Outcomes

National Parks for Scotland: Scottish Natural Heritage's Advice to Government

5: Loch Lomond & The Trossachs

This section provides advice on the powers, structures and geographic area of a National Park in Loch Lomond & the Trossachs

• Issues and Opportunities
• Proposals for a Loch Lomond & the Trossachs National Park
• Powers
• Structures
• Representation
• Area
• Costings
• Next Steps

Issues and Opportunities

5.1 In the consultation paper, SNH highlighted several key factors identified in Sir Peter Hutchison's report which provided a strong case for the establishment of a National Park in this area.

• First, the area has long been the most accessible and valued recreational space for the people of West Central Scotland. It has also had a long role as a national tourism destination, both for residential visits and for visitors in transit north along the A82 and A84/5 trunk roads. The outcome is heavy recreational pressures on the hills, on the West Highland Way and other footpaths, on Loch Lomond and other important water bodies across the area, and on the road network. These pressures need continued sensitive management of a high quality to ensure that the enjoyment of visitors is not to the detriment of either the natural environment or of the people who live and work in the area.

• Second, the area’s scenery has long been valued for its intimate mix of hill, loch and woodland cover, and Loch Lomond in particular has a special place in the affections of the people of Scotland. But there are many other conservation interests, not so well appreciated by visitors - the native woodlands and upland vegetation, the important freshwater habitats and species, and the important cultural heritage of the area. There is great potential for a National Park to sustain and enrich these qualities and provide opportunities for enjoyment and understanding of them .

• Third, this is a working countryside, with an economically fragile hill farming industry, a major role in water catchment management for central Scotland, and very extensive afforestation, some dating back to the 1930s but most of it planted post-war. Arising from these major uses for forestry and water resources, there exists a significant area of land in public ownership, and there are other important land holdings in the beneficial ownership of the National Trust for Scotland and other voluntary bodies. These extensive public lands have a crucial role to play in the future of the area.

• Finally, the economy of the proposed National Park area is dominated by the provision of services to visitors. While the communities are diverse in character and the communication links across the proposed park area from west to east are not strong, the towns and villages throughout the area have a commonality of purpose and problems through their role in servicing rural land uses and tourism. Some of these communities, being close to the population of the Central Belt, also suffer from a strong demand for commuter housing. Careful planning will be needed to service community needs, to maintain and strengthen their character, and to help to diversify their economy in ways which are appropriate to National Park status.

5.2 The importance of many of these issues and opportunities was reinforced during the consultation period. In the view of the majority of the respondents, they form a sound basis for developing the powers, structures and area of a Loch Lomond & the Trossachs National Park.

Proposals for a Loch Lomond & the Trossachs National Park

5.3 From the consultation exercise, there is overall strong support for the establishment of a National Park in this area and for it to operate along the general lines proposed in the consultation paper. In line with the advice set out in the earlier sections of this report, the National Park should therefore:

• pursue the four purposes of National Parks: for the conservation and enhancement of the natural and cultural heritage of the National Park area; the sustainable use of its natural resources, the social well-being and economic prosperity of its local communities; and the enjoyment and understanding of its special values;
• work through a strong National Park Plan, created and put into effect through the involvement of all interests;
• have the general functions and powers identified in Section 4 of this advice; and
• use the specific powers detailed below to take a lead in carrying out some of the core activities (where this is best done by it) and to work closely with those public bodies which at present hold the powers.

5.4 Some concern was expressed that the National Park body should not seek to duplicate the existing roles of local authorities and other public bodies in the area. We recognise these concerns, but consider the proposed approach outlined below minimises the potential for duplication and additional bureaucracy.

Powers

5.5 In the consultation paper, SNH proposed the establishment of a National Park Body which would have powers in a number of key areas. Overall, these proposals were broadly welcomed, subject to further clarification as to how the arrangements would work in practice. In the light of comments received, our proposals are set out below.

