WARNING - By their nature, text files cannot include scanned images and tables. The process of converting documents to text only, can cause formatting changes and misinterpretation of the contents can sometimes result. Wherever possible you should refer to the pdf version of this document. CAIRNGORMS NATIONAL PARK AUTHORITY Planning Paper 2 9 March 2007 CAIRNGORMS NATIONAL PARK AUTHORITY Title: REPORT ON CALLED-IN PLANNING APPLICATION Prepared by: MARY GRIER, PLANNING OFFICER (DEVELOPMENT CONTROL) DEVELOPMENT PROPOSED: FULL PLANNING PERMISSION FOR ERECTION OF TEN CHALETS AND ASSOCIATED GROUND AND ACCESS WORKS AT GRANTOWN ON SPEY CARAVAN PARK, SEAFIELD AVENUE, GRANTOWN ON SPEY. REFERENCE: 06/232/CP APPLICANT: GRANTOWN ON SPEY CARAVAN PARK, C/O A.W. LAING LTD., HIGH STREET, GRANTOWN ON SPEY, PH26 3EL. DATE CALLED-IN: 30TH JUNE 2006 Fig. 1 - Map showing the location of Caravan Park at Grantown-on-Spey (not available in full text format) SITE DESCRIPTION AND PROPOSAL 1. Full permission is sought in this application for the erection of ten chalets and associated ground and access works, on land which adjoins and is in the ownership of Grantown on Spey Caravan Park, off Seafield Avenue. The existing developed area of the caravan park is on relatively level ground and accommodates a mix of static ‘holiday home caravans’ (33%) and the remainder of the area is in use for touring caravan and camping pitches. The new chalets for which permission is being sought are on higher ground to the north of the existing developed area of the caravan park. The north western boundary of the proposed site area runs adjacent to the dismantled railway line. 2. The ten proposed chalets are all of uniform design and are standard pre-site assembled units. The elevation details and floor plans included in the initial application submission have been prepared by a Hull based company ‘Cosalt : Custom Homes’ which specialises in the manufacturer of leisure products, in particular the provision of temporary holiday accommodation. The proposed chalet type is the ‘Cezanne,’ which is one of the company’s Lodge selection. The exterior of the single storey pitched roof structures are proposed to be finished in timber linings, under ‘metro tile roof tiles.’ Each overall structure measures approximately 13 metres in length, with a span of 6 metres. The design incorporates two entry points - a single entrance door in the side elevation and double door in the gabled front elevation. The internal layout incorporates four bedrooms, two bathrooms and an open plan kitchen, dining and living area. The elevation drawings supplied show the structure resting on a wheeled base and indicate an overall ridge height of 4.175 metres including the wheeled base. Although not shown on the elevation drawings, a site section illustrates a decked area along the gabled frontage of the proposed chalets. The proposed chalets have been described in supporting documentation as ‘log chalet type units.’ Fig. 2 : Architect's drawings of Proposed ‘Cezanne’ type chalet 3. In response to concerns raised by the planning officer regarding the standard design of the structures, as opposed to being a unique design concept for the proposed setting, and also concerns regarding the temporary and mobile nature of the structures as detailed on the elevation drawings, further images were submitted by the agent. The images have been compiled from various websites and show similar chalets in situ on various sites. Reference has been made in particular to the potential to incorporate a solid brick / block or timber basecourse in order to “remove any suggestions of a temporary building.” Fig. 3 : Extract from www.westfield caravans.co.uk showing colour photos of the ‘Cezanne’ erected with brick basecourse Fig. 4 : Colour photo showing the method of delivery to site (extract from www.islandleisure.co.uk) Fig.5 : Colour photo of Chalets in place at Erigmore Estate Leisure Park. 4. The ten chalets are proposed on an elevated site, which is approximately 15 - 20 metres above the ground levels of the existing campsite and comprises largely of a wooded bank. This area is part of the hillside which runs in an arc along the western fringes of Grantown on Spey and is covered almost in its entirety by woodland. Within the subject site, approaching the uppermost areas of the bank, a level area has been created by excavations, which have according to details provided on behalf of the applicants been undertaken between 1988 and 2004. In providing a history of the use of the area the re-opening of an existing borrow pit in 1988 is detailed. The borrow pit was reopened to provide material for site works in the caravan park. The excavated area was subsequently extended in 1991 in order “to create a storage area for old holiday home caravans” and was again excavated in 2004 in order to provide gravel for a new toilet block. It has been conceded in documentation that 21 birch trees were felled and removed at that time, and a further 5 or 6 decaying birch trees were removed from the area on the advice of a Caravan Club Health and Safety Inspector. Figs 3 – 5 : Colour photos showing the excavated area of the proposed site 5. The ten chalets are proposed in a largely linear layout, with the majority of the gable fronts of the structures oriented in a southerly direction, to overlook the existing caravan park and afford views over Grantown on Spey and the wider rural area beyond. The site layout plan shows access to the proposed chalet locations being provided from two points. Access to the most northerly area of the proposed site would be via the existing access track which serves the area. The track at present is single carriage width, with an uneven surface and it winds it way up the hillside, sometimes at a significant gradient. It is proposed to create a road through the site, which would effectively traverse past the rear of the majority of the units, before leading downhill in the more southerly area of the subject site. The site plan indicates that the roads would be formed in compacted hardcore and it is also indicated that the ground in the vicinity of the road would be re-contoured in order to accommodate the road line. Fig. 6 & 7 : Colour photos of the existing access track serving the northern area of the proposed site. 6. The water supply to the site is proposed to be derived from the public supply and foul drainage is via a connection to the public sewer. It is proposed to dispose of surface water into a separate soakaway. 