Schedule 4s - Summary of Unresolved Representations
CONTENTS
Schedule Page Issue 1 General 3 Issue 2 Introduction, Vision and Strategy 9 Issue 3 Policy 1: New Housing Development 20 Issue 4 Policy 2: Supporting Economic Growth 52 Issue 5 Protecting the Environment 64 Issue 6 Delivering Infrastructure 100 Issue 7 Badenoch and Strathspey Strategic Settlements 114 Issue 8 Aberdeenshire Strategic and Intermediate Settlements 146 Issue 9 Badenoch and Strathspey Intermediate Settlements 173 Issue 10 Other Intermediate Settlements 204 Issue 11 Rural Settlements 218 Issue 12 Other Issues 230 1 Relevant Documents Page — Issue 1: General
Schedule 4
Representations 006, S Dickie 124, Anonymous 141, J Milne 148, R Locatelli and J Bremner 165, Cairngorms Business Partnership (CBP) 180, J and M Forbes Leith Partnership 181, Scottish Wildland Group 186, Cairngorms Campaign
Site Maps None
Representee Documents RD001 CBP Main Issues Report Summary and Response — Cairngorms Business Partnership — Cairngorms Business Partnership — 165 — Issue 1 RD002 CBP Main Issues Report Summary and Response — Cairngorms Business Partnership — Cairngorms Business Partnership — 165 — Issue 1
Authority Documents None 2 Issue 1 General Principle of development Transport Development plan Site allocation requirements reference: Process General Policy approach Economic growth Reporter: Body or person(s) submitting a representation raising the issue (including reference number): 006 S Dickie 124 Anonymous 141 J Milne 148 R Locatelli and J Bremner 165 Cairngorms Business Partnership (CBP) 180 J and M Forbes Leith Partnership 181 Scottish Wildland Group 186 Cairngorms Campaign Provision of the Principle of development development plan Transport to which the issue Site allocation requirements relates: Process General Policy approach Economic growth Planning authority’s summary of the representation(s):
Principle of development within the National Park S Dickie (006) is of the view that development should not be permitted outwith town and village boundaries. The focus should be on conservation, service provision, town and local facility improvements (car parks, toilets) for visitors and encourage local businesses to support these services.
Transport Anonymous (124) and J Milne (141) believe that all policies are affected / underpinned by transport issues and Anonymous (124) requests that the need for affordable public transport, car-sharing schemes and bike borrowing schemes are added to each policy.
J Milne (141) feels that transport and mobility (including accessibility, affordability and choice) is under-represented in the Proposed Plan and despite the National Park Partnership Plan ‘promoting active travel and public transport provision and reducing the reliance on private motor vehicles’ (Partnership Plan Policy 3.5 f) repeated in paragraph 4.52 of the Proposed Plan on page 40) there is no consideration of how this will happen and what the barriers to achieving this are. It is also raised that there is only one mention of the A95 trunk road which is a key route.
Site allocation Requirements R Locatelli and J Bremner (148) contend that all development allocations in the LDP should not require to prepare any form of site assessment such as protected species, flood, contamination or other reports. They are of the view that the Planning Authority 3 (CNPA) should undertake relevant surveys prior to the allocation of the sites and adoption of the Proposed Plan to demonstrate effectiveness.
Process CBP (165) raised concern that their comments to the Main Issues Report in respect of Main Issue 4: Housing and Issue 5: Affordability of housing were not recorded in the ‘Summary of Responses and Recommended Actions’ which was taken to CNPA Board in June 2018. By not taking these comments into account, CNPA is contravention of the Planning (Scotland) Act 2006.
CBP (165) also added that responding to the consultation according to the process is time consuming and complex and is a barrier to engagement.
General Policy approach J and M Forbes Leith Partnership (180) express support for polices that allow appropriately scaled development across the National Park to encourage development and help to deliver the important outcomes set out in the National Park Partnership Plan.
Economic Growth Scottish Wildland Group (181) suggests amending reference in the Proposed Plan to ‘Sustainable economic growth’ to ‘equitable growth’ as this will likely be the term used in the new Planning Act and Scottish Planning Policy. This term is more ‘future-proofed’ and suitable for the LDP.
Cairngorms Campaign (186) express concern that there is no process for assessing the economic benefits of development. They claim that no analysis is carried out in respect of the potential economic benefits and therefore how can CNPA give greater weight to the first aim of the National Park. They are of the view that further assessment /analysis at the planning applications stage is needed and consideration of alternatives proposals that would be more beneficial.
