Item7AANethyCaravanSiteReport20210090DET

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Item 7 25/02/2022

CAIRNGORMS NATION­AL PARK AUTHORITY

DEVEL­OP­MENT PROPOSED:

Form­a­tion of camper­van site at Land 315M SW Of The Half House Nethy Bridge

REF­ER­ENCE: 2021/0090/DET

APPLIC­ANT: Mr Don­ald S Black

DATE CALLED-IN: 22 March 2021

RECOM­MEND­A­TION: Approve, sub­ject to conditions

CASE OFFICER: Stephanie Wade, Plan­ning Officer

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CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Item 7 25/02/2022

SITE DESCRIP­TION, PRO­POS­AL AND HISTORY

Site Descrip­tion

1. The applic­a­tion site com­prises agri­cul­tur­al land loc­ated approx­im­ately 2km east of Nethy Bridge. An exist­ing farm track runs cent­rally through the site to serve the exist­ing agri­cul­tur­al build­ings and will provide the access route to the approved res­id­en­tial dwell­ing of the agri­cul­tur­al hold­ing. Access to the site is taken off of the C1124 road which runs between Nethy Bridge and the A939 Tomin­toul road. Sliemore wood- a Scots Pine plant­a­tion lies to the south of the site extend­ing east­wards and a semi-nat­ur­al broad-leaved wood­land abuts the east­ern site bound­ary. To the west of the site is the wider agri­cul­tur­al field which slopes in a west­erly dir­ec­tion. To the north of the site, bey­ond the road is fur­ther Scots pine plant­a­tion wood­land and fur­ther agri­cul­tur­al land.

2. The site is not covered by any spe­cif­ic envir­on­ment­al des­ig­na­tions, although it is with­in the vicin­ity of the River Spey Spe­cial Area of Con­ser­va­tion [SAC] and the Craigmore Wood Spe­cial Pro­tec­tion Area [SPA].

Pro­pos­al

1. The draw­ings and doc­u­ments asso­ci­ated with this applic­a­tion are lis­ted below and are avail­able on the Cairngorms Nation­al Park Author­ity web­site unless noted otherwise:

http://​www​.eplan​ningcnpa​.co​.uk/​o​n​line- applications/applicationDetails.do?activeTab=summary&keyVal=QPT5AJSI0BY00

Title	Draw­ing Num­ber	Date on Plan*	Date Received
PLANS
Plan — Loc­a­tion Plan	324⁄02	01/02/21	04/11/21
Plan — Site Plan	324⁄01	12/10/21	04/11/21
Plan — Land­scape Proposals	LFC 100.21 SL-01 Rev.C	16/11/21	19/11/21
Plan — Plant­ing Plan	LFC 100.21 SI-02 Rev.C	16/11/21	19/11/21
Plan — Site Invest­ig­a­tion Layout	217110⁄03 Rev.A	28/09/21	30/09/21
Plan — Sur­fa­cing Layout	217110⁄05 Rev.B	25/10/21	04/11/21
Plan — Junc­tion Vis­ib­il­ity Layout	217110⁄02 Rev.C	20/01/22	20/01/22
Plan — Junc­tion Vis­ib­il­ity Analysis	217110⁄06 Rev.A	17/01/22	20/01/22
Plan — Drain­age Layout	217110⁄04 Rev.A	28/09/21	30/09/21

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Item 7 25/02/2022

|Plan — Site Plan- Water Supply|324/03|01/10/21|04/11/21| |SUP­PORT­ING INFORM­A­TION|||| |Oth­er — Camper­van Hook-up Photograph|||22/03/21| |Oth­er — Sup­port­ing Statement||01/03/21|22/03/21| |Oth­er — Aer­i­al Photograph|||22/03/21| |Oth­er — Vis­ib­il­ity Ana­lys­is Fur­ther Information||20/01/22|20/01/22| |Oth­er — Sup­port­ing Information||13/10/21|20/12/21| |Oth­er — Land­scape Main­ten­ance Schedule|LFC 100.21 Rev.A|16/11/21|19/11/21| |Oth­er — Agent response to consultees||04/11/21|04/11/21| |Oth­er — Let­ter about Water Supply||01/11/21|04/11/21| |Oth­er — Photo of Water Treat­ment Plant|||04/11/21| |Oth­er — Traffic Speed Sur­vey- Northbound|||12/10/21| |Oth­er — Traffic Speed Sur­vey Southbound|||12/10/21| |Oth­er — Water Sup­ply Report|SMS48-847|28/11/14|30/09/21| |Oth­er — Water Sup­ply Questionnaire|||01/10/21| |Oth­er — Exten­ded Phase I Hab­it­at Survey||01/08/21|30/09/21|

*Where no spe­cif­ic day of month has been provided on the plan, the sys­tem defaults to the 1^st of the month.

