Item6Appendix3KingussieCCComments20200193DETKingussieHousing

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 6 Appendix 3 26/03/2021

AGENDA ITEM 6

APPENDIX 3

2020/0193/DET

COM­MUNITY COUN­CIL COMMENTS

Dear CNPA Plan­ning Sup­port Team, With ref­er­ence to your let­ter dated 17^th August 2020 regard­ing the plan­ning applic­a­tion no.2020/0193/DET please find below our com­ments and quer­ies below;

Applic­a­tion 2020/0193/DET; Erec­tion of 23 houses and gar­ages with asso­ci­ated roads, infra­struc­ture and land­scap­ing Land to North, East and West of Dun­barry Ter­race and Ker­row Drive, Kingussie.

1. The Kin­gussie and vicin­ity Com­munity Coun­cil are sup­port­ive in prin­cip­al of the build­ing of new houses in Kin­gussie how­ever until the fol­low­ing com­ments and objec­tions have been addressed and met we can­not give our full sup­port to this plan­ning application.
2. It stated that there are no related cases how­ever applic­a­tions ref­er­ence num­bers 2020/0067/DET (23 Afford­able Houses) and 2020/013/DET (22 apart­ments and form­a­tion of access road) are related as these prop­er­ties are pro­posed being built in the same area are also part of a big­ger over­all devel­op­ment as is this pro­pos­al. There is little ref­er­ence to this over­all devel­op­ment which pro­poses up to 300 new prop­er­ties to be built. This pro­pos­al was giv­en plan­ning per­mis­sion in prin­cip­al 18 Janu­ary 2013 (ref. 09/048/CP).
3. A Haul Road for con­struc­tion of the over­all hous­ing devel­op­ment was pro­posed and per­mis­sion gran­ted on the 29/03/2017 how­ever this road is not shown in the plan­ning applic­a­tion doc­u­ment­a­tion. Unless a haul road is provided that will be used by all con­struc­tion traffic without the use of Ker­row Drive, Dun­barry Ter­race or the Dun­barry Road / High Street junc­tion or oth­er estab­lished roads Kin­gussie & vicin­ity Com­munity Coun­cil would like their objec­tion registered.
4. It is not accept­able to use Ker­row Drive, Dun­barry Ter­race and Dun­barry Road for any con­struc­tion traffic access as the roads and asso­ci­ated pave­ments are cur­rently used extens­ively by Kin­gussie res­id­ents. Note Dun­barry Road is used as a main route for School Chil­dren attend­ing both the primary and sec­ond­ary schools and is cur­rently not fit for pur­pose (ref also com­ment 7 below).
5. Until the con­tract­or sub­mits a con­struc­tion meth­od plan for this devel­op­ment includ­ing the Haul Road and Haul Road usage and a Con­struc­tion Traffic Man­age­ment plan. Kin­gussie and vicin­ity Com­munity Coun­cil (KVCC) registers an objection.
6. In the Pre-Applic­a­tion Con­sulta­tion report dated 28^th May 2020 it was noted that a num­ber of com­ments were raised by the gen­er­al pub­lic which included; keep­ing con­struc­tion traffic off Dun­barry Road / Ter­race and increased use of the Dun­barry Road / High Street junc­tion due to the new devel­op­ment. Writ­ten com­ments were also received about using a sep­ar­ate haul road for con­struc­tion traffic and the capa­city of the Dun­barry Road / High Street junc­tion. The Design Team’s response was to say these con­cerns would be addressed in the Sup­port­ing State­ment Sub­mit­ted with the plan­ning applic­a­tion. In the Plan­ning Sup­port State­ment dated 7^th July 2020 the ​“Design Team Response” was copied ver­batim from the Pre-Applic­a­tion Con­sulta­tion Report without address­ing the issues raised. Giv­en this response by the design team KvCC can­not sup­port this application.
7. With the build­ing of the new houses there will be increased traffic using the Dun­barry Road / High Street junc­tion. This junc­tion is not fit for pur­pose at the moment. There is cur­rently only one pave­ment on the West side of Dun­barry Road which does not extend to the junc­tion of the High Street. There is no pave­ment on the East side of Dun­barry Road. With increased traffic, ped­es­tri­an safety will be fur­ther com­prom­ised. It was under­stood that the new junc­tion to the East of Kin­gussie with the A86 will be the main junc­tion for this devel­op­ment. In the Trans­port State­ment (June 2020) it has been assumed by the con­sult­ant that Dun­barry Road is to be the main access to the houses when built and cal­cu­la­tions car­ried out show­ing that there will be neg­li­gible traffic impact on the sur­round­ing road net­work how­ever no account has been taken of the inten­ded over­all devel­op­ment of 300 houses, which includes the plan­ning applic­a­tions for the 22 apart­ments and 23 afford­able houses. Note for the 23 afford­able houses (2020/013/DET) a new junc­tion with the A86 is to be built to the East of Kin­gussie which can also be used to access this devel­op­ment (2020/0193/DET). a. In the Trans­port State­ment an aver­age of 30 addi­tion­al jour­neys for this devel­op­ment of 23 houses has been used for peak times. It is not clear why no cycle jour­neys and few ped­es­tri­an jour­neys have been accoun­ted for par­tic­u­larly as these modes of trans­port are pri­or­it­ised by the Scot­tish Gov­ern­ment (ref. com­ment 9.c. below). If this cal­cu­la­tion is extra­pol­ated to the 300 house devel­op­ment then 360 motor­ised vehicle jour­neys would be done in a 1 hour slot. This would far exceeds the capa­city of the exist­ing Dun­barry Road / High Street junc­tion if not the A86 junction.
8. Oth­er com­ments on Trans­port State­ment June 2020: 1.6 and 4.6 Devel­op­ment pro­pos­als states that Dun­barry and Ker­row drive have 2m wide foot­paths either side of the road. This is not the case. Please cla­ri­fy. a. b. 2.1.1 The exist­ing bus stop is over 400m from the site which means that this does not meet the stated cri­ter­ia of ​“reas­on­able walk­ing dis­tance”. The Rail­way sta­tion, primary school and sec­ond­ary school are also not reas­on­able walk­ing dis­tances using the stated cri­ter­ia of less than 400m. Please cla­ri­fy. C. 2.1.3 states that plan­ning per­mis­sion should not be gran­ted if dir­ect links to walk­ing and cyc­ling routes are not avail­able or can­not be provided and if access to pub­lic trans­port net­works involves more than 400m walk­ing. Note, pri­or­ity is giv­en to walk­ing, then cyc­ling, pub­lic trans­port and car and oth­er motor­ised vehicle. To meet the require­ments it is pro­posed that the A86 is used as an on- road cycle route and there is easy access to the Route 7 cycle­way. This is not accept­able to the KvCC as the A86 is a busy road and not a des­ig­nated cycle route. Route 7 has recently been

