Policy Monitoring Topic Paper - Engagement version
Cairngorms National Park Authority Ughdarras Pàirc Nàiseanta a’ Mhonaidh Ruaidh
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Topic: Local Development Plan 2021 – policy monitoring
Engagement version – September 2025
Requirements addressed in this section
Table 1 Information required by the Town and Country Planning (Scotland) Act 1997, as amended, regarding the issue addressed in this section.
| Section | Requirement |
|---|---|
| Section 16(1) | A planning authority are, as soon as practicable after the coming into force of section 2 of the Planning Act and thereafter (i) whenever required to do so by the Scottish Ministers, or (ii) subject to sub-paragraph (i), at intervals of no more than 10 years, to prepare local development plans for all parts of their district, and to keep under review the plans so prepared. |
| Section 264A | In the exercise, with respect to any land in a National Park, of any power under the planning Acts, special attention shall be paid to the desirability of exercising the power consistently with the adopted National Park Plan. |
Links to evidence
- National Planning Framework 4
https://www.gov.scot/publications/national-planning-framework‑4/documents/ - Local Development Planning Guidance 2023
https://www.gov.scot/publications/local-development-planning-guidance/documents/ - Cairngorms National Park Partnership Plan 2022 – 2027
https://cairngorms.co.uk/uploads/documents/Local-Development-Plan-Evidence-Report/Supporting-Documents/CNPA010-Cairngorms-National-Park-Partnership-Plan-2022-\_2027.pdf
Cairngorms National Park Authority Ughdarras Pàirc Nàiseanta a’ Mhonaidh Ruaidh
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- Cairngorms National Park Partnership Plan 2017 – 2022
https://cairngorms.co.uk/uploads/documents/Local-Development-Plan-Evidence-Report/Supporting-Documents/CNPA332-CD002-Cairngorms-National-Park-Partnership-Plan-2017.pdf - National Park Partnership Plan Annual Update 2024
https://cairngorms.co.uk/uploads/documents/240913Paper2NPPPAnnualUpdate.pdf - Cairngorms National Park Local Development Plan 2021
https://cairngorms.co.uk/planning-development/ldp-2021/ - Cairngorms National Park Local Development Plan 2021 – Delivery Programme 2025
https://cairngorms.co.uk/uploads/documents/Local-Development-Plan-Evidence-Report/Supporting-Documents/CNPA334-Delivery-Programme-2025-final.pdf - Cairngorms National Park Employment Land Audit 2025
https://cairngorms.co.uk/uploads/documents/Local-Development-Plan-Evidence-Report/Supporting-Documents/CNPA335-Cairngorms-National-Park-Employment-Land-Audit-2025.pdf
Cairngorms National Park Authority Ughdarras Pàirc Nàiseanta a’ Mhonaidh Ruaidh
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Summary of evidence
Policy context
National Planning Framework 4
National Planning Framework 4 came into force in February 2023 and is the long-term National Spatial Strategy for Scotland. For the first time it contains a set of planning policies that form part of the statutory development plan.
Local Development Planning Guidance 2023
Paragraph 93 of the guidance advises that, as part of the preparation of the evidence report, the planning authority should:
- Evaluate whether the previous plan has delivered its outcomes and allocations.
- Identify any lessons learnt for the preparation of the new plan.
- Consider the appropriateness of the previous spatial strategy.
The purpose of this topic paper is to demonstrate how the evidence report meets these requirements.
Cairngorms National Park Partnership Plan (2017 – 2022 and 2022 – 2027)
The Partnership Plan is the management plan for the National Park. It has been approved by Scottish Ministers. It sets out the vision and over-arching strategy for managing the Park, as well as identifying priorities for action and an overall strategic policy framework.
Guidance in Scottish Planning Policy states that Local Development Plans for National Parks should be consistent with the National Park Partnership Plan. The Partnership Plan therefore provides the strategic context for the Local Development Plan, and the Local Development Plan helps to deliver a number of the Partnership Plan’s policies and priorities.
Partnership Plan 2017 – 2022
The Partnership Plan 2017 – 2022 provided the strategic context and spatial strategy for the adopted Cairngorms National Park Local Development Plan 2021. It helps to deliver the long-term outcomes, priorities and policies of the Partnership Plan 2017 – 2022.
Cairngorms National Park Authority Ughdarras Pàirc Nàiseanta a’ Mhonaidh Ruaidh
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It sets out three long-term outcomes for the National Park:
- Conservation a special place for people and nature with natural and cultural heritage enhanced.
