CAIRNGORMS NATION­AL PARK: ECO­NOM­IC ACTION PLAN 2019 – 2022

Paper 3 Annex 2 6^th Decem­ber 2019

1. Intro­duc­tion

A total of 21 writ­ten responses were received and these are sum­mar­ised in this report under head­ings that related to each of the three ques­tions that were asked. The respond­ents are lis­ted below.

Ref	Name/​Organisation	Ref	Name/​Organisation
AC	Aber­deen­shire Council	HC	High­land Council
AE	Alvie Estate	NK/PW	Nick Kempe/​Park­swatch­scot­land
AGCT	Aviemore and Glen­more Com­munity Trust	RT	Rothiemurchus Team
BNG	Bòrd na Gàidhlig	RSPB	Roy­al Soci­ety for the Pro­tec­tion of Birds Scotland
BSCG	Badenoch and Strath­spey Con­ser­va­tion Group	SCNP	Scot­tish Cam­paign for Nation­al Parks
CC	Cairngorms Cam­paign	SE	Scot­tish Enterprise
CBP	Cairngorms Busi­ness Partnership	SLE	Scot­tish Land and Estates
FSB	Fed­er­a­tion of Small Businesses	SNH	Scot­tish Nat­ur­al Heritage
GB	Gor­don Bulloch	TGDT	Tomin­toul and Glen­liv­et Devel­op­ment Trust
GBA	Grant­own Busi­ness Association	WTS	Wood­land Trust Scotland
HIE	High­lands and Islands Enterprise

2. Trends, Chal­lenges, Oppor­tun­it­ies or Data Sources

Q1: Are there oth­er sig­ni­fic­ant eco­nom­ic trends, chal­lenges, oppor­tun­it­ies or data sources that we should be tak­ing into account in devel­op­ing this Action Plan?

(Graph show­ing responses to Q1)

2. The fol­low­ing were sug­ges­ted as addi­tion­al data that should be util­ised further:

• Nat­ur­al her­it­age data improve­ment should/​could be an aim (for example the Ancient Wood­land Invent­ory (AWI) is unre­li­able) — WT, RSPB
• 2011 Census — SLE
• Eco­nom­ic Value Added — CBP
• Eco­nom­ic, Social and Envir­on­ment­al Con­tri­bu­tion of Landown­ers in the CNP (2013 Report) can help identi­fy some of the eco­nom­ic pri­or­it­ies of land-based busi­nesses in the Park — SLE
• Busi­ness Baro­met­er — SLE
• Num­bers using food banks — RT
• House prices (e.g. House prices and rents by travel to work area and house type (exclud­ing detached homes)…expressed as a % of the aver­age for Scot­land — RT
• Num­ber and fre­quency of homes advert­ised to rent as long term/​permanent homes — RT
• Pro­por­tion of afford­able homes that provide a fair oppor­tun­ity for people in loc­al jobs to rent or buy — RT
• Num­ber of suit­able open mar­ket homes to rent and buy that are lived in by people in loc­al jobs where they don’t need a car to travel to work — RT
• Busi­ness premises avail­ab­il­ity and rents — RT
• Time taken to fill an advert­ised job — RT
• Permanent/​seasonal employ­ment and aver­age length of employ­ment — RT
• Out­comes achieved from sup­port for Forestry, Farm­ing and Her­it­age land use and the levels of pub­lic sup­port where applic­able — RT
• TGDT happy to provide its data on vis­it­or num­bers etc. — TGDT
• Scot­PHO Health and Well­being Pro­files — SLE
• Improve­ment Ser­vice provides a range of data and ana­lys­is tools (includ­ing a com­munity pro­filer, inter­act­ive map­ping of Scot­tish Neigh­bour­hood Stat­ist­ics data) — SLE
• Loc­al Gov­ern­ment Bench­mark­ing Frame­work — SLE
• NOMIS — SLE
• Scot­tish House­hold Sur­vey – e.g. social justice and trans­port — SLE
• SIMD (index of depriva­tion based on: income; employ­ment; hous­ing; health; edu­ca­tion; skills and train­ing; geo­graph­ic access to ser­vices and tele­com­mu­nic­a­tions; and crime) — SLE
• Scotland’s stat­ist­ics (wide range of eco­nom­ic related data mostly at a vari­ety of dif­fer­ent geo­graph­ies. It includes fig­ures on employ­ees by industry, busi­ness sites by industry, earn­ings, labour mar­ket indic­at­ors and a vari­ety of bene­fits data) — SLE
• % employ­ment in retail should be included — GBA
• Rur­al pay­ments and data provided through the EU/​others for nature con­ser­va­tion pro­jects — SCNP
• Fin­an­cial con­tri­bu­tion (of) renew­ables to the rur­al eco­nomy — SCNP

3. The pro­posed Action Plan: Themes and Actions

Q2 Do you sup­port the actions to deliv­er the eco­nom­ic strategy as set out in the Nation­al Park part­ner­ship Plan?

(Graph show­ing responses to Q2)

Theme 1. Build­ing on Eco­nom­ic Strengths of the Park

Dur­ing the con­sulta­tion peri­od the Cairngorms Busi­ness Part­ner­ship under­took a sur­vey of mem­bers, ask­ing which of the four Park aims each busi­ness felt it was con­trib­ut­ing towards. The res­ults are sum­mar­ised below:

(Graph show­ing res­ults of survey)

In their com­ment­ary on these res­ults the CBP noted ​“The above demon­strates how busi­nesses play a sig­ni­fic­ant role in the col­lect­ive deliv­ery of all four stat­utory aims of the Nation­al Park. We recom­mend that the EAP is changed so that it recog­nises the con­tri­bu­tion of the loc­al eco­nomy towards such col­lect­ive deliv­ery and explains that a strong and sus­tain­able eco­nomy sup­ports all four stat­utory aims.” (CBP)

Theme 2. Sup­port­ing and Attract­ing Businesses

Loc­al and Oth­er Businesses

CNPA’s (lim­ited) resources should be re-focused to enable a thriv­ing loc­al eco­nomy, giv­en the import­ance of the loc­al eco­nomy to the deliv­ery of all four stat­utory Nation­al Park (NP) Aims (CBP, SLE, SE).

