Managing camping pressures: the real situation on the ground

8

Gordon Watson shares his views

NB: In light of today’s Sunday Herald article by Rob Edwards who has published retired Chief Inspector of Central Scotland Police, Kevin Findlater’s views on the Your Park proposals, I have updated this blog. My updates are highlighted in blue below.

It’s nearing the end of the Your Park consultation and we’re delighted to see the many responses that are coming in, in the last few days of our 12-week consultation aimed at improving the experience on our most popular lochshores.

This consultation looks at two things:

We have made it our priority to make sure the case for change, and the evidence to back up our proposals accessible and easy to understand.  We’ve included case studies of the changes we’ve witnessed in east Loch Lomond and we provided videos to help explain the need for change, our experience on east Loch Lomond and the types of camping provision we’re proposing investing in.

Our full proposals are available to download here and we’ve used this site to break that information down into manageable chunks so that people can respond to our consultation to give us their views.  Where there have been questions or clarifications needed we’ve used this blog, and our Twitter and Facebook feeds .

Disappointment and disbelief

It is disappointing to see well respected figures make assertions which misrepresent intentions or the facts on the ground.  It was a pleasure to meet and chat with Cameron McNeish at the recent Tom Weir Statue unveiling in Balmaha. Both Fiona Logan and I had previously extended several invitations to Cameron to discuss the Your Park proposals to share views on the difficult issues we are trying to address.  It’s a shame that Cameron could not take us up on those offers.

vision2

I am therefore even more disappointed in the content of the blog Cameron has published yesterday as well as the various statements since on social media. Disappointed, not because he disagrees with the Your Park proposals (everyone is entitled to their views, that’s what our consultation is about), but because his blog does not fully represent the situation on the ground that we are dealing with.  Neither does it recognise the significant achievements on addressing the issues successfully on East Loch Lomond for the benefit of so many people.

You can read the blog piece here.

Likewise, it’s particularly saddening to see comments from an ex-colleague who was so closely involved in the work to transform east Loch Lomond.  Kevin Findlater led Operation Ironworks for Central Scotland Police when we introduced the East Loch Lomond byelaws in 2011.  

Indeed, around that time he is quoted in various media (including Rob Edwards’ own blog) being vocal about the impact those byelaws had and this blog yesterday quoted him below as saying in 2012:

“Last year saw the introduction of bylaws on East Loch Lomond. One of these prohibits the public consumption of alcohol on a year round basis. The other bylaw restricts informal camping between March 1 to October 31.

“These bylaws, combined with significant improvements to infrastructure and the patrols by rangers supported by police officers made a huge difference to the area, with a marked reduction in anti-social behaviour. It was noticeable that many families returned to the area as they felt that it was a safer place to visit and enjoy.”

Rob Edwards blog 2010

Kevin Findlater quoted in Rob Edwards blog, September 2010

Kevin Findlater quote in Stirling Observer

Kevin Findlater quoted in the Stirling Observer in March 2011

 

Kevin Findlater query

Excerpt from Kevin Findlater’s response to Your Park consultation, shared by Rob Edwards on his blog

Much like the situation with the respected outdoors writer and broadcaster, Cameron McNeish, my concern about what Kevin Findlater is now saying is not his views on the Your Park proposals – that’s what the consultation period is for – but rather that he is querying the validity and source of evidence that confirms the 81% drop in antisocial behaviour crimes in the area, a figure which he claims

“was not and most certainly would not have been reached from police figures”.  

Not only did those figures come from (what is now) Police Scotland but Kevin shared that very statistic in a letter he sent to community organisations in the area in 2012. He simply cannot rewrite history, and this turnaround in his views is nothing more than that.  

Our working relationship with the Police

We’re extremely proud of the long-standing and productive working relationship we have with the Police.

Today’s Sunday Herald article glossed over the Police Scotland statement provided to them where Divisional Commander, Davie Flynn confirmed: 

“We are currently finalising a formal response to the consultation. We have enjoyed a longstanding positive relationship with Loch Lomond & the Trossachs National Park including the coordinated, successful approach we have been taking to tackle antisocial behaviour crimes, vandalism and littering at east Loch Lomond.

