Item7Appendix3aObjectionsInshcraig20230300PPP
Cairngorms Item 7 Appendix 3a 26 January 2024 National Park Authority Ùghdarras Pàirc Nàiseanta a’ Mhonaidh Ruaidh
Agenda item 7
Appendix 3a
2023/0300/PPP
Representations — objections
Emma Greenlees From: Sent: To: Cc: Subject: Categories: Gavin Miles 21 June 2023 12:45 Murray Ferguson; Emma Bryce; Planning RE: Proposed Community Housing Project — Cathryn Williamson. Balnespick Farm Comments, Emma G
We haven’t yet been notified of the application by Highland Council and can’t yet see it on their website.
Once we have been notified of it we’ll be able to look at it and decide whether it meets the criteria for the Park Authority to call in and determine (which is likely if it is for 5 houses).
Highland Council have a 21-day period for public comments from the date an application is registered as valid with them and we have a period of 28 days for public comments to us from the day we call an application in. We can hold your comment and apply it to the application if we are notified of it and call it in.
Kind regards
Gavin
Gavin Miles (he/him) Head of Strategic Planning T: 01479 870 565 | M: 07850 644 079 E: gavinmiles@cairngorms.co.uk
Cairngorms National Park Authority / Ùghdarras Pàirc Nàiseanta a’ Mhonaidh Ruaidh 14 The Square | Grantown on Spey | PH26 3HG +44 (0) 1479 873 535 | cairngorms.co.uk
Read our plan for the future: cairngorms.co.uk/PartnershipPlan flexibilityworks EMPLOYER AWARDS TOP 10
Sent: Tuesday, June 20, 2023 5:21 PM To: Murray Ferguson MurrayFerguson@cairngorms.co.uk; Fiona McInally fionamcinally@cairngorms.co.uk; Gavin Miles GavinMiles@cairngorms.co.uk; katiecrerar@cairngorm.co.uk; Dan Harris DanHarris@cairngorms.co.uk; Stephanie Wade stephaniewade@cairngorms.co.uk Cc: Kirsty Partridge kirstypartridge@cairngorms.co.uk; Emma Bryce emmabryce@cairngorms.co.uk; Liz Henderson LizHenderson@cairngorms.co.uk; Sarah Fletcher sarahfletcher@cairngorms.co.uk Subject: Proposed Community Housing Project — Cathryn Williamson. Balnespick Farm 1
Dear CNPA Planning
Proposed development of 5 houses by Catheryn Williamson, Balnespick Farm on land south east of B970,
Grid Reference 836035, Northing & Easting 57.108 ‑3.925.
It has come to my attention that Cathryn Williamson, Balnespick Farm is proposing a housing development. I have a number of objections and concerns.
Access to this development is along a track off the Glenfeshie road. Currently the track is access for Inshcraig, farm equipment and livestock also use the access to the fields south of the B970.
The proposed development offers to increase the bellmouth size to 5082mm. The Glenfeshie road is single track and the ‘new’ bellmouth would not offer an adequate service bay.
The plan states that the access track is to be upgraded but appears to still be a track. The SE side of the track is wetland/bog. With the increased use, I’m concerned that a track would not be robust enough for access to six houses. I also have the concern that during the construction of the track upgrade, the access to Inshcraig will be hampered.
The plan only offers one passing place on the track. There is no active travel route on the plan. The illustrated track width is inadequate for a bicycle and car to pass safely and because of the wetland/bog running alongside there is not an opportunity for a pram user to ‘step off’ the track to allow a vehicle to pass safely.
The area is ‘High risk’ from Surface water flooding (SEPA flood map. PH21 1NU. Inshcraig) and the track has flooded in past years.
The visibility splays are not large enough. There are mature trees on the boundary of Insh house. There are trees and bushes to the northeast of the proposed bellmouth.
The pylon electricity line was put underground through the proposed development field. It’s possible to see the line on the google map satellite image. This precludes the planting of screening trees and shrubs within the proximity of the high voltage cable.
The immediate area around the proposed development site is wetland/bog with a number of ‘risers’ in the adjacent field to the south east. This coupled with the pond area to the north west would have problems for natural septic tank drainage. Large and heavy vehicles would regularly access the track to empty the septic tanks.
