Next Monday the Loch Lomond and Trossachs National Park Authority will be asked to approve its third Annual Update Report to Scottish Ministers on the camping byelaws and a revised Outdoor Recreation Plan for public consultation (see here for meeting papers).    I will take a critical look at the the content of these Board Papers but in this post will take a look at the priority the LLTNPA is giving to access and Outdoor Recreation.

 

Access, the much delayed Outdoor recreation plan and the camping byelaws

One of the four statutory aims of our National Park Authoritiess is “to promote understanding and enjoyment (including enjoyment in the form of recreation) of the special qualities of the area by the public”.   While the driving force behind the creation of the Cairngorms National Park was conservation, Loch Lomond and the Trossachs was designated as a National Park because of its importance as a recreational resource, particularly to people living in the Clyde conurbation.

It tells you something about how the LLTNPA has been performing therefore that its last Outdoor Recreation Plan ran from 2012-17.    The new plan will run, at the earliest, from 2020.  The three years between the two plans has been occupied by the LLTNPA’s attempted implementation of the camping byelaws.  That is not a coincidence.  As Parkswatch has long argued, implementation of the the camping byelaws have consumed excessive amounts of resources (for very little gain) at the expense of almost everything else.   While the LLTNPA has been pre-occupied with policing campers – another 735 names taken this year and 8 referrals to the Procurator Fiscal – work on promoting the public’s ability to enjoy the countryside has suffered.

 

The prioritisation of access by the Audit Committee

You don’t need to take my word for wider recreation work having suffered.  The Report which the Park’s  Audit Committee considered earlier this week on outstanding actions (see here) demonstrates how work by the Access and Recreation Team is well behind schedule:

This is not the fault of the Access and Recreation Team.  They are clearly under-resourced.  While the LLTNPA has been pouring resources into the policing and management of the camping byelaws it has been neglecting the basics.  Among other things, this mis-application of resources by the Board and senior management helps explain the failure by the Park to develop basic infrastructure including paths (see here for example on the core paths network)

Note how the Audit Committee has assessed this failure to deliver on access and recreation as “LOW risk”.   Instead of being seen central to what the LLTNPA does and a crucial indicator of its success, access and outdoor recreation are being treated as a side issue, something that no longer matters.  That should be prompting our politicians to demand a fundamental review of how this National Park is operating.

 

What wider audit work shows about the priorities of this National Park

Reading the papers to the Audit Committee, I was struck by the wider mismatch between what staff are being asked to do and the statutory purposes of the National Park.

I didn’t know the LLTNPA had bomb threat procedures – its turns out they were developed earlier this year and then subject to a review by West Dunbartonshire Council who conduct internal audits for the National Park:

What, one might ask, is the risk of any of LLTNPA building being subject to bomb threats and why is a separate procedure required?  Why couldn’t general evacuation procedures (for fire etc) be adapted?  What does it say about priorities and wise use of resources that while the LLTNPA was being looking at bomb procedures on its own property, people living around Loch Katrine were very lucky not to lose their lives as a result of the serious landslides there?  The point is that climate change and environmental degradation pose a far far greater risk to people than bomb threats yet there is nothing about the Park’s failures to act and address those issues in the papers to the Audit Committee.

This lack of focus on what should be the core business of the LLTNPA is also illustrated in the paper from Grant Thorton, a US based firm and the Park’s external Auditors, who are appointed by Audit Scotland:

Note the third requirement for information sharing.  Why on earth would Grant Thornton need to share knowledge about the LLTNPA Board to share intelligence gathering across health and social care agencies?    The answer, I believe, is that you open the Grant Thornton  Audit Paper  up comes the title:  “NHS Dumfries and Galloway External Audit Plan for the financial year ending 31 March 2019 Audit and Risk Committee XX November 2019 [DRAFT]”!

This is a firm that claims to be innovative and to shake up the status quo (see here).  The truth appears to be they are a firm that cuts and pastes documents and applies them to different Public Authorities without any thought about whether this is appropriate or not. The external Audit of our National Parks is not fit for purpose and the Scottish Government should not be tolerating this or allowing public money to be paid to such firms.

Still, its re-assuring that Grant Thorton have highlighted money laundering and fraud as a fifth working area for the year.  Back in January the former Chief Executive of Grant Thornton, when questioned by the UK Parliament’s Business, Energy and Industrial Strategy Committee on the collapse of Patisserie Valerie  said it was NOT their role to uncover fraud (see here).    Perhaps they have done a U-turn but given this record I find it hard to have any faith in the external audit process in the Loch Lomond and Trossachs National Park.

Unfortunately, it appears the LLTNPA’s senior management would prefer this audit farce to continue rather than having to start addressing the issues relating to access and conservation which are the ones that should really matter to a National Park.