Item 5 Appendix4a RepresentationsGeneral 20250109DET NMU Aviemore and Carrbridge
Cairngorms National Park Authority Ughdarras Pàirc Nàiseanta a’ Mhonaidh Ruaidh
Item 5 Appendix 4a 28 August 2026
Agenda item 5
Appendix 4a
2025/0109/DET
Representations — general
The British Horse Society Scotland
Patron His Majesty The King
The British Horse Society Scotland Suite A3 Stirling Agricultural Centre Stirling FK9 4RN
Email catriona.davies@bhs.org.uk Website www.bhs.org.uk Tel 02476 840749
Bringing horses and people together
14th May 2025
By email to: planning@cairngorms.co.uk; eplanning@highland.gov.uk
Dear Sir/Madam,
Re: 25/01207/FUL Formation of 3m wide 9km long segregated NMU route/path Land 130M SW Of Birch Cottage, Avielochan, Aviemore
The British Horse Society (The BHS) represents the interests of the 3.4 million people in the UK who ride or who drive horse-drawn vehicles and is the largest and most influential equestrian charity in the UK. The BHS is committed to promoting the interests of all equestrians and the wellbeing of horses and ponies through our work in education, welfare, safety and access.
Outdoor Access
Access to safe off-road riding routes is vital to the health and wellbeing of horses and their riders. Under the terms of the Land Reform (Scotland) Act 2003, equestrians have the same rights of access to the outdoors as other non-motorised users, such as pedestrians and cyclists. Equestrian use should therefore be included when planning and designing routes for non-motorised users. Considering equestrians in the early stages ensures that projects like this are an opportunity to preserve and improve access for all, rather than restrict it to certain groups.
Active Travel and Suitable Infrastructure
Active travel routes are often used by the public as recreational routes and are highly valued as such. The development of active travel routes should not prevent or discourage recreational users, including equestrians, from exercising their access rights. In addition, horses can be used for active travel, and there are riders and carriage drivers who do so, but equestrians are often not considered when planning active travel routes. By choosing surfaces and infrastructure that are appropriate for horses, it is possible to ensure that routes are suitable for all to use, whether their purpose is recreation or active travel.
The Importance of Off-Road Riding
Most riding accidents happen on minor roads. With increasing numbers of horses and riders seeking to access the countryside, adequate access to off-road riding should be a priority, especially in rural and semi-rural areas, like the Highlands.
I am therefore very pleased to note that this route will be for the use of all non-motorised users, including equestrians. It is important all signage on the route reflects this. For example, shared use NMU signs should include a symbol for a horse rider, as well as symbols for pedestrians and cyclists. This will indicate to all users that equestrian use is permitted. An ideal sign is illustrated below.
The British Horse Society is an Appointed Representative of South Essex Insurance Brokers Limited who are authorised and regulated by the Financial Conduct Authority. Registered Charity Nos. 210504 and SC038516. A company limited by guarantee. Registered in England & Wales No. 444742
[Image: A circular blue sign depicting symbols for a horse and rider, a pedestrian, and a cyclist, indicating a shared route.]
Shared route for horses, pedestrians and pedal cycles only Department for Transport Guidance, Know your traffic signs, Bus and cycle signs and road markings
The signalized crossing of the A95 at the proposed Granish Roundabout should be suitable for equestrian users. Equestrians can be included in a standard pedestrian/cyclist crossing by the addition of a user control for riders set back from the kerb. Waiting times should be as short as possible to avoid horses becoming restless whilst waiting. The BHS is here to help and can provide practical advice on minor adjustments to help make controlled crossing points safe and accessible to equestrian users. I have enclosed our “Advice on road crossings and including equestrians”.
The applicant notes that one section of the route the NMU is shared with vehicular traffic at the existing railway underpass and that fencing and gating arrangements will be developed to reduce the risk to NMU users. These arrangements should be fully accessible to equestrians. Structures that are not accessible to horses, such as kissing gates, should be avoided.