Oth­er sug­ges­tions from sep­ar­ate respondents:

• Rur­al Devel­op­ment Frame­works – HC exper­i­ence re land use plan­ning, busi­ness devel­op­ment and hous­ing policy can con­trib­ute to pro­gress­ing rur­al devel­op­ment frame­works (HC).
• Con­ven­tion of the High­lands and Islands (CoHI) tal­ent attrac­tion group – HC is a mem­ber and can add value to action plan activ­it­ies re sup­port­ing and attract­ing busi­nesses (HC).
• New invest­ment for example to provide infra­struc­ture: CBP recog­nise the abil­ity and track record of the CNPA in lever­aging sig­ni­fic­ant invest­ment. CBP are keen to work in part­ner­ship to lever­age invest­ment that improves some of the infra­struc­ture chal­lenges we face (CBP).
• Attract­ing New busi­ness sec­tors: There is poten­tial for diver­si­fic­a­tion towards new/​higher value sec­tors such as life sci­ence, cre­at­ive indus­tries, renew­able energy and spe­cial­ist tech­no­logy (RT).
• Devel­op­ing an entre­pren­eur­i­al cul­ture — SLE wel­come the inclu­sion of this pro­gramme of events to devel­op an entre­pren­eur­i­al cul­ture. Efforts could be strengthened by dir­ectly involving HIE/​Scottish Enter­prise to help deliv­er spe­cif­ic sup­port to entre­pren­eurs (SLE).
• Sup­port for action re sup­port­ing busi­ness with start-up and growth oppor­tun­it­ies — par­tic­u­larly those that that fit with the eth­os and tra­di­tions of the Park (such as food, tim­ber, sport, learn­ing, her­it­age, health, music and dance) and/​or diver­si­fy the eco­nomy (RT).
• Lack of invest­ment south of Aviemore — CNPA should con­sider wheth­er the A9 dualling might bring an oppor­tun­ity for addi­tion­al road ser­vices facil­it­ies in the area (HIE).
• EAP should emphas­ise import­ance of diver­si­fy­ing the eco­nomy into new indus­tries (HIE).
• EAP should give more recog­ni­tion to import­ance of tech­no­logy and advanced engin­eer­ing and have a new theme of Tech­no­logy, Data and Innov­a­tion (HIE).
• Pub­lic sec­tor invest­ment should not be used to devel­op busi­nesses in com­pet­i­tion with the private sec­tor (AE).
• EAP should acknow­ledge the situ­ation of small busi­nesses and the neg­at­ive effects on them from lar­ger devel­op­ments that bene­fit from sub­sidies (BSCG).
• The pro­posed new dis­til­lery (at Crag­gan) should be included in the cap­it­al invest­ments examples (GBA.)
• Sug­gest action on new modes of busi­ness sup­port, pro­gressed in part­ner­ship with busi­ness asso­ci­ations (GBA).
• VAT threshold is a bar­ri­er to employ­ment and growth — employ­ment law is stifling recruit­ment in small busi­nesses trad­ing below the VAT threshold (GBA).
• Small busi­nesses are unlikely to read EAP as they may feel EAP is too high level and does not relate to them (GBA).
• Aus­ter­ity cuts mean reduced or no small busi­ness sup­port (GBA).
• Eco­nom­ic, Social and Envir­on­ment­al Con­tri­bu­tion of Landown­ers in the Cairngorms Nation­al Park (2013 Report) high­lighted that dir­ect income from activ­it­ies car­ried out by respond­ents totalled £28.1M – although from 2013 the report is still a use­ful data source which can help identi­fy some of the eco­nom­ic pri­or­it­ies of land-based busi­nesses in the Park.
• Sequen­cing of plans — EAP could have informed the LDP if pre­pared in advance (CBP).
• Eco­nom­ic Steer­ing Group should include and listen to loc­al busi­ness representatives.
• Cairngorms Busi­ness Baro­met­er indic­ates low levels of approv­al for busi­ness sup­port (SLE).

Invest­ment

• CBP mem­bers repor­ted that attract­ing inward invest­ment is a key factor for eco­nom­ic devel­op­ment. They recom­mend that through exist­ing chan­nels such as the CTP and a new Eco­nom­ic Strategy group we could look more stra­tegic­ally at the types of invest­ment we want to see and work with pub­lic sec­tor part­ners to tar­get and attract those invest­ments. CBP would be very will­ing to play a full and act­ive role in this and with appro­pri­ate sup­port from CNPA, would con­sider chair­ing an eco­nom­ic action group (CBP).
• CNP is too depend­ent on pub­lic invest­ment and the role of private invest­ment needs to be reviewed (although Cairngorms Con­nect is a rare example of help­ful private invest­ment) (NK/PW).
• AC keen to work with CNPA on Invest Aber­deen (the inward invest­ment hub for the City Region) and the Digit­al Boost pro­gramme (AC).
• It is import­ant to engage with the private sec­tor and lever private invest­ment (SE).
• Invest­ment in infra­struc­ture should sup­port eco­nom­ic activ­it­ies oth­er than tour­ism (AE).
• Invest­ment should include adequate access, facil­it­ies and train­ing for forestry, renew­able energy, pro­cessing and value adding loc­al products (AE, CBP).
• The list of spe­cif­ic invest­ments should be removed — whilst pos­it­ive it has some not­able omis­sions and is not rel­ev­ant to any strategy mov­ing for­ward (CBP).

Increas­ing the pro­por­tion of young and work­ing age people

Sup­port expressed for actions to increase the young/​working age pop­u­la­tion – for example pro­mo­tion of work/​lifestyle bene­fits, eco­nom­ic oppor­tun­it­ies and CNP as a place. Some actions could involve work­ing with young people to max­im­ise oppor­tun­it­ies and address bar­ri­ers to liv­ing and work­ing in the Park. CBP con­sider that attract­ing Young people to stay/​immigrate should be the primary focus of the eco­nom­ic strategy (SE, CBP, NK/PW).

