Item8Appendix3CommunityCouncilComments20210143DET

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 8 Appendix 3 25/06/2021

AGENDA ITEM 8

APPENDIX 3

2021/0143/DET

COM­MUNITY COUN­CIL COMMENTS

Mid Deeside Com­munity Coun­cil c/​o Vic­tory Hall Bal­later Road Aboyne AB34 5HY middeesidecommunitycouncil@​gmail.​com

Alan Atkins Plan­ning Sup­port Team Cairngorms Nation­al Park Author­ity 14 The Square Grant­own-on-Spey Moray PH26 3HG

Ref: 2021/0035/DET Case Officer: Alan Atkins

By email to planning@​cairngorms.​co.​uk

6 June 2021

Dear Mr Atkins,

Re:	Mid Deeside CC Con­sulta­tion Request
Applic­a­tion Number:	2021/0143/DET
Devel­op­ment Proposed:	Tem­por­ary Change of Use of Farm­yard to Form Car Park and Asso­ci­ated Toi­let and Refuse Facilities
Loc­a­tion:	Land at Clarack, Din­net, Aboyne, Aberdeenshire

We write fur­ther to your let­ter of 10 May 2021 ask­ing wheth­er Mid Deeside Com­munity Coun­cil (MDCC) would like to respond to the above proposal.

MDCC has the fol­low­ing com­ments on behalf of the com­munity that we serve. Whilst we are broadly sup­port­ive of the inten­tions behind the pro­pos­al, we do have some con­cerns which we believe need to be addressed.

By way of back­ground, both the applic­a­tion site and the Muir of Din­net Nature Reserve are with­in the bound­ary of MDCC’s catch­ment area. Vis­it­ors are drawn to the Muir of Din­net Nature Reserve for vari­ous reas­ons, includ­ing walk­ing, to see the rare and pro­tec­ted spe­cies of birds or, increas­ingly, for recre­ation­al water sports on Loch Kinord. All vis­it­ors also con­trib­ute to our loc­al tour­ist eco­nomy. How­ever, these are poten­tially con­flict­ing interests which need to be balanced.

In sup­port of the applic­a­tion, we are aware that last year there were impacts on the Muir of Din­net Nature Reserve from high vis­it­or num­bers, includ­ing through park­ing on verges and wild camp­ing around Loch Kinord. Insuf­fi­cient form­al toi­let facil­it­ies for the num­ber of vis­it­ors also res­ul­ted in anti­so­cial beha­viours around the Loch. Hav­ing atten­ded a meet­ing held by NatureScot on 11 May 2021 regard­ing the det­ri­ment­al impact of high vis­it­or num­bers and, in par­tic­u­lar, the increased use of Loch Kinord for water sports such as paddle-board­ing, we 1

appre­ci­ate that, if vis­it­ors to the Loch can be encour­aged to park in one place, then dam­age to the Nature Reserve could poten­tially be lim­ited through con­trolling routes of access and improv­ing the abil­ity to mes­sage vis­it­ors about appro­pri­ate use of the area. The pro­vi­sion of pub­lic toi­let facil­it­ies may also reduce anti­so­cial beha­viours. We there­fore appre­ci­ate the poten­tial for the pro­posed devel­op­ment to alle­vi­ate pres­sure on the Nature Reserve by provid­ing form­al park­ing and toi­let­ing facilities.

