CAIRNGORMS NATIONAL PARK AUTHORITY 
Title: PROCEDURE FOR OFFERING COMMENTS TO LOCAL 
AUTHORITIES ON PLANNING APPLICATIONS WHICH 
HAVE NOT BEEN CALLED-IN 
Prepared by: DENIS MUNRO, INTERIM PLANNING MANAGER 
Purpose 
This report has been prepared to provide the Planning and Development Control Committee 
with a procedure for preparing, considering and communicating comments to Local 
Authorities on planning applications which the CNPA has not called in. 
Recommendations 
That the committee approves the recommendations in paras 1 to 7 as the normal procedure 
for drawing up and submitting comments on planning applications which have not been 
called in. 
Executive Summary 
As the Committee are aware, it is important that decisions on whether or not to call in 
planning applications are based purely on the issue of whether a particular proposal raises 
issues of “general significance” for the CNPA. Those judgements must not be influenced by 
opinions on the merits of the proposal and whether it should ultimately be approved, with or 
without conditions, or refused. Maintaining a strict separation between those assessments 
can be difficult in cases where the CNPA has decided not to call in an application but wants, 
nevertheless, to offer comments to the Local Authority which will ultimately determine the 
application. This report contains recommendations which will help to maintain the necessary 
degree of separation. 
___________________________________________________________________________ 

PROCEDURE FOR OFFERING COMMENTS TO LOCAL 
AUTHORITIES ON PLANNING APPLICATIONS WHICH HAVE NOT 
BEEN CALLED-IN 
Discussion 
1. In the normal course of events, planning applications fall into two categories: 
(a) Those to be called-in and determined by the CNPA because they raise issues 
of general significance for the Park aims, and 
(b) Those which raise no such issues and will be determined by the relevant local 
authority. 
However, during the course of preparing the Protocol, it was recognised that there 
may be occasions when, in relation to category (b), the CNPA wish to pass a 
comment for the Local Authority to take into account when making its decision. 
Conversely, in relation to category (a) a Local Authority may wish to offer a comment 
for the CNPA to take into account when making its decision. 
2. I do not think there will be many occasions when the CNPA will find it appropriate to 
make comments since, broadly, if comments were worth making they would probably 
justify a call-in but that might not always be the case and it is important to have a 
clear procedure which avoids, in particular, any risk of mixing the process of making 
call-in/no-call-in decisions with that of forming reasoned judgements - with the 
benefit of all the relevant information - about the merits of applications. 
3. To maintain a strict separation between those parts of the committee’s business, I 
recommend that in dealing with items on the agenda requiring call-in/no-call-in 
decisions it never be the practice to advocate making comments to the relevant Local 
Authority about how it should deal with an application. To do so would involve 
having, partly or wholly, an opinion on what the outcome should be and, therefore, be 
open to the criticism that a judgement had been reached without adequate information 
in relation, for example, to consultation responses, objections and officer assessments. 
4. Therefore, on the basis that a proposal to make comments on an application may 
come either from a Board Member or Official, I recommend that the following 
procedures be followed. 
From a Member 
5. Provision will be made on each agenda for consideration of the need to submit 
comments on applications which the committee, earlier in the meeting, has decided 
not to call-in. A member advocating comments on a particular application will 
describe, broadly, the issue which justifies a comment and, if the committee agrees, 
officers will be instructed to bring forward a short report to the next committee with a 
review of the issues and suggested wording for the comments. Subject to approval, 
the comments will then be sent to the determining authority. 

From an Official 
6. If the Planning Manager is recommending “no-call-in” for an application but 
considers that there is a case for offering comments, a report explaining the issues and 
containing recommendations on the suggested wording for the comments will be on 
the agenda for discussion by the Committee after the conclusion of its consideration 
of the Call-in Report. 
7. As the process of preparing, considering and communicating comments may take at 
least one committee cycle there is a risk that the determining authority will have made 
a decision on the application before our comments are received and this is most likely 
in relation to minor householder applications many of which will be determined by 
officials using delegated powers. Our staff will advise their counterparts in a Local 
Authority that comments may follow a “no call-in” decision in these instances, but, 
because of the need to meet performance targets for processing applications, a delay 
in decision making may not be possible. This will not be a serious weakness in the 
procedure I have recommended above if, as I would encourage them to do, the 
committee refrains from taking an interest in minor house alteration/extension 
applications in any but this most sensitive locations. 
Denis Munro 
October 2003