Conservation and Environmental Protection

5.6 Our general proposal that the National Park Body should have an important co-ordinating role in conservation management was welcomed. The statutory consultee role for pollution control, water management and fisheries issues was also accepted, with the need for the National Park Body to work with existing bodies to co-ordinate water catchment and fisheries management specifically identified. In addition, there was strong support for the National Park Body to be able to undertake environmental improvements. We therefore propose that the National Park Body should:

• have concurrent powers with SNH to promote the conservation and enhancement of the natural heritage;
• have the ability to manage land on behalf of other conservation bodies including SNH, Historic Scotland and the Forestry Commission; and
• have powers to undertake environmental improvement works.

Recreation and Visitor Management

5.7 Reflecting the current scale and diversity of pressures on the area, there was strong agreement that recreation and visitor management will be of central importance to National Park objectives. Building on the work of the Loch Lomond Park Authority, we propose therefore that the National Park Body should

• have responsibility for developing a Park-wide ranger service on both land and water, and for managing the West Highland Way;
• powers to make bylaws, to enter into management agreements and to provide appropriate facilities for public enjoyment; and
• powers to provide and manage interpretation facilities and relevant visitor information services in conjunction with local tourist bodies.

5.8 Conflicts between different types of water-based recreations present particular challenges for this National Park, and experience to date suggests that the National Park Body should have a strong capacity to regulate and manage these activities. For this, a broader strategic approach is needed for all water sports to ensure that planned provision is made for the national demand for recreational access to the water in ways which are appropriate to the National Park purposes. We propose therefore that the National Park Body should:

• take the lead in developing and carrying out a strategy for the management of water-based recreation in and adjacent to its area; and
• have stronger powers and incentives to regulate and manage water-borne recreational activities.

5.9 Such powers should be part of the national policy changes advocated in Section 3 to manage recreational activities on land and water, in line with SNH's advice to Government on access.

Town and Country Planning

5.10 In Loch Lomond & the Trossachs, the significant development pressures on the area, and the need to improve the planning and quality of built development in ways which contribute to the special qualities of the area are well recognised. Overall, there continued to be very strong support during the consultation for the National Park to have strong planning powers. This case has already been recognised in the increased planning role for local plan making and development control proposed for the Loch Lomond & Trossachs Joint Interim Committee by the three constituent Councils.

5.11 A number of respondents suggested that the National Park Body should also be the structure planning body for its area. We agree that the National Park Body has to be able to influence the structure plan process. However, within the general framework for National Parks we have proposed, we consider that the existing structure plan arrangements still provide the best means to integrate the planning of a future National Park with its wider area.

5.12 We propose therefore that the National Park Body should:

• be the principal partner in the preparation of the structure plans covering its area, with each local authority required to discuss with the National Park Body the proposed contents of its structure plan as it affects the National Park area, to work with the National Park Body during its preparation, and to obtain from the National Park Body a certificate of conformity with National Park objectives, prior to submission of the structure plan to the relevant Minister for approval;

• be the local plan authority responsible for preparing a single local plan for its area, with the possibility that this could form part of the proposals section of the National Park Plan; and

• be the full development control authority for its area, subject to the review of the experience of the three separate, delegated, development control systems proposed for the interim arrangements.

5.13 To fulfil these functions, the National Park Body will need to have adequate planning resources. We propose therefore that further consideration should be given to arrangements whereby planning officers of the existing local authorities could undertake work on behalf of the National Park Body. Alternatively, the option of relevant planning officers being seconded from the existing local authorities to the National Park Body could be explored.

5.14 In the event of dispute between the local authority and the National Park Body on any aspect of the planning function, we propose that there should first be mediation between the bodies through a joint committee to seek resolution of the case. This joint committee should consist of members of the local authority and the National Park Body. If this joint committee cannot resolve the issue, the matter should be referred to the relevant Minister for adjudication.

Traffic Management

5.15 In view of the large numbers of visitors to this area and its role as a through route, with the resulting problems of congestion, SNH suggested that traffic management would be critical to the purposes of this National Park. This view was strongly supported during the consultation. To undertake this function, we propose therefore that the National Park Body should:

• take the lead in preparing a traffic management strategy in and adjacent to its area in conjunction with the local and national highway authorities.

5.16 As part of this strategy, it should also

• promote the planning and delivery of integrated road, rail and water-borne public transport services across the National Park; and
• have powers to initiate traffic management schemes.

