Item6Appendix4Objection20230380DETGosCaravanPark

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 6 Appendix 4 26/04/2024

Agenda Item 6

Appendix 4

2023/0380/DET

Rep­res­ent­a­tions — objection

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Emma Green­lees

From: 30 Octo­ber 2023 23:53 Sent: To: Plan­ning; Emma Bryce Sub­ject: 2023/0380/DET comments

Cat­egor­ies: Emma G, Request to Speak, Comments

Emma Bryce CNPA Planning

30 Octo­ber 2023

Dear Emma Bryce

2023/0380/DET | Exten­sion to cara­van site with 16No. stat­ic hol­i­day cara­vans | Grant­own-On-Spey Cara­van And Motorhome Club Seafield Aven­ue Grant­own-On-Spey PH26 3JQ

I am writ­ing to object to the above applic­a­tion. I would like to request the oppor­tun­ity to address the plan­ning com­mit­tee when they meet to determ­ine this application.

Land­scape 1

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Extend­ing the cara­van site will impact the formerly rel­at­ively nat­ur­al land­scape with addi­tion­al road­ways, stat­ic cara­vans, and asso­ci­ated infra­struc­ture. A num­ber of mature nat­ive trees have already been com­prom­ised to the det­ri­ment of land­scape qual­ity in this gen­er­al part of the cara­van site.

The pro­pos­al site is vis­ible from vari­ous loc­a­tions, includ­ing where there are long estab­lished access routes. These include:

To the south east of the pro­pos­al, from the path that runs from Seafield Aven­ue past Lynemore Care Home (and is joined by the path from beside Inver­al­lan Church) and con­tin­ues north east at the wood­land edge by the Mead­ow Burn to open ground on the Mossie.

North east of the pro­pos­al, from the vari­ous paths and open ground of the Mossie.

North west of the pro­pos­al, from the top of the rail­way line embank­ment. The rail­way line at this point forms part of the pro­moted Dava Way, for which view­points are of course important.

North of the pro­pos­al, from the paths with­in the mainly con­ifer wood­land near the wood­land edge.

There are cumu­lat­ive impacts on land­scape in this part of Grant­own with in par­tic­u­lar the nearby Beachen Court devel­op­ment, as well as the Care Home.

Hab­it­ats

The vari­ety and rich­ness of wet and dry grass­land, fen and wood­land hab­it­ats on the Mossie is exceptional.

The recent work that has stripped the field beside the cara­van site of veget­a­tion, and re-pro­filed the field, appar­ently in order to extend the cara­van site into this area, is a very sig­ni­fic­ant loss to the hab­it­ats and biod­iversity of the Mossie.

In the CNPA report ​“2009 CNPA Sup­ple­ment­ary Hab­it­at Inform­a­tion GS/H1, 2008 CNPA HLM Sur­vey Inform­a­tion GS/H1, Sum­mary of Biod­iversity Data” the most import­ant hab­it­ats on the Mossie are con­sidered to be the cal­careous and unim­proved grass­land hab­it­ats. In the CNPA’s In-Bye sur­vey, there were few oth­er fields with so much spe­cies rich grass­land, and the Mossie was in the top 40 (of 1340) sites sur­veyed in terms of veget­a­tion rich­ness and spe­cies diversity, with less than 4% of the sites sur­veyed being as spe­cies rich as the Mossie.

The CNPA Report refers to the spe­cies rich grass­land and fen between the cara­van site and the birch wood, which is dir­ectly adja­cent to the pro­pos­al site.

Biod­iversity

The Mossie has sup­por­ted a rich and excep­tion­al biod­iversity. How­ever, this can­not be taken for gran­ted and there is evid­ence that its rich assemblage of spe­cies has declined sig­ni­fic­antly in recent years.

Thus, for example, the large pop­u­la­tion of hun­dreds of Field Gen­tian present some 15 years ago has declined to almost noth­ing; and sim­il­arly, the 12 spe­cies of wax­cap fungi recor­ded then, now amount to about two species.

