a small number of paths predominantly on publicly owned land.  What is the LLTNPA going to do to address path erosion on other hills?   Do the existing state management plans, which the LLTNPA has refused to release under FOI, contain any plans for paths?  (see here) The NPPP gives a nod to the problem “finding long term solutions to ensure the existing network is maintained and promoted to a high standard”  but contains no ideas let alone any proposals for how this might be addressed.   How about a bed night tax as is common in the French National Parks?   A small levy on overnight visitors would go a long way, as would car park charges if they were spent on paths rather than on trying to restrict access.


The absence of any context  makes it hard to interpret the commitment to review core paths.  Does the LLTNPA think these are sufficient or insufficient?  We are given no idea.   There should be a clear aspiration to increase the core path network.


VE2 Water based recreation


This section lacks any concrete proposals.     The spin, “Ensuring larger lochs are managed to support and facilitate both water craft and other recreational uses  while maximising safety for all users” is contradicted by the the reality which includes the Milarrochy slipway on east Loch Lomond has been closed on spurious health and safety grounds (see here),  the former access point for canoes at Loch Chon has been blocked off and the Loch Venachar Quay which was gifted to the people of Callander to enjoy boating (and which happens to be adjacent to Venachar House, home of former convener Linda Mackay) has been planted with trees.  There is no analysis of why numbers of boats on Loch Lomond have dropped – the water byelaws are asserted to be a success – and no practical proposals to make access to the water easier.  Instead the LLTNPA is focussing on supporting high profile mass events, such as swimming, which depend on volunteers from the boating community for stewarding.    The Loch Lomond Association, which represents all water users on the Loch, is not included as a stakeholder – that says it all!   The development of a meaningful plan should have started with the people who use the lochs (just as plans for camping should have started with the people who camp).


VE3 on tourism businesses


Priority action 1 says it all:  “Encouraging and supporting new and established tourism businesses to innovate and collaborate to  capitalise on growth markets………………”.    The section then goes on to talk about “recreation activity offerings” and “accommodation offerings” and states the LLTNPA wishes to encourage private sector and other investment in facilitiies for motorhomes and lower cost accommodation.   Nowhere does the Park set out what provision it sees as being needed or what investment might be required.   That is another abdication of responsibility.  The LLTNPA however apparently would prefer to leave not just delivery of facilities but also their planning to the market.   Why have a NPPP or a National Park Authority if you don’t believe in planning?

VE4 Visitor Management


This section states its about popular areas and management of visitor pressures but again is not based on any analysis. Its proposals show that the LLTNPA has learned nothing in the last two years from the criticisms of the camping byelaws.


The first priority action, which is the Park’s way of saying that it wants the camping byelaws to continue, is both meaningless and now defunct after the LLTNPA’s decision that it can no longer limit the number of campervans/motorhomes (see here): “Ensuring that the Camping Management Zones (WestLoch Lomond, Trossachs , Trossachs North and East Loch Lomond) support improvements to the environment and visitor experience through providing for sustainable levels of camping and motorhome use alongside other visitor activities.in the camping management zones


The second priority action “Agreeing an approach to ensuring the sustainable and responsible use of the Loch Lomond islands” is code for extending the camping byelaws to the Loch Lomond islands which the Board has already agreed in principle to look at. No evidence is provided to show that there is a problem that needs addressing and the failure of the LLTNPA to be open about this is another indictment of how it operates.


On the third priority action, while its a step forward that the LLTNPA has recognised the litter at the head of Loch Long as a problem that needs addressing (but if this, why not the litter along the A82 or fly tipping?), the inclusion of this action point under a section dealing with visitor management is incomprehensible. The litter at the head of Loch Long is not created by tourists but comes from the Clyde.  The Park’s reference to “innovative solutions” is devoid of content and therefore meaningless – what’s needed are resources to clear up the mess.


The fourth priority on developing parking and traffic management measures appears to be “code” for the further introduction of car parking charges. There is nothing in the consultation asking what people think about this – another indication that this is not a proper consultation at all.


VE5 Diversity of visitors


The actions in this section are again in my view meaningless. While the LLTNPA recognises that getting outdoors is good for people’s health and also its difficult for many people in the Clyde conurbation to get to the National Park, there is no analysis of how its existing visitor management measures have impacted on this (the camping bylaws hit the poorest most) and not a single proposal for how the LLTNPA could make the National Park more accessible  (A contrast to the Cairngorms National Park Authority who, for example, recognised there are issues about who accesses outdoor education).    The Park’s plan is to engage with health boards – is this really going to sort out the mess it has created?    If the Park really wanted to encourage people it would not have constructed its new campsite at Loch Chon, only accessible by car. The LLTNPA claims the National Park offers a range of quality outdoor learning experiences, again with any analysis. The reality is that outdoor education provision has been hit hard by the cuts while organised groups like Duke of Edinburgh Award and the Scouts (which are working hard to welcome a wider range of young people) now face the bureaucratic rigmarole of having to apply for exemptions to the camping permit system.   Judging by the number of such exemptions, most are voting with their feet.


What the LLTNPA needs to do


Here, in a nutshell, is an alternative agenda for promoting understanding and recreation which depends on the National Park’s special qualities:


  1. The LLTNPA needs to re-write its plan  so it focuses on outdoor recreation and enjoyment of the countryside, not “the visitor experience” and base this on proper evidence and an analysis of what it has/has not achieved since it was created.
  2. The LLTNPA needs fundamentally to change its approach to visitor management from seeing visitors as a problem to recognising the right of people to enjoy the countryside.  This means dropping the existing camping byelaws and the proposals to extend them to the Loch Lomond islands and reversing other measures designed to reduce visitor numbers (such as removing gates from car parks)
  3. The LLTNPA needs to get back to basics in terms of recreational provision, developing a plan describing what infrastructure is needed from litter bins and toilets to new paths and improved public transport.   This should set out what can be funded from existing sources (there is money to invest, for example from Forestry Commission Scotland, through various land management grants or even from hydro schemes) and what additional investment is needed
May 23, 2017 Nick Kempe 4 comments
Photomontage of Option 1 for proposed redevelopment of Ptarmigan.  As well as the raised viewing tower, note the glass viewing area added to  design

I understand that Natural Retreats were not happy last week that their proposals for Cairngorm were obtained through Freedom of Information (see here).   As John Hutchison pointed out on twitter in response to my post, the secrecy at Cairngorm rather undermines – or perhaps reinforces the need for! –  the current Scottish Government consultation onengaging with local communities on decisions about land (see here).     While the draft guidance states there is no need for additional consultation where statutory consultation is required, it appears Natural Retreats and HIE are planning to submit a bog standard planning application without any specific consultation with the local community, let alone with the recreational community or conservation organisations, as would be required if a proper masterplan was developed.    No change then to the way HIE has always operated at Cairngorm, plans are developed in secret and then presented as agreed.


More development, high up on Cairngorm, is totally inappropriate


Design Option 2 for the Ptarmigan


Before considering why HIE are pushing the development of the Ptarmigan, its worth stating clearly why the proposal is fundamentally flawed:


  • Its near the summit of Cairngorm, one of our finest and best known hills.  Its not the sort of place where a National Park, whose mission is to protect our finest landscapes, should be allowing further development.
  • HIE and Natural Retreats will doubtlessly argue that the increased visual impact created by their proposals will not be that significant, but the job of the National Park should be to see that existing impacts are reduced, not increased.
  • In tourist terms, Cairngorm is covered in cloud for much of the time so why would anyone take a train up to near the summit to see…………….. nothing?   The concept is all wrong.  If you want to get people to take trains or gondolas up mountains, they need to finish somewhere with a view.  In Scotland, this means taking people half way up the hill where they might get a view most days of the year, like the Aonach Mor gondola, not onto the Cairngorm plateau.
  • Most tourists, however,  want more than a view, which after all you can see easily enough on film.  They want to experience the outdoors in some way, which means a walk.  Leaving aside the legal agreement, which prevents non-skiers from leaving the stop station, Cairngorm is not a good place for a walk most of the time – the weather is just too wild, though maybe Natural Retreats think will buy a ticket up the funicular so they can be blown about on a viewing platform.  Of course, Cairngorm in fine weather is wonderful, which is why so many people care about the place, but those days are far to few to support mass tourism developments high on the mountain


For these reasons further developments high on Cairngorm are objectionable in principle, something which conservation and recreational organisations have been trying to tell HIE for over twenty years.


Why do HIE and Natural Retreats want to develop the Ptarmigan?


While its not clear at present why the earlier plans to develop the Day Lodge were dropped, the current proposals suggest this is all about the funicular.   The risk of developing the Day Lodge into a visitor and conference centre is that on those wet and cloudy days, people would not have bothered to buy a ticket up the funicular.


The funicular was supposed to increase the number of summer visitors to Cairngorm but Natural Retreats figures (from last year) say it all:  “210,000 annual visitors (120,000 in winter and 90,000 in summer) with vast potential to increase”.    The aim of the new Ptarmigan development appears to be to try and attract more summer visitors to Cairngorm.:

Extract from slide obtained through FOI “Cairngorm Mountain Resort Development Plans”


The initial plan was to increase visitor numbers through the creation of three mountain bike trails down from the funicular top station, as mooted in press.   However, it appears the other public agencies made it clear they would not relax the legal agreement preventing people from leaving the top station.  This is not surprising. One could hardly justify mountain bikers  leaving the stop station while pedestrians were stuck inside.