down­graded by Sus­trans and is for the use of exper­i­enced cyc­lists only. Pro­vi­sion should be giv­en to new cycle and ped­es­tri­an paths. d. 4.12 It is stated that safe access is provided to the schools by pro­vi­sion of a con­trolled cross­ing at the A86 / King Street / Arbroilach Road junc­tion. To access this cross­ing East Ter­race and Arbro­liach Roads are used which do not have pave­ments. Addi­tion­ally there is no pave­ment at the High Street / Dun­barry Road junc­tion. Please cla­ri­fy why this is con­sidered as safe access. 4.14 It is stated that the High School can be accessed via a remote foot­path off Spey Street which is sel­dom used by any Kin­gussie res­id­ents as it is a rough vehicle track, has no light­ing and takes chil­dren on a detour from more dir­ect routes to the school. Please cla­ri­fy. e. f. 4.3 The pro­pos­al is for a 30mph speed lim­it for the devel­op­ment which con­tra­dicts Scot­tish Gov­ern­ment com­mit­ments to intro­duce 20mph speed lim­its. A 20mph lim­it enhances ped­es­tri­an and cyc­list safety and is bet­ter for the envir­on­ment. The KvCC would like to see a 20mph speed lim­it for this devel­op­ment. Please note that on the related plan­ning applic­a­tion 2020/0067/DET (23 Afford­able Houses) a 20mph speed lim­it is clearly shown just off the new A86 junc­tion. This con­tra­dicts the pro­posed 30mph speed lim­it for this devel­op­ment. Please cla­ri­fy. g. 6.0 Con­clu­sions; i. No account has been taken of future devel­op­ment in the traffic impact assess­ment for the Dun­barry Road / High Street junc­tion (ref. also 7a. above). Please cla­ri­fy. ii. There is no link from the pro­posed devel­op­ment to exist­ing cycle routes path except by use of the A86, Dun­barry Road, East Ter­race and Arbroil­lach Road des­pite state­ments to the con­trary. Please cla­ri­fy how recog­nised links to safe foot­paths and cycle paths will be made. iii. Links to exist­ing well-lit foot­paths are by roads without pave­ments. Please cla­ri­fy how this is con­sidered to be safe? iv. Recently the bus ser­vice has been reduced which is con­trary to the state­ment made in item 14 say­ing that there is good sus­tain­able trans­port links. Please clarify.

