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. Objector Ref Name Various Agent Dalfaber Action Group 35 Callart Road Aviemore Inverness-shire PH22 1SR Company Dalfaber Action Group Policy/site ref Settlements - Aviemore H2 Summary Development of H2 would result is unacceptable loss of amenity and recreational land. The site is designated as elevated land within the landscape capacity for housing study for the area considers development inappropriate in landscape terms. CNPA Visitor Services group state the development would inevitably change the nature of the site and remove the important green barrier between existing housing and the new Golf Course. CNPA Natural Heritage Group raise concerns and suggest that any development within the woodland area should be excluded. Part of the site is within the SEPA 1 in 200 flood plain. Development should be prevented in areas of flood risk especially considering current climatic change. The access route (Dalfaber Drive) and its associated level crossing is incapable of coping with any further increase in traffic. Comments by CPNA planners that all land designated for development need not necessarily be developed is an attempt to artificially reduce the density of any development by increasing the area of land designated for housing. Land that is not to be developed should be shown as such in the Local Plan. Designation of this area for development is contrary to the Aims of the National Park. AV/H3 should therefore be designated as amenity woodland CNPA analysis The modifications need to reflect the latest position regaring the extant permissions, and currently submitted but yet to be determined applications which will be determined under the Highland Council local plan. The need to respect the role the site plays in creating a setting for Aviemore should be retained. The importance in assessing the flood risk in the determination of any application on the site should also be retained. Proposed Modification Modifications to include up to date position regarding extant permissions and submitted applications yet to be determined. Make reference to important issues including flooding, landscaping and natural heritage. Objector Ref Name Various Agent Dalfaber Action Group 35 Callart Road Aviemore Inverness-shire PH22 1SR Company Dalfaber Action Group Policy/site ref Settlements - Aviemore H3 Summary Development of H3 would result is unacceptable loss of amenity and recreational land. The landscape capacity for housing study for the area concludes that the site has no opportunity for development, that any development would have a significant impact on the National Scenic Area and as a result development would therefore be inappropriate in landscape terms. CNPA Natural Heritage Group state that the land between Heather cottage and the existing access track should not be developed. The area to the south of the access track should be retained as amenity woodland as it has been in the previous local plan. The land around Dalfaber farmhouse has been flooded within a 1 in 200 year timescale proving that the SEPA 1 in 200 year flood map is accurate. Development should be prevented in areas of flood risk especially considering current climatic change. The access route (Dalfaber Drive) and its associated level crossing is incapable of coping with any further increase in traffic. Comments by CPNA planners that all land designated for development need not necessarily be developed is an attempt to artificially reduce the density of any development by increasing the area of land designated for housing. Land that is not to be developed should be shown as such in the Local Plan. Designation of this area for development is contrary to the Aims of the National Park. AV/H3 should therefore be designated as amenity woodland CNPA analysis The modifications need to reflect the latest position regaring the extant permissions, and currently submitted but yet to be determined applications which will be determined under the Highland Council local plan. The need to respect the role the site plays in creating a setting for Aviemore should be retained. The importance in assessing the flood risk in the determination of any application on the site should also be retained. Proposed Modification Modifications to include up to date position regarding extant permissions and submitted applications yet to be determined. Make reference to important issues including flooding, landscaping and natural heritage. Objector Ref 001 Name Nick Halfhide Great Glen House Leachkin Road Inverness IV3 8NW Company Deer Commission Policy/site ref General Summary No comments to make CNPA analysis-No modification considered necessary as a result of this representation. Proposed Modification No further action required. Objector Ref 002 Name Mrs Deirdre McCreath Ardavon Nethy Bridge Inverness-shire PH25 3DR Policy/site ref Settlements - Nethy Bridge OS1 Summary Wish to see an area of garden removed from the Open Space allocation, and included, instead housing land. Map of site included. CNPA analysis Land may be suitable for inclusion as general land within the settlement rather than open space, and any application could then be considered on its merits. The site will require a site visit and formal consideration as a suitable site for development, or as a site within the village boundary but without specific allocation attachments. Proposed Modification Amend OS1 at Ardavon to exclude garden area as marked on rep from OS and include as soley within settlement boundary. Objector Ref 003 Name Mr & Mrs Rimmell a Broomlea Newtownmore PH20 1AT Policy/site ref Settlements - Newtonmore OS Summary Retain land adjacent to The Paddock and Alvey House Hotel, Newtonmore as open space. CNPA analysis The comment is noted. Undertake site visit to assess the site, and include as open space if considered appropriate. For clarity additional text will be added to the plan to explain the level of protection offered to sites on the boundary of settlements identified in the Plan. Proposed Modification Include land within settlement boundary and allocate as environment. Objector Ref 003b Policy/site ref Policy omission Summary Additional explanation should be included to explain the significance of the settlement boundary, and there should be a presumption against development outside the line, CNPA analysis The comment is noted and additional information will be added to clarify the meaning of such proposal lines, and the impact this will have on development proposals both within and outwith the line. Proposed Modification Include additional para in intro to cpt 7 to clarify the position of sites inside and outwith boundaries Objector Ref 004 Name Agent Mr Mike Munro Ardconnel Woodlands Terrace Grantown on Spey PH26 3JN Company Munro Chartered Quantity Surveyors Policy/site ref Settlements -Cromdale Summary Add land identified in Cromdale to existing allocated land H1 to provide additional land for housing. CNPA analysis The allocated sites within Cromdale will be analysed in light of the comments received. The consideration of the land will be done in light of the fact that sufficient land has already been identified to meet the housing need. The sites will also be judged against the SEA findings, the physical constraints of these sites and the requirements for effectiveness as set out in national guidance. Having assessed these sites, a review will be undertaken of the alternative land suggested to ascertain its qualities in meeting the local housing need, and the impact it would have when assessed through the SEA. Proposed Modification H1 add remaining field area within proposed site. Objector Ref 005 Name Agent Mike Munro Ardconnel Woodlands Terrace Grantown-on-Spey PH26 3JN Company Munro Chartered Quantity Surveyors Policy/site ref Settlements -Cromdale Summary Extend settlement boundary to add land identified. CNPA analysis The allocated sites within Cromdale will be analysed in light of the comments received. The consideration of the land will be done in light of the fact that sufficient land has already been identified to meet the housing need. The site will also be judged against the SEA findings, the physical constraints of these sites and the requirements for effectiveness as set out in national guidance. Having assessed these sites, a review will be undertaken of the alternative land suggested to ascertain its qualities in meeting the local housing need, and the impact it would have when assessed through the SEA. Proposed Modification Amend settlement boundary to include the land identified. Objector Ref 006 Name Richard Renton Nethybridge & Vicinity Community Council Aspen Lodge Nethybridge PH25 3DA Company Nethybridge & Vicinity Community Council Policy/site ref Settlements - Nethy Bridge H1/ C1 Summary Remove the reference to housing within the text for site C1. CNPA analysis The inclusion of the reference within the supporting text of Proposal C1 was intended to allow a degree of flexibility to future development options. However, there is a general view that this reference is unhelpful and misleading, and as a result consideration will be given to the removal of the final sentence of Proposal C1. Proposed Modification Remove reference to housing in the text to C1 Amend text to H1 to confirm planning permissions Objector Ref 007 Name RMB Bloomfield The Grey House Nethybridge Inverness-shire PH25 3EB Company RMB Bloomfield Policy/site ref Settlements - Nethy Bridge Boundary Summary Amend settlement boundary to include land identified. CNPA analysis The allocated sites within Nethy Bridge will be analysed in light of the comments received. The proposed amendment will ensure the land associated with this property is included in total. Proposed Modification Amend settlement boundary to include land identified. Objector Ref 008 Name Davall Developments Ltd Agent Brian W Muir Myrtlefield House Muir Smith Evans Ltd Grampian Road 203 Bath Street Aviemore Glasgow PH22 1RH G2 4HZ Company Muir Smith Evans Policy/site ref Settlements - Boat of Garten H1 Summary Support the allocation of H1 in Boat of Garten for housing development. CNPA analysis The comment is noted. Update wording once appropriate assessment from SNH has been completed. Proposed Modification Include reference to mitigation required by SNH as result of appropriate assessment of H1. Objector Ref 009 Name Susan Culliford Gargowan Nethybridge Inverness-shire Company Policy/site ref Settlements - Nethy Bridge C1 Summary Remove the reference to housing within the text for site C1. CNPA analysis The inclusion of the reference within the supporting text of Proposal C1 was intended to allow a degree of flexibility to future development options. However, there is a general view that this reference is unhelpful and misleading, and as a result consideration will be given to the removal of the final sentence of Proposal C1. Proposed Modification Remove reference to housing in the text to C1 Objector Ref 010 Name Mr Paul Culliford Gargowan The Causer Nethybridge PH25 3DS Policy/site ref Settlements - Nethy Bridge C1 Summary Remove the reference to housing within the text for site C1. CNPA analysis The inclusion of the reference within the supporting text of Proposal C1 was intended to allow a degree of flexibility to future development options. However, there is a general view that this reference is unhelpful and misleading, and as a result consideration will be given to the removal of the final sentence of Proposal C1. Proposed Modification Remove reference to housing in the text to C1 Objector Ref 011a Name Colonel F.M.K. Tuck Allargue Corgarff, Strathdon Aberdeenshire AB36 8YP Policy/site ref Housing (general) Summary Para 5.35 -Amend wording to include 'landowners' CNPA analysis The comment is noted and the wording will be amended. Proposed Modification Include 'landowners' to para 5.34. Objector Ref 011b Policy/site ref Policy 23 Summary Clarify the wording in Policy 23 regarding the amount of 2 and 3 bedroom houses, and houses with 3 or more bedrooms. CNPA analysis The need for a variety of house sizes was established in a paper supporting the local plan produced on behalf of CNPA and available on line for information. However the view has been taken to hold this aspiration as something to be negotiated on a site by site basis to reflect local need. Proposed Modification Move to supporting text of policy 21, para 5.45. Objector Ref 011c Policy/site ref Policy 24 Summary There should be provision within the provision of affordable housing, for landowners to provide small and very small scale developments for local need. The wording of the policy and supporting text is very complicated and full of jargon. Some definitions may be needed within the Glossary. Para 5.50 -why use school catchment areas as these go outwith the Park Boundary. Para 5.57 -clarify how local authority lists are used. We should restrict applicants to those on local lists. Para 5.59 -the wording is unclear. It seems an unfair burden to put on developers of single houses in light of the costs they will bear in building the house. Any 'planning gain' needs to be fair, perhaps linked to selling the property on. There seems to be no allowance for contributions made as a result of tourist accommodation provision. Section 75 agreements could be used for this. CNPA analysis The findings of the work undertaken by the 3Dragons will influence the affordable housing policy and ensure appropriate statistical support for the approach. Further clarification is also needed to ensure housing delivered meets the needs of local people. Proposed Modification Revise policy 24 to create new policy 21. Clarify position regarding % requirements. Move the detail of definitions to an appendix for clarification. Objector Ref 011d Policy/site ref Policy 25,26 Summary How do you define 'a small settlement of 15 dwellings'?