- Visitor experience – people enjoying the National Park through outstanding visitor and learning experiences.
- Rural development – a sustainable economy supporting thriving businesses and communities.
To deliver these three outcomes, the partnership plan contains nine priorities and sixteen policies.
Partnership Plan 2022 – 2027
The Partnership Plan 2022 – has superseded the 2017 plan. The Partnership Plan 2022 2027 contains sets of objectives and policies under three themes: Nature, People and Place.
The overall outcome for nature is a carbon negative and biodiversity rich National Park with better functioning, better connected and more resilient ecosystems. Policy A4 is to conserve and enhance the special landscape qualities of the National Park with a particular focus on:
a) Wildness qualities.
b) Maintaining and promoting dark skies.
c) Supporting woodland expansion that maximises opportunities for long-term enhancement of landscape and wildness qualities.
d) Delivering enhancements that also provide habitat improvements.
e) Enhancing opportunities to enjoy and experience the landscapes of the National Park.
f) Applying a presumption against new constructed tracks in open moorland and, where agreed, ensuring new tracks are constructed to a high standard.
Policy A5(g) is to support off-site mitigation from development that contributes to ecological networks.
The overall outcome for place is a place that people want to live in, work in and visit that works for all. Objective C2 New housing is to deliver new housing in the National Park and ensure as much as possible is secured for key workers and / or to resolve affordability issues. Its target is that by 2030, 75% of new housing is for social rental, mid-market rental or other affordable categories that provide affordability in perpetuity.
Cairngorms National Park Authority Ughdarras Pàirc Nàiseanta a’ Mhonaidh Ruaidh
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Actions include using the next Local Development Plan to identify further locations where more than 25% affordable housing is required and bring this up to 75% overall.
Policy C3 is to enhance the design and sense of place in new development and existing settlements, in particular:
a) Enabling new development which contributes positively to the sense of place
b) Promoting a high standard of sustainable design, energy efficiency, sustainably- sourced materials and construction in new development.
c) Supporting the retention and enhancement of local character.
d) Facilitating the rehabilitation of redundant rural buildings and recycling of resources.
e) Ensuring road upgrades and improvements respond to local landscape character.
f) Promoting active travel and public transport provision and reducing the reliance on private motor vehicles.
Policy C4(a) is to ensure high-quality facilities and infrastructure are designed to manage the effects of visitor pressures on the natural heritage and communities and Policy C4(b) is to ensure that the upgrading or refurbishment of visitor hubs improves accessibility for all potential users and incorporates disabled access toilets and Changing Places facilities where possible.
National Park Partnership Plan Annual Update 2024
This report, presented to the Cairngorms National Park board on 27 September 2024, summarises what work has been done to achieve the outcomes set out in the National Park Partnership Plan 2022 – 2027. The plan contains many goals under the three outcomes, not all of which are related to the policies in the Local Development Plan. The following achievements under the place outcome are relevant:
- Short Term Let Licensing and Control Area implemented by Highland Council in Badenoch and Strathspey.
- Delivery of affordable and mid-market rent housing in Carrbridge, Dulnain Bridge, Kincraig and Kingussie via Highland Council’s affordable housing delivery programme.
- Active travel and path improvement projects progressed on the Speyside Way and Aviemore Orbital route with further projects getting the go ahead.
Cairngorms National Park Authority Ughdarras Pàirc Nàiseanta a’ Mhonaidh Ruaidh
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Cairngorms National Park Local Development Plan 2021
Adopted in March 2021, this is the adopted local development plan for the Cairngorms National Park. The Local Development Plan 2021 shares its vision with the Partnership Plan 2017 – 2022, which is:
‘An outstanding National Park, enjoyed and valued by everyone, where nature and people thrive together.’
The Local Development Plan 2021 contains eleven policies to help to deliver the partnership plan’s long-term outcomes by making sure that:
- The special qualities of the National Park are protected from development that would significantly erode or harm them and are enhanced by new development where possible.
- New development helps to reinforce the valued built heritage of the National Park and the communities within it.
- New or improved visitor infrastructure is supported where appropriate and integrated with other visitor sites, services and communities.
- New development is well connected to core paths and other off-road routes, as well as creating attractive places to live and visit.
- There is sufficient land for housing to meet identified need and demand, including for inward migration of workers.
- More affordable housing is provided to support growth in the working age population and help address the housing pressures faced by young people.