7. A detailed document has been prepared on behalf of the applicants in support of the proposal (please see attachment at rear of report for copy of full text). It documents the applicants1 involvement in the development of the caravan park, which was owned and operated between 1960 and 1988 by the Local Authority. The applicants leased the site in 1988 and eventually purchased it from Highland Council in 2004. Since becoming involved with the facility in 1988 the applicants have undertaken significant upgrading of the site. The work has been recognised through the achievement of a variety of awards and accolades2 (detailed in section 2.2.2 of the supporting documentation). 8. The park is open for the majority of the year, closing only for a six week period in November and December. During full occupation of all caravan units and tent pitches the park has a capacity of 850 people. Average touring pitch occupancy rates vary throughout the season, having an average of at least 50%, but often rising to 100% in July and August. In assessing the economic benefits of the existing facility, the supporting statement estimates that the park contributes approximately £2.15 million per annum to the local economy of Badenoch and Strathspey. The park at present also creates eight full time job equivalents3 and it is estimated that it supports a further six jobs indirectly through local spending on goods and services. Although no quantitative analysis has been provided, the supporting statement claims that the “proposed 10 new chalets will increase local spending by about £70,000 per annum”, increase employment at the park by one full time equivalent and contribute to supporting a further 1.5 fte4 jobs in the area. 9. The applicants propose to construct the ‘log chalet type units’ which are the subject of this application in an effort to meet a demand for accommodation of this nature which they feel is unmet at the present time. During the period in which the applicants were leasing the park from the Local Authority they owned approximately 10 holiday home caravans on the site which were available for hire on a weekly basis to tourists. The caravans were sold off in 2003 in order to raise capital for the purchase of the overall site and consequently there are no units of this nature available for short term holiday lets. The desire to build ‘log chalet type units’ stems from a belief that the structures would be more 1 Ms. Sandra McKelvie and her son Mr. John Fleming own the establishment as Grantown on Spey Caravan Park Partnership. 2 David Bellamy Conservation Gold Award in 2002, 2003 and 2004; David Bellamy Conservation Silver Award 2005; Practical Caravan ‘Best Park for Birdwatching’ 2005. 3 The 8 full time job equivalents comprise of 2 full time year round wardens; 2 full time wardens on a seasonal basis; a year round full time cleaner; 2 full time year round groundsmen and also two part time groundsmen on a year round basis. One of the owners also works full time at the park in the capacity of Managing Partner. 4 Full time equivalent. suitable for year round use, would fit better into the woodland location proposed and would allow the park to provide a more balanced range of visitor accommodation and consequently extend the operating season. Fig. 8 : Architect's drawing of the proposed site section DEVELOPMENT PLAN CONTEXT Highland Structure Plan 2001 10. Section 2.7 of the Highland Structure Plan discusses the economy and tourism in particular, noting that tourism is a vital element of the Highland economy. The identity of the Highlands includes “its built heritage, rich wildlife, scenic beauty, history and culture” which are described as the foundations on which tourism and recreation activities are based. The Structure Plan strategy aims to build on the Highland identity and to “take a proactive approach to the wise use of the natural environment as a primary resource” for tourism. 11. The Structure Plan notes that tourism makes major demands on infrastructure and facilities and also notes that there is scope for improvement in the quality and level of provision. Policy T2 on Tourism Development confirms Highland Council’s support for high quality tourism development proposals, particularly those which extend the season, provide wet weather opportunities, spread economic benefits more widely and provide opportunities for the sustainable enjoyment and interpretation of the area’s heritage. 12. On the specific topic of tourist accommodation, section 2.7.8 refers to a growth trend in recent years in the self-catering sector. In anticipation of further applications for chalet and other self contained accommodation, the Structure Plan advises that they must be designed for minimal impact on services, road infrastructure and the environment. Policy T3 on Self catering tourist accommodation expressly states that permission will only be granted for tourist accommodation proposals on the basis that the development will not be used for permanent residential accommodation. 13. The Highland Structure Plan includes a detailed section on the environment and topics such as nature conservation and landscape are discussed. Para. 2.13.1 notes that the abundance of natural habitats and species is a key element of Highland’s identity and constitutes one of the region’s main strengths. The Structure Plan details the hierarchy of protection of nature conservation interests, but also notes that such interests are not confined only to designated sites. Policy N1 on Nature Conservation requires new developments to minimise their impact on the nature conservation resource and enhance it wherever possible. 