Tag: visitor management

Thanks to the reader who submitted this to Parkswatch

The chaos at Luss (see here) on the first weekend in May, was experienced at several other visitor hotspots in the Loch Lomond and Trossachs National Park, but most notably and predictably at Balmaha.  The LLTNPA has an opportunity to reflect on what happened when its Planning Committee considers draft Supplementary Planning Guidance (SPG) for Buchanan South  (see here) at its meeting today.  The SPG is also very relevant to the controversial proposed housing development in the Balmaha Plantation (see here).   This post considers whether the new SPG will help address the issues at Balmaha in a way fitting for a National Park.

 

There are strict rules on what can be included in Supplementary Planning Guidance, which can only expand on, not change Development Plans.

What the LLTNPA Development Plan, approved by the Scottish Government earlier this year,  proposed for Balmaha (see above)  was however extremely vague.   It allowed considerable scope therefore for the Supplementary Planning Guidance to draw on the Park’s policies, and explain how these would be applied to the area.

SPG map

In the event the SPG only covers three of the policies set out in the Development Plan, Housing, Economic Development and Visitor Experience.   The reason for this is not explained but the SPG  does not cover over policy areas which are very relevant to Balmaha such as Transport and Natural Environment, the village being bordered  by the Loch Lomond National Nature Reserve and the Highland Boundary fault.

 

Visitors and visitor management at Balmaha

 

While Balmaha is not readily accessible, it is the easiest place to get to on the east shores of Loch Lomond and, with Conic Hill providing one of the best viewpoints in Scotland for a hill of its size and with the West Highland Way providing a walk along the loch shore, its not surprising the village is a popular tourist destination.    With a poor bus service most people arrive by car.  With just a hundred odd places in the carpark, and the road north of the village designated a clearway, its hardly surprising that cars overwhelm the village on sunny weekends and bank holidays.

The Park has recognised this in its new draft National Park Partnership Plan (above), which rightly states the “the road network can become very busy at peak times” but then in usual fashion partly blames this on visitors “problems can be exacerbated by illegal and irresponsible parking of vehicles”.  Actually, this “problem”  is what the LLTNPA was set up to address and its challenge I would suggest (its not easy) is the provision of infrastructure to support visitors, including alternative means of transport to get to popular places like Balmaha.

 

The Supplementary Planning Guidance, disappointingly, says almost nothing about this.

SPG diagram

 

There is a reference to improving water transport (light blue arrow) and the Sustrans cycle path (dark blue arrow) but nothing on how the issue of too many cars for too few car parking places with no alternatives will be addressed.  For once I agree with Gordon Watson, the LLTNPA Chief Executive, who stated to the Stirling Observer that “additional overflow” car parking places are  required.  Such provision used to be available.  A farmer opened up a field to provide for parking but was given no support to manage this – people set up tents to stay the weekend – so stopped doing so.   This is the obvious solution, one that is used successfully in England’s National Parks, and one that should be revived, but there is no mention of this in the SPG.   I suspect this is because it would require resources from the LLTNPA (such as its Rangers helping to manage traffic rather than spending time chasing away innocent campers).

 

The lack of join up with the East Loch Lomond Visitor Management Plan 2014-19 – which the SPG interestingly refers to as “draft” even though it is published – is glaring.  That plan recognised the pattern of visitor pressure and committed to:

 

Establish a multi-agency peak period management regime that puts in place procedures for staff across organisations
 
 That commitment appears to have been abandoned.  Why?  And who decided this?
 
Meantime, the transport policies in the approved National Park Development Plan would appear not to be worth the paper they are written on:
 
 “Land will be safeguarded for, and support will be given to, the transport infrastructure proposals identified within Town or Village proposals maps”
 
 and:
 
 “Modal change from private car to more sustainable transport modes within settlements including the provision of integrated new or improved transport infrastructure,”

The SPG contains no hint of this vision, or of the aspiration of  past plans, yet alone how land might be used to achieve this.   Another opportunity to make things happen, make things better, lost.   It should not be difficult.  On the continent many places, not just National Parks, use school transport at weekends and holidays to provide public transport to rural areas for visitors.   Balmaha and east Loch Lomond is an obvious place to start given the road is not a through route.

 

The SPG contains almost nothing outdoor recreation in its broadest sense, the reason most people visit Balmaha in the first place – what the Park calls “Visitor Experience”.    This is illustrated by the Balmaha strategic principles diagram  (above) which includes nothing about how, once people have parked their cars in the car park, they leave the village.   The green lines on the diagram indicate views to the Loch should be maintained but nothing about how people might access the loch shore and the National Nature Reserve, which is supposed to be a place people can enjoy nature.  There is no obvious way to access this at present.  The thinking of the LLTNPA appears to have gone backwards since the proposal, several years ago, to create a path along the loch shore south of the village (abandoned I understand because the ground is very boggy).   To the north, the West Highland Way to Rowardennan offers brilliant walking but with no way to get back unless you are prepared to retrace your steps or go the full way and try your luck with a waterbus.    A hop on hop off shuttle bus would open up the West Highland Way for far more people to enjoy.

 

There is also nothing about the lack of camping provision, the major issue being backpackers along the West Highland Way have nowhere to stop off at the natural stopping off point of Balmaha because of the camping management zone.   This is the National Park’s welcome to walkers who come from all over the world.  The LLTNPA in response to comments on the draft Development Plan saying a campsite was needed at Balmaha, indicated that there was nothing in the Plan to prevent this:  the failure of the LLTNPA even to mention the need for a campsite in the SPG tells you I think that the LLTNPA has no intention ever of trying to make this happen.  There is an obvious place for this:  the former playing field, marked development site, within the pink circle in the diagram above and adjacent to where the West Highland Way enters the car park.

 

Developments in Balmaha

 

The focus of the Supplementary Guidance is on the LLTNPA’s Housing and Economic Development Policies which I believe confuses rather than clarifies matters:

 

New development within Balmaha should reinforce its existing development pattern and be of appropriate (generally small) scale.

 

What the LLTNPA means by “small-scale” however is not the same as what most people would understand by the term:

 

All new development should be of appropriate scale. It will be site dependant but generaIly groupings of 3-8 dwellings should be the most easy to set comfortably in more open landscape. Small groupings should be based on existing development patterns where one (generally larger) property faces onto the road, with other smaller properties behind. If there is a need for larger development (i.e. more than 5 houses) it should be divided by robust landscaping and areas of open land to reduce the impact of development

 

The Strategic Principles diagram above includes some grey lines on either side of the road (the dark blue line with arrows), increasing in density as they approach the centre of the village.    This looks like the LLTNPA is proposing to allow ribbon development either side of the road even though this was not part of the Development Plan.   This would explain why, unlike other settlements, the LLTNPA has not demarcated the village boundary.   It also could explain why the people who I understand are the two main landowners, the Duke of Montrose and Sandy Fraser of the Oak Tree Inn, responded so positively to the draft Supplementary Guidance (see here) about opportunities for development.

 

The clarifications in the Supplementary Planning Guidance that the LLTNPA will  allow more new build at Balmaha raises questions about why the Balmaha Plantation site (which is still waiting to go to Committee) ever needed to be earmarked for affordable housing.   LLTNPA’s recently approved policy on Housing in small rural developments is that  “Development on these sites should provide for 100% affordable housing”, so by allowing more housing at Balmaha, the need for affordable homes could be met without destroying what appears to be an area of ancient woodland.   Except that, in Balmaha the SPG now qualifies that Park Policy: “Some open market housing will be supported where this is demonstrated as necessary to help fund the provision of affordable housing on site.”    I expect the landowners will claim they can afford to construct very little affordable housing and that therefore the Balmaha Plantation site is still needed while very little affordable housing will be provided along the ribbon development.   The effect of the SPG therefore will be to reinforce the current trends towards social segregation of people and housing in Balmaha.

 

Setting aside the question of how else to provide affordable housing, the Balmaha plantation proposal still appears to be a glaring anomaly within the context of the Development Plan and SPG.    The SPG fails to refer to the LLTNPA’s Natural Environment policies – a chance to explain the claim, made by some, that the plantation is not really an Ancient Woodland site.  It also fails to explain how the size and density of the Balmaha Plantation proposal fits with the definition of the type of small scale development the SPG wishes to see in the area, 16 rather than 3-8 units, with density decreasing as you move away from the village centre.

 

What needs to happen

 

The LLTNPA needs to start joining up its various plans and to start implementing actions it proposed to do in the past but has since, without explanation, abandoned.

 

The LLTNPA needs to revive the east Loch Lomond Visitor Management Group (which did not meet last year) but make this both representative  (recreational organisations were not included) and accountable (it is not clear who signed off or agreed the last plan and the LLTNPA failed to provide any resources to make it happen).

 

The LLTNPA needs to start implementing its development plan policies on a consistent basis, rather than changing them so soon after they were adopted.   If the LLTNPA won’t abide by its own planning policies, there is no reason why anyone else should.

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.

Caravan on South Loch Earn Road 14th April 2017

One of primary justifications the Loch Lomond and Trossachs National Park Authority made for camping byelaws was that they were needed to address the problem of encampments on laybys by caravans and motorhomes over the summer.

Extracts from Your Park consultation on the camping byelaws

In their news release (see here) about the approval of the camping byelaws the LLTNPA included the following statement:

 

New seasonal camping management byelaws (which come into force in March 2017 and will apply 1 March – 30 September each year) to regulate camping, tackle antisocial behaviour and make it an offence to cause damage to the Park’s natural environment. They will also prevent inappropriate use of public laybys as encampments by caravans and campervans; (my emphasis).

 

This point was repeated, word for word, in the news release that followed the LLTNPA Board’s approval of their so-called  camping “strategy” last October which included provision for just 20 campervan permits.

 

Its fair to conclude from this that part of the purpose of the camping byelaws was to prevent campervans and caravans using laybys in the four camping management zones.   Now, a caravan, like a campervan, is classified as a type of vehicle under the Roads Traffic Act and, as I have previously pointed out on parkswatch, since its not an offence to sleep overnight in a vehicle on a road within the camping management zones,  the camping byelaws are in effect unenforceable as far as campervans are concerned (see here).   I had not considered the case of caravans but exactly the same considerations should apply.

 

I was surprised to discover therefore on my trip round Loch Earn on 15th April that the LLTNPA appeared to be treating caravans completely different to campervans and in effect had told their staff to tell people with caravans that the byelaws do not apply to them.

 

The evidence from Loch Earn

 

When I met up with fellow campaigner Dave Morris on the south Loch Earn Rd on 14th April (see here) there was a caravan parked on the verge of the road (top photo) and, after spending a couple of happy minutes pushing one of their children who was swinging from a rope (cut off far right of photo!), we went over and asked the occupants if they knew about the camping byelaws and had had any hassle from Park Rangers.    They told us that they had been coming to Ardvorlich for years but we were slightly surprised when they said that estate staff had informed  them the byelaws did not affect them.  Both Dave and I thought this must have been some local arrangement due to the good offices of the Ardvorlich estate.

One of the laybys with caravans on North Loch Earn

We only realised what was going on when, after visiting a number of the laybys on the north side of Loch Earn which had caravans parked in them, we spoke to a family in the last caravan in permit zone D who were about to have their tea.

After telling us that the camping byelaws did not apply to caravans they also told us that the campervan parked next door to them had to get a permit, while their son, who was camping in a tent by the loch shore, had also been forced to buy a permit.  They seemed as bemused as us by how the LLTNPA was applying the byelaws but very happy with their good fortune..