Advice from SNH obtained through FOI

Once the mountain biking proposal was dropped, the only option was to try and think of ways of turning the Ptarmigan into a tourist attraction which visitors would want to visit even though they were unlikely to see anything and would not be allowed out for a walk.   Hence the proposals for viewing towers in the top two photomontages and for a wrap around viewing platform added on to the existing building (purple area below):

This and following slides all from documents entitled “Cairngorms Mountain Resort Development Plans” obtained through FOI

And, in order to give people an “authentic” taste of the outdoors, a board walk out over the top of the funicular tunnel was proposed:


Inside, the idea is first to provide a visitor attraction:



Then, a much larger cafe so people have somewhere to go and spend money after viewing the exhibitions.


And finally, to encourage people arriving at Cairngorm to buy the ticket up the funicular, a partial facelift for the funicular entrance and funicular itself are proposed:


Why the proposals are misguided and what needs to happen

Whatever you think of the designs – and the firms that have developed them, 365 and 442, have some very skilled people – the problem is they are for a development in the wrong place:


  • Adding glass covered walkways and viewing towers to a visitor facility is a good idea but not appropriate for Cairngorm
  • The proposals for the exhibition may be interesting, but the place for a visitor centre is lower down the mountain, where people can go out afterwards and experience some of what has been shown as in Coire cas.
  • The blingy funicular upgrade might be a great idea for Blackpool but not Cairngorm


The basic problem is that HIE are still hooked on trying to increase funicular numbers in summer, still trying to make their asset pay.  They don’t appear to understand most people who visit the National Park in summer want to be outside.  Why would such people ever want to take the funicular when they have the whole of Glenmore to experience?   A visitor centre might be a good option for a wet day but a visitor centre up the top of a mountain on a wet day will be a disappointing experience.


Maybe HIE has conducted proper visitor surveys providing evidence that lots of people visiting Glenmore would pay to visit such a facility and this has informed their decision to lend £4 to Natural Retreats – but somehow I doubt it (I will ask).   Consultation is not HIE’s forte.


A little early engagement with all interests (and not just public authorities) – as recommended by the Scottish Government – would prevent HIE adding to the financial disaster of the funicular, for which it of course was responsible.


Meantime, there is no sign of any proper plan being developed for Cairngorm.  HIE was tasked under the Glenmore and Cairngorm Strategy with producing a Cairngorm Estate Management Plan – there is still no sign of this or the proposed Montane Woodland Project on Cairngorm and in my view both should have been agreed BEFORE any development proposals.    The Cairngorms National Park Authority also asked Natural Retreats to produce a set of standards to guide their operations on the mountain and there has been no sign of this either.


Its time for the Cairngorms National Park Authority to start speaking up for Cairngorm and a first step would be to ask Natural Retreats and HIE to start consulting on all the other proposed plans before any development proposals are considered.  If they are also feeling brave, they could  point out to HIE and Natural Retreats that the priority for sustaining the local economy is maintaining winter visitor numbers, not summer visitors.

May 11, 2017 Nick Kempe 4 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.

April 24, 2017 Nick Kempe 9 comments
Aerial view of the proposed development area included in he scoping report from Peter Brett Associates

At the beginning of April, Flamingo Land (see here for most recent post and links) asked the Loch Lomond and National Park Authority whether an Environment Impact Assessment (EIA) would be needed for its proposed development at Balloch  (see here)   The response of the LLTNPA on 13th April (see here) was that a full EIA will be required:


The development is permanent and will have an impact on a large area (33.5ha) and will have an impact on both visitors to the National Park, residents and businesses.  The proposal is complex and large scale.  The construction period is likely to be long and any impacts during construction will be prolonged in terms of construction traffic, noise and pollution.  The operation of the development also gives rise to potential significant environmental impact in terms of landscape impact, traffic increase and noise nuisance


The response was rapid I believe because the LLTNPA could hardly have said anything else.    So, what can the concerned public learn from the 125 pages of report submitted with the request for a screening opinion?

The most striking thing about this proposed development in our National Park is its size, 33.5 hectares, almost twice the size of the West Riverside Site marketed by Scottish Enterprise (map above).  What the top photo illustrates graphically is how Flamingo Land, through its purchase of Woodbank House, has in effect gained control of all the undeveloped land on the north west side of Balloch and its proposed development will effectively surround Loch Lomond shores.   Its power will increase further if Scottish Enterprise, as its proposing, eventually sells it the West Riverside Site. Land.   In effect the southern gateway to the National Park is being handed over to a private business.   There are legitimate questions about whether this is in the public interest and whether, whatever developments might eventually go be agreed by the LLTNPA,  the ownership of the West Riverside site should remain in public ownership or, alternatively, be transferred to the local community.

The EIA Report makes a reference to the site as being vacant and derelict – a myth that supporters of the development are using to justify the development – and states that there is a desire across  Glasgow Region to treat such land as an investment opportunity.   The trouble is the portrayal of the West Riverside site as derelict is  not true as the photo above shows.  Yes, there are pockets of dereliction and Woodbank House is in a sad state of disrepair.  While the West Riverside site may  not be the best green space in the world there is far more green than dereliction and, contrary again to claims in the Balloch Charrette, its well used by people.  Indeed much of the  greenspace is the  product of earlier restoration of what was formerly the line of the railway.

There are even pockets of wild along the shores of the River Leven.    If this is developed into a constructed river walkway, as the LLTNPA and Scottish Enterprise appears to wish, how will visitors to Balloch be able to access nature?   That is after all what the National Park is meant to be about?


The developers will argue that  people will still be able to access Balloch Country Park on the other side of the River Leven but this is inaccessible.   The EIA makes no mention of the long-wished for pedestrian bridge across  the head of the River Leven  which would enable people visiting Lomond Shores to access the Country Park.  That might offset to some extent the development of this site but the omission of the bridge from the EIA scoping requests indicates Flamingo Land has no intention of paying for this.


The EIA scoping Report is very vague about Flamingo Land’s plans which are listed as follows:


  However, other parts of the report give an indication of what this includes.

As if the existing Drumkinnon Tower at Loch Lomond shores was not enough, the report includes an outline visual impact assessment of a 100m high viewing tower.  Its appears that to compensate for the removal of greenspace  at Balloch, the idea is visitors should be able to view nature from afar.




You don’t need a viewing tower to see Ben Lomond from Balloch but  any viewing tower will have a signficant impact on the views south from the Loch Lomond National Scenic Area, including from the summit of Ben Lomond.   The EIA, though, apparently believes a solution could be found: “consideration should be given as to how to mitigate expansive southerly views from this popular hillwalking viewpoint”.    A friend suggested it could be very slim and reflect the shape of a Flamingo’s neck.

There is another apparent give away in the scoping of the Zones of Theoretical Visability (ZTVs).   On the maps that depict what can be seen from where there are three references to a “chute” which occurs nowhere else in the document.   Is this why the proposed Leisure Development feature is 50m high?    Is this an enormous water slide?   It appears the Sunday Herald was fully justified in referring to the proposal as the blingy bling banks of Loch Lomond (see here).    Such evidence as can be gleaned from the EIA documents provides no re-assurance about what Flamingo Land is going to propose but what it is it appears to be an intensive tourist development.


Such development is, I believe,  not appropriate for a National Park.   National Planning Guidance re-inforces this:

A good reason, one might have thought, for the LLTNPA to reject the proposal but the EIA provides an indication of why this might not happen:

This reads as though the application has already been agreed, its only the fine detail that needs to be sorted out and all can be mitigated.   It makes one wonder if the 100m viewing tower and leisure development are being proposed to divert people’s attention from other aspects of the plan, which are fundamentally about development on greenspace at one of the main entry points into the National Park?   The scenario is that following the inevitable public stushi on the viewing tower, the LLTNPA rejects that aspect of the proposal and tries to market the “compromise” which follows to the public as somehow meeting the statutory objectives of our National Parks.


The EIA contains a number of proposals for consultation, mainly with statutory bodies – potential for lots of wheeling and dealing behind closed doors – but nothing I could see about engaging with people who care about National Parks in Scotland, including the people who signed the petition against Flamingo Land.  So, how about Flamingo Land starting their consultation by asking the public about the viewing tower and leisure chute?



March 9, 2017 Nick Kempe 1 comment
Milarrochy, on east Loch Lomond, has been used by people to launch boats for years. Its one reason why the shoreline around the bay is a shingle beach and devoid of grass – a sign of thousands of people enjoying themselves here.


Three years ago I knew nothing about boating on Loch Lomond and, if you had asked me about the Loch Lomond byelaws, – the ones that control boat users on the Loch – my response would have probably been along the lines of “anything which controls speedboats must be a good thing”.  That way of thinking, which I am afraid was born out of ignorance on my part, is exactly why we have ended up with camping byelaws.   The view of the general population and local communities in the face of relentless propaganda from the Loch Lomond and Trossachs National Park Authority could fairly be summed up as “anything that stops people abandoning tents or having a rave on the lochside must be a good thing”    What I appreciate  now is that such views, whether about boating or camping,  are not just held out of ignorance, they ignore the rights of other people.   We should never condemn the many because of the few, whether we are talking about campers or religion.