( Policy 25) If the settlement eg. Strathdon, does not fall within this definition under Policy 26 the only housing that would be permitted would be affordable housing for workers. There used to be a rule allowing 10% increase in housing where there was a group of 5 or more. This should be restored. Certainly any development which included a business facility should be permitted. CNPA analysis Revise the approach taken to development opportunities outside settlements. Consider options for small settlements and small groups of houses. Ensure approach taken is in line with the requirements of SPP1. Any change to the approach taken may also impact on the SEA. Proposed Modification Include revised policy 23 regarding housing in rural buiding groups Include revised policy 22 regarding housing in settlements, and identify rural settlements within the proposals maps. Objector Ref 011e Policy/site ref Policy 28 Summary The wording of 28a should be amended to clarify actual restrictions placed on development affecting a listed building. CNPA analysis The consideration of listed buildings is considered under Policy 10. Proposed Modification No modification necessary Objector Ref 011f Policy/site ref Policy 30,31 Summary Revise the layout to match with the rest of the Plan and its policies. There are other services which make as much of an impact as telecoms and should be included, eg pylons and poles. CNPA analysis The comments regarding the layout are noted. Modifications will endeavour to ensure the plan and its policies are clearly laid out and are easy to understand and implement. The comment regarding other forms of utilities provision is noted. Developments such as those mentioned would be considered under other policies in the Plan including the impact the development would have on the landscape, natural heritage, etc. Additional information will however be added to clarify the need for all developments to take full account of all the policies in the Plan. Proposed Modification Separate transport and telecomms to avoid confusion in revised policies 30 and 31. Add reference to transmission etc in policy 16 Objector Ref 011g Policy/site ref Policy 33,34 Summary Building for tourist accommodation should be included as well as facilities and attractions. Specific mention of car parking, toilets and information points would help. CNPA analysis The policies have been worded to support as wide a range of facilities as possible and also to facilitate the development of appropriate new provision in locations which are complimentary to the aims of the Park. To ensure the wording is not restrictive, specific mention of particular provisions for tourists has deliberately been left out. Policy 33 would include proposals for tourist accommodation as well as other forms of tourist related provision. No modification considered necessary as a result of this representation. Proposed Modification Clarify wording in Policy 33 and 34 regarding support for tourism development. Objector Ref 011h Policy/site ref Policy 36 Summary Why specify year round activities? The nature of the area means that there need to be separate winter and summer activities provided e.g. skiing and canoeing. CNPA analysis The comments are noted, and the CNPA continue to work closely with the 4 Local Authorities to provide and support an appropriate level of recreational provision for communities across the Park. The policies have been worded to support as wide a range of facilities as possible and facilitate the development of appropriate new provision in locations which are complimentary to the aims of the Park. However in light of the comments received, the wording will be reviewed to ensure that the aims of the policy are deliverable and will ensure that open space is supported across the Park throughout the year. Proposed Modification Amend reference to 'extends the tourist season' in revised para 6.23. Objector Ref 011i Policy/site ref Settlements omissions Strathdon Summary Strathdon should be identified as a settlement. CNPA analysis The approach to the identification of settlements outwith those identified in the deposit plan will be reviewed, and in line with the requirements of SPP1 a detailed rational behind the approach taken will be drawn up. Where it is considered that additional detail including land allocations would assist in the level of detail provided for smaller communities and help attain their aspirations, the specific identification of those settlements will be considered as appropriate through modification both Section 7 of the Plan, the policies regarding housing outwith strategic settlements, and the proposals maps. Any change to the approach taken may also impact on the SEA. Proposed Modification Identify Bellabeg within settlement proposals. Objector Ref 011j Policy/site ref Maps Summary Map D may not be accurate. There never was ancient woodland along the River Don between Delnadamph and Allargue, nor yet on the Hill of Allargue. CNPA analysis The presentation of the maps will be reviewed and modified to ensure correctness of information and ease of understanding. Proposed Modification Use most up to date map bases. Objector Ref 012 Name Mr Robert Robbie 18 Dirdhu Court Nethybridge Inverness-shire Policy/site ref Settlements - Nethy Bridge C1 Summary Remove the reference to housing within the text for site C1. CNPA analysis The inclusion of the reference within the supporting text of Proposal C1 was intended to allow a degree of flexibility to future development options. However, there is a general view that this reference is unhelpful and misleading, and as a result consideration will be given to the removal of the final sentence of Proposal C1. Proposed Modification Remove reference to housing in the text to C1 Objector Ref 013 Name Mr Ian Hogarth Bynackbeg Nethybridge Inverness-shire Policy/site ref Settlements - Nethy Bridge C1 Summary Remove the reference to housing within the text for site C1. CNPA analysis The inclusion of the reference within the supporting text of Proposal C1 was intended to allow a degree of flexibility to future development options. However, there is a general view that this reference is unhelpful and misleading, and as a result consideration will be given to the removal of the final sentence of Proposal C1. Proposed Modification Remove reference to housing in the text to C1 Objector Ref 014 Name Mr & Mrs L Evans Redmires Mossie Road Grantown on Spey Moray, PH26 3HW Policy/site ref Settlements - Grantown on Spey H1 Summary Further to an original objection to development within Grantown on Spey, the original notice for the development of H1 detailed 228 plus 7 dwellings whereas the Deposit Local Plan shows a reduced site of 9.6ha for around 200 units, which must mean a greater density is being allowed. By what standard are such plans being accepted even allowing for the time cycle of 5 years? In GS/OS1 what does 'protected open space' mean. Is it protected for all time or for a 5 year period only? On what basis have the boundaries between the open space and development site been drawn up. Why is the open space not listed as a conservation area? the wedge of land to the rear of Mossie Road serves no purpose other than to isolate people from the Open Space. why is so much and such dense development required in Grantown on Spey or within the National Park. There is no economic need for such scale development. -can the existing road widths cope with this scale of development. -what is the ratio for affordable housing -why is land to the north of Church Avenue not identified for development -what measures are being taken to prevent flooding as a result of building over the Mossie -who will guarantee that appropriate levels of civic amenities will be provided eg. Water, sewerage, schools, health care, care for the elderly, public transport, etc. Also see previous representation made on the submitted planning application. CNPA analysis This site has a current, outstanding application and due to the timescales involved this application will be determined in line with the policies of Highland Council Local Plan. The determination of this site will however be carefully monitored to ensure that the appropriate level of detailed information is included within the future plans for the Local Plan. In the event that the detailed application is refused, the situation will be revised. Proposed Modification Include up to date position regarding extant permissions and submitted applications yet to be determined. Objector Ref 015 Name Mr Jim MacEwan The Manse Nethybridge Policy/site ref Settlements - Nethy Bridge C1 Summary Remove the reference to housing within the text for site C1. CNPA analysis The inclusion of the reference within the supporting text of Proposal C1 was intended to allow a degree of flexibility to future development options. However, there is a general view that this reference is unhelpful and misleading, and as a result consideration will be given to the removal of the final sentence of Proposal C1. Proposed Modification Remove reference to housing in the text to C1 Objector Ref Name Sir Thomas MacPherson Agent Speyville House Newtownmore PH20 1BS Policy/site ref Settlements - Newtonmore H1 Summary The only access to Newtonmore H1is from Perth Road. Current traffic on Station Road and the practical impossibility of widening Station Road means that substantial additional traffic on it is to be avoided. The lower flat area of H1 is liable to periodic flooding and I would suggest that this land is not suitable for housing. CNPA analysis The comments are noted, and the appropriate modifications will be made to the wording of the proposal to highlight any constraints to development. Clarify that current applications will be determined under the currently adopted plan and its policies. Confirm Highland Council roads engineers will be involved in any future development brief in regard to access and capacity of the existing networks. Proposed Modification Include up to date position regarding extant permissions and submitted applications yet to be determined. Objector Ref 017a Name Mrs Sally Spencer Pitagowan House Newtonmore Inverness-shire PH20 1BS Policy/site ref Policy 01 Summary Special consideration should be given to individual applicants with strong family or local connections. Many are unlikely to be able to afford expensive sites or houses, so are currently at a considerable disadvantage and local landowners may be willing to offer land to such people at below market price because he is a ‘local’, In such cases there should be an assumption that permission will be granted unless there are extremely good reasons for refusal. This local connection with folk who have inherited local customs and traditions will be the only way of “conserve and enhance the …. cultural heritage of the area”. CNPA analysis The approach taken has tried to create a clear link between the Park Plan, the aims of the Park and the Local Plan and its delivery. Throughout the remainder of the policies in the Plan, issues such as landscape impact, sensitivity of development and the promotion of a healthy rural economy must all be considered in the determination of any planning application. The proposal regarding local connection is not one favoured by CNPA as it precludes many sectors of society. However the important point raised regarding providing appropriate development opportunities to those wishing to add to sustainable rural communities across the point will be reinforced throughout the Plan Proposed Modification Revise policy 1 in total to reflect the various comments made and make better links with the aims of the Park. Objector Ref 017b Policy/site ref Policy 01 Summary The CNPA needs to ensue the planning process is fair and transparent. Retrospective planning permission should not be granted as it gives the impression that developments which might not get permission if considered in the normal way, do get permission because they are already in existence. Robust discouragement should be in place to ensure retrospective applications are not successful, including fines, additional fees, stringent planning conditions to restore the site, etc. This should be “loophole proof”. Where permission is granted subsequent alterations should not be allowed unless there are good reasons why amendments are needed. The Park Authority should always