The Mossie as a whole is sub­ject to a vari­ety of influ­ences, includ­ing graz­ing and tramp­ling pres­sures from horses and cattle, and applic­a­tion of fer­til­izer, which are out­with the con­trol of the CNPA. How­ever, plan­ning and access are with­in the CNPA’s determ­in­a­tion. 2

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Waders: The Cairngorms Straths have long been appre­ci­ated as of nation­al import­ance for breed­ing waders. The fol­low­ing waders have all been known from the Mossie, but their num­bers have declined sig­ni­fic­antly at the Mossie over recent years: Red­shank (UK Amber List, UK pop­u­la­tion and dis­tri­bu­tion declin­ing); Cur­lew (UK Red List, UK pop­u­la­tion and dis­tri­bu­tion declin­ing); Snipe (UK Amber List, UK pop­u­la­tion stable, dis­tri­bu­tion declin­ing); Lap­wing (UK Red List, UK pop­u­la­tion and dis­tri­bu­tion declin­ing); and Oyster­catch­er (UK Amber List, UK pop­u­la­tion declin­ing, dis­tri­bu­tion expanding).

As explained in the ​“2009 CNPA Sup­ple­ment­ary Hab­it­at Inform­a­tion GS/H1, 2008 CNPA HLM Sur­vey Inform­a­tion GS/H1, Sum­mary of Biod­iversity Data” the Mossie was then ​“crit­ic­al to breed­ing waders.” At that time the Mossie sup­por­ted import­ant num­bers of breed­ing Lap­wing; and Cur­lew, Snipe, Red­shank and Oyster­catch­er all bred on the Mossie. Dur­ing 2008, when the Mossie was sur­veyed for breed­ing waders by the CNPA, the dens­ity of breed­ing waders recor­ded there made it the second most import­ant site of 46 sites reg­u­larly sur­veyed in Badenoch & Strath­spey. An addi­tion­al 12 sites in the Spey catch­ment were sur­veyed in 2006, and none of them sup­por­ted a high­er dens­ity of breed­ing waders than recor­ded at the Mossie.

In the CNPA report the high dens­it­ies of breed­ing waders at the Mossie are con­sidered to be due to the com­plex mat­rix of dif­fer­ent wet and dry grass­land hab­it­ats, open water and fens at the Mossie, the gen­er­ally open nature of the site, as well as the hydro­logy and his­tory of live­stock grazing.

The pro­posed devel­op­ment would increase dis­turb­ance levels in the area of wet unim­proved grass­land that adjoins the pro­pos­al site, through the activ­it­ies of people, pets and vehicles in and near the pro­pos­al site. This wet­land provides valu­able hab­it­at and in the recent past has sup­por­ted sig­ni­fic­ant num­bers of breed­ing snipe.

Amphi­bi­ans and Reptiles

The Mossie is known to have sup­por­ted Com­mon Toad and Com­mon Liz­ard both of which are on the Scot­tish Biod­iversity List, and Com­mon Frog.

Near the now dec­ad­ent Aspen tree close to the pro­pos­al site, there was a former wet area that sup­por­ted Com­mon Toad, which may have bred there. Frog and Toad spawn has been found in the large body of water behind the health centre. The wet grass­land and fen adja­cent to the pro­pos­al provides suit­able hab­it­at for amphi­bi­ans. Liz­ards are likely to breed on the Mossie giv­en the diversity and struc­ture of hab­it­ats available.

Inver­teb­rates

The Mossie is a well known site for its import­ance for inver­teb­rates. It is illus­trated in the book known as the ​‘Bee Bible’ (Field Guide to the Bees of Great Bri­tain and Ire­land by Falk and Lew­ing­ton), which refers to the ​“plen­ti­ful Devil’s‑bit Sca­bi­ous” that ​“attracts bees such as Andrena mar­ginata and Bom­bus soroeensis”.

Parts of the Mossie are par­tic­u­larly rich in Devil’s‑bit Sca­bi­ous, an import­ant source of pol­len and nec­tar later in the sum­mer. It is the only known source of pol­len for Andrena mar­ginata, which is on the Scot­tish Biod­iversity List, is rated Red Data Book Nation­ally Not­able A, and is rare and threatened in much of Europe.

