I attended the special Park Board Meeting that approved the camping bye-laws on 27th April 2015 along with three people from the Loch Lomond Association http://lochlomondassociation.co.uk/. The business took well under an hour and 5 minutes of this was taken up with telling the three of us we were not allowed to say anything – the Park was sufficiently worried about us that they had called on their very own police officer to attend the meeting. There was then a presentation on the outcome of the consultation, about which not a single critical question was asked, followed by less than 15 minutes of discussion. I had not attended a Park Board meeting before and was shocked – I felt like rather like someone who had just witnessed Stalin holding a show meeting of the politburo in public. Luckily, in this country we still have some rights so I started to submit Freedom of Information requests about how the Park Board operated.

There were just three public Board Meetings that discussed visitor management or the proposed camping byelaws. The first, in December 2013, was about Visitor Management in general and while it referred to camping and the east Loch Lomond byelaws, also discussed a ranger of other issues. The second in October 2014 was to approve the Your Park consultation, which started the following week, and which focused entirely on new camping places and byelaws . The third was the meeting on 27th April 2015.

The Park provided me with a list of meetings involving Board members that had discussed the Your Park proposals at the end of May FOI 2015-021 Response Appendix A – meetings that discussed ban

This included ten “board briefing sessions” and seven strategy group meetings. I have been trying to get information about what was discussed in these meetings ever since using Freedom of Information Review and appeals processes and, eight months later, have had my first success with the release of the Strategy Group Minutes. (The Strategy Group, which is not mentioned in Board standing orders comprises the Park Convener, chairs of the two committees that operate in public – planning and audit – along with the Operations Group which does not and senior staff). The minutes, to which I have pasted comments, tell an interesting story FOI 2015-021 response Appendix A Strategy Group notes NK comments

They tell us that Board Members started to discuss camping management in August 2013 and there were two “briefing sessions” of the whole Board which discussed camping before the public Board Meeting of December 2013. This is much earlier than the Park had previously admitted – none of these meetings were listed in the Park’s initial response to my information request.

The implication of this is that the Visitor Management paper presented at the Board Meeting in December 2013 was a front to conceal the Board’s real agenda, which was to ban camping. This would also explain why no other visitor management proposals were developed for the Your Park consultation. There is further evidence for this in the Strategy Group minutes, which show that while by May 2014 the Board had decided it wanted to introduce new byelaws, at the meeting in August 2014, Gordon Watson the Chief Executive stated “When discussing the project with third parties, reference is being made to visitor management options, rather than focusing on the proposed byelaw.” I know that the Park met with Dave Morris and Helen Todd from the Ramblers Association that month and gave them NO indication they were considering camping byelaws. The minute shows this was clearly deliberate.

The second revelation from the minutes is about involvement from Scottish Ministers. In August 2014 – two months before the the byelaw proposals were made public – the strategy group minutes records that “The Chair highlighted there is strong ministerial support for the Your Park visitor management proposals, although raised some concerns relating to the project timeline outlined in the papers”. The indication is that Ministers wished the Park to proceed more quickly: “Chair to ensure that the Minister is kept updated with our progress in correspondence with the revised project time”. Then, in January 2015 the minutes record “GW advised that he is meeting with the minister on the 5th February 2015 and will seek to reassure the minister at this time on the Your Park project”. The main reason the Minister would need re-assuring was if the outcome of the Your Park consultation had not delivered the result that had already been agreed, whether tacitly or explicitly, with Ministers. The majority of respondents to the consultation were against the proposals, and the Park’s analysis totally flawed, as I showed in Appendix 2 of my Report on Your Park consultation process and critique of proposals 150618 (corrected version) The minute suggests that the Park’s flawed analysis was no accident.

There are questions therefore about how far the camping management byelaw proposals were initiated and driven by the Board Strategy Group and how far by Scottish Ministers. What is totally wrong though is that Scottish Ministers, who are supposed to act as independent and final arbiters on proposals to restrict, appear to have made up their mind well before they formally consulted on the recommendations for camping byelaws made to them by the Park.

In a decent world, there would be a full inquiry into what has been a thoroughly corrupt process but, unless there is legal action, I expect the best we can now hope for is that the full truth will eventually emerge through Freedom of Information requests to the Park and the Government. Meantime, there is no justifiable reason for LLTNP to conduct so much of its business, whether its about removing rights or anything else, in secret. The Cairngorm National Park Authority operates far more transparently http://cairngorms.co.uk/authority/meetings/ and provides a clear benchmark by which to judge the way the LLTNP Board currently operates..