Agriculture and Forestry

5.17 There was strong support for the recognition in the consultation paper of the importance of agriculture and forestry and the contribution of the working countryside to the special qualities of Loch Lomond & the Trossachs. Particular concern, however, was expressed by the farming community over changes to agri-environment funding and the proposed requirement to prepare whole farm and estate plans. We consider that this concern can be largely overcome through the availability of appropriate incentives and by the National Park Body working actively to foster a good working relationship with land managers. Part of this involves recognising and supporting the valuable role which good land mangers play in sustaining the high quality of this area and the public benefits which flow from that. We continue to propose therefore that the National Park Body should engage formally with relevant Government bodies and land owners in the following key ways:

• the National Park Body and SOAEFD, the Forestry Commission, the Deer Commission for Scotland and SNH should develop a broad and integrated approach to land management needs, bringing together a tailored agri-environment scheme for the National Park linked to a local forestry framework plan and a tailored WGS for the National Park, and reflecting sporting and fisheries management, conservation and recreation needs;

• the National Park Body should work closely with the owners and managers of land, including non-government organisations in the area, to promote sustainable use, and the development of farm and estate plans, in line with the arrangements suggested in Section 3; and

• the National Park Body should take the necessary steps to involve all these interests in the preparation and implementation of the National Park Plan.

Social and Economic Development

5.18 There was support for the proposal that the National Park Body should have the capacity to influence and promote social and economic development within its area through the National Park Plan. The proposal for close working with existing bodies, including the Local Enterprise Companies and Tourist Bodies, was welcomed, as was the general proposal for the National Park Body to have its own expertise and funding to support community development projects within its area. The need was also identified for the National Park Body to work with these existing bodies on the promotion and marketing of the area in ways which are in keeping with its special qualities.

Structures

5.19 Our proposal for an independent authority for Loch Lomond & the Trossachs was strongly supported and we recommend that approach.

Representation

5.20 SNH's proposal for a body comprising a majority of local authority and community representatives as well as national appointees was broadly supported. A closer analysis of the responses reveals a less consensus on the appropriate balance of these interests. However, the following themes featured strongly:

• strong support for the majority representation on the National Park Body from among those who live and work in the area;
• support for the majority of representatives to be democratically elected, but less agreement on the suitability of local authority or community councillors for this role;
• calls for direct elections of representatives to the National Park Body by those living in the area;
• calls for direct appointments to the National Park Body of representatives of sectoral interests, notably recreation, tourism, business and land management;
• support for national representation on the National Park Body, but concern that the presence of regional interests should not imply funding commitments from these bodies; and
• support for the use of community and land-management fora to complement the National Park Body.

5.21 In view of this lack of agreement, we suggest that Government gives further consideration to the best approach to representation on the National Park Body in line with the general approach which we have outlined in Section 4. We agree that the representation of regional interests on the National Park Body should not imply funding commitments from these bodies.

5.22 Whichever balance of representation is eventually chosen, it will be important that the National Park Body should seek wider engagement through the use of community and land-management fora and through public agency liaison and technical support groups. The option of having each select a representative to the National Park Body should be given further consideration.

Area

5.23 SNH's proposals for the core area of the National Park are shown in broad terms in Figure 5.1 (see inside front cover). At this stage the boundaries are purely indicative and will need to be subject to further detailed consultation.

5.24 In line with the proposals made in the consultation paper, we propose a core area for a Loch Lomond & the Trossachs National Park which comprises the Cobbler and adjoining hills, Loch Lomond, the Trossachs, Balquhidder Glen and Strathyre. This area includes the gateway communities of Arrochar, Inverarnan, Balloch (in small part only), Drymen, Gartmore, Aberfoyle, Callander, Strathyre and Balquhidder. The outer limits of this area have been chosen on the basis of existing boundaries, watersheds and other natural features. Overall, we consider there is broad support for this core area among most communities and other interests within it.

5.25 Following the comments on the proposals made in the consultation paper, we have also identified areas which have potential for inclusion in the National Park, but which require more detailed consideration to determine the advantages of inclusion in terms of the management of the National Park area. From responses to the consultation paper, we know that support for their inclusion among communities and other interests within these areas is generally less strong, particularly in respect to Thornhill, Kippen and Buchlyvie.