14. Section 2.14 of the Plan discusses Landscape where it is declared that “no other attribute of Highland defines more the intrinsic character and nature of the area than its landscape.” The Plan notes that associated with such landscapes are the communities that live in harmony with them and the wildlife that is adapted to their conditions. It is advised that the protection and enhancement of landscape and scenery must be positively addressed. Policy L4 on Landscape Character states that “the Council will have regard to the desirability of maintaining and enhancing present landscape character in the consideration of development proposals.” Badenoch and Strathspey Local Plan (1997) 15. On the general subject of Tourism and Recreation, section 2.2.9 of the Local Plan notes that activities of this nature will continue to make a vital contribution to the economy, but also emphasises that the priority is to ensure that “broadening the range and quality of facilities and accommodation is balanced with protecting the areas exceptional scenic and heritage resources.” The plan suggests within communities and on their edges that tourist accommodation, recreation and leisure facilities of a scale appropriate to the community concerned will be promoted. 16. Section 2.2.10 of the Plan, entitled Tourism, states that the “Council will encourage the development of tourist accommodation and facilities at suitable sites within or immediately adjoining communities” and that “priority will be given to expansion of existing facilities.” This secton of the Plan also requires that that tourism proposals should “either associate well with the prevailing pattern of building, or be well absorbed visually by landform and trees. 17. Under the general heading of Environment the Local Plan includes a section on Woodland and Trees (section 2.5.4) in which it is stated that the “Council will protect existing trees and established woodland areas including small groups or individual granny pines which are important landscape, wildlife and amenity features of the countryside.” It also clarifies that this includes significant areas of ancient and semi- natural woodlands incorporating important areas of remnant native forest as well as exotic specimens. 18. The landscape conservation policy is detailed in section 2.5.10. It is the policy to conserve areas of landscape importance including waterside land, open areas and scenic views. It is also advised that development proposals will be considered carefully in respect of their impacts on conservation and the environment. 19. Section 2.5.15 refers to Settlement Edges noting that in order to protect their identity and setting, and promote the orderly development of allocated land and supporting infrastructure, areas adjoining existing settlements will be protected from sporadic development. Furthermore, it emphasises that development should relate well to the landscape. 20. Part 3 of the Local Plan focuses on Grantown on Spey. The subject site is within the settlement area. The site area is identified as ‘Amenity Woodland’ and is part of a large swath of similarly zoned land which encircles Grantown on Spey. The Local Plan makes a clear distinction in land allocation terms between the proposed site area and the adjacent existing developed area of the caravan park, which is identified for ‘commerce / tourism purposes. Fig. 9 : Extract from the Badenoch and Strathspey Local Plan (1997) 21. Section 3.5.3 of the Local Plan discusses the ‘Amenity Woodland’ of Grantown on Spey, describing it as “mature dedicated woodlands adjoining Grantown” of major importance to the character and setting of the town, and also for informal recreation and wildlife. It specifically states that “there will be a strict presumption against any further encroachment of building within the woodlands, in order to safeguard their integrity in the wider public interest.” 22. With reference to Employment, Section 3.2.3 of the Plan refers to the caravan site stating that “1.5 ha. of land adjacent to the caravan site is allocated for expansion. Consideration should be given by the District Council to a comprehensive landscaping and planting scheme for the site.” The accompanying land use map does not make a distinction within the ‘commerce / tourism’ zoning between the part of the caravan park that was developed at the time of the Plan being adopted and the 1.5 ha. intended for expansion of the facility. CONSULTATIONS 23. Scottish Natural Heritage examined the proposal and noted that aside from the location of the site within the Cairngorms National Park, there are no other designated sites in this area. The response noted that the proposed development area is identified on the Inventory of Ancient and Long Established Woodlands as a long established woodland of plantation origin. Reference was also made to aerial photographs from 1988 which showed the proposed development area to be well covered with woodland, “with slightly sparser coverage in the northern corner of the site.” SNH note that the remaining woodland in this area is high quality with Scots pine, birch and willow present, and with a high density of hazel. In terms of the latter species, it was noted that this is unusual in Strathspey. The habitat is generally considered likely to support many plants and animal species. The response from Scottish Natural Heritage also noted that the woodland that has already been removed is likely to have been of similar quality. 24. In assessing the likely impacts of the proposed development on natural heritage interests, which are described as being of local importance, SNH noted that much of the woodland that would have been affected by the development has already been lost due to work that has taken place in the area. Had this not occurred the proposed development would have led to a loss of locally important woodland habitat and the additional proposed works in the area are described as being “likely to have a further impact on the woodland in this area.” 25. In order to minimise the impact on the natural heritage interest of the site and potentially provide screening of the development, SNH recommend that no further woodland areas or individual trees be removed from the site. SNH also suggest that some tree planting, using species that are present in the remaining woodland, would be beneficial for the site. 26. Scottish Water does not have any objection to this planning application. However the response notes that “although Scottish Water has given approval at this stage, this does not guarantee a connection to Scottish Water’s infrastructure.” It is advised that a separate application should be made for connection to Scottish Water’s infrastructure after the granting of full planning permission. 