Royal Commission Condemns Urquhart Castle Plans

[Thomas Woodrow]

ROYAL FINE ARTS COMMISION for SCOTLAND CONDEMNS CASTLE PLANS:

This scheme "would constitute an offence to the unspoilt countryside
of its setting"

As the public inquiry into Historic Scotland's proposed new car park
extension, visitor centre and retail development at Urquhart Castle
enters it second week, the Royal Fine Arts Commission has strongly
attacked the scheme.

The Commission was established to report upon questions of public
amenity under Royal Warrant in 1927. It has issued a written
submission to the Inquiry and stated that "the Secretary of State
attaches great importance to maintaining a high standard in the
appearance of new development, and considers that the Commission has
an important role to play". It also clarified its position regarding
this controversial proposal: "[our] concerns are with the setting of
Urquhart Castle. The first principle should be the care of the Castle
and the character of its setting for posterity."

It further pointed out that "an enlarged road-side car and coach park
on a supporting structure could not be provided without detrimentally
affecting the setting of the Castle and therefore the experience of
the visitor."

The Royal Commission commented on the "sandcastle" form of the lift
shaft giving access to a "bunker type building designed to house a
café, shop, ticketing office and toilets". It stated its intention
for the strongly worded document to be available to "the Council's
legal representatives and others opposing the deleterious visual and
other impacts which an ill judged and inappropriate design would have
upon the lonely setting which gives Urquhart Castle its greatest
distinction."

The Commission "considers it commendable that the Highland Council at
Urquhart Castle have demanded the exploration of alternatives; and
that the Reporter has in his notes of 20 March 1998 recognised
possible alternatives to a criticised scheme as a legitimate subject
for the inquiry."

The language used by the Royal Commission leaves little doubt of its
members' strength of feeling regarding Historic Scotland's plans: "The
scheme is extravagant both in its land take and in its structure. It
would constitute an offence to the unspoilt countryside of its
setting; and to the simplicity of local vernacular buildings. It would
greatly detract from the qualities of this site of national
importance".

The Urquhart Castle Action Group (UCAG) welcomes the Royal
Commission's submission and agrees with its findings. After a week in
which the Inquiry was told (by witnesses for Historic Scotland) that
"nature could sometimes be improved" at sites like Strone Point, UCAG
looks forward to presenting a very robust case against the monster
sized Loch Ness development.

You can find out much more information about the Castle and this
planning proposal at:

http://www.lochness.co.uk/castle

Thomas.
PS.
Here follows the full text of the Commission's submission:

Urquhart Castle Public Inquiry: Written Submission

Introduction: Role of Royal Fine Art Commission for Scotland

1.1
The Commission was established to report upon questions of public
amenity under Royal Warrant in 1927. The current Terms of Reference
are dated 1953. Under these Terms, the Commission calls the attention
of Departments of State and other public bodies to amenities of a
national or public character. It is authorised and empowered to call
people before it to give explanations; to invite the production of
papers; and to inspect sites. National Planning Policy Guideline Note
I on the Planning System (paragraph 73) states that 'The Secretary of
State attaches great importance to maintaining a high standard in the
appearance of new development, and considers that the Commission has
an important role to play'. The current Scottish Office Circular on
Consultation with the Royal Fine Art Commission for Scotland is SODD
Circular No 30/1996. Both the Terms of Reference and this Circular
are reproduced in the Commission's ]7th Report to HM the Queen through
Parliament, Command 3431 on pages 41 and 44/5 respectively, RFACS
Production

1.2
The Commission was consulted by Highland Council in 1996 on the
proposed development by Historic Scotland to improve visitor
facilities at Urquhart Castle, Drumnadrochit, Loch Ness, by increasing
car parking provision and providing a new visitor centre. This
proposal fails within the criteria for referral of cases to the
Commission as defined within SODD Circular 30/1996 (RFACS 1). The
Commission's considered advice to the Council is expressed in letters
to the Director of Planning dated 12 June 1996; 13 September 1996; and
13 June 1997. Productions RFACS 2, RFACS 3 and RFACS 4 respectively.
These show that the current scheme proposed by Historic Scotland
represents a concept which is unacceptable to the Commission, and
which, even in its own terms, is inappropriately detailed. This
submission to the Inquiry represents the consensus view of the
Commission.