 “Police Scotland is generally supportive of the introduction of a byelaw replicating the purpose and spirit of the existing east Loch Lomond byelaw in other parts of the National Park where visitor pressure, crime and antisocial behaviour is affecting safety, quality of life and the environment. This support extends only when implemented as part of a suite of wider measures such as those introduced from 2011 in east Loch Lomond.”                    

 The article also carries a quote from Dave Morris, ex-director of Ramblers Scotland, who calls for:

“The park authority needs to abandon its byelaw proposals immediately and sit down with Police Scotland, outdoor organisations and other experts and work out sensible solutions,” he said.

The problem is that is exactly what we have been doing throughout 2014 at the numerous informal engagement sessions we had with organisations including Police Scotland, Ramblers Scotland including some with Dave Morris himself before he retired.  You will understand why it’s frustrating to see views like these being aired without question on this, the penultimate day of the 12-week formal consultation period.  

And Cameron McNeish, who was unable to make any of the invitations we extended to him to take part in the informal process that helped us shape the Your Park proposals, is today calling for a “nation-wide talks” to deal with issues that he acknowledges in an updated blog today .

Cameron McNeish updated blog

Excerpt from Cameron McNeish’s updated blog today, 11th Jan 2015

Intense visitor pressure

Nowhere else in Scotland experiences the intensity of the visitor pressure that occurs in Loch Lomond and The Trossachs. A key reason that this outstanding part of the country was given byelaw-making powers under the National Parks (Scotland) Act 2000 was that they were seen as required tools to deal with these pressures.  It’s staggering then that the very supporters of National Parks are so reluctant to see those powers used to solve well-evidenced problems that are destroying what we are supposed to be protecting and enjoying.  

At the heart of the Your Park proposals is the desire to encourage a wide range of access, which is currently prevented by high volumes of inconsiderate and excessive camping along our more accessible loch shores. So to see such fierce arguments made about the rights of one recreational group (campers) without considering the rights and needs of other visitors and recreation activities is a very narrow perspective. Such commentators also seem content to down-play the significance of the damage to the environment and impacts on residents and the millions of people who visit this special area.  

The many residents and visitors affected by these problems are impatient for action and rightly expect us to come up with effective solutions. We need to move forward with the right tailored local solutions, not have a national debate.

Clarifying some key points

Some of these questions have already been dealt with in a previous blog but I wanted to take this opportunity to clarify some of the points raised so that everyone can have the full picture:

1. What made the difference on east Loch Lomond

I don’t think people could now dispute the significant transformation achieved in east Loch Lomond. However, to suggest that a camping byelaw was not needed and that the other measures would have worked without it is simply misrepresenting the situation.

We have used all evidence available to review the first three seasons of operation of the East Loch Lomond Byelaws. The important thing to stress here is that much of the information we have used comes directly from Police Scotland’s own records not the National Park’s.

While initiatives such as the ‘Respect the Park‘ education campaign and Operation Ironworks, which increased police patrolling, helped make some progress before the byelaw introduction, the Police Scotland records of an 81% reduction of reported crime coincided with the introduction of camping and alcohol byelaws in 2011.

Less measurable, but no less tangible, is the total change in the atmosphere of the place on busy summer days.  Stuart Fraser from the Oak Tree Inn sums up the difference he has seen in the area in this video.

No longer do visitors or residents feel intimidated, nor are they confronted by extensive areas of human waste, litter, damaged trees and huge amounts of camping related litter. I can do no better to sum up this transformation than to refer to then Chief Inspector Kevin Findlater’s comments in 2012:

“Last year saw the introduction of bylaws on East Loch Lomond. One of these prohibits the public consumption of alcohol on a year round basis. The other bylaw restricts informal camping between March 1 to October 31.