- The necessary land and support for business development and diversification is provided.
- There are sites for future development that support attractive, vibrant communities and that minimise the need to use energy.
- There is clear guidance on where, when and how the best development will be supported.
Cairngorms National Park Authority Ughdarras Pàirc Nàiseanta a’ Mhonaidh Ruaidh
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Table 2 and Table 3, respectively, show the relationship between the Local Development Plan 2021’s eleven policies and the Partnership Plan 2017 – 2022’s nine priorities and sixteen policies.
Table 2 Relationship between policies within in the Cairngorms National Park Local Development Plan 2021 policies and priorities within the Cairngorms National Park Partnership Plan 2017 – 2022.
| Local Development Plan 2021 – policies | Partnership Plan — priorities |
|---|---|
| Conservation | |
| 1 | |
| Landscape scale collaboration | |
| 2 | |
| Deer management | |
| 3 | |
| Moorland management | |
| Visitor experience | |
| 4 | |
| Visitor infrastructure and information | |
| 5 | |
| Active Cairngorms | |
| 6 | |
| Learning and inclusion | |
| Rural development | |
| 7 | |
| Housing | |
| 8 | |
| Community capacity and empowerment | |
| 9 | |
| Economic development | |
| 1 New housing development | |
| 2 Supporting economic growth | |
| 3 Design and placemaking | |
| 4 Natural heritage | ✓ |
| 5 Landscape | ✓ |
| 6 Digital communications | |
| 7 Renewable energy | |
| 8 Open space and recreation | |
| 9 Cultural heritage |
Cairngorms National Park Authority Ughdarras Pàirc Nàiseanta a’ Mhonaidh Ruaidh
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| Local Development Plan 2021 – policies | Partnership Plan — priorities |
|---|---|
| Conservation | |
| 1 | |
| Landscape scale collaboration | |
| 2 | |
| Deer management | |
| 3 | |
| Moorland management | |
| Visitor experience | |
| 4 | |
| Visitor infrastructure and information | |
| 5 | |
| Active Cairngorms | |
| 6 | |
| Learning and inclusion | |
| Rural development | |
| 7 | |
| Housing | |
| 8 | |
| Community capacity and empowerment | |
| 9 | |
| Economic development | |
| 10 Resources | ✓ |
| 11 Developer obligations |
Cairngorms National Park Authority Ughdarras Pàirc Nàiseanta a’ Mhonaidh Ruaidh
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Table 3 Relationship between policies within in the Cairngorms National Park Local Development Plan 2021 and policies within the Cairngorms National Park Partnership Plan 2017 – 2022.
| Local Development Plan 2021 — policies | Partnership Plan 2017 – 2022 – policies |
|---|---|
| Conservation | |
| 1.1 Land management | |
| 1.2 Habitat, species and land use resilience | |
| 1.3 Special landscape qualities | |
| 1.4 Habitat quality and connectivity | |
| 1.5 Species conservation | |
| 1.6 Collaboration across ownerships | |
| 1.7 Cultural heritage | |
| Visitor experience | |
| 2.1 High quality experience | |
| 2.2 Sustainable tourism management | |
| 2.3 Access and recreation | |
| 2.4 Inspiration, learning and understanding | |
| Rural development | |
| 3.1 Economic growth | |
| 3.2 Sustainable settlements development | |
| 3.3 Low carbon economy | |
| 3.4 Supporting communities | |
| 3.5 Design and sense of place | |
| 1 New housing development | |
| 2 Supporting economic growth | |
| 3 Design and placemaking | |
| 4 Natural heritage | ✓ |
Mhonaidh Ruaidh Ughdarras Pàirc Nàiseanta a’ National Park Authority Cairngorms
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| Local Development Plan 2021 — policies | Partnership Plan 2017 – 2022 – policies |
|---|---|
| Conservation | |
| 1.1 Land management | |
| 1.2 Habitat, species and land use resilience | |
| 1.3 Special landscape qualities | |
| 1.4 Habitat quality and connectivity | |
| 1.5 Species conservation | |
| 1.6 Collaboration across ownerships | |
| 1.7 Cultural heritage | |
| Visitor experience | |
| 2.1 High quality experience | |
| 2.2 Sustainable tourism management | |
| 2.3 Access and recreation | |
| 2.4 Inspiration, learning and understanding | |
| Rural development | |
| 3.1 Economic growth | |
| 3.2 Sustainable settlements development | |
| 3.3 Low carbon economy | |
| 3.4 Supporting communities | |
| 3.5 Design and sense of place | |
| 5 Landscape | |
| 6 Digital communications | |
| 7 Renewable energy | |
| 8 Open space and recreation | |
| 9 Cultural heritage | |
| 10 Resources | ✓ |
Mhonaidh Ruaidh Ughdarras Pàirc Nàiseanta a’ National Park Authority Cairngorms
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| Local Development Plan 2021 — policies | Partnership Plan 2017 – 2022 – policies |
|---|---|
| Conservation | |
| 1.1 Land management | |
| 1.2 Habitat, species and land use resilience | |
