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MMA-REP

United Kingdom
105 Posts

Posted - 01/19/2015 :  18:54:36  Show Profile  Reply with Quote
LLA FORMAL RESPONSE TO NPA NEW CAMPING BYELAW & MANAGEMENT ZONE PROPOSALS

YOUR PARK Proposals

Please find herein the Loch Lomond Association (LLA) response to your consultation as contained on website www.thisisyourpark.org.uk , and for which responses were requested by Monday 12th January 2015.
Please note that our responses refer only to your proposals as they apply to East and West Loch Lomondside, and not to the wider Trossachs Area. The latter area lies beyond our LLA Constitutional remit, and thus we make no comment relative to that zone.

We want to know:

Investment Q.1: Do you agree that over the next five years the National Park Authority should invest in improving camping provision within the three proposed management zones?

LLA Response: YES - Providing that no rights conferred by SOAC and the Land Reform (Scotland) Act 2003 for lightweight camping are infringed.

Investment Q.2: Do you agree with the areas of opportunity for camping provision (marked on Map 4)?

LLA Response: No comment

Byelaws Q.1: Do you agree that these byelaws should be introduced?

LLA Response: No

Byelaws Q.2: Do you agree with the wording of the proposed byelaws?

LLA Response: No

Byelaws Q.3: Do you agree with the proposed zones for the byelaws?

LLA Response: No

Additional information is provided within the remainder of this LLA consultation response.


Additional LLA Information and Comment in Order of Significance

1. The LLA does not support blanket 'solutions' to local problems, which aspire to criminalise the majority of law-abiding citizens by deeming them to be culprits alongside miscreants and law-breakers, by denying or limiting their access to or right to engage in their legitimate recreational pursuits. The NPA consistently pursues such policies, and in doing so it undermines the third stated primary aim of the Scottish Parliament within the National Parks (Scotland) Founding Act 2000.


2. The existing laws of Scotland already contain more than adequate provision to control any forms of either law-breaking or nuisance activities currently occurring within the proposed designated zones, and further byelaws such as those proposed are a gross over-reaction to the scale and nature of the problems being experienced, since there are few genuine similarities with past East Shore problems. The LLA considers that all current problems described (e.g. on the West Shore) are attributable to ineffective policing, along with a failure to prosecute offenders under existing laws or byelaws. The NPA / Police Scotland already has an appalling track-record of not prosecuting byelaw offenders, only matched by the dismal performance of the procurator-fiscal service in failing to prosecute most of those few cases which are pursued on the ground for misbehaviour within the National Park area. In the light of this, there is little purpose in creating more overkill byelaws which would also not be consistently policed or enforced via prosecutions.

3. The proposed new camping byelaws and management zones will adversely affect and unjustifiably restrict the recreational enjoyment opportunities of various categories of shoreline users represented by the LLA. These categories include, inter alia, canoeists, kayakers, small boat users and anglers, who might reasonably wish to light a small fire in the evening while camping on a shore-side, or to sleep overnight in a vehicle closely adjacent to the shore.

4. Again, the problem of littering is not unique to West or East Loch Lomond. It is a ubiquitous Scottish problem which can only be solved by indefinite re-education, and aggressive on the spot fines, wherever and whenever these can be fairly applied, on an exemplary basis. The current problems are exacerbated by the simple fact that neither the NPA nor the riparian local authorities have ANY coherent policies in place for the regular management and clearance of litter on the loch shores. A recent road trip down west Loch Lomond in autumn on the A82 revealed almost no litter bins sited in lay-byes, and where the odd bin was present, they had clearly not been emptied in weeks. Contents had overflowed, and were being re-distributed around the nearby countryside by the wind. To conclude on the subject of littering, both the NPA and the Loch-surrounding local authorities have been happy for some years to use the absence until recently of a Scottish Government Policy on Litter Management as an excuse not to unilaterally or co-operatively adopt a pragmatic local approach to rural waste management.

5. The LLA specifically objects to the parallels that NPA have cited, (in their anecdotal 'evidence'), between former Loch Lomond East-Shore behavioural issues, and their portrayal of current issues on the west shore. They have implied similarity in the problem issues only in order to justify a similar requirement in the 'solutions' introduced. With the exception of camping in Luss village itself, there are few parallels of alcohol-fuelled anti-social behaviour occuring currently on the Loch's west shore zone, or in the extended east-shore zone as proposed.

6. The LLA feels that web access to the consultation documents was unnecessarily difficult to navigate to, from the NPA main website homepage

7. Whilst the LLA was asked for views on the status quo of current issues seen as problematic by the NPA during the pre-consultation period, once again (as in the 2012 byelaw review), no attempt was made to discuss the NPA proposed remedies (prior to release of this byelaw consultation paper) to establish that the Park's proposals were appropriately scaled and targetted. The LLA proposed at the outset of this pre-consultation that the Loch Lomond Stakeholder Group (LLSG) should be re-constituted by the NPA as a forum for informed discussion of all such issues amongst stakeholders (many different categories of water and shore recreational users use the loch and lochside). Our suggestion in regard to LLSG re-activation was ignored.

PETER JACK
LLA CHAIRMAN (Our response was sent to the NPA on 12/1/2015)

MMA-REP

United Kingdom
105 Posts

Posted - 01/19/2015 :  19:50:06  Show Profile  Reply with Quote
quote:
Originally posted by MMA-REP

LLA FORMAL RESPONSE TO NPA NEW CAMPING BYELAW & MANAGEMENT ZONE PROPOSALS

YOUR PARK Proposals

Please find herein the Loch Lomond Association (LLA) response to your consultation as contained on website www.thisisyourpark.org.uk , and for which responses were requested by Monday 12th January 2015.


Followers of such above subjects may be interested to know that the new NPA Chief Executive, Gordon Watson, took office today, 19th January. Since the end of the NPA new camping byelaw consultation period just last Monday, he has been busy fire-fighting the reaction to his (or maybe more accurately his predecessor's) proposals. A flavour of the many verbal clashes which have already taken place may be sampled via the link below:

http://www.lochlomond-trossachs.org/looking-after/final-chance-for-public-to-have-their-say/menu-id-483.html

Whilst reluctant to offer Gordon even well-meant guidance on his very first day as NPA CEO, it is hard to forget the excellent advice offered by the late Lord Healy (Dennis Healy - one-time Chancellor of the Exchequer) many years ago, when he gave to posterity his: 'First Law of Holes', which said:

"When you're in one - stop digging".

PETER JACK
LLA CHAIRMAN

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