27. The response from Scottish Water also indicated that a totally separate drainage system will be required with the surface water discharging to a suitable outlet. In particular Scottish Water support for the principal of a sustainable urban drainage system was highlighted and the response advised that the developer should utilise this in the surface water drainage design. 28. The Area Roads and Community Works division of Highland Council examined the proposal and did not wish to make any comments. 29. In a detailed response from the CNPA's Natural Heritage Group the proposal has been discussed from the perspectives of landscape and ecological impact. In terms of landscape, reference is made to the proposed hillside location and the fact that the subject site is placed approximately in the middle of the hillside arc which runs around the western side of Grantown on Spey. The NHG consultation response quotes from the 2005 "Cairngorms Landscape Capacity for Housing"5 which describes the wooded slopes as 'very highly sensitive' for a number of factors, including landscape character and experience, settlement form and landscape setting and also describes it as 'highly sensitive' for the immediate settlement edge. In terms of landscape setting the "Cairngorms Landscape Capacity for Housing" describes the wooded slopes as contributing "to the landscape setting, by providing well established visual backdrop and defining the setting of the settlement." 30. The consultation response from the Natural Heritage Group comments that the subject site is approximately 15 - 20 metres higher than the general level of the campsite and floor of the strath. Reference is made to the many views from the site and it is also remarked that conversely there are also clear views from the surrounding area to the site, the clearest of which is from the western edge of Grantown on Spey, and especially from Seafield Road, Seafield Court, Dulaig and Beechen Court. In addition it is also noted that the site can be viewed from between housing and trees further into Grantown, "as well as from the upper floors of the taller buildings such as the many hotels in the area." In addition there are also distant views to the site from the hillsides to the east of Grantown. 31. NHG note that prior to the commencement of any development activity at the subject site, it was most likely a mature woodland consisting of birch, rowan, hazel and possibly some Scots pine. The site is described as a sensitive landscape receptor due to its central position within the wooded hillside and elevated location. The defining characteristic of the general area i.e. woodland, means that it is difficult to replace in the short to medium term, which is one of the factors contributing to the sensitivity and vulnerability of the site. 5 The Cairngorms Landscape Capacity for Housing is a study commissioned by the Cairngorms National Park Authority in April 2005 to assess the potential effects of new development on the character of the landscape surrounding twenty two settlements which lie within the CNP and to inform the emerging CNP’s Local Plan. 32. In appraising the impact of the proposed development from a landscape perspective NHG make reference to the works which have already taken place on the subject site. It is noted that the works already undertaken consist of a deep excavation resulting in a levelling of the area, leaving a tall and steep rear embankment running along the western side of the site. The existing access track has been carved across the slope and upon turning towards the top of the track, the achievement of an appropriate gradient has necessitated a separate cutting. The floor of the excavation is broadly level and a bund of between 1.0 metre and 1.5 metre high has been created around the front face of the northern section of the excavated area.6 Excavations have also occurred in the southern area of the subject site and there is evidence of trees and shrubs, such as birch and hazel, having been felled. NHG note however that the stumps remain in situ and are displaying some signs of regeneration. 33. The proposed development would also be likely to result in the ground levels on the subject site being lowered further - the details provided on the contoured site plan and cross sections are not of sufficient detail to determine this; the intention to further excavate the ground was confirmed by one of the applicants to officials from the Natural Heritage Group in the course of their site visit - and NHG have concluded that this would result in the felling of further trees. It is also noted that the excavations to date have had an impact on land elsewhere within the caravan site, as the excavated material has been placed on a flat area of wet grassland at the base of the hillside to an approximate depth of 1 metre. The surface has been covered with granite chippings and has been fenced on two sides by a tall timber palisade. 34. The extent of work that has occurred on the subject site to date, whether directly related to the development proposal or not, has already had a number of impacts on the landscape. The removal of large quantities of material has resulted in a reshaping of the natural landform and the report from NHG comments that "it gives an appearance not unlike a quarry." A scar has been created on the hillside by the cutting and it is visible in both summer and winter. In addition the area of the woodland has been cleared of tree cover, field layer vegetation and soils. In the event of the development proceeding the consultation response from the Natural Heritage Group notes that additional landscape impacts would include the following - the removal of further trees which would create a larger gap in the existing woodland; the removal of further material thereby creating a larger cut face and scar which would be visible from surrounding areas (and would also require disposal elsewhere); and the diminishing of the well defined settlement edge provided by the wooded slope and pattern of building and settlement on the flatter land. 6 Within the bunded area various materials, plant and temporary buildings have been placed. According to information recently submitted on behalf of the applicants the materials etc. are stored in this location for use elsewhere within the caravan site, and are not intended as part of the development proposal which is the subject of this planning application. 