1. The applic­a­tion pro­poses the change of use of agri­cul­tur­al land to provide twelve cara­van pitches for use for use as a tour­ing caravan/​motorhome site. The pitches are pro­posed to be cre­ated of a sub-base and a lay­er of stone-dust­ing over to provide the hard­stand­ing. The pitches are pro­posed to be loc­ated adja­cent to the east­ern site bound­ary with access to the pitches taken off of the exist­ing farm access track, which runs cent­rally through the site in a north-south dir­ec­tion. Two park­ing spaces are pro­posed to be loc­ated on the west­ern side of the access track to be used for waste dis­pos­al. The remain­ing west­ern side of the site is pro­posed as a land­scaped area with a pro­posed pic­nic area and an area for view­ing his­tor­ic farm machinery. The pitches are pro­posed in sets of two across the site inter­spersed with plant­ing and each set of pitches will have a power, water and Wi-fi hook up point between the two pitches. A refuse/​bin area is pro­posed to be sited in the north east­ern corner of the site which is to be enclosed with a slat­ted tim­ber fence and a mixed spe­cies hedge. Waste water is to be dis­posed of by a sealed tank loc­ated adja­cent to the tem­por­ary park­ing spaces to allow for the empty­ing of waste water.

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Item 7 25/02/2022

1. Regard­ing land­scap­ing works, the applic­ants pro­pose a low earth mound along the west­ern site bound­ary, avoid­ing the exist­ing birch tree to provide screen­ing to the site. The mound is pro­posed to be sown with a wild­flower seed mix and planted with groups of nat­ive spe­cies shrubs. A fur­ther mound of the same spe­cific­a­tion is pro­posed on the south­ern side of the site adja­cent to the camper­van pitches. The west­ern side of the site is pro­posed to be main­tained as mown grass. A mixed nat­ive spe­cies hedge is pro­posed along the east­ern site boundary.

2. A grassed foot­path is pro­posed to be cre­ated around the peri­met­er of the adja­cent field to the west, in response to the Hab­it­ats Reg­u­la­tions Apprais­al require­ments, as detailed in para­graphs 10 – 13.

3. Dur­ing the pro­gres­sion of the applic­a­tion, the applic­ant has provided addi­tion­al inform­a­tion in response to quer­ies raised dur­ing the con­sulta­tion pro­cess. The fol­low­ing sum­mary con­tains ori­gin­al doc­u­ment­a­tion sub­mit­ted and addi­tion­al inform­a­tion submitted:

a) Sup­port­ing inform­a­tion: The agent has provided a num­ber of indi­vidu­al responses to the stat­utory and pub­lic con­sulta­tion quer­ies raise dur­ing the ori­gin­al con­sulta­tion peri­od. The Sup­port­ing State­ment provides the busi­ness case for the pro­pos­al and back­ground inform­a­tion on the applicant’s agri­cul­tur­al enter­prise and the diver­si­fic­a­tion scheme to provide a small scale camper­van site along­side the agri­cul­tur­al oper­a­tions. The doc­u­ment states that the applicant’s recog­nised they could ful­fil a demand for provid­ing camper­van­ning accom­mod­a­tion to meet the growth of camper­van­ning in recent years and help to meet the short­age of overnight stop­ping off places with sup­port­ing facil­it­ies with­in the Cairngorms Nation­al Park. Ref­er­ence is also made to the Cov­id-19 surge in stayc­a­tions and camper­van own­er­ship and sug­gests that this demand will be main­tained with fur­ther growth in this industry. Regard­ing oper­at­ing peri­ods, the doc­u­ments state that this will be heav­ily influ­enced by the pat­tern of demand and although oper­a­tion will look to be year round, there is anti­cip­ated quieter sea­sons of demand between Novem­ber and March. Vis­it­a­tion pat­terns are likely to be mainly at week­ends out­with main hol­i­day peri­ods and in the shoulder months. Site man­age­ment is to be provided by the applic­ant who is present on site on a daily basis for the agri­cul­tur­al activ­it­ies of the hold­ing. The applic­ant has per­mis­sion to erect a dwell­ing on the hold­ing and once this is erec­ted, there will be 24hr man­age­ment. The doc­u­ment states that the con­struc­tion of the dwell­ing is anti­cip­ated this year.

b) Roads inform­a­tion: a traffic count and speed sur­vey from 2016 has been sub­mit­ted which demon­strates the speeds recor­ded on the stretch of road, in close prox­im­ity to the pro­posed site access. The data found that vis­ib­il­ity splays should be 152m for 47.9 mph approach (traffic going down­hill to the access in a west­erly dir­ec­tion), and 142m for 45.4mph approach speed (traffic going uphill to the access in an east­erly dir­ec­tion). The pro­posed junc­tion vis­ib­il­ity to the east is 215m and 130m to the west to the far side verge. The inform­a­tion notes that the traffic count was recor­ded near­er to the access which is on a straight piece of road some 6m away from the start of the uphill bend. The report con­cludes that giv­en the increased vis­ib­il­ity to the far side verge of 130m, the pro­posed access loc­a­tion would be acceptable.