 

Last week Nick Halls, during a visit to the Loch Chon campsite,  spoke to a Ranger who said to him “that the people who park their caravans in lay-bys and then occupy the space throughout the summer, could not be required to pay for a permit because the management zones can not include stopping on a highway”.    Official confirmation of my view, that the byelaws are unenforceable against people staying overnight in vehicles.   So why then are the LLTNPA still insisting that campervans apply for permits when they accept the same byelaws cannot be used control caravans?

 

Such discrimination is obviously wrong – though the absence of  moral scruples on the part of the LLTNPA will not surprise regular readers –  but the reason this farce is continuing is that if the LLTNPA were to admit publicly that the byelaws could not be used to control either caravans or campervans, they would lose all credibility not just with the public but with Scottish Ministers.

 

Misinformation, incompetence and squandering of public resources

 

Judging by how the byelaws are being applied on North Loch Earn, it will not be long before they unravel completely.

 

The first layby is described as Permit Zone A and is for tents only (see tents  symbol left).  Why the Park has made no provisions for campervans, when it now appears to be allowing caravans to stay here for free (we saw one) is something that Gordon Watson, the Park Chief Executive, should be asked to explain before a Committee of the Scottish Parliament.

 

The second layby, Zone B, is a permit zone for campervans (photo right).   We came across a man standing outside a campervan who had flown across from Germany, hired the vehicle, arrived at the layby, seen the sign and had tried to book online only to find no permits were available.  The layby was almost empty and he did not know what to do.  What type of tourist message is this?  We told him that in our view as the layby forms part of the road network he could stay there overnight – but trying to explain rights to a foreigner, even when their English is excellent is not that easy and we left him wondering what to do.  If he had driven into either the layby before (Zone A) or after (Zone C) (photo below) he would have never known he needed a permit because the signs say nothing about campervans.  It would be hard to invent such a shambles or a more disastrous message for tourism in Scotland.

 

What is not clear at present is what action the Park is taking against campervanners who try to spend the night on roads outwith the two official permit areas on Loch Earn, zones B and D, or what would happen if a campervan staying in a permit zone, insisted that like the caravans they should be able to stay there without a permit for free.

 

The wording on the signage, which cost the LLTNPA according to its figures £100,000, is wrong.  Its not true that people in campervans require a permit if they wish to sleep overnight in a vehicle in a permit area in the camping management zone.  There is no need to take my word for this.  If caravans, are exempt from the byelaws, because they are vehicles (so long as they are on a road) so should campervans, whether they stop off within a permit zone or outside it.   Any campervan owner who has paid for a permit should try asking the LLTPNA for their money back.

 

The bigger problem though is the information on the National Park website for campervans (see here).  The introductory part of the information sheet has not been changed DESPITE Rangers being told the byelaws cannot be applied to caravans:

 

On 1st March 2017 new byelaws are being introduced to manage the environmental impact of camping on some of the busiest lochshores in the National Park. These byelaws will affect those wanting to stay on and around some lochshores during the summer season in the National Park, whether they are in a tent, motorhome, campervan or caravan.

 

The Q and A information goes on to say:

 

Some of these permit areas allow for motorhomes and campervans to stop off overnight in the Camping Management Zones with a motorhome permit.

 

The clear implication is you can only stop off in a campervan in a permit area – this is wrong and totally hyprocritical of the LLTNPA who are not applying this to caravans. The LLTNPA is clearly trying to direct campervans to formal campsites and permit areas:

 

  1. Where can I go in Camping Management Zones with a motorhome or campervan?

Certain sites within the Camping Management Zones are well suited to providing places for visitors in motorhomes to stop overnight. There are both campsite locations and permit areas within the Trossachs North and West Loch Lomond Camping Management Zones, with suitable off-road locations to accommodate motorhomes. (See map below.)

There are plenty of places within the National Park to stop and rest on your journey.  These are unaffected by the new camping byelaws.

 

Only the last sentence hints at the truth – note it uses the words “you can stop and rest”, though this includes sleeping overnight, because if it explained where the plenty of places were that you could sleep overnight in a campervan, no-one would book a permit.

 

So what is the explanation for this farce?

 

It appears the LLTNPA senior management they failed to consider the implications of people being allowed to sleep in vehicles overnight – a basic safety requirement – and thought they could still ban caravans and campervans.    However, at a late stage, perhaps even after the byelaws commenced – and after these issues were raised on parkswatch?   – the LLTNPA appear to have decided that they could not apply the byelaws to caravans, hence the instruction to staff.  The LLTNPA have consistently refused to provide any information about enforcement about the byelaws, saying to do so would prejudice their operation.  That is clearly nonsense and the LLTNPA now needs to explain publicly why it has abandoned trying to enforce the byelaws against caravans but is still suggesting to campervans that they need to apply for permits like campers.

 

My fear though is that the LLTNPA is  desperately trying to retrieve the ban on caravans and campervans by getting Transport Scotland to ban vehicles from stopping off overnight in laybys on trunk roads and possibly by turning all the main roads in the camping management zones into clearways.    The only way Transport Scotland could do this however is if they could prove that overnight stops were creating safety issues while any new clearways would, as on east Loch Lomond, also impact on the ability of day visitors to stop off.    Transport Scotland should resist any pressure from the LLTNPA – its not their job to sort out the shambles the LLTNPA has created.

 

The LLTNPA also needs to apologise to local communities – NOW!

 

The main reason why so many community councils supported the byelaws is they were told by the LLTNPA that these were necessary to stop caravans being parked for the whole summer in laybys: the worst area for this was the north Loch Earn Rd.   Here are some examples:

 

Response 399) BLS Community Council.  “there seems to be a misconception, amongst a minority of visitors, that they can bring a caravan to the lochside and leave it parked up for the whole ‘fishing season’.  This ruins the opportunity for other genuine visitors………”

Response 460) East Strathearn Community Council “We absolutely support any measures that will discourage any semi-permanent occupation of our loch shores”.

Response 394) Crieff Community Council  “we are aware of the problems and difficulties caused at St Fillans and the adjacent area of Loch Earn by rogue campers and caravaners, anti-social behaviour and rowdyism, and drink related problems and litter” and “ask if the proposed changes will tackle the particular and regular problems of caravans being left in lay-bys and authorised parking places for weeks at a time”.

395) St Fillan’s Community Council.  Referred to a meeting August 2014 90 people re anti-social behaviour, litter and obstruction of lay-bys:   “something needed to be done to address the problems”   “With this in mind the Community Council………………………..supports the proposals of the National Park”.

 

A number of us told the LLTNPA at the time that byelaws were not needed to address encampment by caravans because this was covered by Section 61 of the Criminal Justice and Public Order Act 1994.   Guess what signs appear at the start of each layby on north Loch Earn?

 

Note the absence of LLTNPA livery and that the signs, while claiming to be a joint initiative, were clearly put up by Drummond Estates

So when it the LLTNPA going to come clean on this with local communities and admit it was wrong?

 

As those of us who were involved in negotiating access rights have always said, the camping byelaws were never necessary as there are alternative solutions to all the problems they claim to address.   What we could never have predicted is the resources  that a NIMBY National Park Authority would devote  to conning local people and the Minister that byelaws were the answer to problems or the resources that they are now wasting on trying to enforce the unenforceable.   The LLTNPA should stop trying to enforce the byelaws now, before the situation unravels further, and instead invest resources where they are needed such as public toilets, litter bins and litter collection.

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

 

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

 

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

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

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

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

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

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

 

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

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

 

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

 

What needs to be done

 

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

 

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

Tents at the St Fillans end of the Loch Earn south camping permit zone – much of the camping is on shingle beaches.

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

 

 

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

Loch Earn Leisure Park

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

 

 

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

 

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

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

The enforcement of camping permits

 

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

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

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

 

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

 

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

 

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

 

 

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

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

The impact of flytipping was greater than anything left by campers

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

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

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

 

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

 

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

 

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

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

 

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

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

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

 

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

 

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

 

The real failure in enforcement

 

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

 

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

The implications of the permit zone for access rights

At the end of our walk, both Dave Morris and I agreed, that really the introduction of the permit zone on Loch Earn has so far, changed only one thing.   It has introduced charging for access.   The permits have done nothing to address the litter or other basic infrastructure issues that the LLTNPA should be addressing.
So what, it might be argued, people appear to be accepting the £3 charge.   Well, so would most people faced with the choice of a charge or a ban from staying in a place you have been visiting all your life.   That doesn’t make the charge right – people are getting nothing for it except bureaucracy and intrusion – and of course what is likely to happen is that sometime in the next year or so a report goes up to the LLTNPA Board explaining openly for the first time the enormous enforcement costs and suggesting these should be recovered from campers.   If people accept the principle of permits and charges,  our access legislation will be in tatters.
What needs to happen – and the LLTNPA is currently consulting on its new Five Year Partnership Plan – is the resources currently being spent on enforcement of the permit system (which means almost the entire time of Park Rangers) should be redirected to other tasks.  High on my priority list would be removal of litter – including Rangers encouraging campers and other visitors to take part in litter picks – and provision of wood for campfires.    Ranger services were never intended as quasi – or is that Stasi?  – type police forces  and the Park Ranger service should be allowed to return to its educational role, which should include leading by example.
Plans to rebuild the Day Lodge and turn it into an international conference centre have been dropped

Highlands and Islands Enterprise’s news release on 12th April (see here) on its latest plans for Cairn Gorm – or “CairnGorm Mountain” in marketing speak – was widely taken up by the press.    HIE must be delighted there was so little critical coverage but their announcement raises a number of serious questions.

 

The truth is that the long promised masterplan, if it exists, is not yet public and the only agreement there has been is between HIE and Natural Retreats, the organisation that now run Cairngorm.   Nothing resembling a plan has been issued or is available on either the Cairngorm Mountain or HIE website.    So, for example, no indication has been given about where the proposed dry ski slope will be located nor how that proposal will meet environmental requirements.   The design and location of the dry ski slope and proposals for environmental mitigation are absolutely crucial for determining whether the Cairngorms National Park Authority should give ANY consideration to the new “plan” – yet HIE claims the masterplan has been agreed.  Either there has been yet more shady behind the scenes negotiations or this is pure spin!   I suspect the latter.

 

However, there is a reason I believe for the spin and that is if HIE can get a head of steam up behind the proposal and convince people that in this lies the economic salvation of Speyside, it will make it much harder for the Cairngorms National Park Authority to reject the proposal, however awful it might be.     Hence the emphasis in the News Release about the new jobs that HIE claims will be created – 35-45, but nothing of course about pay or working terms and conditions – and this just a few weeks after Natural Retreats had been threatening to make a large proportion of the workforce at Cairngorm redundant.

 

Rather than a masterplan, what has been made public is that HIE has agreed to re-direct the loan of £4 million its Board had previously agreed with Natural Retreats to construct a new Day Lodge (see here for legal agreement obtained under FOI).  It is now being proposed that the loan should be used for the construction of a dry ski slope and to make changes to the Ptarmigan Restaurant at the top of the funicular, doubling the size of the restaurant and creating a viewing platform.