consider such amendments, and not the Local Authority. CNPA analysis The comment is noted. The regulations regarding the implementation of planning legislation through the development management approach are set out by Scottish Government. The CNPA will continue to work to ensure that these regulations are written in a way which best serves the Park and its communities. No modification considered necessary as a result of this representation. Proposed Modification Revise policy 1 in total to reflect the various comments made and make better links with the aims of the Park. Objector Ref 017c Policy/site ref Policy 07 Summary How do you ensure the implementation of this policy when some developers so not implement that carefully considered landscape sections of their planning permissions. This is also true for light pollution when not all lighting requires planning permission. Robust enforcement is required throughout. CNPA analysis The policy regarding landscape will be implemented through the planning process when development proposals are considered for permission. The detail of such permissions will be considered in the normal way and those issues which can be addressed by the planning process will be. No modification considered necessary as a result of this representation. Proposed Modification Modify 1st para to ensure postive contribution is made to the landscape character. Add 'significant' and 'character' in 2nd para. Add a) and b) to ensure alternatives are considered and adverse effects minimised. Supporting text modified to ensure all development respects the landscape character of the national park. The role of wildness should also be clarified in 4.40 and 4.41. Light pollution should be retained in 4.42 and the role of landscape character assessments explained. Objector Ref 017d Policy/site ref Policy 18 Summary How do you implement such a policy when there are so many new developments which do not reflect the local vernacular and distinctiveness. This is also true in regard to the amenity enjoyed by neighbouring properties. CNPA analysis The policy attempts to draw a line under previous poor quality design and promote good design within the National Park for all new developments. The CNPA will work to promote this policy and its aims across the Park to raise standards and ensure that new developments do reach an improved standard to the benefit of all communities. No further modification is considered necessary as a result of this representation. Proposed Modification No further modification necessary as a result of this representation. Objector Ref 017e Policy/site ref Policy 19 Summary To ensure sustainable communities are created and maintained, developer contributions should be used to provide basic community facilities such as church halls, shops, and a place for people to gather. CNPA analysis The comment is noted. It is the intention of CNPA to base the contributions on community needs surveys and this will be further explained in the supporting text. Proposed Modification Amend text in para 5.20 to confirm use of community needs assessments in establishing need created as a result of the development. Objector Ref 017f Policy/site ref Policy 22 Summary There should be greater links between development and the Health and Safety Executive to allow developments to go ahead sensibly. CNPA analysis The comment is noted. The CNPA work hard and ensuring meaningful links with other agencies and key partners, and this will continue in working to implement this plan. No modification considered necessary as a result of this representation. Proposed Modification No modification necessary as a result of this representation. Objector Ref 017g Policy/site ref General -layout Summary The 4 aims of the Park should be highlighted clearly so that it is clear that they are taken into consideration in the determination of any planning application. CNPA analysis The comment is noted. Modifications will endeavour to clarify terminology and phrasing used. A review of the Introduction and Context sections is necessary to clarify the context for the Local Plan and its relationship with other documents, the Park Plan, and also to expand on the thinking behind the policies as drafted. Proposed Modification Amend introduction to clarify link to 4 aims in para 1.2 and reinforce links through revised policy 1. Objector Ref 018 Policy/site ref Settlements - Newtonmore OS Summary Retain land adjacent to The Paddock and Alvey House Hotel, Newtonmore within the settlement boundary and allocate as open space. CNPA analysis The comment is noted. Carry out site visit to assess the qualities of the land suggested as open space. If appropriate include as open space and amend boundary accordingly. For clarity additional text will be added to the plan to explain the level of protection offered to sites on the boundary of settlements identified in the Plan. Proposed Modification Include land within settlement boundary to be protected from development. Amend para 7.5 to clarify position regarding land within and outwith settlement boundaries. Objector Ref 019 Name Gillianne Clegg Craiggowrie Nethybridge PH25 3DR Policy/site ref Settlements - Nethy Bridge Summary Designate as open space the field in the centre of Nethy Bridge between the Mountview Hotel and Wilburn Homes development. CNPA analysis The comment is noted. Ensure the land identified in the application associated with Wilburn homes is included as open space, and amend text accordingly. Amend text to reflect additional protection offered to this site as a result of planning condition. Proposed Modification Identify land to be protected in line with previous planning permission Objector Ref 020a Name Dr A Watson Clachnaben Crathes, Banchory Kincardineshire AB31 5JE Policy/site ref Housing (general) Summary CNPA need to ensure the plan covers all issues more equally. At the moment, there is an over emphasis on new housing, and living and working in the Park, and not enough focus on conserving and enhancing the national park CNPA analysis The comment is noted. Modifications will endeavour to ensure a more appropriate balance is struck between development opportunities and the protection of the special qualities of the area as identified as a National Park. The wording used within policies throughout will be clarified to ensure the appropriate level of guidance is available for developers, and the Plan is easy to understand and use. A review of the Introduction and Context sections is necessary to clarify and refine the vision for the Plan and set out clearly the strategic background to the policies drafted. Similarly further clarification is needed in the introduction section to each Chapter to state clearly the justification for the approach taken and the aspirations sought as a result of implementation of the policies. Proposed Modification Amend introduction to clarify position and role of aims of the Park. Amend Local Plan vision to link more closely to the National Park Plan. Move definitions regarding housing into appendix. Objector Ref 020b Policy/site ref General - Links to Park Plan Summary Add "where this would not damage the sites" to page 10, ix. CNPA analysis The comment is noted. However the wording referred to is a quote from the National Park Plan which has now been adopted. The consultation undertaken here relates to the wording within the local plan rather than cross references to other documents. No modification considered necessary as a result of this representation. Proposed Modification No modification necessary as result of objection. Objector Ref 020c Policy/site ref Policy 01 Summary Para 3.1 should recognise that Straths include many other habitats as well as farmland. Page 14, right column, 2nd to last para in 3.4 should add that alternative sites have been investigated and found to be more damaging. Include how the term 'outweighed' in this para and also in policies 6 and 7 will be assessed. CNPA analysis The comments regarding the clarity of the wording are noted and the appropriate changes will be made to ensure policies and supporting text are clear, understandable and are not subjective in their implementation. Proposed Modification Revise policy 1 in total to reflect the various comments made and make better links with the aims of the Park. Objector Ref 020d Policy/site ref Policy 06 Summary Recognise that old planted woods, moorland, and some semi-natural habitats within farmland, such as fluvio-glacial sandy hillocks have the same value as long established woodland, in that when they are newly recreated, they do not have equal wildlife value as a long established site. CNPA analysis The comment is noted and the wording of the policy in regard to the comments will be reviewed to ensure correctness and clarity. Proposed Modification add to 1st para 'including cumulative impact' in a) add 'to the satisfaction of the planning authority' in b) add 'commersurate or greater' in last para add 'comprehensive' In supporting text clarify biodiversity obligation and what this requires in terms of development proposals. Objector Ref 020e Policy/site ref Policy 07 Summary para 4.32 last four lines are incorrect para 4.33 line 2 replace mix with mixture 4.35 - agree with principle, but plan needs to recognise this should lead to action. Policy should make this action clear CNPA analysis The comments regarding the text used are noted and the wording will be amended to ensure clarity and ease of use. Proposed Modification Modify 1st para to ensure postive contribution is made to the landscape character. Add 'significant' and 'character' in 2nd para. Add a) and b) to ensure alternatives are considered and adverse effects minimised. Supporting text modified to ensure all development respects the landscape character of the national park. The role of wildness should also be clarified in 4.40 and 4.41. Light pollution should be retained in 4.42 and the role of landscape character assessments explained. Objector Ref 020f Policy/site ref Policy 13 Summary Need to define "wherever reasonable" in para 4.66 to ensure prevention of unnecessary problems of pollution CNPA analysis The comment is noted. The wording of the policy will be reviewed to ensure it is clear and provides an appropriate level of guidance for developers and interested parties. Further work is needed to clarify how policies will be implemented through the development management process and to ensure the wording is not open to unnecessary interpretation. It is proposed to produce a series of working practice notes for use by staff across the 4 local authorities and the CNPA to ensure a consistent approach is taken. Proposed Modification Clarify in 4.80 Objector Ref 020g Policy/site ref Policy 14 Summary Include the reference to alternative sites elsewhere in the plan to support this idea. In ii) define 'outweighed' In final para of Policy include 'vegetation' In 4.73 note that soil plants and soil animals are microbial. Ensure that summary statements on scientific technical issues are accurate. In 4.74 grammar error - 'its' should be 'their'. Replace 'balance' with 'characteristics'. Use 'affects' rather than 'impact'. In 4.75 Include reference to 'suitable alternatives' in previous policies. CNPA analysis The general tone will also be revisited to ensure that it is reasonable and delivers the aims of the policy as detailed in the supporting text. The wording will also be reviewed to ensure it is clear, and supported by the necessary detail to allow assessment and implementation by users. Proposed Modification Revise wording in policy 14 and supporting text to clarify impact of development on soils and mineral resouces. Objector Ref 020h Policy/site ref Policy 17,18 Summary Wording is not clear in reference to reinforcing pattern and local vernacular. How will this policy be assessed. In para 5.2 add at the end 'to the same extent' to ensure future consistency of use. The creation of sustainable communities conflicts with recent experience of increased populations in the Park from commuters, holiday homes and retired people. This will reduce the natural and semi natural habitats. CNPA analysis The comments are noted. The design guide and checklist which will support this policy will be the subject of full and comprehensive public consultation before it is used to support this policy. The aim of the guide is to be clear and user friendly and it is hoped that it will support sustainable communities and developments to the benefit of the Park and all its communities. The wording of the policy will be amended to ensure the links with the guide and checklist are clear. Proposed Modification Redraft policy 17 as Policy 18 and ensure better links to the proposed content of the Sustainable Design Guide. Objector Ref 020i Policy/site ref Policy 21,22 Summary Design and materials can have a large impact on the landscape and should be mentioned. Grammatical correction in 5.14 use 'mix' not mixture. CNPA analysis The issue of design and materials will be assessed through policies 17 and 18. In regard to the grammatical error, the amended text to support the