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Item 7 25/02/2022

c) Water sup­ply inform­a­tion: The doc­u­ment­a­tion con­firms that there is no water mains with­in a reas­on­able dis­tance of the devel­op­ment and a private water sup­ply will serve the devel­op­ment. The private water sup­ply bore­hole was drilled back in 2014, and the flow was meas­ured at a pro­duc­tion value of 2.27 cubic metres per hour equat­ing to 54.48 cubic metres per 24 hours. A raw sample was ana­lysed and there is an ultra­vi­olet treat­ment sys­tem in place to main­tain the qual­ity of the sup­ply. The sys­tem will be tested annu­ally to ensure qual­ity is main­tained. The sup­ply will also serve the farm­house and agri­cul­tur­al build­ings with­in the same ownership.

d) Eco­logy sur­vey work: An Exten­ded Phase I Hab­it­at Sur­vey has been sub­mit­ted which states that the site pre­dom­in­antly com­prises semi-improved grass­land with expans­ive con­ifer plant­a­tions to the north and south, semi-nat­ur­al broadleaved wood­land to the east and arable fields to the west. No rare or not­able plants or hab­it­ats were recor­ded on site. Signs of foraging/​com­mut­ing pine marten were noted although no rest­ing or breed­ing sites were recor­ded. A range of bird spe­cies were observed across the site and no oth­er field signs of pro­tec­ted mam­mal spe­cies or wood ant nests were recor­ded. Suit­able hab­it­at for red squir­rel, badger, wild­cat and rep­tiles was recor­ded, although no field signs con­firmed the pres­ence of these spe­cies. Suit­able bat for­aging hab­it­at was noted along wood­land and scrub edges. The report con­cludes that no addi­tion­al eco­lo­gic­al sur­veys are con­sidered neces­sary and that no neg­at­ive impact on the des­ig­nated sites is anti­cip­ated from the pro­posed development.

1. Cop­ies of the plans which accom­pany the applic­a­tion can be found at Appendix I.

His­tory

1. The wider land own­er­ship area, which util­ises the same access point has been sub­ject to a num­ber of his­tor­ic plan­ning applic­a­tions for the erec­tion of agri­cul­tur­al build­ings and the erec­tion of a farm­house. The dwell­ing ori­gin­ally gained plan­ning per­mis­sion in Octo­ber 2015 and an amend­ment to its loc­a­tion was approved in 2018 under applic­a­tion ref. 17/05650/FUL which was determ­ined by the High­land Council.

Hab­it­ats Reg­u­la­tions Appraisal

1. A Hab­it­ats Reg­u­la­tions Apprais­al [HRA] has been under­taken to con­sider the effects of the pro­pos­al upon the con­ser­va­tion object­ives of the European Sites as lis­ted with­in the doc­u­ment- attached at Appendix 2.

2. Regard­ing the River Spey SAC, the Apprais­al con­cludes that as there is no dir­ect or indir­ect con­nectiv­ity with the pro­posed devel­op­ment site due to the nature of the pro­pos­als, inter­ven­ing topo­graphy and veget­a­tion, there is no likely sig­ni­fic­ant effect on the qual­i­fy­ing interests of fresh­wa­ter pearl mus­sel, Atlantic sal­mon, sea lamprey or otter.

3. Regard­ing the Craigmore Wood SPA, the Apprais­al con­cludes that provided the below mit­ig­a­tion meas­ures are imple­men­ted as con­di­tions of plan­ning per­mis­sion, then

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Item 7 25/02/2022

there should not be sig­ni­fic­ant addi­tion­al dis­turb­ance to caper­cail­lie over and above what is already occur­ring through use of the exist­ing tracks and access points to the north of the pub­lic road. There­fore this con­ser­va­tion object­ive can be met. The mit­ig­a­tion meas­ures are:

a) Provide a fenced route with­in the field in which the pro­posed camper­van site is loc­ated, that provides an altern­at­ive access route off the pub­lic road and oppor­tun­it­ies to con­nect with the exist­ing path net­work around Nethy Bridge. Cre­at­ing a more appeal­ing altern­at­ive route dir­ectly access­ible from the camper­van site would help con­nect with and encour­age people to make use of the field route for short walks (includ­ing early morning/​late even­ing dog exer­cise), as well as make more use of the pro­moted path net­work in and around Nethy Bridge, rather than the sens­it­ive caper­cail­lie woods;

b) Pro­mote the field route as a means to access oth­er routes away from the sens­it­ive caper­cail­lie woods, via inform­a­tion provided at time of book­ing (as part of the book­ing terms and con­di­tions), as well as a per­man­ent onsite inter­pret­a­tion board; and

c) On-site sig­nage to encour­age use of the field route.

1. Fol­low­ing the pub­lic­a­tion of the HRA, the pro­posed plans have been amended to show the pro­posed peri­met­er access path around the field, as required by the HRA. This can be viewed on the Loc­a­tion Plan included with­in Appendix I.

DEVEL­OP­MENT PLAN CONTEXT

Policies

Nation­al Policy	Scot­tish Plan­ning Policy 2014
Stra­tegic Policy	Cairngorms Nation­al Park Part­ner­ship Plan 2017 — 2022
Loc­al Plan Policy	Cairngorms Nation­al Park Loc­al Devel­op­ment Plan (2021) Those policies rel­ev­ant to the assess­ment of this applic­a­tion are marked with a cross
POLICY I	NEW HOUS­ING DEVELOPMENT
POLICY 2	SUP­PORT­ING ECO­NOM­IC GROWTH	X
POLICY 3	DESIGN AND PLACEMAKING	X
POLICY 4	NAT­UR­AL HERITAGE	X
POLICY 5	LAND­SCAPE	X
POLICY 6	THE SIT­ING AND DESIGN OF DIGIT­AL COM­MU­NIC­A­TIONS EQUIPMENT
POLICY 7	RENEW­ABLE ENERGY
POLICY 8	OPEN SPACE, SPORT AND RECREATION
POLICY 9	CUL­TUR­AL HERITAGE
POLICY 10	RESOURCES	X
POLICY 11	DEVELOPER CON­TRI­BU­TIONS	X

