The heated controversy over the planning application for Flamingo Land’s Lomond Banks raises wider questions over what Scotland’s National Parks are for, say campaigners.

Such is the concern that Nick Kempe, author of the parkswatchscotland blog, has called for the Scottish Government to conduct  "a proper review of what our National Parks have achieved before it progresses anything further in Galloway.”

Kempe joins others who say that the Lomond Banks plan for a large shoreside resort, with hotels, lodges, swimming pool, craft brewery and monorail in Loch Lomond & The Trossachs National Park (LLTNP), raises questions about the performance of our current parks. With a new Scottish National Park in the pipeline for Galloway, they say, a debate is needed over what we want and require of our parks.

Scottish Green MSP, Ross Greer, who has been fighting the Lomond Banks development since 2017, said: “There's a wider issue here than this one development. Are National Parks just a different way to foster so-called ‘sustainable economic growth’. Is that really the purpose of a National Park? Or is the purpose of the National Park to say: ‘This is an area of such outstanding environmental and ecological importance and our goal is to protect and enhance that’.”

The National Parks Act (2000) states that the aims are the following: to conserve and enhance the natural and cultural heritage of the area; to promote sustainable use of the natural resources of the area; to promote understanding and enjoyment (including enjoyment in the form of recreation) of the special qualities of the area by the public; to promote the sustainable economic and social development of the areas’ communities.

But is too much priority being given to economic development, and in particular large commercial ventures, over protecting the environment? And, given tourism is a key feature of our National Parks, how can it be developed  in a way that protects wildlife and keeps damaging over-tourism at bay?

As one of the architects behind the petitions that resulted in Lomond Banks becoming 'the most objected to planning application in Scotland’s history',  Greer believes the reaction says something about how the public views National Parks.

Bird's eye view of Loch LomondBird's eye view of Loch Lomond (Image: Archive)

“I would wager," he said, "a majority of people across Scotland think that National Parks should be there to protect the national environment and communities, and not to give companies like this a different opportunity to build whatever they want.

“There's a debate to be had around whether we should be doing developments on the scale of Lomond Banks at all.  Whether in a National Park or not, a development like that is just completely contrary to our climate objectives. It's completely contrary to a desire to create strong local economies with more small, independent businesses.

"To have got this far in a National Park, to have held a community hostage for the best part of the decade shows that there's something wrong with how we understand National Parks and their purpose. That’s pretty relevant given that we're about to go through the process of setting up a new one in Galloway, thanks to the agreement the Greens got when we entered government.”

Part of the problem, Greer pointed out, is the sheer scale of the resort and the impact on the environment of the construction process. “You don't build a development like this in an area of outstanding natural beauty without having to dig up and disturb that natural beauty. It's not just the building, but all the piping, all the sewage pipes, all the utilities, etc.”

Not all countries have the same approach to National Parks as Scotland does. In fact, many operate a more protective one. National parks in the United States, for example, are owned by the nation and strictly prohibit activities such as hunting, livestock grazing, mining and logging. With Scottish and UK parks, most of the land is privately owned, by individuals, companies, local councils and charities, and commercial considerations are often given priority over environmental concerns.

“In Scotland,” said Greer, “some people see National Parks just as a different way to do exactly the same kind unsustainable economic growth, disruptive economic growth, as elsewhere. If National Parks were really about protecting our natural environment, Flamingo Land would never have got as far into this process as they have.”

A development like this, he says, belongs "to the past" and is “incompatible with the Park’s strategies, but also with the national planning framework.”

A relevant question around Lomond Banks is whether enough consideration is being given to protecting the environment and biodiversity, as well as meeting net zero goals. Does the development’s plan for 372 parking spaces, for instance, fit with park goals relating to biodiversity and net zero?

In its 2024-29 Partnership Plan, the Loch Lomond & The Trossachs National Park Authority said that to combat the climate emergency and reduce emissions it will “address things like how people travel to, from and around the National Park as this is a major source of carbon emissions”.

Greer said: “The National Park explicitly wants to reduce the number of people who come to visit by car. And they’ve been making good efforts, with, for instance, the Trossachs Explorer, a new pilot bus between Aberfoyle and Callendar.

