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 6 29 July 2005 CAIRNGORMS NATIONAL PARK AUTHORITY Title: CONSULTATION REPORT: CNPA RESPONSE TO ANGUS COUNCIL NOTICE OF INTENTION TO DEVELOP APPLICATION. Prepared by: ANDREW TAIT, PLANNING OFFICER (DEVELOPMENT CONTROL) DEVELOPMENT PROPOSED: CONSTRUCTION OF RANGER CENTRE, AT VISITOR CAR PARK, GLEN DOLL, ANGUS (FULL PLANNING PERMISSION) REFERENCE: APPLICANT: ANGUS COUNCIL DEADLINE FOR RESPONSE 1 AUGUST 2005 Fig. 1 - Map showing location of Glen Doll Car Park, Glen Clova (not available in full text format) SITE DESCRIPTION AND PROPOSAL 35. This report has been prepared at short notice to provide a formal consultation response to Angus Council in relation to the above application. The scheme was presented to the Planning Committee on the last call-in list. Because the application is in the form of a ‘notice of intention to develop’ the Park could not under current planning arrangements call-in the proposal. However, the nature of the development and its location was considered to raise relevant issues with regard to the aims of the Park and so it was resolved that a considered response should be provided to Angus Council and this report is intended to form the basis for that consideration. There may also be funding considerations for the Park Authority. However, they are a totally separate matter from the planning assessment of this scheme. 36. The site location is at the end of the single-track road, which leads up from the Clova Hotel to Glen Doll and is within the Deeside and Lochnagar National Scenic Area. The site is at the northern end of a substantial visitor car park within a dry stone wall enclosure, which hosts several small trees that would be removed to accommodate the proposal. The site is bordered on two boundaries by fields used for grazing with Jocks Road right of way that leads to Braemar passing along the western boundary of the site. The River South Esk passes approximately 40 metres to the east. The site is generally flat and partly screened by a range of trees. An existing small visitor information centre on the car park would be removed, as would toilet blocks to the south east of the site. It is understood that there was formerly a Scottish Natural Heritage (site owners) building on the site, which was removed. The general environment of the site consists of the car park with grassed areas and picnic benches; there is a range of mature trees around the site. Fig. 2 colour photograph showing site for ranger base within dry stone wall enclosure (not available in full text format) 37. Glen Doll is a significant visitor destination within the National Park receiving some 63,000 visitors per annum. The site is within easy access of Perth, Dundee, Fife, approximately 315,000 people live within 90 minutes drive of Glen Doll. The car park site provides access to a range of Munro’s and the Jocks Road and Capel Mounth routes across the mountains. Corrie Fee National Nature Reserve, managed by Scottish Natural Heritage is some 3.5 km from the car park. 38. The intention of the scheme is to replace the ranger base at Braedownie Farm, approximately 400 metres to the south east of the application site, which is currently regarded as unsatisfactory. The building proposed is intended to incorporate office and staff accommodation as well as a reception/exhibition space for visitors linked to a large multi-purpose project room that can be used for educational purposes. 39. The building is of an ‘L’ shaped design and sited so that its front elevation faces towards the car park. The front elevation incorporates a screened walkway and a glazed entrance lobby. The front section of the building incorporates the reception area and staff facilities. A projecting section behind houses the project room and is divided from the reception by a sliding screen, to create a flexible space. The windows are positioned in the building to provide key views out to the surrounding hills, enabling interpretation of the hills from inside the building. 40. The building is single storey, the front section housing the staff facilities is flat roofed and the project room to the rear has a pitched roof. The external materials will generally be locally grown larch, untreated so that it weathers to a silvery grey. The building will have timber pile foundations. The pitched roof section would be finished in timber also and the intention is that the flat roofed section will be covered in locally sourced gravel. The proposal also includes a landscape plan. 41. A full report is provided with the application, which includes a design brief and landscape report. There are three other buildings (2 toilets and visitor building) at the site and it is the intention that these would be removed. DEVELOPMENT PLAN CONTEXT 35. In planning policy terms the area is covered by the Angus/Dundee Structure Plan 2001-2016 and the Angus Local Plan. 36. Structure Plan Environmental Resources Policy 2: The Wider Natural Heritage considers that the Local Biodiversity Action Plan produced for the Cairngorms will constitute a material planning consideration in determining development proposals. All developments must respect main features and characteristics of the natural heritage and should contribute to landscape restoration or improvement, biodiversity conservation and enhancement, environmental quality and where appropriate, promotion of public enjoyment and understanding. Developers will be encouraged to incorporate positive environmental features that either enhance existing or create new habitats networks, such as native trees and woodlands; lochs, ponds, wetlands and watercourses; traditional field boundaries; unimproved grasslands; and coastal habitats. 