I have been trying since the summer to obtain copies of the “Land Management Plans” which the Loch Lomond and Trossachs National Park claim to have agreed with certain landowners (my appeal is with the Scottish Information Commissioner). The content of these plans seems to me important for understanding how far the LLTNPA are getting landowners to manage their land according to the National Park’s statutory objectives. A couple of months ago however I realised that the Review of the National Park Partnership Plan for 2013-14 (extract above) claimed the pilot phase of these plans had been evaluated. I assumed from this statement that there would be some sort of evaluation report of these management plans, which might even say what progress had been made in achieving National Park objectives, and so submitted another information request. I received this response a month ago:
This appears to confirm that the pilot was evaluated BUT the information provided EIR 2017-071 evaluation land management plans Appendix A consists of extracts of reports given to the National Park’s Delivery Group (which oversees progress against plans) and reference to Board updates. There is nothing that remotely resembles an evaluation. The nearest any extract gets to this is one which says “lessons have been learned” but without saying what!
I wrote to the Park’s Director of Conservation last week and asked if an evaluation report existed, yes or no, and so far have not had an answer. LLTNPA senior staff appear to find such questions, which are about truth, not spin and marketing, difficult to answer. Meantime, staff appear to have mislead both the Board – not the fault of the current Conservation Director, it was before his time – and the Minister.
Our Public Authorities talk a lot about values but when listing these, I cannot recall “truth” ever being mentioned. Yet a commitment to truth should arguably underpin everything else our National Parks do. Unfortunately, as with other Public Authorities, our National Parks have been under pressure to reduce spending while telling the world everything is going wonderfully and they can keep doing better on less. Its been very hard in these circumstances for Boards to retain a clear eye on the truth. What starts as spin and omissions, eventually becomes totally detached from reality and ends up a lie – little different to Donald Trump but said more nicely. The claim in the Review of the National Park Partnership Plan to have evaluated the land management plans pilots – exactly what the LLTNPA should have been doing by the way – is just one example.
While I can understand how things might have gone wrong in this way – I have been there myself – this is no longer about isolated instances (the Review Report for Ministers on the Camping Byelaws (see here) is a case in point). I am not sure how far Board Members appreciate this – there is far too little questioning of senior staff – or how the LLTNPA is losing its reputation for probity, but they need to start putting truth and facts back at the centre of everything the LLTNPA does.
Meantime, the Information Response does reveal the names of the handful of landholdings with whom Land Management Plans were agreed, Portnellan, Benmore Farm, Loch Dochart and Inverlochlarig (which form a geographical block) bloand that a contractor was appointed to provide them with advice on renewables. That raises some interesting questions about what advice the LLTNPA was giving on the landscape impact of hydro tracks – which it acknowledged at the last Board Meeting was an issue – and is even more reason the information in the land management plans should be made public.
Thanks again Nick. You are on the right track here. The NP Planning Dept. refers to “material considerations” in the planning context. That suggests material facts and evidence “EXIST” on paper and that is the truth. When I’ve objected about the pontoon moorings I am talking about the sensible and tangible R. Leven and WHERE IT EXISTS. That is not on paper or between my ears. My head might be big but it is not that big. This has plagued me all along…the subject shifting from my experience on the river to their paperwork. With WDC as well. Likewise, given adequate research in the field about the conditions and the state of naturalness, written up I would be able to detect some resemblance between fairly scientific papers and what exists on the outside and their relevance. But that has just not happened in my experience.
Fortunately, I have a good formal example of what this means in practice. That is FOI…Decision 081/2011 Mr James Graham and Loch Lomond and The Trossachs National Park Authority Pontoon Moorings on River Leven Ref No. 201100110 Decision Date: 21 April 2011 Ultimately what “material evidence” and “expert advice” means is what the NP says…even when they have failed to demonstrate it’s existence or it’s relevance on the outside. Post truth, indeed, and they invented it.