| 1.3 Special landscape qualities | |
| 1.4 Habitat quality and connectivity | |
| 1.5 Species conservation | |
| 1.6 Collaboration across ownerships | |
| 1.7 Cultural heritage | |
| Visitor experience | |
| 2.1 High quality experience | |
| 2.2 Sustainable tourism management | |
| 2.3 Access and recreation | |
| 2.4 Inspiration, learning and understanding | |
| Rural development | |
| 3.1 Economic growth | |
| 3.2 Sustainable settlements development | |
| 3.3 Low carbon economy | |
| 3.4 Supporting communities | |
| 3.5 Design and sense of place | |
| 11 Developer obligations |
Cairngorms National Park Authority Ughdarras Pàirc Nàiseanta a’ Mhonaidh Ruaidh
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Cairngorms National Park Local Development Plan 2021 – Delivery Programme 2025
The aim of the Delivery Programme is to achieve the intended outcomes of the Cairngorms National Park Local Development Plan 2021.
As an update and replacement for the Action Programme 2022, it introduces a colour- coded ‘delivery pipeline’ (section 2); provides details on affordable housing and financial contributions secured through planning permissions (section 3) and provides a greater level of detail on the planning history of each allocated site in each settlement (section 6). A draft version was the subject of consultation with internal officers and key stakeholders (local authorities, landowners, developers and key agencies).
Baseline of policy monitoring matters
This section evaluates whether the adopted Local Development Plan 2021 has delivered on its outcomes and allocations; identifies any lessons learnt and considers the appropriateness of the previous spatial strategy, as required by Paragraph 93 of the Local Development Planning Guidance (2023).
It also considers the relationship between the Local Development Plan 2021 policies, and the National Planning Framework 4 policies to identify the effect of its publication on the use of the Local Development Plan policies.
It covers the following issues:
- Analysis of Local Development Plan 2021 policy usage in planning decisions
- Summary of delivery of allocations
- Lessons learnt
- Spatial strategy
- Relationships between Cairngorms National Park Local Development Plan 2021 and National Planning Framework 4 policies.
There are links between this topic and all other policy areas.
Analysis of Local Development Plan 2021 policy usage in planning decisions
In the Cairngorms National Park, arguably more than in any other part of Scotland, there is a partnership approach to planning. The Cairngorms National Park Authority and the five relevant local authorities – Aberdeenshire Council, Angus Council, Moray Council,
Cairngorms National Park Authority Ughdarras Pàirc Nàiseanta a’ Mhonaidh Ruaidh
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Perth and Kinross Council and The Highland Council – all play a key role in making the planning system work effectively.
The Cairngorms National Park sets the planning policy framework through the Cairngorms National Park Partnership Plan and the Local Development Plan and all planning applications in the National Park are determined in line with this policy framework.
However, planning applications are submitted in the first instance to the relevant local authority. The Cairngorms National Park then ‘calls in’ and determines the most significant planning applications for the National Park (generally around 10% of all applications), leaving the remainder to be determined by the local authorities.
The type of applications that the Cairngorms National Park Authority are highly likely to call-in are:
- All ‘major’ applications as defined in planning legislation.
- Private ways, which require Environmental Impact Assessments and those which could have a potential impact upon important natural and cultural heritage interests and/or sites of particular landscape sensitivities.
- Wind turbines, hydro schemes or large solar panel farms.
- Minerals applications.
- Housing – five or more residential units within a settlement.
- Housing — three or more residential units outside a settlement.
- More than 250m² gross floor area, or 0.25ha, of employment space outside settlements.
- Applications which would require Environmental Impact Assessment.
- Listed building consent applications that involve major external or internal changes or are otherwise linked to an application type in this list.
- Conservation area consent applications linked to another application type in this list.
The types of applications that are unlikely to be called in include householder development, small housing schemes, small scale extensions, alterations and changes of use and other applications such as advertisement and heritage consents.