Modifications sought by those submitting representations:
Principle of development within the National Park • Do not permit development outwith town and village boundaries (S Dickie, 006); • Focus on conservation, service provision and local facility improvements for visitors (S Dickie, 006).
Transport • Add a requirement for affordable public transport, car-sharing schemes and bike borrowing schemes to each policy (Anonymous, 124); • Give greater prominence in the Proposed Plan to the provision of transport, the key challenges and how it will be delivered (J Milne, 141); • Make greater reference to the A95 (J Milne, 141)
Site allocation Requirements • Remove the requirement for any assessments or surveys for allocated sites (R Locatelli and J Bremner, 148).
Economic Growth Amend references to ‘Sustainable economic growth’ to ‘equitable growth’ (Scottish 4 Wildland Group, 181). • Require more rigorous assessment / analysis of economic development proposals (Cairngorms Campaign, 186).
Summary of responses (including reasons) by planning authority:
Principle of development within the National Park CNPA do not agree that development should not permitted outwith settlements. While conservation is a key aim of the National Park, the development strategy for (set out on page 16) aims to focus the majority of development within settlements however acknowledges the need for smaller scale development to support housing, including affordable housing and rural businesses outwith defined settlements (page 16, paragraph 3.11). Once adopted, all proposals will be subject to relevant policies in the LDP to ensure that development does not have adverse impacts. Therefore no modification is proposed (S Dickie, 006).
The provision or maintenance of local services such as public car parks, toilets and visitors facilities cannot be influenced or informed by the Local Development Plan and it is not considered that this should be the only focus of development within the National Park as set out above. No modification proposed (S Dickie, 006).
Transport The LDP cannot influence or inform public transport provision, car sharing schemes or bike borrowing, however can ensure that the provision of necessary transport infrastructure is incorporated within a development. Policy 3: Sustainable Design, part 3.3 f) requires the promotion of ‘sustainable transport methods and active travel, including making provision for the storage of bicycles and reducing the need to travel’. CNPA do not agree that transport is relevant to all policies, however Policy 3 applies to all developments and therefore no modification is required (Anonymous, 124).
While the National Park Partnership Plan and Proposed Plan seek to support and improve transport infrastructure and particularly the provision of active travel, the LDP cannot directly influence or inform public transport provision or improve the affordability or choice of public transport. However, it can seek to ensure that transport provision is taken into account in new developments and opportunities to incorporate active travel are utilised. All development proposals within the National Park are subject to all relevant policies including Policy 3 (stated above) to ensure that appropriate transport options are supported as far as possible within the parameters of planning. CNPA are not the roads or transport authority so is required to consult and work with relevant body where necessary. CNPA is of the view that the Proposed Plan makes appropriate reference to support and encourage more sustainable transport methods, and takes a proportionate approach considering the limited influence planning and the LDP can have of transport provision and infrastructure. No modification proposed (J Milne, 141).
In relation to making reference to the A95, while this is a key route, it is not clear from the response what the purpose of increasing reference to it is. CNPA do not consider there is a compelling argument to make greater reference to the A95. No modification proposed (J Milne, 141).
Site allocation Requirements CNPA does not support the suggestion to remove the requirement for site assessments 5 and surveys for development allocations. The LDP currently takes a number of years to prepare and runs for a 5 year plan period. Site conditions and circumstances change over time so an assessment carried out 2 years prior to a development coming forward will not accurately reflect the current circumstances. It is more appropriate to undertake site assessments and surveys at the time of the planning application to determine if the proposal is acceptable. Different developments will impact on the environment, infrastructure and other factors in different ways and therefore may require different mitigation measures. For example waste and water infrastructure capacities change depending on the progress of other developments in the area and therefore cannot be confirmed prior to the adoption of the LDP.
In addition, it is a significant undertaking for the authority to spend time and money undertaking assessment for all sites when they will be progressed at different rates and not always within the Plan Period. Therefore this would have to be repeated at the time development is being proposed. No modification is proposed (R Locatelli and J Bremner, 148).
Process CNPA have investigated the absence of CBP being omitted as a respondent in relation to Main Issues 4 and 5 and can confirm that their response, which did not raise any unique issues, was taken into account but their name was omitted as an administrative error in recording the respondents. No modification proposed (CBP, 165).
