OK - What is the Problem ?
The Loch Lomond and Trossachs National Park (LLTNP), formed in 2002, covers some 700 square miles. The LLTNP announced to the press in mid-2004 that they wanted to ‘presume against’ seaplane operations citing “a substantial increase in the use of Loch Lomond by seaplanes”. Presume against means exactly that – they want a byelaw that will prevent seaplanes from using the loch. They also announced that they would be conducting a review of Byelaws. However, in late 2004 they were subjected to much sustained criticism in the Scottish Press. Mostly from a very vocal minority who are unhappy at what they perceive is mismanagement of several major issues. Use of jetskis, water-skiers, litter, rave parties, BBQs, vandalism, drunkenness and the extensive golf course and retail developments springing up along the southern part of the Loch. This has led to pressure from the Scottish Executive and the feeling within that the National Park must ‘be seen to be doing something’. So, they have brought forward the proposals for the Seaplane Byelaw. Good to see that they have got their priorities right.
To this end the National Park Authority are conducting a public consultation on Loch Lomond Byelaws, starting on 14 January 2005. This includes -
· A formal 12 week consultation on a new byelaw for Loch Lomond under the National Parks (Scotland) Act 2000 to allow regulation of seaplane landings and take-offs on Loch Lomond.
· The wording of the proposed Byelaw is -
· A policy consultation to help the Authority determine its policy when reviewing the existing byelaws on Loch Lomond. The National Park are seeking your views on current and future management of Loch Lomond.
But this Seems Harmless Enough ?
Do not be fooled. This is not some cuddly attempt to ‘allow regulation of seaplane landings and take-offs’ – it is designed to act as a total ban – the presumption is AGAINST seaplanes.
Please examine the wording carefully, and especially look at how they intend to police or apply this Byelaw. The devil is in the detail, and when you examine exactly how the National Park view this draconian measure … there is a lot of devil ! REMEMBER that this has been drafted by people with little understanding of, or sympathy with flying. The realities and passions of aviation are often lost on them.
All pilots will be required to obtain written approval in advance and provide details of where they wish to land, taxi, clearance areas, landfall, aircraft type and engine, when, how many days a year, flights per day, operating hours, support facilities, what alternatives they have, noise levels, what rules they apply for avoiding other loch users, demonstrate they do not disturb wildlife
Talk about overkill ? You could just as easily ask why are these requirements not being applied equally to boats ? Or for that matter cars .... or walkers …or strimmers …or golf course cutters …. or tractors …. or anglers ? Why are they not being asked to provide their noise levels, wildlife impact, routes, frequency, pollution caused etc.. ? Why are seaplanes being singled out for unfair treatment ? Is it too much to ask that we are treated fairly and given the same rights and access as other Loch users ?
There are two aspects to the operation of seaplanes to bear in mind here. First we have the spontaneous recreational side, (perhaps 50 landings per year) which will effectively be killed off by these requirements. Second we have the professional operators (perhaps 350-400 landings per year), whether that be local charter flights, weddings, fishing trips, golfing trips or cross-country training flights visiting local hotels or the local area. In both cases ALL FLYING and landing area suitability is determined by the weather on the day and the pilot’s professionalism. Winds and water conditions are very localised around Scotland and it is impossible to give the precise details required by The National Park in advance.
There also appears to be no published right of appeal.
This proposed Byelaw is discriminatory, singling out seaplanes as an easy target. As such it is a direct attack on all pilots and our freedom to fly. Today it is Loch Lomond and seaplanes ? Tomorrow …. who knows – will all other lochs and every other light aircraft wishing to fly over National Parks be targeted ? It is based on hyperbole, distorted facts, knee-jerk political response and ignorance. These misrepresentations must be challenged and by as many individuals as possible.
Let the Loch Lomond National Park and the Scottish Parliament know that the flying community will put up a fight.
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