“These bylaws, combined with significant improvements to infrastructure and the patrols by rangers supported by police officers made a huge difference to the area, with a marked reduction in anti-social behaviour. It was noticeable that many families returned to the area as they felt that it was a safer place to visit and enjoy.”

2. We’re proposing a suite of measures promoting access

There are three key points here:

First, the effects of the changes made in east Loch Lomond have been that a much wider range of people and age groups are now coming back to enjoy the area. We have promoted more access and recreational enjoyment by solving these problems. By managing just one recreational activity (camping), we are now supporting far more activities whilst still providing safe, low-cost opportunities to camp.

Second, we firmly believe that no one measure works on its own. It has been suggested that an alcohol byelaw would have been enough on its own. It’s worth pointing out that restricting drinking outdoors does not extend to inside tents. Campers could still consume alcohol under canvas – the offence is to be found drinking outdoors. Areas such as Luss and its surrounds have an alcohol byelaw in force but they continue to experience issues with antisocial camping.

Thirdly, the problem is not just antisocial behaviour, it is equally the sheer impact of the large amounts of camping  week-in, week-out that happens at popular lochside locations, and the environmental degradation that results from that persistent overuse. In a National Park we have a duty to manage recreational impacts where they are harming such valuable landscapes.

3. We have no desire to “criminalise campers”

When the east Loch Lomond proposals were consulted on, much was made of the byelaw allegedly criminalising responsible campers. The actual operation of the byelaw has demonstrated that this is clearly not the case.

Our approach is to use our Ranger service to provide advice and communication on the ground, and through other information to ensure visitors are well informed about where you can camp. If visitors are camping in restricted areas our Rangers let them know, and if necessary, they’re assisted to move to designated sites (such as the site at Sallochy that Cameron praises in his blog). In four years of operation only one group have refused to voluntarily comply resulting in one breach of the camping byelaw. We’re pleased to see this package of measures has had a deterrent effect, helping change previously entrenched behaviours, meaning very little formal enforcement has had to take place.  Nobody acting responsibly has been criminalised.

It’s worth remembering that our proposals cover less than 5% of the National Park’s 720 square miles.  The management zones focus on the area from the roadside to the lochshore and then an average of 200m to the nearest feature (fence, wall etc).  We’ve recommended including some road corridors to help deal with the issue of displacement and to help with communicating the zones affected.  TRUE wild camping remains unaffected beyond these areas.  Walkers who love to get out into the hills or along the majority of our long-distance routes and paths to camp will still be able to do that.  Detailed maps of the zones we’re proposing can be found here.

4. It’s not as simple as having more Police enforcement

Operation Ironworks has been operating for over 7 years and is an excellent example of partnership working with Police Scotland. We invest public money in additional Police patrols on busy weekends and have a dedicated National Park Police Officer to help co-ordinate efforts. This allows us to respond quickly to situations and to ensure prosecutions of existing laws.

The point is that this only deals with crime once it has been committed and requires a Police presence to enforce.  While we continue to take enforcement seriously, we’d rather focus our efforts and investment on preventing this damage being done in the first place.

Despite the additional investment we’ve made in Operation Ironworks and the very significant Ranger presence over a 720 square mile National Park, these initiatives along with educational campaigns are not preventing antisocial behaviour in our other lochside camping hotspots.

Once large numbers of people congregate we have to wait until an incident is reported before action can be taken. Despite significant Ranger contact and polite requests, we still see these damaging behaviours. In east Loch Lomond, it simply isn’t an issue any more.

I’m delighted to see that Police Scotland have responded very positively to the Your Park consultation.

Davie Flynn, Divisional Commander, Police Scotland, said,

“We have enjoyed a longstanding positive relationship with Loch Lomond & the Trossachs National Park including the coordinated, successful approach we have been taking to tackle antisocial behaviour crimes, vandalism and littering at east Loch Lomond.

