Response to SNH Consultation Document:
"A proposal for a Loch Lomond and the Trossachs National Park"

We agree that the general area of Loch Lomond and the Trossachs meets the legislative conditions for designation as a National Park.

Area

The Argyll Forest

Although this region might appear as a separate limb extending south-west from the core area of the National Park, its steep hillsides and the presence of Loch Goil/Loch Long and Loch Eck give it similarities in character.

The area has suffered extensive disfiguration from commercial forestry, and there is urgent need for restructuring and diversification of the plantations. The National Park could give extra impetus to this work.

These factors, together with its traditional popularity with visitors and the strength of local support for National Park status, would make a very good case for inclusion.

Strathfillan and Glen Dochart

There is a stong case for including Crianlarich and Tyndrum. As an important road junction, Tyndrum is a natural entry point to the National Park from the north and the west.

The mountains to the south of the main road (A82/A85) ought to fall entirely within the boundary so that their northern slopes are included. The more popular approaches to Ben Lui/Oss/Dubhchraig, Ben More and Cruach Ardrain are from the north and this should be recognised. It seems illogical to exclude Ben More.

Although this boundary modification would involve dividing Glen Dochart, that would seem preferable to dissecting the important mountain groups to its south.

Loch Earn and Ben Vorlich

Despite the problems resulting from the existing administrative boundary, the character and popularity of this area make it a natural candidate for inclusion. The exclusion of mountains as popular as Ben Vorlich/Stuc a' Chroin would seem odd, as would the exclusion of Loch Earn in view of its high level of recreational use.

However, the boundary ought not to be drawn along the northern shore of Loch Earn, but along the northern watershed to include the hillsides north of the loch.

Flanders Moss and Menteith

We would have liked to see Flanders Moss included, and it would seem regrettable for an area of such conservation importance to fall on the "wrong" side of a National Park boundary, but local suspicions about National Parks need to be acknowledged. It is difficult to impose a decision against overwhelming local opposition, and it might be better to wait until the National Park has been in operation long enough for its impact on agriculture to be more fully understood. Boundary changes might then be agreed to include Flanders Moss.

The inclusion of the Lake of Menteith itself, however, seems a suitable compromise at this stage.

Strathendrick and Strathblane

There does not appear to be a particularly strong case for including these areas.

Powers

We are happy that the original proposals for full local planning and development control powers for the National Park Authority have been retained, with the addition of minerals consent powers, controls over hazardous substances and several other peripheral planning functions. With these powers the Authority stands a good chance of not only preparing effective planning policies based on a strong Local Plan, but also of influencing a wide range of land use and environmental concerns that are not subject to planning control, which is the chief omission in the content of the report.

Strategic planning responsibilities are on balance probably left with the local authorities, with the exception of Indicative Forestry Strategies and the possible exception of traffic management and transport integration. Bearing in mind SNH's original comment in their first proposals report for LL/Trossachs that "traffic management is expected to be critical to the purposes of this National Park", the roads authority should be expected to liaise closely with the NPA in defining its roads strategy for the area. Certainly, Indicative Forestry Strategies should be carried out by the NPA in consultation with the local authorities.

Similarly a number of other agencies, authorities and land managers should be stated to be expected to more than merely consult the NPA on developments outwith normal planning controls in a National Park, but to work with, not against, the authority to achieve greater environmental gains as set out in the National Park Plan, rather than constraints. A Plan that would achieve the best voluntary co-operation in this way would not be one that emphasises constraints. This principle applies particularly to agri-environmental schemes for which farmers are applying for grants to the Scottish Executive, but also to approval of Forestry Grant schemes by the Forestrv Commission that may affect the landscape, leisure and recreation activity, and to Electricitv Act proposals including hvdro-electric schemes. Less contentious perhaps in this National Park than it will be in the Cairngorms, is the need for the Park Authority to influence land managers with clear indications in the Park Plan of where or to what extent extensive grazing by sheep or deer, burning of heather, excessive forest fencing, blanket felling or bulldozing of tracks for whatever purpose could be most or least accommodated.

National Parks are being set up in Scotland with great expectations of the first one, particularly when such a large measure of consensus has been achieved through years of working by the Interim Committee and its predecessors. Wi1d land issues will raise the most difficult problems for the Park Authority, but it will not be helped in setting clear parameters for rural land management and control of developments outwith local authority planning if these are not referred to in SNH's final Proposals.

Representation

We agree with the proposed composition of the NPA, with Perth and Kinross being represented to reflect our view that Loch Earn should be included. It would be of the utmost importance that all members, in all categories, should be known to have the four stated aims of the National Park at heart.

John Digney	Steering Team member, Scottish Wild Land Group
Tel:	01877-382636
E-mail	John.Digney@ukgateway.net
Date:	6 February 2001