The officer reports of all planning applications determined by the Cairngorms National Park Authority and the five local planning authorities since the Cairngorms National Park Local Development Plan was adopted in March 2021¹ have been analysed to help
1 All planning applications determined between 1 April 2021 and 31 March 2025.
Cairngorms National Park Authority Ughdarras Pàirc Nàiseanta a’ Mhonaidh Ruaidh
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to assess whether the outcomes of the National Park’s partnership plan and local development plan have been delivered.
Local Development Plan 2021 – overall policy use
1,266 planning applications have been determined since the Cairngorms National Park Local Development Plan 2021 was adopted. 94% of those have been determined by the constituent local planning authorities and only 6% determined by the Cairngorms National Park. 57% have been determined by The Highland Council. Figure 1 indicates the number and proportions determined by each authority.
Aberdeenshire Council, 355
Highland Council, 814
Cairngorm National Park Authority, 83
Perth and Kinross Council, 72
Moray Council, 53
Angus, 7
Figure 1 Number of planning applications determined by each local planning authority April 2021 – March 2025.
The 11 local development plan policies are used to determine applications across the Cairngorms National Park (alongside the National Planning Framework 4’s policies since its publication in February 2023). Figure 2 Cairngorms National Park Local Development Plan policies referred to in planning applications approved by the Cairngorms National Park Authority and by each constituent planning authority between April 2021 and March 2025. indicates the proportion of approved applications decided using each policy by each local authority. It highlights that each
Cairngorms National Park Authority Ughdarras Pàirc Nàiseanta a’ Mhonaidh Ruaidh
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authority has quite a similar pattern of policy usage. While the National Park sometimes differs, this is likely due to the different types of applications. In further graphs and analysis, we will look further into the policy use of the Cairngorms National Park vs all other local authorities and on which they differ significantly. This graph also starts to introduce which policies are most used and least used across the park.
100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% Policy 1 Policy 2 Policy 3 Policy 4 Policy 5 Policy 6 Policy 7 Policy 8 Policy 9 Policy 10 Policy 11
Cairngorms National Park Angus Perth and Kinross Moray Aberdeen Highland
Figure 2 Cairngorms National Park Local Development Plan policies referred to in planning applications approved by the Cairngorms National Park Authority and by each constituent planning authority between April 2021 and March 2025.
To help show the overall picture of main policy use, Figure 3 shows the proportion of policy usage in all decisions made by all authorities. This gives us a clear picture of the most used policies which are:
- Policy 3 (design and Placemaking) used in 87% of all decisions.
- Policy 1 (new housing development) used in 42% of all decisions.
- Policy 4 (natural heritage) used in 42% of all decisions.
It also helps us to understand which policies were used the least:
- Policy 6 (the siting and design of digital communications equipment) used in 2% of all decisions.
- Policy 7 (renewable energy) used in 3% of all decisions.
- Policy 8 (open space, sport and recreation) used in 5% of all decisions.
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100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% Policy 1 Policy 2 Policy 3 Policy 4 Policy 5 Policy 6 Policy 7 Policy 8 Policy 9 Policy 10 Policy 11 Figure 3 Percentage of all planning decisions where each Cairngorms National Park Local Development Plan policy was referred to between April 2021 and March 2025.
Leading on from the overall picture, Figure 4 shows proportionate policy use by the Cairngorms National Park Authority when approving and refusing applications. This can then be compared to Figure 5 which shows policy use by the combined local authorities in decision-making. From this we can see that there are policies which have been used more by the Cairngorms National Park in their decision making, than by the other local authorities. These are:
- Policy 5 (landscape) used in 90% of application decisions by the National Park compared to in 16% of application decisions by the local authorities.
- Policy 4 (natural heritage) has been used 94% of application decisions compared to 39%.
- Policy 10 (resources) has been used in 73% of application decisions compared to 29%.
Policies which are use more by all other local authorities compared to the Cairngorms National Park are:
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- Policy 1 (new housing development) which has been used in 43% of application decisions by the constituent local authorities, compared to in 29% of application decisions by the National Park.
- Policy 9 (cultural heritage) 32% of applications compared to 18%.
Policy 1 Policy 2 Policy 3 Policy 4 Policy 5 Policy 6 Policy 7 Policy 8 Policy 9 Policy 10 Policy 11 0% 20% 40% 60% 80% 100% Approved Refused Figure 4 Proportion of planning applications that each