“Police Scotland is generally supportive of the introduction of a byelaw replicating the purpose and spirit of the existing east Loch Lomond byelaw in other parts of the National Park where visitor pressure, crime and antisocial behaviour is affecting safety, quality of life and the environment. This support extends only when implemented as part of a suite of wider measures such as those introduced from 2011 in east Loch Lomond.”

5. Investing in more camping facilities

We have made a firm commitment to ensure that more low-cost informal camping facilities are developed in the National Park, similar to that provided at Sallochy Bay on east Loch Lomond.  Indeed, part of this consultation process is dedicated to seeking opinions on the projected £10m investment in improving camping facilities in the Park.

We need this type of infrastructure so that basic toileting, water supply, litter management is available. The National Park Authority doesn’t have a significant landholding, meaning we have to work with other landowners both public and private to provide these sites. As is the case with the facilities we invested in at Sallochy Bay we wish to ensure affordable charges for camping.  Managing camping will not work unless there are facilities and locations for people to use.

Let’s be clear, nobody is looking to make money from such facilities, but we do need to find ways of delivering them sustainably in a period of declining public resources.

We will continue to have strong education on responsible camping through our Ranger service, and longer term through all the work we do with schools, young people and through our association with the John Muir Trust.

Summing up – it’s a careful balance

We’re guided by the aims of National Parks in Scotland, so the measures to deal with problem camping have to balance our responsibilities to:

We have spent years dealing with the damage being done to this special place.  We have significantly invested  in and will continue to invest in education, enforcement and infrastructure.

It’s a real shame to see critics of our work overlook the significant efforts to date, or down-play the massive negative impact that irresponsible and unsustainable levels of camping are having on the environment of a National Park, as well as on its visitors and residents.

As for John Muir, the founder of National Parks, I’m sure he would indeed be “doing cartwheels in his grave” if he were to see the damage being done to this precious part of the world.  It’s our daily duty, and honour, to take care of this special place, and the proposals we’ve made in Your Park, have at their heart the best interests of the Park and the people who cherish and enjoy it.

There is still time to respond to our consultation, which closes on Monday 12th January at midnight.  

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8 Comments

  1. Kevin Findlater MBE on

    I am disappointed to find that I have been rather cynically included within your blog as showing apparent support for the proposed bylaws, especially as he has known for some considerable time that this is not the case.

    For the avoidance of doubt may I briefly respond:

    1. Though LL&TTNP has, since inception, done fantastic work across a whole range of community and environmental issues, including along East Loch Lomond, I do not support the current proposals as they are wholly unnecessary and, I must add, grossly exceed the ELL bylaw in terms of matters criminalised and geographical area covered.
    2. Regards the 81% reduction in crime alleged to have been along ELL; this figure relates to a larger and more significant geographical area that encompasses the likes of Drymen Village and Drymen Show Field that both have their own record of asb that aren’t a feature of the bylaw’s concerns. The only reliable comparison for ELL was a 60% reduction in asb calls to the police after Year One of Operation Ironworks and this, relying on existing powers, predated the bylaw.
    3. Unquestionably there were a whole raft of measures and investments that made the difference on ELL, to say otherwise would greatly undervalue the many contributors. I have no doubt whatsoever that the camping bylaw assisted, but to suggest that it was even a significant factor would ignore history and would lack evidence. Even if it has been significant, it must be reiterated that the proposals now being put forward are entirely different and bear no comparison in terms of scope and geography.
    4. I have a whole range of issues around the topics that are covered by the proposals; most of the issues already carry sufficient criminal law for the police to deal with and I question whether the public would be happy that, for example, them being assaulted may, as the bylaws suggest, be fit to be dealt with by Park Rangers (if this is not to be the case why include it)! I see that “nuisance” is to be covered for a variety of acts including the use of a vehicle; this is an area that even the police don’t have such powers and on the grounds of civil liberties, neither should they. It would also appear that, under the unnecessary wildlife bylaw, it would be an offence to pull nettles or even pick fruit!
    5. According to the title of the consultation this is about; “Your Park: transforming our lochshores”; why, then, will the bylaws cover the miles of roads and villages not beside a “lochshore” through the wider Trossachs shown within the contribution?
    6. I note that landowners and tenants will have the power to disregard the bylaws. In other words they can selectively choose those that they would permit to camp upon their land. Is that in the spirit of the “right to roam”?

