Public Inquiry - Urquhart Castle
Urquhart Castle Action Group (UCAG)
- Final Submission
Mr. Robert McIlwraith,
Regional Director, Historic Scotland North
UCAG asked Mr.
McIlwraith whether he agreed with The Operations Manager of Inverness Traction
(Stagecoach) group that (during peak months only) the Castle's visitors
(in cars) could be ferried to and from Park & Ride areas using two coaches
plus a third in reserve (see UCAG3).
Coach visitors would continue to use the Castle car park.
Although Mr. McIlwraith
disagreed that this was possible, UCAG highlighted Stagecoach's wealth of
experience and specialist knowledge and interest in participating in a Park
& Ride solution.
UCAG also asked Mr.
McIlwraith to read SNH's letter (UCAG58) in which they stated that they believe
their earlier letter had been "used wrongly" to support the
Mr. McIlwraith was asked
how he believed the word "safeguarding" (taken from Historic
Scotland's remit - "to protect and
safeguard the nation's built heritage") could be applied to NOPD2. He stated that he believed the
Applicant was "safeguarding it by presenting it well to the public".
UCAG contends that his remarks do not adequately explain how the enormous
impact of NOPD2 will actually
safeguard the Castle, in the protective sense of the word.
UCAG showed that
although Mr. McIlwraith stated that the Applicant "was driven by the same
commercial pressures" as other businesses they are in fact, as part of
government, in a very different and somewhat privileged commercial position.
UCAG also questioned Mr.
McIlwraith on the lack of visitor surveys into NOPD1 or NOPD2. Mr.
McIlwraith said that the Applicant had conducted some "internal
surveys" (which have not been produced) but had not conducted full surveys
of visitors' views regarding the proposals. UCAG asked whether the problem was
that visitors (when asked by local businesses or on the Internet) had always
stated their total opposition and that Historic Scotland simply did not want
this answer, Mr. McIlwraith disagreed. UCAG considers that no satisfactory
alternative answer was given to the lack of visitor surveys. It is considered
very surprising that an Agency like Historic Scotland has made no efforts to
poll its visitors' opinion and UCAG is concerned as to the reasons.
Mr. McIlwraith was asked
about the normality of the day on which his video evidence (as shown during the
Inquiry) was obtained. UCAG sought to establish whether, in fact, it was a day
on which Invergordon cruise liner coaches all arrived together (having given
prior notice) on top of normal coaches, cars etc. The Reporter interrupted at
one point to clarify whether UCAG was seeking to point out that it felt it was
"a set-up job". The evidence given by Mrs. K. Matheson also appears
to support this. UCAG contends that the day in question was indeed a
predictable (and therefore avoidable) coincidence of events captured on video.
UCAG established that
land not belonging to the Applicant had been purchased from a third party and
that it now forms the location of NOPD2.
UCAG therefore established that the systematic criticism of each option (in the
Applicant's "Appraisal Of Options Document (HS16)) on the grounds that
they required land not already owned by the Secretary of State was not, in
fact, correct. Clearly, the Applicant could purchase any land required in connection with its activities, even
if not adjacent to the scheduled areas.
UCAG established that
the "illegal Park & Ride" operation last year involved
co-operation between Historic Scotland and other landowners. UCAG notes that
Mr. McIlwraith's initial denial of knowledge of the Park & Ride operation
was cleared up by Superintendent McGhee, who confirmed its existence.
Ken Wilson, Ken Wilson
UCAG established from
Mr. Wilson that NOPD2 was not
located south-west of the Castle and therefore was not in keeping with the
Local Plan (sect. 4.42).
Mr. Wilson also
confirmed that the visitor centre in NOPD2
had not been part of the "design competition" which resulted in this
proposal. Only a possible location for a centre was requested from
Mr. Wilson confirmed
that the new slope would be made from imported infill and would be largely
un-reinforced. Apparently, outlying edges of the slope would be held together
with a geotextile material. Mr. Wilson brought forth a great deal of evidence
seeking to pre-empt discussion on the potential for land slides (caused by
heavy rain or other means) and seismic activity at the site. UCAG implores the
Secretary of State to consider urgent
incorporation of UCAG 10, UCAG 11 and PPG14 into an NPPG for situations in which existing
slopes are excavated or new slopes are created. UCAG highlighted that Scotland
has one of the highest incidences of landslides within the UK and that NOPD2 will sit directly upon a known
fault, numerous natural springs and, of course, alongside the Great Glen fault
UCAG established that
most of the existing fill could not be reused due to its silty content and
therefore the new slope would require new material, putting the estimates for
the number of required lorry journeys into the upper most figure.