I have also learned in two years of campaigning against the camping byelaws that it has been boat users, whether motorised or not, as represented by the Loch Lomond Association,  who have been the strongest defenders of the right to camp in the National Park. So effective indeed has been their opposition, that the LLTNPA deliberately excluded the Loch Lomond islands from the camping byelaw consultation because of the trouble they knew this would create for them.


About six weeks ago the LLTNPA announced in a letter to registered motor boat users on Loch Lomond that they intended to close the slipway at Milarrochy from 1st April.  There had been no warning of this, no consultation and the “decision” was taken by LLTNPA staff, not the Board, allegedly on grounds of health and safety.    The nature of the “decision” and the way its been taken should be of concern to all recreational users of the Loch Lomond and Trossachs National Park whether walkers, sailors, cyclists, fishermen and women, birdwatchers or anyone else who enjoys the National Park.  …………………..


The letter is full of the type of parkspeak which permeated the camping byelaw consultation “we want people to continue to enjoy this area” – “speak” for “its another ban” – “difficult decision” and “striking a balance”:

I therefore submitted an FOI request, along with a number of other people. about the basis of the decision and a week ago received this response EIR 2017-018 Response Milarrochy.


Analysis of LLTNPA response by Peter Jack

Peter Jack, chair of the Loch Lomond Association, who has attended every Board Meeting for the last two years as a member of the public, has undertaken an excellent analysis of the response which I am pleased to be able to feature here.  Its well worth reading, to understand just how the Park operates,  along with the Park’s “Health and safety” assessment which is pasted below it.






You can see the numbers of launches here Milarrochy March-Boat-launch-figures.   The LLTNPA Health and Safety assessment consists of four lines – note the assessment which the LLNPA claim to have undertaken is NOT on their website, the only information is that pasted below:

I have commented before on the arbitrary exercise of authority by the National Park, but if the LLNPA is allowed to take decisions on this basis, they could close down anything for health and safety reasons.  Note the lie, motorboats……….. must be dangerous for swimmers etc.   In fact, guess who lobbied the LLTNPA to take action to ensure inadequate health and safety measures at one of the mass swimming events in the lochs was addressed?  The LLA.  And its boating volunteers who provide the voluntary escorts at these “wild swims”.


The real reasons for the decision to close the Milarrochy slipway


This decision clearly has nothing to do with health and safety.  My initial view was that it was probably about releasing park rangers to police the camping byelaws.   In the last paragraph of their response the LLTNPA has used a spurious interpretation of my use of the word “policing” to avoid answering the question on whether rangers were to be redeployed to chase off campers and I have therefore refined my request..


However, I also think the motivation for stopping boat launches at Milarrochy could be to test out the strength of the LLA with a view to deciding when the LLTNPA should start trying to extend the camping byelaws to the Loch Lomond islands.  This decision was minuted at the Board Meeting in April 2015, which approved the camping byelaws, and also appears, heavily disguised, in the draft  National Park Partnership Plan which will be launched for consultation by the Board at their meeting on Monday: “The access and use of the Loch Lomond islands still requires attention to ensure their precious habitats can thrive alongside land and water based recreational activity.”    The words “still requires attention” is code for more camping bans.    Every reason therefore for other recreational groups to support the LLA in their efforts to get the Milarrochy “decision” reversed.


Today though, I also came across this in the Operational Plan for the Park for the new financial year under the Park’s commercialisation programme.  :



I believe the kiosk is to be the old Ranger base at Milarrochy – so this looks like part of the LLTNPA’s strategy to hand over as much of its property within the National Park as possible to commercial businesses in return for rent.  The same commercialisation policy is driving the incremental introduction of car parking charges  across the National Park.   I will comment on the Partnership Plan in due course, but part of what needs to be changed within that plan is the neo-liberal ethos that sees National Parks as having to make money.  Some things should be beyond price and that includes the right of people to launch boats onto the loch.


What needs to happen


The Board meeting on Monday needs to re-assert the need for decisions like this to be taken at Board level and overturn the decision of staff to shut the Milarrochy slipway.   A test of the new Convener, James Stuart’s, mettle.


February 6, 2017 Nick Kempe 3 comments

A further insight into the failure of the Cairngorms National Park to protect native wildlife was revealed in the article above which appeared in the Strathy last week.  There may also be a link between the CNPA’s approach to mountain hares and its apparent attempt to silence Councillor Bill Lobban last week (see here).


While I welcome the fact that the estates involved in the mountain hare counting project have agreed to stop culling mountain hares – (and if Glenlochy’s claim is true it appears they stopped culling mountain hares while poisoning of buzzards was still happening on their land (see here)) –  there is  another agenda here which is illustrated by some of the quotes from the piece:

  • Glenlochy is claiming that overpopulation of mountain hares can be detrimental while at the same time claiming mountain hares are “notoriously difficult”  to count, which is why this project is needed.   How, one might ask, does any keeper know there is an “overpopulation” of mountain hares if they do not know numbers?
  • What is an “overpopulation” of mountain hares – who sets the criteria for this? – and what is the impact of hare numbers of flora and fauna?   It is generally accepted that without human intervention, mountain hare numbers rise and fall naturally.  If its impact of mountain hares on flora, from so many nibbling mouths, which estates are concerned about, well…………….how does this compare to the impact of the muirburn conducted by these same estates on vegetation?   We know the main alleged impact on fauna which concerns estates is that Mountain Hares carry the tick which can infect Red Grouse with the louping ill  virus and this is what has led to the mountain hares culls.  But how will counting mountain hares tell us anything about the levels of transmission of ticks between one species and another?    There appears very little rationale to the counting project unless its purpose is to kick any action to protect mountain hares in the National Park into the long grass for a three further years.
  • The claim that culling hares is necessary for the “general health of the species itself” seems based in eugenics.  While genetic manipulation and selection by humans has been integral to the development of farm crops and animals, applying such thinking to what should be wild is a different matter.   Why not let nature sort this out?    The claim is complete nonsense anyway.   All the photos that have appeared on Raptor Persecution Scotland (see here) show there is indiscriminate culling of mountain hares.  If natural ecosystems were functioning in the Cairngorms no culling would be necessary anyway as there would be eagles and other predators which would live off the mountain hares and control their numbers.   The populations of predators would then fluctuate along with the population of their food source.  The fact that the impact of predators, or rather their absence, appears to have no role in this study tells you its not about tackling the real issue, wildlife persecution.


While the CNPA has no direct role in the study, to design a study which is to take place in the National Park without considering how it meets the overriding national conservation objectives of the National Park appears to me just wrong, a mis-use of public resources.   The CNPA too has claimed it cannot take any action to protect mountain hares until this study is completed.  Whatever happened to the precautionary principle, which says you protect nature until you know its safe not to, or the conservation objectives of the National Park?


Our public authorities and research institutions are studying all the wrong things in our National Parks.   They should not be funding studies whose main purpose can be to serve the interests of the shooting lobby.  What we need from the CNPA is  a proper assessment of the wildlife deficit in the Cairngorms – just how many stoats, weasels, hen harriers, golden eagle etc are missing from the the eastern Cairngorms and what is the potential for species like the beaver – and then fund research into alternatives to the current model of sporting estate.


Species champions, in Highland Council and in the National Park


A few years ago Highland Council decided to support its Councillors becoming  species champions:


The elected members will be invited to become a species champion. This follows on from the successful initiative that Scottish Environment Link undertook with MSPs. The choice of species will come from a list of over 70. The role of a species champion will be to take an interest in “their” species and act as an advocate for it, highlighting its importance and/ or the issues affecting it in relevant debates or other opportunities that arise.

There are currently at least 27 Species Champions in the Council including such species as harbour porpoise, red kite, strawberry spider.   The three Highland Councillors who sit on the Cairngorms National Park Authority Board are all species champions, Dave Fallows for the Capercaillie, Gregor Rimell for the Northern Damselfy and Bill Lobban……………. for the mountain hare!   Indeed, Councillor Lobban has spoken out for the Mountain Hare (see here) unlike the convenor of his planning committee (see here).     Evidence I think that the attempt to silence Councillor Lobban last week on planning issues was part of an attempt to silence one of the few CNPA Board Members prepared to speak out for wildlife.    .


The ability of the three Highland Councillors to become advocates for wildlife on Highland Council is quite a contrast to what they are allowed to do as CNPA Board Members.  When the Cairngorms Nature plan (see here) was being drawn up, it was suggested that Board Members could become species champions – what an opportunity one might have thought for the National Park?    After all according to the plan, the Cairngorms is home to 1/4 of all rare and endangered species in the UK.  The CNPA rejected this proposal.    This failure in leadership has had a huge impact.  Contrast the attitudes of landowners and local communities in the West Highlands to species like the sea eagle, which they know are fantastic for tourism, and to how the Cairngorms National Park treats its wildlife.  A little diversification of the tartan tourism on Deeside which is based on Balmorality to wildlife could do not harm.


