Camping on West Loch Lomond – a review of the evidence from Nick Kempe   December 2015
Introduction
My report on the Your Park consultation process highlighted a significant number of issues with the evidence provided by Loch Lomond and Trossachs National Park in support of its camping byelaw proposals and contained a detailed critique of the Review of the east Loch Lomond bye laws.   Since producing that report I have been looking at the situation elsewhere in the National Park in more detail and the purpose of this paper is to review the evidence for west Loch Lomond.
When I asked under Freedom of Information for evidence for the proposed byelaws, the Park provided me with data from its Ranger Patrol sheets for east and west Loch Lomond (but stated it did not do have the resources to do this for all the proposed Management zones) and also notes of meetings with various community councils.   My “Report on the Your Park consultation” included a critique of these data sheets and how the absence of any means of recording relationships between the different data categories severely limited its usefulness (section 3b attached as Appendix 1).   It did not however attempt to analyse the data to show what, with all its deficiencies, it might demonstrate.  The main purpose of this short review is to do just that but also to introduce some further evidence obtained under FOI and from other sources. 
Notes on the analysis of the data sheets
The analysis here is based on extraction of data from the patrol sheets for 2013, the most recent year for which data was provided, and for west Loch Lomond only.    Although there is nothing to suggest that 2013 was an exceptional year – as you can see by looking at the data sheets – there are variants between years so for example the numbers of tents at Stuckendroin and Culag were lower in 2013 than previous years but those for 3 bays and Loch Long were higher.   These changes appear to cancel each other out but it would be possible to add data to the spreadsheet for the other years to check this (my ability to do so has simply been constrained by time and it may be worthwhile to do so as a result of comments on this draft).  
The four data sheets for east Loch Lomond have been excluded from the analysis because camping and alcohol byelaws and a clearway were in place were in place from June 2011 and the clearway affected not just the numbers of tents recorded but also the numbers of vehicles.  It is worth noting this did not prevent litter as the Park acknowledged in their review of the ELL bye-laws.  In 2013 over 25 ranger visits to Craigie Fort not a single tent or vehicle was recorded but there were still 5 bags of litter, about the average for west Loch Lomond. 
Since my Report on the Your Park consultation, I have established (FOI 2015/045) that a car which had been abandoned by the side of the A82 for three months south of Inverarnan was NOT recorded on the Park’s database “as the Park Authority is not responsible for dealing with such matters”.  However, the same FOI goes on to state “rangers have access to information regarding relevant litter authorities” and previous public statements by Fiona Logan made clear it was local authorities rather than Park who is responsible for collecting litter.   This therefore simply begs the questions as to why the Park collect information about some types of litter or loss of amenity but not others. The same FOI established that the Park has no policy or procedures for frontline staff on recording litter or reporting it.   What’s recorded on litter in the data base therefore appears to a large extent subjective.

Data analysis and commentary 
Place	Number Ranger visits	Visits where people recorded	Visits where vehicles recorded	Visits where tents recorded	Max tents recorded	Visits where bags of litter collected	
Fallen Tree	66	25	31	9	3	13	
Ardvorlich	59	17	19	9	3	7	
Rubha Ban	58	14	24	12	7	11	
Stuckendroin	58	13	20	4	2	7	
Stuckendroin Farm	53	7	9	2	1	6	
Tarbert VC	44	34	34	2	1	1	
Tarbert Picnic site	84	79	78	7	1	2	
Kenmore Wood	62	16	19	12	4	8	
Tarbert Isle Forest Walks	45	11	10	2	1	5	
Culag Guest House	82	23	33	3	4	7	
3 Bays South	85	64	65	11	4	11	
Suie Field	81	39	62	16	6	10	
Firkin Picnic site	81	69	73	7	5	4	
Firkin Old Point Rd	19	9	2	1	1	0	
Hollybank	65	15	21	4	2	10	
East Loch Long A814	46	31	34	10	8	10	
Glen Douglas	26	13	14	1	5	1	
7 Bays Northbound	75	30	44	0	0	6	
Aldochlay North	54	4	3	5	4	2	
Aldochlay	89	54	66	2	1	2	
Duck Bay	94	88	90	10	7	5	
Lomond Shores	13	7	2	1	1	1	
Balloch 	10	5	2	0	0	1	
Glen Luss	10	8	7	0	0	0	
TOTALS	1359	675	762	130	71	130	

This data extract demonstrates a number of things:
•	First, that it is easier to record static things than people as is demonstrated by 762 visits recording vehicles but only 675 recording people.   Tents are easy to record and so their numbers and, by extension, the numbers of people camping are easier to count than the numbers of day visitors and overrepresented in the statistics.