How­ever, we are con­cerned that, in provid­ing an extra 70 spaces for park­ing, there is the poten­tial for the exist­ing prob­lem to be exacer­bated rather than improved if meas­ures are not taken sim­ul­tan­eously to ensure that a sim­il­ar num­ber of cars that cur­rently park else­where to access the Loch are pre­ven­ted from doing so. Hav­ing met with the Factor of the Din­net Estate on 18 May 2021, which was a very help­ful meet­ing, we are aware that the Din­net Estate intends to restrict park­ing else­where around Loch Kinord to encour­age users to park at the Clarack facil­ity. This includes block­ing off the New Kinord car park, accessed from the road to Ordie, where there is cur­rently space for approx­im­ately 15 cars. How­ever, such meas­ures are not included as part of this plan­ning applic­a­tion. We are also con­cerned that there may be poten­tial for more than 70 cars to park at Clarack if they are allowed entry into the Stead­ing area and are able to find space to park out­with the form­al park­ing bays. We under­stand that a small daily fee will be charged to help to pay for the facil­it­ies, which is sim­il­ar to fees charged for park­ing and toi­let facil­it­ies else­where in the Nation­al Park. Many users who will be happy to pay this fee, but there may be some who decide that they would rather park else­where. Once future plans for the devel­op­ment of the Clarack Stead­ing are pro­gressed, the addi­tion­al park­ing spaces will be serving vis­it­ors to the new facil­it­ies; how­ever, in the mean­time, they will only be serving vis­it­ors to the Nature Reserve and Loch.

We are there­fore con­cerned that the pro­posed applic­a­tion could have the unin­ten­ded con­sequence of poten­tially exacer­bat­ing the cur­rent impacts that high vis­it­or num­bers are hav­ing on the Muir of Din­net Nature Reserve. Bear­ing in mind what we have been told by NatureScot, namely that ​“urgent action is needed to reduce dis­turb­ance” in order to ​“avoid a cata­stroph­ic fail­ure of bird breed­ing on Loch Kinord this year”, this is of con­cern to us. This is par­tic­u­larly because NatureScot have said that, although guid­ance is cur­rently in place regard­ing access to the Muir of Din­net and, in par­tic­u­lar, Loch Kinord, ​“even if exist­ing guid­ance is fol­lowed, the num­ber of users now tak­ing access onto to the Loch means that even if indi­vidu­ally every­one fol­lows the guid­ance and behaves respons­ibly, unac­cept­able levels of dis­turb­ance are still very likely due to the rel­at­ively small size of the loch.” (See NatureScot’s ​“Water access at Loch Kinord – Muir of Din­net Nation­al Nature Reserve Com­munity & stake­hold­er notice – April 2021”.) It is in everyone’s interests to ensure that the loss of pro­tec­ted spe­cies from the Muir of Din­net Nature Reserve is avoided.

We there­fore think that it would be help­ful if plan­ning applic­a­tions such as this were part of an over­arch­ing strategy to man­age vis­it­ors at the Loch, into which each of the parties with an interest in the Loch (for example the Din­net Estate, NatureScot, the Cairngorms Nation­al Park, MDCC, the SCA and rep­res­ent­at­ives of users of the Loch) have con­trib­uted. Such a strategy may, for example, identi­fy suit­able meas­ures to lim­it num­bers of people access­ing the Loch or per­haps the types of pur­suits that are accept­able, wheth­er on a sea­son­al basis or all year round. In the absence of such a strategy, there is a risk that actions taken by an 2

indi­vidu­al party, albeit with good inten­tions, may have unin­ten­ded con­sequences. We under­stand that NatureScot is review­ing the res­ults of its pub­lic con­sulta­tion held earli­er this year which may provide the found­a­tion for such a strategy, wheth­er led by them or by anoth­er stakeholder.

In the mean­time, we ask that any approv­al of this applic­a­tion should only fol­low the pre­par­a­tion of an impact assess­ment under­taken by the applic­ant which demon­strates that the pro­pos­al will not increase but prefer­ably reduce the over­all impact of vis­it­ors to the Loch. We also believe that any per­mis­sion gran­ted should be sub­ject to ongo­ing mon­it­or­ing of vis­it­or num­bers using the facil­ity, and any res­ult­ing impact on the Loch, to ensure that use of the car park does not increase pres­sure on breed­ing birds or on the Nature Reserve as a whole. The CNPA should also have the abil­ity to require that the use of the addi­tion­al park­ing provided at the Clarack Stead­ing must cease, or be reduced, if any impact on the Nature Reserve arising from its use is con­sidered unsustainable.

Please let us know if you have any ques­tions or would like fur­ther clarification.

Kindly acknow­ledge safe receipt.

Yours sin­cerely,

Fiona Saw­yer Plan­ning Lead, MDCC For and on behalf of Mid Deeside Com­munity Coun­cil 3

4