What needs to happen


  • In the forthcoming Partnership Plan the CNPA could show its commitment to wildlife by encouraging all its members to become species champions and allowing Highland Councillors to play this role both within their own Local Authority and the National Park.  The first new species that should be championed is the beaver, with the Board Member advocating for it leading the re-introduction of this species into the National Park
  • The forthcoming Partnership Plan needs to include a commitment to put wildlife in the National Park first and stop any species, including the mountain hare, being persecuted for the benefit of shooting interests.  That entails developing measures to regulate shooting, trapping and the use of dogs to hunt wildlife in the National Park.
September 1, 2016 Nick Kempe No comments exist
IMG_6787 west LL laybys - Copy
Caravan and awning in 3 bays Layby on southbound side of A82 14th August 2016

There has been a history of people staying in caravans in the laybys along the A82 south of Tarbert.    The caravan in the photo above was still there when I went past on Monday 29th August.    The Loch Lomond and Trossachs National Park Authority used  long stays such as this, which are commonly known as encampments, to justify the proposed camping byelaws – despite powers being available to stop this under the Criminal Justice and Public Order Act 1994.


When I asked the LLTNPA about this over a year ago, I was told:


“The National Park Authority does not have powers to take action with respect to long-stay caravans, tents or motor homes and therefore has no policy or procedure for taking action”.

Loch Earn sign Cameron McNeish - Copy (2)
Loch Earn sign 2016 – similar signs were in place 2015. Photo Credit Cameron McNeish

This response is misleading.  Section 61 of the Criminal Justice and Public Order Act can be used where two or more people on land “with the common purpose of residing there for any period”   and “reasonable steps have been taken by or on behalf of the occupier to ask them to leave”.   While the LLTNPA owns very little land in the National Park, I am sure the landowners who have been complaining about encampments would be only too happy to give their permission to the LLTNPA to act on their behalf.  Indeed, this appears to have happened on the north side of Loch Earn (see left).


Further, one might have thought that with its Rangers out on daily patrol recording every tent, caravan and fire the LLTNPA would have a key role in supplying the evidence necessary for the police to take action under Section 61.  The police can remove encampments where “any of those persons has caused damage to the land or to property on the land or used threatening, abusive or insulting words or behaviour towards the occupier, a member of his family or an employee or agent of his, or those persons have between them six or more vehicles on the land”.


However,  FOI 2015-025 Response encampment also showed that besides having no policy or procedures to report encampments to the police, the LLTNPA’s rangers did not record how long tents or caravans were in place let alone whether there was any evidence of campers/caravaners causing damage.    It also admitted that the LLTNPA had no means of identifying or recording when complaints were received about encampments – despite local communities stating they had submitted frequent complaints to the Park.   If the LLTNPA had fixed these issues and created mechanisms to ensure adequate liaison between landowners, the police and itself most of the problems associated with encampments could have been addressed.  And there would have been no need for the proposed camping byelaws………..


I find it curious that, to the best of my knowledge, the signs on Loch Earn are the ONLY initiative the Park has been involved in regarding encampments.   There are NO signs like this on West Loch Lomond.   This suggests to me that the signs on Loch Earn was very much an initiative from Drummond Estates, who had serious reservations about the proposed camping byelaws, and not the LLTNPA.   Assuming that the LLTNPA believe the caravan in the above photo to be a problem, it appears that rather than take action about this now, along with the local landowner Luss Estates,  they would prefer to ban camping and campervans completely.


Now there are limitations to Section 61.   There need to be two people encamped and there have been caravans parked in laybys on the A82 that look as though they may be used by single people as a temporary home (if you are working in the area on one of the roads projects for example its far cheaper to park your caravan than rent a place to stay).    The police also have no grounds to remove longstay campers/caravaners who abide by the Access Code in every respect except for the length of their stay (i.e they do nothing that could be classified as damage) and who remain polite at all times.   However, I suspect very few people who “encamp” are aware of the law and if the Park put up some signs, like Drummond Estates, and its Rangers spoke to the people in the caravans most would leave.  Problem solved, no need for camping byelaws.    There are no signs that the LLTNPA has done anything on West Loch Lomond and I am not aware of any other initiatives elsewhere in the Park.    A complete indictment of its failures as a National Park.


To make matters worse, by opting for camping byelaws rather than using existing powers, the Park is proposing to stop all those people in campervans who stop overnight off the A82 (two of which are in the top photo), the cycle tourers, canoe tourers and fisherman none of whom cause any serious problems.  This August I have seen dozens of campervans stopping off overnight in laybys along the A82, one of the two main tourist routes north.   It appears the LLTNPA is in league with certain commercial caravan park owners on loch Lomondside to force all the campervans to stay in their sites.  I guess the LLTNPA believe it will increase tourism revenues:  its more likely to destroy the reputation of the National Park as a tourist definition.


What needs to happen

I suggested to Ministers last November that they should suspend any further work on the camping byelaws until the LLTNPA had used all the existing powers available to itself and its partners and shown that they were not sufficient.    I never received an answer to my letter.   The new Minister, Roseanna Cunningham, should now be asking the LLTNPA to provide an independent evaluation of the impact of the Drummond Estates initiative, the extent to which it has been successful or not, and the reasons for this.  The Minister should also ask for a tourism impact assessment – none has ever been produced – on the likely impact of the byelaws not just in the National Park but for the whole of Scotland.

August 22, 2016 Nick Kempe 4 comments


The new car parking meters at Inveruglas carpark – it appears these are about to be scrapped in favour of a new automated number plate recognition system

At the end of last week, while the National had an excellent article by Lesley Riddoch and follow up letter by James Cassidy on access to the countryside, the Loch Lomond and Trossachs National Park Authority was advertising its latest plans to charge for access.    The contrast between what is needed and the Loch Lomond and Trossachs National Park is doing could not be greater.


I would urge you to read the Lesley Riddoch article in full if you have not already done so – and don’t be put off about it starting on the Olympics, its all about why access to the countryside is more important.


“Norway has sorted two big structural problems Scots have yet to really address; access to the Great Outdoors and access to excellent, affordable outdoor early years care. Looking first at outdoor access, the two countries have had very different sporting histories. Norway has 43 national parks – the first established in 1962. Scotland has two national parks – the first established in 2002 and neither is a wilderness area owned by the government as national parks are in Norway. Indeed, across the piece, formal rights of access to the outdoors in Scotland have typically occurred half a century later than Norway, have been less far-reaching and have not changed or challenged the dominance of private, sporting estates. Outdoor experience begins almost at birth in Norway – informally in near universally available family weekend cabins (hytter) and formally in kindergarten. Children in Norway not only have the right to affordable childcare between the ages of one and six, they also have the right to be outdoors at least one day per week.”


James Cassidy’s response, headed “Privatisation by Stealth, is equally good and makes the link with how the Loch Lomond and Trossachs National Park Authority have been undermining access rights.


What we are seeing in LLTNP is the privatisation by stealth of a healthy and growing outdoors lifestyle, and if there’s anything more likely to deter ordinary people from accessing the outdoors it’s by pricing it out of their reach, and all under the threat of a £500 fine if you so much as camp where you shouldn’t. In the 1920s and 30s many people from the industrial heartlands of Scotland, such as the iconic outdoorsman Tom Weir, would take to the hills of Loch Lomond and Arrochar, camping by loch-sides, sheltering in caves and under old army capes, trying to escape the horrendous conditions and grinding poverty of the cities.



The LLTNPA’s privatisation by stealth


At the end of last week the LLTNPA advertised a tender for an Automated Number Plate Recognition system for three car parks it owns, Millarochy, Tarbert and Inveruglas. So what, you might ask?  Well the tender document tells you a little  about where commercialisation in the National Park  is going.


The idea is not just to charge for carparking but to raise the maximum amount of money possible:


“2.17.1    The proposed system must: Maximise the revenue achieved via all car parks across stated NPA sites Minimise any restriction to the flow of traffic on NPA sites. Maximise overall parking occupancy”


“The service must be able to operate 24 hours per day per year on a planned and adhoc basis. The NPA however will determine at what times charges will apply. For example charges might not be made on Christmas Day.”


It will be hard for any contractor to influence occupancy, as the LLTNPA sets the charges but its clear the LLTNPA is determined that no-one will escape without paying.


It is also clear this is intended as only the start of a process of introducing carparking charges across the National Park – I suspect how far this goes will depend on how much they can get away with:


“The NPA plans to enter into an agreement with the successful contractor, offering exclusive rights to introduce and operate an ANPR car park management system at sites of the NPA choosing, subject to agreement.

The contract will initially be for the three NPA’s sites quoted herein with the possibility of further sites being added or subtracted during the duration of the contract subject to suitability.”


Not for the first time, poorly thought out proposals by the LLTNPA will result in the squandering of public money.   The tender makes clear this includes provision of Payment machines – which will replace the Pay and Display machines the LLTNPA has just installed at Inveruglas!   (see photo above) :


“The successful contractor will be responsible, at their cost, to purchase, install and maintain all necessary equipment required to fulfil the contract.”

2.20       The contractor if required must ensure any car park is adequately covered with ticket issuing machines to ensure minimal walking distance from any car parking space to ticket machine.