 

The rationale behind the Ptarmigan part of the proposal is obvious, to increase numbers of people using the funicular, but whether it is sensible is another matter.  The funicular has been a disaster from start to finish, both for skiers and day visitors, but HIE management and funding of the Cairn Gorm estate has been driven by the need to justify it and  keep it afloat financially:  HIE’s one and only idea about how to do this up till now has been to increase the numbers of paying visitors in summer.  Why take the funicular in summer though when all you can do is walk around inside the Ptarmigan restaurant,  because the soils and vegetation on Cairn Gorm are just too fragile to sustain thousands of visitors, or be escorted to the top of Cairn Gorm and back by Rangers for a price.   The wrap around viewing platform proposal would appear to be an attempt to enable more visitors to experience fresh air – or should that be the more usual howling gale at the top of Cairn Gorm? – and expansion of the restaurant designed to allow people to sit around for longer periods at the Ptarmigan spending money.

Back of the Ptarmigan January 2016 – why anyone would want to walk around a viewing platform to look onto this is unclear.

The key problem for though for HIE is when Cairn Gorm is shrouded in cloud, as it is for much of the year, why would anyone visit?  Not many people want to pay a £12 entry fee (the cost of the funicular) to a restaurant.  On clear days, given the legal agreement in place preventing funicular users leaving the stop station, for those fit enough to do so, its much better to walk up Cairn Gorm and, for those who are not, to walk elsewhere. The whole concept of attracting people to the top of the mountain to sit inside is fundamentally flawed  yet HIE persist with it.   The wider flaw in their thinking though is the belief that people visit National Parks primarily for a manufactured tourist experience rather than for the great outdoors.   A strategy built on trying to extract large amounts of money from people for poor experiences is just not going to work.

 

What you can charge money for at Cairn Gorm is for skiing and there is a hint in the news release that at long last HIE realise that if they want to make the Cairn Gorm ski facilities financially viable, they need to make it a better place for skiing.  One part of that is to try and compensate for poor snow cover as this year- hence the dry ski slope proposal in an attempt to guarantee beginners a ski experience.   That however will not bring in enough people to make the ski area financially viable.   What’s needed is a complete re-think of skiing at Cairngorm within the context of the challenges posed by global warming.  There is no sign of HIE doing this, instead they are “lending” money to Natural Retreats.

 

Financial questions that need to be asked

 

The first  question HIE needs to answer is what, if anything, are Natural Retreats going to invest in the Cairn Gorm ski area?  While the HIE News Release referred to HIE’s  £4m loan to CairnGorm Mountain Ltd, it said not a thing about any financial contribution from Natural Retreats.  I suspect that this is because Natural Retreats are contributing nothing.   CML  at the end of December 2015 had net liabilities of £776,328 and while 2016 was a good ski season, 2017 has been awful and its safe to conclude CML has no money to invest – that is why is was threatening to lay off staff just a few weeks ago.  Its owner, Natural Assets Investment Ltd is ostensibly in a far worse financial position, with net liabilities at 31st December 2015 of £38,083,245  (see here for consideration of both sets of accounts).

 

The second question HIE needs to ask is on what basis do they believe CML will ever pay the loan back given the losses currently being made by the company?   CML had a £1,219,606 operating loss in the nine months to December 2015.  I assume HIE has already produced a set of visitor projections to the new Ptarmigan and the dry ski slope that shows projected income exceeding projected expenditure and how the loan will be repaid.   While any such projections should be treated with healthy scepticism – remember how the funicular would have paid for itself by now – HIE needs to explain how any projected extra income will also offset the current massive operating loss.

 

The third question HIE needs to answer therefore is why is it lending money to a company that is basically insolvent and dependent on the goodwill of hedge fund manager, David Michael Gorton, the ultimate owner?   When selling CML HIE retained most of the assets at Cairngorm, including the land and lift infrastructure.   Why not then simply pay for the new assets itself and retain them in public ownership rather than lend money so they end up in the hands of a hedge fund manager whose companies appear to be going bust?   The safe way to get the money back would be to keep the asset and then to charge extra rent to CML for the use of those assets?

 

I suspect the reason this option is not being taken is because of neoliberal dogma, that public assets and public investment are bad and everything is best done through the private sector.    The financial evidence in this case (as in many others) suggests otherwise and that HIE is creating a disaster at Cairn Gorm.  HIE will no doubt claim that it will secure its loan as it it did in its agreement with CML over the day lodge (see link in paragraph 4 above).   That agreement states CML cannot sell the new assets financed by the HIE loan without permission.   That sounds fine until a company goes into liquidation – and CML appears heading that way – when its assets are distributed among all creditors which would inevitably result in HIE getting back less than what it put in.  I am not an expert in these things but  its looks to me as though its almost impossible for HIE to secure its loan properly.

 

The wider questions about Cairn Gorm

 

Part of the justification for selling Cairngorm Mountain to Natural Retreats was to enable much needed investment in facilities to be financed by the private sector – the latest investment announcement suggests that is no nearer to happening.  If investment depends on the public sector, the obvious question is why have the private sector involved at all?

 

The answer is that sometime the private sector has expertise that the public sector lacks.  However, Natural Retreats was a new company with little experience and no expertise in skiing – so why then did HIE choose them?   There were – and are now – local people and businesses who are prepared to work together and manage Cairn Gorm for the benefit of everyone and keep money invested in the local area.    The biggest question therefore which HIE needs to answer is why its still pressing ahead with financing Natural Retreats instead of putting its efforts into supporting a community enterprise to takeover and run Cairn Gorm?

 

It would appear from the HIE News Release is that the proposal to redevelop the Day Lodge has now been abandoned.   The delivery of a new Day Lodge was a condition of HIE’s lease with Cairngorm Mountain and set out in Schedule 4.  That schedule now needs to change and it appears therefore that HIE would, if it gave notice to Natural Retreats to terminate the lease now, be secure from any legal challenge.   It has no excuse for not doing so.

 

The public investment at Cairn Gorm is a good thing – its just being given to the wrong people for the wrong purpose.  Its time our politicians appreciated this and started arguing for alternatives.

The Loch Venachar Quay carparking area – a nice scene or a demonstration of how powerful interests control how we enjoy the landscape?

On Sunday, I was reminded of Oscar Wilde’s story of the selfish giant.   The story is about a giant who returns to his castle, finds children playing in his garden and infuriated, builds a wall to keep them out but then the hard way learns the error of his ways.  Its a parable about many things, but access and sharing land is at the heart of it.   For readers who don’t know it,  its a recommended read (5 minutes – see http://www.online-literature.com/wilde/180/). 

 

I had gone to the Trossachs to check a couple of hydro schemes (about which more anon) but first of all wanted to check some details about the land around Loch Venachar House, the home of Linda McKay, the soon to depart convener of the National Park.  She appears to have been the driving force behind the forthcoming camping byelaws (see here).   I stopped at the carpark at the Quay on the Invertrossachs Rd, which the Loch Lomond and Trossachs National Park upgraded in 2015.   Parkswatch has previously covered how the Loch Lomond and National Park Authority had changed some of the original plans for this site (see here for the cock and bull stories about why gates were installed)   as set out in the Five Lochs Visitor Management Plan in 2012.  What I had not appreciated till last week was that the Park had applied for planning permission to itself for re-landscaping this car park and planning documents were also available:

The plan that was approved 14th January 2015 by planning – note the footpath out along the quay.

In the original Five Lochs Visitor Management Plan,  the area to the right of the gate which is directly adjacent to the grounds of Loch Venachar House, Linda McKay’s House, was to be grassed.  On the planning application the grass was replaced by trees.  You can see from the photo that many are of prickly variety and sit in front of a full height barbed wire fence.  The objective would appear to be the prevention of any public access along the shoreline towards the old water works. Why the LLTNPA should be so determined to curtail  public access here remains obscure.

 

While the landscaping in the foreground of the photo at the top accords with the plan granted planning permission, the path along the quay has totally disappeared and been replaced by closely planted trees making access very difficult.  Again, it would be in the public interest to know why it was decided to do this.

According to the plans approved by the LLTNPA the path was supposed to run just to the right of the larger trees on the left side of the Quay

The land at the Quay was gifted to the people of Callander on 7th August 1909 as part of a deal in which a builder, John Watherston, bought the lands of Easter Duilater (now known as Dullater) from the McLaren Educational Trust.   The original deeds from the Register of Sasines state that the purpose of the gift was for local people “to enjoy the rights and privileges of fishing and boating in Loch Venachar……together with the right of access to Loch Venachar for these purposes”.   Over the years the land was managed on behalf of the people of Callander, first by the McLaren Educational Trust, then Callander Borough Council before being transferred to Stirling Council and thence to the Loch Lomond and Trossachs National Park Authority on 22nd September 2004  (along with other parcels of land on the north side of Loch Venachar, Rowardennan, Milarrochy Bay and some other places).

 

While the quay had fallen into disrepair, one might have thought a National Park would have wanted to respect the terms of the original gift.  Not so – the LLTNPA has now effectively stopped anyone from launching boats from the quay while  the dense treeplanting  discourages anyone from walking out to the end of the Quay and enjoying the view along the shoreline to the dam and waterworks, a  fine piece of Victorian architecture.

Loch Venachar House is behind the Scots pine, Venachar dam to the left. The full height fence appears to stop close to where what I believe is willow scrub can be seen in the water

This landscaping appears to contravene one of the four statutory aims which is to promote enjoyment of the countryside.  An artificial quay built into a loch is not the sort of place that would normally be planted or where tree regeneration would be promoted.    I have written to the LLTNPA asking for them to explain why the path has been replaced by a barrier of trees and the basis for this decision.

 

One might have hoped that with the Convener of the LLTNPA, Linda McKay living next door, she would have taken a close interest in the need for the Park to demonstrate best practice here and intervened to prevent this measure.   On the contrary, I have – despite asking – seen no evidence that she made any written representations on the Park’s development of the Quay site.

 

The main thing I wanted to check on my visit though was access along the boundaries of Loch Venachar House.    Last summer I had seen a barrier between the high fence, which I suspected marked the property boundary, and a lower fence that runs along the edge of the quay.  It was still there:

The wire is very hard to see from a distance (you can see a faint haze across between the fences if you look carefully) and its only if you tried walking between the fences that you would realise it was there:

Close up though the barbed wire and wire netting below it form a very effective barrier with no way round without wading through the Loch.   I have no idea of who has done this.   It appears though to be fairly recent from the way the barbed wire is wrapped round the fence wire, i.e it post dates that, and whoever did this appears to care little for trees.  Nor do I know who owns the land outside the fence.  This could form part of the Venachar House property or could be owned by someone else, such as by Scottish Water – or it could form part of the harbour and quay and be owned by the National Park itself (I was not able to find the diagram of the land originally gifted from the Register of Sasines).

 

What I did learn on Sunday though, from a man fishing with his son, is that people used to walk around the shoreline of the loch here to the dam during the long period when the former Venachar House was derelict.  The intention of the new wire is clearly to stop people doing this and because its outside the fence that marks the garden boundary, whatever the ownership, it appears to be an obstruction to access, possibly on land owned by the LLTNPA.    Interestingly, the man fishing – who turned out to be a police officer in his day job – also told me that when the reservoir is low you can still walk round to the dam along the beach.  LLTNPA photos from the Your Park consultation prove that people used to camp on the beach along the shoreline by the Invertrossachs Rd and perhaps they also used to camp on the beach in front of what is now Loch Venachar House.

 

After checking the Quay side of the shoreline and being unable to get further, I walked round Linda McKay’s house then took the track to the dam.

The track to the dam, Loch Venachar House on the left.

 

The access is not welcoming, there are no signs making  walkers welcome however,  I knew the track was used by Scottish Water to access the dam and the last time I had visited, a woman from the house to the right of the track gave me a friendly wave as I walked past.

