This response has been submitted to The Loch Lomond and The Trossachs National Park Authority to assist them in drawing up a National Park Plan that sets out how the National Park will be managed to deliver its four statutory aims. See the Authority website for more info.

Introduction
The Mountaineering Council of Scotland (MCofS) is the representative body for hillwalkers, climbers and off-piste skiers and receives core grant funding from sportscotland in recognition of this status. We are a membership organisation with over 2,000 individual members plus 130 affiliated clubs that contain over 7,000 members. Our Committee structure is entirely voluntary and appointments are the result of a democratic process. The professional staff complement is made up of four posts at our Perth office.

As one of the organisations that campaigned for National Parks in Scotland we are delighted to be at the stage where we are now responding to the consultative draft plan for Scotland's first National Park. MCofS members regard this area very highly because of its significance for providing popular day trips to quality mountain areas, and also for its historical importance in the development of Scottish mountaineering. The Loch Lomond and The Trossachs National Park is therefore extremely important to us and we appreciate and applaud the general approach that this draft plan is taking to the future management of this area.

We believe that National Parks should be models of good practice that other areas should be able to learn from and in this respect we regard this draft plan as a template for a new way of managing rural Scotland, and which could be replicated in other National Parks and distinctive areas of popular countryside. Nevertheless, we feel there is room for improvement within this draft plan, and will explain our thoughts in this consultation response.

The MCofS responded to all the previous consultation exercises during the development of the National Parks (Scotland) Act and then in the setting up of the two national parks. One of the points we have consistently made throughout all of these responses is that we “wish to see the parks making a difference on the ground”. We believe that a good park plan should set out the strategy and policies for guiding its work, but it should also include the practical actions that flow from the policies and which will ultimately make that difference on the ground. This draft is a reasonable start, but with the addition of more detail in terms of practical actions it should be possible to sharpen the focus and make this a useful document that will lead to much needed work where it really matters; out on the ground.

The Guiding Principles
The seven guiding principles contain a sensible balance of conservation, visitor experience and quality of life. At this strategic level we would support these principles and agree with the concept of working together to deliver the plan. We regard this as a plan for the park authority and its partners, and in that respect the plan is about the National Park Authority engaging other organisations in order to meet its objectives.

The MCofS considers itself to be one of those partners, and in making this response we wish to ask “how can we help in delivering the policies in this plan?”

National Park Special qualities
This section of the consultative draft is useful in setting the scene for the rest of the document, but it could portray more feeling for the human enjoyment of the area. For example the section on “Enjoyment of the Special Qualities” is very good, but the “Mountains and Moorlands” paragraph could be expanded to acknowledge the present day popularity of these mountains as well as their place in the history of Scottish mountaineering. The section on “Communities, Local Culture and Traditions” makes some valid points, but it should also mention the simple fact that the Park area is a wonderful place in which to live and work.

Landscape
The MCofS is concerned about the protection of our mountain landscapes and welcomes the generally positive policies in LS18 and LS19, which seek to protect wildness, remoteness and tranquillity within the glens and uplands, and on the lochs. We support this kind of policy and will encourage the park to adhere to this policy whenever a proposed development threatens these special qualities in the park, but we question the use of the term “avoiding development”. The national park is the planning authority, not the developer, so we would prefer to see a stronger statement like “opposing development”.

Along with many other bodies we are concerned at the lack of action by the Scottish Executive on the review of the National Scenic Area (NSA) designation, so we welcome the statement in policy LS24.

Using Resources Wisely
The biggest threat to Scotland's landscapes at the current time is from renewable energy developments, mainly in the form of onshore wind factories and hydro schemes. It is of great concern to the MCofS that huge areas of Scotland's uplands are poorly protected from such development proposals, so it is of some relief that National Park status should now afford greater protection to two of our finest mountain areas.

Our belief is that micro scale renewable energy should be developed whilst research is carried out to investigate the potential for large scale marine developments that can eventually produce massive amounts of renewable energy. We are convinced that the current trend for developing onshore wind factories is the wrong energy policy for the UK and devolved governments to follow, and we also believe it is a policy that is likely to have serious consequences for our treasured landscapes that are the basis of our tourism industry and the refreshment that thousands of people gain from visiting wild land areas.