policy has removed the para. Proposed Modification No modifications necessary. Objector Ref 020j Policy/site ref Housing (general) Summary Incorrect use of language in box regarding the Extract from the National Park Plan. In 5.34 use 'council houses' not 'council owned property'. Suggest that the sale of council houses should end. In 5.39 note that the increase in housing will be accompanied by a lack of sustainable growth, energy use, pollution and destruction of habitats. In 5.49 support this idea. CNPA analysis Amend the text to support the housing policeis to clarity the wording. Proposed Modification modify para 5.29 to clarify the issue of need. Objector Ref 020k Policy/site ref Policy omission Summary There should be greater control over the change of use both in forestry and agriculture. Where activities which cause an impact cannot be controlled by the planning system the CNPA should be requesting control from Government. CNPA analysis Where such operations are covered by planning legislation the policies of the local plan would apply as with any other form of development. However where such operations are not covered by planning legislation the local plan would not apply and such operations would be dealt with under separate control or guidance as relevant to that industry. The CNPA will however continue to work to ensure the most appropriate level of control operates in the Park area. No modification considered necessary as a result of this representation. Proposed Modification No modification proposed. Objector Ref 020l Policy/site ref Policy 31 Summary Use “impact on affected wildlife species, habitats or archaeological features” instead of 'ecology' and 'archaeology'. CNPA analysis The comments regarding use of terminology are noted and the appropriate amendments will be made. Proposed Modification Amend wording in policy 31 to include natural and cultural Objector Ref 020m Policy/site ref Policy omission Summary There is no policy on Vehicle tracks. CNPA analysis In regard to tracks the comment is noted. However it is considered that any application for such development will be judged against all the policies in the plan and there is not a need to specifically highlight such developments within separate policies. The intention throughout the plan is that all policies should be taken into account when considering any development proposal. The wording within the Introduction will be amended to clarify this position. Proposed Modification Clarify introduction to clarify role of all policies (para 1.20). No other modification proposed. Objector Ref 020n Policy/site ref Policy 34,35 Summary There is no mention of new paths, bridges, huts etc. CNPA analysis The policy has been worded to consider all forms of recreational facility and does not therefore refer to specific forms of recreation. The policy should be read in conjunction with the other policies in the plan, in particular those regarding landscape and visual setting, developments impacting on natural heritage etc. Additional information will be included to ensure that users of the local plan are clear that all policies must be taken into account in all applications for development. Proposed Modification Amend policies 34-36 to clarify access issues. Objector Ref 020o Policy/site ref Maps Summary Map D 'ancient woodland' actually covers all woodland. The blue of 'Ancient woodland' should be on the guide. CNPA analysis The presentation of the maps will be reviewed and modified to ensure correctness of information and ease of understanding. Proposed Modification Ensure most up to date maps are used in future modifications and versions. Objector Ref 020p Policy/site ref Policy omission Summary There is no policy regarding signs or advertisements. CNPA analysis The comment is noted. However it is considered that any application for such development will be judged against all the policies in the plan and there is not a need to specifically highlight adverts and signs within a separate policy. The intention throughout the plan is that all policies should be taken into account when considering any development proposal. The wording within the Introduction will be amended to clarify this position. Proposed Modification No modification proposed other than to clarify role of all policies in para 1.20. Objector Ref 020q Policy/site ref Policy 28 Summary There should be a limit on the size of any replacement house. Eg 50% CNPA analysis The wording of the policy will be reviewed to ensure that it does deliver the aim of the policy, and is not overly restrictive or onerous, but also provides an appropriate level of guidance for developers and people using the policy. However issue of the appropriate scale of extensions would be considered in light of the proposed development and the impact on the building, a prescriptive % is therefore not supported. Proposed Modification No modifications proposed. Objector Ref 021a Name Mr D Carrott Tigh na Fraoch Nethy Bridge PH25 3DA Policy/site ref General -Housing Summary The consultation process is not transparent and could be misleading. a)The Deposit Plan was only forwarded to people who previously made comments which could preclude others getting involved. b)On the proposals maps 'Community' use also includes Affordable Housing. This is confusing as there is a separate colour used for housing. c)It is clear that affordable housing for the community does not necessarily mean the local people from that settlement. d)It contradicts the value of the Plan to have windfall sites which could be used for housing. This implies that any suitable site outwith the designated areas could be used for housing without going through the consultation process. CNPA analysis The comments are noted. The consultation on the Deposit Plan has exceeded the requirements of the guidelines prepared by the Scottish Parliament, and every effort has been made to contact as many people within the community and other interested groups and individuals. The level of response is testament to the efforts made. The comments regarding the terminology used on the proposals maps are noted, and clarification on the terms used will be included as a proposed modification. The comments regarding affordable housing are also noted and further clarification on this point will be added to paragraphs 5.47-5.60. The comments regarding windfall sites are noted. National planning guidance allows for the consideration of such ad hoc sites for all forms of development, where applications are judged against the policies within the Plan regarding such considerations as impact on the landscape, design, sustainability, impact on natural heritage, etc. Consideration will be given however to the need for an additional policy to consider development proposals within settlements, and also further clarity on how development proposals outwith settlement boundaries are assessed. Proposed Modification cpt 7 change wording in 7.10 to revised para 7.11 referring to 'sustainable communities'. Objector Ref 021b Policy/site ref Settlements - Nethy Bridge H1 Summary The plan should make reference to the outline approval for H1 and highlight the debate associated with that application regarding the height of the buildings and the nature of the housing provided in terms of sheltered housing rather than affordable housing. CNPA analysis The comments are noted, and the wording of the local plan will be amended to reflect extant planning permissions to increase clarity including the nature of the development which will occur, and any influence that this proposal can still make to any future development. Proposed Modification Amend text to H1 to confirm planning permissions Objector Ref 021c Policy/site ref Settlements - Nethy Bridge C1 Summary Protect the site C1 from all forms of development. More than a change to the wording is required if the reference to affordable housing is retained within the definition of Community Use. CNPA analysis The inclusion of the reference within the supporting text of Proposal C1 was intended to allow a degree of flexibility to future development options. However, there is a general view that this reference is unhelpful and misleading, and as a result consideration will be given to the removal of the final sentence of Proposal C1. The reference to developments which may be in the wider community interest should be considered and the definition of what constitutes 'community use' should be carefully considered. Proposed Modification Remove reference to housing in the text to C1 Objector Ref 022a Name Mrs J Carrott Tigh na Fraoch Nethy Bridge PH25 3DA Policy/site ref Settlements - Nethy Bridge H1 Summary The plan should make reference to the outline approval for H1 and highlight the debate associated with that application regarding the height of the buildings and the nature of the housing provided in terms of sheltered housing rather than affordable housing. CNPA analysis The comments are noted, and the wording of the local plan will be amended to reflect extant planning permissions to increase clarity including the nature of the development which will occur, and any influence that this proposal can still make to any future development. Proposed Modification Amend text to H1 to confirm planning permissions Objector Ref 022b Policy/site ref Settlements - Nethy Bridge C1 Summary Protect the site C1 from all forms of development. More than a change to the wording is required if the reference to affordable housing is retained within the definition of Community Use. CNPA analysis The inclusion of the reference within the supporting text of Proposal C1 was intended to allow a degree of flexibility to future development options. However, there is a general view that this reference is unhelpful and misleading, and as a result consideration will be given to the removal of the final sentence of Proposal C1. The reference to developments which may be in the wider community interest should be considered and the definition of what constitutes 'community use' should be carefully considered. Proposed Modification Remove reference to housing in the text to C1 Objector Ref 023 Name Roy Gibson Craigower Lodge Newtonmore Inverness-shire PH20 1AT Policy/site ref Settlements - Newtonmore Boundary Summary Redraw the Newtonmore settlement boundary to include the fields previously allocated as agriculture/set aside/community woodland/open space provision in the current Local Plan (policy 8.3.3) CNPA analysis The comment is noted. Carry out site visit to assess land and include as open space as appropriate, amending settlement boundary. Clarify para 7.5 in modifications to explain the level of protection offered to sites on the boundary of settlements identified in the Plan. Proposed Modification Modifiy to include land as open space within settlement boundary. Objector Ref 024a Name Hebe Carus The Mountaineering Council of Scotland The Old Granary West Mill Street Perth, PH1 5QP Company The Mountaineering Council of Scotland Policy/site ref Policy 01 Summary Support for approach being proposed in Policy 1 CNPA analysis No modification considered necessary as a result of this representation. Proposed Modification No further action required. Objector Ref 024b Policy/site ref Policy 02 Summary Policy needs to recognise the low capacity for recovery of habitats as well as the impossibility of replacement of long established woodlands. It also needs to ensure the integrity of the Park is not eroded through cumulative effects. CNPA analysis The wording has been selected to reflect accurately the legislation regarding Natura 2000 sites. However in light of the comments, the policy wording will be reviewed to ensure it is accurate, clear and precise, whilst providing an appropriate level of guidance for developers. Proposed Modification Amend wording to accurately reflect Natura 2000 regulations. Objector Ref 024c Policy/site ref Policy 03 Summary Support the protection of the integrity of sites, but the policy should be changed to recognise the importance of corridors between sites. Concern over proposals to allow mitigation for loss of certain sites by enhancement of different qualities that are of equal importance to the National Park's natural heritage. CNPA analysis The policy wording endeavours to link the requirements of national legislation regarding natural heritage designations and the responsibilities placed on CNPA with the aims of the park, and to provide an appropriate level of guidance to developers in line with SPP1. In light of the comments made, the wording will be reviewed to ensure that these intentions are achieved, and that the policy is clear, precise and accurate. Any additional information will be added to both policy and supporting text accordingly. Proposed Modification Amend to secure better balance between development and impact on natural heritage designations. Objector Ref 024d Policy/site ref Policy 04 Summary Policy needs to recognise the low capacity for recovery of habitats as well as the impossibility of replacement of long established woodlands. It also needs to ensure the integrity of the Park is not