Item5Appendix4BObjections

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 5 Appendix 4B 27/05/2022

AGENDA ITEM 5

APPENDIX 4B

2022/0046/DET

PUB­LIC REP­RES­ENT­A­TIONS- OBJECTIONS

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Deirdre Straw

From: BSCG info info@​bscg.​org.​uk Sent: 21 March 2022 23:51 To: Plan­ning; Stephanie Wade Sub­ject: 2022/0046/DET

Badenoch & Strath­spey Con­ser­va­tion Group

Fiod­hag, Nethy­bridge, Inverness-shire PH25 3DJ

Scot­tish Char­ity No. SC003846 Email info@​bscg.​org.​uk Web­site bscg​.org​.uk/

Stephanie Wade CNPA

21 March 2022

Dear Stephanie Wade 2022/0046/DET | Form­a­tion of moun­tain bike track and related infra­struc­ture | Ranger Base Office Cairngorm Moun­tain Glen­more Aviemore PH22 1RB

The Badenoch & Strath­spey Con­ser­va­tion Group wishes to object to the above pro­pos­al and we request the oppor­tun­ity to address the plan­ning com­mit­tee when the applic­a­tion is determined.

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We are con­cerned about the eco­lo­gic­al and land­scape impacts of the tracks and asso­ci­ated works.

Bats (All spe­cies are European Pro­tec­ted Spe­cies): Tree growth can be pre­dicted to extend up the hill, to high­er alti­tudes, due to the increas­ing effects of cli­mate change. This is likely to increase the con­nectiv­ity with exist­ing trees and forest at lower alti­tudes, and poten­tially improve the con­di­tions for bats. As the Enviro­Centre Report says (3.2.2), the com­mut­ing, roost­ing and for­aging oppor­tun­it­ies for bats would be likely to improve with more tree cov­er. We con­sider that the site should be care­fully man­aged in the imme­di­ate term, so as to max­im­ise the poten­tial future bene­fits for bats over the longer term.

Road traffic is a known cause of mor­tal­ity for bats in Scot­land. Bats are rel­at­ively long lived, take sev­er­al years to reach repro­duct­ive matur­ity, and only pro­duce one off­spring a year. This repro­duct­ive strategy makes bats par­tic­u­larly sus­cept­ible to impacts that com­prom­ise their num­bers or abil­ity to reproduce.

The assess­ment doesn’t take account of bat mor­tal­ity due to road traffic acci­dents (off the pro­pos­al site), and gives no ref­er­ence to the nearest known bat roosts.

Note­worthy bat roosts have been recor­ded in build­ings near the main Glen­more road and Loch Mor­lich. The Glen­more road provides a lin­ear fea­ture of a type known to be used by bats.

Bats use the Glen­more road, espe­cially in the vicin­ity of Loch Mor­lich, and dead bats asso­ci­ated with the road have been found, highly likely to have been RTAs. The pro­pos­al would increase traffic on this road and be likely to con­trib­ute to elev­at­ing bat mor­tal­ity due to RTAs.

A weak­ness in the Assess­ment of Risks to European Sites is the ongo­ing devel­op­ment of new types of bikes, includ­ing e‑bikes, that are suited to more chal­len­ging ter­rain, mak­ing the assess­ment of risk unre­li­able. Pat­terns of recre­ation have changed sub­stan­tially over recent years, and this trend looks set to continue.

Water Voles are known from the area and the Eco­lo­gic­al Con­straints report found suit­able water vole hab­it­at. How­ever, the report doesn’t provide an indic­a­tion of pos­sible impacts or sug­ges­tions of mit­ig­a­tion meas­ures. Sim­il­arly, ring ouzel are known from the site but there is no indic­a­tion of impacts or mit­ig­a­tion measures.

Land­scape impacts dur­ing con­struc­tion and oper­a­tion, and pos­sible mit­ig­a­tion meas­ures, are insuf­fi­ciently addressed.