We therefore welcome paragraph 4.7.11, which states “Smaller-scale installations are more likely to be successfully accommodated without damaging impacts on the special qualities”, as well as policies EN1 to EN13. The adoption of these policies should go a long way to ensuring that only appropriate scale renewable energy is encouraged in the park, whilst larger scale developments are strongly discouraged.

Balancing Recreation Opportunity with Sustainability
The introduction to this section appears to fail to distinguish between visitors who go to places as a result of promotion and visitor information, and those who know where they want to go to in order to carry out their chosen activity such as climbing on a particular crag or walking up a Munro. The latter group, a section of which we represent, cannot be diverted to other locations, but they do require visitor infrastructure in the form of car parks, toilets and public transport provision. The presence of a National Park, however, is not going to alter recreational patterns in that Munros are still Munros and will continue to be popular with walkers, whereas quiet areas are likely to remain quiet because of the lack of recreational interest in those other areas.

We support the clause in policy VM1 that states “The number of visitors will continue to be monitored, in accordance with Policy MON1, to inform future reviews of this policy”, but we wonder if this is an area where the plan could go into more detail. We are aware that the park is active in visitor monitoring, but are not sure how much use is being made of the collected data. Visitor data without calibration surveys is meaningless and we are concerned that the park is gathering data that is not being converted into usable information. The section on “Monitoring the Recreation Balance” is very good and we agree with policies MON1 to MON3, but points of detail like calibrating counting machines should be recognised and written into the plan.

Map 5 on page 188 of the draft plan is worthy of mention, because it is too general to identify the visitor hot spots that require the highest levels of visitor management. An example of this is in area 29 Glen Ample and Ben Vorlich, where the map shows the area in the “Moderate levels of activity – consolidate and sustain” category, which is probably an accurate reflection of the level of recreation on the hill, but this fails to acknowledge the car parking pressures at Ardvorlich, and the extra problems caused to visitors by the loss of the bridge at Edinample.

The two areas shown in red are very different in character and we question whether their being in the same category is correct. The types of visitor, pressures and management options are entirely different, and we feel that this should be reflected more clearly in this section. The Arrochar Alps are a popular area for hillwalkers and climbers, and the management of the area could be improved, but work on car parks and footpaths has taken place over the years, and further work is in progress. The management of mountain based recreation in the Arrochar Alps does not represent the same level of challenge as the much broader issues being faced on the east side of Loch Lomond, which we believe are the most difficult set of problems to resolve within the park.

Paragraph 5.2.11 on page 187 states the national park's duty to form a local access forum, but this is not mentioned in any of the policies. The local access forum will be an important means of managing access within the park and it would be appropriate to describe its functions in a new policy between REC7 and REC8 on page 196.

Providing a Valued Quality Experience
The MCofS welcomes the commitment to path management shown in policy REC24. We would, however, like to see some commitment to maintenance of paths, and would suggest inserting the words “and maintain” into that policy so that it reads “A strategic approach will be taken to identifying and prioritising upland path improvements to create a sustainable path network. The National Park Authority and its partners will adopt best practice, contained in national path design and construction standards, in order to provide and maintain a high quality path network”. The MCofS has expertise in this area of path management and is willing to help on this matter.

Strengthening the Park's Economy
We welcome policy SED8, but would like to request that specialist groups of park visitors be considered when implementing this policy. Visitor centres in the United Kingdom's mountain areas quite often fail to provide information and other services for mountaineers, whereas in other countries like Canada, USA and New Zealand, national park visitor centres are usually capable of providing information on weather, avalanche risk, health hazards in the back country, and of providing a good general knowledge of the places where walkers and climbers wish to travel to. We believe that from the point of view of demonstrating best practice it would be commendable if visitor centres within the park were to improve their level of service to mountaineers and other recreational visitors. There is a view that mountaineers do not go into these facilities, but this is a chicken and egg scenario. If visitor centres provide the information, then mountaineers are more likely to go in and seek that information.

Partnerships and Mechanisms for Delivering the Plan
We welcome the statement in 7.16, and the associated policy P6, about setting up special interest groups covering recreational interests. We believe the park should make a firm commitment to this by having the statement in the plan. The MCofS is keen to be fully engaged in this process and to be an active partner in working with the National Park to deliver this plan.

Mountaineering Council of Scotland
6 September 2005