The situ­ation could be improved by util­ising CNP cul­tur­al cap­it­al – for example the spe­cial sport­ing culture/​high num­ber of Olympi­ans per head. This asset can be pro­tec­ted, enhanced and pro­moted to attract young people to live in the CNP (aligned with the pro­posed theme 2 action ​‘Attract­ing tal­ent and Invest­ment’), whilst also fos­ter­ing a cul­ture of per­son­al devel­op­ment, skills devel­op­ment, fit­ness and train­ing. CBP recom­mend fur­ther research and con­sid­er­a­tion to bet­ter under­stand and artic­u­late our cul­tur­al cap­it­al (for example regard­ing ski areas) — to ensure it can be con­served and enhanced for the bene­fit of the eco­nomy and com­munit­ies (RT, CBP).

Con­cerns expressed that the increase in the (Work­ing age) pop­u­la­tion has not kept pace with the growth in vis­it­or num­bers and this is likely to cre­ate issues with staffing/​quality of pro­vi­sion (RT, CBP, SLE).

Theme 3. Edu­ca­tion, Train­ing and Skills Development

Cli­mate Change Response

A num­ber of respond­ents com­ment that Cli­mate change and Biod­iversity loss (CCh/​Bd) should have great­er emphas­is in plan and CNPA actions. Reas­ons include that CCh/​Bd are the most import­ant issues facing the Park/​its eco­nomy, whilst it is also noted that nature con­ser­va­tion has primacy among the NP aims. One action re a cir­cu­lar eco­nomy is con­sidered insuf­fi­cient and a new approach/​ambition/​actions are required to address the declar­a­tion of a Cli­mate Emer­gency (as raised at a con­sulta­tion meet­ing with Scot­tish Envir­on­ment Link). The EAP should include more ana­lys­is of impacts/​opportunities – for example impacts on infra­struc­ture from an increase in extreme weath­er, increased flood risk and the effect on nat­ur­al resources (such as sal­mon and soils). The EAP should show more ambi­tion and involve people in design­ing solutions/​setting out how eco­nom­ic activ­ity can con­trib­ute to solu­tions rather than increas­ing prob­lems (WT, NK/PW, SNH, GB, SCNP, AE, BSCG, SCNP).

CNPA: the plan could pri­or­it­ise the estab­lish­ment of a net­work of elec­tric vehicle char­ging infra­struc­ture to ensure that people can move around the whole of the Nation­al Park in an elec­tric vehicle (this could be included as a meas­ur­able target\indicator)(CBP would sup­port pack­aging and pro­mot­ing this through our net­works) (SLE, RSPB, CBP, CC)

All new hous­ing in the Nation­al Park should be car­bon neut­ral (some sug­gest Passivhaus category)/have high stand­ards of design and high energy effi­ciency (NK/PW, SNH, BSCG, CC).

Train­ing should be provided (includ­ing for young people) in how people can under­stand and reduce their car­bon foot­print, improve effi­ciency, identi­fy entre­pren­eur­i­al oppor­tun­it­ies and encour­age biod­iversity as part of their cur­rent and future business/​work. It is key that res­id­ents and busi­nesses in the park have the skills and know­ledge to address cli­mate and biod­iversity chal­lenges, for example in busi­ness mod­els (RSPB, NK/PW, SLE, BSCG).

Busi­ness sup­port should be provided to address cli­mate change and biod­iversity loss (espe­cially those busi­nesses which seek to take action) (RSPB, NK/PW, SLE).

Cir­cu­lar eco­nomy — A num­ber of respond­ents com­men­ted on this:

• A busi­ness-led approach is sug­ges­ted (CBP are happy to lead on cir­cu­lar eco­nomy oppor­tun­it­ies, sub­ject to adequate resources and fund­ing being avail­able) (SLE, CBP).
• Cir­cu­lar eco­nomy should form part of the stra­tegic con­text of the Eco­nom­ic Action Plan and be giv­en great­er prom­in­ence in the actions (SNH, BSCG).
• Oppor­tun­it­ies could be iden­ti­fied by engage­ment with key stake­hold­ers to under­stand where cir­cu­lar­ity could com­ple­ment oth­er activ­ity and offer oppor­tun­it­ies for business.
• Ana­lys­ing mater­i­al flows and waste gen­er­ated by key sectors/​organisations may identi­fy help­ful actions such as set­ting strict tar­gets for waste dis­pos­al and land­fill (the hos­pit­al­ity industry may have par­tic­u­lar issues re food waste). Zero Waste Scot­land could be help­ful re oppor­tun­it­ies in key sec­tors and has case stud­ies on Edin­burgh, Tay­side, North-East Scot­land (SNH, BSCG).
• Scope for a Mon­it­or farm/​Pilot Pro­ject (one area of interest may be upland live­stock sys­tems) (SNH).
• The Cir­cu­lar Eco­nomy Invest­ment Fund has sup­port avail­able to tar­get sec­tor busi­nesses (SNH).
• AC keen to work with CNPA on the Cir­cu­lar North East programme.
• Meas­ures might include: optim­ising the energy effi­ciency of build­ings, mak­ing build­ings self-reli­ant for water sup­ply and waste man­age­ment, using green energy sources, great­er resource effi­ciency in agri­cul­tur­al prac­tices (live­stock pro­duc­tion in par­tic­u­lar) (SNH).

EAP should not include actions that add to CCh/​Bl emis­sions – for example con­struc­tion, gap solu­tions for ski-ing on Cairngorm Moun­tain without a con­sidered mas­ter­plan, actions that pro­mote driv­ing (e.g. Snow Roads). We should stop pro­mot­ing the Park for eco-tour­ism and instead raise aware­ness of the dif­fer­ent ways people can be envir­on­ment­ally friendly (BSCG, CC).