1. All new devel­op­ment pro­pos­als require to be assessed in rela­tion to policies con­tained in the adop­ted Loc­al Devel­op­ment Plan. The full word­ing of policies can be found at:

https://​cairngorms​.co​.uk/​w​p​-​c​o​n​t​e​n​t​/​u​p​l​o​a​d​s​/​2​0​2​1​/​0​3​/​C​N​P​A​-​L​D​P​-​2​0​2​1​-​w​e​b.pdf

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Item 7 25/02/2022

Plan­ning Guidance

1. Sup­ple­ment­ary guid­ance also forms part of the Loc­al Devel­op­ment Plan and provides more details about how to com­ply with the policies. Guid­ance that is rel­ev­ant to this applic­a­tion is marked with a cross.

Policy I	New Hous­ing Devel­op­ment Non-Stat­utory Guid­ance (2015)
Policy 2	Sup­port­ing Eco­nom­ic Growth Non-Stat­utory Guidance	X
Policy 3	Sus­tain­able Design Non-Stat­utory Guid­ance (2015)	X
Policy 4	Nat­ur­al Her­it­age Sup­ple­ment­ary Guidance	X
Policy 5	Land­scape Non-Stat­utory Guidance	X
Policy 7	Renew­able Energy Sup­ple­ment­ary Guidance
Policy 8	Sport and Recre­ation Non-Stat­utory Guidance
Policy 9	Cul­tur­al Her­it­age Non-Stat­utory Guidance
Policy 10	Resources Non-Stat­utory Guidance	X
Policy 11	Developer Con­tri­bu­tions Sup­ple­ment­ary Guid­ance (2015)	X

CON­SULTA­TIONS

Sum­mary of the main issues raised by consultees

1. NatureScot con­firm that the HRA looks very com­pre­hens­ive and they have no com­ments to make on it. Fol­low­ing review of the addi­tion­al inform­a­tion, they have no fur­ther comments.

2. The High­land Coun­cil Trans­port Plan­ning Team ori­gin­ally reques­ted cla­ri­fic­a­tion and fur­ther inform­a­tion in rela­tion to the pro­posed site access and its vis­ib­il­ity splays. Fol­low­ing the sub­mis­sion of addi­tion­al inform­a­tion and from a site vis­it under­taken by the Trans­port Plan­ning Team, the fol­low­ing com­ments are made:

3. Cla­ri­fic­a­tion on the loc­a­tion of the 2016 speed sur­vey allowed them to determ­ine that the hori­zont­al and ver­tic­al align­ment of the road dir­ectly to the west would encour­age slower vehicle speeds before they are likely to speed up once they reach the straight­er sec­tion of road where the sur­vey was under­taken. There­fore, at the lim­it of the achiev­able 120m vis­ib­il­ity splay, it is likely that gen­er­al traffic speeds will be closer to the 40mph that would sup­port the 120m vis­ib­il­ity. The Team also note that vis­ib­il­ity to the oppos­ite side of the car­riage­way would be closer to 130m and whilst they do not gen­er­ally sup­port such means of meas­ur­ing vis­ib­il­ity, as this would not take account of any vehicles trav­el­ling on the wrong side of the road or over­tak­ing slower vehicles, such driv­ing man­oeuvres are unlikely at that loc­a­tion due to it being an unsafe place to do so. There­fore the abil­ity to see slightly fur­ther than the 120m clear vis­ib­il­ity meas­ured to the nearside edge gives some com­fort that even if approach speeds are slightly high­er than 40mph, there is some resi­li­ence in the abil­ity to achieve appro­pri­ate clear vis­ib­il­ity of approach­ing vehicles. Giv­en this, the Team remove their objec­tion relat­ing to clear visibility.

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Item 7 25/02/2022

1. The Team recom­mend the inclu­sion of plan­ning con­di­tions cov­er­ing; the install­a­tion of access pri­or to the first oper­a­tion of the facil­ity and that the pro­posed new fil­ter drain and ditch arrange­ment along the new private access will remain private and main­tained by the operator/​owner.

2. The High­land Coun­cil Envir­on­ment­al Health Officer ori­gin­ally reques­ted the sub­mis­sion of fur­ther inform­a­tion in rela­tion to the private water sup­ply. The Officer notes that the applic­ant has sub­mit­ted a plan of the water sup­ply and has provided details of the water flow rate of 55m³ per day which is con­sidered to be more than suf­fi­cient for the size of the pro­posed devel­op­ment. The applic­ant has also con­firmed there is a UV treat­ment sys­tem in place. The Officer states that the applic­ant will need to obtain a cara­van site licence and the water sup­ply will be sub­ject to a man­dat­ory mon­it­or­ing régime. The Officer con­cludes he has no objections.

