I have been asking the Loch Lomond and Trossachs National Park Authority what criteria it would use to decide the planning application it is making to itself for a campsite at Loch Chon. Among the issues is that the Your Park proposals to develop new campsites is not consistent with the Park’s proposed Development Plan (see here) Just over two weeks ago I received this reply which is far from clear:
“With regards to your request for advice regarding the determination of the planning application for Loch Chon, this will be determined in accordance with the development plan, taking relevant material considerations into account, as is the case when determining any planning application. The Adopted Local Plan and the Proposed Local Development Plan, which will eventually replace the current adopted plan (following the outcome of the current examination and including any modifications required by the Reporter) can both be found on our website.”
My guess is that in saying any planning application “will be determined in accordance with the development plan” the LLTNPA are referring to the Adopted Local Plan NOT the Proposed Local Development Plan and I have asked the Park to confirm this. If so they have wasted money preparing an application which uses terminology from the proposed Local Development Plan (£100k spent last financial year with nothing to show as yet).
Now I can find NOTHING at all about campsites or camping in the current Adopted Local Plan. This is a historic omission which has enabled the LLTNPA, since its creation, to grant planning permission to one former campsite after another to convert to caravan parks or “luxury tourist lodges”. At least the proposed Local Development Plan mentions camping, although its provisions are so unclear and so muddled that it is unlikely it will do anything to help remedy the lack of campsites in the National Park.
The Adopted Plan though does contain policies about developments in the countryside, which are relevant to the Loch Chon Planning application, including:
a) ” Proposals for medium to larger scale tourism development within the countryside will generally be resisted unless there is demonstrable evidence of:
(h) Strong market demand for the development that is currently not being met, and
(i) the benefits that development would bring to the local economy.”
b) A map which shows Loch Chon in an area designated suitable for “moderate increases in outdoor recreation”
The LLTNPA is proposing over 30 places in the Loch Chon campsite – if this is not a medium to large scale development what is? Moreover, the Park’s Ranger records show there is very little camping in the area at present. This suggests there is no market demand for such a large campsiten so it should “generally be resisted”. Moreover if it were to be approved and did create new demand this would breach the Park’s policy on this being an area that is only suitable for moderate increases in recreation.
What’s as interesting is that the policies in the proposed Local Development Plan, as they apply to Strathard and Loch Chon, are very similar to the current Adopted Plan. Its designated an area of “smaller scale tourism potential”. The proposed plan states that recreational developments should be where existing demand is – in other words the Park should only develop larger campsites such as that at Loch Chon where they are needed – and generally says quieter areas of the countryside should be conserved as such. So, the Loch Chon campsite planning application contravenes both the current Adopted Local Plan and the proposed Local Development Plan.
Gordon Watson, the Chief Executive, as the former Director of Planning should have known this but the LLTNPA was desperate to announce it had some plans for campsites when the Minister approved the camping byelaws. The only place the Park and Forestry Commission Scotland – the key partner who was supposed to deliver new campsites – had agreed on was Loch Chon. My suspicion is that the original proposal here was for a much smaller campsite but Gordon Watson was either told or decided to increase the numbers to 30 to make the Park look better. This was despite him knowing it contravened the Park’s own planning policies. The whole proposal has been unravelling ever since and I trust that if it ever goes to the Planning Committee – and their meetings for July and August have been cancelled – members of that Committee will take an objective look at their own policies and do the right thing.
What needs to happen
The sooner the Park abandons the proposal for such a large campsite at Loch Chon the better. The proposed site is great for camping – I was walking with someone at the weekend who had camped there and just seen a couple of other tents – and no-one would object to installation of a toilet and litter bin (for day visitors as much as campers). But the mad ideas of using shipping containers for toilet blocks, trying to get people to camp on wooden platforms and forcing people to camp in designated places away from the lochside just need to be dropped. The LLTNPA needs to go back to basics.
What the LLTNPA should do is create a network of small campsites through the Trossachs. In Strathard there could be small sites (just toilet and tap) at Loch Ard (e.g in the area being considered for camping permits) Loch Chon and Loch Arklet. This would enable cyclists and walkers to make far better use of the path network that was created a few years ago and is sadly underused. Such a network would be totally compatible with the vision of small scale tourism developments in the area which is contained in the Park’s plans.
The £345k allocated to the Loch Chon campsite this year should be easily enough to achieve this. For £10k you could buy and install very high quality composting toilets and if the rest of the money and money current spent on ranger patrols was given to the local community they could invest it to maintain both campsites and manage the impacts of day visitors.
This post crossed with an email from the LLTNPA which clarified: “The application will be determined in accordance with the development plan which currently is the Adopted Local Plan (2011). The Proposed Local Development Plan is a material consideration to the determination of all planning applications which is why I referred to this as well.” This is helpful and shows that it was not a complete waste of money getting consultants to refer to the Proposed Local Development Plan in the planning application. However, if the proposed Local Development Plan is a material consideration that makes it even more important the LLTNPA sorts out the problems with the terminology that it has used in that plan and which is now being considered by the Reporter appointed by the Scottish Government