In respect of the LDP preparation process, this is stipulated in Planning Legislation (Planning (Scotland) Act 2006) which CNPA are required to adhere to. Due to the more limited nature of the Proposed Plan consultation, which specifically requires respondents to support or object to specific parts of the Proposed Plan, it can be more complex. The response survey was designed to obtain specific comments in line with the legislative requirements. No modification or action proposed (CBP, 165).
General policy approach CNPA are of the view that the Proposed Plan’s development strategy and policies do support appropriate development outwith allocated sites. No modification proposed (J and M Forbes Leith Partnership, 180).
Economic Growth While CNPA note the suggested amendment of ‘Sustainable economic growth’, it is not considered essential on the basis that the new Planning Act and Scottish Planning Policy have not yet been implemented. However CNPA would not object if the Reporter is minded to support it (Scottish Wildland Group, 181).
CNPA notes the request for more rigorous assessment of economic development proposals, particularly where in conflict with the first aim of the National Park to conserve and enhance the natural and cultural heritage of the area’. However, the current economic development policy (Policy 2) sets out the requirements that proposals must meet (as well as being subject to all other relevant policies within the LDP), which require evidence and justification demonstrating how they meet these requirements (Cairngorms Campaign, 186).
Given the small population and scale of settlements, it can be difficult to obtain a representative picture of need and demand for economic development land as well as to accurately determine the true economic impact of a proposal, particularly as there are 6 more localised pressures which may not be apparent or properly represented through research and available evidence. The data used to inform the Proposed Plan’s approach has been the most up to date available.
In addition, CNPA have a statutory requirement to allocate sites for economic development and include an economic development policy within the LDP to support business and employment in the National Park. The National Planning Framework 3 (paragraphs 1.6 & 2.25) and Scottish Planning Policy (2014) recognise ‘the continuing need for diversification of our rural economy to strengthen communities and retain young people in remote areas. Planning should address the development requirements of businesses and enable key opportunities for investment to be realised. It can support sustainable economic growth by providing a positive policy context for development that delivers economic benefits’ (Scottish Planning Policy, paragraph 92, page 24).
In some cases, further assessments such as a retail impact assessment may be required however the net economic benefit of a proposal to the local economy is not a material planning consideration. Therefore, no modification is proposed (Cairngorms Campaign, 186).
Reporter’s conclusions:
Reporter’s recommendations: 7 Relevant Documents Page — Issue 2: Introduction, Vision and General
Schedule 4
Representations 089, Scottish Government 117, Paths for All 131, Tactran 159, John Muir Trust 165, Cairngorms Business Partnership (CBP) 179, R Turnbull 182, Wildland Ltd
Site Maps None
Representee Documents None
Authority Documents CD002 — National Park Partnership Plan 2017 – 2022 CD005 — Habitats Regulations Appraisal CD006 — Strategic Environmental Assessment CD012 — Housing Evidence Report CD017 — Draft Economic Action Plan CD018 — Site Assessment Report 8 Issue 2 Introduction, Vision and Strategy Development plan Introduction, Vision and Strategy (pages 4 — Reporter: reference: 17) Body or person(s) submitting a representation raising the issue (including reference number): 089 Scottish Government 117 Paths for All 131 Tactran 159 John Muir Trust 165 Cairngorms Business Partnership (CBP) 179 R Turnbull 182 Wildland Ltd Provision of the Introduction, Vision and Strategy development plan to which the issue relates: Planning authority’s summary of the representation(s):
Introduction CBP (165) argue that Figure 2 misquotes the National Park Partnership Plan 2017 – 2022 (CD002) by referring to an ‘Economic Action Plan’. They wish this to be corrected and that CNPA produce an Economic Strategy. They argue that the Plan will fail to deliver on key challenges faced by the local Economy because the Proposed Plan has been published without the context of an Economic Strategy. They do not believe the Proposed Plan addresses the availability of housing for workers.
CBP (165) argue that the population projections on which the development plan is based will be disastrous for the local economy and that consequently plan does not address the need for housing and the infrastructure to support population growth and the development and diversification of the economy. Accordingly, the approach taken by the Proposed Plan fails to deliver the collective aims of the Cairngorms National Park as set out in the National Parks (Scotland) Act 2000.
