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CAIRNGORMS NATIONAL PARK AUTHORITY 
Planning Paper 7 3 June 2005 
APPENDIX 2 


A Draft Policy Statement on “Commenting” 

• The legislation makes it clear that the primary decision to be made by 
the CNPA is whether or not to call an application in, based on an 
assessment as to whether or not the application "raises a 
planning issue of general significance to the Park aims". There is no 
mention of commenting in the legislation or the Planning Protocol. 

• It is inevitable, however, that there will be some applications that raise 
issues that are neither general nor all that significant, but still of 
legitimate interest to the CNPA. It is entirely proper, therefore, that the 
CNPA may wish on occasions to make comment to the LA that is to 
determine an application, just as the views of the LAs are expected 
and welcomed on applications to be determined by the CNPA. These 
may be formal comments, but as often as not they may be more 
effective through informal channels between respective officers. 

• If comments made by the CNPA are to be effective, then it is important 
that they are only made when it is really considered to be necessary, 
and that care is taken not to restate points that are already obvious to 
experienced LA Members and professional officers. CNPA planning 
staff are probably the people best placed to secure this difficult 
balance. It is also of relevance that comments made by LAs on 
applications being determined by the CNPA almost always come from 
LA officers, not from Members sitting in Committee. These comments 
are often through informal dialogue between CNPA and LA officers. In 
cases where formal comment is made it still comes from a LA officer 
who is delegated to submit views on behalf of that authority. It is 
important to try and maintain balance and parallels in the way in which 
CNPA and the LAs comment to each other in order to avoid potential 
misunderstanding and to maintain common practices. 

• It is concluded from this that the best policy for the CNPA would be to 
delegate commenting to planning officers just as the LAs do, but to find 
some way in which Members can have input into the thinking of 
planning officers. It is crucial, however, that the decision on whether 
and how to comment is delegated as it is your professional officers, 
with a detailed understanding of the context, who are perhaps best 
placed to judge whether a comment will be effective and how best to 
make it so. 

• It is suggested, therefore, that immediately following the call in list we 
continue to have an agenda item called "comments on applications not 
called in". It is proposed, however, that this item should simply invite 
Members to note issues to their officers on any applications where they 
think issues are raised on which comment to their LA counterparts may 
be relevant. These will be noted in the minutes but it will then be for 
officers at their discretion to decide how best to address them, either 
through formal comment to the LA or informal discussion with LA 
officers with a view to securing the most effective means of conveying 
the CNPA comments and concerns on a particular case. 

• Finally, Members are also encouraged to speak informally with their 
officers outside the Committee meetings if they require clarification or 
want to highlight potential issues relevant to any application. Formal 
expression of views must of course still be within the context of the 
Committee meeting. 


Don McKee 
Head of Planning 
25 May 2005