The proposed development is not within a settlement. Housing in this field would encourage further linear development along the B970
The CNPA park partnership plan is for 85% of current houses to be full time residential with 15% being holiday lets or second homes. This policy means that a number of properties in the Kincraig area will become available of purchase or rental. I’m unsure that there is a future need for additional housing outwith the current park plans.
Thank you for your attention in this matter. I hope that you will take my objections into account while considering the development proposal.
Yours 2
3
Emma Greenlees From: Sent: To: Cc: Gavin Miles 21 June 2023 12:46 Murray Ferguson; Emma Bryce; Planning Subject: RE: Proposed development Categories: Comments, Emma G
We haven’t yet been notified of the application by Highland Council and can’t yet see it on their website.
Once we have been notified of it we’ll be able to look at it and decide whether it meets the criteria for the Park Authority to call in and determine (which is likely if it is for 5 houses).
Highland Council have a 21-day period for public comments from the date an application is registered as valid with them and we have a period of 28 days for public comments to us from the day we call an application in. We can hold your comment and apply it to the application if we are notified of it and call it in.
Kind regards
Gavin
Gavin Miles (he/him) Head of Strategic Planning T: 01479 870565 | M: 07850 644 079 E: gavinmiles@cairngorms.co.uk
Cairngorms National Park Authority / Ùghdarras Pàirc Nàiseanta a’ Mhonaidh Ruaidh 14 The Square | Grantown on Spey | PH26 3HG +44 (0) 1479 873 535 | cairngorms.co.uk
Read our plan for the future: cairngorms.co.uk/PartnershipPlan flexibilityworks EMPLOYER AWARDS TOP 10
Sent: Tuesday, June 20, 2023 10:06 PM To: Murray Ferguson MurrayFerguson@cairngorms.co.uk; Gavin Miles GavinMiles@cairngorms.co.uk; Fiona McInally fionamcinally@cairngorms.co.uk; Kirsty Partridge kirstypartridge@cairngorms.co.uk; Dan Harris DanHarris@cairngorms.co.uk; Katie Crerar KatieCrerar@cairngorms.co.uk; Emma Bryce emmabryce@cairngorms.co.uk; Liz Henderson LizHenderson@cairngorms.co.uk Subject: Fwd: Proposed development 1
Subject: Community Housing Project Kincraig
Dear National Park Planners.
Community Housing Project, Kincraig — Cathryn Williamson. Five houses I’m the owner of This is the property that will be most affected by this development, and once this precedent has been set, any other developments in neighbouring fields.
The access track, which has up until now just been used to move cattle, is right outside one of Inshcraig’s living room windows, the kitchen window looks directly down the track. Any development using the track for access would be an invasion of privacy.
There have been a couple of issues with the track in recent years. In 2016⁄17 the culvert at the end of track failed and there was significant flooding of the track and Glenfeshie Road. It took months of emails and phone call to get Highland Council to remedy the situation. At the time Balnespick estate were little help with this.
Over the years all the track maintaince has been paid for by me. I had two lorry loads of hardcore to raise the track to reduce the flood risk. If there is to be a development – who will be responsible for the track maintaince in future years? It frequently seems that once the developer has finished there is no budget for future repairs.
In the winter the track gets snow covered. The track won’t be an adopted road, so the council snowplough will not clear this. One stuck car would lead to the blocking of the whole track. Because of the bog running down the side of the track there is no option for another vehicle to squeeze past.
If this development were to proceed would it still be a farm track or would the cattle have to be moved along the B970 to get to the grazing?
The field and the surrounding wetland offer an abundance of habitat for various wildlife. The development and subsequent activity would have a dramatic effect on this and lead to a decline of our precious open space and wetland habitat.
After the track diverges at the entrance to Inshcraig the track to the field (proposed development site) floods to throughout the winter and water sits on this section of track over the winter months. My concern is if this is upgraded – where does this water go. There seems to be no additional drains on the plans that I have seen.
At the moment the track going past Inshcraig to the development field is a natural soakaway.