Mr. Wilson agreed that if you treble car-parking spaces (40 to 120) and you
treble dwell time (see precognition) you will still have the same problem of a
full car park. He replied "I suppose that is one way of looking at
it". It was also put to Mr. Wilson that the Applicant currently claims to
have about 250,000 visitors a year and claims to lose about 25,000 (see Ms.
Fiona Larg's precognition) due to a full car park. Therefore adding the
reclaimed lost souls gives 275,000 visitors a year, which is the design
capacity of NOPD2 (HS2). He again
replied, "I suppose that is one way of looking at it".
Dougall Baillie Associates
Mr. Carrie said, "I am comfortable that there could be a few years of
comfort gained by this scheme". UCAG considers that it has demonstrated
that NOPD2 is likely to be full on
the day of opening and, in any event, a few years comfort at a cost of
£4million is an outrageous proposition. The few years of comfort would
presumably be followed by even worse chaos.
UCAG agrees with NRD
that "none of us are Mystic Meg" but highlights its own
recalculations of the Applicant's figures which demonstrate that, using
additional data for Castle visitor numbers for 1996/97, NOPD2 will, in all likelihood, be full to capacity when it opens.
UCAG remembers other well-known fiascos such as, for example, the M25 motorway,
which was over capacity before it officially opened.
highlighted that summer and winter traffic at the Castle is very different.
UCAG also considers that the 44mph "design speed" was calculated
after inadequate measurements were taken on one single day. It was
agreed that the "design speed" could be very different if the
measurements had been taken over more periods, including different times of the
Variable message signs
were suggested as a means of directing traffic. UCAG points out that the usual
message may well be "Car Park Full". Notwithstanding this, UCAG did
not find itself reassured by NRD that the proliferation of signs at the dangerous
Castle bends (e.g. Entry, Exit, Pay on Enter, normal road signage, tourist
signage, stacking lane markings and new variable message signage) will do
anything other than add to the confusion and utter chaos.
Mrs. Lucy Vaughan,
District Architect - Historic Scotland
UCAG established that
Ms. Vaughan considered the maximum capacity figures for the site to be 400 in
the Castle, 400 in the new visitor centre and 200 elsewhere on the site. Mrs.
Vaughan was questioned regarding the mechanism for controlling the numbers of
visitors allowed into the Castle itself at any one time. The reply was that a
electronic till system would report on numbers going through and Mrs. Vaughan
agreed with UCAG that this meant that people would be held back in a sort of
"holding tank". This in itself leads to a great increase in
"dwell time" on site and Mrs. Vaughan was unable to provide any
information concerning the method for prioritising coaches over persons held
back in the "holding tank". UCAG also considers that it was made
clear that the mechanism could not possibly cope at peak periods, or when
sudden rain drove large numbers of people from the ruins back into the already
full visitor centre.
Mrs Vaughan also stated
that 13% of visitors arrived by coach and boat.
Mrs. Vaughan was asked
how visitors would know of the "pay on enter" philosophy given as a
mitigating factor against use of NOPD2
by non-Castle visitors (i.e. tea-room visitors). She said this could be
achieved by signage, possibly variable signage. UCAG questioned whether, in
fact, the variable message signs had already been identified as purely for Road
Traffic control purposes. Mrs. Vaughan then suggested that signs could be
placed in the new car park, but was forced to accept that signs placed in the
car park could not be seen by visitors until they had actually turned into
the car park. Therefore, UCAG clearly highlighted that there will either need
to be an incredible profusion of confusing signage at the dangerous Castle
bends or all kinds of visitors will still turn into the car park, thereby
adding markedly to the predicted numbers of vehicles entering and exiting the
site. Clearly, this matter has not been adequately addressed.
Mrs. Vaughan was asked
whether the area marked for "community use" in NOPD2 would be made freely available. She did not know.
Mrs. Vaughan was
recalled for further questioning (by the Reporter) to deal with the issue of
lighting at the site. When asked if any exterior lighting had been considered
in NOPD2, she stated that she was
not aware of any such consideration. UCAG asked whether the car park would have
a barrier at night. The answer was "no".
UCAG contends that the
"community area" is effectively useless to the community if the area
is unlit, since it is clear that it would generally be used outside Castle
opening hours and, for a good part of the year, these would be hours of darkness.
The community area also appears to have no windows so would not be particularly
pleasant for many purposes.