    It is very important that I qualify what I have said here. Without a shadow of doubt a minority of wild campers, usually vehicles based and near a waterside, have greatly degraded the environment and the wellbeing of affected communities, businesses and visitors to the park. As you will agree, I have been saying this longer and louder than any other public servant for many, many years. However, my argument is not that we should do nothing, but rather that these badly crafted bylaws are not the answer. Instead, this truly needs a Scotland wide solution, as it is a Scotland wide problem. Giving the criminal power to Police Scotland that they presently do not have to rid shores of the minority along with a means of, through perhaps SNH, attaching enforcement powers to an order that restricts any type of specified degrading behaviour at specific, clearly defined areas of public or private land throughout Scotland would make the proposed park only bylaws unnecessary. This would also allay the concerns of the many communities, landowners (including RSPB who have asked it be extended further within the park to include all of their area) and others, outside the management zones whom you and I know to be greatly concerned over displacement.

  2. Dave Rossetter on

    As a previous member of the LLTNP Access forum when the original bylaws were being written I stated then that it was about education. They were on,y ever stated that the byelaw would be for a short time to give opportunity for education.

    This has been very poor and in my opinion not followed through. We now find ourselves where paddlers are going to be criminalised for camping out of their canoe & kayaks following some of the best inland waterways routes within the UK. Routes that connect Loch Voil to Loch Lubnaig following the River Balvaig, DofE groups coming from Locah Achray into Loch Venacher and for the more adventurous paddling and portaging their way across Scotland coming from Loch Lomond through to Stirling.

    To deny them and others the ability to camp at the waters edge for one night as they travel and explore the National Park from the water seems to go right against the ideals that the National Park needs to uphold. There could be real safety issues by forcing groups to paddle on a specific side of the loch or by forcing them to keep paddling further to get outside the no camping zone.

    I would like to see more down and mentioned from the park about not just walkers but the growing number of watersports enthusiasts.

  3. I n view of these very personal attacks on the integrity of Mr Findater I hope the National Park publishes his response in full. I have read it and he has done a great duty to the public. I hope too it will be sent to every Board Member so they can make up their own mind

    To take one just small point, I am not sure why Mr Watson you are critical of Mr Findlater criticisms of the the alleged 81% reduction of anti social behaviour being due to camping bans when hidden in the National Park’s own review of the East Loch Lomond bye-laws it says this figure applies to the whole of east Loch Lomond including Drymen. Nowhere does the Park say how many of the incidents took place in the land covered by the bye laws nor does it make any attempt to analyse what part of this can then be attributed to camping.

    I could cite many further examples of distortion which are in my own response which I submitted last night. I hope the Park will publish this too but for anyone who wants a copy I am happy to send it direct nickkempe@tinyworld.co.uk

  4. Kevin Findlater MBE on

    Regards my reply to Gordon’s blog submitted before his subsequent attack on me, but nod added until afterwards; his response requires that I further clarify the 81% I refer to at Point 2 of my earlier response. Previously, I have stated that LL&TTNP did not get 81% decrease on ELL from the police, in that I am entirely correct. Instead from work undertaken by an analyst comparing asb crimes over the three years to 2012 there was an 81% drop in asb ACROSS THE WHOLE DRYMEN BEAT, of which ELL is the least populous area and for which least such crime reports would exist.
    1. LL&TTNP new that this was not just applicable to ELL, but have they alerted communities to this in their consultation – no they have not. Nor, I suspect, have they done so to others to whom they have supplied this figure.
    2. Operation Ironworks, which there is real evidence of a 60% reduction in asb pre bylaws, was operating across almost all of the park and not just on ELL. LL&TTNP must acknowledge the impact it was having otherwise they wouldn’t have paid for the police to undertake such patrols. Without doubt Operation Ironworks patrols were operating in the whole of Drymen beat between 2009 and 2012 when this analysis took place.
    3. Of greatest significance, and one very well known to Drymen residents, was that 2012 was the year Drymen Show was cancelled because cows had been left too long in the fields. Residents, especially, know the asb that was associated with licensed premises and more particularly within and outwith the snowfield because of the significant influx of young people from nearby towns such as Balloch, Vale of Leven and Dumbarton. I have personal experience of the violence and serious disorder at these dances. But all of this takes place outwith the bylaw area, yet within the wider Drymen police beat.