It is unclear how com­bin­ing the user groups of walk­ers and bikers on the same path will not be to the det­ri­ment of both groups’ enjoy­ment, espe­cially where the path is not par­tic­u­larly wide. For example, the ascent trail appar­ently uses the exist­ing foot­path for a stretch.

The inclu­sion of an ​‘Advanced Des­cent Trail’ seems at odds with the pro­vi­sion of beginner/​intermediate trails, and it is not clear how this is inten­ded to coordin­ate with the rest of the trails; 2

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In terms of trans­port the pro­pos­al does not cre­ate a low car­bon facil­ity. It fails to sup­port gov­ern­ment net zero tar­gets and does not sup­port a sig­ni­fic­ant switch in use from private cars to pub­lic transport.

For fam­il­ies to take their own car, with or without their own bikes, is by far the most likely choice in order to access the MTB facil­ity. It is unreal­ist­ic to expect fam­il­ies to walk or cycle to the Cas car park in any sig­ni­fic­ant num­bers. And the bus will only attract lim­ited use, and will have lim­it­a­tions on num­bers of bikes it can transport.

The pro­pos­al requires all traffic to go through the Glen­more cor­ridor, which con­tra­dicts the CNPA’s stated inten­tion to reduce car use in the Glen­more corridor.

There has long been recog­ni­tion of prob­lems with car num­bers and over­heat­ing in terms of traffic impacts in the Glen­more corridor.

The pro­pos­al would exacer­bate this with increased car num­bers driv­ing through Glen­more, as well as adding to prob­lem­at­ic con­cen­tra­tion of vis­it­or pres­sure on this area. Glen­more is a ​‘red hot’ des­tin­a­tion already, as is evid­enced by heat maps of recre­ation use, and we are not aware of any rationale from the CNPA as to why encour­aging fur­ther con­cen­tra­tion of use of the Glen­more area is appro­pri­ate, desir­able or rep­res­ents wise plan­ning, in either the imme­di­ate or the longer term.

In terms of sup­port­ing action to address the cli­mate and nature emer­gen­cies, there is no rationale for pro­mot­ing car use in the Glen­more cor­ridor nor up to the Cas car park.

We con­sider Cairn Gorm is an inap­pro­pri­ate loc­a­tion for MTB trails aimed at the young, begin­ner fam­ily mar­ket. There are sig­ni­fic­ant issues of windy, cold, exposed and wet weath­er con­di­tions mak­ing rid­ing at this alti­tude unat­tract­ive; and the trails will be unus­able due to the pres­ence of snow/​ice on them at times when facil­it­ies at lower alti­tudes would not have this con­straint and would be rideable.

In addi­tion, extreme and stormy weath­er is pre­dicted to increase in fre­quency and sever­ity due to the pro­gres­sion of cli­mate change.

We find the sug­ges­tion that it would be glob­ally among the best fam­ily ori­ent­ated MTB facil­it­ies as extremely unreal­ist­ic: in addi­tion to the con­straints of weath­er con­di­tions, there is the fail­ure to main­tain the cur­rent site as an attract­ive-look­ing, well main­tained and evid­ently well cared for facility.

The facil­ity would provide a focus for moun­tain bik­ing from the Cas car park area, wheth­er this was inten­ded or not, with attend­ant envir­on­ment­al and recre­ation­al issues. We are con­cerned at the extent to which mit­ig­a­tion meas­ures such as notices, online inform­a­tion, etc. will be suc­cess­ful. In this con­text we point out that the mit­ig­a­tion meas­ures CNPA put in sev­er­al years ago with respect to impacts of moun­tain bikers at Bad­aguish, remain com­pletely inef­fect­ive, with the notices ask­ing people to ​“Please use des­ig­nated tracks” loc­ated so that they are nonsensical.

The assess­ment of the impacts on Glen­more European sites fails to take account that the bridge over the burn accessed from the Ciste car park has been closed for many months. The assess­ment emphas­ises the indis­tinct 3

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nature of the path; how­ever, when the bridge is repaired, this path could rap­idly become a clear route with poten­tially cata­stroph­ic con­sequences for caper­cail­lie in Glenmore.