Main Points of Representation:
2.1 To quote the Commission's letter of 12 June 1996 to Highland
Council, ' The Commission's concerns are with the setting of Urquhart
Castle. The first principle should be the care of the Castle and the
character of its setting for posterity. The demand of the tourists of
this generation should be met only in ways which do not offend this
primary principle. The policy should not be to offer less and less in
the way of genuine historic experience to more and more visitors. An
enlarged road-side car and coach park on a supporting structure on
the hillside above Urquhart Castle could not be provided without
detrimentally affecting the setting of the Castle and therefore the
experience of the visitor. This car/coach park could not be expanded
in the future without further damage the Castle's setting.

2.2
The Commission discussed the case of the proposed Visitor Centre and
coach/car park at its meeting on 6 April 1998 in preparation for the
public inquiry due to start on 2 June 1998. The proposal still
appeared to consist of improvements to traffic arrangements at the
trunk road/lay-by junctions by forming a right turning stacking lane
and deceleration lone; the existing lay-by to be reformed to accept 12
coaches and four cars towing caravans; at a lower level, a car park
for 120 cars to be supported on the roof of a bunker type building
designed to house a cafe, shop, ticketing office and toilets; and a
lift shaft to be expressed externally as a 'sandcastle' form, with a
canted wall to an oval plan.

2.3
The Commission observed that its advice was generally in harmony with
the Council's decision to refuse consent to Historic Scotland.
Following discussion, the Secretary was therefore instructed to
prepare the Commission's evidence to be given to the inquiry in
written form. It would thus be available to the Council's legal
representatives and others opposing the deleterious visual and other
impacts which an ill judged and inappropriate design would have upon
the lonely setting which gives Urquhart Castle its greatest
distinction.

Urquhart Castle:

3.1
Urquhart Castle is a Scheduled Ancient Monument, which is described by
John Gifford in his Highland Buildings of Scotland volume in the
series, as 'A ruined stronghold on a promontory jutting into Loch
Ness. The position is of strategic importance, commanding the
landward route down the west side of the Great Glen and the entrance
to Glen Urquhart'.

3.2
Gifford continues that 'The site is shaped like an hourglass, the
centre of its north bulge filled by a knoll, the south bulge rising
quite steeply from the low waist to a craggy hill at the south west
corner. Cliffs on the east and north made attack from the loch almost
impossible. On the west and south side is a curved ditch, some 4.9 ms
deep and up to 30 ms broad; it is partly artificial, the man made
excavation perhaps dating from the early Middle Ages'. The A82 Trunk
Road lies to the west of the site.

3.3
The Commission would agree with the Environmental Appraisal (page 14)
which states that 'the Castle promontory is an imposing feature in the
landscape, most particularly from the loch itself, from the far side
of Urquhart Bay to the north and from the bend in the A82 to the north
west. In addition, the Castle itself offers splendid views out over
the loch and surrounding scenery'. indeed, the Environmental Appraisal
states that 'very little in the way of man made structures impinge on
this largely natural setting'.

The Site:

4.1
The site lies between the A82 Trunk road and the Castle. It is
identified within the Environmental Appraisal (page 22) as comprising
a car park on a wooded embankment with a footpath which leads visitors
down the embankment to rough grassed area and then to the Castle. The
proposed scheme will extend the embankment over the grassed area and
bring the 'toe' of the embankment some 45 metres closer to the Castle.

Development Plan Considerations:
5.1
Urquhart Castle lies within the area covered by the Drumnadrochit and
Fort Augustus Local Plan, prepared by the former Highland Regional
Council, and adopted in October 1991 (Production RFACS 5, extract).
In reference to the visitor facilities at the Castle, paragraph 4.42
of the plan states that 'The car and coach park, however, frequently
becomes overloaded during the peak summer season. The need for
additional parking together with a visitor reception centre to replace
the temporary ticket office has been recognised by the Scottish
Office. Given the steep terrain, the facilities might be accommodated
by way of a 'terraced' layout to help absorb development visually, and
minimise construction costs, although land has not yet been secured.
There is a need for a bus stop opposite the Castle'.

5.2
Within the associated Policy the plan states that 'The Council will
encourage the provision of additional visitor facilities at Urquhart
Castle, subject to the availability of land. A scheme to provide
additional parking preferably to the south west of the Castle, and a
visitor reception centre would be appropriate. The layout and siting
of these elements will require to safeguard the setting of the Castle,
and a high standard of design and landscaping will be essential'.