eroded through cumulative effects. CNPA analysis The comment is noted and the appropriate amendments will be made to the wording to clarify the position. Proposed Modification In b) change 'equal' to 'commensurate or greater'. In 4.23 define 'commensurate'. Objector Ref 024e Policy/site ref Policy 06 Summary Concern about proposals to allow for mitigation for loss of habitats. Well- established habitats often have an intrinsic value due to their age alone. The policy should be changed to ensure that new habitats created as mitigation should be able to support the same population size, and have the same levels of complexity and connectivity. CNPA analysis Modifications will endeavour to ensure a more appropriate balance is struck between development opportunities and the protection of the special qualities of the area as identified as a National Park. The wording used within this policy will be clarified to ensure the appropriate level of guidance is available for developers, and the Plan is easy to understand and use together with ensuring the appropriate level of protection and compliance with national and international obligations placed on the CNPA. Proposed Modification add to 1st para 'including cumulative impact' in a) add 'to the satisfaction of the planning authority' in b) add 'commersurate or greater' in last para add 'comprehensive' In supporting text clarify biodiversity obligation and what this requires in terms of development proposals. Objector Ref 024f Policy/site ref Policy 07 Summary Concern that the Policy states adverse effects on the special landscape quality can be outweighed by economic and social benefits. MCofS seeks protection against adverse effects on the wildness qualities in and on the fringes of the mountain areas in the Park. Suggest using Landscape Character Assessment to define this higher level landscape areas as the Plateau and Upland & Glens categories. Also then suggest these areas of 'wildness' should be given greater weight in any balancing against social and economic benefits. CNPA analysis Modifications will endeavour to ensure a more appropriate balance is struck between development opportunities and the protection of the special qualities of the area as identified as a National Park. The wording used within this policy will be clarified to ensure the appropriate level of guidance is available for developers, and the Plan is easy to understand and use together with ensuring the appropriate level of protection and compliance with national and international obligations placed on the CNPA. Proposed Modification Modify 1st para to ensure postive contribution is made to the landscape character. Add 'significant' and 'character' in 2nd para. Add a) and b) to ensure alternatives are considered and adverse effects minimised. Supporting text modified to ensure all development respects the landscape character of the national park. The role of wildness should also be clarified in 4.40 and 4.41. Light pollution should be retained in 4.42 and the role of landscape character assessments explained. Objector Ref 024g Policy/site ref Policy 33 Summary Tourism Development policies must also recognise the large numbers of people who visit the NP and who find way marking / surfaced paths detracting from their visitor experience. CNPA analysis Modifications will endeavour to ensure a more appropriate balance is struck between development opportunities for business and tourism and the protection of the special qualities of the area as identified as a National Park. The wording used within this policy will be clarified to ensure the appropriate level of guidance is available for developers, and the Plan is easy to understand and use together with ensuring the appropriate level of protection and compliance with national and international obligations placed on the CNPA. The approach taken in the proposals maps will also be reviewed to ensure appropriate levels of clarity and guidance are included. Confirm way marked paths are considered in policy 34 where they form part of the core path network. Proposed Modification No modification proposed. Objector Ref 025a Name Mairi Maciver Communities Scotland Urquhart House Beechwood Park Inverness, IV2 3BW Company Communities Scotland Policy/site ref General -layout Summary Welcome the shorter version of the plan. Need to include a statement on the CNPA's policy on complaints handling. CNPA analysis The comment is noted. Modifications will endeavour to clarify such procedures or refer to CNPA wider policies which affect the Authority as a whole, rather than the Planning Section. Proposed Modification Include reference after 1.20 regarding use of plan in regard to other CNPA policies including approach to take if there are complaints. Objector Ref 025b Policy/site ref Maps Summary Reinstate smaller settlements as identified in the proposals maps to give a more comprehensive picture of settlement proposals overall within the Park. Also include a map indicating the 4 local authorities with responsibility within the Park. CNPA analysis The comment is noted and an overarching proposals map will be included as a modification showing the boundaries of the four local authorities and settlements identified in the proposals section of the Plan. Proposed Modification Add smaller settlements to give more accurate picture of proposals across the Park. Objector Ref 025c Policy/site ref Housing - links to other plans Summary Local Housing Strategies should be given more prominence, with reference to their role in the delivery of the Local Plan established at the start of the Housing section. CNPA analysis The links with Local Housing Strategies will be clarified in the text explaining the links between the Local Plan and other Plans and Strategies (para 2.10-2.11). Any further explanation considered necessary within the Housing section of the Plan will be added as appropriate. Proposed Modification 5.24-5.26 expand clarity on the role of strategic guidance including role of local housing strategies. Objector Ref 025d Policy/site ref Policy 24 Summary Other supportive of the idea behind policy 24, there is concern that this discourage private developers building in the Park, driving development pressure to the surrounding areas. In the detail, there needs to be additional information on how Sec 75 agreements would be used and monitored. With the use of waiting lists, the wording should be amended in 5.57 sentence 2 to "The Park Authority will continue to work with the relevant organisations operating within the Park to develop their allocations' policies to ensure they are as responsive to the needs of individuals and communities in the Park as possible." Allocations' policies should also be consistent with homelessness duties of local authorities and registered social landlords. Additional clarity is also needed on how the allocation or residents will work in terms of a housing ownership market in terms of selection, regulation, and local connection. Also additional clarity is needed on who will be responsible for the allocations criteria and who will maintain the waiting lists. There may be a need for some agreement through planning condition regarding developers entering into a nominations agreement - more clarity on this is needed. CNPA analysis The findings of the work undertaken by the 3Dragons will influence the affordable housing policy and ensure appropriate statistical support for the approach. Proposed Modification Reduce the requirements to 25% in line with national guidance and 40% in exceptional circumstances and in line with the findings of the 3Dragons report. 5.47 include additional info for clarity. 5.48 - amend in line with wording. Also expand to clarify the criteria to be used, the implementation of the policy, use of local waiting list etc. Objector Ref 025e Policy/site ref General -Consultation Summary Welcome information about the consultation process contained in the Plan, but there should be a statement how local development forums contributed to the Local Plan. CNPA analysis The comment is noted. The wording does not however identify particular forums and groups but remains a general comment. Proposed Modification No modification proposed. Objector Ref 025f Policy/site ref Housing (need) Summary Welcome general approach to housing land provision and comments regarding access to affordable housing. Need to include a definition of "Local Need", as its current use is confusing and potentially excluding. CNPA analysis Further clarification on terms used within the Plan, such as that of 'local need' will be added within the modifications. Proposed Modification Include appendix to clarify issue on housing need. Objector Ref 025g Policy/site ref Policy 01 Summary Policy 1 should refer to requirement for planning decisions to reflect current Scottish planning legislation and national planning policy guidance and advice. CNPA analysis The comment is noted. Modifications within the Introduction and Context sections will endeavour to clarify the relationship of the Local Plan and its relationship with other documents including the aims of the Park, and the Park Plan, and also national planning guidance. Proposed Modification Revise policy 1 in total to reflect the various comments made and make better links with the aims of the Park. Objector Ref 025h Policy/site ref Policy 13 Summary Support for approach to water resources, but it would be useful to address the requirement for major investment required at source for new developments once those with detailed planning permission have been connected. CNPA analysis The comment is noted. The issue of investment is an important one and consideration will be given to highlighting it in the supporting text to the policy. Confirm ongoing working relationships with Scottish Water to ensure appropriate investment to keep up with development pressures. Proposed Modification No further action required. Objector Ref 025i Policy/site ref Policy 16 Summary Support for policies 16, 17, 18 and 19. Suggest amending Policy 16, first sentence, to read "… complement the sustainability of a development." to focus clearly on sustainability and not on perception. CNPA analysis The comments are noted and the appropriate amendments will be made to the wording to clarify the position. Proposed Modification Change wording of 1st sentence to 'a development'. Objector Ref 025j Policy/site ref Housing - links to other plans Summary Support the reference to provide a range of opportunities and mechanisms to enter the housing market, and the need to create an appropriate balance of house sizes. Further detail on what mechanisms and opportunities exist would be helpful, as in PAN 74. There should also be clear reference to the Homelessness etc (Scotland) Act 2003 and its impact on the homelessness duties of local authorities and registered social landlords, as well as on the Planning Authority area for any potential land-use implications. CNPA analysis Within the section dealing with Housing Issues in the National Park, further clarity will be included on the mechanisms available to address the issues faced. Cross referencing to PAN 74 and the Homelessness etc (Scotland) Act 2003 will be undertaken to ensure the policies are supporting text are in alignment with the advice therein. Proposed Modification 5.24-5.26 expand clarity on the role of strategic guidance. Objector Ref 025k Policy/site ref Housing Table 2 Summary The sourcing of the figures used in Table 2,3 and 4 and para 5.39 should be added. The wording in Table 2 should be amended to ".. to reflect both the backlog of existing demand for housing from recent years, changes in household structure and inward migration." Regarding the need identified in Table 2, given Heriot-Watt's suggestion that the net need for additional affordable housing is 132 units per year over the Plan period, it appears that insufficient land supply has been allocated to meet this need. Land allocations in the Plan should be sufficient to meet all need. CNPA analysis Include the work of the consultants on line for general viewing. Amend table 2 to reflect comment. Proposed Modification Reword table 2 part 1 to 'inward migration'. Cross check allocations in table 4 against requirement in Table 2. Objector Ref 025l Policy/site ref Housing - Table 3 Summary Table 3 should be clearer with columns labelled 0-5 years and 5-10 years, if this is what is meant. CNPA analysis The titles used in the table will be reviewed to ensure clarity and easy understanding. Proposed Modification Amend table 3 to clarify years referred to. Objector Ref 025m Policy/site ref Housing (affordable) Summary In Para 5.49 suggest using PAN 74 definition of affordable housing ("housing of a reasonable quality that is affordable to people on modest incomes") CNPA analysis Move definition to appendix and cross referencing of the definition in PAN 74. Proposed Modification Include appendix on definition of what is affordable housing Objector Ref 025n Policy/site ref Housing (affordable) Summary In Para 5.57 'applicants'' should be defined to clarify to whom it refers. CNPA analysis