The cur­rent pro­pos­al, if approved, can be pre­dicted to lead to fur­ther applic­a­tions for more MTB facil­it­ies else­where on the hill. Where­as we real­ise that plan­ning is under­taken on the mer­its of each applic­a­tion, we are also aware of how one devel­op­ment is used to jus­ti­fy the next one. We are very con­cerned that by approv­ing this applic­a­tion, the CNPA would be set­ting in motion a sequence of future applications.

Yours sin­cerely

Gus Jones Convener

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Cairngorms Nation­al Park Author­ity Plan­ning Team The Dulaig Seafield Aven­ue Grant­own-on-Spey PH26 3JG 20 March 2022 14 The Square Grant­own on Spey PH26 3HG

Objec­tion to Plan­ning Applic­a­tion 2022/0046/DET — Form­a­tion of moun­tain bike track and related infra­struc­ture These com­ments are presen­ted as: a con­cerned mem­ber of the pub­lic liv­ing in the Cairngorms Nation­al Park an oper­at­or of a tour­ism accom­mod­a­tion busi­ness oper­at­ing with­in the Cairngorms Nation­al Park, and a Dir­ect­or of the Cairngorms Cam­paign with the approv­al of the Cairngorms Cam­paign Board I wish to object to this plan­ning applic­a­tion for reas­ons of lack of an over­all devel­op­ment plan for the Coire Cas area, insuf­fi­cient sup­port­ing detail, major adverse land­scape and envir­on­ment­al impact of the cur­rent pro­pos­als and that the applic­a­tion does not sup­port many of the CNPA Plan­ning Policies. Con­sequently, I recom­mend that CNPA rejects this applic­a­tion in full.

1. Lack of a Devel­op­ment Plan

CMSL has pro­duced what it calls a mas­ter­plan. In the intro­duc­tion to the doc­u­ment CMSL states: ​“This mas­ter­plan has been cre­ated as a frame­work to enable the plan­ning author­ity to con­sider the impact of future applic­a­tions not only as indi­vidu­al pro­jects but as con­trib­ut­ors to a joined-up vis­ion of Cairngorm’s future that is based on tar­geted and pub­lic con­sulta­tion.” The major prob­lem with the CMSL mas­ter­plan is that it simply presents a series of dis­join­ted aims and goals without show­ing what the fin­ished devel­op­ment will look like and how the vari­ous aims (win­ter­s­ports, bik­ing, walk­ing, centre for the moun­tain envir­on­ment) fit togeth­er on the ground. In fact, des­pite moun­tain bike trails being a so-called key strategy, there is no men­tion of moun­tain bik­ing any­where in Sec­tion 5 of the mas­ter­plan entitled ​“Cre­ation of a zoned mas­ter­plan that sup­ports the key strategies”. Are we meant to assume that moun­tain bik­ing is only a tem­por­ary activity?

Des­pite all the vis­ion­ary words which way overegg the import­ance of this part of Cairngorm Moun­tain, this doc­u­ment is far from a mas­ter­plan. Sec­tion 3 is entitled ​“Key 1

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strategies”, but all that it con­tains are a vis­on and some indi­vidu­al goals – not one strategy is explained or developed. A strategy is a plan to achieve a cer­tain aim or goal. This so-called mas­ter­plan con­tains no plans to achieve the ambi­tious goals it presents and does not demon­strate how all these goals link with each oth­er and what the over­all plan might look like on the ground with all its impacts on the land­scape and the envir­on­ment and on sus­tain­ab­il­ity targets.

