Formal Board Paper 1 - Evidence Report

For Decision

Title:

Loc­al Devel­op­ment Plan 3 – Evid­ence Report 2025

Pre­pared by: Dan Har­ris, Plan­ning Manager

Pur­pose

This paper seeks approv­al of the Evid­ence Report, as set out in Annex 1, for sub­mis­sion to Scot­tish Min­is­ters for its Gat­echeck review by the Divi­sion for Plan­ning and Envir­on­ment­al Appeals (DPEA).

Recom­mend­a­tions

The Board is asked to: a) Approve the Evid­ence Report for sub­mis­sion to Scot­tish Min­is­ters for its Gat­echeck review via the Scot­tish Gov­ern­ment (SG) DPEA. b) Del­eg­ate author­ity to the Head of Plan­ning and Chief Plan­ning Officer to respond to any request for fur­ther inform­a­tion or amend­ment as a res­ult of the Gat­echeck process.

Stra­tegic context

1. The Plan­ning (Scot­land) Act 2019 has brought numer­ous reforms to Scotland’s devel­op­ment plan sys­tem. It has con­firmed that the Nation­al Plan­ning Frame­work is a part of the stat­utory Devel­op­ment Plan and sets out a new way of pre­par­ing loc­al devel­op­ment plans. Major changes to devel­op­ment plan­ning include: a) The require­ment to pre­pare an Evid­ence Report to inform the new Loc­al Devel­op­ment Plan (LDP). b) The intro­duc­tion of a Gat­echeck review pro­cess to eval­u­ate ​‘suf­fi­ciency’ of the inform­a­tion in the Evid­ence Report. c) Main issues reports no longer form part of the plan mak­ing process.

The Evid­ence Report

1. The Evid­ence Report has been pre­pared in accord­ance with the Town and Coun­try Plan­ning (Scot­land) Act 1997, as amended, and the Town and Coun­try Plan­ning (Devel­op­ment Plan­ning) (Scot­land) Reg­u­la­tions 2023.
2. The pur­pose of the Evid­ence Report is to inform the pre­par­a­tion of the Pro­posed Plan. The Evid­ence Report reflects the ini­tial stage of inform­a­tion and evid­ence gath­er­ing, shaped by early con­sulta­tion and stake­hold­er engage­ment. The Evid­ence Report does not include site spe­cif­ic pro­pos­als or set out detailed plan­ning policies and asso­ci­ated require­ments. These will be developed dur­ing the sub­sequent Pro­posed Plan stage. Instead, the report out­lines key con­sid­er­a­tions and actions to be addressed in the pre­par­a­tion of the Pro­posed Plan. In accord­ance with rel­ev­ant guid­ance, the Evid­ence Report does not con­tain all the detail of evid­ence but focuses on a sum­mary of the evid­ence and what it means for the Pro­posed Plan.
3. Evid­ence is presen­ted on a top­ic basis, with the Evid­ence Report com­pris­ing a series of top­ic-based sched­ules broadly arranged accord­ing to the policy themes set out in Nation­al Plan­ning Frame­work 4 (NPF4) – sus­tain­able places, live­able places, and pro­duct­ive places. Where pos­sible, the Park Author­ity has sought to gath­er inform­a­tion and evid­ence in a place-based man­ner. Each sched­ule with­in the Evid­ence Report con­tains a sum­mary of: a) The legis­lat­ive require­ments addressed with­in it. b) The policy require­ments and con­sid­er­a­tions addressed with­in it. c) A sum­mary of the baseline evid­ence to inform the Pro­posed Plan. d) Any iden­ti­fied evid­ence gaps. e) The implic­a­tions for the Pro­posed Plan. f) The engage­ment under­taken to inform it. g) Any state­ments of agree­ment and out­stand­ing dis­pute arising from the engagement.

Sum­mary of key implic­a­tions for Pro­posed Plan

1. This sec­tion provides a sum­mary of the main implic­a­tions for the Pro­posed Plan based on the inform­a­tion in the Evid­ence Report. Please note that this is not an exhaust­ive list of all con­sid­er­a­tions and implic­a­tions – the implic­a­tions are set out in full with­in each of the sched­ules in the Evid­ence Report.