35. The Natural Heritage Group consider that the proposed development would create a "campsite style landscape in the middle of the woodland" which would introduce a completely new character that conflicts strongly with the secluded natural one of the original site as well as of the remaining surrounding woodland. It is commented that the proposed new chalets would be highly visible structures within this sensitive area and would play a large part in altering the character of the area, and in particular would reduce the positive effect of the hillside upon the location of Grantown. The size and nature of the proposed chalets would make them visible from a wide surrounding area, which would be at its most pronounced in winter, due to a combination of a lack of leaves on trees and lighting of the units. 36. In the concluding comments on landscape issues, the Natural Heritage Group state that the introduction of buildings in this location would take away the undeveloped 'natural' quality of the wooded hillside. In addition to the work which has already been undertaken at the site the erection of the chalets would have a considerably greater impact than the work to date and would "render the whole development a serious and permanent detractor to the character and amenity of the area." The development as it exists at present is described as conflicting with the first aim of the National Park and "completing it as proposed would increase the magnitude of the impact upon the landscape character considerably and therefore heighten the conflict with the first aim of the Park." Given the work that has been undertaken to date the site would be difficult to restore in anything other than the long term and completion of the proposed development would make any remedial action and landscape mitigation difficult, or indeed impossible to achieve. From a landscape perspective, the Natural Heritage Group recommend that permission be refused for the development and in addition that remedial action be undertaken to repair some of the damage already caused. 37. From an ecological perspective it has been difficult to ascertain the type and condition of habitats on the site due to the work that has already been carried out there. Based on an examination of the ecological character of the woodland immediately surrounded the felled and excavated area, as well as from remnant trees and recently cut stumps and brash on the site, it is concluded that an area of mature, broadleaved woodland consisting of birch, rowan and hazel, has been cleared from the site. The removal of a considerable volume of soil over a large area has destroyed the woodland ground flora. 38. In examining the site it was noted that a handful of prominent, mature trees have been left around the fringes of the site, but even some of these have suffered mechanical damage to boughs. Additionally the creation of the access track to the site has resulted in considerable damage and has exposed the roots of several trees which line the track. It was noted in particular that the ground around the root plate of one impressive mature Scots pine located at the northern end of the site is likely to experience soil compaction and further damage to the roots, as the area is currently used to store building materials, including sand, bricks, timber and a cement mixer. 39. As referred to in the course of the Natural Heritage Group's consideration of the landscape impacts, it was noted that excavations within the site have given rise to impacts outwith the application site, in particular the grassland area on the lower level of the caravan park. The area of wet, semi improved grassland downhill of the woodland site has been lost due to the "dumping and subsequent levelling and surfacing with stone of excavated material from the woodland site." It was noted that four mature birch trees in this area have either died or are showing signs of stress brought about by the pressure of the deposited soil and stone. 40. The NHG response notes that some mitigation of the damage already done in the overall area is possible, and comments that there are a wide range of restoration options using a combination of techniques such as hydro seeding, bio mats, natural regeneration and refilling of the excavated area. It was highlighted however that the grazing and browsing of rabbits and deer in the area would have to be controlled in order to ensure a successful outcome. This would require the area to be stockfenced with rabbit proof netting, and planted trees would also require protection from roe browsing with the use of tree tubes. In their concluding comments on the ecological impact on the area the Natural Heritage Group stated that the construction of chalets would make any mitigation measures much harder to achieve. 41. The CNPA's Economic and Social Development Group also examined the proposal and in the consultation response noted that the Caravan Park is currently assessed as a 5 star facility under VisitScotland, commenting that this shows a commitment to quality. The response also noted that there are no other groups of chalets in the Grantown area (although there are some individual self catering units) and consequently the proposal for 10 chalets is unlikely to give rise to displacement locally. It was also noted that chalets can help extend the tourism season, offering appropriate accommodation during the winter months. 42. Grantown on Spey Community Council was consulted on the development proposal although at the time of preparation of this report no response has been received. REPRESENTATIONS 43. No representations have been received in respect of the proposed development. APPRAISAL 44. There are a number of issues to take into account in determining whether or not the proposed development is appropriate. It is necessary to consider relevant planning policies from both Highland Council’s Structure Plan and the Badenoch and Strathspey Local Plan, take into account the impact of the development on the aims of the Cairngorms National Park, examine siting and design issues, and also take into account the case advanced for the development on behalf of the applicants. 