The view of the dam and track beyond the houses – clearly an access track

At the dam I tried walking back towards the Quay along the lochside, but this was soon blocked by vegetation, so I walked through the open field (to left of picture), climbed over a wire fence and then realised by a short section of wooden fence between the fence and the shore that if I went further I could be in what is now Linda McKay’s garden.  I turned round.

The view from the wooden fence outside the field.  This is where apparently people used to walk along the loch shore between the Quay and the dam. The Quay is round the corner in the distance. The double height fence in the previous photos stops somewhere between here and the Quay allowing the occupants of Loch Venachar House open access to the lochshore.

 

 

I don’t know as yet whether the shoreline here forms part of the property of Loch Venachar House or whether the wall or line of trees in the photo forms the boundary and, if so, who owns the land outside the boundary, including the sloping embankment down to the reservoir.     If the wall or lines of trees forms the boundary, the land outside of this would still be within access rights.  However,  because there is no information and because no-one wants to walk into what is legally someone’s garden, what this would effectively mean is that the owners of Loch Venachar House have secured part of the shoreline for their own private use.   I turned back because of this.    If the owners had continued with the boundary fence, as they have every right to do, this would indicate to the public that the land outside the fence was within access rights but would have blocked Linda McKay’s access to the shore.

 

If the entire shoreline now forms part of the Loch Venachar House property, since its been effectively treated as being part of the garden, then access rights would no longer apply.    If that is the case, this is a land reform issue – how do we protect land that is important for recreation from being bought up for exclusive private use?

 

I live in Glasgow, am lucky enough to live in a nice house on a fairly quiet residential street and on an average day several hundred people walk within metres of my front door.  If people, whether children or drunks step onto the property I happen to own, I tolerate it and sometimes welcome it.  In this respect I am no different to many thousands of other city dwellers.  I know there are though some people who live in the countryside or very large houses who feel differently.  They become so hooked on their own privacy or right to enjoy the land that they try and put barriers around their property, like the selfish giant.

 

One of the significant things that have changed for the better as a result of our access legislation in 2003 has been the whole culture of access among the general population (if not among public officials).    Many people who live in the countryside have become far more relaxed about access and have come to realise that people visiting and walking close to where they live are not a threat but a positive thing.  There are now walkers welcome signs all over Scotland.    Views have changed, like those of the Selfish Giant, but on a mass scale.  This is something that Scotland can and should be very proud of, one of the greatest achievements of the Scottish Parliament.

 

Unfortunately there are still some people who have not seen the light, who, like the selfish giant, remain shut up in their properties.   While Linda McKay appears to have done nothing illegal, my investigations have re-inforced what I thought the first time I saw how she had fenced her house and how the National Park had blocked off access at the Quay.  Neither she, nor the National Park staff who changed the landscaping design at the Quay,  appear to be to be among those people who understand or appreciate the importance of access.   Such people have a right to their views but should not be holding positions of power in a National Park which has a legal duty to promote access to the countryside and that they do is a matter that should be of the greatest concern.

 

What needs to happen

 

We need to learn from what has gone wrong  in the Loch Lomond and Trossachs National Park Authority.    A key lesson for  the Scottish Government is to avoid in future the appointment of anyone to a National Park Board  who appears to  have strong private interests which conflict with the protection and promotion of access rights.    I think that should require that at Board Interviews, people who own land should be asked to demonstrate how their management of land is in sympathy with the National Park’s objectives.  This should include not just access but also conservation and sustainable use.  If people cannot demonstrate this in their own ownership of land they should not be appointed (that would also rule out any landowners who had in any way tolerated raptor persecution or flouted planning permission from serving on National Park Boards)

 

At Loch Venachar, public access should be restored from the quay to the dam area along the shoreline linking to the path alongside the river beyond.   The dam is a listed building, a great place to visit and it could form part of a path network linking Gartchonzie with the Invertrossachs Rd, a distance of c1.5k.   Walking along river and lochside would be immeasurably superior experience to walking along the Invertrossachs Rd, which is currently marked as a core path.   If that requires the LLTNPA to purchase of a strip of land on the edge of Linda McKay’s property then they should do this, as soon as possible, using their compulsory purchase powers, if necessary.

The downstream side of the Loch Venachar dam – an interesting place to visit that could be linked to a path along the river and the Invertrossachs Road
This slide from the secret Board Meeting of 6th September 2013 shows two interesting things. The first is that the LLTNPA was originally considering banning camping and campervaning along roads throughout the whole of the National Park – a proposal it had put to and which had been rejected by the Land Reform Review Group earlier in 2013. The second is that this would have resulted in camping being banned in 11.2% of the National Park.

In early December the Park released to me slides which were presented at secret Board “Briefing Sessions” held on 6th September (see here) and 28th October 2013 (see here).   These provide further evidence for how the Park developed its fatally flawed camping byelaws were developed and should be studied by everyone who cares or is involved in access rights in Scotland.   The slides are an education in how not to approach access issues.

 

Before considering the slides from these two meetings, its worth considering why it has taken the Park over a year to make them public since I first asked for all written information about the Board’s involvement in the development of the byelaw proposals.   First, the Park failed to tell me about these two meetings when I first asked for a list of all meetings which had considered the Your Park proposals.  The Park’s subsequent excuse for this was that I had asked for information relating to the Your Park proposals and it was only after these meetings that the Your Park terminology – parkspeak – was developed!  You only need to take one look at the slides to realise the Park was wanting to ban camping from September 2013.  Second, while after the LLTNPA had released a list of all topics discussed at  secret Board “Briefing Sessions” since 2010  (see here), it was clear these two meetings had considered camping, staff claimed they held no written infomation pertaining to these meetings.   I challenged this in November, after evidence emerged that the Park had withheld information from the Information Commissioner (more on this in due course when the Commissioner has finished their investigations), and, low and behold,  the LLTNPA suddenly found it did have written information on these two meetings after all!   I am still not convinced they have released all of it – Page 11 of Appendix A for example is a blank slide  – and have written to the Park asking them to explain anomalies.    What all of this shows is that the LLTNPA’s claim to operate in an open and transparent manner is complete rubbish.  I believe there there needs to be a systematic external review of how the LLTNPA operates and how it has subverted basic principles of good governance.

 

Back to the slides………………..!

6th September 2013

This was the second slide presented to the Board on “Camping Management – new approaches”.   Shocked, so you might be, but most campers do not behave anything like this.  Abandoned tents, as the latest Keep Scotland Beautiful Litter Audit shows (see here),  are a rare occurrence compared to the total numbers camping.  My best estimate from this data, and its the best estimate there is given the Park has never made any attempt to assess this, is that tents are abandoned in c1% of camping trips.  And in most cases of abandoned tents the mess is not anything like what is pictured.   What is important about this slide therefore is that senior Park staff  set the Board off on the wrong course, they presented the litter problem as being inextricably linked to campers.  The slide was a complete misrepresentation of the truth.  The Board appear to have been convinced ever since that if  only they can manage camping all the Park’s litter problems would disappear.   This was the wrong starting point.  The result has been the LLTNPA Board, in all its secret Briefing Sessions FOI 2015-021 Response Appendix A – meetings that discussed ban, has never considered the numbers of responsible campers and campervaners or their rights.    There is nothing either in any of the slides presented to the Board in all the Briefing Sessions that took place that shows they ever considered the framework for access rights agreed by the Scottish Parliament (e.g. the role of the Scottish Outdoor Access Code and the existing criminal law) and how this could be applied to visitor management in the National Park.  That should have been the starting point for any discussion.  Having started in the wrong place, the Board have been on the wrong course ever since.

6th September 2013 – note how the slide presents camping numbers under the heading “camping pressures”.  This conflates two entirely different things because its possible to have large numbers without pressure and small numbers that have considerable impacts.

This slide contains far more useful information than anything that was presented in the Your Park consultation.    I thought it strange that the Park had never presented an analysis of the data it held for the Your Park consultation and that I had to obtain the Ranger Patrol records (on which this map must have been based) through a Freedom of Information request.  Those records disproved many of the Park’s claims.   What this slide shows is that the Park had actually conducted an analysis of the data it held but then appears to have decided to suppress that information.   I think there were three reasons for doing this.  First, the slide undermines the Park’s claims, which continue to be parroted by the LLTNPA Chief Executive Gordon Watson, that the byelaws were needed because of the sheer number of campers.  The slide show that there were relatively few areas where camping was high.   Second, if you compare this slide with the camping management zones approved by the Scottish Government (left) it shows graphically that the actual camping management zones cover many areas where there is very little camping.  The reason for this is explained by the slide at the top of this post on Options – the intention of the Park has always been to stop roadside camping and campervaning whether or not there was any evidence of problems or alternative solutions.  That I believe remains the LLTNPA’s ultimate aim which is why the current byelaws encompass as many roads as the LLTNPA thought they could get away with.   Third, the slide shows that the LLTNPA  has always known the Loch Lomond Islands were one of the most popular areas for camping – and therefore under its own warped understanding that equates numbers with pressure – should have been a priority for it to tackle.  It knew though that if the walking community and the boating community joined forces, it would lose the argument for byelaws, so it decided to introduce byelaws in stages.   The LLTNPA Board Minutes from April 2015 record that the islands will be next.  More evidence of how manipulative this National Park Authority is.

 

This slide shows that in their first debates there was some attempt by the LLTNPA to put camping into the wider context of visitor pressures.  This should have been the starting point for a discussion on how best to allocate resources for visitor management as a whole, not just camping, but footpaths (Arrochar Hills and West Highland Way), litter facilities, parking places etc.   Unfortunately, and we don’t know why, the LLTNPA quickly abandoned any attempt to look at visitor management in the round and focussed purely on camping.

 

This slide clearly shows the LLTNPA were considering byelaws from September 2013 as the main solution to visitor management.  Yet the public paper on Visitor Management presented to the Board Meeting of December 2013 gave almost no indication of this – it talked of a broad range of measures – while LLTNPA staff, when they met recreational organisations in late summer 2014, never made any reference to byelaws and were still claiming a broad sweep of management proposals.   The Park therefore spent almost a year preparing to consult on its plan to introduce camping byelaws while deliberately keeping the recreational organisations – including its own Local Access Forum, a statutory consultee – and the wider public in the dark.

The title slide for the secret Board “Briefing Session” in October 2014 is interesting because it shows while the focus of the Board was on camping management, they were considering byelaws that could be applied to all visitors, not just campers.    This potentially could have resulted in an even more drastic curtailment of access rights.  I think this arose from the LLTNPA submission to the Land Reform Review Group where they had proposed the introduction of Fixed Penalty Notices for any breaches of the Scottish Outdoor Access Code, a draconian measure which had been rejected by the Scottish Parliament as being unworkable.

This slide provide further evidence that the second meeting did at least consider camping within a wider context before deciding to focus simply on camping.  It also shows that the LLTNPA had done work on campervans at an early stage and clearly knew the numbers – note the symbols for carvan/motorhome pressures –  which makes its current failure to provide for campervans even more telling (just 20 places across all the management zones (see here).

This shows is that right from the start the Park was considering how it could enforce a ban on camping and campervans before there had been any public debate on whether this was an appropriate way forward.

This slide shows that the Park had from an early stage anticipated many of the objections that would be made during the Your Park consultation process.  Instead of engaging on these issues, which might have resulted in alternatives solutions (e.g fishing permits could have been used to reduce the impacts from fishermen camping), the Park decided to go ahead with its own preferred solution – to ban camping – which it settled on in a remarkably short period of time.  All the subsequent “consultation” was focussed on “persuading” people and organisations to agree with its own point view.

