Eagle Star Life Assurance Co Ltd has applied for planning permission to build 40 houses plus a business unit on 5.3 ha (13 acres) of the 50 ha (124 acres) School Wood on the outskirts of Nethy Bridge, Strathspey. Most of the houses are very likely to be sold as holiday/second homes, with 10 referred to as "low cost", though Eagle Star are unable to say what that means. This application follows refusal last year of a similar application, for 48 houses, which was outwith the Local Plan allocation. This application is within the Local Plan.
Large numbers of objections will help to ensure that the serious environmental and social issues that this application raises are properly addressed.
Causes of concern include:
These issues are considered below:
School Wood is listed in the Inventory of Ancient and Semi-natural Woodlands as a "long established semi-natural pinewood". At present it consists of Scots pine (with some lodgepole pine and Norway spruce) planted in the 1960's, naturally regenerated pine of similar age, and older pines that survived wartime fellings. It is particularly rich in broadleaved trees: birch, goat and eared willows, aspen, juniper, rowan, bird cherry and whitebeam, and includes many fine specimens. Its soils (iron humus podsols, peats and peaty gleys) are largely pristine, having developed undisturbed under Caledonian woodland for thousands of years since the last ice age.
Species identified in School Wood include red squirrel, pine marten, otter, capercaillie, crested tit, crossbill, woodcock, and several wood ant species. Flowering plants include Pyrola (wintergreen) species, as well as the orchids: Creeping Ladies Tresses, Lesser Twayblade, and Coral Root Orchid. The latter is known from only two other places in Strathspey.
One species that would be adversely effected is the red squirrel. Red squirrels are one of the UK's most endangered mammals, and a priority species in national and local biodiversity action plans. Strathspey's pinewoods are one of their strongholds, and School Wood has a good population of red squirrels. They are vulnerable to predation from domestic cats, road accidents and contagious diseases (eg. parapox) from garden feeding stations.
The Nature Conservancy Council for Scotland in its response to the first draft of the present Local Plan 1991 stated "Woodland is a vital component of the Badenoch and Strathspey landscape and fundamental to the conservation of aspects highly important to nature conservation. NCCS ... emphasises the essential difference between remnants of the native woodland and plantation or newly planted groups of trees for amenity. Semi-natural woodlands ... are not recreatable; new stands of trees and plantation ... do not compensate for the loss of the semi-natural areas and additionally are often not of such high amenity and aesthetic value."
School Wood is one of the remnants of (largely) native semi-natural woodland referred to above, and one moreover occupying a "stepping stone" position between Abernethy and Craigmore (see below). There is probably a greater diversity of soils, plants, and animal life in School Wood than in some equivalent areas of Abernethy Forest.
School Wood lies 250m from Craigmore Wood and 500m from Abernethy Forest, and is sandwiched between them. Both these larger woods are Special Protection Areas under the EU Wild Birds Directive because of their importance for capercaillie.
This Directive requires that Annex 1 species, like the capercaillie, "must
be subject to particularly stringent scrutiny" and require "special
conservation measures concerning their habitat".
The foremost UK authority on capercaillie, Dr Robert Moss (Emeritus Fellow of the Centre of Ecology and Hydrology) has stated "the proposed development is likely to have a significant impact on capercaillie". Impacts include loss of habitat, disturbance by people and dogs, predation from foxes and crows attracted to gardens, and decreased connectivity between Abernethy and Craigmore Wood.
The capercaillie populations in Abernethy and Craigmore are not self contained. Their long term survival depends on caper being able to move easily between woodlands. This proposal would make this movement more difficult.
The Directive also requires that a development that would have an "adverse
effect" on capercaillie "in or adjacent to these sites" (i.e.
School Wood) "should only be permitted where"
* "there is no alternative solution" and
* "there are imperative reasons of over-riding public interest, including those of a social or economic nature"
In this context it should be noted that planning permission was granted for 15 affordable houses for young people in Nethy Bridge in March 1998. No development on this site has yet commenced, nor to my knowledge is any in prospect. Eagle Star include 10 "low cost houses", in their application, though Eagle Star representatives before the Nethy Bridge Community Council on 10th January this year were unable, when asked directly, to give any indication of what they meant by low cost housing. Eagle Star have also stated that they will not be the developer, since they intend that the land will be sold to a developer with outline planning permission, if granted. The developer may not eventually be bound by any such constraints.
Thus it is the case that a) there is already provision for more than adequate
affordable housing already granted planning permission within Nethy Bridge.
This provides an alternative to Eagle Star's proposal, even if it is accepted
that the latter would provide some low cost housing, which is doubtful.
b) it is most likely that any development in School Wood would be to cater for the provision of holiday/second homes. This cannot be said to be required for imperative reasons of over-riding public interest.