    I am reminded of a phrase used when I was taught statistics at university, there are lies, damn lies and then there are statistics.

    I trust that with my earlier comments these will form part of the consultation. Also, with Gordon’s comments being widely and regularly tweeted I trust that in the fairness of a consultation my and other such comments will similarly be circulated?

    For those interested the well respected Cameron McNeish has been using his Facebook site to elicit comment; it is worth a visit to read the very well informed rejection of the bylaws by a prominent local landowner and elected member within the heart of the Trossachs who, like me, was heavily involved in supporting LL&TTNP during its excellent 5 Lochs Project. https://www.facebook.com/cameron.mcneish?fref=ts

  5. I left a comment earlier today in response to the update of the blog by Mr Watson requesting the National Park publish Kevin Findlater’s response but it did not appear. I am not sure if this is because of problems with the technology – if you look at comments on Cameron McNeish’s facebook comments you will see lots of people are having problems trying to submit comments. I am very happy to send mine to anyone who requests this – nickkempe@tinyworld.co.uk – and have also pasted here the Freedom of Information request which I have just submitted which may help people judge whether the consultation process has been fair and impartial.

    23 Queen Square
    Glasgow
    G41 2BG

    12/01/15

    Gordon Watson
    Chief Executive
    Loch Lomond & The Trossachs National Park Headquarters
    Carrochan
    Carrochan Road
    Balloch
    G83 8EG

    Dear Mr Watson,

    Freedom of Information requests relating to proposed Loch Lomond and Trossachs bye-laws

    The consultation by the National Park on the proposed camping bye-laws raises a number of questions and issues where in my view more information is required. I have seen the National Park’s response of 22nd December to a previous FOI request in wish you are wishing to charge the person for the information they have requested. I believe the opens the National Park Authority to accusations of acting in a totally biased manner – if it is consulting properly it needs to make available all information held by it that is relevant to the camping byelaws proposal and should have made this available as part of the consultation material and provide this for free.

    I have read through your board papers relating to the current proposals and the review of the East Loch Lomond bye-laws and while there is some information presented in those documents – which gives me reason to believe you have much of the data I am requesting – it appears from complete.

