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Observation 35:  Fatally flawed Proposals
 
Green Key Proposals Formal notification of Objection to proposed strategy

Having considered in detail the proposals contained in the consultation document I find myself with no choice other than to object to a document I consider to be both fatally flawed and an inappropriate use of public money. Can I also express my concern that while you placed the consultation on the internet to facilitate public access you provide no internet access to the key documents referenced by the consultation document. This to my mind substantially reduces the scope for informed criticism of the underlying assumptions on which the document is based.

The reasons for my objection and an indication of areas I find I have a common interest are broken down as follows

Section 1

This section lays down the fundamental basis for the remainder of the document. To my view it is neither contentious not warranting further comment

Section two

This section marks out the grounds upon which the strategy is to be based.

I would however contend that many of the assumptions are based on a catch all definition of tourism. This seems to define a tourist to mean any person from outside the area that is entering the park. It makes no differentiation between different types of visitor e.g. mountain walker/climber, coach tripper, non walking visitor, sightseer. This failure to recognise the different types of user entering the area under consideration is to my mind the underlying strategic weakness of the whole document and one that leaves it fatally flawed.

Taking the key points in turn

The juxtaposition of 2.2 and 2.3 suggest a cause and effect relationship with the cure being force people out of their cars within the towns and you will get greater spend. The comparison is them made with Lakeland towns and villages. No consideration is give to the possibility that the attractions offered by Lakeland towns are substantially greater than most towns/villages in the control area. They hence attract a greater number of coach parties and non walking visitors to them. This is likely to account for why they have a greater spend. 2.3 also identifies the reduction in length of stay. This almost certainly can be attributed to the improved access to Snowdonia afforded by the A55 making the venue viable as a day out from Merseyside. This means the area has a new type of visitor that needs to be attracted to the area

Point 2.4 marks out a seemingly frightening figure of traffic growth, but taken over the timeframe is relatively insubstantial The simple action of banning lorries from using the core area except for access to support local services would take a large chunk of this traffic out of the equation. A large percentage of the remainder could be removed by cutting down on town based tourist and local movement by car between villages and attractions.

Points 2.6 and 7 are largely irrelevant to this proposal except in that any proposals being delivered must not make the existing situation worse.

I would disagree that the statements made make the situation "neither environmentally or economically sustainable." All that they illustrate it that the area is failing to provide sufficient reasons to encourage visitors to either stay or spend money in the area and is not providing a public transport service that meets the needs of local residents.

Proposal Details Section 3 onwards

The goal set out in 3.1 is both laudable and achievable and the idea of establishing a set of towns as gateways to Snowdonia (3.2.3) with improved tourism facilities is something I would wholeheartedly endorse. Likewise the enhancement of the cycling network 3.2.4 is to be applauded and the failure to integrate a cycle route with the redevelopment of the Welsh Highland Railway is a missed opportunity. They remain the only parts of these sections with which I find myself in any agreement.

The basic premise surrounding these proposals are that people visiting Snowdonia both want to visit the towns and if we get (force) them there they will spend money. Can I on behalf of the majority of the walking community let you into a little secret. With the exception of the walking shops for gear, food shops for the chocolate bar we forgot and the pubs for a meal or a drink before going home/back to the tent/hut/hostel the towns and villages of Snowdonia hold little attraction for us.

We come to Snowdonia for the open countryside, the long walks and rock faces. We seek to get away from the throng of the city resorting only to the villages when the weather is too bad to safely walk or we want a rest in the course of an extended expedition. Herding us into the towns before we start our walks will not make us more likely to spend money in central Snowdonia. All we will do is drive through the area on our way further south to walk or climb in the Rhinogau, Moelwyns and Arans instead. Assuming of course we don’t turn our backs on North Wales altogether in favour of the welcome we receive in the Beacons, the Peak or the Lakes. In short far from encouraging us to spend more in the Central area you will drive us away from it.

So what specific problems are there with this section of the proposals as they stand. On a fundamental level the idea of drawing tourist into honeypot towns has its attractions. It allows organisations to focus the provision of related services in a specific area. The idea of expanding the public transport network to link those towns and reduce the amount of road traffic between those towns is also highly appropriate. This should reduce traffic as the town visitor can carefully control their visit to fit to a timetable. Integrating this in with cycle touring allowing a drop off and cycle back approach is also likely to generate income. However the proposal as they stand show little understanding of the needs of the hill-walking / climbing community and attempts to pigeon hole them in with other attraction visiting tourists. The first problem is the assumption that there are only a finite number of points from which walkers wish to commence their day and end it (Penypass, Idwal, Capel Curig, Beddgelert, Rhyd Ddu). Looking over my personal journals I can identify 26 locations from which I have started a walk within the control area over the past 5 years. Of these fewer than half are on the proposed network of Sherpa routes and most have only a handful of people using them on any given day all starting and finishing at different times.

How many buses each day will you run to Gwernydd or must I walk an extra 3 miles from the A5 in Bethesda, from Llwyn Eigau or must I add 7miles onto the walk and start in Talybont. These proposals therefore mean that walkers are being forced into a decreased number of start points limiting choice, increasing erosional pressures on those areas and greatly reducing the enjoyment of the area due to the increased human presence. As such they run counter to the CROW act and interfere with my civil liberties.