Confirm that the use of the term 'applicant' is a commonly used on in the planning process -for those applying for permission. Proposed Modification No modification proposed. Objector Ref 025o Policy/site ref Housing (affordable) Summary In Para 5.59 has consideration been given to the possible effects on affordability for those building their own home who do not require grant aid, but have limited means. CNPA analysis The apporach taken will support any method of truly affordable housing provision. The revisions to the policies will not therefore preclude against any particular mechanisms. Proposed Modification Modify policy 21 to reflect 3Dragons report and include list of options for affordable provision in appendix. Objector Ref 025p Policy/site ref Policy 24 Summary Welcome monitoring mechanisms as stated. CNPA analysis No modification considered necessary as a result of this representation. Proposed Modification No modifications required. Objector Ref 025q Policy/site ref Policy 26 Summary What is meant by an "occupation appropriate to the rural location"? CNPA analysis Further work is needed to clarify how policies will be implemented through the development management process and to ensure the wording is not open to unnecessary interpretation. It is proposed to produce a series of working practice notes for use by staff across the 4 local authorities and the CNPA to ensure a consistent approach is taken. Proposed Modification Include para to clarify such rural occupations. Objector Ref 025r Policy/site ref Policy 26 Summary What would happen if the original "rural business" no longer functions? CNPA analysis Further work is needed to clarify how policies will be implemented through the development management process and to ensure the wording is not open to unnecessary interpretation. It is proposed to produce a series of working practice notes for use by staff across the 4 local authorities and the CNPA to ensure a consistent approach is taken. Confirm that if there was a restrictive planning condition the property would have to be sold with the business or the owner would have to apply to have the condition removed and provide sufficient justification for this action. Proposed Modification No modification proposed. Objector Ref 025s Policy/site ref Policy 28 Summary In para 5.71, second sentence -What is meant by "recent past" here? CNPA analysis The comment is noted and additional wording will be added to clarify to position. Proposed Modification Change to past 10 years. Objector Ref 025t Policy/site ref Policy omission Summary The policy regarding gypsy/traveller sites should be retained. CNPA analysis The comment is noted. However it is considered that any application for such development will be judged against all the policies in the plan and there is not a need to specifically highlight gypsy/traveller sites within a separate policy. The intention throughout the plan is that all policies should be taken into account when considering any development proposal. The wording within the Introduction will be amended to clarify this position. Confirm the issue of gypsy/traveller developments would be considered under all policies of the plan including specifically those regarding 'conserving and enhancing' and 'living and working' and not under a particular policy regarding gypsy/traveller developments. All policies of the plan must be complied with where relevant to gain permission, therefore a topic specific policy is not considered appropriate. Proposed Modification No modfication proposed. Objector Ref 025u Policy/site ref Policy 30 Summary Support developer requirement to submit a transport assessment covering local transport impacts of developments, but note that where Communities Scotland funding is being used for a development, it can only be used for housing purposes and not as a contribution to transport infrastructure. CNPA analysis The limitations of the funding available to certain sectors is recognised. The policy will be reconsidered in line with the requirements of SPP17 to ensure that the requirements place on all developers is not onerous. The expense would then fall to the developer or similar. Proposed Modification No modification proposed. Objector Ref 025v Policy/site ref Policy 36 Summary Welcome policy regarding open space provision and proposed open space audit and open space strategy. CNPA analysis o modification considered necessary as a result of this representation. Proposed Modification no modification proposed. Objector Ref 025w Policy/site ref Housing (land supply) Summary In Section 7 timescales for the completion of the number of houses in each settlement should be included, making clear the link to Table 4. CNPA analysis The links between the proposals section and Table 4 are noted, and some cross referencing will be made to help clarify the position. Proposed Modification Amend tables to ensure correct and clear. Cross reference to settlement proposals Objector Ref 025x Policy/site ref General -wording Summary Check the alphabetical ordering of settlements in Section 7. Para 4.48, first sentence -amend "Panning" to read "Planning" Policy 24 para 3 - "to a target of 30 per cent" conflicts with para 5.54 "will start at 30 per cent". CNPA analysis The ordering of settlements will be reviewed to ensure clarity and ease of use. The typo in para 4.48 and wording in policy 24 are noted and the appropriate amendments will be included. Proposed Modification Amend typos in line with comment Amend order of settlments in Cpt 7 to logical alphabetical order. Objector Ref Name Frogmore Estates Scotland Ltd Agent Philip Clarke 026a Barton Willmore 12 Alva Street Edinburgh EH2 4QG Company Frogmore Estates Scotland Ltd Policy/site ref Policy 01 Summary Object to the removal of general policies 1-3 from the draft plan and their substitution with new policy 1. Landscape character assessment carried out for the Cairngorms identified a variety of different landscape character areas, each with different sensitivity for development. The policies in the draft plan recognised this, the new Policy 1 does not, and therefore wish to see original approach retained. CNPA analysis The approach taken has tried to create a clear link between the Park Plan, the aims of the Park and the Local Plan and its delivery. Throughout the remainder of the policies in the Plan, issues such as landscape impact, sensitivity of development and the promotion of a healthy rural economy must all be considered in the determination of any planning application. Whilst the approach taken may not be a definitive, modifications will be made to the Introduction and Context to clarify that all the policies in the Plan must be considered equally, and also to clarify the relationship with other documents including the aims of the Park, and the Park Plan, and also national planning guidance. Proposed Modification Revise policy 1 in total to reflect the various comments made and make better links with the aims of the Park. Objector Ref 026b Policy/site ref Policy 07 Summary Policy 7 is overly restrictive in terms of appropriate development in rural areas and as such is not in line with SPP15. Wording should be amended to “All development will be sited, laid out, designed and constructed of materials so as to ensure no unacceptable adverse impact upon the special landscape qualities of the Cairngorms National Park.” CNPA analysis The wording of the policy will be reviewed to ensure that it is in line with national guidance on the topic, as well as striking an appropriate balance between development opportunities and protecting the special qualities of the area as identified as a National Park. Any amendments will be made as appropriate to ensure the underlying aim of the policy is achieved. Proposed Modification Modify 1st para to ensure postive contribution is made to the landscape character. Add 'significant' and 'character' in 2nd para. Add a) and b) to ensure alternatives are considered and adverse effects minimised. Supporting text modified to ensure all development respects the landscape character of the national park. The role of wildness should also be clarified in 4.40 and 4.41. Light pollution should be retained in 4.42 and the role of landscape character assessments explained. Objector Ref 026c Policy/site ref Policy 07 Summary Object to the term 'wildness' in Policy 7. The elements attributed to “wildness” are ambiguous and lack objectivity, and could be misapplied against any and all new development within the Park, Adverse impact on wildness could be used as a broad-brush justification to refuse any development within the National Park whenever it introduces new building and/or lighting where there was none before. This would be out of keeping with the policy, aims and spirit of SPP15 and would also be contrary to the provisions of PAN49: Local Planning. Reference to “wildness” should be removed. CNPA analysis The wording of the policy will be reviewed to ensure that it is in line with national guidance on the topic, as well as striking an appropriate balance between development opportunities and protecting the special qualities of the area as identified as a National Park. Any amendments will be made as appropriate to ensure the underlying aim of the policy is achieved. In addition, more information will be included to define the terms used, and ensure the wording is clear and easy to understand. Proposed Modification1 Modify 1st para to ensure postive contribution is made to the landscape character. Add 'significant' and 'character' in 2nd para. Add a) and b) to ensure alternatives are considered and adverse effects minimised. Supporting text modified to ensure all development respects the landscape character of the national park. The role of wildness should also be clarified in 4.40 and 4.41. Light pollution should be retained in 4.42 and the role of landscape character assessments explained. Objector Ref 026d Policy/site ref Policy 26 Summary Object to the overly restrictive wording used in identifying where new housing development will be permitted outwith existing settlements. These instances are either where the proposal is for affordable housing which cannot be accommodated within a settlement, or where the housing can be justified by the operational needs of a rural business. The use of occupancy conditions through Sec 75 agreement is suggested in the supporting para 5.67. Whilst it may be appropriate to link some new housing to business use in this way, the wording precluded any other form of housing provision. The approach, in line with SPP15 should be more flexible to allow development where it would not impact on any of the special qualities of the Park. The underlying attitude towards housing in the countryside is much changed from the Consultative Plan (para 3.106) and the absence of this adjusts the spirit of the provisions of the Plan and reduces its compliance to SPP15. CNPA analysis The approach taken in policy 26 will be reviewed to ensure it allows for the appropriate level of development and is flexible enough to support local people in their own communities. The wording will also be reviewed against national guidance on the issue of rural development to ensure the appropriate level of clarity is provided to developers in line with SPP1. Proposed Modification Revise para in b) regarding retiring persons, and add c) brownfield development. Objector Ref 026e Policy/site ref Policy 28 Summary The re-use of existing permanent structures which were previously dwellings offers the most sustainable means of providing housing outwith settlements, without compromising the landscape qualities of the Park through the introduction of new structures. At present, the combined provisions of Policy 26 and 28 are not in keeping with SPP15 and require adjustment accordingly. The wording should be amended to remove point c), which requires that the original building must either be intact with external walls and roof or must have been occupied over the previous five years. CNPA analysis The wording of the policy will be reviewed to ensure that it does deliver the aim of the policy, and is not overly restrictive or onerous, but also provides an appropriate level of guidance for developers and people using the policy. Proposed Modification Revise policy 23 to reduce the size of groups to 3. In policy 24 Add para c) taking on need to include brownfield land or reuse of redundant sites to create some more opportunities. In b) refer to other rural workers. Objector Ref 026f Policy/site ref Policy 28 Summary The 2nd and 3rd sentences of para 5.71 should be deleted and para 3.106 from the consultative draft plan should be reinstated after para 5.70. CNPA analysis The wording of the policy will be reviewed to ensure that it is in line with national guidance on the topic, as well as striking an appropriate balance between development opportunities and protecting the special qualities of the area as identified as a National Park. Any amendments will be made as appropriate to ensure the underlying aim of the policy is achieved. Confirm the policy is intended to renovate