2.21       The contractor if required must also provide an alternative machine immediately available in case of breakdown within a minimal walking distance. Proposed number and location of machines will be agreed with the NPA.”


What’s wrong with the proposed car parking charges


  • They appear to have been developed in secret just like the camping byelaws.  There have been no papers in public board meetings about this.
  •  There has been no open public consultation about whether the LLTNPA should try to make as much money as possible out of the assets it owns nor whether this is right in our National Parks.  There are plenty of other ways to fund out National Parks.    This is commercialisation by stealth,  motivated by neo-liberal thinking.
  • The LLTNPA has made clear in its tender that charging has nothing to do with encouraging people to stop coming to the National Park by car or adopt sustainable transport- its about maximising the number of cars and therefore its own income.
  • Encouraging people to visit a place – as has happened at Inveruglas where a new viewing tower to look out over Loch Lomond was built as part of the new Scenic Routes initiative – and then 18 months later to sting them for the privilege strikes me as being both immoral and maladroit.  Is the Park trying to destroy tourism?
  • Forcing people to pay car parking charges at important places for outdoor recreation – Inveruglas is the most popular starting point for Ben Vane and Ben Vorlich while Millarochy has long been an important launching point for canoes and dinghies – is basically a charge for access.   The LLTNPA has a statutory duty to promote enjoyment of the countryside and is tasked by Ministers with encouraging  physical activity but is proposing car parking charges which will penalise the people who want to get out and into the countryside and be active most.   If the LLTNPA want to know why this is plain stupid, they should just read Lesley Riddoch.
  •  The proposal is clearly linked to the proposed camping byelaws.  The tender document which states the successful bidder will “If required report on any NPA byelaw violations.” (para 2.30.6).  The proposed camping byelaws would make it an offence to sleep in a vehicle overnight – almost impossible to enforce when Ranger Patrols stop at 10pm but if you have video cameras in carparks this becomes much easier to enforce.   No wonder the tender says the successful bidder may be asked to extend the system to other carparks in future.  Where will this stop?
  • The charges are likely to destroy local tourism or create problems elsewhere because they will  deter people from using the carparks.  They will either go elsewhere or find other places to park.   This could be on verges, forcing the Park to cordon off even more areas, or in settlements like Tarbert people will find other places to park, to the inconvenience of local residents.  Where people go elsewhere this will be to the detriment of the local economy, directly in some cases such as the cafe situated in the Inveruglas car park and the hotel at Tarbert.
  • The introduction of car parking charges at Milarrochy will remove the last signficant free stopping off point along east Loch Lomond between Balmaha and Rowardennan.  James Cassidy in his letter wrote eloquently about the impact of the existing camping byelaws on walkers of the West Highland Way, but day visitors are now being squeezed out.  There is no bus and the creation of an urban clearway reduced the number of potential stopping off points.  The Rowardennan hotel offered free parking on its land along the shore – because it knew this was good for business – but the LLTNPA’s response to this has been to try and extend the clearway to the FCS carpark forcing people to use this.   In this context, charging for cars at Millarochy seems like part of a plan to deter people from visiting east Loch Lomond completely.  Was this what we created National Parks for?


July 12, 2016 Nick Kempe No comments exist






I was interested to see in May that meters had been installed at the carpark in Inveruglas.  I appreciate you are short of money but it seems to me particularly mean to advertise the new wooden structure at Inveruglas, as part of Scotland’s scenic routes, and then charge people for the privilege of stepping out of their cars to take a closer look.    I might not mind so much if it was clear what the money was being used for and litter bins were being installed not just at Inveruglas but at all the stopping points along the A82.    I would like our National Parks though to assert the fundamental value of being able to experience our countryside for free, as a common good, and what better way to demonstrate this than by creating a free campsite at Inveruglas (behind the parking area) from which people could experience the glories of the loch overnight?


The experience of sleeping out is worth more than any hotel.









June 27, 2016 Nick Kempe 2 comments

The National Trust for Scotland, which owns two important properties in our National Parks, Ben Lomond and Mar Lodge, was in the news again last week because of its latest financial crisis  (Herald “NTS faces death by 1000 cuts “).   The script is wearily familiar: the need to re-organise to make ends meet and cut expenditure; modernise to attract new members and increase visitors to properties; and of course a net loss of jobs.   This is the third time this has happened in the last ten years and each time the NTS claims what they are proposing will solve the issues  as Simon Skinner, their current Chief Executive, did last week http://www.nts.org.uk/Charity/Transforming-the-National-Trust-for-Scotland/Overview/


I have my doubts.   When Kate Mavor, the previous Chief Executive, departed in April 2015 after 6 years the Herald carried an interview with her http://www.heraldscotland.com/life_style/homes_interiors_gardens/13211104.What_next_for_the_National_Trust_for_Scotland/ which makes interesting reading 15 months later:


“making the trust pay is exactly what she has done in her six years”

Is it fair to say that the trust was on the brink of ruin? “It was heading that way,” she says. “It was like putting on a huge brake to stop it careering over the edge of the cliff and because we did that, that stopped it happening. It would have gone over the edge.”

So what evidence is there to suggest that another re-organisation is any more likely to solve NTS’ problems than the last one?   I am not sure there is any.   What one can say for certain though is in each previous re-organisation the NTS has lost excellent staff and, inevitably during any re-organisation the whole focus of management is on what jobs they will get in the new structure rather than doing what needs to be done.  You can almost guarantee that this will put back any timetable for the renovation of Derry Lodge by at least two years http://parkswatchscotland.co.uk/2016/06/02/derry-lodge-wild-land/  but then those who promote re-organisation, a very British disease, never consider the adverse consequences, only the alleged benefits.


The real problem is not being discussed openly but was hinted at by Simon Skinner the new Chief Executive in the Herald:  “Mr Skinner has revealed that despite an overall rise in the popularity of Scotland’s tourist attractions, visits to Trust properties have declined by 250,000 in the past decade as many potential customers view it as “castle-owning elitists””.   Now,  I don’t think Simon Skinner is right that its perceptions of the NTS which is actually the biggest issue, its that people are excluded from NTS.   This is partly because as a result of the financial crash and austerity people simply don’t have enough money in their pockets to visit NTS properties.  To become a single member is £48 and the one-off entry fee to see the “state of the art” Culloden visitor centre is £11 for non-members.  Hence, the crash in visitor numbers over the last ten years.


The cost of joining NTS points to the fundamental issue.  NTS is a private membership organisation which was set up by members of Scotland’s elite to act as custodians for much of Scotland’s heritage. On the one hand the consequence of this has been that much of Scotland’s population has never had access to its cultural heritage (and NTS manages far more than just the former homes of the great and the good).  On the other hand, it has meant that the funding of its countryside properties like Ben Lomond and Mar Lodge, which are open to all, is dependent on NTS’ income from membership and legacies and that is not sufficient to keep NTS going.   With a huge backlog in building funding, there is never enough money to invest in its countryside properties including Ben Lomond and Mar Lodge or those such as Glen Coe which should be part of a National Park.    When a specific crisis happens, like the flooding on Deeside in December which caused something like £100k of damage to paths on the Mar Lodge estate, staff are left to run appeals to raise the necessary funds.


One solution would be for NTS to ask its members to pay more.  The problem though is that doing so would probably prompt many members (like myself) to leave and in the past the very rich in Scotland, while very happy to leave large properties to NTS, have not shown much willingness to contribute to revenue costs.  With the rich now siphoning money off to tax havens as a matter of course I cannot see that changing.   The consequence is that NTS as a membership organisation is in constant crisis.


I believe the solution is that the assets that are held by NTS should be treated as national assets and not those of a private organisation.  There is a citizenship argument for this, people should have a right to be able to access the country’s heritage.   This is recognised with our museums and art galleries where admission is normally free.  There is also a tourism argument.  We know that our museums are a major attraction to visitors and that large entry fees are  a deterrent (unless they are for somewhere like Edinburgh castle). Yet NTS continues to think that if only it makes its built properties attractive enough somehow they will pay.  Meanwhile the Scottish Government is ignoring the potential boost that opening up these properties might give to tourism, particularly in rural areas.   Its time that we started to talk about how NTS could become an open and accessible custodian of Scotland’s assets and what government funding might be needed to do this instead of constant attempts to re-structure to make ends meet.


There is a precedent for this within NTS and that is its countryside properties.   Percy Unna, whose gifts enabled NTS to purchase Glencoe, Kintail, Torridon, Goat Fell and Ben Lawers – all prime areas for National Park status – did so on the basis there should be unrestricted access to the public.   So, on the one hand NTS runs properties that are exclusive, on the other hand property that is open to all.  There has always been some tension though between these two sides of NTS, which has manifested itself in the way it has managed its countryside properties.  An example is Ben Lomond in the Loch Lomond and Trossachs National Park.  On the one hand NTS as an organisation did not protest strongly about the camping bye laws on east Loch Lomond (which extended to cover its property at Rowardennan below Ben Lomond) or about the LLTNPA’s proposed permit system.  Both are totally contrary to the Unna principles that there should be unrestricted public access to its properties.  On the other hand NTS staff two years ago offered the Loch Lomond and Trossachs National Park Authority land at Rowardennan for a campsite (an offer which as far as I am aware the LLTNPA has done nothing to progress).