3. The High­land Coun­cil Con­tam­in­ated Land Team has no com­ment regard­ing this site.

4. The High­land Coun­cil Flood Risk Man­age­ment Team has no objec­tion to the applic­a­tion not­ing that the hard­stand­ing appears to be free drain­ing and is there­fore accept­able. The Team note that the foul water drain­age arrange­ment would be sub­ject to SEPA licensing.

5. The High­land Coun­cil Forestry Officer provided com­ments on the ori­gin­al scheme sub­mit­ted, not­ing that there is no inten­tion to remove trees but requests tree pro­tec­tion is put in place for the exist­ing trees on site and that a detailed plant­ing plan should be provided. Fol­low­ing the sub­mis­sion of the revised inform­a­tion, the Officer notes that tree pro­tec­tion meas­ures are shown for the single birch which although are not to BS:5837(2012) stand­ard, would be adequate and could be accep­ted. The draw­ing does not show the trees on the bound­ary out­with the site to the east nor does it show any pro­tec­tion of these trees. Provid­ing the hard­stand­ing for the camper­vans comes no closer than 2m from the bound­ary fence as shown on the site plan, the neigh­bour­ing trees should be unaf­fected. The Officer sug­gests that fur­ther nat­ive trees could be added to the pro­posed plant­ing as an enhance­ment. The Officer recom­mends plan­ning con­di­tions for the imple­ment­a­tion of tree pro­tec­tion meas­ures, and the revi­sion of the plant­ing plan to include addi­tion­al tree planting.

6. CNPA Eco­logy Officer ori­gin­ally reques­ted the sub­mis­sion of fur­ther sur­vey work includ­ing an Exten­ded Phase I Hab­it­at Sur­vey to estab­lish which spe­cies are most likely to be impacted and identi­fy mit­ig­a­tion. Fol­low­ing the sub­mis­sion of the addi­tion­al inform­a­tion, which included the required sur­vey, and a path for dog walk­ers around the peri­met­er of the field, the Officer con­firms that no fur­ther inform­a­tion is required pri­or to determ­in­a­tion but vis­it­or man­age­ment meas­ures is recom­men­ded through con­di­tion, in accord­ance with the HRA. The Officer also recom­mends plan­ning con­di­tions for the imple­ment­a­tion of the tree pro­tec­tion meas­ures pri­or to con­struc­tion, and a con­di­tion to ensure the works are under­taken in accord­ance with the Phase I Exten­ded Hab­it­at Sur­vey Recommendations.

7. CNPA Land­scape Officer ori­gin­ally con­firmed that the Officer did not con­sider the pro­pos­al would cause an adverse impact on the land­scape, sub­ject to landscape

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Item 7 25/02/2022

mit­ig­a­tion works plus fur­ther details on plant­ing and tree pro­tec­tion. The latest sub­mis­sion addresses the Officer’s quer­ies with regards to the pro­posed bund. The Officer pre­vi­ously recom­men­ded the con­struc­tion of a dry­stone dyke along the west­ern bound­ary and at the gate­way which the Officer con­siders is a missed oppor­tun­ity to mit­ig­ate the land­scape and visu­al effects of the pro­pos­al and enhance the loc­al Spe­cial Land­scape Qual­it­ies. The Officer judges, how­ever, that the omis­sion would not res­ult in sig­ni­fic­ant effects on the Nation­al Park. In addi­tion, the latest sub­mis­sion include a new hedge along the east­ern side of the site. This would not res­ult in sig­ni­fic­ant adverse land­scape effects but it is high­lighted that neither would it have sig­ni­fic­ant bene­fi­cial effects on land­scape interests. The Officer expands on this by stat­ing that it is because it would spa­tially divide and obstruct views into the adja­cent open woodland/​scrub which cur­rently con­trib­utes to the dis­tinct char­ac­ter of the site. When pre­par­ing the ground and plant­ing this east­ern bound­ary hedge the Officer high­lights the import­ance of pre­vent­ing any root dis­turb­ance to trees with­in the adja­cent area. The Officer con­siders that the land­scape scheme is thor­ough with good plant­ing and man­age­ment proposed.

1. CNPA Out­door Access Officer has reviewed the applic­a­tion in rela­tion to dir­ect impacts on the exer­cise of access rights and core paths and is sat­is­fied that there are no dir­ect impacts as a con­sequence of this devel­op­ment. The Officer sup­ports the require­ment for a Vis­it­or Man­age­ment Plan.

2. Nethy Bridge Com­munity Coun­cil fully sup­port the pro­pos­al stat­ing that they feel it will provide a much needed ser­vice in the loc­al com­munity by remov­ing many of the inap­pro­pri­ately parked camper vans which in recent years become all too com­mon around the area. They request the prompt determ­in­a­tion of the scheme so that the devel­op­ment can be up and run­ning in time for next year’s tour­ist sea­son. The Com­munity Council’s full com­ments can be viewed at Appendix 3.

REP­RES­ENT­A­TIONS

1. The applic­a­tion was advert­ised when first sub­mit­ted and a num­ber of pub­lic let­ters of rep­res­ent­a­tion were received fol­low­ing the ori­gin­al con­sulta­tion. Full cop­ies of all let­ters of pub­lic rep­res­ent­a­tions received, can be found at Appendix 4 and a sum­mary of these now follows.