The bottom line is where does the water go in the winter.
Five houses would lead to desire line paths from the houses to the B970. These illicit tails defy planners. Over the years they would become established routes and make the area have a more urban feel.
I hope that the national park will take account of my objections when considering the development at your next meeting.
Yours truly, 2
3
Comments for Planning Application 2023/0300/PPP
Application Summary Application Number: 2023/0300/PPP Address: Land 80M SW Of Inshcraig Insh Kingussie PH21 1NU Proposal: Development of three affordable houses Case Officer: Emma Bryce
Customer Details
Comment Details Commenter Type: Neighbour Stance: Customer objects to the Planning Application Comment Reasons: Comment:Having lived in the CNP since its inception, we wish to object to the above planning application on the following points:
a) The CNP Local Plan states that housing should be within the existing settlements and not new developments. There are still ongoing developments within Kincraig, which would seem preferable to greenfield sites/agricultural land as there is public transport and a primary school available and a Community Centre. Within the Kincraig boundary there is a brownfield site identified. b) The proposed development of 3 houses is adjacent to a rural group of 4 existing properties. However, the Local plan Appendix 2 Item 9 (24÷06÷22) states in the final paragraph of the section Housing development in existing rural groups that new development must not cause a group to increase in size by more than one third during the LDP period. This therefore precludes a development of 3 houses and if fact only one would be possible. c) Affordable housing is classified as semi-detached or terraced property as evidenced by that constructed within Kincraig. Therefore, the proposed detached properties in large plots does not seem to conform with that requirement and there is no specific need being shown. d) The construction on this agricultural site would adversely affect the biodiversity as well as personally cause us loss of amenity — being a loss of our only unimpeded views of the mountains. e) Any planting of trees would have to take into consideration the presence of underground high voltage power lines which run through the site and their existence might have future health implications on any overhead properties. f) The area around the track and the Glenfeshie road has been subject to flooding over the years.
We have no objection per se to the construction of affordable housing within the village boundary as per the CNP Local Plan but we do strongly oppose building on agricultural land and the precedent it sets.
Comments for Planning Application 2023/0300/PPP
Application Summary Application Number: 2023/0300/PPP Address: Land 80M SW Of Inshcraig Insh Kingussie PH21 1NU Proposal: Development of three affordable houses Case Officer: Emma Bryce
Customer Details
Comment Details Commenter Type: Neighbour Stance: Customer objects to the Planning Application Comment Reasons: Comment:I wish to object to planning application ref 2023/0300/PPP on the following grounds. 1) It is contrary to the CNPA Local Plan. It is a new isolated development with no relation to the existing adjacent settlements. 2) Access to this site will need an upgraded road & bell mouths that would adversely impact on the existing wetland to the rear of Insh House. 3) Drainage from the proposed site would also damage the existing wild wetland unless a containment sewage works was built. That would necessitate regular Council emptying which would require an upgraded & adopted road capable of supporting heavy lorries. 4) There are many High Voltage cables under this site & the remains of the foundations of a pylon. This would cause considerable additional groundworks & extra disruption to the rural, wetland habitat.
I would add that there are some misleading errors in the design statement attached to the application. There are 5 houses on the “Insh House” site not 4, as stated. Insh House, Glebe house, Telford cottage, Fraser cottage & Inshcraig. Telford & Fraser cottages were purpose built, semi- detached, self catering cottages newly constructed in 1989 on virgin ground & are not a redevelopment of existing outhouses.
It says in the design statement that the site is disused farmland. To my certain knowledge this site has been in constant use for over 40 years for grazing cattle, sheep & horses.
The site is not “tucked behind Insh House” it is in Moorfield which is 100m to the south of Insh House.
The description of adjacent small settlements has been distorted. It does not give an accurate
account of the real situation. The “Insh House” settlement is to the north & has no connection to the development. The settlement to the west is 4 in no. on the old Sawmill site. The 5th house described in this group called Druimuachdar, is part of a group of 4 houses spread along the access track to Moorfield & cottage.