37. Angus Local Plan Policy ENV 6 Development in the Countryside considers that developments in countryside areas will be considered on their own merits against the policies established by the Local Plan. 38. Policy ENV: 7 of the Local Plan considers that development affecting National Scenic Areas will only be permitted exceptionally where it can be adequately demonstrated that either: ii) the proposed development will not compromise the underlying objectives and overall integrity of the designated area; or jj) there is an overriding and proven public interest where social or economic considerations outweigh the scenic quality interest and integrity of the area and the need for development cannot be met in other less visually damaging locations or by reasonable alternative means. 1. Policy ENV 8 Conservation of Landscape Character considers that proposals should follow the guidance provided by the landscape character assessment on how various types of development or land use changes might best be accommodated within the different landscape areas identified, and on their capacity to absorb these changes, to conserve characteristic landscape features and to strengthen and enhance landscape quality. All development proposals in the countryside will be considered against a range of criteria including. ii) sites selected should be capable of absorbing the proposed development to ensure that it fits into the landscape; jj) where needed landscape mitigation measures such as screening should be in character with, or enhance the existing landscape setting; kk) development should be compatible with its surroundings in land use terms and not result in a significant loss of amenity to the local community; ll) areas of landscape, environmental or scientific value should be avoided; mm) in relation to new buildings/structures, development should respect the existing pattern of building in terms of scale, siting, form, design, colour and density of development; nn)priority should be given to locating new development in villages or building groups in preference to isolated development. 35. Policy ENV 13 Natura 2000 and RAMSAR sites considers that development likely to have a significant effect on a site designated or proposed under the habitats or birds directive (Special areas of Conservation and Special Protection Areas) and not directly connected with or necessary to the conservation management of the site, must undergo an appropriate assessment as required by Regulation 48 of the Conservation (Natural Habitats etc.) Regulations 1994. The development will only be permitted where the assessment indicates that: - ii) it will not adversely affect the integrity of the site; or jj) there are no alternative solutions; and kk) there are imperative reasons of overriding public interest, including, for sites hosting non-priority habitat types or species the only overriding considerations are human health, public safety, primary environmental benefit or other reason subject to a opinion from the European Commission (requested by the Secretary of State under Regulation 49). INTERNAL CONSULTATION RESPONSES 36. Visitor Services and Recreation Group (VSRG) have provided detailed comments upon the scheme and its background and these comments are attached at the back of the report. 37. VSRG give a clear indication of nature of the site and its popularity. The CNPA worked in partnership with Angus Council on a study to assess the feasibility of the development of a new ranger base. It was identified that no single site would effectively cover Glens Prosen, Clova and Mark. There was a strong steer from Angus Council, SNH and FCS that the visitor pressure and the site management needs at Glen Doll meant that the base needed to be located in that area. The management needs of the National Nature Reserve were a significant factor in the discussion. The CNPA asked for other locations to be considered, but after further investigation it was felt that a base at Glen Clova would not reduce pressures at Glen Doll, and that visitors may by pass such a facility. 38. In conclusion there is a clear need for a ranger base in the Angus Glens and a need for intensive site and visitor management at Glen Doll. While a ranger service is required elsewhere in the Glens, the demands are not as critical as at Glen Doll. VSRG support the development of the proposed base and feel that it amply meets the aims of the National Park. The development has great potential for promoting understanding and enjoyment of the special qualities of the Park to a population who may not visit other areas of the Park. 39. Economic and Social Development note that Angus exhibits average unemployment, lower wages and less working age people set against Scottish averages, so new development is to be welcomed. With large numbers of people visiting the glens it is important not only to educate and inform people, but that they are directed by a tourist information service that is not focused and outwith the glens and park area. There are obvious positive impacts for residents of the Park, amongst them; young people will be able to interact more easily on school trips in the Glens. This will have longer-term impacts in attracting more young people into environmental training. 