A devel­op­ment plan for the whole area should as a min­im­um show: a plan of the com­pleted devel­op­ment illus­trat­ing the over­all lay­out and inter­ac­tion between the vari­ous aims and goals an apprais­al of the over­all land­scape and envir­on­ment­al impact of the com­plete mas­ter­plan a descrip­tion of how the over­all devel­op­ment plan is con­sist­ent with and sup­ports the LDP Policies some detail on the plan to achieve the vari­ous aims and goals There is an attempt to illus­trate in out­line format the plan to achieve the vari­ous aims and goals in the table in Sec­tion 3.3 of the mas­ter­plan, but all the oth­er key parts of a devel­op­ment plan are either miss­ing or have major omissions.

Just one example which makes the assess­ment of the part of the mas­ter­plan to which this plan­ning applic­a­tion relates very dif­fi­cult are the ref­er­ences to the relo­ca­tion of the snow fact­ory into and through the moun­tain bike trails area. Without details of the haul road, ser­vices pro­vi­sion and design of and sit­ing of the snow fact­ory base it is not pos­sible to assess the viab­il­ity of the moun­tain bike trail area and the over­all impact on land­scape and the envir­on­ment. It is also not clear how the oper­a­tion of the moun­tain bike trails inter­faces with the snow fact­ory infra­struc­ture. This is yet anoth­er clas­sic example of what CMSL and its own­ers HIE have done over the years with plan­ning applic­a­tions. They try to inch their way with dis­join­ted plan­ning applic­a­tion after dis­join­ted plan­ning applic­a­tion to achieve what they want at the time of each plan­ning applic­a­tion without present­ing a clear over­all pic­ture of how these indi­vidu­al schemes fit together.

This is a clas­sic example of dan­ger­ously poor plan­ning, and CNPA should reject all the claims that this plan­ning applic­a­tion is sup­por­ted by a mas­ter­plan. If this applic­a­tion is approved, we will get yet anoth­er example of plan­ning creep where it might be presen­ted that the applic­a­tion will provide bene­fits, which will not mater­i­al­ise when the over­all pic­ture devel­ops. We will all waken up to real­ise what a com­plete mess CMSL and HIE has made of Cairngorm Moun­tain. Many of us have been aware of this for years. When will CNPA waken up and real­ise that these plans are not plans but just wish­ful thinking?

1. Lack of Sup­port­ing Detail This applic­a­tion appears to be a concept only and lacks co-ordin­a­tion and detail. Issues include:
2. It is unclear how the pro­posed tracks and infra­struc­ture fit in with the exist­ing snow sports infra­struc­ture. Is the magic car­pet there for snow sports or for the begin­ners 2

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bik­ing area? Is such a magic car­pet needed for uplift in this begin­ners’ area?

1. The pur­poses of the ascent trails are not explained. Why do these need to be sep­ar­ate from the exist­ing roads, giv­en that vehicu­lar traffic is sup­posed to be minimal.
2. The trails seem to be schem­at­ic only with no real explan­a­tion of how they will oper­ate and integ­rate together.
3. There is no clear indic­a­tion how people will access the moun­tain bike trails from the car park and how these bikes will integ­rate with walk­ers using the area.
4. How do bikers get up to the mid sta­tion? Do they ride or walk up one of the tracks, or will the funicu­lar be used or even avail­able for use?
5. The track sec­tions, clearly lif­ted from oth­er plans, do not give a clear indic­a­tion of what track lay­outs will be used in the vari­ous loc­a­tions. This can­not be left to CMSL to decide, there needs to be clear plans of what track sec­tions will be used and where, espe­cially when there is a sens­it­ive envir­on­ment and ground con­di­tions to consider.
6. There is no detail on berms and rollers or pro­posed tree planting

7. High­land Council’s con­cerns over the trans­port link­ages with Aviemore and the Glen­more area need to be addressed. There has been little or no attempt to do this in the applic­a­tion documents.