UCAG also believes it
has demonstrated the folly of creating a large, out-of-town, car parking area
with tree and shrub screenage while leaving it unlit during the hours of
darkness. The area may be used for unwholesome purposes or as a convenient
"over night stop" for motor homes, caravans etc. UCAG's witness, Mr.
Dick McMillan MBE, gave evidence that the area around the existing car park is
"filthy". This problem may be seriously compounded by NOPD2.
UCAG also pointed out
that adequate lighting in the new car park could constitute serious light
pollution, in this most sensitive area and this matter has not been, as Mrs.
Vaughan admitted, adequately addressed. Light pollution is a matter of planning
concern at this sensitive location.
UCAG questioned the ease
with which the "reduced" kitchen area to the tea-room in NOPD2 could be returned to NOPD1's restaurant size version. UCAG
successfully demonstrated that, physically, only one light
"stud" partition would need to be moved. The tea-room, already agreed
as equivalent in seating capacity to the original restaurant, could then be a
fully functional restaurant with a magnificent view over the Castle and Loch
Ness. UCAG's witness Mr. Dick Beach, proprietor of the "Fiddlers"
restaurant in Drumnadrochit gave evidence that the tea-room would cause him
serious damage but a restaurant at the magnificent Castle location could
devastate the village's existing facilities.
Mrs. Vaughan stated in
her precognition that one of the benefits of NOPD2 would be the removal of "the existing shop, the
temporary toilets in the ditch and the mobile food van and ticket office."
UCAG obtained agreement that any of the suggested alternatives could achieve
the same objective.
Ms. Fiona Larg, Chief
Executive Inverness & Nairn Enterprise
Ms. Larg admitted that
the percentage figures provided in her precognition relating to village support
for various options at the Castle site were derived from just 78 letters. She
did not provide the Inquiry with any tangible evidence of these documents or
their contents. UCAG notes that, despite endless requests and offers, these
letters have never been forthcoming and are, in consequence, hearsay.
UCAG established that
Ms. Larg considered that the Applicant had made "significant
concessions" in NOPD2 that
mitigated its effects on the community. UCAG then established that Ms. Larg did
not feel that this "out-of-town" plan would damage the village (this
evidence clearly conflicts with the 7-11% downturn predicted her own
organisation's assessment). UCAG contends that there is an inconsistency in all
of this evidence since, if no damage would occur via the out-of-town NOPD2, then it must follow that the
"mitigation" and "concessions" are actually irrelevant.
Notwithstanding this, UCAG established that Ms. Larg does not agree with the
independent report by Development Options (UCAG61), commissioned by her own
agency. The report clearly states that "…the single most important visitor
attraction related issue for Drumnadrochit is Castle Urquhart (p36)." The
"car park and visitor centre at Castle Urquhart would provide an
alternative major visitor attraction to Drumnadrochit itself." Also,
"the implementation of such a proposal would damage the potential for
developing Drumnadrochit as a centre for visitors (p37)".
provision of the shuttle bus should provide the core of an integrated transport
system..(p40)". "The advantage of using this approach is that it
supports the further development of Drumnadrochit as a centre for visitors
UCAG has demonstrated
that the report by Development Options is extremely relevant and detailed. It
is the only independent report that actually deals with the whole of the
Drumnadrochit area in detail, unlike other more tightly focused, or blinkered,
reports (before or since).
considerable inconsistencies between past INE economic impact assessments of
options for the castle. The fact of business displacement is no longer
disputed, merely its extent and duration. It was felt that the latest INE
economic impact assessment made too little allowance for the "Loch Ness
focus factor". This assessment also failed to reassure local businessmen
who at the least, would have to adopt a "wait and see" policy in
regard to their own development plans. They are also unsure of how long the
economic damage would last. Ms. Larg
readily agreed that the tourist proportion of traffic on the A82 closely
matched that of the A9 and that therefore Drumnadrochit could not expect to
attract visitors to the area but rather, must rely upon the proportion who stop
on their way through.
Ms. Larg agreed under
cross-examination that she was not aware of the detailed financial position of
village businesses, as she had not seen their accounts. She said that some door
to door visits had been made but agreed that "you cannot get a very
accurate picture by simply asking questions of businesses" in that context.
She was unable to say how much damage the 7-11% loss of turnover
mentioned in her precognition might do to local businesses.
Mr. Patrick, Town
UCAG discovered that Mr.
