A parkswatch reader recently sent me this photo of an unattractive development on the bonnie banks

The two new lodges were originally granted planning permission by Loch Lomond and Trossachs National Park Authority (LLTNPA) planning staff in April 2018 with work required to commence within three years (see here for planning papers).  The planning deadline was, however, extended by the Covid emergency legislation and the building work only completed last summer. The planning approval therefore preceded the new national planning policies set out in National Planning Framework 4.

Those new policies make it much harder to erect new buildings in areas at risk of flooding, such as loch shores, and were the main reason the LLTNPA refused the Flamingo Land development in August (see here).  Floor risk, however, was not even considered in the officers report for this planning application despite the obvious risks.

The water level in Loch Lomond varies by around 3m and it is not difficult to envisage the lower floors of these lodges flooding when the loch is high and when the wind is blowing as it was eight days ago:.

Such conditions drive up risks and insurance premiums and can turn assets into liabilities, hence in part the new rules on building in areas at risk of flooding in NPF4.

There was just one objection submitted to the planning application which raised a number of points and to which officers responded as follows (my underlining):

• Over-development of the site – the site is constrained however the proposed design, arrangement and finish of the two additional lodges and the alterations to the existing lodge are of a high quality, sympathetic design and will create a cohesive, attractive building group complemented by remedial landscaping works to create a much improved naturalised setting.

Comment.  How is any of this development sympathetic to Loch Lomond?  While claiming the development would create a “much improved naturalised setting” the report, without a hint of irony, describes “excavation work to level more of the ground on the loch shore with steel sheet piling retention walls (as existing and which weathers (rusts) to a natural red brown colour)” and “installation of below ground foul drainage treatment plant with partial soakaway”.   Effectively the claim is that development is making nature more natural.  Pure parkspeak!

• Negative impact on the natural environment including removal of trees – a full tree survey and detailed landscape proposal were submitted and the proposed loss of four trees which are in poor condition will be amply compensated for by the removal of most of the Rhododendron Ponticum from the site and a comprehensive native species planting proposal including trees, woodland ground cover and new shrub beds

Comment.  Given the regeneration capabilities of rhododendrum, removing “most” of it is pointless and its likely to overrun the site just like the sitka which can be seen spreading over the hillside above  .

• (Lodge 2) too close to the Jetty Lodge giving rise to noise, disturbance, overlooking issues – in common with those existing (Jetty Lodge has a sunroom and extensive decking to the front), the proposed lodges maximise views of the loch with predominantly glazed frontages and lochside decking.

Comment. The value of the view from the loch, for those who boat or swim, or of the loch shore to the general public is simply not considered.

 

The objector did not apparently comment on more detailed design issues buts its interesting to compare what the planning report claimed about the design with the photos above:

“Lodge 1 would sit alongside the existing lodge mirroring the form, massing and footprint (57 square metres) but with a contemporary finish: slate roof, slate clad side elevations and zinc vertical standing seam cladding to front (lochside) and rear. The natural, darker materials with minimal eaves and verge detailing are intended to make the new lodge appear subservient to, or ‘ a shadow of’, the existing lodge ………………The proposed new lodge (1) would thus be linked by a new shared covered raised entrance area and have matching decking on each side, which extends slightly forwards of the respective lodges, to enhance the building line and visually tie the twin lodges together.”

What the photos show is that far from Lodge 1 appearing darker and “subservient” to the existing lodge, it stands out even more prominently.

The planning report goes on to claim Lodge 2 would be of “similar size and form” and  “extend in line” with the existing lodge, whatever that means:

“Lodge 2, on the site of the existing laundry / woodstore (southern end), would be similar in size and form but with a ‘fold’ (90 degrees, like the prow of a boat) in the main gable elevation facing the loch and entirely clad in zinc with grey aluminium clad timber frame windows. The front fold would be mostly glazed and access to the lodge would be via a new metal staircase (south) from the upper level path to a deck that would extend 3.5m forwards and across the full frontage (7.9m wide) and ‘pierced’ in the middle by the folded front gable, with steps down to the loch side. Lodge 2 would sit further back on the site and extend in line with the existing lodge.

Actually, the two buildings look very different.

The report goes on to claim that the associated landscaping work will compensate for all this development on the shoreline:

“In landscaping terms four poor quality trees would be removed and, apart from one area where they form a useful dense hedge between the road and first section of the path to the lodges, the site will be cleared of the invasive Rhododendron Ponticum and cherry laurel and replanted with appropriate native species including four trees (yew, rowan, wild crab apple); native woodland ground flora and mixed small trees and shrubs in new planting areas on the loch side and further back in raised beds; and a new mixed native species hedge on the roadside beyond the fenced inset parking area. Once established the proposed planting would significantly enhance the existing loch fringe woodland, ecology and the visual appearance of the site.

This is a good example of planning greenwash.  Building of lodges or any other accommodation on the shoreline like this destroys “loch fringe woodland ecology”.

As I have explained before there is significant development pressure along the shoreline on the southern half of Loch Lomond (see here): Tarbet, the Cameron House extension, Flamingo Land, the Tom Hunter Leadership Centre at Ross Priory, Kirsty Young on Inchconnachan were/are all about developers wishing to enable (mostly rich) people to buy exclusive views/access to the shore with no regard to others who enjoy the loch.

There are similar development pressures on shorelines all over the world but Loch Lomond is in a National Park which was set up to enable the people of Scotland to experience its special qualities. Instead, the LLTNPA has been turning it into the preserve of the few through the planning system and wrecking it in the process – the Duck Bay development is just another example.

While the extension of the areas around Loch Lomond now deemed to be at risk of flooding under NPF4 may help spare some undeveloped areas of the shoreline, what the LLTNPA needs to do is to preserve the bonnie banks commit to protect the whole of its shoreline from new development.  This would mean any new development by Loch Lomond, including at Balloch, being set well back from the water so it doesn’t affect the ecology or the landscape.

With the LLTNPA having started the process to prepare its new Local Development Plan it has an opportunity to show a lead for a change, accept that giving the go-ahead to developments like the Auchenhenglish lodges were a major mistake and adopt a strong policy presumption against any new developments on the loch shore.