The next problem is in the frequency of buses. Nowhere is this exactly spelt out other than at least every half an hour. If on a cold wet October day when I am soaked to the skin I arrive at Idwal at 8pm in the evening having missed the bus by a minute how long will I have to wait 1minute, 5 minutes, 10 minutes, 30 minutes an hour or have I even missed the last bus.

If while waiting, instead of immediately changing into the dry clothes that await me at my car, I shiver away and am subsequently taken ill or worse exhibit signs of hypothermia will the authority compensate me for loss of income for any days I take off work?

If I am walking late into the evening what time will the last bus run and in converse if I finish my walk what guarantee will I have that I will not be stranded waiting as one full bus after another passes me by meaning I arrive home too late for something I had planned to do in the evening. Figure 1 gives no indication at all of these.

Next what happens if I stay in the area. I’m most likely to camp or use a climbing hut but am unlikely to walk from the base. Since many of these are in the central area but remote from the bus routes are you seriously suggesting I drive past the point from which I intend to walk to a gateway town in order to catch a bus back. On the surface that is what the logic of the proposals suggest. If this is the case will you compensate the owners of these remote facilities whose value has now significantly declined?

Then your proposals for parking and their charging structure are counter productive. The average hill walker/climber will drive into the area at an economical 50mph, where road conditions allow, park the car disappear for between 4 and 10 hours then repeat the journey in the other direction. For a car park that houses 50 vehicles in the course of one 12 hour day about 100 journeys will be made to it. If you reduce the time allowed to 2 hours you change the user from walker to sightseer. The journey speed will drop as they absorb the view, as will that of every other user behind them, reducing fuel efficiency and increasing environmental damage. At the same time assuming maximum stays are used that same car park will now generate 300 journeys all of which could have been better made from a bus.

Finally there are the assumptions of economic benefit. The initial work identifies a benefit of 107 jobs for an investment of £65k each. Assuming the 107 is correct these are the only new jobs that are guaranteed. The income projected from the scheme as a whole assumes existing users will continue to frequent the area and new users are attracted. However having made all those statements in the main document we come to the admission in the strategic aim 1.1 that the "needs and expectations of the wide range of people that "use" Northern Snowdonia" are not known as there is a target to "complete an appraisal of visitor and local needs and/or expectations." Since these are unknown on what basis are the projections of £3m, £9m and £27m and their consequent job based. To illustrate an alternative impact let me consider my most recent trip to the area.

"I left home about 7am driving up to Ogwen and started walking about 10.30. I finished about 4.30 and dropped down into Capel where I looked around the walking shops, finding nothing I needed I picked up a mars bar and travelled on to Betws y Coed. There I picked up the first aid kit I had been looking for for £15 and a few additional items I had not planned for a total spend about £25. I drove home stopping for fuel outside Dolgellau where I purchased some more chocolate arriving home about 7.30." Net spend in central area £26

Under these proposals I could see the following scenario happening. Stop at Betws (£4 to council) and picked up a bus, the wait and drive meant I wasn’t walking till 11and a further half hour was lost at the end of the walk. Pressed for time I didn’t want to risk a further long wait in Capel so missed the shops there. Short on time and needing to get back home I went into the first shop in Betws and picked up the first aid kit not stopping to look round the store (£15) Arriving back home later than planned at 8.15 I missed helping put my children to bed Net spend in central area £19.

In this instance the area would have lost at least £7 spend with the food shop in Capel receiving no income. Further the bus adds in a factor that is outside my control so had I needed to guarantee being home by 8pm the additional uncertainty of the bus journeys would without question resulted in me changing my plans and walking in southern Snowdonia. A net loss of £26 to the area.

In this case far from increasing spend in the park the proposal would lead to a fall off in expenditure with the village in the core being worst hit.

Conclusions

So in summary I welcome the decision to review the traffic management regime in the central area of the park. However, based on personal experience, I believe your basic assumptions and hence your proposals are fatally flawed.

In particular;

  1. They interfere with the basic concept of the National Park and open access legislation by forcing walkers into a number of honeypot locations.
  2. They place the health and safety of walkers at risk in inclement weather as walkers either rush to meet a bus or wait long periods having just missed one.
  3. They increase the number of potential car journeys by encouraging short term parking thereby increasing throughput at sites within the core area
  4. They reduce the likelihood of casual visits to shops at villages by introducing parking charges or additional waits for buses
  5. They reduce the likelihood of casual visits to shops by walkers in all towns by increasing the time taken to travel from doorstep to start of walk.
  6. They increase the money spent on parking (government) and thereby reduce the disposable income available to spend in shops (private)
  7. They reduce the attraction of Snowdonia in the autumn and winter months by cutting down further the available daylight time by increasing journey times.
  8. They assume that the proposals when enacted will have no detrimental effect on walking visitor numbers. Yet the proposals very first strategic target recognises that the needs of users are currently unknown by calling for an appraisal.
  9. They assume that cyclists will be attracted to the area by the prospect of using paths that are little more than an extension of the carriageway while failing to improve safety by removing any lorries from the road that adjoins them.

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