Patrick did not feel that alternative options were a material consideration for
planners. He did however agree that no provision for a tea-room, shops or café
had been made for Urquhart castle in the Local Plan (sect. 4.42). He also
agreed that development between the A82 and Loch Ness would fly in the face of
the Development Plan and all
planning convention and precedent for the area. It was also agreed that the
Development Plan was a statutory
consideration and that Development Control policy 7 was a material
Mr. Patrick agreed that
geology of the site was a material
consideration for planners but that there are no guidelines in existence
(in Scotland). UCAG again hopes that the Secretary of State will urgently
consider an NPPG on this matter
(taking into account UCAG10 and UCAG11 and PPG14).
Mr. Patrick failed to
convince UCAG that a presumption to leave in situ did not mean the same as a
presumption against excavating the artefacts (NPPG5). UCAG felt that, on this
point, Mr. Patrick was not logical and should have heeded the words of
Dennis Healey; "when you find
yourself in a hole, stop digging".
Mr. Douglas Sampson,
Derek Lovejoy Partnership
UCAG succeeded in
highlighting the inadequacies of the digital pictures and "artist's
impression" sketches used by Mr. Sampson in his evidence. It is clear from
Mr. Sampson's own precognition that the digital photos provide a "backbone"
that lacks detail and Mr. Sampson readily agreed under cross examination that
there is no "depth of field" or "perspective" in them.
Given that this is the case, the artistic impressions produced from these
images cannot be considered to be even remotely accurate.
demonstrated that Mr. Sampson, while evidently very capable of landscaping a
large new building in a man made area such as Milton Keynes, cannot possibly
improve upon the natural setting of Urquhart Castle's surrounding countryside
(no human being could do such a thing). UCAG believes that his display of the
geotextile material (synthetic netting) aptly demonstrates the alien
inappropriateness of this whole project. The natural beauty of one of the most
well known views in the Highlands cannot and should not be meddled with.
Additionally, Mr. Sampson stated that the development would start to look more
settled after the first five years, a lot better after ten and settled after
fifteen years or so. Asked whether this meant we needed to wait fifteen years
to see if his experiment would work, he answered "that a lot of us will be
dead by then anyway". UCAG contends that the lengthy period, which even Mr.
Sampson concedes will be required for the massive scars on the landscape to
heal, is no laughing matter and will, by itself, greatly detract from the
enjoyment and amenity of the unique Castle site. It could easily seriously harm
the international view of the area, its reputation and its tourist economy.
Fifteen years would, in any event, be well beyond any estimate of the life of NOPD2, in terms of its design capacity.
Mr. Sampson gave
evidence that he would provide "glimpses" of the Castle from the car
park to draw people to it, but that the car park would not, in turn, be visible
from the Castle. UCAG asked if he meant he was going to use some sort of
"one way trees" for screening. UCAG notes Mr. Sampson's analogy
through which he sought to explain the "one way glimpse" paradox. He
stated, "a man sitting in a tree waiting to shoot you could see you, but
you could not easily see him". UCAG points out that a car park is much
larger, much more visible and much more dynamic than a man in a tree.
Mr. Sampson systematically
failed to convince UCAG under cross-examination that he could "improve the
natural setting in some ways".
Mr. Sampson stated that
he absolutely disagreed with the submission of the Royal Fine Arts Commission.
Asked why they might have lodged such a strong objection, he stated that he
felt they had made up their minds first and then written their submission to
fit. UCAG pointed out that this might have been the case for Mr. Sampson but
received no reply.
pointed out a contradiction between Mr. Sampson's evidence and that of Ms. Lucy
Vaughn. Para 5.14 of Mr. Sampson's precognition states that "planting on
the roadside must be kept to a minimum due to the sight lines required at the
exit point. This will in itself facilitate views from the A82 into the upper
area of the car park making people aware of its existence and encouraging them
to stop". This directly contradicts para 4.3 of Ms. Lucy Vaughn's
evidence that a "prime objective" is to "[make] as much of the
proposal as possible invisible when viewed from strategic points such as; the
Mr. Nicholas Brigland, HM Inspector of Ancient Monuments
Mr. Brigland, HM
Inspector for Ancient Monuments, agreed under cross-examination that the
Applicant should have commissioned the Headland Archaeological Report much
earlier in this process. He said that if the report had been available
before the Applicant lodged its proposals he would have advised against
pursuing this plan. Mr. Brigland agreed that NPPG5 left no doubt that the
preference is to leave archaeological remains in situ, undisturbed. UCAG
accepts Mr. John Wood's (Council Archaeologist) assertion that the remains are
unique and not properly understood and should be left undisturbed, in
accordance with NPPG5.
