Here is the summary of NEMT's comments on the Main Issues Report of the Cairngorms Park Local Development Plan.
Main Issue 1: Over-arching development strategy
We agree that the current strategy, focussing on the main strategic settlements and not going for a blanket approach, remains appropriate and should be the basis for the next LDP.
Main Issue 2: Designing Great Places
This simply accepts the Scottish Planning Policy's six "qualities for successful places". However, adopting standard planning policy, places far too little weight on the Park's four statutory aims, and especially the first three. The Park's LDP should encourage the use and enhancement of vernacular building styles.
The supplementary guidance should clearly set out the highest standards for sustainability and resource efficiency and how these will support landscape and climate change policies.
Main Issue 3: Impacts and opportunities from the A9 and Highland Main Line
The opportunities in this section are clearly and explicitly linked to economic development, i.e. Main Issue 6. The main component of the Preferred Option identifying new economic development sites at Aviemore, Carrbridge, Dalwhinnie and Kincraig is common to the two Issues. Our comments are given under Issue 6.
Although, the opportunities are considered elsewhere, the impacts have been neglected. Consideration needs to be given to both the problems created in "bypassed" communities and the effects of increased commuting to both Perth and Inverness. Clear actions need to be developed to mitigate these impacts.
Main issue 4: Housing
A lot of the discussion here is about the possible need to identify alternative development land if An Camus Mor (ACM) doesn't go ahead. In a way, this is good news as the plan is starting to acknowledge that ACM is limping at best. We are pleased and hope to see, in the next update, that the development has fallen off the radar screen altogether. We support the proposal to identify a limited number of smaller sites in some communities to encourage small local infill development as a better way forward than a very large new development.
We have not commented on the individual proposals as these are best addressed by the local communities concerned, other than Dalwhinnie where there are some real eyesore sites that need to be developed before any greenfield sites are used.
We note that, even without ACM, there is sufficient land supply until at least 2023 and even then any shortfall can be easily made up by less than the proposals above. Hence, there is plenty of land identified. We need to be careful that in providing for the possibility of ACM not going ahead we don't end up with an excessive amount of development land.
Main Issue 5: The affordability of housing
We fully support the proposal to increase the affordable housing requirement from 25% in certain places. Indeed, we have been suggesting this for a long time! We also support being flexible when dealing with planning applications but urge caution against giving in too easily to developer's claims of poverty and insufficient return.
We don't challenge the rationale to increase the allocation of affordable housing to 35% in Ballater and Braemar and to 45% in Aviemore and Blair Atholl. However, it would improve transparency if this rationale was made clear.
We know that the Authority has done work on trying to increase the role of housing associations and community ownership in trying to increase the provision of affordable housing. It would be helpful if more of this thinking was shared as it seems to be a promising way forward. Similarly, has there been any progress on agreeing increased taxation on second homes with the relevant authorities? What progress has been made? Is it time to reconsider a form of residency criterion?
The document talks in general terms about affordability, without specifying an aspired target. We suggest that a target ratio of median house price to median household income be set to allow monitoring of the effectiveness of the plan.
Main Issue 6: Economic development
Economic development is only (a part of) the fourth of the Park's four statutory aims, and it is worrying that the other three aims (heritage conservation, sustainable resource use, and public enjoyment) are nowhere referred to in the "Background" section. For example, in Main Issue 3 (A9/rail upgrade opportunities), demand for development land is explicitly contrasted with "threats" such as commuting and second homes, with no recognition that meeting such demand may well damage the natural heritage of the relevant areas.
The Background admits that there is "little empirical information on which
to base land requirements", yet the Preferred Option is to allocate additional
"sufficient land", on a "propose (by developers) and provide" basis. This
Option seems selected simply on the basis that the Park's Partnership Plan states that new business sites should be identified.
Future need for sites for medium- or large-scale manufacturing or even storage/distribution seems highly dubious; the Park's future seems much more likely to be driven by tourism and recreation. These sectors exhibit mixed geographical demand, from dispersed small-scale accommodation and daytime attractions to large-scale mass-tourism centres. However, the latter seem likely to be dominated by low-wage and often seasonal employment as well as external ownership and should not be encouraged by the Plan.
Main Issue 7: Impacts on Natura Designations
We support the proposals to conserve the named species, namely the continued delivery of the Cairngorms Capercaillie Framework, and, for the freshwater pearl mussel, the proposed collaboration over waste water treatment and levels of water abstraction.