Wildland Ltd (182) are concerned that with respect to the National Park’s four aims, that the Proposed Plan is too focused on built development and while recognising that a balance needs to be struck, the National Park is a heritage designation and therefore this should be reflected more strongly in the Plan, for example by prioritising the first aim of the National Park within Paragraph 1.6 and strengthening the policy provision on natural heritage and landscape.
Wildland Ltd (182) also argue that the policy framework in which the Plan sits, as illustrated in Figure 2 is too excessive and leads to a loss of focus. They argue that only the National Park Partnership Plan and an LDP focused on natural heritage and landscape would solve this.
Vision Wildland Ltd (182) state that they are unclear how the Long Term Outcomes contained within paragraph 2.2 are translated into Policy within the LDP. They question how large 9 allocations, such as those in Aviemore, Newtonmore and Kingussie, are compatible with the Long Term Outcomes.
Tactran (131) request that the vision section should state that new developments will be accessible by public transport and where this is not possible other alternatives to private car use are included within any development proposal.
R Turnbull (179) believes the vision is ‘delusional’ because development allocations encroach onto land valuable for its environmental qualities. He argues that the history of the planning in the National Park has resulted in an excessive allowance of market dwellings which have not been suitable for local and first time buyers. This has mainly benefited large landowners and house builders with houses largely sold as second, holiday and retirement homes, taking up valuable land and damaging local communities.
John Muir Trust (159) argue that in paragraph 2.3 the principle of protecting the special qualities of the Park be placed ahead of the “enhanced by new development” bulletpoint. They also request wildness be reference as a special quality. Wildland Ltd (182) state that they are unclear how these principles relate to the Long Term Outcomes and that certain principles, such as providing sufficient land to meet need and demand are contrary to the conservation Long Term Outcome. It is suggested that these linkages be shown and that there should be a stronger focus on natural heritage and conservation.
Strategy Scottish Government (089) state that there is no-commitment to upgrade a parallel route for non-motorised users along the whole A9 and therefore this needs to be made clear in in paragraph 3.2.
Wildland Ltd (182) state that there is no spatial strategy for the extensive rural and mountainous areas of the National Park. They therefore suggest that the LDP should visualise a rural strategy in some way, for example by showing areas around settlements where small scale development might be permitted while also highlighting the mountainous areas, for example Wild Land Areas, that merit a strong priority for natural heritage and landscape protection. They argue that such an approach would be commensurate with the statutory aims of the National Park.
Paths for All (117) are concerned that efforts should be made to avoid severance of access routes along the upgraded A9.
Tactran (131) request the spatial strategy section should state that travel by private car should not be prioritised over other more sustainable transport modes.
R Turnbull (179) claims that the Proposed Plan’s strategy will cause significant environmental damage, with the dualling the A9 fragmenting wildlife populations and generating increased pressure for unsuitable and unsustainable development and An Camas Mòr failing to relieve the development pressure on other settlements. It is argued that the effect of this is a move towards suburban sprawl.
Modifications sought by those submitting representations:
Introduction • Produce an Economic Strategy to guide the Local Development Plan (CBP, 165). 10 • Prioritise the first statutory aim of the National Park and strengthen policy provision for natural heritage and landscape (Wildland Ltd, 182) • Simplify the National Park’s policy framework as shown in Figure 2, to just include a National Park Partnership Plan and LDP focused on natural heritage and landscape protection (Wildand Ltd, 182).
Vision • Clarify how Long Term Outcomes are translated into Policy (Wildland Ltd, 182). • Section should confirm that new developments will be accessible by public transport and where this is not possible other alternatives to private car use are included within any development proposal (Tactran, 131). • A considerable reduction in the overall level of house-building (R Turnbull, 179). • Emphasise building a far greater proportion of smaller houses, suitable for first time buyers (R Turnbull, 179). • Create strong presumption against large multi-bedroom houses (R Turnbull, 179). • Include recognition that the role of the National Park is not to facilitate the cash-flow of large building companies or landowners, or to bow to the pressure put upon the National Park by politicians (R Turnbull, 179). • Place principle of protecting the special qualities of the Park ahead of the “enhanced by new development” bullet point in paragraph 2.3 (John Muir Trust, 159). • Reference wildness as a special quality in paragraph 2.3 (John Muir Trust, 159). • Show links between Long Term Outcomes and principles set out within paragraph 2.3 and place greater emphasis on natural heritage and landscape protection (Wildland Ltd, 182).