Mr. Brigland also
agreed, under cross examination by UCAG, that Historic Scotland, as a
monitoring and regulatory authority given powers over third party planners and
developers, had not set the "best example" by their conduct.
UCAG successfully demonstrated
that the previous Community Council gave detailed consideration to NOPD1 and NOPD2 and, following active Public Meetings in the village,
rejected them on two occasions.
UCAG demonstrated that
between the last considered rejection of the Applicant's plans and the recent
volte-face the only material change was the discovery of archaeological remains
in "Trench 9" (Headland Report, HS
). UCAG demonstrated that the new Community Council's position must
therefore be, at best, inconsistent with the facts of this matter as they have
come to light. UCAG also demonstrated, through cross-examination of Mr. Alan
Bell, that the Community Council had not given consideration to Headland
Archaeological Report and very little to any of the other reports and
documentation concerning the Applicant's proposal. Possibly a case of "not wishing to be burdened by
facts". UCAG discovered, through cross-examination, that at least one
of Members participating in the Community Council debate was the spouse of a
Historic Scotland employee working at the Castle. Except for this Member, Mr.
Bell accepted that no others had direct links with the important tourist
economy in the local area.
Mr. Bell denied
knowledge of correspondence received by the Community Council either in favour
or against their decision but acknowledged the existence of at least one letter
strongly against (published in the Inverness Courier, UCAG 66). Mr. Bell acknowledged, under
cross-examination that the Castle had not
been an issue in the Community Council elections. To his knowledge no election
literature or canvassing mentioned the matter. He agreed that some candidates
who were known to support the Applicant's Proposal lost, as well as some
candidates known to oppose it (and vice versa). This proves beyond any
reasonable doubt that NOPD2 was not
The Community Council's
precognition is considered, by UCAG, to present a list of reasons to oppose the
Applicant's proposal, rather than to support it. The precognition is noted to contain the following line
"members felt that most who had approached them (not a representative
random sample) were in favour but then states that "this was not the case
for all members".
UCAG notes that some
Community Council members sought to introduce a second precognition into this
Inquiry without seeking the formal authority of its own Members. UCAG also
notes that this second precognition was then pulled out of the Inquiry after it
had been delivered and a third precognition was entered (equivalent to the
first with the addition of a Community Councillor's name on the top). UCAG
contends that the confusion of the Community Council is indicative of their
competence on this whole matter.
UCAG has demonstrated
that the Community Council's recent decision could most generously be
considered as ill-considered and inconsistent. UCAG looks forward to its
Mrs. Margaret Davidson
demonstrated that Mrs. Davidson's so called "polls" of village
opinion on the issue of Urquhart Castle are not backed up by any tangible
evidence and that the "polls" were not conducted with a
consistent methodology. Mrs. Davidson accepted that she had sought to
"explain" the proposals to a proportion of those she
"polled". This was contrasted by a variety of petitions collected by
UCAG and produced in evidence to the Inquiry (including 169 local signatures
against NOPD2, all of the
mainstream businesses in Drumnadrochit and Lewiston and thousands of
Internet letters and submissions).
Mrs. Davidson argued
that her fellow supporter, Ms. Fiona Urquhart, had canvassed most of the local
"bed and breakfast" supply community and that the majority supported NOPD2. UCAG demonstrated, under
cross-examination, that, since Ms. Urquhart was absent from the Inquiry and had
only told Mrs. Davidson of the poll, it amounted to hearsay about hearsay.
Again, in complete contrast to UCAG's productions, no tangible evidence
of any description has been placed before this Inquiry. UCAG witness, Ms. Elma
Urquhart, who has lived and worked in the Glen for some 49 years also gave
evidence that directly contradicted Mrs. Davidson's comments on the views of
local community opinion. Mr. Charles Kennedy has also made his views known to
UCAG highlighted that
the claimed moderation or downgrading of the "restaurant" to a
"tea-room" following the rejection of NOPD1, and thus fulfilling the wishes of the Highland Council, was much devalued by the fact that the food
retailing area was actually called a "tea-room" in the original
plans of NOPD1 submitted to Highland
Council in May 1996. UCAG contends that it had only "grown" into a
"restaurant" so it could be downgraded to a "tea-room"
later, as a grand gesture of compromise. Mrs Davidson was asked if, as a Councillor,
she had ever observed that developers sometimes ask for more than they needed,
so that by appearing to compromise they would actually achieve their original
objectives. She said she had not noticed such things.
demonstrated that Mrs. Davidson's allegations of self-interest made in her
precognition were false and designed only to damage its members' credibility.