5.26 We propose that potential areas for primary consideration should include Glen Falloch, Ben Lui, Glen Dochart, Strathfillan, Glen Ogle and the Ben Vorlich area to the north and north-east, and Flanders Moss to the south-east. Some of these areas are already included in the proposals for the Interim Joint Committee, and final decisions should benefit from the experience of these arrangements.

5.27 We propose that potential areas for secondary consideration include: the Endrick catchment, Glen Lochay, Loch Earn and the northern part of Cowal focusing on the remainder of the Argyll Forest Park and Loch Eck. The case for inclusion of these areas is based on the advantages in terms of the integrated management of the wider National Park area. Indeed, even if not formally included, many of the policies developed by the National Park will need to consider the management of these areas. However, the inclusion of these areas would spread further the resources of the National Park. At the same time, their inclusion would extend the National Park area beyond that which can sustain community linkages, and may indeed require reconsideration of the name of the National Park. They would also need to be examined against the national criteria we have proposed in Section 3.

Costings

5.28 In the consultation paper, SNH referred to previous estimates of the core and key-activity costs of previous proposals for the management of the area. To allow for further consideration of our proposals, we have now prepared equivalent core operational costings for them which are set out below. These costings are for the third year of operation, by which time the National Park would be fully operational. While they make a number of assumptions, they are believed to be in the correct order of magnitude given the proposed size of the area, the proposed functions and structure of the National Park Body and the experience of Parks elsewhere in Britain.

5.29 We conclude that about £0.9 million a year will be required to meet the additional core operating costs of the National Park Body because of the administration required to support the National Park Board and extra staff envisaged.

 

Figure 5.2: Core Operating Costs

5.30 In addition, there will also need to be an increase in programme expenditure to make things happen on the ground, particular in areas outwith the existing Loch Lomond Park Authority Area. Such programme expenditure could consume significant funds and therefore decisions will need to be taken about the proposed timing of such investment in the area.

5.31 In the next few years, we consider that £1.5 to £2.0 million of new money over and above the existing £1 million annual spend may need to be made available to the National Park Body so that it can persuade others to engage in the delivery of key projects. It should be noted that these illustrated costs are gross costs and that various forms of existing expenditure and income in the area will substantially reduce the net costs to the principal funding partners of the proposed National Park.

5.32 We expect total gross costs in the region of £4.9 to £5.4 million per annum (comprising £2.4 million core operating costs, £1.5 to £2.0 million new programme costs plus the existing £1 million programme costs).

5.33 We estimate that the additional cost of this National Park in year three could be in the order of £2.4 to £2.9 million per annum over current spending levels (comprising additional core operating costs of £0.9 million, and additional programme costs of £1.5 to £2.0 million).

5.34 These figures are based on the existing arrangements for the area. We have also examined the proposals submitted by the Loch Lomond & the Trossachs Joint Interim Committee of the local authorities. We consider that SNH's proposals for a Loch Lomond & the Trossachs National Park go beyond those recommended by the local authorities, both in terms of proposed functions of the National Park Body and its potential area, and that further funding, over and above that needed for the local authorities' proposals, will therefore be required to implement them.

Next Steps

5.35 Responses to the consultation have again confirmed that there is a strong consensus for National Park proposals among local authorities, public agencies, local communities and other interests. At the same time, there is an understandable degree of concern, particularly among some members of the public and the farming community, over what this may mean in practice.

5.36 Against this background, we propose that Government moves quickly to confirm the proposals for a National Park for this area and establishes a programme of action to put them into practice. Essential elements of this programme include:

• continuing dialogue with local communities and other interests on the implications of National Park designation;
• capacity-building among local communities and other interests to allow them to participate effectively in the current development of the proposals for the powers, structures and area of the National Park;
• participation of local and national interests in the development of an interim strategy for the area and policies for Loch Lomond & the Trossachs National Park;
• a strong commitment to the interim arrangements proposed by three local authorities subject to delivery of the three points above; and
• the continued alignment of the plans and operations of Government Departments, local authorities and other public bodies to ensure that the special qualities of the area are maintained and enriched where appropriate, prior to the establishment of the National Park.