North of the existing underpass, there is a short section where the route runs along a narrow strip of land between the Highland Mainline Railway and the A95. There is a risk that a horse startled by a passing train could shy into traffic on the A95. Whilst we acknowledge that current “Design Standards do not require the provision of safety barriers to separate NMU routes from carriageway” (Design and Access Statement, section 5.5.4), at this location a barrier is needed to reduce the risk to road users on the A95 as well as horses and their riders. This barrier could be a standard metal vehicle barrier, or an earth embankment. Natural vegetation, such as a hedge or trees would also help divert a momentarily frightened horse away from the road.
The BHS is here to help and can provide guidance on suitable infrastructure to accommodate equestrians and other access takers. We would be very willing to work with the applicant on these aspects.
Construction Traffic Management Plan (CTMP)
Equestrian road users are classed as vulnerable in the Highway Code as they are more likely to be involved in a road accident and more likely to suffer the worst consequences. Few riders access busy roads by choice (although the horse has as much right to be on public roads as cars, bikes and pedestrians) – but they often have no other way to access their safe off-road riding. I note that “Prior to implementation, the successful Contractor will be required to submit detailed traffic management plans to the relevant Road Authority, for approval.” (Aviemore to Carrbridge Non-Motorised User (NMU) Route – Traffic Management Plan, section 1.4).
This document should include a clear plan of how all vulnerable road users, including equestrians, will be accommodated and their safety prioritised alongside construction traffic.
Again, The BHS is here to help and can provide advice on how the applicant can help keep equestrians safe on the road. We would be very willing to work with the applicant on this. I have enclosed a copy of our “Guidance to drivers of large vehicles” document.
The Horse and the Rural Economy
Scotland’s equestrian industry is worth over £300 million to the Scottish economy annually. This figure excludes the value of the horse racing industry, which is worth a further £300 million. Equestrianism is therefore an important part of the rural economy in rural areas like the Highlands. Recent joint research between SRUC and The BHS showed current trends in the sector point to a continued increase in horse numbers and riding activity in all geographical areas of Scotland and across a wide cross section of society, leading to growth in the sector.
A national survey of riders who had recently given up their horse found that 27% of them had done so because they had lost access and had nowhere to ride. Failing to accommodate horses on our local path networks may lead to riders being forced to give up their horses, which in turn may damage the local economy.
I trust that the above information is of assistance. If you have any questions or would like to discuss the needs of equestrians further, please do contact me.
Kind regards,
Catriona Davies Scotland Access Officer The British Horse Society
The British Horse Society Scotland
Guidance for Drivers of Large Vehicles
Horses are naturally nervous of large vehicles, especially if they do not often meet them. If they are very frightened, they can run away in panic. Whilst their rider or carriage driver will do all they can to prevent this, should it happen, it could cause a serious accident for the horse and rider or carriage driver and for other road users.
The main factors which cause fear in horses are:
- Being approached by a large, moving object, which may be unfamiliar or intimidating to them,
- Lack of space between themselves and the vehicle,
- The noise of the vehicle, especially air brakes,
- Picking up on the anxiety of their rider or carriage driver.
Horses have keen eyesight and due to the position of their eyes on the sides of their head, can detect vehicles approaching from behind as well as ahead. They also have very sensitive hearing and will detect an approaching vehicle, and begin to react, before their rider or carriage driver.
How can you help?
When you meet a horse on the road:
- Slow down to 10mph or less and be prepared to stop if necessary.
- Be aware that the sound of your air brakes may spook a horse.
- If a horse shows signs of nervousness as you approach, stop, turn off your engine and allow them to move away. Don’t move off again until they are well clear of your vehicle.
- Pass wide and slow, when it is safe to do so – allow at least 2m between your vehicle and the horse, and drive away slowly.
- If you are approaching a horse on a narrow road and wish to pass or overtake, slow down and give the rider or carriage driver time to find a gateway, layby or other refuge to create sufficient space between the horse and your vehicle.
- Please be patient. Most riders and carriage drivers will do their best to make way as quickly and safely as they can.