LAND MANAGEMENT PLANS. As you saw with the last Local Plan Inquiry the planners have a problem with acknowledging the fisheries as a registrable interest in land. That’s twice the NP have ignored the Inquiry I did win against WDC, to have the fisheries explicitly mentioned in the Local Plan. These LAND MANAGEMENT PLANS should also cover fisheries. For nearly 20 years now they have been going on about integrated catchment management/river basin management planning…and they still can’t hold a conversation about fisheries. Only on the River Leven. The rest of the Scottish salmon fisheries are light years ahead in terms of standards. I was a member of the Tweed Foundation. WDC/NP wouldn’t be allowed near the Tweed. They will never admit it but they just won’t give me more grounds for objecting against the boating interests and the canal plans. But they will go flat out for Flamingo Land. The priorities for a NP are completely upside down. We should be investing in and developing productive green industries and green technologies and skilled jobs. £100’s of millions later we’ve got more shops, a clown fish aquarium and Flamingo Land. They lost their marbles a long time ago.
Thanks James, very interesting on fisheries and I accept point they should be in land management plans. If I win the appeal to the Information Commissioner it will be interesting to see what the Dochart Plan has to say about fisheries given its on the Tay Special Area of Conservation Nick
Thanks Nick. Alex, I recall, of the Tay Liaison C,ttee, was on the NP Fish and Fisheries Forum. The TLC is connected to the Tay Protection Order (a fisheries provision). That covers the Dochart. Make sure to keep the existence of A) The Fisheries Interest…..and……B) The Natural Heritage Interest, e.g. SAC’s…distinct. A source of general NP confusion and ignorance. They are closely related in practice, the fisheries exploit the natural resource, but the legal/formal provisions, funding and support, are separate. Both Alex and Dr. David Summers of the Tay contributed to the REPORT OF THE NP FISH AND FISHERIES FORUM. At that point the Forum was chaired by Colin Adams of Glasgow Unis Field Station and was informed by some of the most eminent scientists in the Scottish salmon and freshwater fisheries. That took about two years to complete and many meetings that went into everything in detail. Years later I can still remember what the top priority was without checking…..THE LACK OF DATA. How we are supposed to have “evidence based management” without data I still don’t know. That report was shelved before the ink was dry. The local community have been deprived of their interests in land for centuries and what you have lost you don’t know how to value. Hence, the common fall back into the default position….jobs. That will be jobs in the Stone Age at this rate. As always I use these campaigns as a platform to remind people about how the politics of power and control shape their lives.
I’m trying hard to understand why the NP wouldn’t, by default, want to be open about how it works and how it engages with stakeholders. What motivates it to behave like this? Most public bodies operate in an “open by default” way. I fail to see where a “commercial sensitivity” defence might be applied (if that’s the usual excuse) as the NP landowners are mini monopolies – who competes with them? So why would any information relating to how the NP engages with them possibly affect them commercially, were it to become public…
Andrew. You are asking a question a lot of people, public and private, have been asking for a long time….which is about how difficult the NP is to work with. Nobody knows why that is. For example, I was on the NP Fish and Fisheries Forum for over ten years. All of the work of the Forum was/is in the public domain…unless they have deleted it. Most of the Forum members were in the private sector. The rest were public servants and I was a sole ordinary member of the public. There was no problem if a private member had private business to discuss with the NP. They could raise that outside of the Forum meetings. So long as everyone observed some fairly common courtesies and respect you might think, what was wrong with that arrangement? Well I can’t speak for the rest but I felt the Forum was ignored and our time was wasted….which is even more galling when you consider it was the NP who set it up in the first place and created the impression that there was some productive collaboration going on. I was certainly not alone feeling let down….for no reason and without any explanation. Some of the most eminent scientists on fish and fisheries in Scotland were members of that Forum…free of charge. I think they are running something more akin to a cabal than a National Park. I doubt we’ll ever find out what the reason is for their attitude problem. They are just very disagreeable and uncooperative people.