    1) Data. The report to the Board in Dec 2013 on Managing Visitors and Recreational Pressure states “significant progress has been made on preparing the evidence and audit findings which include patrol data from our Ranger service, images, site surveys, research findings and information from Partners” while the Report to the Board of March 2013 on the East Loch Lomond bye laws refers to “considerable factual information gathered over a number of years by the National Park Authority Ranger Service”. This information does not appear to have been made available to the Board in October 2014 when it gave the go ahead for the current consultation and is not included in the consultation documents (the strategic environment report omits data that back up statements which are relevant to the justification for the bye laws such as “litter has increased” and “fire sites are common”. So, I would like to request the following to promote an informed objective debate:
    a) Your Rangers in checking on campers must have come across many incidents of people camping responsibly. What data does the NP therefore have on the number of people exercising their rights to camp responsibly who would be affected by the proposed new by laws? Please supply this.
    b) What data does the NP have on the people using the Sallochy campsite both in terms of numbers and why they are there. What are the numbers of people who formerly held drinking parties on the lochsides, people who would have formerly wild camped (and if so what is their view of the campsite) and people who only ever use campsites?
    c) The consultation repeats the figure reported in the east Loch Lomond bye law review that there had been a reduction of 82% in incidents of anti-social behaviour since the introduction of the bye laws. That report gives no context or other data on that drop apart from a reference from Police Scotland that the figure is for the whole of the east Loch Lomond area including Drymen. Please therefore provide 1) total figures for each year for the number and type of anti social behaviour for the east Loch Lomond area and of these how many of these took place in the area covered by the existing bye laws and then out of these how many were linked to people camping and what the nature of that link was.
    d) The evidence section in the Your Park consultation consists of a series of photographs illustrating irresponsible camping but no context is given for this. Does the National Park take photos of people camping responsibly, if so is this done on same basis as for irresponsible camping (eg each time rangers come across a camp) and why are these not also posted on the website as part of the evidence?
    e) The Your Park consultation appears to focus on the damage it claims is associated with wild camping and not on any damage caused by day visitors. It is quite possible for example for people to visit the park for a day, start drinking and causing environmental damage. This is reflected in the NP’s review of the East Loch Lomond bye-laws which shows that litter and fires continue to be an issue. What data does the NP have for the other proposed management zones which demonstrates what impacts are associated with overnight rather than day stays? If so, please supply it.
    f) The Your Park consultation has focussed on the need for camping infrastructure although the impacts of day visitors is also in large part determined by the presence of suitable infrastructure such as car parks or public transport, litter bins and public toilets. The consultation refers to problems of human waste and I was reminded of this on a recent visit to Rowardennan when I found the toilets to be closed – in the day, midweek. I would therefore request you provide me with the opening dates and times of ALL public toilets in the park, both those operated by the Park authority and those by other public authorities.

    2) The National Park in its consultation alludes to difficulties with enforcing the current Criminal Law – it states this is an “interesting area” – as a justification for the bye-laws. In order to give the context I would like to know the total number of examples of criminal behaviour identified by the National Park in relation to camping (preferably for the last four years), the number of times the police were called to these incidents and what action was subsequently taken. However, the main data I would like to know is how many FAILED prosecutions have resulted from police action for the same period.

    3) The National Park claims that only 5% of the National Park will be covered by the extension of the camping bye laws but as you will be aware, most of the glens that could be affected by the bye-laws are steep sided and many covered in blanket conifer afforestation so that there are few other places to camp. I would like to ask therefore if the Park has any information about what percentage of “campable” land within the National Park under 300m in height is affected by proposed bye laws and if so what this shows.

    4) The Park attributes a number of improvement on east Loch Lomond (highlighting the 81% reduction in antisocial behaviour question above) to the camping bye laws. However, at the same time as the bye-laws were put in place, joint operations with the police had been stepped up with “Operation Ironworks”, Stirling Council had introduced an alcohol ban while the clearway made it easy to prevent people camping from their vehicles (which the Park’s research shows was the main problem). The Review of the East Loch Lomond bye laws states that “it is evident that camping bye laws contribute most” without citing the evidence on which this statement is made or the reasons why this might be the case. As the review of the East Loch Lomond Bye-laws makes clear the alcohol ban was not well advertised – it still isn’t – but the clearway was in place and enforced and appears likely to have played a key role in stopping car based camping. In terms of the current proposals a combination of an effective enforcement of the alcohol ban and the urban clearway would appear equally as likely to tackle the issues as identified in the NP’s own research of 2007 and result in a reduction of irresponsible behaviour. My question therefore is has the statement about the impact of the bye laws being evident been validated in any way and if so how and by who? Please supply the validation if it exists.

    5) Related to the question 4, the NP in its Board papers from December 2013 stated staff would consider a range of options for addressing visitor management issues, including those associated with camping. What discussions therefore has the NP had with relevant authorities about extending alcohol bye laws and overnight parking restrictions in the proposed new management zones? If discussions have taken place, what were the outcomes?