5.3
The Commission would of course support improvements to motor traffic
arrangements between the A82 and any coach/car park. The principle of
improving coach/car parking must also be commended. The Commission
must however, warn that Historic Scotland's proposals would
detrimentally affect the setting of the Castle, and thus the
experience of the visitor; and that the proposals are therefore
contrary to local plan policy. The scheme is extravagant both in its
land take and in its structure. It would constitute an offence to the
unspoilt countryside of its setting; and to the simplicity of local
vernacular buildings. It would greatly detract from the qualities of
this site of national importance.

5.4
Page 15 of the Environmental Impact Appraisal states that 'there is no
doubt that the proposed development will impinge on the setting of the
castle site even more than the present car park'. However, it
considers that this impact would not be significant if the landscape
measures defined within the proposals are as successful as those used
for the existing car park. Indeed, the Appraisal states on page 20
that 'the proposed scheme does not therefore appear to alter the
historical setting of the monument as this precedent (of the existing
car park) has already been set'. Any precedent which is open to
criticism, however, should never be followed uncritically.

5.5
These proposals, even in their reduced form would radically alter an
area of landscape right above the Castle, more extensive than the
Castle rock site itself. The Commission can find no evidence within
the Environmental Appraisal demonstrating that Historic Scotland's
proposed intrusion is acceptable in this historic landscape setting of
Urquhart Castle.

Design Team:
6.1
In the Environmental Impact Assessment, page 4 paragraph 2.00 'Members
of the Design Team' states that the Project Architect is still 'to be
appointed'. James Maxwell and Company, stated in the EIA to be the
Landscape Architect, does not appear to be a chartered landscape
architect as recorded by the Landscape Institute in its list of
members.

The Commission would expect the architect and landscape architect in
the design team to have the duty to provide the vision for the site
and purpose proposed. The scheme's failure to convince the Commission
may be explained by a lack of suitably qualified and appropriately
experienced professional consultants in the design team at the
conceptual stage, who could have steered the clients away from the
present proposals.

6.2
With regard to the five Historic Scotland members of the design team,
it may be that Historic Scotland have differing judgements of their
responsibilities to their professional archaeological interests and to
safeguarding the nation's built heritage and promoting its
understanding and enjoyment. The Commission considers it commendable
that the Highland Council at Urquhart Castle have demanded the
exploration of alternatives; and that the Reporter has in his notes of
20 March 1998 recognised possible alternatives to a criticised scheme
as a legitimate subject for the inquiry.

Towards Acceptable Solutions:
7,1 The Commission would draw attention to exemplars such as the city
centres of York and Durham, where motor traffic is largely excluded;
and Fountains Abbey and the Castle at Lindisfarne, Holy Island where
able bodied visitors are obliged to walk. At Castle Howard, effective
measures have been taken to manage tourists and their vehicles: and
the Commission has recently been consulted on comparable measures
proposed for Culzean. At Callanish, a visitor centre has been
developed which is of a contemporary design yet in harmony with the
best buildings in Lewis. Among its most successful aspects is its
location which totally conceals it and its coach and car park from the
Callanish Stones.

7.2 At Urquhart Castle, the Commission can not deny that the
proposal offers improvement with regard to the situation which has
developed at this point on the A82 Trunk Road during the summer weeks
of maximum tourist activity. However, the Scottish Office
Deve1olDmentDepartment National Roads Directorate and the Council's
officials as well as the police authority would not deny that
alternative motor traffic management solutions, including those at
other locations favoured by the Commission, could also be designed to
provide equivalent improvement.

Historic Scotland as a central government authority, in full
co-operation with other central and local government and police
authorities as well as neighbouring land owners and boat owners,
should therefore devise a series of smaller schemes which in aggregate
would sol the motor traffic problem and satisfy demand for parking. A
team of planners of proven ability to produce the right concepts
should be appointed.

7.3 The Traffic Impact Assessment claims to have been carried out
generally in accordance with the guidelines issued by the Institution
of Highways and Transportation, but with certain limitations (due to
time constraints). For instance, where there are alterations proposed
to the highway, in this case, the A82, IHT advise that there should be
a 15 year traffic forecast. Only a ten year forecast is provided.

7.4
On page 5 of the TIA, projections are based upon previous visitor
figures. 'To allow for increased traffic generated by the new
development, this increase will be doubled for the first three years
from opening.' This prediction, (in circumstances where it would be
reasonable to assume a sensitivity test of plus or minus 500/o ) is
speculative in the extreme. The TIA states that the proposed extra
parking would be adequate. There can be no certainty as to when it
would no longer be adequate. Adequacy or inadequacy will depend not
only upon growth in visitors to Urquhart Castle. but also upon growth
in traffic on the A82.