 

 

 

 

 

 

 

 

 

 

 

 

This slide provides more evidence of how the LLTNPA had decided what it wanted to happen right from the start and mapped out the process by which camping and campervanning would be banned.  While the process has taken two years longer than planned, the important point is that the Park had decided what to do and how before this was considered by any public Board Meeting.  This is not how National Parks or any public bodies are meant to operate.  Decision making is supposed to be in public, in fact my understanding this is a legal requirement.  It clearly wasn’t observed and is another reason why the Scottish Government should reject the byelaws.  By approving them the former Minister, Aileen Mcleod, in effect undermined basic standards of good governance in public authorities.  Its not something her successor, Roseanna Cunningham, should accept.

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Overflowing litter bin Balmaha 12th November 2016

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

 

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

 

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

 

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

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

 

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

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

 

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

 

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

 

Abandoned tents are a very minor problem

 

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

litter-table-8

 

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

litter-9

 

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

 

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

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

 

Methodological and other issues in the KSB Audit

 

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

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

 

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

 

What needs to happen

 

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

 

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

 

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Slide presented to secret Board Briefing session 23rd February 2015

 

This slide provides a crude summary of the Park’s data on camping activity within the four proposed management zones.  Its not surprising, its what anyone who camps or goes to the countryside knows, most camping takes place in summer (despite the midges!).   It raises though serious questions about why the The Loch Lomond and Trossachs National Park Authority recommended the camping byelaws should extend from 1st March to 31st October and then why Aileen McLeod, Environment Minister at the time, modified this recommendation so the proposed byelaws will now run from 1st March to 30th September.

 

The first thing to say is that the slide demonstrates that the main justifications the LLTNPA is now citing for the proposed byelaws, a) the sheer number of campers and b) environmental damage, do not justify the period of the proposed byelaws.    While the number of campers represented by each colour in the chart is not defined in the slides (again this is typical for the Park, this is not evidence that would stand up in a court of law), if they were they would show that the number of campers in  the green months are very low and in the orange months low compared to the summer period.    So, even if one accepts the argument that byelaws are needed to limit the number of campers, the LLTNPA has no evidence that,  outwith the four summer months, numbers are a problem or need to be regulated .

 

Related to this, unless a far higher proportion of campers outwith the summer months behave irresponsibly, the impact of irresponsible behaviour when it occurs will be much less March-April and September-October and is  much easier to manage. In visitor management terms, if an occasional abandoned campsite has to be cleared up, so what?   There is only a problem if lots and lots of tents are abandoned and are beyond the capacity of the Ranger service and other services to cope with.  (The LLTNPA incidentally has never provided any evidence that this actually happens or assessed this problem relative to other litter, such as that washed up at the head of Loch Long after storms).   Actually, I believe  the proportion of people camping responsibly outwith the summer months is likely to be higher, as people camping at these times are more likely to be dedicated to pursuing their chosen activity and such people are generally more aware of their impacts on the environment.

 

What this slide shows therefore is that the LLTNPA’s recommendations to Ministers about the byelaw periods was not based on any evidence worth the name but rather on something else.   While there are a number of possible explanations, I believe NIMBYISM – which is of course totally contrary to access rights – is at the heart of this.

 

When I learned that Scottish Ministers had decided to reduce the proposed period of the byelaws from 1st March – 30th September I asked them on what grounds they had done this.  I received this reply on 29th April:

 

Question Four

The decision taken to reduce the period of operation of the byelaws by 1 month was a policy decision taken by Ministers in line with their options to approve, approve with modifications or reject the byelaw proposals submitted by the National Park Authority. While the National Park Authority’s preference was for the byelaws to be in place between 1 March to 31 October as per the operation of the existing East Loch Lomond byelaws, Ministers decided that in approving the new measures they wished to see a reduction in the period of operation by 1 month across all the proposed zones, including those operating in East Loch Lomond. This decision was based on a view that visits to the National Park and the affected areas naturally start to tail off in October, in part due to falling overnight temperatures. 

 

This simply provides further evidence of the arbitrary decision making.  The Minister has NO evidence that numbers are less in October than March – indeed the opposite is probably the case because of the fishing season – and as for the claim that October is colder than March this is MINCE!   The official who wrote this did not even think it worth consulting the records of the Met:  March is significantly colder than October.

 

What worries me most about the whole camping byelaw farce is that none of it is based on any evidence that would stand up in court.  What a contrast to the levels of evidence Ministers demand before agreeing to protect mountain hares or cull red deer.

 

 

 

 

 

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Natural Retreats included this graphic in its announcement that its guided walks to the summit of Cairngorm had stopped for another year.   It tells us a lot of what is going wrong at Cairngorm.

 

The walks cost £20 a shot which means Natural Retreats earned £36,640 from them between May and October this year.   While the charge includes the return trip on the funicular  (cost for an adult £12) I think we can safely say many of the people would never have taken the funicular unless they had been able to go for a walk at the top.   So, I think its safe to say this is extra income for Natural Retreats and extra visitors to contribute to its formal agreement with HIE (as written in the lease) that the minimum number of visitors it should attract to Cairngorm each year should be 210,000.

 

These walks only happen because of the closed funicular system as explained on the Cairngorm Mountain Website:

 

In order to protect the plateau outwith our snowsports operation, funicular passengers are not permitted to exit the top station to go onto the mountain unless they are booked on a guided walk or a guided mountain bike descent.

The closed system, which was intended to protect the Cairngorm plateau, is being used by Natural Retreats to raise extra income for itself.  At the same time Natural Retreats completely ignored their own method statement for the West Wall Poma, work which is now completed, and needlessly trashed a section of the plateau (see here).  

 

highland-council-letter-copyHighland Council were alerted to this when the evidence of destruction first became evident early September but have still not responded to the formal complaint which was submitted about unauthorised operations at the end of September.    Another example of the totally ineffective system of planning enforcement in our National Parks.

 

HIE meanwhile seem to be quite happy to allow Natural Retreats to destroy parts of the plateau on the one hand – they have not intervened as far as I am aware in the breaches of planning permission at the West Wall poma – while on the other charging people for walks to protect that same environment.

Part of lease agreement between HIE and Natural Retreats includes this clause:

 

Minimum of 1 Head Ranger and 2 season rangers to be employed for at least as many days and hours per annum as they are currently employed

So, maybe Natural Retreats are using the closed funicular system as a means to raise money to pay for the Ranger Service.   £36,640 would be enough to pay for a Head Ranger.   The trouble with this explanation is that as far as I am aware HIE still employ the Ranger Service at Cairngorm* and are in discussions with the CNPA about creating a unitary ranger service as part of the strategy for Glenmore/Cairngorm.  I will check with HIE about this but if they still employ the Rangers public monies are being used to raise money for Natural Retreats.   The much bigger issue though is that despite raising monies through the Ranger service for guided walks on the plateau, lower down the mountain they are completely failing to maintain the infrastructure that would enable people to conduct their own guided walks.

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The Cairngorm Mountain Garden Project is history repeating itself. It replaced the former Alpine Garden created by Ben Humble which had been neglected and was removed by the creation of the funicular. It is now sadly neglected.
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There is no sign of Natural Retreats investing in replacement signage
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The lack of care was very evident earlier this summer. No sign of the Alpine Bistort described by this sign. No sign for the Dwarf Cornel which was easy to see.

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The bleeding of Cairngorm

 

The wider message behind the charges for guided walks and the lack of investment in signage for walkers is really quite simple, Natural Retreats are taking every penny they can and investing as little as they can get away with at Cairngorm.    The way they are treating interpretation is just a small example of a much wider problem of what happens when you allow companies like Natural Retreats to operate what should be public assets.

 

The accounts for Cairngorm Mountain Ltd, the company which is owned by Natural Retreats and operates Cairngorm, show this quite clearly.  The last accounts ending March 2015 cml-accounts-to-march-2015 show a profit of £466,216.   I will come back to that figure and wider issues of how money appears to be being drained out of Cairngorm in future posts but just a small part of that profit could have renovated all the signs at Cairngorm and paid for a clean-up too.   Natural Retreats, in its first year of running Cairngorm Mountain Limited chose not to invest  money in what would benefit Cairngorm but instead to take make a profit.   This is the company which was widely touted as having the financial resources to invest in Cairngorm.   I will come back to a wider look at Natural Retreats finances in future posts but I believe understanding them is the key to understanding  everything that is happening at Cairngorm, from the protection of the environment, investment in the ski area, treatment of customers, whether skiers or summer visitors, to the treatment of staff.

 

A key question is why is HIE allowing all of this to happen?

 

Update

*I received this note from HIE on 22nd November “CML/NR have funded the Cairngorm Ranger Service since taking over the lease of the ski area”.     I am sorry I did not have time to check this properly before the post.  I think the main argument however stands and it raises questions about the National Park will be able to “Move to a single integrated ranger service across Cairngorm and Glenmore with increased presence on the ground” as set out in the Cairngorm/Glenmore Strategy approved in September.

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

 

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Leafield recycled litter bin £145

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

 

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

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Layby between Ballater and Balmoral

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

 

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

 

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

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

 

Small but perfectly formed

 

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

 

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

 

Smaller still, but out of touch

 

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

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

 

Meetings about meetings as the Park Authorities failure to act continues

 

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

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

Innovative Approach or just good Management?

 

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

A stark and damning contrast

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

 

Polar opposites

 

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

 

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

 

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

 

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

 

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

Appendix 1 – Fixed Penalty Notice Policy

Appendix 2 – Fixed Penalty Notice Scheme of Delegation

 

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

 

New Forest Litter Strategy

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

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

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

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

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

 

Reporting litter and fly-tipping

 

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

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

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

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

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

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

Contact details:

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

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

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

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

 

What is being done

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

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

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

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

Recent joint initiatives include:

  • Each year, staff visit schools across the New Forest to talk at assemblies and to individual classes about why it is so important not to drop litter. These are specially themed sessions that appeal to the age of the children and link to their curriculums.
  • Rangers and education staff often talk with people who might not normally think about litter through public events and at local fetes. Some of these are ideal for the topic – for example an annual Marine Wonders event at Lepe Country Park is a great place to talk about the effects of litter on the sea.
  • Each year, litter picks are organised in a variety of places, ranging from beaches to Open Forest. Usually these are instigated by local community groups but equipment such as litter pickers and tabards can be supplied on loan. Guidance on organising a litter pick is available from the District Council, which is able to call by to pick up bags at the end of the event. Following the success of the Clean for the Queen event in March 2016 we intend to promote an annual ‘spring clean’ – please let us know if your group or organisation would like to get involved.
  • Litter bins are provided at key locations throughout the Forest. Specially designed litter bins have been installed in villages where ponies graze. Not only are the bins pony-proof, but they have a routed ‘message’ saying how important it is not to leave litter where the animals might try to eat it. The Forestry Commission’s car park litter bins are also pony-proof and carry the same message; some locations have double-sized bins to cope with the demand.
  • Each year, posters are put up at key locations across the New Forest including car parks and windows of local businesses. To catch the eye of regular visitors, posters are changed at regular intervals, and rotated with posters about other important topics.
  • Increasingly, social media is used to encourage people not to drop litter. Through Facebook and Twitter we can reach a very wide local and visiting audience.
  • Roadsides are regularly litter picked by NFDC contractors, either at a regular frequency or when excessive litter is reported. This currently includes a contract with the Forestry Commission to cover Crown Land roadsides.
  • Hampshire County Council and Highways England are both committed to liaising with NFDC to ensure that where possible litter picking is coordinated with verge maintenance activities.
  • Please visit our webpage signposting people to the best ways of reporting litter. No single organisation is responsible for litter across the whole of the National Park, and it really helps those who are responsible to be quickly informed when there is a problem.
  • New Forest organisations have joined Tidy Britain Group’s Love Where You Live campaign. This encourages people to take pride in their local area and inspire them to get out there and make it the kind of place they want to live and work. It is planned to be a 10-year national campaign with widespread advertising and we welcome this additional publicity.
  • There are some good examples of local businesses that actively encourage their customers to take litter seriously and, for example, staff from the McDonalds restaurant at Picket Post regularly litter pick nearby roadsides. We hope to work with other local businesses to encourage best practice wherever possible.