    6) Many of the problems seem to be related to people who go to fish, rather than walkers as such, and as such there is a responsibility on owners of riparian fishing rights to link issue of permits to responsible behaviour. Does the National Park know how much income is generated each year by the issues of fishing permits (I assume this figure is part of the estimated £247m visitors bring to the Park each year)? If so, how much is it? What efforts has the Park made to ensure that the owners of riparian fishing rights “police” the permits they issue?

    7) What is the cost to the National Park of funding the police involvement in operation Ironworks? How many police officers are so funded (full time equivalents). How many Police Officers (fte) does Police Scotland deploy in the National Park? What evaluation has the National Park taken on the effectiveness of the deployment of police resources as opposed to Rangers to tackle anti-social behaviour (as opposed to the educational role of rangers).

    8) The East Loch Lomond bye-laws as published stated they would be reviewed at the end of October 2014 but the review was considered by the Board in March 2014 (ie before the three years was complete). I can find no explanation for the reasons for this change in the Board papers. Why did this happen and who took the decision? Has the Minister responded to the Review? Why was the Review, which was already a public document, not included in the consultation documents?

    Yours Sincerely

    Nick Kempe

  6. Your Park Blog on

    Thank you for your comment. Our updated blog published a link to Mr Findlater’s response.

  7. Some of the very real problems with the claims made by Mr Watson in the additional material added by the National Park today will I think in due course be exposed. I want to focus here though on commenting on the new section headed “We have no desire to criminalise campers”.

    The first claim here is that because Rangers ask people to move on and in practice they have done so that there has been no criminalisation of campers. This is true. However, if the people had not moved on voluntarily then they would have been fined and there has nevertheless been a criminalisation of camping. There are two important thing here. The first is that wild camping is part of access rights so long as undertaken according to the Scottish Outdoor Access Code. If the National Park believed people should be able to camp responsibly it could never have proposed bye laws that criminalise ALL camping in the zones (apart from at campsites and the 2 or so permits a year the Park has issued up till now). The second is that in effect Mr Watson is saying the Parm will use its r discretion about when to prosecute people under the law and generally if they move on (and presumably have left no signs of damage) they will turn a blind eye. What he does not say is why not then just then introduce a bye law that says people must camp according to the Scottish Outdoor Access Code and the Park rangers could leave all but irresponsible drinking parties camping in peace.

    The second statement that needs to be seen in context is the claim that only 5% of the land in the NP is affected. What is not said is the bye laws includes much of the campable land under 300m; the reality of the steep sided glens and conifer plantations is that outside the proposed management zones there is very little land to camp. The situation is even worse of course if you are trying to tour by canoe (as with many Duke of Edinburgh schemes) or are cycle touring and want to stop for the night by the road. A very high percentage of suitable camping places for these activities will be covered by the proposed bye-laws.

    The third thing that needs to be contested is the claim that “TRUE wild camping” will not be affected. True wild camping is a new concept completely undefined – or perhaps that Park can show me otherwise. If it has defined “TRUE wild camping” perhaps it could explain the difference between this and wild camping as set out under Access Rights and why it believes the National Park has the right to redefine this concept.

    The fourth thing that needs to be said about the claim that the Park is not criminalising campers is that the Park’s proposals are not just about camping,they are about bivouacs and any other type of shelter (apart from umbrellas) but also extends to anyone sleeping overnight outside and in stationary cars in one of the proposed Management Zones. So, if you drive up to a hill one night hoping for an early start and sleep in your car you will be committing a criminal offence. There are many other examples which people will be able to think of for themselves. The important thing here is that if the bye laws are passed the Park will in effect be able to ask anyone who is in the Park Management Zones anytime between 7pm to 7am to prove where they are going to sleep in order to be assured that the offence of going to sleep in the management zone will not be committed. This is of course unlikely early in the evening especially on our long summer nights but the later it gets, the more likelihood there is you will be asked why you are out and where you are going to sleep. This raises a fundamental threat to access rights at night. Many people will not know that in the discussions on the access legislation (in which I was involved) some landowners initially wanted to confine access rights to daylight only but this was roundly rejected.

  8. Pingback: Wild debate over wild camping

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