40. The Angus Glens need to develop their identity within the National Park and at present lack a focus or role. By building on its natural qualities, the base will help develop the area as an educational and personal development hub which utilises natural qualities more sustainably than before. 41. Natural Resource Group (NRG) have provided a detailed response on the application and consider that the proposal does not appear to have any significant detrimental natural heritage impacts and the accompanying report comprehensively considers the landscape and visual impact of the proposal. NRG agree that the proposal does not significantly impact on the landscape of the Angus Glens area and the use of natural materials in the building will be in general keeping with its surroundings. 42. The main natural heritage consideration here will be the services associated with water use and effluent disposal. The site is close to the River South Esk, a candidate Special Area of Conservation for Atlantic salmon and freshwater pearl mussels. The involvement of SEPA should help ensure that there is no impact upon these conservation interests. 43. The proposal should make more of the building’s location amongst the trees and location next to the river by incorporating bat boxes in suitable locations and ensuring that any timber preservative is bat friendly. 44. The interpretation facilities proposed would help to enhance enjoyment and understanding of the National Park’s special qualities, thereby helping to inform and foster responsible use of the area. REPRESENTATIONS 35. No representations received by CNPA. APPRAISAL Introduction 36. The proposal presents a wide range of planning issues and many of the detailed considerations with regard to highways, parking and drainage will be dealt with by the determining authority. It is understood that some objections have been raised to the proposal and the Council will now have to refer the application to the Scottish Executive. The development plan context section of this report is largely for informative purposes, as Angus Council Planners/Scottish Executive will make an assessment of the proposal against these policies. However, it is my view that the proposal does not offend the development plan. 37. This report is styled very much in the way that previous consultation reports have been structured with an assessment of the proposal made against the four aims of the Park. However, is must be recognised that any comments provided to Angus Council through the commenting procedure are of an informal nature and do not carry statutory weight. 38. The detailed response from VSRG (see back of report) sets down the strategic issues and reasons why Angus Council have chosen this site for the application. A range of other potential areas were considered in Glens Prosen, Clova and Mark. The CNPA specifically asked for other locations to be considered, but after further investigation it was felt that a base at, for example, Glen Clova would not reduce pressures at Glen Doll and that visitors would simply bypass the facility, or stop for a short time and then move up the glen. It was considered that a location at Clova would hinder site and visitor management at Glen Doll. However, the Doll location would not preclude rangers from working in other glens, it would simply add to journey time. As noted by VSRG there was a strong steer from SNH and FCS that the new base should be located at Glen Doll and the management needs of the National Nature Reserve were a strong consideration. 39. While as outlined above there a wide range of strategic issues behind the location of the base, and while I would not want to curtail discussion of these wider issues it is important to recognise that this is site chosen by the applicants and is the formal planning application site which the CNPA must come to a view upon in terms of its acceptability. Conserve and Enhance the Natural and Cultural Heritage of the Area 35. The site is located adjacent (approx 40 metres) to the River South Esk Special Area of Conservation, which is designated for its populations of Atlantic salmon and freshwater pearl mussels. The site is not immediately adjacent to the banks of the river and the Natural Resource Group has been consulted and raised no particular objection. It should also be recognised that SEPA and SNH should be consulted upon the application. While I have not been able to contact the case officer for the application I understand that the file indicates that these organisations have not been consulted. Because of this, part of my recommendation requests that they are consulted. 