Strategy • Amend paragraph 3.2 to make it clear that there is no-commitment to upgrade a parallel route for non-motorised users along the whole A9 (Scottish Government, 089). • Create spatial strategy for the National Park’s Rural and mountainous areas, for example by showing areas around settlements where small scale development might be permitted while also highlighting the mountainous areas, for example Wild Land Areas, that merit a strong priority for natural heritage and landscape protection (Wildland Ltd, 182). • State within spatial strategy section that travel by private car should not be prioritised over other more sustainable transport modes (Tactran, 131). • Require the proper assessment of the impact of dualling of the A9 on wildlife populations (R Turnbull, 179). • Develop specific policies to resist ribbon development along the A9 (R Turnbull, 179). • Reduce the rate of housebuilding (R Turnbull, 179). • Take proper and adequate consideration of the first aim of the National Park (R Turnbull, 179).
Summary of responses (including reasons) by planning authority:
Introduction The strategy for promoting a sustainable economy in the National Park is set out within the National Park Partnership Plan (CD002). The National Park Partnership Plan identifies 11 nine Priorities across three Long-term Outcomes: Conservation, Visitor Experience and Rural Development. The Long-term Outcome for Rural Development is:
“A sustainable economy supporting thriving businesses and communities”.
Due to the integrated nature of the National Park Partnership Plan, delivery of each outcome plays a role in the supporting the economy of the National Park – for example, investment in woodland expansion enhances the landscape for visitors, provides increased recreational opportunities and new economic opportunities. All nine Priorities are therefore important to the deliver a sustainable economy of the National Park but the two most significant Priorities are:
“AGENDA FOR ACTION: ECONOMIC DEVELOPMENT
Partners will deliver the current Economic Strategy for the Park to 2018 and then review, focussing on action plans for key business sectors:
Developing sector-specific plans to tackle investment, enhance skills through stronger links with higher and further education, improve long-term resilience and increase average wages, as well as building business on the natural capital of the National Park; • Supporting Cairngorms Community Broadband* to deliver superfast broadband in the hardest to reach parts of the Park; Continuing to improve physical infrastructure, including access to affordable housing and digital connectivity; • Maximising the opportunities for businesses, communities and visitors from the A9 dualling project; • Review implications and options for the farming sector as changes in long-term support become clearer; • Using the next Local Development Plan to identify new sites for business use and expansion and the delivery of the Local Development Plan to target investment that opens up those sites to business.”
- Note this action is now being delivered through the roll-out of Scottish Government’s Reaching 100 project.
And:
“AGENDA FOR ACTION: HOUSING
Partners will respond to the unique housing challenges and pressures within the Park by developing a special approach that is based on:
Reducing the proportion of second homes in new developments by ensuring the new housing development is targeted at meeting local needs as far as possible; Maximising the proportion of new housing that is affordable in perpetuity; • Identifying sites in the next Local Development Plan where the affordable housing contribution will be more than the normal national maximum of 25% because of acute affordability pressures and the shortage of supply; Using the next Local Development Plan to manage the nature of new open market housing so it is better targeted towards local needs (e.g. by seeking a greater mix of house types and sizes, with an emphasis towards smaller homes in new 12 developments); • Applying flexible planning policies to promote majority affordable housing developments and encourage the use of innovative delivery models to maximise the number of affordable homes that are built; Targeting public sector funding towards the National Park and to sites with the greatest potential for delivering affordable housing; Supporting communities to deliver community-led housing solutions, including by making the most of powers to buy land and taking a more pro-active role in management where appropriate; Promoting high standards of sustainable design and energy efficiency in new homes to ensure they are affordable in terms of lifetime running costs.”
In addition, each of the three Long-term Outcomes in the Partnership Plan have a comprehensive policy framework that provides continuity over the long-term, for example National Park Partnership Plan Policy 3.1, which states “Grow the economy of the Cairngorms National Park by strengthening existing business sectors, supporting business start-ups and diversification, and increasing the number of workers employed in the Park through: Maintaining the population of the National Park and maintaining or growing the proportion of the working age population. • Supporting the diversification of existing land-based businesses. • Encouraging growth of business sectors that draw on the special qualities of the Park such as sustainable tourism and food and drink. • Broadening the economic base of the Park into sectors such as creative industries, renewable energy, and making stronger links with higher and further education. • Increased provision for business land where there is an identified need and demand; and to support the use of land for small business particularly within settlements. Slowing outward migration of young people; to encourage their return; and the inward migration of workers to the Park to meet business and community needs. Provision of a housing land supply that supports migration of young people and workers to the park and maintains vibrant communities. Reducing the proportion of vacant and second homes to support community vibrancy by ensuring that new housing development best meets local needs. Maximising the proportion of new housing development that is affordable in perpetuity.”