Unfortunately though, while there are and have always have been some very good people working for NTS, the overall balance of power – as hinted at by Simon Skinner in his reference to castle owning elites – is still held by those who think that the private way is the only way of doing things and to whom “social inclusion” is a foreign concept.   I am fearful therefore that the latest round of cuts will inevitably impact adversely on the countryside properties – the proposed distribution of resources between buildings and countryside in the new structure is far from clear – and on Ben Lomond and Mar Lodge in particular.


I believe our two National Park Authorities could play a role in developing alternative ways of managing NTS properties.  Indeed this could be part of their new Partnership Plans, about to be issued for consultation, which will set out what our National Parks propose to do over the next five years.   This needs to start by proper look with NTS about what funds are actually required to manage these properties effectively, including nature conservation/re-wilding,  recreational infrastructure  (footpath maintenance, renovation Derry Lodge,  provision of campsites) and dealing with the impacts of unforeseen events such as the flooding on Deeside this year.   There could then be a national conversation about whether we should treat these properties  as national assets – there is a precedent for this as in 1995 Ben Lomond was designated as a “National Memorial Park” – or whether they should remain entirely in the custodianship of NTS.   My own view is that I don’t believe NTS will ever be able to deliver its aspirations on its own and the current model is broken beyond repair..



June 21, 2016 Nick Kempe No comments exist
Spotted on the headwall of Coire Cas
Spotted on the headwall of Coire Cas – thanks to the reader who sent this

I picked up earlier this winter that there has been a lot of discontent from downhill skiers and boarders about how Natural Retreats has been operating the ski area, with the general perception being they have neglected winter sports in favour of summer visitors.    There is also a lot of concern on Speyside about the quality of the tourist offering and the implications of this for the local economy.  What is really interesting is that people are now openly expressing this.   In the past there has always been a certain tension between conservationists and recreationists, mountaineers and skiers, local people and national organisations and this has allowed Highlands and Islands Enterprise to get away with a series of poor decisions, the latest of which appears to be its lease with Natural Retreats.   I believe the general discontent with Natural Retreats will help turn the spotlight on HIE.    There is now a great opportunity for the various interests to get together and rethink a vision of the ski area and the role it should play within the wider Glenmore corridor.



June 17, 2016 Nick Kempe 17 comments

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


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

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








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


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


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


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

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

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









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

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


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


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


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


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

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



No sign of the alpine bistort among the dwarf cornel







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




















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








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


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


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


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















June 6, 2016 Nick Kempe 2 comments

The Strathie carried an article last week that Natural Retreats, the company that operates “Cairngorm Mountain” on behalf of Highlands and Island Enterprise, has dropped its plans to rebuild the Day Lodge complex by the Coire Cas carpark http://www.strathspey-herald.co.uk/News/Plans-for-futuristic-Cairngorms-Day-Lodge-are-axed-02062016.htm   This would have included new facilities, such as a conference centre.   This is to be welcomed.  It would have been a tourist facility in the wrong place.

Day Lodge 3rd June. The altitude of the
Day Lodge Friday 3rd June 2016, not a sensible location for a conference centre
The funicular was practically empty - its amazing that anyone would take a journey even further into the cloud
Funicular 3rd June.  It was practically empty – why would anyone take a journey even further into the cloud?  As in the Alps, the cloud drops and so do visitors.  The problem at Cairngorm from a tourist viewpoint is the number of days the summit is in cloud.



The decision by Natural Retreats I am sure is partly driven by money.  They have realised, after a winter season, there is no point throwing good money (they had talked about investing £10m in buildings) after bad.   Their focus, in terms of buildings, now appears to be on internal refurbishment of what is there.   While this is to be welcomed its only part of what needs to be done.


The external environment in the ski area continues to be a disgrace for a National Park.

The chairs from the former Coire na Ciste lift have been simply dumped along with other rubbish


Buildings currently in use may be being upgraded but what is being done about the abandoned ones? Restoration?
Buildings currently in use may be being upgraded but what is being done about the abandoned ones?





If the Coire na Ciste building, as the signs indicate, is not safe and cannot be restored it should be removed



There were no fewer than three skips at Coire na Ciste but unfortunately the commercial rubbish that should have been in them wasn’t.





















In Coire Cas there are plenty of signs of a similar lack of care which are unfitting for a National Park.   This is not a good visitor experience, particularly in summer when the  extent of the rubbish and neglect is more obvious.IMG_6116

Old cables straddling the burn – would it really be so difficult to remove these?

Many of the eyesores pre-date Natural Retreats but some are much more recent. Could they just not clear up as they undertake work instead of treating the natural environment as a poorly run building site?


The cloud parted for ten minutes. Expensive machinery is simply left outside to rust. There must be a better way to stop this looking like a building site. What do visitors on the funicular think when they look across to this?   There needs to be a store for machinery but it needs to be big enough and in keeping with the natural environment.  Why not bury it into the hillside?
The concrete plinth and all the industrial waste should be removed and a new place found to store spent fuel (in the red and blue metal containers)

Keeping the ski area in a manner fitting for a National Park – or indeed for any quality tourist facility – should have been part of the HIE lease with Natural Retreats.  I have asked HIE for a copy of the relevant parts of their lease.  If there are conditions about the general state of the environment they need to be enforced.  If not, HIE should pay for the cleanup, after all its the landowner.   The Cairngorm National Park Authority needs to use its powers and influence to get the external environment tidied up as a pre-condition to agreeing anything else.


I believe Natural Retreats’ decision to drop its development proposals provides a great opportunity to re-consider what could be done to improve the Cairngorm ski area  and  make it more financially viable within a wider context of how Cairngorm and Glenmore should be managed.  A draft strategic plan for Cairngorm and Glenmore, which was put out for consultation earlier this year,  treated the ski area in isolation from Glenmore.   This has been a problem ever since Highlands and Islands Enterprise purchased the ski area from the Forestry Commission.  What we now need is some joined up thinking and I would suggest the current model, in which Natural Retreats is expected somehow to make the ski area become a financially viable operation in itself, needs to be rethought.    I will outline a vision for how this might be approached in a post later this week which will focus on the potential of the natural environment at Cairngorm as a means of making the ski area into a sustainable tourist attraction.

June 1, 2016 Nick Kempe 2 comments

Cameron McNeish has some interesting comments to make on National Parks and the political priorities for the new Scottish Government in the latest Walkhighland newsletter http://www.walkhighlands.co.uk/news/political-priorities/0014950/    In it he states he believes the reason the SNP did not commit to more National Parks was lack of cash – or to put it another way because of current UK Government policies of austerity that arise from neo-liberal economic thinking.


Raising more money in taxation is the main alternative to austerity and while the Scottish Parliament can do relatively little to raise taxes at the national level, one thing it could do if there was the political will would be to encourage the introduction of tourist taxes.   A campaign for a tourist tax in Edinburgh is now gaining momentum.  An eloquent case for this was made by Rosemary Goring in the Herald yesterday  http://www.heraldscotland.com/opinion/14525115.Why_it__39_s_time_to_say_Yes_to_a_tourist_tax/  but why not also for the countryside?


Our existing National Parks would be a good place to start.   The issues faced by the Loch Lomond and Trossachs National Park in particular are not dissimilar to Edinburgh – litter, eyesores, congestion  – and as Rosemary Goring says are both practical matters and about aesthetics.  A tourist tax would enable improvements in visitor management such as public toilet provision, litter collection etc.   A quick look at the statistics indicates that between 2009-11 on average foreign visitors spent 2.4m bed nights in the LLTNP.  An average charge of £1 a night bed tax would raise a lot of money from people who otherwise make no direct contribution to the National Parks (the VAT they pay on hotel nights etc goes to the UK Government).


Such money I believe should not be used to replace central Government funding but as additional monies to invest in rural areas.  The best way to ensure this happens is not to add any money raised to the National Park’s or Local Authority budgets but to devolve it to local communities, as on the continent.  In Europe there are many examples of where local communities get to decide where to spend monies raised in their area in a way that benefits both local residents and visitors.  This wold empower local communities against the centralising trends in Government in Scotland.


While such a model could be replicated across rural Scotland the National Parks would be an ideal place to start as they have the infrastructure to support the roll out of such a tax.  There are already some initiatives in our two National Parks which raise money from businesses on a voluntary basis and my suggestion is this should be developed into a tourist tax.  The tax would be on the tourists not the business and the main cost to the business would be in accounting for it, a small price to pay for increased local investment which can only benefit them.    In my view such a tax should also be proportional rather than flat rate, so people staying in expensive hotels pay more than people camping.



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.

May 12, 2016 Nick Kempe 2 comments

David Lintern, the wild land photographer who writes for Walk Highland,  contacted me last week about the Ben Glas hydro scheme, above the Beinglas farm campsite at the head of Loch Lomond.   He has written a heartfelt and poetic piece on his blog http://www.davidlintern.com/blog/  about this, along with photos which show the destruction that is taking place in the Loch Lomond and Trossachs National Park and the beauty that survives.    He has kindly provided me with a  photo to publish here but I would recommend looking at his blog.   This includes photos of the fine hummocky ridge of Ben Glas that leads, after a fair amount of up and down,  to the summit of Beinn Chabhair and the Lochan of that name.