8. Adverse Land­scape and Envir­on­ment­al Impact The main sup­port­ing doc­u­ments on this import­ant sub­ject are:

9. “Work­ing with the Envir­on­ment at Cairngorm” (dated Feb­ru­ary 2018) and a slim lack­ing in any detail Con­struc­tion Meth­od State­ment, which just relies on the gen­er­ic Work­ing with the Envir­on­ment at Cairngorm doc­u­ment. This gen­er­ic doc­u­ment provides some use­ful guid­ance on con­duct­ing excav­a­tion and con­struc­tion works on and into the sens­it­ive veget­a­tion cov­er and under­ly­ing soils. The prob­lem is that there is a raft of evid­ence that most of the pre­vi­ous works con­duc­ted in the area under pre­vi­ous plan­ning con­sents have not com­plied with this guid­ance and there is a his­tory of little or no enforce­ment of this guid­ance by CNPA Plan­ning. Des­pite the Con­struc­tion Meth­od State­ment being almost wholly based on this guid­ance, what con­fid­ence is there that CMSL and its chosen con­tract­ors will com­ply with this guid­ance or that CNPA will act­ively check on works to ensure that CMSL and its con­tract­ors comply?

10. Assess­ment of Risks to Adja­cent European Sites to inform a Hab­it­ats Reg­u­la­tions Apprais­al This report pur­ports to thor­oughly explain that the risk of moun­tain bikers stray­ing out­side of the Moun­tain bike park onto oth­er vehicu­lar trails, walk­ing paths and out into the sur­round­ing pro­tec­ted area is either low or very low. How­ever, there is little or no evid­ence to back up the opin­ions and state­ments. There is little or no evid­ence presen­ted of what has happened on oth­er moun­tain bike areas (e.g. Glen­liv­et or Nevis Range). One simple example of an erro­neous claim is that the quant­ity of walk­ers on some routes would deter moun­tain bikers. I have per­son­al exper­i­ence of walk­ing on the track from Glen­more up to Ryvoan bothy and reg­u­larly hav­ing to step aside to let bikers pass. The many walk­ers on this path do not deter moun­tain bikers. There are claims that notices and enforce­ment on the ground will pre­vent moun­tain 3

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bikers stray­ing out of the moun­tain bike park. Giv­en the track record of poor man­age­ment over many years of the Coire Cas area, what con­fid­ence is there that pro­lif­er­a­tion of moun­tain bik­ing will not ju8st be allowed to hap­pen? Also what enforce­ment will there be to ensure that CMSL con­tains moun­tain bik­ing to the moun­tain bike park area. The report claims that moun­tain bikers are unlikely for a vari­ety of reas­ons to open up routes down the moun­tain from the Ciste car park area. Again, the reas­ons giv­en are just unsub­stan­ti­ated opin­ions. The pic­tures show­ing the poten­tial bike tracks along exist­ing walk­ing routes seem quite plaus­ible bike tracks for exper­i­enced riders. What mon­it­or­ing would CMSL do in the Ciste area, giv­en their lim­ited resources and the great focus on the Cas area? I sus­pect there would be no monitoring.

Without real sub­stan­ti­ation of the assess­ments by inde­pend­ent, know­ledge­able and exper­i­enced per­sons with evid­ence from oth­er moun­tain bik­ing areas, these assess­ments of risk lack cred­ib­il­ity as they are just the opin­ions of a motiv­a­tion­ally biased organ­isa­tion – namely CMSL, the applicant.