1. In con­clu­sion the Kin­gussie & vicin­ity Com­munity Coun­cil sup­port the build­ing of this new devel­op­ment how­ever it should integ­rate with the exist­ing trans­port sys­tem, be future proofed, an integ­rated phased approach taken to the over­all devel­op­ment which makes full use of a haul road to keep Kin­gussie res­id­ents safe with the least dis­rup­tion. We would like to see an over­all pro­ject plan for the devel­op­ment of the whole site for the build­ing of 300 houses.

Yours sin­cerely Kin­gussie & vicin­ity Com­munity Council

Sub­ject: Plan­ning Applic­a­tion no.2020/0193/DET 10^th Novem­ber 2020 Dear CNPA Plan­ning Sup­port Team, With ref­er­ence to our response, pub­lished 10^th Septem­ber 2020, to the sub­ject plan­ning applic­a­tion please find below the res­ults of a traffic sur­vey con­duc­ted by the Kin­gussie & vicin­ity Com­munity Coun­cil on Thursday 29^th Octo­ber 2020.

This sur­vey is related to our pre­vi­ous let­ter items 7 & 8 where we had com­ments on the Trans­port State­ment, pro­duced by Camer­on + Ross ref A/191443 for Dav­all Devel­op­ments Ltd. dated June 2020. In this doc­u­ment, sec­tion 3.2 an estim­ate was made of Total Per­son Trips which appeared to be remark­ably low giv­en the num­ber of houses on and to the North of Dun­barry Road. The con­clu­sion of the Camer­on + Ross per­son trip estim­ate was that the junc­tion was oper­at­ing well with­in capa­city how­ever our sur­vey shows that the junc­tion is cur­rently oper­at­ing sig­ni­fic­antly over capa­city as shown below and the actu­al Total Per­son Trips that we recor­ded are approx­im­ately 4 times those estim­ated by Camer­on + Ross. On this basis the devel­op­ment can­not pro­ceed unless the junc­tion is improved and meets cur­rent Trans­port Stand­ards and Dun­barry Road can­not be safely used as a con­struc­tion haul road.

MODE	WEEK­DAY AM (08:00 – 09:00 29th Octo­ber 2020 Weath­er: dry, cloudy, 5 degrees.	WEEK­DAY PM 17:00 – 18:00 29th Octo­ber 2020 Weath­er: light rain, dark, 10 degrees
IN	OUT	TOTAL	IN	OUT	TOTAL
VEHICLE	18	60	78	45	25	70
TAX­IS	0	0	0	0	0	0
OGVS	3	7	10	10	4	14
PSVS	2	1	3	0	0	0
CYC­LISTS	0	0	0	1	0	1
VEHICLE OCCU­PANT (Includes Driver)	25	85	110	67	29	96
PED­ES­TRI­ANS	1	17	18	5	4	9

PUB­LIC TRANS­PORT | 0 | 0 | 0 | 0 | 0 | 0 TOTAL PER­SON TRIPS | 26 | 102 | 128 | 73 | 33 | 106 Camer­on + Ross Estim­ate Trans­port State­ment 3.2 | 7 | 23 | 30 | 20 | 12 | 32

Yours sin­cerely Kin­gussie & vicin­ity Com­munity Council