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I visited the south Loch Lubnaig car park for the first time on Sunday, on the way back from a day on the hill, and was struck by the signage.  I think it proves the dangers of car park charging I made in my post two weeks ago.    Loch Lomond and Trossachs National Park Authority would have visitors believe that the charges are to help maintain the car park.  In fact I suspect a significant proportion of the charges collected is being used to pay for the people who come round to lock the gates of this car park each night and other car parks where the LLTNPA has not yet installed pay and display machines.  Some of the money will also contribute to the installation of gates at all the car parks controlled by the LLTNPA.    This is a National Park that is supposed to be promoting access but instead is paying people to prevent it.   This needs to be stopped.

 

When I asked Gordon Watson, the Chief Executive of the LLTNPA, the reasons why gates were installed across the car park outside the Park Convener, Linda McKay’s House on the Invertrossachs Road on South Loch Venachar, this was his response (Complaint 093 response dated 14th December 2014):

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Gate at first Invertrossachs Road car park – Loch Venachar House, the home of the Park convener, is behind the double height fence

This was nonsense and I followed it up as I had photos showing the then recent flooding at Loch Venachar where water levels were well below the carpark – indeed a local person informed me they had never known the loch to flood that high.  I also could not understand how a car park could assist with traffic management on what is generally a very quiet back road.   This is the Park’s Response –EIR 2015-014 Response.   What it proves is part of the response from Mr Watson to my complaint was simply made up.  EIR 2015-014 clearly states that the Park had “no written information about the basis of the decision to install gates at the car parks”, “does not hold information about flooding on the loch shore at the location on the car parks on south Loch Venachar” and had no information from the police or Stirling Council about any need for traffic management.  So the National Park held absolutely no evidence to substantiate Mr Watson’s claims as to why the gates were installed – not the first time this has happened.

 

The wider problem is that the letter shows that people like Mr Watson are being allowed to take decisions that fundamentally affect access rights (and its worth knowing Mr Watson lives in the National Park):

 

“The decision to install gates was an internal decision by officers [note the LLTNPA avoided my question as to who authorised the installation of the gates].  This decision follows the same approach as that taken at other visitor sites that have been improved by the Park Authority, including Loch Lubnaig North and South, Milarrochy Bay, North Loch Venachar and Firkin Point.”  

If this is true, a group of senior staff would appear to have taken a decision to install gates with a view to keeping people out across the National Park. (If its not true, the Park Board is responsible).  I would question how on earth this promotes the statutory duty of the National Park to promote public enjoyment of the countryside?   Why shouldn’t campervans pull in and spend the night at south Loch Venachar or Firkin Point or anywhere else?   Elsewhere in the Highlands people are generally welcomed but in the Loch Lomond and National Park everything is done to discourage visitors unless they pay for it at times the Park decides.   I think it significant that Linda McKay, the Park Convener, while apparently fully aware of the installation of gates as neighbours were notified (though the letter indirectly shows she did not comment) did not think to raise the wider access implications.   More evidence that NIMBYIST attitudes and assumptions in the LLTNPA  start at the top with the Chief Executive and the Convener.

Photo taken 22nd August Ben Lawers Car Park Photo Credit Liza Downie
Photo taken 22nd August Ben Lawers Car Park Photo Credit Liza Downie

 

 

 

 

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New Inveruglas pay and display

 

 

 

 

 

 

 

 

 

 

 

Thanks to Liza Downie for sending me this photo from Ben Lawers after my last post.  I had questioned why the Loch Lomond and Trossachs National Park had just tendered for an automated number plate charging system when it had just installed new Pay and Display machines at Inveruglas – but perhaps they have already been stolen?!   Or has the LLTNPA realised their plan for Pay and Display machines at the three carparks was too risky and they are now trying to shift the costs of providing equipment onto external providers?

 

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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:

2.17.1.2 Maximise the revenue achieved via all car parks across stated NPA sites

2.17.1.3 Minimise any restriction to the flow of traffic on NPA sites.

2.17.1.4 Maximise overall parking occupancy”

and,

“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?

 

“It is not felling or fire that destroys a pine wood, but overgrazing of the ground beneath and beyond, whether by sheep or by deer.”   Chris Smout

 

On Thursday Rothiemurchus made a Facebook post of a burning granny pine and the following comment:

 

“A sad day on Rothiemurchus today. One of our beautiful 250 year old granny pines, beside the Lily Loch, was burnt down by selfish campers. Not only that, they chopped down two old birch trees to provide fuel for their fire! Luckily we had a team out very early moving cattle who saw the smoke, alerted the fire brigade and went straight to the scene. They arrived to find the campers had scarpered and the tree engulfed in flames. Their quick actions prevented the fire spreading further which would have destroyed surrounding woodland and wildlife in this protected area. These campers have not only broken the law, they have behaved in a shockingly irresponsible way. We would ask people to think very carefully before they do anything which could impact upon an environment which takes hundreds of years to recover. It’s only a tiny proportion of visitors who behave stupidly and we are extremely grateful and thank all those who help care for this special place.”

 

While I personally hate to see trees burned in acts of vandalism, the post – whether deliberately or not – has inflamed public opinion in the social media world with over 650 written comments and 3.5k  likes/reactions.    The largest proportion of these express disgust and a desire for retribution for whoever did this with calls to lock the people up and even “burn them” – this is social media after all.   A few, predictably, are asking for camping bans but it is good to see a larger number try and draw a line between responsible campers and vandals.   Indeed a few question how the estate can be sure it was campers who had done this when the people concerned had “scarpered” and the birch trees cut down with a heavy saw that most campers would never carry.  The estate has responded by affirming it was campers (as though to emphasise that this is the important fact) though to be fair it does say only a small minority of people behave like this.

 

The reaction has been focussed on the burning of the tree rather than the wider significance of this.  I find it interesting that there appears more public concern at present about the damage to one tree  than the systematic destruction going on up the road at Cairngorm or the systematic muirburn that takes place on grouse moors.

 

The Rothiemurchus post did not help put matters in perspective by claiming that the environment takes hundreds of years to recover after fire or similar acts.   This is simply not true.  Indeed it says so in their own Forest Plan:

 

“Visitors may be left with the impression that the pinewood of Rothiemurchus is an untouched wild wood, but this is a myth. In fact the Rothiemurchus woodlands exist today because of their ability to regenerate, having probably been clearfelled twice, and not because they were spared by the axe” (Smout & Lambert, 1999)

 

Moreover, fire is one of the most important ways in which the Caledonian pine woods regenerate.     Chris Smout, made the point succintly in the inaugural Royal Scottish Forestry Society “The History and the Myth of Scots Pine”  (see here) which is essential reading for anyone interested in the pinewoods:

 

“Accidental or deliberate fires also sometimes devastated pinewoods, but again they usually caused no lasting damage as pine readily regenerates after a fire.”

 

The ecology of this that older pines are quite resistant to fire (unlike other trees like birch) while pine seedlings do not germinate or grow well under extensive vegetation.   Burn the vegetation and the pine seedlings have a chance to grow.   The problem is not fire itself – it has been actively used by the RSPB at Abernethy (see here) to promote regeneration and indeed the Rothiemurchus Forest Plan has a section on the use of fire in regeneration – but its overuse.   Burn a bit of moorland once, and trees will regenerate, but burn it over and over again as they do on grouse moors and they have no chance.    I find it ironic that Rothiemurchus is claiming that the burning of one tree is a threat to the environment when elsewhere on the estate, beyond an artificial forest boundary, muirburn is practised and is preventing the expansion of the pine wood:

 

“Thanks to the Rothiemurchus Estate who manage the land, we were able to see the heather in different stages of growth due to recent muirburn management. Muirburn is a way of managing the moorland to create patches of heather at all different stages of growth – essential to maintaining a healthy and abundant grouse population.” (http://getoutadventures.co.uk/blog/)

 

The best way to mitigate the consequences of a large fire in a place like Glenmore is to expand the extent of the forest and in that respect Rothiemurchus has been part of the problem because of its muirburn practices.

 

Unfortunately, people do not seem to appreciate that the likelihood of a large fire in Glenmore is almost inevitable as a result of current conservation initiatives.  If you allow a forest to develop with only very limited human intervention, the ground cover will increase and at some stage, in dry weather, there will be an extensive fire.   This could happen naturally through a lightening strike or could be triggered by humans, whether accidentally or deliberately.   This does not make those conservation initiatives a bad thing, rather the contrary, but as Smout notes, in the past human management of the pine forest (clearing areas of timber and so creating fire breaks and removal of ground vegetation for various purposes) reduced these risks.    Allow nature primacy, as we have seen in the US and Australia, and eventually you will get a huge fire.   Such fires of course are much more common in those countries, in part due to the climate, but to think they will not happen here is to put your head in the sand.   At some point, a whole lot of granny pines are going to burn but we should despair or condemn too much, the woodland will regenerate. Personally I believe this outcome to be preferable to what is happening in much of the rest of Scotland where overgrazing has reduced the likely impact of fires to negligible proportions but has been slowly strangling the pinewoods as the granny pines die one by one.

 

None of this means I condone people setting trees alight or that, because a large fire will happen at some point, I believe it would have been okay if the fire had spread in this case.  If we are going to allow natural processes to dominate certain areas – which is what I would like to see – it would be preferable that disasters should happen naturally, rather than being created by human foolishness.   In the case of fire, this means fires caused by lightening strikes rather than chainsaw wielding vandals.

 

We will not though, I believe, ever get rid of human foolishness/irresponsibility entirely and we should not use that foolishness, as some people have in this case – and as Loch Lomond and Trossachs National Park Authority are proposing to do with their camping byelaws – as a reason to remove people’s right to enjoy nature or simply an excuse to get people off the land.   Camping should be part of the right to enjoy nature.  To defend that right we need to increase people’s understanding of ecological processes and expose the hypocrisy of those who are only too happy to condemn certain acts of irresponsible behaviour while turning a blind eye the much greater destruction that is going on elsewhere.

IMG_6325

Dear LLTNPA,

 

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

 

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

 

Here’s to a litter free Scotland

 

 

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

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

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

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

On 27th May the Loch Lomond and Trossachs Park Authority advertised a planning application to create a new 30 place campsite at Loch Chon.  You can find all the papers through the Park planning portal http://eplanning.lochlomond-trossachs.org/OnlinePlanning/applicationDetails.do?activeTab=dates&keyVal=O79O0SSIJ6T00.