Mrs. Davidson was forced to accept that many members of UCAG had no identifiable vested interest
of any kind, and that her personal attacks and remarks were simply malicious
Mr. Allan Sellar,
Provost Highland Council
UCAG quickly established
that Mr. Sellar simply believed that his colleagues on Highland Council had
conspired to wreck Historic Scotland's plans as "an act of vengeance"
for previous disagreements between the two organisations. UCAG considers this
to be a remarkable and, frankly, ridiculous slur on the Council and forced Mr.
Sellar to accept that many Councillors had made impassioned speeches regarding
the integrity of Urquhart Castle and its setting.
UCAG also demonstrated
that Mr. Sellar had very little grasp of the facts, since he failed to realise
that his example of a tragic fatal accident at the Castle exit had actually
taken place elsewhere. UCAG also showed that, in any event, NOPD2 would not materially improve the
chances of avoiding such an accident in the future.
UCAG clarified that,
despite submitting his comments on Town House headed paper, Mr. Allan Sellar's
view was his personal view and was not in any way officially sanctioned.
Kathleen Matheson, Tour
UCAG contends that it
established that many coaches visiting Urquhart Castle offload at the site and
then travel to Drumnadrochit car park where they wait, empty, until returning
to the Castle to collect their passengers. This uses up valuable parking space
in Drumnadrochit in the peak season.
Mr Alastair Mackenzie
Mr. Mackenzie suggested
to the Inquiry that the planning process could not be used to prevent
commercial competition and claimed that village businesses would not be harmed
by the Castle proposals. Under UCAG's cross-examination former Councillor and
local shop owner, Mr. Mackenzie (now retired in both respects) accepted that he
had been instrumental in passing the "Urquhart Castle Off-Street Parking
Order" (UCAG 14). The bye-law expressly forbade the sale of goods at the
Castle and Mr. Mackenzie was the supermarket owner in Drumnadrochit at the time
it was put through (naturally, all businessmen fear commercial damage of their
own businesses and wish to protect them). UCAG thereby demonstrated that there
was, at best, an inconsistency in Mr. Mackenzie's evidence. Clearly,
yesterday's village businessmen feared the damage an "out-of-town"
Castle development would do to them. Today's businessmen now face the same
UCAG established that
Northern Constabulary's Area Commander, Super Intendent McGhee has serious
safety concerns about the continuing operation of Urquhart Castle as a visitor
attraction. He also voiced worries about the footpath adjoining the A82, as it
nears the Castle. He also indicates his concerns regarding the hazards inherent
in a major construction operation at such a dangerous location. He has
indicated, as have his predecessors, that closure of the Castle must be
considered as an early option if matters are not resolved soon. UCAG accepts
that closure of the Castle car park is therefore a viable and safe solution
for, if it were not, it would not have been suggested by Superintendent Finlayson
(UCAG 42) and Superintendent McGhee at the Inquiry. UCAG accepts that it could
be closed temporarily, while a solution is implemented, or permanently. The
Secretary of State may wish to consider whether the imminent threat of a
serious or fatal injury at the location merits such action.
readily confirmed the existence of last year's illegal Park & Ride and UCAG
showed that the cars which successfully parked at this offsite location would
need to be added to the numbers accommodated by NOPD2.
UCAG has successfully drawn attention to
the unrepresentative data used in the preparation of visitor growth
projections, which have lead to the erroneous conclusion that the project is
viable to 2008, when 277,000 visitors are predicted.
UCAG has produced
recalculations of Ken Wilson Associates tables showing that the data selected
was more favourable to Historic Scotland,
by a factor of more than 2, than any other projection of visitor
growth which could reasonably be produced, based on figures in H.S.
The KWA table showed
visitor numbers growing at an average rate of 4711 per annum. UCAG recalculations showed a range of growths
between 9459 and 20,432 per annum, indicating that
capacity would be reached, at latest, by the (expected) second year of
Counsel for Historic
Scotland argued that the 1996 and 1997 figures are unrepresentative. UCAG would
say that they are real figures, but to
accommodate H.S. Counsel's concerns here, if data from those years is
excluded, the lowest of our predicted growth rates is lost in the
process, and our lowest growth rate based on data in precognitions now rises to
10,240 per annum.