45. Paragraphs 10 – 22 of this report detail the Structure Plan and Local Plan policies applicable to the site. Each of the Plans include general policies which are supportive of the tourism industry and the Structure Plan recognises that there has been a growth trend in recent years in the self catering tourist accommodation sector. The support expressed in the Plans for the general growth of the industry and the associated provision of new or improved facilities does not however automatically render all such developments acceptable. The Structure Plan, for example, requires developments of self catering tourist accommodation to be designed for minimal impact on services, road infrastructure and the environment and also requires all new development to minimise the impact on the nature conservation resource and enhance it wherever possible. The proposed development involves the creation of a significant and mostly new road network which would lead uphill from the existing lower ground of the caravan park to the proposed development site, traverse to the rear of the proposed location of the chalets thereby necessitating further excavations of the hillside, before travelling downhill from the opposite end of the site. The infrastructural requirements alone of the proposed development would necessitate extensive excavations and the removal of much of the remaining tree growth on the site. Such actions cannot be considered in compliance with the Structure Plan policies referred to above. 46. In terms of the Badenoch and Strathspey Local Plan (1997) tourism is recognised as continuing to make a vital contribution to the economy. However, as detailed in paragraph 15 the Local Plan also emphasises that development in this sector should be balanced with protecting the areas exceptional scenic and heritage resources. The Local Plan undoubtedly encourages the development of tourist accommodation and facilities at suitable sites within or immediately adjoining communities and in particular advocates giving priority to the expansion of existing facilities. I accept that the proposed development of ten chalets is intended as an expansion of the existing tourist accommodation provision offered within the established area of Grantown on Spey Caravan Park. However, the proposed location does not represent a natural expansion of the developed area and the subject site is in fact detached from the existing facility, with the steeply rising hillside, on which it is proposed forming a physical barrier. 47. The most significant aspect of the Local Plan policies affecting the proposed site is the actual land use allocation and the associated policy. The site is identified as ‘Amenity Woodland’ and is part of a wider area of similarly zoned land surrounding much of the developed area of Grantown on Spey. The Plan quite clearly recognises the importance of the entire woodland area to the character and setting of the town – a fact which has also been emphasised in considerable detail in the consultation response from the CNPA’s Natural Heritage Group – and consequently the Plan advocates a strict presumption against any further encroachment of buildings within the woodlands, in order to safeguard their integrity in the wider public interest. 48. The proposed development would be entirely contrary to the land use allocation attributed to the subject site. Supporting documentation submitted in February 2007 (please refer to attachment) suggests that the presumption against further development should be taken only to refer principally to the main Anagach Woods, which are now community woodlands, and not the subject site. It is a suggestion which is not supported in any way by the Local Plan land use allocation and associated policies. The fact that the subject site is now in the ownership of the applicants, as opposed to larger pockets of similarly zoned woodland in the vicinity which are part of the community woodland, does not in any way confer development rights on private landowners in contravention of the land use allocation. Therefore I reject the comments made in the supporting documentation which state in relation to the presumption against development in the Amenity Woodland that “its blanket application to the woodland within the Caravan Park would be unreasonable.” 49. It is also worth noting that at the time of the preparation and adoption of the Badenoch and Strathspey Local Plan (1997) the actual caravan park was in the ownership of Highland Council, i.e. the same Authority that ultimately allocated the land which is the subject of this application as ‘Amenity Woodland’ and clearly in allocating it did not consider it as a potential extension of the caravan park or did not consider it appropriate to introduce any policy which would treat the area differently from the general policies relating to the Amenity Woodland area. The applicants, although having leased the caravan park from the Council since 1988, only purchased the caravan park in 2004, presumably with full knowledge of the land use allocations pertaining to the area. 50. As already detailed in paragraph 20 of this report (and as also detailed in Fig 9), the Local Plan makes a clear distinction in land use allocation terms between the proposed site area and the adjacent caravan park, where the latter is specifically identified for ‘commerce / tourism’ purposes. The area identified for ‘commerce / tourism’ purposes when the Plan was adopted in 1997 incorporated the area of land referred to in Section 3.2.3 of the Plan, namely “1.5 ha.of land adjacent to the caravan park” allocated for expansion, which I understand has largely been carried out or is in the process of being carried out. 51. In addition to the principle of the development being unacceptable, I also have considerable concerns regarding the actual siting and design. The proposed location is on significantly higher ground than the established caravan park and the Grantown settlement area in general. Simply because the site is part of a woodland area does not negate the negative visual impact which the development of ten chalets and the associated infrastructure, in particular access roads, car parking provision etc. would result in. The introduction of buildings and associated works in this elevated area on the settlement edge would, as commented in the consultation response from the CNPA’s Natural Heritage Group, take away the undeveloped ’natural’ quality of this wooded hillside. 