Photo Credit David Lintern
Photo Credit David Lintern





I have walked or tried to run the Ben Glas/Ben Chabhair ridge several times,  sometimes starting up the path by Eagle Falls, and to my mind it is one of the best walks up a Munro in the National Park.  Once above the Eagle Falls, you were suddenly in an area that felt wild, away from it all – marred only for a short way by the tracks of All Terrain Vehicles that had come up the track to the North.   The Lochan a Chaisteil, nestled on the ridge, like a fortress – hence its name I guess – was one of the finest places to picnic, camp, swim or simply loiter in the whole National Park, but now overlooks the  new track that has been extended up the Ben Glas Burn.


I am certain the National Park’s response to David would be that this is the last of the four Glen Falloch hydro schemes, work is still in progress and the damage will be restored and that to judge this scheme because of photos taken at a particular point of time is unfair.


I will come back to the question of how far such damage can be restored in a post in the next few days on the other Glen Falloch schemes.  I had however been on Ben Vorlich recently, seen the long scar of the new track above the Eagle Falls – the light was poor but the scar stands out for miles – and had resolved to find out more.   David’s contact prompted me to do so.

The new Ben Glas hydro access track, the top of the Eagle Falls visible in bottom left hand corner, seen from Ben Vorlich


The Ben Glas hydro scheme is one of four in Glen Falloch  which were approved back in 2010 by the Scottish Government 2009_0249_ECN-BEN_GLAS_DECISION_LETTER_AND_CONSENT-39389. 

Having looked at all four schemes, I believe Ben Glas is the one that is objectionable in principle, having an impact on the landscape that can never been compensated.    While its too late now, this hydro scheme should have never been allowed in a National Park:

    • Not far above the Eagle Falls you used to pass over the lip of the glen, away from the noise of the traffic into another world.   Hard going, even trying to follow the baggers path to Beinn Chabhair, and beautiful as David’s photos show.   Untamed moor and bog, rather than grassland dominated by sheep.   Prime wild land, though not marked as core wild land on the Park’s wild land map because it is not remote enough.  Remoteness isn’t everything.
    • The summit of Ben Glas itself, Beinn Chabhair and Parlan Hill are all however designated as wild land areas.  In walking terms though, what has been constructed is  a new motorway extension to Beinn Chabhair which will be permanent, however well restored.   The old track from the north, which has also been extensively re-engineered, ended close to the Ben Glas burn.  It now heads up the burn.  According to the Park’s wild land map this was a buffer zone, intended to protect the remoteness of the core.  That buffer has now been deeply punctured.
    • The line of the Ben Glas burn, which supplies the hydro scheme, marks the boundary of the National Scenic Area.  The burn itself and the Eagle Falls are, for a reason unknown to me,  just outside it.  Not that this would have made a difference in planning terms because the Park has no policy to ban renewable developments in National Scenic Areas.   Their Supplementary Planning Guidance-Renewables-final guidance approved in 2013 is all about factors to consider, no absolute protection for any designated land, whether wild land, national scenic area or Site of Special Scientific Interest.   Its guidance about how to do renewable development, not where to do it.
    • Ironically, the land up the Ben Glas burn  is not dissimilar in character to that on the north side of Ben Lomond which is fully in the National Scenic Area and where the Craig Royston hydro scheme was proposed.   That proposal led to a public outcry, a 200,000 signature petition and the creation of the Friends of Loch Lomond – but not even they objected to this scheme.  It seems to have passed beneath the public radar.
    • The line of pylons that cross the hill to the south of the Ben Glas burn spoil the view but they are in the Loch Lomond National Scenic Area and could, one day have been removed, restoring the blemish – a suitable aspiration for a National Park.   Not a reason, I believe, to justify more development, though the proximity of the national grid was what made Glen Falloch so attractive to the developers of renewables.
    • Wild land  aside, the most compelling reason of all why this scheme should never have been allowed is that the pipeline, running back down into Glen Falloch, will divert the water which currently flows down the Ben Glas burn away from the Eagle Falls.  Yes, it will destroy the waterfall.   In tourism terms, this is madness – waterfalls since Wordsworth have been one of the biggest draws to the countryside – but then the LLTNPA also approved the Cononish goldmine which basically trashes the tourist potential of that other major waterfall in the Park, the Eas Anie.


Ironically, while the Scottish Government and LLTNPA are  busy promoting the A82 as a national scenic route, investing money in the sculpture at Inveruglas to encourage people to get out of their cars, they have never invested anything to encourage people to walk to the Eagle Falls, a natural attraction.   Too late now, I suspect, and one less thing for walkers on the West Highland Way to enjoy.


A further irony.   David Lintern pointed out to me that down the loch at Balmaha, the Park has been celebrating the life of John Muir at the National Park visitor centre.   The same John Muir who fought, unsuccessfully, against the Hetchy Tetchy hydro scheme.  I am pretty sure I know what he would have said about Ben Glas.   I suspect the LLTNPA, if they thought about it, know too what John Muir would said but that will not stop them agreeing schemes such as Ben Glas.



May 6, 2016 Nick Kempe No comments exist

In London, what appears to be a  very successful campaign  is developing to turn it into the world’s first National Park city.  The proposal won the support of the Labour, Tory, Liberal Democrat and Green candidates for the London Mayor election.  Its proponents, from health experts to nature conservationists, architects to geographers, are now trying to win support from local councillors.   According to a poll in the London Evening Standard something like 90% of Londoner’s agree with the idea.


As the Greater London National Park City admits, the proposal is not for a National Park in the traditional sense.   It is not about the countryside, does not fit the criteria of the National Park legislation in England (see statement from National Parks England) and does not fit any of the international criteria for protected areas.   The City of London will still dominate.  It is though about further greening of the city.  The term “National Park” is being used because it has resonance, the power to convey a message.


Thereby, I believe,  lies a danger.  That the whole concept of what National Parks should be about is diluted, perhaps even polluted.   The risk is the term “National Park” no longer represents ideas about putting the natural environment first but rather becomes associated with attempts to fit nature better around human development.    To put it crudely, if the City of London merits the term National Park, what is to prevent us from building a city in the middle of the Cairngorms or over the top of Loch Lomond if the need arises?


The success of the campaign though does tell us something about the importance of nature to people.      People want to connect to nature but, because London is so large and difficult to escape from, the only option for many people is to green their our own backyard or treasurer the pockets of wildness among the skyscrapers.    People like David Lindo, who writes for the RSPB magazine about urban birdwatching, illustrate the point well and the London City National Park campaign pages have some fantastic photos of London wildlife.


Cities in Scotland, and indeed the rest of England, also have some wonderful wildlife – the discovery of water voles in the East End of Glasgow comes to mind – but because they are so much smaller, the  countryside is much easier to access.    If you want to connect to nature, it is much easier – if you have the income – to escape the city.  There are of course plenty of green initiatives in Scottish cities, people care just as much as they do in London, but I think our geography reduces the political pressure to green our urban environment.   The middle classes can and do get out – and its often to our two National Parks – areas where the natural environment should come first.


While our geography should make it easier to keep the concept of National Parks separate from Greening the City, I believe we need  to consider the relationship between our cities, where most people live, and our National Parks.


To give one example, if you agree with our National Park’s current statutory objectives to promote recreational enjoyment and understanding, their connectedness and accessibility  to the urban population should be one benchmark of their success.   By this measure, at present our National Parks are not doing well, aside from the arterial routes along the A9 and A82 and their railway lines, with large swathes of the inhabited off limits for those who have no car.

Try getting to:

    • Ben Lomond from Glasgow – our aspiration should be that everyone from the Glasgow conurbation should experience the view from Ben Lomond once in their lifetime but the only way to get to Rowardennan by public transport is by expensive private waterbus in the summer months
    • Braemar from the south – Balmoral is, for better or worse, one of our most famous tourist attractions but  even as a tourist, after viewing Holyrood palace, you cannot jump on a bus to Deeside but have to go the long way round to Aberdeen.  Blairgowrie to Braemar is 45 minutes or so by car, 5 hours and 30 minutes by bus.
Lochnagar, an iconic mountain like Ben Lomond which is very hard to access without a car
Lochnagar, an iconic mountain which, like Ben Lomond, is very hard to access without a car

There are many other examples, particularly of dead-end roads that provide the main means of access to some of the core areas of our National Parks.   This is a challenge if you are a hillwalker or mountaineer with a green conscience but its also an issue, to use the current political terminology,  about social inclusion, equality of access and social justice.   Its another very good reason for the new Scottish Parliament to review our National Parks.











