Forest Drive has miraculously re-opened after my post last week (see here) which revealed that the Loch Lomond and Trossachs National Park Authority had only opened 192 out of the 300 plus camping places it had promised to Scottish Ministers for the start of the camping byelaw season.

In permit area Q, for example (see above) there are now ten camping places advertised as being available, when just a week ago this area was closed until Sunday 15th March:

Campervanning places on Forest Drive have also be re-opened.

I am not sure when the closed permit areas were re-opened, as I did not check until yesterday evening, but I had copied to the Minister, Roseanna Cunningham into a complaint that I submitted to LLTNPA Convener, James Stuart, on 3rd March.  With Ministers due to review the camping byelaws, I expect LLTNPA officers acted pronto!  Meantime they have not even had the decency to acknowledge my complaint.

The problem, however, has still not been fully addressed.  Four permit areas at Firkin Point are still not available for booking and there is no information on the permit booking system about when they might “re-open”.

With the Sallochy campsite still not due to open until 12th March and the Loch Achray campsite advertising a restricted number of places, I suspect the LLTNPA has still failed to meet its promised 300 plus places to Scottish Ministers.

This could have been an opportunity for the LLTNPA to admit that whatever the arguments are for the camping byelaws, there was NEVER any justification for them in March or April.  When approving the camping byelaws, the Scottish Government Minister Aileen McLeod decided they were not justified in October because the numbers camping then were so low. She reduced the “season” the LLTNPA had proposed from 1st March until the end of September.  The LLTNPA’s own data, however, showed there were even fewer campers in March than October!

The small numbers in the Spring is no doubt why the LLTNPA and Forest and Land Scotland thought that this year they could get away with not opening all the places from 1st March as promised.  This though vicitimised anglers, for whom March is a key time of year, by making it impossible for them to camp lawfully at places like Loch Drunkie.  However, instead of admitting to Scottish Ministers that they have got anything wrong or that any aspect of the byelaws needs to change, LLTNPA officers have just recommended more of the same in the 3 Year Review Report which they are presenting to their Board for approval on 16th March (see here).

I will consider the Board Paper more fully in a further post, but it does also confirm that the LLTNPA breached the first administrative condition attached to the camping byelaws:

4.5 Following discussions with our Scottish Government Sponsor Team, we have received authorisation to submit the final report to Ministers following the March Board meeting, which is slightly after three years of implementation, as referred to in the first administrative condition.

This is being economic with the truth.  There was no mention of any need for such an authorisation at the December Board Meeting which decided to consider the 3 Year Review Report in mid-March in breach of the Ministerial condition.   What this belated authorisation tells you  is that LLTNPA’s Chief Executive cares not a jot about due process.  Starting the fourth year of the camping byelaws BEFORE their Board or Scottish Ministers have had time to consider the 3 Year Review clearly prejudges the outcome of that process.  Unfortunately, the Board appears too weak to challenge their Chief Executive on this (or anything else for that matter).  I have therefore written to the Minister responsible for National Parks, Mairi Gougeon, bringing this to her attention and asking her to allow time for the public to respond to the Review Report before taking any decisions.

Outdoor Recreation Plan delayed

On Friday I received an email (see here for text) as a respondent to the Outdoor Recreation Plan (ORP) consultation.

This email states that the ORP will  now be considered at the June Board Meeting.  At their December meeting, the LLTNPA Board decided they wanted to finalise the Outdoor Recreation Plan in March and REJECTED any extension to the consultation – launched over the Xmas period – because of this.  So, another U-turn!

Its hard to see why this delay is needed IF the following statement in the email is  true:

“85% of responses were positive about the overall direction of the Plan and consequently it is not believed that significant changes are required for the final draft.”

If true, all that would be needed would be a few tweaks here and there and that surely could have been done in six weeks?

I have been in touch with several individuals and organisations, however, all of whom had expressed SERIOUS concerns about the ORP.  Indeed, the update paper for the Board Meeting next week provides an analysis of the on-line responses (not the paper ones).  This hardly shows an 85% positive response rate:

 

The key issues are not the responses to the vision statements, which are the usual fine words that could mean anything (though its interesting that only 71% agreed with the vision for coasts and waters), its the responses to the focus areas and delivery principles, the things that made the document just another policy development rather than a real plan (see here).

Given that its unlikely that Forest and Land Scotland, SNH, local councils or other public authorities  will have expressed any objection to the focus areas and delivery principles which commit them to do precisely nothing , I suspect levels of concern from those free to speak out was fairly high.  We will find out in due course when the responses are published (or obtained by Freedom of Information requests if necessary).

The update report to the Board (see here) does acknowledge that “several important topics emerged” through the consultation – like Outdoor Centres and Visitor infrastructure!  Lets hope that frontline staff working on the plan are now allowed to add some meaningful content and commitments.   A further three month delay in the plan (already three years late due to resources being diverted to the byelaws) could be justified but only if it results in a commitment to some meaningful actions.  Unfortunately, that seems unlikely to happen because by recommending to Scottish Ministers the byelaws continue as they are, the LLTNPA is effectively committing to divert resources from where they are really needed.