Oth­er sug­ges­tions from sep­ar­ate respondents:

• Invest­ment in nat­ur­al cap­it­al should be a key prin­ciple on which to base eco­nom­ic strategy and a Pri­or­ity Theme from which actions flow. These can include spe­cif­ic plans to identi­fy risks and oppor­tun­it­ies relat­ing to nat­ur­al assets, tar­get invest­ment, enhance skills, improve long-term resi­li­ence and build busi­nesses util­ising nat­ur­al cap­it­al assets. Anoth­er focus could be invest­ing in the growth and diver­si­fic­a­tion of busi­ness sec­tors that draw on the spe­cial qual­it­ies of the Park (such as sus­tain­able tourism/​food/​drink) and identi­fy­ing value chains that link nat­ur­al assets with loc­al busi­ness needs and poten­tial investors (SNH).
• Plan could go fur­ther in provid­ing detail on how implic­a­tions (and ensu­ing eco­nom­ic trends) will be addressed — for example re invest­ment in cycle routes/​infrastructure, green­ing meas­ures, micro-renew­ables in hous­ing and oth­er devel­op­ments (RSPB).
• Devel­op a cli­mate pos­it­ive rat­ing for busi­nesses along with a train­ing pro­gramme (CC).
• EAP should refer to cli­mate change mit­ig­a­tion before adapt­a­tion (‘we do not need to adapt to cli­mate change we need to reverse it’) (CBP).
• Lack of actions re low-car­bon trans­port and the neg­at­ive impacts of A9 Dualling are not assessed) (NK/PW).
• Work towards all elec­tric and/​or hydro­gen pub­lic trans­port and extend the net­work to and from pop­u­lar des­tin­a­tions (CC).
• Review of policies for Forestry and Farm­ing required re cli­mate change (RT).
• Energy trans­ition will be a great­er factor going for­ward (SE).
• Plan is not clear how the Pri­or­ity Themes align with deliv­ery of nation­al pri­or­it­ies – for example re cli­mate change, biod­iversity loss and nat­ur­al cap­it­al (SNH).
• SLE mem­bers can be key deliv­ery part­ners in con­trib­ut­ing to car­bon sequest­ra­tion under forestry, farm­ing and moor­land policies (SLE).
• Invest­ment in nature through nature-based solu­tions can be a cost-effect­ive way of man­aging Cli­mate risks to the eco­nomy (and be enhanced by work to con­nect the value with wider com­munity and eco­nom­ic bene­fit, such as through nat­ur­al flood man­age­ment) (SNH) we should plan for anti­cip­ated changes in cli­mate includ­ing increased fre­quency and intens­ity of flood events. Hydro dams could help (AE).
• Waste Water Treat­ment Works — EAP should refer to the prob­lem from low water flows and elev­ated tem­per­at­ures asso­ci­ated with cli­mate change (BSCG).
• Engage­ment with UNW­TO Tour­ism for Sus­tain­able Devel­op­ment Goals (SDG’s) (SNH).
• Con­struc­tion is a major con­trib­ut­or to cli­mate change and biod­iversity loss (BSCG).

Skills

Three respond­ents expressed sup­port for the inclu­sion of train­ing and skills action (TGDT endorse sup­port for CLP (Cairngorms Learn­ing Part­ner­ship), SLE#Route 2050 report pri­or­it­ies include training/​knowledge for improv­ing effi­ciency) (CBP, TGDT, SLE).

Sup­port for a train­ing pri­or­ity around tech­no­logy and digit­al­isa­tion (CBP in con­junc­tion with CNPA/HIE/SE would be happy to deliv­er and/​or facil­it­ate the deliv­ery of digit­al train­ing for all rel­ev­ant sec­tors although fund­ing would need to be iden­ti­fied — for example from CNPA/HIE) (Vis­it Aber­deen­shire keen to col­lab­or­ate with CNPA re their digit­al skills for tour­ism busi­nesses train­ing) (SE, CBP).

High­land Council’s Busi­ness Gate­way Ser­vice has provided a range of advice and assist­ance to SMEs in the area and Aber­deen­shire coun­cil keen to work with CNPA re Busi­ness Gate­way ser­vices (HC, AC).

Oth­er sug­ges­tions from sep­ar­ate respondents:

• A skills plan may help identi­fy oppor­tun­it­ies for sec­tor­al growth or poten­tially new sec­tors. Skills Devel­op­ment Scot­land (SDS) recently pre­pared a Skills Action Plan for Rur­al Scot­land: https://​www​.skill​s​devel​op​mentscot​land​.co​.uk/​m​e​d​i​a​/​4​5​6​8​3​/​s​k​i​l​l​s​-​a​c​t​i​o​n​-​p​l​a​n​-​f​o​r​-​r​u​r​a​l​-​s​c​o​t​l​a​n​d​-​s​u​m​m​a​r​y​-​r​e​p​o​r​t.pdf (SE).
• SLE#Route 2050 report pri­or­it­ies include gov­ern­ment bod­ies and busi­nesses improv­ing the use of data to tar­get invest­ment (SLE).
• High­land Coun­cil have a role in skills devel­op­ment as the loc­al edu­ca­tion­al author­ity (and work closely with Skills Devel­op­ment Scot­land) (HC).
• Unclear how skills gaps and part­ners to help close those gaps will be iden­ti­fied. Fur­ther research is required (CBP would be happy to sup­port CNPA in doing this or identi­fy­ing an appro­pri­ate body to do so) (CBP).

Theme 4. Infra­struc­ture and Cap­it­al Investment

Hous­ing

There is a short­age of affordable/​suitable hous­ing (which affects organ­isa­tions capa­city to attract and retain employ­ees) (RT, CBP, SLE, AE).

An Camas Mòr: some would appre­ci­ate a great­er sense of urgency from CNPA/​SG/​other stake­hold­ers so that the vis­ion for a new well-designed, exem­plar, sus­tain­able com­munity has the pub­lic infra­struc­ture situ­ation resolved and the com­munity can be com­menced in 2021. (CBP would be happy to use their chan­nels to pro­mote this if the infra­struc­ture was in place to deliv­er the prom­ise) (CВР sug­gest CNPA cre­ates and leads a task force for this and oth­er key devel­op­ments) (RT, CBP). How­ever anoth­er respond­ent sug­gests ACM is stopped due to it being on green space and adding to biod­iversity loss (CC).

