These views have been discussed by SCRA Council and are representative of that Councils opinions and views as the elected officials of SCRA, but not necessarily those shared by all members of the association.
SCRA appreciate the difficult and challenging issues and pressures that are faced by Loch Lomond and the Trossachs National Park Authority in terms of managing visitor pressure in Loch Lomond, particularly the problems and challenges presented by 'wild' camping around the east side of the Loch where there is significant visitor pressure.
However, whilst SCRA support some of the tools proposed to tackle these issues, we are not fully supportive of the implementation of byelaws as we do not feel that the arguments presented in the consultation paper justify this measure; we feel that some of the issues discussed in the proposal are not addressed by byelaw implementation.
We have a number of minor points which essentially relate to the 'message' that the Authority would be communicating perhaps not to the user, but to the wider community of land management bodies through implementation of byelaws;
1) LLTNP has the largest Ranger Service in Scotland and has a far higher number of staff 'on the ground' than any other organisation in Scotland. In this instance SCRAs opinion is that there are enough staff to be able to find more proactive ways of managing anti-social camping issues in terms of education and community engagement.
2) If, given point 1 above, LLTNP are resorting to byelaws as a management technique, its a worrying precedent to set to other landowners and managers; basically demonstrating that a high staff presence with an promotional, educational and management role cannot manage this issue - how can we expect a landowner with minimal, if any staff with a similar issue not to expect/want to revert to byelaws?
3) There is a fear that by making byelaws at Loch Lomond, problems will simply be moved to areas where there are simply not the resources or ability to manage them, thus expanding rather than managing the problem
4) The implementation of byelaws in this respect goes against the nature of the Land Reform act. We appreciate that the Act grants powers to use byelaws as a management technique and approach, but we feel that the implementation in this instance goes against the nature of the act.
5) Wild camping itself can be carried out legitimately and legally by a large number of people and is a valuable lesson in the outdoors for many people, fostering what can become a lifelong passion and enthusiasm. The vast majority of people will do this responsibly. Byelaws around Loch Lomond would be applicable equally to all sectors and would spoil this activity for many.
6) The antisocial behaviour is already in a large number of cases illegal, and whilst the byelaws perhaps clarify this illegality, are they really needed to manage problems that are already illegal?
However, SCRA has more substantial concerns in regard to what byelaws might mean for the profession;
7) The proposals are based on a saving of staff time, this will simply not be the case as many staff currently involved in managing anti-social camping will now need to be deployed in an enforcement role - this is a substantive argument in the consultation paper and one that we feel is unjustified - the role for staff might change, but we cannot see an argument for it easing the burden of staff, indeed, if the byelaws are to be implemented well, we can see that there would be a noticeable increase in the staff resource needed to implement and enforce the byelaws.
8) Given point 7 above, we are looking at a fundamental change in the nature of the role of the Ranger in Scotland. LLTNP have already started to increase the enforcement role of Rangers through partnership with the police and special constables; to further increase this enforcement role with Rangers deployed to enforce byelaws, we will soon see the word Ranger being synonymous with enforcement as it is in some other countries. Arguably, Scotland's Rangers enjoy a unique relationship to their advantage, having a role which is to encourage positive behaviour - a carrot without a stick. This means that we have a friendly or soft approach with the public and have come to be a profession that succeeds on this basis - having Scotland’s first National Park change its Rangers into enforcement officers would threaten this relationship not only in the National park, but also potentially wider as the National park acts as an introductory experience to Scotland’s outdoors for many people. SCRA stand apposed to this sea-change in a Rangers position; Scotland’s Rangers indicates in policy the persuasive and educational role of Rangers, not their enforcement role.
SCRA are supportive and positive welcome some aspects of the consultation:
7) We see the value in designating wild camping spots, and would support this approach as part of an educational and advisory approach to manage anti-social issues of wild camping; camping facilities in Scotland are under pressure nationally, and in popular areas such as East Lomond, we would see this as an ideal approach, alongside education to manage camping. 'Managed' wild camping sites will help to tackle many of the illegal and antisocial issues arising from the wild camping on the loch side, by way of protecting biodiversity, limiting tree damage and providing a litter collection facility. We are concerned at the limited number of sites proposed and see this as a limiting factor.
SCRA feel strongly that there are a range of measures that could be applied to help manage this problem that are not yet shown to have been tried. We feel that byelaws stand against the nature of the Land Reform act. One of the key arguments made for the byelaw is the resource saving that can be made, but no indication is made of the potential staff demand likely to manage the byelaws themselves. The use of a Ranger Service is educational and advisory and welcoming; this should be sufficient to manage the issue; resorting to byelaws is almost a sign that this does not work, which sets a dangerous precedent for other land managers. Finally, the management of byelaws by Rangers changes the nature of the Ranger role and may well have wider ramifications and implications for the profession.
I stress that the Association is sympathetic to the issues and challenges faced, but we have real concerns about the proposal to implement byelaws at this point as a management measure; we would rather see a range of measures, such as designated wild camping areas, high profile education and campaign work, interpretative signage and guidance offered, prior to byelaw implementation. We would welcome an approach that left byelaws as a 'last resort' perhaps after trialling a combination of these other measure, most notably the managed wild camping areas, over perhaps a three year period, leaving the byelaw as the last resort.
Once again, my apologies for the tardy response and I hope it can be considered.
Many thanks, Niall
For and on behalf of, the Scottish Countryside Rangers' Association