(It is also the case that there is provision within the Local Plan under "short term" (School Wood is "medium/long term) for approximately 60 dwellings around Nethy Bridge, which have yet to be developed. In the period 1990-2000 there were 73 births and 80 deaths in Nethy Bridge.)
Capercaillie are also a significant economic asset, and wildlife tour guides rate caper as one of the top species that people visit this area to see. Many people visit Nethy, especially in April, just to see caper.
The proposal represents an increase of about 15% in the number of houses in Nethy Bridge. As long ago as 1991, the First Draft Local Plan stated, "concern is emerging about the rate and scale of change in established villages. Unsympathetic cramming and expansion of communities is eroding their character and setting and threatening to overwhelm facilities, or creating imbalance in the social structure." Is that not what is happening in Nethy?
This proposal ignores several of the Principles laid down for Nethy Bridge in the Local Plan, viz.
The issue of low cost housing has been addressed above.
In its Key Forecasts p.5, the 1990 Structure Plan, upon which the present Local Plan is based, states that, amongst other things, "changes in population" (my emphasis)... "provide the framework within which the Council's strategy and policies will need to operate..." The population change envisaged from 1988 to 1998 was from 10,807 to 12,029 i.e. an increase of 1222 for the whole District The actual increase was 503, a mere 41% of that envisaged, and the population of 12029 is not now expected before 2014 (figures from Highland Council). Yet the Local Plan was constructed on the assumption that the population change figures were approximately correct. Clearly that assumption has been shown to be wrong, and the allocation of any housing for School Wood is inappropriate, if the Structure Plan's Key Forecasts statements are respected.
The applicant proposes "a limited number of temporary septic tanks" for sewage disposal. This is because the Nethy Bridge wastewater treatment plant will not have the capacity for further development until upgraded in 2005/6 (at the earliest). How many septic tanks, for how many houses, and for how long, is not made clear. Nor is it stated where the septic tank(s) would be, or to where they would discharge. The drainage from the School Road site flows through the primary school grounds, and from the Craigmore Road site into the Caochan Fhuarain, (noted for its purity, and this week showing signs of otter activity).
However once outline planning permission is granted, the applicant would have a legal right to build septic tanks, even though these serious questions had not been addressed. Many would consider that this problem is grounds on its own for refusal of planning permission at the present time, particularly since the allocation for housing in School Wood in the Local Plan was "medium/long term".
Published by the Cairngorms Partnership in 1999 (after the Local Plan was finalised), the Framework gives "broad guidance on the nature and location of woodland." One of its aims is: "To conserve and enhance the natural heritage, biodiversity and cultural interest of the area by:
* Enhancing the conservation value of existing [my italics] woodlands by developing effective habitat networks.
This recognises that fragmentation of existing habitats can be a potent cause
of local extinctions and that the establishment and enhancement of woodland
corridors should be a major priority within the Cairngorms area.
This is also recognised in Article 10 of the EU Habitats Directive, which emphasises the importance of "stepping stone" features of the landscape, such as small woods, which are essential for migration, dispersal and genetic exchange.
This housing allocation would damage the woodland corridor and fragment the woodland habitat of the two SPAs, and runs directly counter to the Framework and Article 10. The Local Plan in which the housing allocation is made was produced several years before the Framework came into existence, and without reference to Article 10. The Local Plan is therefore out of date.
Nethy Bridge will be included within the future national park, and almost certainly within the World Heritage Site were that to be established.
National Planning Policy Guideline 14, "Natural Heritage" states:
Under National Parks (para 33.) "planning authorities should take particular care to safeguard the landscape, flora and fauna of ... the [future] Cairngorms [National Park]", and also:
(para 51) "Planning authorities should seek to protect ... areas of woodland where they have natural heritage value or contribute to the character or amenity of a particular locality. Ancient and semi-natural woodlands have the greatest value for nature conservation."
School Wood is an "ancient and semi-natural woodland" within the future Cairngorms National Park. This sort of development should never even be considered within what is described as Scotland's finest National Park. The Local Plan allocation of School Wood for housing occurred before the national park was proposed. Again, the Local Plan is out of date.
The above gives a summary of some of the questions that this planning application raises. At heart it is a question of a huge multinational company (Eagle Star were formerly a subsidiary of British American Tobacco, and now of Zurich Financial Services, managing assets of some $543 Billion), applying for outline planning permission for what will almost certainly be holiday/second homes on an ancient woodland site in a District that in the last 20 years has already seen an increase of 52% in the number of houses.
Please write, however briefly, stating "I object to planning application 02/00045/OUTBS", preferably to arrive by 14th March, to:
Area Planning and Building Control Manager
100 High Street
Thank you Roy Turnbull
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