•	Second, the data shows that the numbers of ranger visits that encounter a tent are small, 130 out of 1395 visits – less than 10% of all ranger visits – as are the number of tents.  Indeed out of the 24 sites monitored on west Loch Lomond just eight had tents recorded on 9 or more occasions and these accounted for 89 or over two thirds of the 130 records.   While the Park records include Balloch and Lomond shores, where camping is unlikely, there were far fewer ranger visits to these sites and removing them from the data hardly affects the overall picture.  So the data shows that the level of camping is low and it appears most of the camping which does take place is concentrated in seven locations.    
•	The maximum column shows that the maximum number of tents recorded in a single location was 8.   Only six sites had a maximum of five or more tents, and the total of the maximum numbers recorded (which is unlikely to have taken place on the same date) was 71 tents across 24 sites or an average of just three tents MAXIMUM per site.  Four of the six sites where a maximum of 5 or more tents were recorded also number among the eight sites where tents were most frequently recorded:  Rubha Ban, east Loch Long, Suie Field and Duck Bay.    Some of the groups of 5 or 6 tents are likely to be Duke of Edinburgh Expeditions e.g for Glen Douglas there was just one occasion when tents were recorded and 5 tents on that occasion and this was likely to be a DofE expedition as they use this area.  Unfortunately, the Park’s database provides no information as to why people are camping and its impossible to tell if some of the other maximum numbers recorded are a result of expeditions. (The DofE uses the lochs for for canoeing expeditions, as it made clear in its response to the Your Park consultation, and their practice is wherever possible to inform landowners beforehand about camping plans).
•	In terms of size of groups, there was one significant exception to this, in another year, 2012, when at Duck Bay 260 tents were recorded.   This is important because there is a widespread local view that campers are a problem.   While the data does not support this it seems likely that one-off events like this stick in people’s minds.   
•	Because the data collected by the Park is entered discretely, without relationships given, it tells one nothing about the origins of litter for example, whether this was from a camper, vehicle or day visitor arriving by some other means.   The data does appear to demonstrate however that there is no simple relationship between issues such as litter and the numbers of visitors, campers or vehicles.   Thus 7 bays northbound records 6 occasions on which bags of litter were collected but not a single camper – almost certainly the litter here came from vehicles.   Conversely, at Aldochlay, there were 66 visits which recorded vehicles but only two where litter was collected.  To explore the relationship between litter and visitors further one would need information from other bodies that may collect litter at these locations, such as local litter picks or Luss Estates.
•	The data for Suie field is interesting because we know from LLTNP coverage in 2010 that there had been problems in this location for some time: http://www.lochlomond-trossachs.org/looking-after/national-park-black-spot-litter-blitz-03/12/2010/menu-id-522.html  This article states “It was agreed that Rangers would clean up the site and Luss Estates would take robust measures to prevent vehicle access in the future” and that “The final tally for the day came to over a ton of litter including 55 large black bin bags, 25 bags of metal cans and 63 bags of glass bottles as well as curious items including a ceramic toilet”. The article says this litter probably had accumulated over a period of two years and attributes this to camping.  It seems clear that prior to 2010 vehicular access had been fundamental to the style of camping that occurred at the site and according to the articule that Luss Estates had done nothing to prevent vehicle access.   While the Ranger data sheets indicate bags of litter were collected on ten occasions in 2013 its not clear if Luss Estates also collect litter from this site and therefore whether the litter problem has improved or not.   Luss Estates is in receipt of significant public subsidy and employs its own rangers and its unclear why the Park therefore still patrols this site and picks up litter on behalf of the estate.  The data sheets indicate that out of 81 visits, 62 recorded vehicles and 16 tents.  It would appear therefore that Luss Estates have not prevented vehicular access as they stated they would in the articule.   It is therefore unclear how far the litter now collected from the site comes from campers as opposed to day visitors.