1. Eco­lo­gic­al Con­straints Sur­vey Con­cerns about this doc­u­ment include: How much faith can any­one have with this Enviro­centre report when in sec­tion 1.3 it says, ​“The ​‘site’ is loc­ated on the south facing slopes of Cairngorm Moun­tain”! Any quick look at a map shows the site is on NW facing slopes – so what oth­er errors are there in this report? This sup­port­ing doc­u­ment was com­mis­sioned to provide a ​“an eco­lo­gic­al baseline of the site, in terms of the hab­it­ats present and evid­ence of pro­tec­ted and not­able spe­cies. Apart from a desk study, only one on-site sur­vey was con­duc­ted (20 Octo­ber 2021). This is insuf­fi­cient to estab­lish a cred­ible baseline sur­vey as many spe­cies and flora need to be sur­veyed dur­ing vari­ous sea­sons. It does recom­mend fur­ther sur­veys be con­duc­ted pri­or to com­mence­ment of con­struc­tion works, but this can­not influ­ence any decision on this applic­a­tion and can only be used at best to attempt to add fur­ther mit­ig­a­tion meas­ures. The sur­vey report even admits that Mid Octo­ber is not the right time to assess bird or rep­tile pop­u­la­tions and pres­ence. This sur­vey should have at least have been con­duc­ted in the sum­mer months when birds are breed­ing and amphi­bi­ans and rep­tiles are not hibern­at­ing. A list of pos­sible mit­ig­a­tions to avoid dam­age to flora and fauna dur­ing con­struc­tion work is provided. What the report is silent on is the effect of loss of hab­it­at etc. by the con­struc­tion of the moun­tain bike park on pro­tec­ted spe­cies. Addi­tion­ally, there is no advice on what should hap­pen if nests etc. are found which would be dam­aged or aban­doned if con­struc­tion pro­ceeded. The NVC sur­vey con­duc­ted in 2019 has been ref­er­enced and extracts from this report have been included, although I can­not find any assess­ment or com­ments on wheth­er this devel­op­ment would adversely affect these NVC com­munit­ies. In sum­mary, a basic eco­lo­gic­al sur­vey has been con­duc­ted, but the adverse effects of this pro­posed devel­op­ment on the eco­logy of the area have not been assessed. The report just assumes that the devel­op­ment will pro­ceed and provides basic mit­ig­a­tion recom­mend­a­tions. If the moun­tain bike park is suc­cess­ful, there will be a much lar­ger human pres­ence in 4

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the Coire Cas area over the sum­mer months. The num­bers of people, the move­ment of people and the inad­vert­ent extra human noise must have a neg­at­ive effect on loc­al wild­life, espe­cially dur­ing the breed­ing sea­son. The eco­lo­gic­al report is silent on this sig­ni­fic­ant issue a major omis­sion which must be addressed.

1. The Sup­port­ing State­ment The descrip­tion of the visu­al impact of this pro­posed devel­op­ment is at best sketchy and optim­ist­ic. The state­ment men­tions that trail berms and rollers will reduce visu­al impact, but there is no inform­a­tion on the design of these fea­tures or wheth­er these fea­tures will actu­ally do any­thing to reduce visu­al impact. The state­ment fur­ther claims that visu­al impact is mit­ig­ated by the devel­op­ment being in the lower Core Cas area. CNPA needs to remem­ber that it rejec­ted a plan­ning applic­a­tion for a syn­thet­ic ski area in this very area – one of the main reas­ons for rejec­tion was the adverse visu­al impact of that pro­posed devel­op­ment. Even using the applicant’s meas­ure of the devel­op­ment area (1.82 hec­tares) this is a large part of the lower Coire Cas and will have sig­ni­fic­ant visu­al impact. The state­ment says that there will be moun­tain wood­land plant­ing to ​‘enhance’ the area and reduce visu­al impact. No details of any pro­posed plant­ing haves been provided. Giv­en the high alti­tude, great care needs to be applied to any design of tree plant­ing both in pos­i­tion­ing and tree spe­cies selec­tion. Fur­ther­more, how will such tree plant­ing suc­ceed in screen­ing the moun­tain bike park, whilst not inter­fer­ing with (or being pro­tec­ted from) winter sports?

There are far too many ques­tions and omis­sions on poten­tial adverse impact on land­scape and the envir­on­ment for these to be covered off by plan­ning con­di­tions, thus unless these ques­tions and admis­sions can be pro­fes­sion­ally answered this applic­a­tion should either be rejec­ted or held in obey­ance until sat­is­fact­ory sup­ple­ment­ary inform­a­tion has been submitted.