sites which have fallen into recent dereliction and not to allow new housing on all historic house sites throughout the park which go towards createing the culturally significant landscape of this area. Proposed Modification No modifications proposed. Objector Ref 026g Policy/site ref Policy 30 Summary Two principal elements of achieving sustainability in terms of transport are to encourage walking and cycling, public transport and reduce the need to travel. Whilst these two themes run throughout SPP17 Scottish Ministers are realistic about the practicality of these requirements in remote and rural areas) Specific reference should be made to para 12, 50 and PAN 73 para 26, 34-36, and also circular 12/1996 para 5 and 11. In terms of the Policy it is appreciated that, where a development has a significant impact on the local road network through traffic generation it is appropriate for that impact to be mitigated and a contribution towards the sustainable transport network secured. However, in the case of minor developments this may not be appropriate. Any minor proposals which would not generate a significant amount of traffic or have any material impact upon the existing road or public transport network should not be required to contribute towards the sustainable transport network. With such minor developments it may be impossible for it to make a positive contribution towards the sustainable transport network. An otherwise acceptable proposal for a single dwelling in the rural area would be required to make such a contribution. Given the remoteness of some areas of the Park, it may be the case that the development is inaccessible to any of the methods of transport commonly identified as achieving sustainability. Even if the proposed dwelling is near a public transport route, the level of finance required to result in any positive impact a local bus service would be entirely out of keeping with the scale of the development proposed. The wording is therefore overly prescriptive in its requirement that all proposals must make a positive contribution towards the sustainable transport network. CNPA analysis The wording of the policy will be cross checked against Scottish Government guidance and in particular SPP17 to ensure there is no confusion or omissions. The wording selected may also have resulted in confusion and will be amended accordingly. Proposed Modification Retain reference to government guidance regarding transport. Change reference to Development proposals. Objector Ref Name Sandra McKelvie & John Fleming 027 Grantown on Spey Caravan Park Seafield Avenue Grantown on Spey PH26 3JQ Policy/site ref Settlements - Grantown on Spey Boundary Summary Amend the settlement boundary for Grantown on Spey to include the whole of the Caravan Park. CNPA analysis The comment is noted, and a site visit will be undertaken to assess the extent of the Caravan Park, and amend the proposals map and the settlement boundary to ensure that the appropriate boundary is included. Proposed Modification Amend boundary in line with comment. Objector Ref Name Janet Eileen Jemmett 1 Rhuarden Court Grantown on Spey PH26 3DA Policy/site ref Settlements - Grantown on Spey H1 Summary The proposed housing site at H1 would have an adverse impact on the economic viability of the Caravan Park. The open space associated with this development should therefore be extended to border the caravan park and part of Seafield Avenue to protect the rural setting. The density of the proposed housing site is out of character with this part of the town. The overall density should be reduced to bring it in line with that of surrounding villages. This is particularly needed on the part of the site adjacent to Seafield Avenue. The development if completed as proposed would have an adverse and dangerous impact on the traffic situation within Grantown. Several junctions are already hazardous. Should any development go ahead, serious consideration is needed to how the affected roads and pavements can be improved. CNPA analysis This site has a current, outstanding application and due to the timescales involved this application will be determined in line with the policies of Highland Council Local Plan. The determination of this site will however be carefully monitored to ensure that the appropriate level of detailed information is included within the future plans for the Local Plan. In the event that the detailed application is refused, the situation will be revised. Proposed Modification Include up to date position regarding extant permissions and submitted applications yet to be determined. Objector Ref Name Mr Derek N North 029 6 Monaltrie Way Ballater Aberdeenshire AB35 5PS Policy/site ref Settlements - Ballater H1 Summary H1 in Ballater is within the floodplain, the density is out of keeping with the rest of Ballater, the development would adversely impact on the Games field and its use for the local games, and the parking required would use up 2/3 of the site. If development was to proceed, it should not be in the floodplain, the density should be reduced and more green spaces to absorb any potential flood water, and an appropriate site should be retained for parking for the Games. CNPA analysis The allocated site at Ballater will be reviewed in light of additional information being sought from the Prince’s Foundation. Additional information may then be added to reflect the findings of this study and provide a level of detail regarding mixed uses, access, densities, and areas to be protected from development. Further consultation will then be required within the community to assess the level of support for any modifications. The addition of extra information may impact both on the SEA and the Flood Risk Assessment for the site. Confirm ongoing work regarding flood risk assessment and discussions with SEPA regarding this issue. Proposed Modification Amend H1 to reduce the allocated land making provision for parking. Include reference to confirm density will be in line with that found in Ballater Objector Ref Name Stuart Wright 2 Craigview Place Ballater AB35 5PJ Policy/site ref Settlements - Ballater H1 Summary Development on this site, at this density would destroy the character of Ballater. It would also destroy a valuable piece of good quality agricultural land and therefore erode the economic viability of agriculture in the area. The area already has enough new houses, and too many holiday and second homes. There should therefore be no more large scale housing development and no more houses sold as second homes. CNPA analysis The allocated site at Ballater will be reviewed in light of additional information being sought from the Prince’s Foundation. Additional information may then be added to reflect the findings of this study and provide a level of detail regarding mixed uses, access, densities, and areas to be protected from development. Further consultation will then be required within the community to assess the level of support for any modifications. The addition of extra information may impact both on the SEA and the Flood Risk Assessment for the site. Confirm the housing requirement comes from various reports and studies and is based on a long term growth projection. Confirm that although holiday homes cannot be controlled, affordable homes can and this will form part of any development. Proposed Modification Amend supporting text to H1 to refer to ongoing work of princes foundation - and refer specifically to density of new development and the comparison to the existing density of Ballater. Include reference to ensure design of new development will support Ballater and care will be taken to ensure the character of the planned settlement and the conservation will be protected Objector Ref Name Roger Muhl 031 The Heather Allanglach Wood North Kessock, Inverness IV1 3XD Company Mountain Bothies Association Policy/site ref General Summary No issues raised. CNPA analysis No modification considered necessary as a result of this representation. Proposed Modification No further action required. Objector Ref Name R M Lambert 032 28 Corrour Road Aviemore PH22 1SS Policy/site ref Settlements - Aviemore H2/H3 Summary Development of these sites would have an unacceptable impact on loss of amenity and recreational land in Aviemore. These sites provide a positive benefit to the local community. Further loss of such land should therefore not be allowed. CNPA analysis The modifications need to reflect the latest position regaring the extant permissions, and currently submitted but yet to be determined applications which will be determined under the Highland Council local plan. The need to respect the role the site plays in creating a setting for Aviemore should be retained. The importance in assessing the flood risk in the determination of any application on the site should also be retained. Proposed Modification Modifications to include up to date position regarding extant permissions and submitted applications yet to be determined. Make reference to important issues including flooding, landscaping and natural heritage. Objector Ref Name Ian G Hay 033 Braemore 2 Morven Way Ballater AB35 5SF Policy/site ref Settlements - Ballater H1 Summary The proposed density for housing on H1 is excessive when compared to the population, and the influx of such a large addition of residents would not be sustainable for the village in terms of amenities, medical and educational resources. The density is not in keeping with the character of the village, and the entrance to the village from Tullich will be destroyed. The number of houses built need not be so high. Many of the houses built will end up as holiday homes, If any affordable houses are to be included there must be limitations on who can buy or rent them, and this should be linked to local family connection or local workers. Any new development must be adequately screened, at least to the standard of the Invercauld Park development. CNPA analysis The allocated site at Ballater will be reviewed in light of additional information being sought from the Prince’s Foundation. Additional information may then be added to reflect the findings of this study and provide a level of detail regarding mixed uses, access, densities, and areas to be protected from development. Further consultation will then be required within the community to assess the level of support for any modifications. The addition of extra information may impact both on the SEA and the Flood Risk Assessment for the site. Confirm the housing requirement comes from various reports and studies and is based on a long term growth projection. Confirm that although holiday homes cannot be controlled, affordable homes can and this will form part of any development. Proposed Modification Amend supporting text to H1 to refer to ongoing work of princes foundation - and refer specifically to density of new development and the comparison to the existing density of Ballater. Include reference to ensure design of new development will support Ballater and care will be taken to ensure the character of the planned settlement and the conservation will be protected Objector Ref Name Jean Slimon 034 Blaven Golf Course Road Newtonmore, Inverness-shire PH20 1AR Policy/site ref Settlements - Newtonmore Boundary Summary The land to the south of Newtonmore, previously identified in the consultative plan as Open Space should be retained as such, and included within the settlement boundary. CNPA analysis The comment is noted. A site visit will be undertaken to assess the qualities of the land suggested as open space. If considered to fit within this use the proposals map for the settlement will be amended. In the event that the land is not considered to be open space, the contribution it makes to the settlement will be assessed, and the settlement boundary may thereafter be amended. For clarity additional text will be added to the plan to explain the level of protection offered to sites on the boundary of settlements identified in the Plan. Proposed Modification Include land within settlement boundary to be protected from development. Objector Ref Name DW and IM Duncan 037a Pineacre West Terrace Kingussie PH21 1HA Policy/site ref Housing (land supply) Summary The focus of the Local Plan on housing development is at odds with the first aim of the National Park. CNPA analysis The aims of the Park are paramont in all decision making the Policy 1 must be complied with to allow any development to go forward. Proposed Modification No modifications proposed. Objector Ref 037b Policy/site ref General -links to other agencies Summary There should be mention of SNH and Historic Scotland in the policies where they are the lead regulatory agency. CNPA analysis The comment is noted. Additional reference will be included within the background text in support of each application to clarify the roles of partner organisations. Proposed Modification Amend 1.16 implementing the Plan to highlight the role of partner organisations. Objector Ref 037c Policy/site ref Policy 13 Summary a -Any major development proposals, including those for housing within the