Comments for Planning Application 2023/0300/PPP Application Summary Application Number: 2023/0300/PPP Address: Land 80M SW Of Inshcraig Insh Kingussie PH21 1NU Proposal: Development of three affordable houses Case Officer: Emma Bryce
Customer Details
Comment Details Commenter Type: Neighbour Stance: Customer objects to the Planning Application Comment Reasons: Comment:I wish to object to planning application ref 2023/0300/PPP We are the oldest residents in the vicinity. We bought Insh House in 1984 to run as a Guesthouse. Only Insh House, Inshcraig & Moor cottage existed at that time. In 1989 we purpose built Telford & Fraser cottages for holiday letting, which we still operate today. The 4 houses on The Old Sawmill site & the 3 houses on Moor cottage track were all built before the advent of the CNPA. In 2008 we were granted permission by the CNPA to build Glebe House for our retirement, on the grounds it would be the 5th property in the settlement. We matched all the stone gable ends to suit Insh House. The design statement is very misleading & incorrect on the nature of the settlements in the vicinity of Insh House. Re: The CNPA local plan for “Housing development in rural building groups” I wish to highlight Policy 21. Section 5.1 also states ‘must not add more than one third to the group’. The application is totally contrary to this. It is not part of a group & if it was, would certainly add more than one third. It is a new development and there is no good reason to attach it to the Insh House group. There is no particular requirement for Affordable Housing in this vicinity. There are no amenities & no public transport on the B970. There is room for expansion in Kincraig village & land suitable for Affordable Housing. Much has been said about the access track being substandard but consideration should also be given to Insh House corner, a 90 degree bend, on the B970. The only straight on this road runs from Insh House to Druimuachdar & I feel there is already an accident waiting to happen with some of the speeds drivers manage to achieve. Granting planning permission for this scheme would set a precedent for Moorfield. This is agricultural land. If it is no longer of use for that purpose, if anything, it should be rewilded.
Comments for Planning Application 2023/0300/PPP Application Summary Application Number: 2023/0300/PPP Address: Land 80M SW Of Inshcraig Insh Kingussie PH21 1NU Proposal: Development of three affordable houses Case Officer: Emma Bryce
Customer Details
Comment Details Commenter Type: Neighbour Stance: Customer objects to the Planning Application Comment Reasons: Comment:While we support the principle of affordable housing in the Kincraig area, we are not sure that this site is appropriate for the development.
This would establish a new settlement completely separate from existing settlements. If allowed would this permit extensions to this new settlement?
The site would result in loss of agricultural land.
A number of high voltage underground cables cross the development site. We would be concerned about how radiation from the high voltage could affect implanted medical devices (eg pacemakers) and the incidence of childhood leukaemia for those living over the cables in the longer term.
Access to the site is by a rough narrow track running alongside a bog. At present the track is used for agricultural purposes and as the main access for one house. The track would require upgrading and widening into the wetland to accommodate the increase in traffic. There would be a resultant loss of habitat. The track has flooded in the recent past.
Access from the track onto the narrow but busy Glenfeshie road would necessitate the development of a bell mouth incorporating a hard standing for bins and service vehicles. This would encroach into the wetland with further loss of habitat. The sightline to the left when exiting onto the public road could result in the unnecessary destruction of a mature hawthorn tree. The junction of the Glenfeshie road with the B970 would require assessment due to the increase in traffic. There have been a number of accidents over the years due to drivers speeding and
failing to take the corner.