CNPA has consulted on an Economic Action Plan (dates 26th June – 20th September 2019) (CD017) that will sit beneath the National Park Partnership Plan and alongside the LDP. The purpose of the Action Plan is to focus partners’ work in the National Park on five priority themes: Supporting and Attracting Business • Building on Economic Strengths of the Park • • • Education, Training and Skills Development • Community and Enterprise Infrastructure
CBP’s (165) claim that the Proposed Plan is produced in the absence of an Economic Strategy and that the reference to an Economic Action Plan is a mis-quote is therefore unfounded. 13 Matters relating to the level and delivery of housing, including the Housing Supply Target (HST), Housing Land Requirement, Population and household projections are covered under Issue 3: Policy 1: New Housing Development with further information in the Housing Evidence Report (CD012). Fundamentally, however, the population projections are not the sole method by which the HST has been reached and that growth scenarios were taken as the baseline from each of the Local Authority Housing Need and Demand Assessments. CNPA fundamentally disagree that the in this respect, the Proposed Plan fails to deliver the collective aims of the Cairngorms National Park (CBP, 165). Matters relating to the level of housing were also raised by R Turnbull (179) against the vision and Strategy; these matters are also covered under Issue 3: Policy 1: New Housing Development.
The LDP is focused on development because it is a development plan. As stated in the National Parks (Scotland) Act 2000 the National Park’s aims are to be collectively achieved in a co-ordinated way. It is only where conflict is identified between the National Park Aims that the first aim, which is “to conserve and enhance the natural and cultural heritage of the area”, should be given greater weight. The LDP has been subject to both Habitats Regulations Appraisal (CD005) and Strategic Environmental Assessment (CD006) and no conflict between the aims has been identified. Therefore, priority does not need to be given to the first aim. The Proposed Plan contains strong policies around environmental protection, including Policies 4: Natural Heritage, 5 Landscape, 7: Renewable Energy and 10: Resources. CNPA is therefore confident that taken together, as is stated in paragraph 4.2, that the Proposed Plan is sufficiently strong to ensure that the National Park’s special natural heritage and landscape features are protected from adverse effects (Wildland Ltd, 182).
The policy framework in which the Proposed Plan exists does not fall within the scope of the LDP to alter. The National Park Partnership Plan and LDP are both statutory Plans and therefore required by legislation. CNPA does not however agree that the other plans and strategies are unnecessary or that they can be incorporated effectively into the two statutory Plans. They are crucial for setting out how the various aims, outcomes and actions of the National Park Partnership Plan will be achieved (Wildland Ltd, 182).
No modifications proposed.
Vision The Long Term Outcomes set out in paragraph 2.2 are overarching and it is the role of the Proposed Plan as a whole to deliver them. A stated in paragraph 4.2, planning applications will be assessed against all relevant policies of the Plan and therefore all policies may in some way, depending on the application, support each of the Long Term Aims. For example, Policy 1: Housing, while not specifically a conservation policy, may support the conservation outcome by directing housing proposals to the appropriate locations and for proposals to be of an appropriate scale. The creation of a table or diagram to show linkages is therefore not considered useful (Wildland Ltd, 182).
CNPA does not agree that large allocations are incompatible with the conservation Long Term Outcomes. All policies and sites have been subject to Habitats Regulations Appraisal (CD005) and Strategic Environmental Assessment (CD006) to ensure significant adverse effects do not occur (Wildland Ltd, 182).
The vision section is sets out the overarching principles that the Proposed Plan aims to deliver. The request to state that “new developments will be accessible by public transport 14 and where this is not possible other alternatives to private car use are included within any development proposal” is considered to be a policy matter. Policy 3.3: Sustainable design requires development to promote sustainable transport methods and active travel, including making provision for the storage of bicycles and reducing the need to travel. The points requested by Tactran (131) are therefore already included within the Proposed Plan and so CNPA does not consider that a change needs to be made.