Development should not prevent habitat expansion, particularly the proposed connectivity of woodland habitats between the major river valleys. "Around half the park is designated as being of European importance for nature and conservation and over a quarter of UK's rare and threatened species are found here" but the consultation only considers two species, capercaillie and freshwater pearl mussels.
The nationally important habitats within the Cairngorms National Park should be protected from development. 14 scarce habitats are a primary reason for designation of the Cairngorms as a Special Area of Conservation. Golden Eagles and six other bird species are listed in the designation of Cairngorms and Cairngorms Massif as Special Protection Areas. These habitats and species should be protected in line with the Cairngorms Nature Action Plan. The Park Partnership Plan calls for a reversal of the loss of biodiversity within the park. The LDP should require no net loss of biodiversity in any development. Particular attention should be given to landscape scale conservation.
Main Issue 8: Planning Obligations
We agree with the proposal to produce a clearer policy on planning obligations. We encourage a tailored policy across the park so that the facilities provided are appropriate to each area. The park authority should have specific guidance for the five local authorities and other key stakeholders.
Main Issue 9: Flood risk and climate change resilience
We agree that flooding is a very significant risk and that the next Local Development Plan should set out clear policies to manage this. Natural Flood Management (NFM) is highlighted as one of the key tools to mitigate flood risk and we very much support this principle since NFM can also deliver other benefits such as biodiversity gain and landscape improvements. We also strongly support a policy that requires Sustainable Urban Drainage in all new developments. However, we are disappointed that there is no further policy intention in the LDP to encourage an integrated approach to NFM. The Preferred Option appears only to attempt to ensure that flooding is not made any worse through new developments whereas the LDP should encourage NFM in the broader design of developments, e.g. in maintaining connectivity of hydrological systems, of wetlands and of woodlands. The LDP should encourage an integrated approach and delivery at catchment scale by building effective partnerships of stakeholders to bridge the gap between policy and local implementation. Existing developments and flood risks could employ NFM measures too, through appropriate community partnerships and with advice on funding.
We note this main issue includes climate change resilience but there is no mention of how this will be taken into account. The Strategic Flood Risk assessment does indicate that developments should provide further allowance for increased flood risk and it would have been useful to indicate this in the Preferred Option too. Climate change is likely to present other risks. The very special arctic-alpine ecology of the Cairngorms is particularly at risk as are protected aquatic species reliant on cool water temperatures (e. g. salmon, freshwater pearl mussels). We expected to see more thought given to how development policy should take account of, and help to mitigate, climate change risks other than flooding (e.g., by ensuring the improvement in resilience of riparian woodlands).
The descriptions of the Potentially Vulnerable Areas in the catchments comprising the CNP are very useful context. If available, the potential for damage to infrastructure outwith these PVAs, for example to bridges and roads around Braemar, would also be very informative. A good example is the damage caused by a floating tree to the bridge at Cambus O' May.
Main Issue 10. Land Management in Upland Areas
The Background states that "Hill tracks are one form of development which sometimes falls under the control of the planning system. Whilst some tracks for agriculture and forestry purposes benefit from permitted development rights, all other new private tracks require planning permission before they can be developed." This is incorrect. Agriculture and forestry tracks require prior notification and hence do fall under the planning system.
Furthermore, the Background states that "tracks are a necessary component of land management". This is untrue. Tracks are sometimes necessary but are often not. Those built for sporting purposes are simply for convenience.
Land management in upland areas of the National Park is rightly considered to be one of the main issues for planning. The Partnership Plan for 2017-2022 recognises that hill track developments have taken place that are substandard and have had significant adverse effects on landscape. We are very supportive of the Preferred Option to strengthen the policy on hill tracks to reflect a specific presumption against new tracks in open moorland.
An associated issue is the growth of "evolved tracks" caused by running ATVs
across the same line in open, typically water-logged, countryside. The Authority
needs to consider instituting a byelaw "to prevent damage to the land and to
regulate the use of vehicles". This would not interfere with occasional use
for carcass extraction but stop repeated use along the same line.
The next LDP and the planning system should also do more to ensure that new developments do not negatively impact on the resilience of upland ecosystems to adapt to climate change or contribute to carbon storage. Furthermore, The Park Plan highlights that wetlands are small, fragmented and under a variety of pressures while supporting a great many species as well as providing natural flood management services.
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