April 3, 2016 Nick Kempe No comments exist

There was more press coverage last week about the reduction in cycle storage capacity on the West Highland Line http://www.heraldscotland.com/news/14388363.Campaigners_warn_that_train_refurbishments_will_slash_space_for_bikes/   

On Friday I received a response to my letter to Gordon Watson about whether the Park had made any representations about the impact this would have on tourism in the Park.  I covered the potential impact on the National Park in a previous post http://parkswatchscotland.co.uk/2016/03/18/public-transport-national-parks-1/     As is usual, the reply was in the form of an FOI response: the answer appears to be that the Park has made no attempt to influence Transport Scotland or the Government on this issue FOI 2016-011 Response


I hope that tourism and cycling interests will now put pressure on the Park to speak out.  While there is an unspoken rule between public authorities that they do not criticise each other in public, Transport Scotland is listed as one the Park’s key partners in the LLTNP Partnership Plan 2012-17. You might have thought therefore that Transport Scotland would have consulted the Park about the reduction in cycling capacity on the West Highland Line and – assuming they failed to do this – the Park would have made representations when the news became public.


You might also have thought that Transport Scotland was signed up to the transport objectives set out in the Partnership Plan and the Park would be deeply concerned by the proposals to reduce cycling storage on trains which can only undermine that plan.   Among the statements in the plan are the following:

  • “There is great potential for improvements to scenic routes, viewpoints and public transport” – but not apparently if you want to put your bike on a train to Tarbert and take the cycle route back to Glasgow
  • “There is a lack of value attached to maintaining existing infrastructure and assets to a high standard to support tourism”  –  as now is further evidenced by the proposal to reduce cycle storage capacity on trains
  • “Creating, co-ordinating and promoting a wider range of well integrated transport options which will appeal to visitors…………….”  but not apparently if this is about increasing opportunities to take your bike on the train

Partnership Plan









The statement that “linking public transport and recreation and tourism is crucial” is spot-on but if those words are to mean anything, the Park needs to speak out about changes to trains which will undermine this and make the links far worse for cyclists.   Transport Scotland, meantime, need to start acting as a partner to the plan instead of unilaterally.   Bizarrely, they are not listed as a relevant organisation in VE (Visitor Experience) 11 on sustainable transport.   Perhaps the new Environment Minister, who chairs the annual reviews of the Park’s Parternship Plan, will knock some heads together but I suspect it will need more campaigning to achieve this.

March 27, 2016 Nick Kempe 4 comments

On Friday I took advantage of the only good day forecast for the holiday weekend to visit Loch Chon (dog loch) before going for a walk over Beinn a Choin (Ben of the dogs).  Most of the road between Aberfoyle and Inversnaid, covering Loch Ard, Loch Chon and Loch Arklet is part of the proposed Trossachs West camping management zone and is owned by Forestry Commission Scotland.   Loch Chon is the one place in the National Park where the LLTNPA has announced plans for a new campsite since the Your Park consultation and I wanted to take a closer look.


The proposed Trossachs West camping management zone is hard to access except by car.  There is no bus between Aberfoyle and Inversnaid and its a long drive from Glasgow.   Even on a sunny holiday Friday there was very little traffic which reminded me how little visited this area is.   Driving along the shore of Loch Ard, where the road hugs the shore, there are very few places where is physically possible.


Most of the Loch Ard shoreline looks like this
Most of the Loch Ard shoreline looks like this
The flat headland opposite Ledard House, at the start of the southern path to Ben Venue
The flat headland opposite Ledard House, on the shores of Loch Ard,. at the start of the southern path to Ben Venue









When I got home I checked the Park’s Ranger Patrol records, which I obtained through a Freedom of Information request.    In 2015 tents were only recorded on four occasions along Loch Ard in the whole of 2015, twice on the Kinlochard Community Field.    So not only is the terrain alongside Loch Ard mostly unsuitable for camping, as anyone can see, but very few people camp there anyway.


Ranger Patrol records show a similar position for Loch Arklet, above Inversnaid, where tents were recorded on only a handful of occasions in 2015.


The patrol records show Loch Chon is easily the most popular of the three lochs in the proposed west Trossachs campingse lochs for camping.   This is hardly surprising as it has fewer houses and more flat areas than Loch Ard and is far less bleak than Loch Arklet.  We saw two groups “camping” there.

Camping at south end of Loch Chon
Camping at south end of Loch Chon









We went over and spoke to the first, a group of people from Glasgow who had originated from Hongkong and had come out for a day for a picnic.  They had a large lump of meat they had just placed on a spit over an open fire and it looked as though they were planning for a great feast in the outdoors while the children played.  They told me they had been here several times before. They had  not heard that the proposed byelaws would make it an offence for them to light a fire or erect a tent without permission from the Park and the response from one, that they would take to the hills, met with laughter.  I think it might have tickled Rob Roy too.


There was evidence in the area of some of the things the Park says justify banning camping.

Chopped tree south Loch Chon
Chopped tree south Loch Chon
Remains of fire Loch Chon
Remains of fire Loch Chon
Tent blown onto island Loch Chon
Tent blown onto island Loch Chon










I guess some people might see the chopping of the tree as a justification for banning access completely.    I think the Park need to think about why people might chop a tree down.  It might be mindless vandalism, a criminal offence already, and something that won’t stop just because there is a campsite in the vicinity.  Or it might have been because someone wanted to light a fire (although there was no sign of the tree having been burned).

FCS felling Loch Chon
FCS felling Loch Chon


If the latter there is an easy solution.  Transport some of the trimmings from the tree felling on the north side of the Loch to the areas where people camp.  In other parts of the Park landowners have sold wood for fires to people fishing.   And, if FCS is concerned about fires, put in a few barbecue pits.  Problem  more or less solved.



Not many people camp at Loch Chon though, so there is not that much pressure.   The maximum number of tents recorded in 2015, from six different sites spread over approximately 5 kms , was 22 and on only two other days were more than 10 tents recorded.  So why did the Park, in its news release welcoming the byelaws http://www.thisisyourpark.org.uk/approval/, announce that it was proposing to create a 30 place campsite at Loch Chon with the Forestry Commission?     I have asked the Park for the basis of their decision through FOI, but they have so far refused, claiming an exemption on the grounds that it is commercially confidential.   The answer I believe is that having claimed throughout the Your Park consultation that it aimed to create 300 new camping places the Park had to announce something to save face.  Loch Chon was the only proposal for a campsite it had on the table and to make it sound good the Park  decided to say 30 places would be created.  No matter that there is no demand for anything like this number or that the west Trossachs camping management zone must be the lowest priority for new campsites in the National Park.


What is even more shocking though is that the Loch Chon campsite will consume ALL the resources the Park has available for new campsites next year, £245k out of £505k in the 2016/17 budget approved by the LLTNPA Board in March Agenda Item 10 DRAFT – Appendix 1 Draft Budget 2016-17  (the rest of the budget is to be spent on things like signage).  This contradicts the statement in the Park’s Press release that “Similar sites will be created across the four management zones”.  How, if there is no money allocated?


According to the figures for 2015/16 which were included in the Draft Budget for comparison purposes,  the Loch Chon campsite will have already consumed £100k by 31st March.  There was no sign of any works having started on the 25th March but maybe the Park has purchased some toilets which are now ready to install?.  Given that you can buy a block of composting toilets with disabled access for under £10k that still leaves a lot of money to be accounted for.  In a time when public resources are being so savagely cut, it is completely incomprehensible how the Park Authority has decided to spend £345k on developing one camping facility at Loch Chon on ground owned by another public authority,  Forestry Commission Scotland.   The money could be spent in far better ways and in far more camping facilities.



The Park’s own data for the proposed west Trossachs Camping Management zone, which is backed up with what I have observed, contradicts its Chief Executive’s claim that the Park is being swamped by campers.  It also demonstrates that the Environment Minister’s claim that the  camping byelaws cover “four hot spot” areas where controls are needed because of a combination of a high volume of campers with environmental damage is complete nonsense Govt Press release


So, why have camping byelaws been proposed for the lochs between Aberfoyle and Inversnaid?


The answer I believe lies in the fact that almost all this land in the west Trossachs Camping Zone is owned by Forestry Commission Scotland and they wish to remove roadside camping from access rights across Scotland http://www.robedwards.com/2015/11/fury-over-proposal-to-ban-camping-by-roads.html.    I will post more evidence about this in due course but its striking that Loch Arklet was not included in the original area camping management zone but only added after the Your Park consultation.   The only explanation I can see for this –  the Park Ranger patrol records contain no evidence of any significant use let alone problems – is that FCS asked for it to be included.   It appears that LLTNPA is so in thrall to FCS staff that they did what they bid,  including paying for a campsite, no doubt to FCS specifications,  on FCS  land.


The FCS have I think though shot themselves in the foot.   At present they are trying to promote the Great Trossachs Trail, part of which runs along the old military road along Loch Arklet. IMG_5842 I ran along a section of this on Friday, its a great path (and all credit to FCS for the work that went into it) but is sadly underused.   It should be promoted for backpacking both  as part of the Great Trossachs Trail to Callander and following the path network by Loch Chon to Aberfoyle.  Some campsites along the way would help  – and Loch Chon is a good place for one – but backpackers need the freedom to be able to stop as needed, a freedom that is available under access rights but which FCS and the Park wish to remove.


What I would like to happen is that FCS staff drop their blinkered opposition to camping near roads, that the LLTNPA  spends its limited resources far more wisely and the Minister for the Environment wakes up and admits she has been presented with duff evidence and an even duffer plan.