There were a num­ber of sug­ges­tions for increas­ing the avail­ab­il­ity of hous­ing for loc­al people/​increasing hous­ing supply:

• Enhan­cing com­munity and busi­ness-led hous­ing deliv­ery sup­por­ted, (although it is repor­ted that BSW Tim­ber has already run into chal­lenges with time­frames and sup­port) (NK/PW, CBP).
• Afford­able hous­ing should be afford­able in per­petu­ity (BSCG, CC).
• There should be a change in legislation/​taxation to enable more homes for rent for loc­als (Scot­tish Gov­ern­ment policy and reg­u­la­tion does not incentiv­ise prop­erty own­ers to refur­bish and rent out exist­ing houses to res­id­ents or build new houses to rent on land they own) (AE, SLE).
• Increased tour­ism is hav­ing a neg­at­ive effect through increas­ing num­bers of second homes (AE).
• A res­id­ency cri­ter­ia should be intro­duced (so new builds are for res­id­ents) (ΑΕ).
• Sup­port for smal­ler hous­ing schemes (AC).
• Sup­port for more focus on ret­ro­fit­ting of old build­ings (BSCG).

Hous­ing Assess­ment eg Hous­ing Needs and Demand Assess­ment (HNDA) inad­equate — it omits sub­stan­tial num­bers who do not apply for hous­ing as they have no expect­a­tion of obtain­ing a home. Oth­er sur­veys should be com­mis­sioned and addi­tion­al sur­veys reviewed (an example is the High­lands Small Com­munit­ies Hous­ing Trust detailed report for An Camas Mòr) (RT, SLE).

Oth­er sug­ges­tions from sep­ar­ate respondents:

• Sus­tain­ab­il­ity — hous­ing deliv­ery needs to include hol­ist­ic con­sid­er­a­tion of factors includ­ing pub­lic trans­port, space for com­munity facil­it­ies, busi­ness, eco­lo­gic­al enhance­ment, learn­ing and recre­ation (SLE).
• No objec­tion to a review of vacant and derel­ict land and prop­erty, stalled devel­op­ment sites and impacts of short term lets – how­ever any review must be car­ried out in a trans­par­ent and inclus­ive man­ner (CBP).
• CNPA urgently need to devel­op ways to sig­ni­fic­antly reduce the level of new hous­ing as con­struc­tion is a major con­trib­ut­or to the prob­lems of cli­mate change and biod­iversity loss (BSCG).

Nat­ur­al Heritage

Sug­ges­tions from sep­ar­ate respondents:

• Invest­ment in nat­ur­al cap­it­al should be a key prin­ciple for the eco­nom­ic strategy and ideally a Pri­or­ity Theme from which actions flow (for example actions around invest­ment in growth and diver­si­fic­a­tion for busi­ness sec­tors such as sus­tain­able tourism/​food/​drink that util­ise the spe­cial qual­it­ies of the Park or actions identi­fy­ing value chains link­ing nat­ur­al assets/​local busi­ness needs/​potential investors) (SNH).
• Invest­ment in land­scape scale eco­sys­tem pro­jects should be an action (and has suc­cess­fully attrac­ted private fund­ing pre­vi­ously) (WT).
• Forestry and wood­land is import­ant both for itself and as an asset for Tour­ism. Wood­land cre­ation and pro­tec­tion (par­tic­u­larly Ancient Wood­land) is import­ant (WT).
• Repla­cing hill farm­ing with large scale forestry could have hav­ing neg­at­ive effects on hab­it­ats and land­scape (AE).
• More poten­tial oppor­tun­it­ies for Her­it­age Land Use, includ­ing coun­tryside activ­it­ies and the cul­tur­al her­it­age (RT).
• Con­cerns over the impacts of the A9 dualling (for example Cruben­more to Kin­craig sec­tion) (RSPB).
• An Camas Mὸr (ACM): A robust set of detailed mit­ig­a­tion meas­ures and mon­it­or­ing will be required to ensure that ACM does not have an adverse effect on inter­na­tion­ally des­ig­nated sites for Caper­cail­lie or com­prom­ise achieve­ment of biod­iversity tar­gets and oth­er pri­or­it­ies in the Cairngorms Nature Action Plan (RSPB).
• Scope for great­er emphas­is on the link­ages between busi­ness and nature (SNH).
• Pos­sible devel­op­ment of Land­scape Enter­prise Net­work (SNH).
• Plan should be clear that eco­nom­ic pro­jects should not have a neg­at­ive biod­iversity impact (WT).
• Increas­ing num­bers of tour­ists has a neg­at­ive effect on envir­on­ment (AE).
• Envir­on­ment­al edu­ca­tion oppor­tun­it­ies such as exhib­i­tions, sig­nage on walks, rangers and guides (AGCT).
• Con­struc­tion is a major con­trib­ut­or to cli­mate change and biod­iversity loss (BSCG).

Theme 5. Com­munity and Enterprise

There is no men­tion of eco­nom­ic prob­lems of com­munity high streets/​high streets need more sup­port (need change in con­sumers atti­tude to shop­ping loc­ally) (GB, GBA).

Sug­ges­tions from sep­ar­ate respondents:

• Social and Eco­nom­ic Devel­op­ment should be con­sidered togeth­er — it is crit­ic­al that employees/​people can live in sus­tain­able, bal­anced, con­fid­ent, strong, resi­li­ent and sup­port­ive com­munit­ies close to fam­ily, friends, employ­ment, trans­port options (RT).
• Need to make towns attract­ive places for people of all ages to live (FSB).
• Com­munity-led devel­op­ment; SLE wel­comes work to secure this after the end of the cur­rent LEAD­ER pro­gramme ends (SLE).
• Ques­tion­able wheth­er the sur­vey points for the cur­rent vis­it­or sur­vey would cap­ture many moun­tain bikers, so it is pos­sible that input from moun­tain bikers is not being cap­tured (AGCT).
• Com­ple­ment­ar­ity noted re the Cairngorm LEAD­ER Loc­al Action Group strategy object­ives with those for North and South Aber­deen­shire LAGs … par­tic­u­larly around build­ing com­munity capa­city; grow­ing the eco­nomy; attract­ing and retain­ing young people; and improv­ing trans­port and wider con­nectiv­ity, includ­ing digit­al (SE).