Over­arch­ing topics

1. The Pro­posed Plan needs to be pre­pared in accord­ance with: a) The four aims of the Nation­al Park as set out in the Nation­al Parks (Scot­land) Act 2000), as to be amended by the Nat­ur­al Envir­on­ment (Scot­land) Bill. b) Sec­tion 9(6) of the 2000 Act, which states that while the aims are to be pur­sued col­lect­ively, if there is con­flict between the first aim and any of the oth­ers, great­er weight is giv­en to the first aim. c) The spa­tial strategy and prin­ciples of NPF4.
2. In accord­ance with Sec­tion 14 of the Nation­al Parks (Scot­land) Act 2000, as to be amended by the Nat­ur­al Envir­on­ment (Scot­land) Bill, pub­lic bod­ies have a duty to facil­it­ate the imple­ment­a­tion of the Nation­al Park Part­ner­ship Plan (NPPP). There­fore, the Pro­posed Plan should: a) Align with the NPPP and adopt its vis­ion and three over­arch­ing out­comes for nature, people, and place. b) Align with the NPPP’s spa­tial strategy, which sup­ports an infra­struc­ture first approach.
3. The Pro­posed Plan should take account of the pri­or­it­ies and actions of any: a) Pub­lished com­munity action plans – there are cur­rently eight­een com­munity action plans with­in the Nation­al Park. b) Registered loc­al place plans – there are cur­rently no registered loc­al place plans in the Nation­al Park.

Sus­tain­able places

1. The Pro­posed Plan should: a) Safe­guard the hab­it­ats and spe­cies pro­tec­ted by inter­na­tion­al and nation­al des­ig­na­tions from the poten­tially adverse effects of devel­op­ment, includ­ing through the site assess­ment, Hab­it­ats Reg­u­la­tions Apprais­al and Stra­tegic Envir­on­ment Assess­ment pro­cess. b) Make the most effi­cient use of devel­op­ment land to ensure that devel­op­ment meets the needs of the present without com­prom­ising the abil­ity of future gen­er­a­tions to meet their own needs. Not only is this to ensure that pro­tec­ted sites are safe­guarded, but it also aims to ensure that devel­op­ment land is avail­able in the future to meet long term needs. c) Con­trib­ute to estab­lish­ing and sup­port­ing the deliv­ery of nature net­works. d) Pro­tect and enhance the Spe­cial Land­scape Qual­it­ies of the Nation­al Park.

Live­able places

1. Hous­ing need with­in the Nation­al Park has been determ­ined from a range of sources, includ­ing the hous­ing need and demand assess­ments of the five loc­al author­it­ies cov­er­ing the Nation­al Park. On the basis of this evid­ence, the Pro­posed Plan should identi­fy suf­fi­cient deliv­er­able land to meet an indic­at­ive ten-year loc­al hous­ing land require­ment of around 889 new homes, in accord­ance with the spa­tial strategy set out in the Part­ner­ship Plan. This fig­ure: a) Com­plies with the require­ment to exceed NPF4’s min­im­um all ten­ure hous­ing land require­ment of 850 new homes. b) Has been bench­marked against past deliv­ery rates and is con­sidered to be real­ist­ic and achiev­able. c) Has been bench­marked against the exist­ing effect­ive hous­ing land sup­ply, as set out with­in the hous­ing land audits of the loc­al author­it­ies cov­er­ing the Nation­al Park. This demon­strates that there is capa­city to deliv­er 797 new homes between April 2024 and March 2039 on sites alloc­ated for devel­op­ment in the cur­rent LDP and / or with exist­ing plan­ning per­mis­sion. A pro­por­tion of this exist­ing land sup­ply will be car­ried for­ward into the Pro­posed Plan, with the exact amount depend­ent on the out­come of the site assess­ment pro­cess. d) Has been con­sidered in rela­tion to the capa­city and con­di­tion of infra­struc­ture with­in the Nation­al Park and is con­sidered to be deliv­er­able in line with infra­struc­ture first principles.
2. The Pro­posed Plan should also: a) Ensure that both cur­rent and future needs can be met by mak­ing an effi­cient use of land to max­im­ise the amount of afford­able hous­ing delivered on alloc­ated sites. b) Facil­it­ate the imple­ment­a­tion of the over­all Part­ner­ship Plan tar­get that 75% of new hous­ing is for social rent­al, mid-mar­ket rent­al or oth­er afford­able categories.
3. There are no sig­ni­fic­ant con­straints to the edu­ca­tion, health­care, water or digit­al infra­struc­ture serving the res­id­ents of the Nation­al Park which would oth­er­wise pre­ju­dice the deliv­ery of spa­tial strategy, indic­at­ive hous­ing land require­ment or the infra­struc­ture first approach. How­ever, to ensure that the Pro­posed Plan is pre­pared in accord­ance with infra­struc­ture first prin­ciples, the Park Author­ity will con­tin­ue to work in part­ner­ship with the loc­al author­it­ies, NHS boards, and oth­er rel­ev­ant infra­struc­ture pro­viders to determ­ine the level of developer con­tri­bu­tions, if any, to be levied for this infra­struc­ture and the trig­gers for determ­in­ing when developer con­tri­bu­tions are needed.