52. Had the principle of the development been acceptable in terms of land use zoning, the opportunity to accommodate the development on this site would still remain limited, in part due to the extent of tree loss that has already occurred in the area as a result of works which have been carried out in the past. There is evidence of the felling of an area of mature, broadleaved woodland consisting of birch, rowan and hazel. Aside from the destructive impact on the natural heritage of the area, such felling activities have resulted in the subject site being opened up to a greater extent than would otherwise be the case. Had the trees remained on site their foliage may have provided more effective screening and coverage for significant periods of the year and in so doing assisted in assimilating any buildings in the area into the landscape. 53. The site layout which is largely linear in form, apart from minor deviations in the orientation of some of the proposed structures, does not represent any real effort to take account of and work with the natural contours and features of the site. Instead the layout displays a type of suburbanised uniformity, which is being superimposed on the landform in an unnatural manner. The contoured site plan and associated sample site section are not of sufficient detail to accurately ascertain the extent of further excavations that would be necessary in order to facilitate the development. It is however known that the siting of the units, as well as the construction of the associated road network, would necessitate further excavations on the site. This would result in further damage in an area where past works have resulted in it taking on an appearance similar to a quarry. Given that a scar has already been created on the landscape due to the combination of past tree felling and excavation activity, further excavations and the erection of the proposed structures in the area would only serve to exacerbate the negative visual impact. 54. The intentions of the applicants are to be commended in seeking to provide a higher quality of service and facilities for their clients, and indeed their efforts to date in developing the caravan site and winning several accolades in the process must also be acknowledged. However, this does not alleviate concerns regarding the design of the proposed structures. Earlier sections of this report provided details of the nature of the units proposed, which are essentially pre assembled units, of a standard design, manufactured remote from the site and transported to the site on wheeled bases. The proposed structures have not been designed to reflect the unique qualities and setting of the site. Even with the addition of block or timber base courses, which admittedly give the proposed unit’s a more permanent appearance than that portrayed in the elevation drawings incorporating wheel bases, the units remain quite similar to large static caravans, albeit with the addition of pitched roofs and timber cladding. One must question the appropriateness of such structures for the provision of new self catering tourist accommodation within the Cairngorms National Park. Within such an area the emphasis must surely be placed on raising overall standards of siting and design. Accepting the proposed structures would in essence promote uncertainty about the design standards acceptable within the Cairngorms National Park. In addition to the foregoing siting and design concerns, it is also worth noting that the application documentation failed to include any comprehensive landscaping plan for the subject site, which would be fundamental to any efforts to assimilate the development into the landscape. 55. The impact of the proposed development on the natural heritage of the area has been documented in detail in earlier sections of this report. The development would have negative effects on two counts. Firstly it would result in irreparable changes to the landscape character of the area and would diminish the quality of the wooded slopes of the settlement edge of Grantown on Spey. This is of particular significance given that the wooded slopes have been described in the Cairngorms Landscape Capacity for Housing as being ’highly sensitive,’ as well as defining the setting of the settlement. 56. The second impact that the development would have on the natural heritage of the area is in relation to ecology. Work which has previously been carried out on the subject site has already resulted in the loss of trees, has caused damage to a number of the existing trees remaining on and in the vicinity of the site and has also had negative impacts outside the identified site boundaries. In particular dumping and levelling of excavated material from the subject site has resulted in a wet semi improved grassland area downhill of the site being lost. In assessing the natural heritage implications of the proposed development, the advice of the Natural Heritage Group, as detailed in paragraph 38 of this report, is of particular importance. At present mitigation of the damage that has already resulted from the carrying out of works within the subject site remains possible through a combination of restoration techniques. The construction of the proposed chalets would however make any meaningful restoration of the site extremely difficult to achieve. 