2. Six mem­bers of the pub­lic note their sup­port for the applic­a­tion and make the fol­low­ing observations:

a) Wel­come the applicant’s pro­pos­al to address tour­ism industry issues

b) Pro­pos­al will serve a grow­ing need, espe­cially in response fol­low­ing COV­ID-19 staycations

c) Pro­vi­sion of more short-term stop over facil­it­ies for camper­vans is a vital necessity.

d) Pro­pos­al will help to provide for the 400,000 motor homes in the UK

e) Small scale devel­op­ments around the nation­al park in com­munit­ies like this will help to spread the vis­it­ors without caus­ing over­load in pop­u­lar places.

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Item 7 25/02/2022

f) One mem­ber not­ing sup­port also ref­er­ences that Cam­paign for Real Aires in the UK (CAMPrA) recom­mend a dis­tance of 3m spa­cing between parked motorhomes on pitches.

1. One let­ter has been received from a loc­al res­id­ent provid­ing gen­er­al com­ments on the scheme. The respond­ent appre­ci­ates the need for camper­van pro­vi­sion across the High­land and appre­ci­ate the small scale nature of the devel­op­ment, how­ever they query the pro­pos­al with regards to: poten­tial light pol­lu­tion, poten­tial noise pol­lu­tion, increase traffic flow and more ped­es­tri­ans, and cla­ri­fic­a­tion on oper­at­ing periods.

2. Let­ters of objec­tion have been received from the Badenoch and Strath­spay Con­ser­va­tion Group (BSCG); RSPB and two mem­bers of the pub­lic. Their com­ments are sur­mised below:

a) Impact on caper­cail­lie with the likely increase in dis­turb­ance to the sur­round­ing wood­land habitat;

b) Impact on otter with the likely increase in dis­turb­ance to otter with­in the sur­round­ing area;

c) Impact on badgers and brown hare through the increased disturbance

d) The pro­pos­al would be det­ri­ment­al to the land­scape qual­it­ies of this scen­ic location;

e) Insuf­fi­cient inform­a­tion has been provided to allow the assess­ment of the poten­tial adverse effects on caper­cail­lie as a qual­i­fy­ing fea­ture of Craigmore Wood Spe­cial Pro­tec­tion Area.

f) Inap­pro­pri­ate loc­a­tion due to frag­ment­a­tion of con­nect­ing hab­it­at caused by human disturbance

g) Pro­pos­al does not con­serve and enhance the nat­ur­al her­it­age of the area

h) Con­cern that sur­vey work has not taken place for the east­ern parts of Cul­stank Moss wood­land which lies approx­im­ately 400m west of the pro­posed site.

1. Fol­low­ing these pub­lic com­ments and ori­gin­al con­sulta­tion responses, the applic­ant provided fur­ther inform­a­tion and revi­sions to seek to address con­cerns raised. This inform­a­tion is included in more detail, and described in para­graph 6.

APPRAIS­AL

1. The main plan­ning con­sid­er­a­tions are: the prin­ciple of devel­op­ment; the impact upon land­scape, sit­ing and design; the envir­on­ment­al impacts; amen­ity impacts; access and ser­vi­cing impacts; and developer contributions.

Prin­ciple of Development

1. The Nation­al Park Part­ner­ship Plan (2017) encour­ages the pro­vi­sion of low cost tour­ist accom­mod­a­tion includ­ing motor home and camp­ing sites in suit­able loc­a­tions. Policy 2.2: Tour­ist Accom­mod­a­tion of the Cairngorms Nation­al Park Loc­al Devel­op­ment Plan 2021 per­mits devel­op­ment for tour­ist related accom­mod­a­tion where:

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Item 7 25/02/2022

a) It has no adverse envir­on­ment­al or amen­ity impacts on the site or neigh­bour­ing areas; and

b) It con­trib­utes to/​sup­port the pro­vi­sion of a wider range of vis­it­or accom­mod­a­tion options includ­ing low cost accom­mod­a­tion; and

c) It sup­ports or con­trib­utes to a year-round economy.

1. This applic­a­tion for tour­ism accom­mod­a­tion looks to provide a small scale site for use by tour­ing cara­vans and motorhomes.

2. The applic­ants have sub­mit­ted a busi­ness case for the pro­pos­al not­ing their agri­cul­tur­al back­ground and the diver­si­fic­a­tion into the tour­ist accom­mod­a­tion sec­tor through the sub­mis­sion of this applic­a­tion, to be run along­side the agri­cul­tur­al hold­ing. The doc­u­ment states that the applicant’s recog­nised they could ful­fil a demand for provid­ing camper­van­ning accom­mod­a­tion to meet the growth of camper­van­ning in recent years and help to meet the short­age of overnight stop­ping off places with sup­port­ing facil­it­ies with­in the Cairngorms Nation­al Park. Ref­er­ence is also made to the Cov­id-19 surge in stayc­a­tions and camper­van own­er­ship and sug­gests that this demand will be main­tained with fur­ther growth in this industry. Regard­ing wider eco­nom­ic bene­fits, the cus­tom­ers of the site will util­ise the loc­al tour­ist attrac­tions and businesses.