Live­able places

1. The Pro­posed Plan should: a) Identi­fy and alloc­ate land for eco­nom­ic devel­op­ment, giv­ing con­sid­er­a­tion to the loc­a­tion of any new eco­nom­ic alloc­a­tions in rela­tion to com­munit­ies, access to ser­vices and all forms of travel and trans­port ser­vices. b) Safe­guard the loc­a­tions of import­ant com­munity assets, reflect the com­munity wealth build­ing pri­or­it­ies for the Plan area set out by the loc­al author­it­ies’ com­munity wealth build­ing strategies and plans, and take account of areas of eco­nom­ic dis­ad­vant­age and inequal­ity. c) Con­duct a review of town centre bound­ar­ies to bet­ter reflect the NPF4 defin­i­tion of a town centre use. d) Sup­port the viab­il­ity of exist­ing tour­ist infra­struc­ture and identi­fy land for new sus­tain­able tour­ism devel­op­ment that sup­ports the vis­it­or eco­nomy while also pro­tect­ing loc­al com­munit­ies from poten­tially adverse effects. e) Sup­port sus­tain­able tour­ism devel­op­ment that also man­ages tour­ism pres­sures on the nat­ur­al envir­on­ment and pro­motes respons­ible access where relevant.

Engage­ment

1. The Park Author­ity has under­taken a wide range of online and dir­ect engage­ment through­out the pre­par­a­tion of the Evid­ence Report. A sum­mary of this is provided on pages 50 – 71 of Annex 1.0.

Gat­echeck

1. The pur­pose of the Gat­echeck is to provide an inde­pend­ent assess­ment of wheth­er the plan­ning author­ity has suf­fi­cient evid­ence to pre­pare a LDP. It will be car­ried out by a report­er from the DPEA. The tar­get date for com­plet­ing the Gat­echeck review is three months from the DPEA’s receipt of the Evid­ence Report.
2. The report­er may decide there is suf­fi­cient inform­a­tion, and, on being so noti­fied, the Park Author­ity may then move to pre­pare and pub­lish the Pro­posed Plan. Altern­at­ively, the report­er may con­sider there is not suf­fi­cient inform­a­tion and provide recom­mend­a­tions for improv­ing the Evid­ence Report. If the report­er determ­ines that the inform­a­tion is not suf­fi­cient, then the Park Author­ity will need to amend the Evid­ence Report and resub­mit it to the DPEA for anoth­er Gat­echeck review.

Stra­tegic policy consideration

1. The Park Author­ity has a stat­utory duty to pre­pare a LDP, which should be adop­ted by May 2028. The Evid­ence Report is the first major step in this process.