57. In conclusion, having regard to the fact that the proposed development is contrary to planning policies and in particular the land use allocation of the area, together with the negative impacts in terms of visual amenity and impacts on the natural heritage of the area and the precedent the development would set for the further erosion of designated ’amenity woodlands’, it can only be concluded that both the principle of the development, as well as the detail of the siting, layout and design is unacceptable. In addition, having regard to the damage that has already occurred on the subject site, it is clear that there is a need for restoration of the area as soon as possible. IMPLICATIONS FOR THE AIMS OF THE NATIONAL PARK Conserve and Enhance the Natural and Cultural Heritage of the Area 58. The proposed development would have a negative impact on the natural heritage value of the area as development at this location would result in the loss of further trees, significant changes in ground levels and overall in appropriate alterations to the landscape character of the area. Promote Sustainable Use of Natural Resources 59. In light of the fact that the elevation drawings submitted show standard chalets, pre manufactured off site (in this case apparently by a Hull based company), the origins of the materials are not known. In addition, the pre-manufactured nature of the structures will give rise to significant transport movement between the manufacturing unit and the subject site. Promote Understanding and Enjoyment of the Area 60. The proposed development would provide an accommodation opportunity for tourists wishing to holiday in the area, but other than this direct benefit to those choosing to avail of this accommodation option, the overall development would fail to promote any understanding or enjoyment of the area by the wider public. In addition, it is considered that the elevated and exposed location of the development, the almost linear layout and the overall design of the structures would detract from the general public’s understanding and enjoyment of this area of the Cairngorms National Park. Promote Sustainable Economic and Social Development of the Area 61. The development would be likely to have positive benefits in promoting economic development in the area in the course of the construction period and later by encouraging visitors to holiday in the area and potentially extending the season into the winter months. The economic benefits cannot however be definitively quantified at this stage. The development would not make any direct contribution towards promoting the social development of the area. RECOMMENDATION 62. That Members of the Committee support a recommendation to (A) Refuse full planning permission for the erection of ten chalets and associated ground and access works at Grantown on Spey Caravan Park for the reasons listed hereunder : - 1. The proposed development by reason of its elevated siting in a woodland area which forms part of the settlement edge of Grantown on Spey, and where the development would result in the loss of additional areas of woodland and consequent changes to the landscape character of the area, would be contrary to the provisions of the Highland Structure Plan. It would be contrary in particular to Policy L4 on Landscape Character which refers to the desirability of maintaining and enhancing present landscape character and also Policy N1 on Nature Conservation which requires new developments to minimise their impact on the nature conservation resource and enhance it wherever possible. 2. The proposed development is located on land which is identified in the Badenoch and Strathspey Local Plan (1997) as ‘Amenity Woodland’ and is outwith the caravan park area, where that land is identified in the Plan for ‘commerce / tourism’ purposes. Development within the ‘Amenity Woodland’ would be contrary to Section 3.5.3 of the Local Plan where it is expressly stated that there will be a strict presumption against any further encroachment of building within the woodland. The development of ten chalets within this woodland area would set a precedent for further inappropriate development of this nature within the woodland areas surrounding Grantown on Spey and would lead to the gradual erosion of the woodland area which forms the settlement edge of the town. 3. The proposed development by reason of its inappropriate siting, layout and design in an elevated and highly visible location would be detrimental to the visual amenity, quality and overall character of the local landscape. The proposed development would be injurious to the landscape character of the area and would reduce the positive effect of the wooded hillside on the town of Grantown on Spey. The development would result in the loss of further woodland, thereby diminishing the well defined settlement edge, and would also involve significant excavations in the area. The overall development would represent a serious and permanent detractor from the character and amenity of the area, would fail to conserve or enhance the natural heritage of the area and would detract from the enjoyment of the rural qualities of this area by the general public. It would therefore be contrary to the first and third aims of the National Park. The proposed standard kit design of the holiday chalets also does little to achieve compliance with the second aim of the National Park. The proposed development would create an extremely prominent precedent for unsympathetically designed and landscaped new developments in the National Park. And (B)Resolve to authorise the taking of enforcement action as necessary in order to secure the appropriate restoration of the site. Determination background : This planning application was 'called-in' by the CNPA's Planning Committee on 30th June 2006. Following an assessment of the proposal, including site visits and the receipt of various consultation responses, a detailed letter was issued to the applicants agent on 31st August 2006, outlining the difficulties associated with the proposal and requesting further information and clarification on a number of issues. A meeting was also held with one of the applicants in October 2006 in order to discuss the proposal and the extent of additional information required. The information was submitted to the CNPA on 2nd February 2007. Mary Grier planning@cairngorms.co.uk 1st March 2007 The map on the first page of this report has been produced to aid in the statutory process of dealing with planning applications. The map is to help identify the site and its surroundings and to aid Planning Officers, Committee Members and the Public in the determination of the proposal. Maps shown in the Planning Committee Report can only be used for the purposes of the Planning Committee. Any other use risks infringing Crown Copyright and may lead to prosecution or civil proceedings. Maps produced within this Planning Committee Report can only be reproduced with the express permission of the Cairngorms National Park Authority and other Copyright holders. This permission must be granted in advance.