3. This applic­a­tion looks to provide suit­able motorhome facil­it­ies at a scale appro­pri­ate to its rur­al con­text, and to improve the man­age­ment and ease grow­ing pres­sure from camper­vans with­in the wider area to help meet the con­tin­ued and long estab­lished demand for small scale sites. The Com­munity Coun­cil fully sup­port the pro­pos­al stat­ing that it will provide a much needed ser­vice in the loc­al com­munity by remov­ing many of the inap­pro­pri­ately parked camper vans which in recent years become all too com­mon in the area.

4. On this basis, the prin­ciple is con­sidered to accord with Policy 2: Sup­port­ing Eco­nom­ic Growth of the Cairngorms Nation­al Park Loc­al Devel­op­ment Plan 2021 sub­ject to com­pli­ance with oth­er rel­ev­ant Loc­al Devel­op­ment Plan policies.

Land­scape Impacts, Sit­ing and Design

1. Policy 5: Land­scape of the Cairngorms Nation­al Park Loc­al Devel­op­ment Plan 2021 pre­sumes against devel­op­ment which does not con­serve and enhance the land­scape char­ac­ter and spe­cial qual­it­ies of the Nation­al Park and in par­tic­u­lar the set­ting of the pro­posed development.

2. The pro­posed devel­op­ment site lies with­in the Aber­nethy Forest land­scape char­ac­ter area which is char­ac­ter­ised by a patch­work of moor­land, wood­land and farms/​settlements across a wide basin con­tained by an out­er arc of hills. The site is clearly vis­ible by people trav­el­ling east­wards along the adja­cent C1124 minor road although vis­ib­il­ity from the wider area is lim­ited by sur­round­ing wood­land to the east, north and south and by undu­lat­ing land­form to the west. The CNPA Land­scape Officer con­firms that the pro­pos­al would not cause an adverse impact on the land­scape sub­ject to the mit­ig­a­tion meas­ures being incor­por­ated includ­ing the tree pro­tec­tion meas­ures and imple­ment­a­tion of the sub­mit­ted land­scape plan. The pro­posed mit­ig­a­tion meas­ures as put for­ward by the applic­ant include nat­ive spe­cies shrub

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Item 7 25/02/2022

plant­ing and a small bund on the west­ern site bound­ary to be planted with nat­ive spe­cies shrubs. Although the Land­scape Officer sug­gests a dry-stone dyke along the west­ern bound­ary would be a land­scape enhance­ment, the omis­sion and the use of a planted bund in this loc­a­tion, as put for­ward by the applic­ant, would not res­ult in sig­ni­fic­ant effects on the Nation­al Park.

1. Regard­ing the plant­ing scheme, it is noted that the High­land Coun­cil Forestry Officer recom­mends the plant­ing of nine trees on site, in the interests of amen­ity. The plant­ing plan has been reviewed by the CNPA Land­scape Officer who con­siders that the land­scape scheme is thor­ough with good plant­ing and man­age­ment pro­posed. The pro­pos­al includes no works or remov­al of any trees, which would require com­pens­a­tion, and the visu­al impact of the pro­pos­al is judged to be sat­is­fact­ory based on the inform­a­tion provided. Although addi­tion­al tree plant­ing is always wel­comed, it would appear unreas­on­able to request the addi­tion­al tree plant­ing when the scheme as presen­ted has been judged to meet policy require­ments in terms of its biod­iversity enhance­ments and visu­al impacts.

2. The pro­pos­al includes lim­ited per­man­ent infra­struc­ture to help reduce its visu­al impact, and addi­tion­al veget­ated screen­ing is pro­posed on site. The loc­a­tion of the pro­pos­al is con­sidered to be dis­tinct­ive cre­at­ing a pleas­ant envir­on­ment due to the low dens­ity of the devel­op­ment and spa­cing of the pitches. A plan­ning con­di­tion is recom­men­ded to lim­it the num­ber of pitches on site to twelve pitches to ensure that any future changes in site dens­ity can be fully reviewed to assess impacts.

3. No trees are to be felled for the pro­pos­al and cara­van stances and water treat­ment area are all installed out­with the root pro­tec­tion area and can­opy of the trees. In addi­tion, the applic­ant has con­firmed that elec­tri­city cables and water pipes would be con­struc­ted out­with the root pro­tec­tion areas. A plan­ning con­di­tion is recom­men­ded to ensure root pro­tec­tion areas are installed on site pri­or to works commencing.

4. The devel­op­ment com­pon­ents would not intro­duce any not­able det­ri­ment­al change to the char­ac­ter of the site and imme­di­ate area, and sub­ject to the con­di­tions being included, the pro­pos­al is con­sidered to com­ply with Policy 5: Land­scape of the Cairngorms Nation­al Park Loc­al Devel­op­ment Plan 2021.

Envir­on­ment­al Impacts

1. Policy 4: Nat­ur­al Her­it­age of the Cairngorms Nation­al Park Loc­al Devel­op­ment Plan 2021 seeks to ensure that there is no adverse impact upon des­ig­nated areas, pro­tec­ted spe­cies or biod­iversity whilst Policy 10: Resources sets out the need to fully con­sider impacts on flood­ing and water resources. A num­ber of pub­lic rep­res­ent­at­ives raise con­cern regard­ing the proposal’s impact on the eco­lo­gic­al interests of the area and the qual­i­fy­ing interests of the European Sites, due to the poten­tial recre­ation­al pat­terns of the occu­pants of the cara­van site.