36. In natural heritage terms the site hosts a number of saplings that would have to be removed. However, these are small self-sown trees that contribute little to the overall character of the area. The site for the building is within a dry stone wall enclosure, the ground has been disturbed in the past and this is indicated by the predominance of nettles within the enclosure, the site has only a slight rise to the west and the building would not require any significant cut and fill to be accommodated at the site. Given this, there are considered to be no significant negative impacts on natural heritage and this is recognised by the comments from the Park’s Natural Resource Group. A garden is also to be provided at the rear of the building and this would be likely to contribute towards educating visitors about the natural heritage. The further addition of wildlife features in the intrinsic design of the building could further contribute towards the Park’s natural heritage aim. 37. In terms of existing cultural heritage the building is likely to have little impact upon the site and the toilet blocks and existing information centre to be removed will reduce the general scatter of small buildings in the area. Part of the dry stone wall enclosure will be retained. 38. Some concern has been raised that the existing temporary ranger base at Braedownie could be used, or that disused traditional steading buildings at this site could be re-used to accommodate the ranger service and visitor facility. Purely in terms of cultural heritage, the reuse of these buildings would be a positive step and ensure that the buildings are retained and maintained into the future. If purely a ranger base was being proposed this could well be a preferable option. However, the proposal effectively provides a visitor centre and project room for visitors to the Glen. The existing car park provides a starting point for a range of walks in the area, but what became clear from my visit is that the car park and its grassy environs with picnic benches close to the river, taken together with fine views out of the site means that for many visitors, the car park is a destination in itself. Many people who visit the site, particularly with families and those that may be less able, experience the countryside from the immediate environs of the car park. In addition, the car park has been well known to visitors over a number of years, is recognised in international guide books to the area and has an existing small visitor building. This is why, in my view it is much more practicable for the building to be located at the car park, which is the visitor focus at the end of the glen. Locating a new visitor centre at Braedownie would in my view lose the focus point that the car park and its environs provide and possibly encourage driving between the two sites. A footpath between the two sites could perhaps be provided, but this is largely speculation about a scheme that is not before us. It is important to note that Angus Council do not own the site at Braedownie and consider it to be in the wrong place with buildings that are not of a suitable design. 39. The building has a rather unusual contemporary design with a large flat roof presenting to the car park, a rear projecting element of the building will incorporate a steep pitched, timber finish roof in the style of the existing building on the site. The application comes with a very detailed landscape and visual impact assessment to show how the building fits into its surroundings and shows that the building would not be visible from the hills. I have no concerns with regard to this as the site for the building is in the valley bottom, next to the large car park and there are other buildings around in the area, certainly on sunny days it is much more likely that parked cars would be visible from a distance than the building proposed here. 40. In terms of its detailed siting the building makes good use of the dry stone wall enclosure and surrounding vegetation. The flat roof section of the building presents to the car park and in part it is the intention that this reduces the overall impact of the building in visual terms. However, given that the building would be clearly visible from the car park and is intended as such to announce itself visitors I can see no aesthetic justification for a flat roof, when a pitched roof would be more typical of the buildings in the area, and can be more pleasing to the eye. Some discussions had been carried out regarding whether this section could be a green roof as such and in one sense this would provide a strong justification for the flat roofed design by adding benefit to the natural heritage aim of the Park. This is reflected in the response of the Natural Resource Group who consider that the building could make more of its position close to trees by providing bat boxes and ensuring that the building contributes more to biodiversity in line with recent initiatives by the CNPA to promote biodiversity in buildings. 