The Leafcut­ter bee (Megachile ) has been recor­ded on the Mossie, which at the time was the only record for the Nation­al Park accord­ing to NBN. 3

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But­ter­flies known from the Mossie include Large Heath (Scot­tish Biod­iversity List, classed as Vul­ner­able); Small Heath (Scot­tish Biod­iversity List, classed as Near Threatened); Small Pearl-bordered fritil­lary (Scot­tish Biod­iversity List, classed as Near Threatened); North­ern Brown Argus (Scot­tish Biod­iversity List, classed as Vulnerable).

Thirty one spe­cies of hov­er­fly are recor­ded from the Mossie, with two spe­cies (Eri­stal­is rupi­um and Xylota jakator­um) known to have bred on the Mossie.

Cumu­lat­ive impacts on biod­iversity need to be taken account of. Flower-rich hab­it­ats of value to inver­teb­rates have been lost at the Beachen Court site; and Lynemore Care Home has developed the south west edge of the Mossie.

Access

Pub­lic access has been lost since the land to the north west of the cara­van site came under the same own­er­ship as the cara­van site, and a fence with no access through it (such as a gate) was erec­ted on the east bound­ary, demarc­at­ing the new own­er­ship. Now, fol­low­ing very recent work, the field has been fur­ther trans­formed, with veget­a­tion stripped and major re-pro­fil­ing of bare soil.

Pre­vi­ously a path lead through this field, from the lower ground of the Mossie to near the top of the field where there was a fine view over the Mossie, the town and bey­ond to the Crom­dales. This path con­tin­ued and joined the rail­way line and con­nec­ted with the vari­ous routes that form part of the path net­work in this part of Grantown.

The pro­pos­al would reduce the qual­ity of exper­i­ence and enjoy­ment of the coun­tryside through devel­op­ment fur­ther encroach­ing on the Mossie and impact­ing the qual­ity of land­scape and biod­iversity which make import­ant con­tri­bu­tions to people’s enjoy­ment of the countryside.

Cumu­lat­ive impacts on access need to be taken account of, with a reduc­tion in access on the Mossie as well as at the fields that have been developed at Beachen Court.

Waste

We note that there is a large drain eman­at­ing from the site and drain­ing dir­ectly into the Mossie, with signs of oil in the drained water on the Mossie side of the fence. This source of poten­tially long- term pol­lu­tion into the Mossie is of con­cern, and may increase as a res­ult of the pro­posed development.

Nation­al Plan­ning Frame­work 4

We do not con­sider the pro­pos­als to be in line with policies in NPF4, in par­tic­u­lar Policy 3 Biod­iversity. It is appar­ent that the Mossie is both excep­tion­al in terms of biod­iversity but that its spe­cies rich­ness is sig­ni­fic­antly declin­ing. The pro­posed devel­op­ment would not ful­fil the Policy Intent to pro­tect biod­iversity, reverse biod­iversity loss, deliv­er pos­it­ive effects from devel­op­ment and strengthen nature net­works. Neither would the pro­pos­al deliv­er the Policy Out­come of achiev­ing enhanced biod­iversity with strengthened nature networks.

Cara­van Sales and Uses 4

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We note that the cara­van site advert­ises ​“Hol­i­day Homes For Sale”. Con­cern­ing the ques­tion on the cara­van site web­site ​‘Can I live full-time in my cara­van” the web­site provides the per­haps ambigu­ous answer ​“The Cara­van Park is open 12 months of the year for hol­i­day use.”

It is unclear how the CNPA or The High­land Coun­cil can reg­u­late the use of such ​‘Hol­i­day Homes’ on the site. It appears that there is scope for liv­ing on a per­man­ent, res­id­en­tial basis on the site irre­spect­ive of wheth­er this is permitted.

The pro­posed devel­op­ment of 16 stat­ic cara­vans, has the poten­tial for these pro­posed cara­vans to become res­id­en­tial homes rather than hol­i­day homes. There is also the poten­tial for these cara­vans to be advert­ised for sale as hav­ing ​“excel­lent rent­al poten­tial” if you ​“Fancy some extra income” just as com­par­able cara­vans at the site are already.

We are con­cerned that the import­ant land­scape and biod­iversity as well as people’s enjoy­ment of the coun­tryside in the Nation­al Park may poten­tially become degraded through this wider use of the cara­van site.

Your sin­cerely

Con­vener 5