- The safest place for a rider or carriage driver’s hands is on the reins, so they may only be able to nod their thanks to you, but please be assured, they will be very grateful for your consideration.
Thank you for helping to keep horses, and the people who care for them, safe.
The British Horse Society
Advice on Road crossings and including equestrians
The law and management of public access rights vary widely between the four countries of the United Kingdom. Practical elements of the following advice apply in all of them but the legal requirements in Scotland and Northern Ireland may differ from those in England and Wales.
More advice is available on www.bhs.org.uk/accessadvice.
IMPORTANT This guidance is general and does not aim to cover every variation in circumstances. Where it is being relied upon, The Society strongly recommends seeking its advice specific to the site.
Contents
- Light-controlled crossings
- Waiting time
- Design and construction
- Examples of non-standard light-controlled crossings
- Warning signs
- Joining a road
- Sightlines
- Corrals or staggered barriers
- Obstructions and barriers
- Trunk roads and dual carriageways
Routes used by equestrians include bridleways, byways, unsurfaced unclassified roads, quiet lanes, permissive paths, commons and some public open space. These very rarely form a coherent network, so riders and carriage-drivers have no choice but to use busy roads, predominantly used by motor traffic, to reach them. The following advice is referring to busy or main roads, which equestrians will avoid travelling along if at all possible, unless there is provision for them within the verge or otherwise off the main carriageway, but will need to cross them, otherwise the road is a complete barrier to a journey.
An underpass or bridge are the ideal for crossing a busy road but too frequently are impractical and an at-grade crossing is the only option, in which case, it may need to be signal-controlled so users have the chance to cross.
May-25
At-grade road crossings
Light-controlled crossings
Light-controlled crossings are the best means of improving safety for crossing roads at-grade. Where new roads are planned, the British Horse Society recommends construction of underpasses where feasible as first choice.
Light-controlled crossings are user-operated by a press-button control, sensor or Bluetooth app which changes ‘traffic lights’ to stop road traffic while users cross.
The standard design for a multi-user¹ light-controlled crossing in the government’s guidance segregates equestrians from cyclists and pedestrians by having two parallel crossings (sometimes called a ‘Pegasus’ crossing, like a pedestrian ‘Pelican’ crossing). This frequently means that a crossing which includes riders is refused because of insufficient space and doubled cost, resulting in a frightening number of crossings used with horses where pedestrians and cyclists have a protected crossing, but equestrians are forced to risk the uncontrolled traffic to cross or are prevented from crossing. This is highly discriminatory and a situation which can be changed at relatively low cost.
Conflict between different users while waiting or crossing is the reason given for a dual crossing, however, evidence to justify it has not been seen by the BHS and few sites are likely to have a level of traffic where segregation is justified. For instance, riders would avoid peak periods,
For the majority of sites, riders can be included in a standard pedestrian-cyclist crossing by a simple addition of a user-control for riders set back from the kerb within easy reach of a rider’s hand (1.7 – 2m). This provision enables equestrians to cross a road in safety. Conflict with other crossing users is unlikely and avoidable, as on all bridleways and byways, by adopting the basic highway principle of consideration and ‘giving way’ to other users as appropriate. The risk of conflict is far less than the risk to riders from having to cross without control of the motor traffic.
The Society suggests options dependent on the site and number of non-motorised users using the crossing at any one time. A heavily used site may require a DfT-standard dual crossing, but for most sites, all users can be adequately served by a pedestrian crossing plus a control at rider’s hand height (1.7 – 2m) set back from the road either:
Where a bridleway or byway meets the road crossing, the user-control for riders is sited along the bridleway/byway 5 – 6 metres back from the kerb, or
With additional user-control on a pole at the opposite side of a ‘footway’ from the kerb so a ridden horse is as far as possible from the traffic while a rider operates the control
¹ Pedestrian (including with mobility aid), horse-rider, cyclist
May-25
At-grade road crossings
In 2, the additional pole can also benefit any user, in being a little further from motor noise and pollution, and feeling safer. There is particular advantage for those with a pushchair, wheelchair, mobility scooter, recumbent cycle, tandem or cargo bike, who are not well-served by the standard kerbside pole placement. A lower control for them can be installed below that at rider’s height, thereby providing for all users in safety.