41. In terms of cultural heritage the proposal would provide an interesting contemporary building at the head of the glen with minimal landscape impact that would be well related to its users. While I have no specific knowledge in relation to the former uses of the site, prior to the SNH building that was removed I note the dry-stone wall enclosure in which the building is located and it would seem pertinent to ensure that an archaeological survey of the site is carried out prior to the determination of the application to find out whether there is an archaeological interest at the site. Promote Sustainable Use of Natural Resources 35. The location of the building reinforces the existing use of the site as a car park with existing information building and toilets nearby, the location of the centre away from this key location at the head of the Glen may well encourage more driving and discourage the use of the existing facilities at the site such as the picnic benches. 36. The credentials of the proposed building, as set down in the report that accompanies the proposal indicate a building that is designed along sustainable lines. The main external finish would be locally sourced larch, an existing stone enclosure within which the building is sited will be part retained/part re-used to enclose the rangers educational garden. Gravel for the flat roof would also be sourced locally. The building would be heated by a geothermal system. Promote Understanding and Enjoyment of the Area 35. The popularity of Glen Doll for both enjoyment and understanding is not in doubt, whether it be enjoyment in terms of the challenging walks in the area, or use of the immediate environs of the site for picnicking. The small visitor building at the site also contributes to the understanding of the special qualities of the area with a small display and a range of leaflets. 36. In my view, the proposal clearly contributes strongly to this aim The site as it stands is already an important resource with regard to this aim and the new building will provide information to guide and manage visitors not just in the immediate vicinity of the site, but over a wider area. The key factor is that the building will house the ranger service at this key site ensuring that the rangers are much more accessible to the public at large. The addition of the garden at the rear of the centre would be a key feature both in interpreting the area for visitors in general but would also be an important feature for those who are less able to move away from the car park and as with the Ben Humble garden on Cairngorm would bring the wider environment into focus at the centre. 37. The orientation of the building faces the car park, so it would form a crucial feature in terms of visitor management at the site, the circulation system at the car park would be changed so the cars would enter the upper part of the car park, ensuring that the ranger base is the first thing that they see on the site. Interpretation will be in a format, which would be educational without the need for a ranger presence all times. 38. The intention is that the base will also be a mini centre for disseminating tourist information about the wider area and not just the immediate surroundings of the site. 39. In my view the proposal contributes strongly and positively to this particular aim with few drawbacks. Promote Sustainable Economic and Social Development of the Area 35. The effects of the proposal upon this aim are perhaps less easy to predict. However, one clear issue is that the base will provide a centre for the dissemination of information about the area, both in terms of education on the environment, but also in terms of the facilities that are available in the Angus Glens. In addition, the centre can be used to provide information about the wider area of the Cairngorms National Park and promote visits to other areas of the Park. RECOMMENDATION 36. That Members of the Committee support a recommendation to: A. Express support for the scheme in principle, as making a significant positive contribution to the collective aims of the Park. B. With regard to natural heritage and in line with recent CNPA initiatives the CNPA would comment that the building could contribute more towards biodiversity. The provision of bat boxes within the scheme is recommended. C. With regard to natural and cultural heritage, the CNPA has concern regarding the flat roof for a large part of the building when the local vernacular architecture exhibits pitched roofs. If the flat roof is retained the CNPA would recommend that it is designed as a green roof and incorporates where at all possible local plants/grasses that are typical of the area. This would provide a strong justification for the flat roof and contribute towards the Park’s natural heritage aim and the educational principles of the project. D. With regard to its cultural heritage aim the Park would recommend that an archaeological study is carried out to ensure that any archaeological interest is identified. E. In terms of its natural and cultural heritage aim and with regard to enhancing the local landscape, the CNPA would recommend that the existing toilet and visitor information buildings are removed within 6 months of the new centre opening. F. The CNPA would recommend that both SEPA and SNH are consulted on the application. Andrew Tait planning@cairngorms.co.uk 25 July 2005