 

It is bizarre that the LLTNPA is applying to itself for planning permission when the land is owned by Forestry Commmission Scotland.   In their response to the Your Park consultation the FCS stated it would support new campsites but had no money to pay for them.  Leaving aside the fact that FCS appears to have plenty of money to lavish on private landowners, rather than the public  (it paid John Grant £7.4m to purchase Rothiemurchus), it now appears that FCS are basically taking nothing to do with campsite provision and are leaving LLTNPA to do everything.   This is totally wrong.  FCS are a public body with a recreational remit and should be serving the public.  Instead the FCS seem to have the Park wrapped round their little finger and, now they are no longer able to introduce their own camping byelaws, using the LLTNPA to do this for them as at Forest Drive by the Duke’s Pass

 

The Planning application contains no justification for this campsite.  I had previously asked the Park for all information they held about why they had decided to construct a campsite here and they have refused it (and that case is now with the Freedom of Information Commissioner)   The background was given in a previous post http://parkswatchscotland.co.uk/2016/03/27/con-loch-chon-proposed-trossachs-west-camping-management-zone/ which showed there is no demand for a campsite of this size in this area and called on the LLTNPA to publicly justify their plans.

 

Objection from Local Residents

A similar point has been made in a objection from two local residents who have questioned the size of the campsite and the proposals for managing it (there are now three objections from residents on the planning portal).   Put simply, the proposed campsite will either be a white elephant and not used or, if used, will have attracted far more people into the area without any plans for how this influx will be managed.     While I am against the NIMBYISM which is so evident among some people who are fortunate enough to live in the National Park, I thought this letter and the other letters of objection lodged on the Park’s planning portal have made some excellent points:

  • The residents question the proposal to use old shipping containers for the toilets, store and equipment room.  The Park says the containers will be plated with aluminium and painted – their illustration shows trees painted on the sides.    I think the residents are right, these will look dreadful from the start.      At present there is a glut of old shipping containers across the world  and they are now being used to provide housing in places like Africa.   So, they are cheap.  While I am sure the Park will justify their use as their contribution to recycling what about  supporting the local wood products  industry and constructing  toilet blocks which are in keeping with the National Park?
    IMG_5829
    The forest plantation on the southside of Loch Chon which was being harvested earlier this year. Neither FCS nor LLTNPA have given any consideration to using this wood to construct toilets on the proposed campsite.

    Is it really so hard  to construct buildings out of locally sourced natural materials land help sustain local employment?    If the LLTNPA really does want to make a contribution to world recycling, it could use these containers as temporary toilet blocks, like portaloos, and install them in the places most popular for camping over the summer. 

  • How is the Park going to hire out firepits when there is no warden on site?  To which I would add, why cannot this Park Authority provide anything for free?    If fires are such a problem as claimed by LLTNPA, surely every camping place should have a fire pit?     But then, given the lack of demand for camping here, this would be throwing more good money after bad.
  • Why is the Park wanting to install gates?  An excellent question.  A reader of parkswatchscotland recently pointed out to me that the gates that had been installed at Loch Chon made it very difficult for canoeists to access the loch.   Throughout the National Park the LLTNPA, which has a statutory duty to promote access, has been busy installing gates at carparks, the only purpose of which can be to stop access.  This NIMBY culture in the LLTNPA  affects the rights of local people as much as visitors.

Other reasons why the application should be rejected

The Park is proposing to provide some of the 30 proposed places – its unclear how many – on wooden platforms.     Now, I don’t think any camper in their right mind would want to camp on a wooden platform (I know it happens on sand dunes in Australia) and this illustrates two serious issues.   The LLTNPA has simply failed to consult with campers about fire pits, places or anything else.   Either none of its staff have ever gone camping or more likely senior management in the Park have simply failed to consult their staff who do camp and could tell them what makes a good camping place.      The second issue is that there is simply not enough ground in the area the Park has identified for a campsite to support 30 camping places.

IMG_5825
The path that goes through the proposed camping area. As the site plan states, much of the area is too boggy or steep to provide good places to camp but the Park wishes to fit 30 tents in a place that could sustain a third of that number.  The only reason for doing this is so it can say its delivered some new camping places.
IMG_5826
The area to the east of the current carpark is unattractive for camping and, while its been left out of the plans, similar areas have been included.

 

 

At present,  the area around the lochshore close to the proposed campsite is  the most popular for camping around Loch Chon, although people do use several other places (often to fish).  However, the Park wants to stop all this and herd people onto an area of slightly higher ground above the loch.   One reason there are not more people camping at Loch Chon at present is simply that the number of good places to camp is limited.  Creating camping platforms is not going to change this.

 

The design of the campsite is shown in the .Loch Chon 2016_0151_DET-Engineering_Layout-100262476 and there is an accompanying design statement produced by the consultants Loch Chon 2016_0151_DET-Loch_Chon_Design_Statement-100262485

 

Remains of fire Loch Chon
The best places to camp, by the loch shore, are NOT included in the campsite area

The Design Statement states that are no camping places by the shore as  “this will minimise visual impact on visual receptors such as canoeists on Loch Chon”.  Its great to know the views of canoeists are so important but I am sure neither the consultants or the LLTNPA bothered to consult the Scottish Canoe Association.   The SCA strongly opposed to the byelaws precisely because their members need and like to camp on the loch shores.   The statement is doubly ironic given that canoeists have been prevented from accessing Loch Chon  by the gating of access tracks which prevent anyone getting the vehicles or trailers that carry their canoes close to the water.

 

The Design Statement claims that “camping pitch locations………will allow for a range of experiences loch-side, burnside, high level”.   Ignoring the fact there are no lochside places planned, this is patronising drivel but it illustrates the mindset of the LLTNPA.  You need to remember the Park is intending to try and force people to book places:  “I am sorry Mr Kempe but the burn-side places are not available tomorrow but we suggest that if we allocate you a high level place that might expand your horizons”.    Petty bureacracy to replace access rights.   I really don’t believe this is coming from frontline staff.

 

The  Design Statement describes the Loch Chon con as a semi-formal campsite.   One of my objections to Park’s Development Plan was it used totally different terminology to the Your Park Plan which produced the byelaws Response – Development Plan and Camping.   A case of two parts of the LLTNPA bureaucracy failing to talk to each other .  Your Park used the terms “basic” and “limited” facilities, while the Development Plan – which is still to go to a Public Local Inquiry – used the terms “formal”, “semi-formal” and “informal” campsites.   A semi-formal campsite, according to the draft Development Plan approved by the Board, appeared the same as an informal site except it could have low level lighting.   Informal sites were defined as having no water or drainage, while both informal and semi-formal sites could have temporary or composting toilets.    From the Design Statement it appears the definition of semi-formal campsites has changed so semi-formal campsites will now include waste water treatment and a water supply while the toilets can be permanent as well as temporary.  It is good the LLTNPA  has made the definitions clearer, even if it is unclear who authorised this change or if they have replaced the Your Park terms – but then the LLTNPA takes lots of decisions behind closed doors.   .

 

The new definition of a semi-formal campsite however has had the consequence that such campsites now require formal planning permission, which in turn means the LLTNPA has to meet not just its own but other public authorities rules.  This has created a whole set of new problems.   Stirling Council’s Flood Officer has even objected formally to the application due to a lack of information on drainage culverts.  The risk of flooding may be an additional factor which explains why there are no camping places proposed by the loch shore where most people  want to camp.  Indeed part of the application includes a proposal by the LLTNPA to operate the Scottish Environmental Protection Agency’s flood warning system only for SEPA to point out that their system does not cover the area!  To add to the planning shambles, the Stirling Flood Officer has pointed out the road to Loch Chon, the B829,  floods regularly  so there would be difficulties evacuating campers.

 

 

All of these bureaucratic problems could have been avoided if the LLTNPA simply allowed people to camp as at present under access rights and take their own decisions about where it was sensible to camp.   To minimise the impacts of people camping here, the LLTNPA could have recommended to FCS that it should take responsibility for its own property and install couple of composting toilets and some litter bins.       FCS could have done this for under £20k instead of the £345k or so the Park has budgeted.  I am sure would have been welcomed by local residents.   To address the concerns about anti-social behaviour raised by local residents, the LLTNPA  should have been talking to Police Scotland about their role and how they could respond.    As the letter from two local residents clearly states  anti-social behaviour can take place in campsites just like anywhere else.    Only good policing will address that.

 

The amount of money the Park has devoted to the Loch Chon proposal could have been far better spent.   According to the Park’s end of year budget report to the Board it was aiming to spend £100k by the end of the financial year 2015/16 year  on the proposals.   I had previously wondered if this money had been spent because there had been no signs of work on the ground.  Its now clear now from the papers appended to the planning application it must have been spent on consultancy to produce plans for the campsite and environmental assessments.   The environmental assessment took place in January – not a good time for surveying wildlife and not surprisingly came up with a list of common birds.   I intend no criticism of the consultants but this was a bureaucratic exercise for what?   A poorly designed campsite for which there is no demand and on which it is planned to spend another £245k this financial year.

 

What the LLTNPA should have been doing, is what it should have been doing across the National Park, and that is to consider what basic facilities would help those exercising access rights (not just campers) to do so responsibly and to do so in consultation with both local communities and recreational bodies.    It could even have allowed local communities to make bids to install new camping facilities in their area – I am sure they would have spent the money being wasted on Loch Chon far more effectively.

 

If you want to comment on or object  to this proposal you can do so on the Park’s online e-planning facility or send an email to planning@lochlomond-trossachs.org   If you are objecting make sure you head whatever you say “Objection”.  The reference for the application is 2016/0151/DET

 

Glen Derry
Glen Derry

I have been meaning for a couple of weeks to refer readers to the excellent piece from Neil Reid, the Cairngorm Wanderer on the National Trust for Scotland’s latest proposals to renovate Derry Lodge

Plans announced for Derry Lodge development

 

I remember discussing the future of Derry Lodge at the Mountaineering Council of Scotland twenty years ago with the main options being to knock it down and restore this as an area of wild land or to turn Derry Lodge into an Alpine-style hut.   The lack of action since then is all about money, about the the National Trust for Scotland operating under a model in which it is expected to fund the vast majority of its activities despite being a national resource and struggling to do so.  It has consequently lurched from one financial crisis to another and is undergoing yet another internal restructuring at present driven by the need to balance its books.    With large historic buildings to maintain, the consequence is that Derry Lodge is a low priority and I fear that despite the good intentions of the staff who are behind these proposals, nothing may happen.    The wider financial issue is really about how do we get financial investment in rural areas.  There are lessons here from Alpine Associations on the continent and how they manage to raise funds to renovate mountain huts in locations which from a construction viewpoints are far more challenging than Derry Lodge.

 

The other big question is how the proposals to renovate Derry Lodge sit within the need to protect and enhance wild land – the central Cairngorms are after all one of the largest areas of wild land in the country.   Why not just knock it down?   And what is the difference, if any, between renovating Derry Lodge and installing a new run of river Hydro scheme in Glen Derry?

 

The arguments about the importance of wild land led the NTS to remove the bulldozed track from Glen Derry above the old lodge building and, along with nature conservation, helped drive the reduction in deer numbers which is allowing the pinewoods in Glen Derry and Glen Lui to regenerate.  So, keeping wild land values and concepts of rewilding to the forefront of thinking about Derry Lodge seems to me very important.