“The Scottish Greens have been pushing for a public transport masterplan for the whole National Park area. Something like Flamingo Land takes you entirely in the wrong direction on that ambition, generating huge amounts of additional car traffic.”

Artist's impression of Lomond BanksArtist's impression of Lomond Banks (Image: Lomond Banks)

But Lomond Banks does have its own emissions reduction plans. It has set out an ambition to become Scotland’s first “Whole Life Zero Carbon Resort” and, in creating its planning submission, has used energy specialists, Third Energy. The developer proposes to incorporate net zero concepts into every stage of development.

But also, according to its community engagement lead, Fiona Robertson, the development is in line with the National Park plan. She said: “When Loch Lomond and the Trossachs National Park was set up, it was recognised that it’s a very different type of national park to the Cairngorms. You’ve got Scotland’s biggest conurbation half an hour away. So a big part of it is about managing visitor pressure, and the National Park plan identifies as a key location which has got the infrastructure to be able to manage visitors and that is really why this whole project was started and why the fight is on for development. Lomond Banks as a project is in line with policy.”

For Nick Kempe, a key question is how commercial do we want our parks to be? He argues that in 2008,  the strategy of the Loch Lomond and the Trossachs National Park Authority  became more commercial. He also cites large-scale developments right on the shore of the loch, that have been approved by the National Park : the Hunter Foundation at Ross priory (now withdrawn), Cameron House, Kirsty Young’s luxury lodge at Inchconnachan.

“Anywhere on the shore of Loch Lomond is absolutely prime land, and the National Park hasn’t been able to draw those lines. If you try to say the most famous piece of landscape in Scotland it's probably Loch Lomond. It’s definitely up there.” 

Buchan Burn in GallowayBuchan Burn in Galloway (Image: Alarmy)

Kempe, who is calling for a review of National Parks, said: “There was a first stage review of National Parks that basically took a fairly shallow look at governance and reduced the size of the park board. That was it. It didn't look at what the Parks had achieved. That’s a fundamental lesson arising out of this. Have the National Park Authorities been applying the principles right? We need to do that before we progress anything in Galloway.”

“The Scottish Government and National Park authorities haven't engaged with what people think is valuable about National Parks. I think people instinctively know a National Park should be different. If we're going to have National Parks, we need to make them different and I don't think either of our National Parks or the Scottish Government really have a clue about how to do that at the moment.” 

A Scottish Government spokesperson said: “National Parks bring positive benefits for the environment, local communities and the economy.

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“Last month the Cabinet Secretary for Rural Affairs, Land Reform and Islands announced our proposal to create a new National Park in Galloway. NatureScot – as the Reporter - will now carry out extensive consultation and engagement with local people, communities and businesses to gauge support for the proposal and to look at specifics like the proposed boundary, the suitability of the area as a National Park and what powers and functions it could have.

“We want to hear people’s views on whether Galloway should become a new National Park. If there is to be one, it must take account of local circumstances and help meet the needs of local communities. We hope that all those with an interest will choose to be a part of this process and share their views and perspectives with us.”

Gordon Watson, Chief Executive at Loch Lomond & The Trossachs National Park Authority, said: “The National Park Authority determines hundreds of applications every year, balancing the need to safeguard the environment and landscapes, while supporting the social and economic development of its communities. We are approaching this planning application [Lomond Banks} in exactly the same way.

“Recent planning decisions taken by the National Park Authority demonstrate our commitment to achieving that balance. For example, the National Park Authority Board refused an application for a marine fish farm below Beinn Reithe, Loch Long, concluding that the risk of an escape of farmed fish, together with significant landscape, seascape and visual issues, meant the proposed development would not be appropriate in a National Park.

“A previous planning application from the Lomond Banks applicant was also recommended for refusal, prompting it to be withdrawn before the Board Meeting to take a decision could take place.”

“Why are we not leading the way with what has to be Scotland’s first eco-tourism destination?” asked Alannah Maurer. “Why are we not going from that angle? Why are we not, with every issue that we have with the climate, sustainability, committing to sustainable development goals.”