HIE sug­gest changes to the list of Actions and Lead organisation(s) (pages 13 – 17).

Sug­ges­tions for oth­er par­ti­cipants on lis­ted actions:

• Wages — CNPA, HIE, SDS (and pos­sibly CBP and FSB?).
• Tour­ism — CNPA, Vis­it Scot­land, CBP (as the DMO).
• Cairngorm Moun­tain — SNH, wider com­munity (rather than Com­munity Trust).
• Eco­nom­ic and social data — HIE, SE.
• Invest­ment in com­munity-led devel­op­ment – HIE.
• Devel­op­ing an entre­pren­eur­i­al cul­ture — HIE.
• Hous­ing deliv­ery — Loc­al Author­it­ies? (HIE)

Oth­er Com­ments and Information

• EAP insuf­fi­cient re key ele­ments of the eco­nomy that are a strength/​could be recon­sidered to take a more hol­ist­ic view of the strengths and poten­tial oppor­tun­it­ies with­in spe­cif­ic ele­ments of our eco­nomy for example, farm­ing and renew­able energy. Renew­able energy is a grow­ing sec­tor for many rur­al busi­nesses and it is par­tic­u­larly import­ant in the con­text of the cli­mate emer­gency, whilst although the plan talks about build­ing the case for a region­al­ised approach to agri­cul­ture, it could be more ambi­tious, spe­cif­ic and meas­ur­able (CBP, SLE).
• Inequality/​Inclusive growth — should be highlighted/​reviewed fur­ther, giv­en the much great­er aware­ness of in-work poverty nation­ally and CNP being one of most unequal places in Scot­land (SE, NK/PW).
• Rur­al devel­op­ment Frame­work: idea of long-term plan­ning for land-use, busi­ness devel­op­ment and hous­ing wel­comed (many estates already do this) and SLE would wel­come fur­ther involve­ment in this where appro­pri­ate. Any pilot frame­work needs to estab­lish that this exer­cise will not become a bur­den­some require­ment on small estates and com­munit­ies with lim­ited resources. Some SLE mem­bers indic­ated that some­thing akin to this had been developed in the pre­curs­or to the CNPA but had not been acted on. TGDT would like to be involved in a Rur­al Devel­op­ment Frame­work pilot with CES (Com­munity Energy Scot­land?) (SLE/TGDT).
• Flex­ib­il­ity: EAP needs to be (more) flex­ible re changes in the eco­nom­ic envir­on­ment. Ques­tioned what mech­an­isms will be in place to ensure the EAP can adjust actions in response to chan­ging eco­nom­ic cir­cum­stances? CBP recom­mend estab­lish­ment of an eco­nom­ic action group which could help with respons­ive­ness. (CBP, NK/PW).
• Top Down/​Bottom up: EAP needs to be more bot­tom up/​is more likely to achieve real change from a series of bot­tom up dis­cus­sions among busi­nesses, loc­al res­id­ents and oth­er stake­hold­ers focussed on how to devel­op the economy/​change land-use (CBP, NK/PW).
• EAP should set a tar­get to phase out single use plastic in the Park and lead the way in sub­sti­tu­tion of agri­cul­tur­al plastics (BSCG, CC).
• Cairngorms Con­nect should also be added to the list of ​‘Cap­it­al Invest­ment Pri­or­it­ies’ due to the eco­nom­ic value of the pro­ject, pro­vi­sion of employ­ment and nat­ur­al cap­it­al (RSPB).
• SLE mem­bers can be import­ant deliv­ery part­ners (SLE).
• Pro­posed plan has pos­it­ive ele­ments but would not deliv­er strategy dis­cussed at 09 – 2018 meet­ing between CNPA and CBP The primary ambi­tion of the eco­nom­ic strategy of the Nation­al Park should be: To sus­tain and grow the pop­u­la­tion of young and work­ing age people in the Nation­al Park (in line with the Nation­al Park Part­ner­ship Plan) and ensure the Nation­al Park is an attract­ive place that encour­ages busi­ness to invest” (CBP).
• ‘CBP met with CNPA in Septem­ber 2018, the out­put of that meet­ing was shared and agreed as a fair reflec­tion. The con­sulta­tion doc­u­ments, which we do not believe take sig­ni­fic­ant account of our input, were approved for con­sulta­tion by the CNPA Board on 6^th Decem­ber 2018. Why was the decision taken not to run the con­sulta­tion at that time when it could have benefited from both bet­ter engage­ment with busi­ness and informed the LDP con­sulta­tion? There­fore some CBP mem­bers have spe­cific­ally reques­ted that the con­sulta­tion remain open until the end of Janu­ary 2020 – can this be done?’ (СВР).
• Key factors for eco­nom­ic devel­op­ment (not men­tioned under spe­cif­ic top­ics) include:
  • Digit­al Infrastructure/​Connectivity (CBP, FSB).