Stra­tegic risk management

1. While no risk is posed by the sub­mis­sion of the Evid­ence Report for its Gat­echeck review itself, there are risks to the LDP’s timetable for pre­par­a­tion if the Evid­ence Report is found to be insufficient.
2. In par­tic­u­lar, there remain uncer­tain­ties around the volume and nature of inform­a­tion required for the Evid­ence Report to be con­sidered suf­fi­cient by the DPEA dur­ing the Gat­echeck review. At the time of writ­ing this paper, DPEA had issued nine­teen form­al Gat­echeck decisions on the evid­ence reports sub­mit­ted by oth­er plan­ning author­it­ies. Of these, nine (43%) evid­ence reports were found to be suf­fi­cient and 12 (57%) were found to be insuf­fi­cient and returned to the rel­ev­ant plan­ning author­it­ies for fur­ther work.
3. Where an evid­ence report is returned, the plan­ning author­ity is required to carry out a range of tasks to bring it to suf­fi­ciency. This may include the need to redraft sec­tions of the report, gath­er addi­tion­al evid­ence, com­mis­sion addi­tion­al stud­ies and carry out fur­ther engage­ment, as well as the stat­utory demo­crat­ic pro­cesses. The revised ver­sion of the Evid­ence Report must then be resub­mit­ted to the DPEA for a fur­ther Gat­echeck. While the delay caused in the pre­par­a­tion of the LDP in such cases will depend on the spe­cif­ic cir­cum­stances, the delay caused in all cases is likely to be sev­er­al months.
4. Park Author­ity Officers have sought to reduce the risk of the Evid­ence Report being found insuf­fi­cient as far as pos­sible. Emer­ging guid­ance and best prac­tice have been taken into account, as have the out­comes of oth­er Gat­echeck reviews. Officers have also met with a report­er from the DPEA to dis­cuss the con­tent of key sched­ules cov­er­ing the top­ics of hous­ing and infra­struc­ture. This pro­cess is reflec­ted in the con­tent and struc­ture of the Evid­ence Report.
5. Any sig­ni­fic­ant delay to the Park Authority’s timetable for pro­du­cing its next LDP is likely to present a risk to the abil­ity to meet Scot­tish Min­is­ters’ expect­a­tions of hav­ing a new plan in place by May 2028. An intern­al pro­gramme board has been estab­lished to co-ordin­ate the devel­op­ment of the NPPP and the LDP. This will mon­it­or and man­age the above risks inso­far as it is pos­sible. The Board will be kept up to date on the pro­gress of the LDP’s pre­par­a­tion and the Devel­op­ment Plan Scheme will con­tin­ue to be updated annually.

Suc­cess measures

1. The approv­al of the Evid­ence Report for sub­mis­sion to Scot­tish Ministers.

Next steps

1. Once the Board has approved the sub­mis­sion of the Evid­ence Report for its Gat­echeck Review: a) Final checks will be under­taken to ensure all format­ting, doc­u­ment ref­er­en­cing and fig­ure / table / page ref­er­en­cing meets DPEA require­ments. b) The Evid­ence Report and its sup­port­ing mater­i­al will be sub­mit­ted to Scot­tish Min­is­ters via the DPEA. c) The Evid­ence Report will be pub­lished on the Park Authority’s website.

Sup­port­ing information

1. Annex 1 – Cairngorms Nation­al Park Loc­al Devel­op­ment Plan: Evid­ence Report (March 2026)

Due to file size, the Evid­ence Report in Annex 1 is presen­ted as a series of sep­ar­ate sched­ules / chapters, as follows:

• Annex 1.0 – Evid­ence Report — Introduction
• Annex 1.1 – Sched­ule 1: Plan outcomes
• Annex 1.2 – Sched­ule 2: Policy monitoring
• Annex 1.3 – Sched­ule 3: Site assess­ment methodology
• Annex 1.4 – Sched­ule 4: Cli­mate change
• Annex 1.5 – Sched­ule 5: Nat­ur­al heritage
• Annex 1.6 – Sched­ule 6: Landscape
• Annex 1.7 – Sched­ule 7: His­tor­ic and cul­tur­al heritage
• Annex 1.8 – Sched­ule 8: Land use, soil and resources
• Annex 1.9 – Sched­ule 9: Energy
• Annex 1.10 – Sched­ule 10: Zero waste
• Annex 1.11 – Sched­ule 11: Sus­tain­able transport
• Annex 1.12 – Sched­ule 12: Liv­ing loc­ally and 20 minute neighbourhoods
• Annex 1.13 – Sched­ule 13: Housing
• Annex 1.14 – Sched­ule 14: Education
• Annex 1.15 – Sched­ule 15: Heat­ing and cooling
• Annex 1.16 – Sched­ule 16: Blue and green infrastructure
• Annex 1.17 – Sched­ule 17: Play, recre­ation and sport
• Annex 1.18 – Sched­ule 18: Health and safety
• Annex 1.19 – Sched­ule 19: Flood risk and water management
• Annex 1.20 – Sched­ule 20: Digit­al infrastructure
• Annex 1.21 – Sched­ule 21: Eco­nom­ic development
• Annex 1.22 – Sched­ule 22: Town centres and retail
• Annex 1.23 – Sched­ule 23: Tourism

Dan Har­ris 26 Feb­ru­ary 2026 danharris@​cairngorms.​co.​uk