WHAT IS THE NATIONAL PARK’S REASONING ?
Good question ! Please read on and discover their irrational attitude. We hope that by the end of these pages you will have enough facts, material and motivation to make a worthwhile contribution to the Consultation process. If you can demonstrate through skilful use of facts the hypocrisy and double standards of the National Park Board, then all the better.
When we examine the briefing put out by the National Park, we should remind ourselves of what we understand by ‘National Park’. We are not dealing with a pristine natural wilderness, miles from habitation where you need a permit to enter a fragile ecosystem (such as is found in other “National Park” areas around the world).
We are dealing with a huge leisure and recreation resource, cited within 20 miles of Scotland’s largest city, 10 miles from Western Europe’s largest nuclear weapon store and with millions of visitors and vehicle movements per year. A National Park that contains newly developed golf courses, hotels, retail and leisure developments and numerous diesel powered motor cruisers.
IN EVERY ARGUMENT OR LETTER THAT YOU SEND IN, PLEASE KEEP IN MIND (AND CLOSE TO HAND) THE FOUR AIMS OF THE NATIONAL PARK. IF YOU CAN SHOW THAT THE BYELAW IS CONTRARY TO ANY OF THESE STATED AIMS, THEN THAT WILL CARRY A LOT OF WEIGHT.
THESE FOUR AIMS ARE -
So EXACTLY what is the National Park’s Objection to Seaplanes?
No-one has actually clearly said what the problem is. First it was noise, then when those arguments were refuted, it was pollution. They too were refuted, and now the real opposition seems to be ‘because’.
This hardly seems a fair basis to structure a Byelaw. Indeed a similar Byelaw was considered in 1994 by the Scottish Executive but was removed as it was considered to be unfair. What has changed to make it fair now ? Could it be that the National Park just want to test their muscles and never mind who gets in their way ?
If you read the Byelaw proposal, you will find 5 issues that will apparently be taken into consideration for any application to operate a seaplane. These are stated below -
1 – Noise Impact - will seaplane operations (landing, taxiing, taking off) result in an unacceptable increase in noise above the ambient noise, both in relation to the areas of the loch in the vicinity of the proposed landing/taxiing route and to the nearest land, including any islands?
2 – Wildlife - the operations must demonstrate that wildlife is not disturbed through aspects such as noise, shadow, effect of landing and taking off.
3 – Loch Users – the operation of a seaplane may increase the likelihood of unacceptable conflicts with other users of the. Activities such as landing, taking off and taxiing to the proposed landfall is considered to increase the likelihood of unacceptable conflicts. The Park Authority will consider whether the operator has taken adequate safety measures in relation to other loch users in respect of the proposed seaplane operation and in relation to emergency
4 – Servicing of Aircraft - the Park Authority will consider whether those activities associated with the servicing of a seaplane, which do not require planning permission, are considered to raise unacceptable hazards. In particular, the appropriateness of any proposed refuelling points and refuelling and servicing practices.
5 – Commercial Passenger Service – where the proposed seaplane relates to a commercial passenger service the operator would supply details of the proposed licensed aerodrome area, including details of clearways and movement areas and any apparatus required for Civil Aviation Authority licensing purposes, including marker buoys.
In relation to ALL proposals the operator will be expected to supply –
· Details of the proposed landing and take-off area, required take-off and landing clearance area, taxiing route and landfall
· Details of intended protocol for dealing with the presence of other loch users in the proposed landing area, including proposals for alternative landing areas
· Details of aircraft including engine type
· Details of the proposed flying days per year, number of flights per day, frequency of flights and operating hours
· Details of any shore-based supporting operations, including details of refuelling activity and measures to deal with any emergency incidents.
· An assessment of noise impact on the proposed seaplane activity including a selection of nearby shore-based locations agreed by the Park Authority. Such assessments should highlight the likely changes in relation to normal ambient noise levels at such locations.
In the next section we will examine these 5 points above in detail together with additional views and counter-arguments. We will also show how the Byelaw conflicts with the 4 stated aims of the National Park. Please bear with us, while we seek to enlighten you !!
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