 

In this large area of wild land, the existence of Derry Lodge and a few bothies, has very little impact.  The Lodge is well screened by trees and sits at one of the main entry points for walkers and climbers to the central Cairngorms.   NTS’ proposal to include public toilet facilities would address the main human impacts on the area.   Its worth contrasting Glen Lui with Glenmore, where the road intrudes well into the mountain core and new development high up on Cairngorm  is continuing.   There are far bigger issues affecting wild land and landscape in the Cairngorms National Park.

 

In addition, Derry Lodge is regarded by most people as an attractive building.   NTS would have significant issues getting agreement to demolish it because it is bound to protect and conserve the historic buildings it owns.   From a cultural viewpoint too, the area has a well known history, including use by mountaineers.   All of this seems to me to be a reason to support the proposals.  This is not about new development as such but restoring an existing building in a way that should help conserve the landscape and enable people to enjoy it.

 

IMG_1583
Lower Glen Lui – few signs of rewilding

While supporting the proposals in principle,  I do think there is a strong case that the renovation of Derry Lodge should be considered alongside what could be done to re-wild lower Glen Lui.    This is still dominated by the track and forestry plantations and walking or cycling along it is far from a wild land experience.   The main reason the track has been kept is again one of money, the cost of culling deer without NTS vehicles being able to transport stalkers to Derry Lodge would be considerable.    It would be good though if the NTS  vision included the case for converting the track into a footpath and outlining the  public financial assistance it would then require to continue effective deer culls.    Together with plantation restructuring this would make the approach to Derry Lodge a far wilder experience. Part of this vision could be that one day Derry Lodge provides a refuge for people uncomfortable with the idea of camping in places where wolves or lynx roam, that it part of the core wild land area and not on the edge of it.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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.

 

 

The Cairngorms National Park Authority has, with Scottish Natural Heritage,  issued a short educational video on dog walking in the National Park https://t.co/ZsYpjNosWL   This is to be welcomed.  The Land Reform Review Group, which reported to the last Scottish Parliament, concluded that access rights were working well but there were a number of areas where further education was needed.   Dog walking was the priority area for further work (camping was not seen as a major issue at all and the Review Group rejected representations from the Loch Lomond and Trossachs National Park Authority that the legislation needed to be amended to remove the right to camp by roads).   The CNPA video should be seen as a positive initiative by a public authority to implement the recommendations of the Land Reform Review Group.

 

SNH also, to its credit, engaged with commercial dog walkers to draw up a new code of practice.  An exemplary way to do things in contrast to the LLTNPA who failed to engage seriously with recreational organisations about how to educate people about reducing the impacts of wild camping.

 

The dog video, which is aimed at visitors, includes information on the impacts of dogs on wildlife.   Good stuff and something that I think Dick Balharry, the great Scottish ecologist who died last year, would have approved of – I remember him saying to me how he thought there should be NO dogs in National Nature Reserves.    This, however,  begs the question about landowners dogs.   Anyone who has walked by estate buildings in the National Park will have experienced the howling of dogs in kennels and earlier this year I came across a very nice keeper (he kept his most dangerous looking dog by his side as we passed!)  running six or seven dogs at Dalnaspidal.    The purpose of these dogs of course is to assist with hunting and what is not said publicly at present is that this includes anything that the estates perceive as vermin or might prey on red grouse.  For estate dogs helps keepers track down ground nesting raptors, mountain hares and stoats all of which are persecuted in the National Park.    I suspect estate dogs are responsible for far more damage to wildlife on grouse moors than visitors dogs but let’s not wait for a three year scientific study before anyone acts on this.

 

So, my question is when will the National Park and SNH be producing a video on good practice for local estates?    Indeed, should they not go further and introduce licensing of dogs on estates and set conditions about what they can be used for?   Or follow Dick Balharry and ban dogs completely from National Nature Reserves or indeed the National Park and make legitimate hunting a bit more challenging?.    I suspect if any of this were to happen the number of dogs in estate kennels would drop dramatically.

Following my last post on camping provision in the LLTNP  http://parkswatchscotland.co.uk/2016/04/27/con-loch-chon-loch-lomond-trossachs-national-parks-disappearing-camping-plans/ I asked Gordon Watson, the Park’s Chief Executive once again  about the outstanding campsites which had been agreed for the Trossachs back in 2012 and to clarify how the Park’s draft Development Plan would encourage new campsites  email to Gordon Watson 28th April 2016

 

On 25th May I received EIR 2016-017 Response which states “no decision has been taken about the outstanding proposed campsites in the Five Lochs Management Plan”.   I very much doubt this and believe it is yet more obfuscation.   I wonder if the Park can explain what is has been doing at the site it owns on North Loch Venachar which was originally designated as a campsite and which I visited with Nick Halls on Monday 15th May?

Loch Venachar North Plan
Extract from the 5 Loch Visitor Management Plan produced by the LLTNPA show the Plan for North Loch Venachar, with a camping area on the right.   The full plan and key to the diagram can be found on page 37 of the Five Lochs Plan http://www.lochlomond-trossachs.org/images/stories/Looking%20After/PDF/5%20Lochs/5LochsPlan_2012_web.pdf

 

 

 

 

 

 

 

 

 

North Loch Venachar site owned by the LLTNPA showing new car park
The newly created carpark on North Loch Venachar. The original plans were for twice as many car parking spaces (there bays on the road side of the car park have been removed) and for these to be gravel, not tarmac.    The whole carpark has been “suburbanised” compared to the original plans – is this appropriate for our National Parks?

 

The two spaces for motorhomes included in the original plans at the west end of the carpark have been removed.
The two spaces for motorhomes included in the original plans at the west end of the carpark have been removed and appear to have been replaced by a picnic bench.

Why would the LLTNPA have not provided any spaces for motor homes, as planned, unless it had actually taken a decision not to allow them to use this site overnight?

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The original plan was for a toilet block in front of where the white van is parked and for a septic tank to be installed under the carpark.

 

 

 

 

 

 

 

Unless a septic tank has been built under the carpark as planned it is difficult to see how a toilet block could now be provided, except at considerable extra cost.  This casts doubts on the statement by the Park that no decision has been taken on a campsite here.

 

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One is needed for both campers and day visitors – as soon as you are in the trees toilet paper is only too apparent.

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The area earmarked for a campsite on the original plans, the carparking area is behind the trees

 

 

 

 

 

 

 

 

 

 

 

 

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In the original plans a recycling point (litter collection) and woodstore (for fires) was planned by the gate.  Its not clear if this will be installed but is clearly needed.

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The car park gates already fitted with locks to keep people out – this is public land in a National Park

Its interesting that the LLTNPA has installed metal gates at North Loch Venachar. Gates were on the original plans unlike those at the carpark on the south shore which was constructed a year ago.

 

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The south Loch Venachar quay carpark site directly adjacent to Loch Venachar House, the home of the Convener of the LLTNA Linda McKay (behind the fence). At this site wooden gates have been installed though there were none on the original plans.

Many would say the use of natural material for gates is more in keeping with the ethos of the National Park and would help avoid “suburbanisation”.  I  believe the LLTNPA needs to explain publicly why it has installed wooden gates at south Loch Venachar but metal gates at north Loch Venachar and who took the decision.

 

I hope the photos illustrate that while it is not yet impossible to create a campsite at north Loch Venachar, the way the recent works have been undertaken suggest a decision has in effect been taken.  Appended to this post are a further set of questions I have asked the Park about this.  I believe that any work now to create a campsite here is likely to result in significant extra costs.  What is far more likely is the Park will try and introduce its proposed permit system, where you have to pay to camp even where there are no facilities.     The Park would have been much better constructing a toilet at this popular site on north Loch Venachar than giving an estimated £345k to Forestry Commission Scotland to construct a new campsite at Loch Chon where very few people visit.   If they had done so as planned, the unsightly toilet paper littered around the trees would have been a thing of the past – another opportunity missed.

 

The solution to these failures is quite simple.  Engage publicly with the recreational organisations about the proposed camping development plan instead of refusing to divulge details and doing everything in secret.

 

The Park’s Development Plan and camping

I had  heard Gordon Watson speak at the Scottish Council for National Parks AGM last month where, in response to a question,  he had asserted that he saw the Park’s Development Plan playing a facilitative role in encouraging new campsites.   I took this as an encouraging response but it was plainly just words.  The key words in EIR response 2016-017are “the delivery of new campsites will be supported should they be proposed”.    What this confirms is that the Park has no intention of using its planning powers to help create new campsites where they are needed but will only support them where they are proposed by others and ONLY in certain places as you can see from this extract from my  Response – Development Plan and Camping

“The Guidance on Visitor Experience states “We are likely to support tourism development within towns, villages and land allocated for tourism” and “We are likely to support small scale tourism development with good access to the existing network of paths, infrastructure or visitor facilities the red shaded areas on maps” (P11).  It goes on to state “an informal touring caravan or campsite would be likely to be considered small scale” (P12).    Apart from an area around Glenbranter and between Crianlarich and Tyndrum all the red shaded areas are on the east side of the National Park and while covering the Trossachs lochs do NOT cover west Loch Lomond, east Loch Lomond or Loch Long.  So, what this means in terms of the Local Development Plan as worded is the LLTNP is NOT supporting new “informal” campsites in the west side of the National Park.   This is totally wrong and I wish to object. The National Park Authority needs to allow small scale sites in the west of the National Park area.”

 

To be clear its NOT the Park’s proposed policy under the new Development Plan to support new campsites in most of the western half of the National Park.

 

I will come back to the Development Plan in due course but  the claim in EIR 2016-017 response that “it is incorrect to say that your suggestions were rejected” should be taken with a large pinch of salt.  They were mostly simply ignored although proposals for campsites in specific areas, such as Balmaha (originally proposed by Friends of Loch Lomonds and Trossachs and SCNP) were actually rejected.    What the EIR confirms is that the Park has no intention of using the Development Plan to address the lack of camping provision in the National Park.   This is perhaps hardly surprising given the Park is still swithering about delivering campsites on its own land.  Its a matter that the new Environment Minister, Roseanna Cunningham, who has responsibility for the National Parks  needs to address.

 

 

My further questions to the LLTNPA following receipt of EIR 2016-017 Response

“Thankyou for this response.  I was out visiting the North Loch Venachar site ten days ago and saw that work had been done to the carpark.   This does not conform to the original plans in the 5 Lochs Visitor Management Plan.  I would therefore request that you provide me with all written information you hold about the work that has been completed at the North Loch Venachar site including plans and how much of the allocated budget from last year and this has been spent on the works to date (creation of the tarmac area, wall, gates, signage and some seats).   I would also appreciate a response to the following specific questions:

– why was it decided to replace the gravel car parking spaces marked on the original plan with tarmac?

– why have the number of car parking bays been reduced from the original plan?  Specifically what has been decided about the 13 car parking spaces shown on the original design for the north side of the carpark?

– why are there no parking spaces for motorhomes? (two were marked on the original map).

– has the treatment/septic tank marked on the original design been installed under the carparking area?   If not, how could a toilet block still be possible for this site as originally proposed in the 5 Lochs Management Plan?

–  is a wood store and barbecue stands  still planned for the area around the carpark?  (none are in evidence but I appreciate the intention may be to install these now the main works are completed)

– is a recycling point still planned for this site (none was in evidence but is clearly needed)?

– are the four picnic benches which I saw all that is planned for the site or is the intention to provide the seven which were illustrated in the original plans?”

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

 

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

 

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

 

Views of picnic area from Loch side road.

 

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

 

 

 

 

 

 

 

 

 

 

 

 

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

 

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

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

 

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

 

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

 

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

 

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

 

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