It can be seen that
visitor figures predicted by KWA for the years 1996 and 1997 are underestimates
by 36,105 and 32,438 respectively of the actual turnstile figures in those
years. This alone should have triggered a recalculation by Historic
Scotland. It did not.
Historic Scotland itself
suggested, in Mrs Vaughan's evidence, that almost 87% of visitors arrive in
cars. This conflicts totally with KWA's basic design assumption that the figure
is 40%. There are also inconsistencies in the estimates of dwell time. They
appear never to have been measured yet they are a critical design parameter.
KWA assess that traffic
and visitor growth will total 34%
over a ten year period, in line with the Design Manual for Roads and
Bridges High Growth Estimate.
Alas, Mrs Vaughan
indicated that visitor numbers grew by 15%
in 1995, and a further 20% in 1996,
showing that the DMRB rate of growth is inapplicable to a visitor attraction,
and fails to take account of such variables as, inter alia, exchange rates,
perceived security risk, movie releases, industrial action in the transport
sector, and the weather.
While UCAG identified
the years chosen as a basis for growth calculations
as unrepresentative, it
also criticises the arithmetic growth model used as being rather unusual, and
point out that percentage growth models are more generally used.
Two other methods of
assessing the long-term viability of the car park have been mentioned. In the first, the idea of tripling the car
parking space from 40 to 120, followed by tripling the dwell time from 40 minutes
to 2 hours, leads inevitably to the concept of no net gain over the present
In the second even
simpler method one takes the visitor figures
produced for INE by Ms Larg, which were 250,000 admissions in 1997 and
25,000 turned away.( – this last figure was first used in an INE – HS document (UCAG 60) as early
as 7/10/94, and may well have grown by now.)
One simply adds those
entering to those trying and failing to enter, to get 275,000 in total.
UCAG also pointed out
that the 1997 visitor numbers were achieved by utilising additional parking
space in the village car park for empty buses, and an unofficial Park and Ride
scheme from Borlum Farm at peak season. Turnstile figures show numbers paying
to get in, without commenting on where they parked while they did so. Testimony
from local residents suggests that far more than 40 car spaces were being
employed thus defeating implications that 40 spaces can accommodate 244,000
visitors per year.
UCAG has shown that the
calculations of future car parking space requirements are fundamentally flawed and
invariably underestimates. The fact that NOPD2
is not viable has hereby been amply demonstrated.
Ms. Heather Cary
UCAG notes that Ms.
Cary's option is radically different to that presented within Historic
Scotland's "Appraisal of Options" document (HS ).
The plan is presented as
a viable and sustainable alternative to NOPD2
and is, most importantly, reversible - if and when demand for car parking at
the Castle falls away.
Ms. Cary's option offers
future scope for enlargement and could be cut lower into the ground to further
conceal its layout. Trees and / or a bund could provide heavy screening. Again,
this screenage would be removable in the future. The proposed car parking area
is located away from the Castle, would be an order of magnitude cheaper to
implement and could co-exist with a Park & Ride or integrated transport
solution, if so desired. A modest display area and toilets could easily be
accommodated within the proposed layout.
Like other options in
HSxx, Ms. Cary's option has not been accurately and fully explored. Ms. Cary
also stated that her proposal is based on an acceptance that the Castle road
improvements (listed for NOPD2) and bus park improvements would also be
Mr. A. Shine, Chamber of
UCAG demonstrated that
too little weight had been given to the Highland Council's Development Control
Policy No7, even though it formed part of the Local Plan. Mr Patrick agreed
that this Policy did make the safeguarding of investment within established communities,
a matter of material consideration. Furthermore, he saw some justification for
the rejection of NOPD1 on the
grounds of scale since the Local Plan specific to the castle, makes no
reference to catering or retail facilities. It is argued of his view that
"visitor reception facilities" should be interpreted as containing
these elements, is subjective when judged against reception facilities at other
UCAG did show that
opposition to the proposals was effectively universal among local businesses and that this opposition is
current. It is accepted that there are individual bed and breakfast proprietors
in support but it has been shown that commercial impact upon them is more
neutral and it appears that some were under the impression that an
accommodation booking service was to be operated from the castle. It has also
been made clear that a park and ride solution to the problems at the castle is
that favoured by local businesses. These facts are not obscured by there being
two or more businesses on one site or more than one proprietor of a business.
The use made of the petitions in production entirely supports the conclusions
stated in precognition.
The planning application
made by the chamber for the village car park was outline only and while it was
certainly introduced in order to bring the park and ride concept within the
planning debate there was no wish to cast details in stone. Highland Council
only received a tiny handful of letters of objection. Rightly or wrongly it was
a conscious decision of the Chamber to step aside, pending this public enquiry.