2. A Hab­it­ats Reg­u­la­tions Apprais­al has been under­taken (Appendix 2) regard­ing the proposal’s impacts on the des­ig­nated sites of the River Dee SAC and the Craigmore Wood SPA, which con­cludes that sub­ject to the mit­ig­a­tion meas­ures being imple­men­ted as out­lined with­in the Apprais­al, there would be no likely sig­ni­fic­ant effect

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Item 7 25/02/2022

on the qual­i­fy­ing interests. Regard­ing the altern­at­ive fenced route, the plans have been amended to indic­ate the inclu­sion of this around the peri­met­er of the field with­in the same own­er­ship. Plan­ning con­di­tions are recom­men­ded to ensure the mit­ig­a­tion meas­ures are car­ried out in full and there should there­fore not be sig­ni­fic­ant addi­tion­al dis­turb­ance to caper­cail­lie over and above what is already occur­ring through use of the exist­ing tracks and access points to the north of the pub­lic road.

1. Regard­ing pro­tec­ted spe­cies and hab­it­ats, the CNPA Eco­logy Officer has con­firmed that suf­fi­cient sur­vey work has been sub­mit­ted to determ­ine the applic­a­tion and the Officer has no objec­tions to the scheme sub­ject to the inclu­sion of plan­ning con­di­tions to ensure vis­it­or man­age­ment meas­ures are imple­men­ted and a pre-com­mence­ment walkover sur­vey is under­taken. On this basis, the pro­pos­al would not have a neg­at­ive impact on any pro­tec­ted spe­cies or hab­it­ats in or around the site.

2. The tree pro­tec­tion meas­ures and reten­tion is wel­comed, togeth­er with the biod­iversity enhance­ment of the plant­ing of an addi­tion­al nat­ive shrubs and wild­flower seed mixes to enhance the eco­lo­gic­al interests of the site. On this basis the pro­pos­al is con­sidered to accord with Policy 4: Nat­ur­al Her­it­age of the Cairngorms Nation­al Park Loc­al Devel­op­ment Plan 2021.

3. Regard­ing oth­er envir­on­ment­al mat­ters, it is con­firmed that the site is not at risk of flood­ing from any source, and the High­land Coun­cil Flood Risk Man­age­ment Team raise no objec­tions on flood grounds. The High­land Coun­cil Con­tam­in­ated Land Officer has no com­ment on the applic­a­tion not­ing that there is no indic­a­tion of any past use of the site which may have caused con­tam­in­a­tion. The pro­pos­al is there­fore con­sidered to com­ply with Policy 10: Resources of the Cairngorms Nation­al Park Loc­al Devel­op­ment Plan 2021.

Ser­vi­cing

1. Policy 3: Design and Place­mak­ing of the Cairngorms Nation­al Park Loc­al Devel­op­ment Plan 2021 sets out the need for new devel­op­ment to be sat­is­fact­or­ily ser­viced and without harm to resources or the environment.

2. It is noted that the pro­pos­al is for use by camper­van which have their own toi­let facil­it­ies and the dis­pos­al of waste from them is a key issue in rur­al areas. Waste water is to be dis­posed of to a sealed tank which would be reg­u­larly emp­tied and removed for off­s­ite dis­pos­al. The High­land Coun­cil Flood Risk Man­age­ment Team have no objec­tion to the drain­age meas­ures and an inform­at­ive is recom­men­ded to high­light that the drain­age arrange­ment would be sub­ject to SEPA licens­ing. All cara­van pitches are pro­posed to be sur­faced with a per­meable sur­face and a plan­ning con­di­tion is pro­posed to be attached to any sub­sequent decision notice to ensure that any changes to sur­fa­cing which may require addi­tion­al drain­age arrange­ments is pri­or agreed by the Plan­ning Author­ity. The drain­age pro­pos­als are con­sidered to be accept­able on this basis.

3. There is no pub­lic water sup­ply with­in the area and the pro­pos­al will there­fore be ser­viced by util­ising an exist­ing private water sup­ply which cur­rently serves the agri­cul­tur­al hold­ing and will also serve the asso­ci­ated dwell­ing, once erec­ted. The High­land Coun­cil Envir­on­ment­al Health Officer has reviewed the water supply

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Item 7 25/02/2022

inform­a­tion and con­firms that the water flow rate of 55m³ per day is con­sidered to be more than suf­fi­cient for the size of the pro­posed devel­op­ment. The pro­posed water sup­ply is con­sidered to be suf­fi­cient in terms of qual­ity and quant­ity to meet the needs of the pro­pos­al and the exist­ing needs of the agri­cul­tur­al dwell­ing and build­ing, and will be sub­ject to a man­dat­ory mon­it­or­ing régime.

1. Regard­ing site licens­ing, the Coun­cil has con­firmed that a Cara­van Site License would be required to be applied for through the Coun­cil and the devel­op­ment would be required to be oper­ated in accord­ance with the restric­tions imposed on that licence.

2. On this over­all basis the pro­pos­al is con­sidered to com­ply with Policy 3: Design and Place­mak­ing of the Cairngorms Nation­al Park Loc­al Devel­op­ment Plan 2021 with regards to its servicing.

Access

1. **Policy 3: Design and Plac