•	The locations do not include all places that people camp and indeed do not record problems in all known hotspots.   The notes of the Luss Community Council Meeting on 24th April 2014 attended by Bridget Jones of the National Park (FOI 2015/46 Appendix B meeting notes) states “Community Council members confirmed issues at quarry, suggested less issues last year, but impacts are high especially on residents nearby and visitors using the paths” and “Agreed numbers not high but impacts of a few were very significant”.  They asked for more ranger and police patrols.   Interestingly members of the Community Council stated that Luss commercial campsite “can be limited and selective with who is allowed to camp” and suggested a potential new campsite at Firkin Point.
•	The locations also do not seem to record traveller encampments which take place in the area and may be in situ for weeks or months.
•	While the data does not tell us who is camping or for how long, it would appear that most camping visits to these sites are short-term (otherwise tents would be recorded on a far greater proportion of ranger visits). 
•	While the evidence from Luss Community Council is that at the quarry there were links between camping and anti-social behaviour and that specific sites such as Suie Field were used in the past for outdoor parties, the Ranger data gives no indication of which sites are used for this.   While the Police also report data in Operation Ironworks for south Loch Lomond this is not location specific.   In 2013 they reported 92 public drinking offences, 21 urinating in a public place, 32 Breaches of the Peace, 1 vandalism, 2 littering and 13 people fishing without a permit.   It is unclear how many of the drinking places were in Luss where there are alcohol bye-laws and how many in Balloch.  To put this into perspective there were 62 Fixed Penalty Notices for driving offences and 32 individuals found in possessions of drugs.  The figures do not distinguish between offences caused by residents or locals and those by outside visitors.
Implications of the data
The main things the data tells us is that there are relatively small numbers of people camping along West Loch Lomond in scattered locations.   The implications of this are:
i)	Camping is a relatively minor activity, and 'environmental' impacts arise from activities other than camping and occur whether tents are present or not.  The presence of people and vehicles are likely to be a much more reliable indicator of 'visitor' pressure than tents. 
ii)	The numbers of campers at present will NOT in themselves support new commercial or self-financing campsites.  This is not to say new commercial campsites would not be financially viable, but they will need to do so by attracting NEW visitors as at Beinn Ghlas Farm.
iii)	The LLTNP has justified its bye-laws mainly because of what it claims is massive pressure from campers.  It appears clear that on the majority of sites along west Loch Lomond there is almost no camping pressure and even in the most popular sites, numbers camping are low compared to day visitors.   This strongly suggests that camping should be considered within a wider context of visitor management – as originally proposed but then lost in the Your Park Consultation.
iv)	The LLTNP needs to take another look at infrastructure to support day visitors and campers.  While the lack of litter bins along the A82 is well known, consideration needs to be given to visitor messages and education (eg please take your litter home) but also other camping specific facilities (whether proper places to park off road or maybe compost toilets in the woods which landowners could provide to anglers but would not be advertised to the general public).
v)	Any facilities designed to accommodate the requirements of static campers dependent on vehicles would not adequately accommodate the needs of peripatetic outdoor activists who probably constitute a very small number of people whose impact if they camp as permitted by the Access Code would be negligible, and probably almost invisible.   There are also some people travelling by car or campervan, eg who pull off into laybays to sleep the night, who come into this category.