Mr. Takala, Internet
UCAG showed that
thousands of letters and messages have been received from local people,
nationals and internationals. The letters have been available to read during
the Inquiry and were sent to Highland Council and The Secretary of State.
The Internet campaign
demonstrates a weight of feeling against both NOPD1 and NOPD2 as,
prior to Highland Councils meeting, many earlier respondents were in fact
re-contacted, given details of the changes and asked to comment. The opposition
figures stayed broadly consistent with earlier figures.
highlighted the value of many of the submissions, given that they came from
Castle visitors or those knowing the area extremely well.
UCAG also demonstrated
that the area is extremely prone to land slides and heavy rain damage and drew
attention to UCAG10 and UCAG11 and PPG14. UCAG hopes that the Secretary of
State will review these documents and close what it perceives as a loophole
within the NPPG series.
UCAG considers that,
given Mr. Patrick's confirmation that geology is a material consideration, it
has cast some doubt on the suitability of NOPD2
for its location.
Mr. Alastair Macpherson
UCAG showed that two
meetings of the "Working Party" set up to explore options for
development at Urquhart Castle were simply inadequate. No significant changes
were made to NOPD2 and Mr. Macpherson expressed his view, as a member of the
working party, that it had been a waste of time.
UCAG also highlighted a
local fear that development at the Castle will open the floodgates to an
Aviemore style over development of the loch's shoreline.
UCAG produced evidence
to the Inquiry showing that some 95% of mainstream businesses in the village
had signed up in opposition to the Applicant's proposal.
UCAG demonstrated that a
Park and Ride would be a viable stand alone solution or could be integrated
into an integrated transport system. It is a solution waiting to happen. The
Chamber of Commerce had sought to demonstrate the local wish by businesses to
get together and help themselves by facilitating a Park & Ride, as they had
already successfully developed the car park with Highland Council.
UCAG demonstrated that
this is a community that can help itself to solve problems and succeed and it
should be allowed to do so.
UCAG highlighted Mr.
Menzie's concern that previous planning mistakes such as Bridge Street in
Inverness and the Supermarket in Drumnadrochit (nominated Radio Scotland's ugliest
building in Scotland) should be learned from and used to prevent fresh follies.
UCAG noted that at least these disasters could be reversed in the future,
unlike NOPD2, which would effectively remain, like Dounraey, forever.
UCAG believes that the
scale of impact to the Castle and its setting was best appreciated during the
site visit. Sadly, the scaffolding erected to demonstrate the degree of
intrusion to Highland Councillors, before their Planning Meeting (Sept. 96),
was not available for consideration by the Reporter. The scaffolding left some
Councillor's visibly shaken at the time. However, it was possible to pace out
from the Castle to the toe of the slope and this comes within just 30m of the
castle moat. It is not difficult to imagine the impact that the scheme's steep
slope would have on the site from all the major vantagepoints. The Castle would
be dwarfed by a modern day construction, described by Mr. Charles Kennedy MP
(in his submission to this Inquiry) as a "literal blot on the magnificent
The walk along the A82
was most interesting because it was clear that some motorists did indeed seek
to enter via the Castle's Exit and also a high speed overtaking manoeuvre took
place as a car turned into the Entrance. Given the short duration of observation
(a few minutes), and the odd but undoubtedly calming impact that a large group
of clip board wielding individuals must have had upon the traffic, it is clear
that the road is far more dangerous than the National Road Directorate
has led this Inquiry to believe. UCAG feels that it clearly demonstrated that
NRD's reliance on one day's design speed to get around the need for vast
improvements is simply reckless and may easily result in a future catastrophe.
UCAG implores the Secretary of State to review this matter as common
sense tells all of us that the road around the Castle is extremely dangerous.
UCAG and many of its opponents agree that this road is very dangerous.
UCAG points out that
there will be little improvement to the Exit, or egress from the site,
and that it may be made more dangerous as southbound traffic speeds increase
due to the reduction of stacking on the A82 (southbound). It was clear during
the site visit that coaches were unable to make a left turning exit without
crossing the centre line of the carriageway. Post NOPD2 traffic making a right turn exit from the site will need to
negotiate oncoming southbound traffic, traffic coming from the south and
turning right into the castle using the new "deceleration / stacking
lane" and north bound traffic. These factors, combined with the high
numbers of foreign tourists involved are a recipe for disaster.