  • Phys­ic­al Infra­struc­ture (includ­ing vis­it­or inform­a­tion centres) (CBP).
  • Improved Pub­lic Trans­port (CBP) (HIE noted the Moray Growth Deal over­laps with the Park and should improve pub­lic trans­port through the bus ser­vice ini­ti­at­ive) (HIE).
  • Excel­lent Trans­port Links (FSB).
• SLE #Route 2050 report pri­or­it­ies include access to cap­it­al and know­ledge to improve pro­ductiv­ity and resi­li­ence (SLE).
• Com­pet­it­ive Cap­it­al­ist Sys­tem: EAP includes no ana­lys­is of the impact on the Nation­al Park, such as impact on wages (NK/PW).
• Land Own­er­ship should be assessed due to its impacts on eco­nomy and employ­ment (NK/PW).
• Changes in stra­tegic con­text sec­tion should include Com­munity Empower­ment Act 2015 and enhanced role of com­munit­ies re ser­vice deliv­ery, asset own­er­ship and eco­nom­ic prosper­ity (TGDT).
• Brexit may cre­ate both oppor­tun­it­ies and chal­lenges re any changes in trad­ing envir­on­ment and the value of pound (SE).
• HIE’s Draft Stra­tegic Frame­work – Cairngorm and Wider Area will also provide fur­ther loc­al con­text and provide oppor­tun­ity for align­ment, col­lab­or­a­tion, lever­age but there will need to be care to avoid duplic­a­tion of effort and resource (SE).
• Pub­lic grants for private landown­ers (e.g. for farm­ing and forestry) needs to be reviewed (NK/PW).
• Some of the actions are quite high level and will need some more detailed plan­ning (by leads/​partners) around deliv­ery mile­stones includ­ing time frames. There may be scope for the Plan to align with or ref­er­ence the SG eco­nom­ic pri­or­it­ies around Inter­na­tion­al, Innov­a­tion and Inclus­ive growth. The dia­gram (p12) could bene­fit from demon­strat­ing how the themes relate to the key drivers/​economic factors and then link­ing to the stra­tegic oppor­tun­it­ies and how they con­nect to the eco­nom­ic strategy pri­or­it­ies in Annex A (SE).
• Actions around wages, cir­cu­lar eco­nomy and social enter­prise could be more power­fully included as cross-cut­ting actions rather than stand-alone i.e. how are these areas pro­moted in the way we devel­op sec­tors (Theme 1) or in the way cap­it­al invest­ment pri­or­it­ies are delivered (Theme 4)? (SE).
• Key respons­ib­il­it­ies for the co-ordin­a­tion/de­liv­ery of the Plan will need to be defined and bene­fit from inclu­sion of the private sec­tor (giv­en poten­tial lever­age oppor­tun­it­ies and to help secure ​‘buy in’ from busi­nesses) and com­munity rep­res­ent­a­tion (SE.)
• EAP does not men­tion Oppor­tun­ity North East (AC).
• There is a danger of turn­ing what was an act­ive and dynam­ic diverse grow­ing eco­nomy into a moribund museum dom­in­ated by tour­ism and the pub­lic sec­tor (ΑΕ).
• Cul­tur­al aims should be strengthened (Cul­ture should be in Pri­or­ity Theme I and be part of the oppor­tun­it­ies infograph­ic) and include ref­er­ence to Gael­ic cul­ture and lan­guage, Gael­ic Tour­ism Strategy for Scot­land and the CNPA Gael­ic Lan­guage Plan (BNG).
• The plan refers to an eco­nom­ic strategy but not clear what that eco­nom­ic strategy referred to is? (the Part­ner­ship Plan refers to the now expired strategy whilst Annex A with­in the con­sulta­tion doc­u­ment is not what we would describe as an eco­nom­ic strategy) (CBP).
• CBP raised ques­tions regard­ing resolv­ing any con­flicts between NP pri­or­it­ies — How these are to be resolved? What is the pro­cess with­in the CNPA for decid­ing if there is a per­ceived con­flict and what pro­por­tion of great­er weight is applied? Do the CNPA Board retain this power? If it is del­eg­ated to officers to whom and how is it del­eg­ated? What con­flicts have been iden­ti­fied in the draft­ing of this plan? CBP recom­mend that an eco­nom­ic strategy, along­side oth­er strategies, would help to both decide on per­ceived con­flict and the appro­pri­ate weight­ing to be applied (CBP).
• EAP needs action points on how oppor­tun­it­ies can be taken and threats over­come (FSB).
• New action on his­tor­ic archi­tec­ture needed to identi­fy land­lords and assist with applic­a­tions for fund­ing (GBA).
• EAP needs more emphas­is on A9 dualling oppor­tun­it­ies (HIE).
• EAP appears to con­sist mainly of a regur­git­a­tion of old mater­i­al (NK/PW).