Nature Scot Loch Insh holds SSSI, SAC, SPA, NNR and RAMSAR Wetlands of National Importance status. (as per attached map). The River Spey holds SSSI status. The development will be built near an area which drains into the loch. With the National Park wishing to re-introduce species such as Wildcats, Beavers, Cranes etc near to the loch, I would suggest a full environmental report was carried out at the site to ensure that no impact is made to the Loch and the current species which reside therein, I would also urge a full invertebrate survey to be a key element of the report. NatureScot NàdarAlba SiteLink Map About A9 B9152 B970 Map Search Farr h Insh or Centre Layers D E D Q Sites of Special Scientific Interest Special_Areas_of_Conservatio n Special Protection Areas RAMSAR Wetlands of International Importance Geological Conservation Review Sites National Nature Reserves Local Nature Reserves Demonstration and Research MPAS Marine Protected Areas X Esri, Intermap, NASA, NGA, USGS | Esri Community Maps Contributors, Esri UK, Esri, HERE, Garmin, Foursquare, GeoTechnologies, Inc, METI/NASA, USGS | SNH, Contains Ordnance S… Powered by Esri The entrance track to the proposed development is wet, often lying under water for weeks at a time, especially during winter, and will require ground works to provide year-round access. Any drainage works, (drains in blue on map above) other than significantly raising ground levels to elevate the access are likely to affect a greater area of wetness than just the access track and further impact on local biodiversity, amphibians in particular, especially newts. SSEN — Underground Cables EUser Guide AAA Insh Marshes National Nature 8970 River Sty Start Again View as a List Feshwbridge Explore our Social Useful Links Policies/Notices C OpenStreetMap cor Emergency Conta
Only recently did the CNP negotiate a mitigation clause to remove overhead pylon lines across the proposed development, to accommodate power distribution works undertaken elsewhere within the National Park. These high voltage cables were buried in the vicinity of the proposed development and to relocate these cables will be, perhaps, cost prohibitive and cause further damage to the local environment (see map of underground cables above). To reroute these cables would mean an expense that would no longer see any build here as being affordable. Have SSEN been asked to comment on this application? If not, then they should be approached to ascertain whether the development would require a reroute of cables and an indicative cost to determine whether this would “affordable”.
SSEN also require full continuous access to the area in case there is any problems with the underground cables and as such, no planting of trees or hedges is permitted “SCHEDULE 3 GRANTOR’S COVENANTS 1. The Grantor shall not make any alteration to the Easement Strip, nor plant any tree or shrub or erect any structure on or over the Easement Strip, other than with the prior written consent (not to be unreasonably withheld) and under the supervision of the Grantee.” Flooding — Sepa Website SEPA Flood Maps Basic Map Viewer 440 40 Search location Old Farr Sawn 8970 8970 House Inespick 250m … Find address or place Flood Map Data Layer List Layers ✔Flood Maps River Flooding ✔High Likelihood ✔Medium Likelihood ✔Low Likelihood Surface Water Flooding High Likelihood ✔Medium Likelihood Legend Low Likelihood Flood Maps Surface Water Flooding High Likelihood Each year this area has a 10% c of flooding Medium Likelihood Each year this area has a 0.5% c of flooding 12023108 100016001 C As you can see from the SEPA map above, the area is prone to flooding as is the drain area which is used as a means to try to control water in the area. The water from this drain flows into Loch Insh. Any development must ensure there is no contamination to this area both during and after development. Application The application was originally for 5 houses, but this has now dropped to three houses. The size of the plots for the houses would indicate that the houses would be of a large size, no actual plans of the houses have been submitted. It would be good to know that the houses ALL were restricted to be sold to people currently residing in rented accommodation within the National Park Area and not sold to people who currently reside outside the National Park Area. I would like to know if this is to circumvent the CPNA Local Development Plan 2021 Policy 1. 1.5 Affordable housing Developments consisting of four or more dwellings should include provision for affordable housing amounting to: a) 45% of the total number of dwellings on the development site in the settlements of Aviemore, Ballater, Blair Atholl and Braemar; b) 25% of the total number of dwellings on the development site in all other areas of the National Park. Proposals for fewer than four market dwellings will also be required to make a contribution towards affordable housing. This will be a monetary payment towards meeting housing need in the local community. Developers seeking to negotiate a reduction in affordable housing provision must demonstrate through a Viability Assessment that the requirements make an otherwise commercially viable proposal unviable.
The application also says it has the backing of the Community Council. This is not true. The community council minutes specifically say “4.6- Community Housing Project Balnespick. Noted to be in green field site outwith the
Community Plan. KVCC support Community housing projects in general but more information is needed before we can support this project.” Ms Williamson does not own the track into this area, and as such she would require the permission of the owner. A search of the ROS/ sasine register to ensure the owner is aware of the proposal. Ms Williamson is to be applauded for wishing to help with affordable housing in the area, however I do not believe this is the best place for the housing development.