Lights can be operated by sensor or by Bluetooth devices to accommodate users (developed for users with disabilities but extendable to all) without them needing to manually operate a control. A small device is fitted to the control box (retrospective or new installation) and linked to a sensor or a phone app (which is advertised to users) to activate the call. This option avoids the need for an additional pole and the standard kerb location of a single pole may work for all users. In 2022, the cost of the device was around £1,000; an additional pole and control box set back from the kerb was £10,000.
Standard pedestrian crossings require tactile paving. Tactile paving rarely presents a problem to horses in a small area (as found at a crossing) so is not a constraint on including horse-riders.
Waiting time
The waiting period between pressing the button and lights changing to stop the traffic is of primary importance for riders as it should be as short as possible to avoid horses becoming restless while waiting. This is the primary reason for setting call controls well back from the kerb, so that traffic halts as a rider reaches the crossing.
On a dual carriageway where it is inappropriate to halt both carriageways simultaneously, the Society strongly recommends that controller configuration conditioning uses ‘call forwarding’ to halt the traffic on the far carriageway as the rider reaches the central reservation, so horses are not waiting in the centre and a rider is not needing to manually operate another control, and that the near carriageway traffic is not released until horses have left the central reservation. The aim should always be to avoid:
- waiting in central reservations, where horse and rider are at greatest risk because of the unpleasant environment;
- taking a hand from the horse to press a button, which is a precise action taking attention of the rider from horse and environment when it is least desirable to do so;
- moving traffic both in front and behind the horse.
Design and construction
Recommendations for crossing construction and dimensions were produced by the Department of Transport in Traffic Advice Leaflet 03/03 Equestrian Crossings. This advice
May-25
At-grade road crossings
has been archived and not replaced but still appears widely assumed. The Society considers the specification to be over-complex for most sites and not to be relied upon.
It is replaced by The Design Manual for Roads and Bridges Volume 6 Section 5 CD 143 ‘Designing for walking, cycling and horse-riding’ which includes road crossings which segregate riders, but the Society is working with the manual’s revision team to adjust that specification as it has been accepted as overly prescriptive in many circumstances.
The DMRB is a guide for major roads, it does not need to be and should not be applied to every road. Highway authorities may act at their discretion on non-trunk roads. If certainty is required, a non-standard crossing may be installed by seeking consent for variation from the Department for Transport, but consent may not be necessary except on a trunk road.
The BHS emphasises the following points:
- Rider-operated controls on a crossing should minimise waiting time as far as possible and may need to be set back from the kerb to reduce the wait.
- The required time at red for a crossing will depend on the width of the road being crossed. Walking speed of a horse is between 2 and 4mph, similar to a human, plus the horse’s response-to-aids time as well as the human’s response-to-signal, so maybe two seconds to add. A rider is likely to be waiting further from the kerb than a pedestrian, so the extra two or three metres must be included in the length of ground to cover.
- Waiting pens/corrals are not always necessary and should be considered by site, dependent on speed of road traffic and incidence of multiple users waiting to cross.
- Fencing around waiting areas at a crossing in rural areas is likely to only be necessary if there is a drop or some other hazard beyond it.
- Waiting in the middle of a dual carriageway should be avoided. The centre of the dual carriageway is a very hostile environment which most horses and riders will find disturbing and where it may be too challenging to reach for a user-control or wait for lights to change. Traffic should be halted on both carriageways to allow a rider to complete the crossing without pausing, whether both carriageways at once or by ‘call forwarding’ so the far carriageway comes to halt before the rider reaches it. It is also recommended that traffic on the first carriageway is not released until after the rider has left the central reservation.