Theme 4. Deliv­ery and Mon­it­or­ing of the Plan

Q3 Are these deliv­ery & mon­it­or­ing arrange­ments appro­pri­ate for the Eco­nom­ic Action Plan?

(Graph show­ing responses to Q3)

Two respond­ents repor­ted some reluct­ance to con­trib­ute to the con­sulta­tion, due to a per­cep­tion that the views of land-based busi­nesses are not being listened to and that CNPA strategies and plans do not reflect the con­cerns, needs or aspir­a­tions of those who live or work with­in the Park (SLE, AE).

Oth­er sug­ges­tions from sep­ar­ate respondents:

• Giv­en the com­plex­ity of the issues, it is essen­tial that the CNPA takes a lead­er­ship role in the devel­op­ment and deliv­ery of an Eco­nom­ic Strategy for the Nation­al Park. CNPA could also be more pro-act­ive re tar­get­ing the types of invest­ment that are most appro­pri­ate to achiev­ing the Nation­al park aims. Ques­tioned wheth­er the CNPA can include this with­in the EAP and work with the CBP and Enter­prise Agen­cies to estab­lish how to agree and tar­get spe­cif­ic inward invest­ment oppor­tun­it­ies? To sup­port this CBP sug­gest the cre­ation of an eco­nom­ic strategy group. (CBP).
• Sup­port for CNPA role as a facil­it­at­or that enables col­lab­or­a­tion between stake­hold­ers, par­tic­u­larly out­side of the estab­lished ​‘bubbles’. Sug­ges­ted stake­hold­ers include: loc­al people, Scot­tish Gov­ern­ment (SG), Scot­tish Envir­on­ment­al Pro­tec­tion Author­ity (SEPA), Scot­tish nat­ur­al her­it­age (SNH), Scot­tish Exec­ut­ive Rur­al Pay­ments and Inspec­tions Dir­ect­or­ate (SER­PID), His­tor­ic Envir­on­ment Scot­land (HES), Envir­on­ment Scot­land, Trans­port Scot­land re Trunk Roads, Homes for Scot­land, Loc­al Government(s) ( includ­ing hous­ing, edu­ca­tion, roads and plan­ning depart­ments), Vis­it Scot­land, util­it­ies, private sec­tor organ­isa­tions, Roy­al Soci­ety for the Pro­tec­tion of Birds (RSPB), Sco­trail) (RT).
• Recom­mend that the CNPA does more to lead on deliv­ery, for example by cre­at­ing and lead­ing task forces for key devel­op­ments to help remove any bar­ri­ers (one example would be An Camas Mòr) (CBP).
• Pro­mote an under­stand­ing with SG and oth­ers that the Cairngorms is a very spe­cial area that jus­ti­fies adjust­ments to nor­mal policy (RT).
• Plan­ning — CBP report a pos­it­ive engage­ment and respons­ive­ness from CNPA for pre applic­a­tion dis­cus­sions, how­ever they feel that for Plan­ning Applic­a­tions, the plan­ning pro­cess leads to lack of responses/​delays. They query wheth­er CNPA could sep­ar­ate eco­nom­ic devel­op­ment from plan­ning and estab­lish pro­ced­ures for ​‘Chinese walls’ with­in the Author­ity (right up to board level), so busi­nesses can con­tin­ue to receive sup­port and guid­ance but not jeop­ard­ise the import­ant plan­ning pro­cess? CBP also ques­tion wheth­er it is pos­sible for CNPA to con­sider a more risk based approach to plan­ning? (CBP).
• Also ques­tioned what resources, (out with the Authority’s stat­utory plan­ning func­tion of restrict­ing inap­pro­pri­ate devel­op­ment), will the Author­ity put towards deliv­ery of the EAP? (CBP) EAP includes no evid­ence of resources to deliv­er plan (GB).
• Sug­gest to the Min­is­ter to men­tion An Camas Mòr as a pri­or­ity in the Action Plan as in the cur­rent Eco­nom­ic Strategy (RT).
• Tomin­toul and Glen­liv­et Land­scape Part­ner­ship (TGLP) leg­acy needs CNPA sup­port to max­im­ise the bene­fits (TGDT).
• Scope for a great­er degree of integ­ra­tion between this plan and the oth­er sub­si­di­ary CNPA action plans (SNH).
• Not much point in ded­ic­at­ing much resource to mon­it­or­ing a plan which is already in many senses out of date due to glob­al warm­ing and Brexit (which if it goes ahead will ter­min­ate many of the fund­ing streams with no altern­at­ives being put in place.). Sub­stan­tial changes to the EAP likely to be needed over the next three years and CNPA need a dif­fer­ent way of doing this (SCNP).
• Con­sider HIE’s fail­ure to engage with stake­hold­ers, co-oper­ate with the ​“Glen­more” Strategy or provide a mas­ter­plan at Cairn Gorm as chal­len­ging the Park’s cred­ib­il­ity (SCNP).
• Requests from plan­ners regard­ing trees and paths (for example), were seen to be unreas­on­able, incon­sist­ent and to inhib­it eco­nom­ic diver­si­fic­a­tion (SLE).
• Col­lab­or­a­tion: quer­ied how the suc­cess of col­lect­ive work­ing monitored/​reported and wheth­er par­ti­cipants in part­ner­ship work­ing feel they are listened to and able to con­trib­ute? (RT). Cairngorm Moun­tain situ­ation indic­ates CNPA and HIE need to col­lab­or­ate more effect­ively (NK/PW).
• CNPA com­mu­nic­a­tions have a prob­lem in that the net effect of all Plans is not repor­ted (for example they need to provide a net bal­ance between tree plant­ing and peat res­tor­a­tion gains com­pared with losses from hill roads, felling, muir burn­ing and con­struc­tion (CC).
• Add BNG to Eco­nom­ic Steer­ing Group to act as cul­ture cham­pi­on (BNG).
• The Plan should identi­fy some ​‘quick wins’ to estab­lish sup­port and allow it to gain real trac­tion and impact (SE).

Indic­at­ors, Data, Monitoring

Sev­er­al respond­ents con­sidered there were gen­er­al issues with the pro­posed indic­at­ors, data and monitoring:

• Sug­ges­ted tar­gets and indic­at­ors set for rur­al devel­op­ment in the Nation­al Park Part­ner­ship Plan do not neatly reflect the range of EAP actions proposed.
• Pro­posed indic­at­ors insuf­fi­cient to determ­ine wheth­er the EAP has been suc­cess­ful or ques­tioned how suc­cess will be meas­ured against the 5 pri­or­ity themes.
• Should include quant­it­at­ive targets.
• More spe­cif­ic tar­gets and indic­at­ors need to be developed and they need to be ​‘meas­ur­able, meas­ured and acted upon’.
• Should not meas­ure suc­cess in vis­it­or num­bers or gov­ern­ment investment.
• Sus­tain­ab­il­ity of the eco­nomy should be giv­en a high­er pri­or­ity (HC, WT, CBP, SLE, AC, RSPB, AE).

Two respond­ents felt addi­tion­al clar­ity was needed on who is respons­ible for the actu­al deliv­ery or how the body respons­ible for deliv­ery is determ­ined (ACGT, GB).

Sug­ges­tions from sep­ar­ate respondents:

• Mon­it­or­ing should not be too oner­ous — A high-level RAG status could be applied to each of the high-level actions (assum­ing that each pro­ject developed against the actions will have its own mon­it­or­ing arrange­ments in place) (SE).
• Com­bin­ing demo­graph­ic, social, eco­nom­ic and infra­struc­ture trends togeth­er for the whole Park hides huge anom­alies between dif­fer­ent com­munit­ies with­in the Park (e.g. from tour­ism and its impact ) — mon­it­or­ing of sup­ply and demand should be split by com­munity (AE).
• Ques­tioned wheth­er the data is to be updated and improved as part of the data gath­er­ing exer­cise for the next stat­utory Park Plan (to include a meas­ure of eco­nom­ic value added) and wheth­er CBP and oth­ers will be con­sul­ted about what data is needed to help devel­op an effect­ive eco­nom­ic strategy? (CBP).
• Eco­nom­ic data on p8 is more than 4 years old and a ques­tion was raised wheth­er the data will be updated pri­or to the next park plan? CBP would like to be involved in decid­ing what data