1. Plan­ning Policy Con­text The sup­port­ing doc­u­ment sub­mit­ted on behalf of CMSL by Ryden, pur­ports to cov­er off the plan­ning policy con­text of the applic­a­tion. The very slim doc­u­ment does list the rel­ev­ant plan­ning policies in the CNPA LDP 2021, how­ever the simplist­ic bul­let points pur­port­ing to demon­strate that the applic­a­tion is sup­port­ive of these policies are at best min­im­al and misleading.

Policy 2: I agree that there is poten­tial for the applic­a­tion to enhance recre­ation­al and leis­ure facil­it­ies, how­ever the pro­viso in this policy that there is no envir­on­ment­al impact, is not met – unless one cyn­ic­ally assumes that the envir­on­ment with­in Coire Cas is already com­pletely trashed. Even then the case has not been made that this applic­a­tion will not adversely impact the vari­ous sur­round­ing pro­tec­ted areas, and the poten­tial adverse effects on drain­age and asso­ci­ated erosion down­hill of the pro­posed development.

Policy 3: I believe that this applic­a­tion falls into the defin­i­tion of a Major Devel­op­ment. The applic­a­tion claims in drwg CR20158-002 that the devel­op­ment area is only 1.82 hec­tares. Even if the fig­ures presen­ted are believed, the table in this draw­ing adding 5

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up the devel­op­ment area omits the Upper Zone referred to in CR20158-005 as a boxed area. Inclu­sion of this zone takes the devel­op­ment over 2 hec­tares mak­ing it a Major Plan­ning Applic­a­tion with all the extra requis­ite sup­port­ing doc­u­ments. Addi­tion­ally, I can find no attempt to jus­ti­fy the sus­tain­ab­il­ity of the design (e.g. min­im­ising the effect on cli­mate change – no sus­tain­able trans­port plans described, lack of descrip­tion on access and egress and no assess­ment that the built struc­tures will sur­vive the adverse weath­er con­di­tions without caus­ing envir­on­ment­al erosion and reg­u­lar maintenance).

Policy 4: The poten­tial adverse impact on sur­round­ing des­ig­nated sites, on pro­tec­ted spe­cies and on biod­iversity has been glossed over by the rel­ev­ant sup­port­ing doc­u­ments. Attempts to describe min­im­isa­tion and mit­ig­a­tion are either miss­ing or lack­ing detail.

Policy 5: I can find no evid­ence presen­ted to sup­port that this devel­op­ment com­plies with this policy as this devel­op­ment will not enhance or con­serve the land­scape char­ac­ter and spe­cial land­scape qual­it­ies of the CNP includ­ing wild­ness. It is clear that the oppos­ite will res­ult. Addi­tion­ally, no evid­ence has been sub­mit­ted to demon­strate that any social or eco­nom­ic bene­fits of this devel­op­ment out­weigh the neg­at­ive land­scape impacts, neither has adequate mit­ig­a­tion of the neg­at­ive impacts been demonstrated.

Policy 8: I believe this devel­op­ment in some respects does meet the require­ments of Policy 8, how­ever, I have real doubts about wheth­er this devel­op­ment meets the require­ments of 8.1a, namely, that it ​“demon­strates best prac­tice in terms of sus­tain­able design, oper­a­tion and future main­ten­ance, and where there are no adverse envir­on­ment­al impacts on the site or neigh­bour­ing areas”.

This sec­tion of my objec­tions alone presents strong grounds for the rejec­tion of this plan­ning application.

This applic­a­tion does not meet the required qual­ity stand­ards to demon­strate com­pli­ance with CNPA LDP Policies. There are also numer­ous sig­ni­fic­ant omis­sions and unsub­stan­ti­ated state­ments and opin­ions with­in the sup­port­ing doc­u­ments. At the very least, CNPA Plan­ning should point out the omis­sions and fail­ures and ask the applic­ant to resub­mit the applic­a­tion. If the applic­a­tion goes to the CNPA Plan­ning Com­mit­tee in its cur­rent form it should be rejected.

Yours faith­fully,

Dr Gor­don Bul­loch 6