vi)	In relation to revellers (and much revelling and antisocial behaviour may be a consequence of day visitors as much as campers who come out for barbecues in an evening for example) local people should not have to tolerate this (as at Luss quarry) but the cost of providing for the foreseeable impacts is not high and site specific solutions should be quite possible without the need for bye-laws.  A camping ban is simply likely to drive revellers elsewhere – as it appears to have done after east Loch Lomond – and its possible that basic campsites, as proposed by the Park, if properly policed, could allow partying to be managed without detriment to others (e.g by providing litter collecting facilities and toilets but fining people who do not use them).  There is a precedent for this at Sallochy which according to the Park used to be the worst of all east Loch Lomond sites and where the FCS campsite works well.  Given the small number of tents and even smaller “anti-social” element, its probable that just one or two such campsites would enable the problem on west Loch Lomond to be managed without affecting the rights of others.

 

Appendix 1 Section 3b) of “Report on the Your Park Consultation Process and Critique of proposals”

What is the evidence of problems associated with camping in the National Park?
The lack of any conceptual or analytical framework means that the data the LLTNP has related to camping is almost worthless.  Its Rangers record on their patrols the numbers of people, dogs, vehicles, tents, fires, information given out and bags of litter for specific sites on their patrol rounds.  It is totally unclear what these provide evidence of because the relationships between the data is not explained:
i)	The data is provided discretely for each data category so, for example, there is no means of telling if the bags of litter picked up or fires observed relate to camping or day visitors or whether this is unknown.
ii)	The data analysis headings for “minimum”, “maximum”, “normal”, “busy” and “peak” appear to be automatically  populated only if a positive number is entered from a patrol for a particular data category such as number of visitors.  The result is that if no record is entered under a category on a particular patrol, e.g. no litter is observed, this is discounted in terms of the data analysis headings.   So, rangers could make 50 visits, on 49 of which no litter was recorded but if they collected 6 bags on one occasion this will be recorded as being the “normal”, “busy” and “peak” level of litter.  Its clearly only the “peak” level and not normal.  To illustrate this  for Glen Douglas, sheet 21, for example over 2011-2013 there were between 28-33 visits by rangers but under the data category of tents the record shows minimum, maximum, normal, busy and peak numbers being exactly the same 2 for 2011, 0 for 2012 and 5 for 2013. What appears to have happened is that tents were recorded on two occasions over three years but because the data feeds through to each category, the maximum/minimum numbers are meaningless.  Because of this flaw it is impossible to provide any sound analysis of the LLTNP’s data.
iii)	In addition the data does not indicate why people are camping (e.g. according to the SNH classification) so one cannot tell how long the tents observed have been in place (whether overnight or a week) or by whom (backpackers, fishermen etc).   The result is the LLTNP has no evidence on which to plan.
iv)	Furthermore FOI 2015-25 shows that since Rangers do not record for how long tents have been there it is impossible for the Park to identify where there are problems of encampment, which is outwith the SOAC, and what proportion of campers are staying within the SOAC guidelines that stays of 2-3 nights are within access rights.
v)	Furthermore, the data does not provide any information about the impacts of people camping e.g. in respect of fires, whether the camper has brought wood with them, whether it is in a barbecue or fireplace or whether its live wood chopped from a tree.    None of the problems the LLTNP has claimed are associated with camping apart from litter, i.e. erosion of ground, chopping of wood and disposal of faeces are even recorded in the data base and as stated above there is no means of linking litter to campers rather than say day visitors.
As Friend of Loch Lomond and Trossachs stated in their response to the Your Park consultation there has been no proper analysis of the evidence.  
Yet, the LLTNP did commission some proper research in 2007 about camping and impacts and in the absence of any other evidence to the contrary, its findings are still relevant.   It found most of problems associated with camping were linked to people camping close to their cars and who had been abusing alcohol.   It found these people are in a very small minority.   This view is shared by many other people e.g. in the note of the LLTNP meeting with Loch Lomond Fisheries Trust during the Your Park consultation.