The bullet points under paragraph 2.3 are not listed in order of importance, therefore reordering would make no difference to the implementation of the Plan. While CNPA recognises wildness as a special quality of the National Park, it is just one of many and the purpose of the paragraph and its bullet points is to highlight outcomes, not highlight particular qualities. Policy 5.1: Special Landscape Qualities already highlights wildness as a special quality and requires it to be a considered as part of planning proposals where relevant. Furthermore, paragraphs 4.70, 4.79 and Figure 9 draw attention to Wild Land Areas and wildness as a special quality. CNPA do not therefore agree that an amendment to paragraph 2.3 is necessary (John Muir Trust, 159).
The principles under paragraph 2.3 are like the outcomes themselves, general overarching statements to provide additional context for the way the Plan is to be used. Like, the policies, depending on the type of development, these principles could be in some way, depending on the proposal, support each of the Long Term Aims. The creation of a table or diagram to show specific linkages is therefore not considered useful (Wildland Ltd, 182).
All allocations have been subject to site assessments (CD018), Habitats Regulations Appraisal (CD005) and Strategic Environmental Assessment (CD006). There is no evidence that the strategy is likely to significantly undermine the National Park’s special qualities or that the vision is unachievable. Furthermore, the Proposed Plan includes a range of policies (e.g. Policy 3: Design and Placemaking, Policy 4: Natural Heritage and Policy 5: Landscape) to ensure that development sites are delivered without causing significant, un-mitigatable harm. As stated in paragraphs 4.1 and 4.2, planning applications will be assessed against all relevant parts of the Plan (R Turnbull, 179).
Policy 1.4 Designing for affordability requires developments to provide a mix of dwelling types and sizes to help secure a balanced housing stock. The policy emphasises the delivery of smaller dwellings. This specifically to ensure that there is stock suitable for first time buyers and those who cannot afford housing at or above the median price. Housing will be delivered through a mixture of commercial and public sector schemes, just as it is elsewhere in Scotland (R Turnbull, 179).
No modification proposed.
Strategy CNPA is of the view that section 3 clearly sets out the spatial strategy for the National Park, including how the strategy incorporates rural areas; specifically, paragraphs 3.7 and 3.11 cover this. The strategy diagram is designed to be as simple and as easily understandable as possible. CNPA does not therefore support Wildland Ltd’s (182) suggested changes, particularly as the Proposed Plan does not contain a provision for small scale development specifically around settlements, while upland environments and designations, for example Wild Land Areas and Moorland areas, are already identified on figures 9 and 10, which both relate to the implementation of Policy 5: Landscape. 15 Proposals on dualling the A9 within the National Park are not yet fully complete (Scottish Government, 089). Current designs have an off road multi path from Kingussie to Aviemore, but none to Carrbridge, with Transport Scotland maintaining that either the current NCN7 using B970 and B9153 (Aviemore, Coylumbridge Boat of Garten, Carr- bridge), or the Speyside Way or existing A9 tracks (neither direct or tarmac multi-use) are sufficient.
Transport Scotland undertook the statutory public consultation in August / September
- CNPA, Cairngorms Local Access Forum (CLOAF), Highland Council and four Community Councils (Aviemore and Vicinity, Boat of Garten and Vicinity, Carr-Bridge and Tomatin) have outstanding objections to these proposals as they do not meet Transport Scotland scheme objectives or support CNPA’s Active Cairngorms Strategy or the National Park Partnership Plan with the specific target of increasing active travel.
In February Transport Scotland met with CNPA, Highland Council, Sustrans and Hitrans and agreed to fund a feasibility study to look at options to create a tarmac off road muti- use path between Aviemore and Carrbridge linking to A9153 north of Carr-bridge (on road). This design is in progress but no initial outputs have been shared and there is currently no clear commitment to build and maintain this route.
CNPA and Highland Council are therefore sustaining their objections, and it is understood that this is also the case for the four community councils, until there is clarity about the design, build and maintenance of any proposed route. CNPA does not therefore agree with the Scottish Government’s (089) proposed change and would not consider including any such specific statements until the outstanding objections are resolved.
The management of access routes along the A9 falls outside of the remit of the LDP. However, as the access authority for the area, CNPA is involved in the process and has and will object to any proposals that negatively affect the area’s Core Paths and