- TAL 03/03 (archived guidance) stated under Shared Use that, “it is usually desirable to provide a cyclist and/or pedestrian as well as an equestrian crossing facility”. This is excessive in most circumstances particularly as it almost doubles the costs of equestrian crossings, making them prohibitively expensive to install so leaving equestrians at risk or obstructed by motor traffic.
May-25
At-grade road crossings
- The Society has seen no evidence of problems arising while mixed groups wait at crossings. Such circumstances are rare as peak use for pedestrians and cyclists is unlikely to coincide with use by riders.
Examples of non-standard light-controlled crossings
As stated under Light-controlled crossings, a ‘standard’ light-controlled crossing inclusive of horse riders comprises two adjacent crossings, one pedestrian-cyclist, one horse-rider. The BHS makes the case above that this is unnecessary at most sites and a single crossing for all users is adequate. The following are examples where a combined single crossing is installed.
- A1307 Babraham, Cambridgeshire – pedestrian-cyclist crossing with additional control at rider height, set back from the road and partial aggregate-rubbercrumb surface 52.140149, 0.202662, streetview
- Govier Way, Severn Beach, Bristol – foot-cycle crossings modified with addition of set back higher control for riders at 1 streetview and 2 streetview.
- Hall Road, Wouldham, Kent – non-segregated light controlled crossing with additional rider height control boxes 51.344800, 0.45677246 streetview
- A26 Isle of Man, Glen Darragh Road, Glen Vine – pedestrian-cyclist crossing with additional control at rider height, set back from the road 54.174440, ‑4.557071
The following have dual crossings but do not meet the DMRB standard because of lack of space.
- A322 Guildford Road, Bisley, Surrey 51.3206488,-0.6303049 streetview
- A405 Bricket Wood, Herts 51.7073674,-0.3808824 streetview
Warning signs
Warning signs to motorists of horses on the road (DfT P550.1) on the approach to a crossing should be considered. These are particularly useful where sightlines are poor for the crossing, or a light-controlled crossing is not appropriate because of resistance to reducing the speed limit to the required level for a light-controlled crossing.
User-responsive lit or flashing warning signs which are activated by the presence of equestrians can be highly advantageous in alerting motorists and avoid ‘sign fatigue’. Such signs are activated by equestrians on approaching the road by a sensor, Bluetooth signal from an app or touch. Rather than the ‘button’ call of light-controlled crossings, which requires very precise operation, probably at standstill, a much broader mechanism is preferrable for riders, for example a ‘wand’ on top of the control box which can be touched at while moving at arm’s length or by a whip. The control and signs must be set
May-25
At-grade road crossings
back far enough that the signs are activated to alert motorists so they have time to slow before reaching the crossing or section of road where equestrians are present. This must, of course, also coincide with the equestrian reaching it.
Joining a road
Bridleways or byways ending at a main road should not have a gate within several metres of the road edge, partly to ensure there is space well off the road for equestrians to wait, and partly so that equestrians are not negotiating a gate while at risk from motor traffic close by.
A gate is a hazardous manœuvre for a rider, even when the gate is well-maintained and sited, and sadly, many roadside gates are far from well-maintained or positioned with flat level ground, no overhead hazards and plenty of manoeuvring space. Forcing a rider to dismount is not the solution as a rider has less control on the ground and is at increased risk during mounting or dismounting, even if mounting blocks are provided.
A driver of a horsedrawn vehicle requires one person to be on foot to open the gate with space for horse and vehicle to wait so a byway meeting a road will need 6 metres between the road edge and any gate.
Sightlines
It is sometimes possible to improve the crossing point through clearing vegetation to increase sightlines and provide sufficient space for horses to wait away from the kerb or surfaced carriageway edge. A rider’s sightline is greater than a pedestrian in the same position because of their additional height. This fact is often not taken into account and adequacy of sightline is based on pedestrian height. Standard sightline recommendations for a rider are generally higher than for a pedestrian as taking account of the additional response time for horse-to-rider, not just rider-to-traffic but this may be mitigated by height, the recommendations do not appear to be evidence-