7.5 There is a contradiction as between the evidence presented on
page 5 of the TIA and the statements by the same consultants in
paragraph 6.8 of the Environmental Impact Assessment on the subject of
Traffic Noise and Vibrations. The above observations demonstrate the
advisability of reviewing the TIA evidence strictly within the
Institution of Highways and Transportation Guidelines.

7.6 in paragraph 6. 10 of the Environmental impact Assessment,
entitled Vehicle Travellers, it is stated that the travellers' view
from the road would be unlikely to be changed significantly by the
proposals. The Commission is far from convinced.

7.7
The Environmental Impact Assessment does not adequately address
questions as to what the proposal would look like, from the A82 above;
from across Drumnadrochit Bay; from the approaches by water from
across the loch as well as from the Inverness and Fort Augustus
directions; and from the hill walks and high vantage points which are
so important to this area. 7.8 The Commission therefore advises that a
series of photo montages from many points at different times of the
year (as they affect deciduous trees) would confirm that the
development would be too extensive and would come too close to the
Castle to avoid affecting its lonely , rural setting unacceptably and
would in terms of both its building and its landscape need to be
reduced , simplified and revised radically in order to be in harmony
with the landscape of the Great Glen and the monument of the castle.

Options.

8. It is not the Commissions intentions below to do more than point
the way to a possible solution and to amplify the messages contained
it its letters to the Director of Planning mentioned in 1.2 below.

8.1
Historic Scotland's Option: Bremner Option & Strone and the Cary
Option.

With the help of the Scottish office National Roads Directorate, the
road structure at Tinny Bank on the M74/M6 should be studied (see p] 8
of the Commission's 17th Report. Production RFACS 1). This road was
designed for the Scottish Office Development Department National Roads
Directorate by Fairhursts, engineers; RPS Cairns, landscape
architects; and Percy Thomas Partnership (Ran Weeks) architects.
Following many months of design exploration attempting to devise a
satisfactory way of locating a terraced dual carriageway for the new
M74 it was discovered that a single shelf, with the hillside above
steepened to the maximum possible extent, was the option least
damaging to the environment. (it should be noted that this conclusion
contradicts the suggestion of terracing quoted in the local plan -see
paragraph 5. ]above).

With the Tinny Bank example in mind, a strong planning and design team
needs to reconsider the above three options for Urquhart Castle at the
existing lay-by not as rival schemes but as a single, straightforward
'shelf on the hillside' lay-by solution for a suitable proportion only
of the total parking requirement.

8.2 Borlum Farm
Borlum Farm offers a parking site which is potentially excellent for
the proposed purpose because it is both out of sight and within easy
walking distance of the castle. This area below the A82 at use it is
both out of sight from and within easy walking distance
This scheme needs to be planned professionally to be environmentally
acceptable and satisfactory from a practical point of view to
contribute to a fair proportion of
the total parking requirement to an overall solution. Again, the
example of the 'single shelf'
solution at Tinny Bank should be borne in mind when planning and
designing any

8.3 A shuffle bus from Drumnadrochit and a shuttle boat from
Temple Pier These are both very attractive options, especially for the
busy summer weeks. The boat trip especially would provide an
experience for visitors of memorable quality (a matter to bear in mind
when so much of Historic Scotland's evidence is quantitative). With
professional planning advice and a grasp of successful examples in
other parts of the world, shuttles could be made to work as useful
contributors to an overall long term solution.

9. The Visitor Centre
Its earlier correspondence and its advice above show that a joint
'belt and braces' strategy exploiting all available options
simultaneously is recommended by the Commission. It might therefore
be that visitors would arrive on foot at the Castle from three
different directions; from the A82 above the Castle, as at present;
from the Barium coach and car park via a lower contour; and from the
pier. The Commission therefore recommends as an essential next step
the appointment of an architect/planner team to advise on the
philosophy of preservation, conservation and continuing history as a
basis for drafting a fresh brief for a Visitor Centre, to take into
account the factors such as are mentioned above. A sensitively
designed Visitor Centre (or its constituent parts) as part of the
monument might be considered as a possible solution. It would have
precedents at Castles and other places owned and managed by Historic
Scotland.