Plan should be supported by an assurance of a secured water supply. c -whilst supportive of the principle, the constraints within Kingussie should be recognised. d -support. e -any new developments should be linked to adequate provision for sewage capacity. This again is particularly the case in Kingussie and Newtonmore. CNPA analysis The comments are noted. The policy is written to ensure that new developments do not have a significant adverse impact on current hydrology/water environment and the planning authority has a duty to ensure that all planning proposals comply with this and all other planning policies in the local plan unless there are over riding reasons for departure. It is therefore considered that the wording addresses the issues raised and therefore no modification is considered necessary as a result of this representation. Confirm close working relationship with SW and input into their investment programme to ensure it is in line with the local plan. Also confirm SW approach to connections and supply. Proposed Modification No further action required. Objector Ref 037d Policy/site ref Policy 16 Summary What is small scale? CNPA analysis Further information will be provided in regard to the comment, both in terms of the supporting text and wording in the policy and in any supplementary planning guidance produced to support this policy. Proposed Modification Remove 'small scale' and 'micro' from the wording. Objector Ref 037e Policy/site ref Policy 19 Summary The local community should be able to advise of what projects they consider to be a priority. CNPA analysis The comment is noted. It is the intention of CNPA to base the contributions on community needs surveys and this will be further explained in the supporting text. Proposed Modification Clarify the role of community needs assessments in para 5.20. Objector Ref 037f Policy/site ref Policy 22 Summary To protect sustainable communities there should be a presumption against any more large supermarkets. CNPA analysis The comment is noted. The policy has been worded to correspond to national guidance on the subject, but will be reviewed to ensure the most appropriate criteria are included to achieve the best outcome for the National Park and its settlements. Confirm developments such as that would require to include a retail impact assessment to consider the impact it may have on existing shops. This is done along with the planning application and there are regulations on this kind of consideration given by the Scottish Government. Proposed Modification No modification proposed. Objector Ref 037g Policy/site ref Housing (need) Summary In para 5.27 it is ironic that the designation of the National Park has increased demand for housing which has added to the cost of housing. CNPA analysis The policies in the plan and the allocations for housing development are intended to redress the balance in house prices and the need for affordable housing across the Park. Whilst the asking prices for open market houses cannot be controlled by the CNPA the policies are designed to impact particularly on affordable homes, and provide choice for those in need of such accommodation. No modification considered necessary as a result of this representation. Proposed Modification No modification proposed. Objector Ref 037h Policy/site ref Housing (land supply) Summary The addition of 500 houses as second homes in the table is concerning. The CNPA should take a more robust approach to resisting such homes. The total allocation of 1640 houses in the next 10 years seems unsustainable, in terms of water provision, energy use, pollution, traffic and congestion. Such level of development would have an adverse impact on important habitats in the area, and the impact on landscape is already evident in certain settlements in Strathspey. CNPA analysis Amend table 2 to reflect the parts of the housing market not controlled by the plannnig system. The total figures are however based on work undertaken to establish need within the Park and this study is available on line. Issues such as infrastruture are considered through the planning process and the local plan feeds into the investment programmes for supplies.T he policies regarding housing do however have to be read together with all the other policies of the plan, and the aims of the Park, and development will not therefore occur to the detriment of the natural resources of the Park or undermine its aims. Proposed Modification Amend table 2 to reflect parts of the market not controlled through the planning process. Place consultants work on line. Objector Ref 037i Policy/site ref Policy 23 Summary The wording does not support low cost rented housing, there should be a recognition that developers profits will be less than for those to be made from higher value properties. CNPA analysis The need for a variety of house sizes was established in a paper supporting the local plan produced on behalf of CNPA and available on line for information. However the view has been taken to hold this aspiration as something to be negotiated on a site by site basis to reflect local need. Proposed Modification Move to supporting text of policy 21, para 5.45. Objector Ref 037j Policy/site ref Policy 24 Summary The % of affordable housing should be 80% to meet the local demand. CNPA analysis The findings of the work undertaken by the 3Dragons will influence the affordable housing policy and ensure appropriate statistical support for the approach. Proposed Modification Reduce the requirements to 25% in line with national guidance and 40% in exceptional circumstances and in line with the findings of the 3Dragons report. Objector Ref 037k Policy/site ref Policy 25 Summary New development is rural settlements should only be permitted where it enhances the character of that settlement. CNPA analysis The approach to the identification of settlements outwith those identified in the deposit plan will be reviewed, and in line with the requirements of SPP1 a detailed rational behind the approach taken will be drawn up. Where it is considered that additional detail including land allocations would assist in the level of detail provided for smaller communities and help attain their aspirations, the specific identification of those settlements will be considered as appropriate through modification both Section 7 of the Plan, the policies regarding housing outwith strategic settlements, and the proposals maps. Any change to the approach taken may also impact on the SEA. Proposed Modification Add an additional policy 22 to include rural settlements and identify them in proposals maps. Reduce the figure here to 3 in policy 23. Add to policy regarding groups 'and does not detract from the landscape setting' Objector Ref 037l Policy/site ref Policy 30 Summary The scale of proposed new housing will lead to the need for additional sustainable transport links and there should be additional investment in cycle tracks to match the demand. CNPA analysis The policy is intended to promote alternative forms of transport other than the private car. The CNPA is committed to more sustainable development in all its senses, and new housing developments will have to comply with this policy in the same way as any other proposed development. No modification considered necessary as a result of this representation. Confirm ongoing work to improve cycle networks through the core paths plan and network and close working with other partners in provision. Proposed Modification no modification proposed. Objector Ref 037m Policy/site ref policy 35 Summary The site of the old Aviemore ice rink should be used to benefit locals and visitors CNPA analysis The comment is noted. The policy has been worded to support the widest range of facilities and ensure that they are located in the most appropriate locations across the Park. Any proposal which would support the range of facilities in a settlement such as Aviemore would therefore be supported under the terms of the policy. The CNPA will continue to work closely with partners and developers to encourage and facilitate the provision of such facilities in key settlements. No modification considered necessary as a result of this representation. Confirm ongoing discussions regarding this and finding an appropriate site. Proposed Modification No modification proposed. Objector Ref 037n Policy/site ref Settlements -Aviemore Summary No further development should be permitted west of the A9 at Aviemore. CNPA analysis Land to the west of the A9 is not allocated within the Plan for additional development. No modification considered necessary as a result of this representation. Confirm that no new allocations fall outwith the areas described. Proposed Modification No further action required. Objector Ref 037o Policy/site ref Settlements -An Camas Mor Summary This area should remain undeveloped CNPA analysis This site, previously allocated within the Highland Council Local Plan in 1997 has been considered a realistic concept to providing for the housing needs of the Badenoch and Strathspey area since the creation of the National Park Authority. Further information will be provided as a result of this review to detail the numbers of houses needed across the Park, and how these houses will be provided for local people at affordable prices and held that way in perpetuity. The development of An Camas Mor will require careful consideration to be given to the surrounding landscape and natural heritage interests and the CNPA will work closely with all involved to ensure this is done to an appropriate standard. Confirm existence of site within the current Highland Counicl Plan and so this plan has continued the allocation. Proposed Modification No modication proposed. Objector Ref 037p Policy/site ref Settlements -Kingussie OS1 Summary Is there a real requirement for 300 additional houses in Kingussie. However it is good to see that the woodland surrounding the town is outwith the settlement boundary and therefore protected. In OS1 'valley' should be replaced with 'gorge'. CNPA analysis A detailed paper outlining the background to the housing land requirement calculations, land supply requirements and proposed balance of house sizes will be prepared to clarify the rationale behind the housing policies. Within this reference will be made to the relationship between the provision of new housing within the Park and the National Park Plan and aims of the Park. Further explanation will also be required to justify the allowance made in table 2 for second homes and vacant properties, and detail how the approach taken will benefit local people. On completion of this paper, information will be circulated to all those who made representation on this issue, and detailed consultation undertaken to assess the level of continued objection, which may result in a modification to the calculations and allocations made. The comment regarding terminology is also noted. Confirm allocations are based on consultants work, waiting lists, etc and is continually monitored. Proposed Modification Change wording in OS1. Objector Ref 037q Policy/site ref Settlements - Ballater Summary The level of proposed new development would adversely alter the character of Ballater. CNPA analysis The scale of development is linked to work done on establishing the housing need within the area, and further work will be done to prepare information which fully explains the thinking behind the approach taken. Additional work will also be undertaken to ensure that the scale of development is not out of character with the densities currently built in Ballater. This will be done in conjunction with ongoing work with the Princes Foundation to prepare a masterplan for the site, and a long term vision for the future growth of Ballater. Confirm the housing requirement comes from various reports and studies and is based on a long term growth projection. The design of new development will support Ballater and care will be taken to ensure the character of the planned settlement and the conservation will be protected Proposed Modification Amend supporting text to ensure design respects character of Ballater. Objector Ref 037r Policy/site ref Settlements -Carr-bridge Summary The site for 117 houses in Carrbridge should not be included. CNPA analysis The site has outline permission granted and a detailed application has now been submitted which is being dealt with by CNPA. Due to the timescales the current application will be carefully monitored to ensure that the appropriate proposal or detailed information is included within the future plans for the Local Plan. However, as the application is currently registered, it will be determined in line with the policies in Highland Council Plan. In the event that the detailed application is refused, the situation will be revised. . Proposed Modification Include up to date info on extant permissions and outstanding applications. Objector Ref 037s Policy/site ref Settlements -Kincraig Summary The site for development in Kincraig is important botanically and should not be allocated for development. CNPA analysis The comments are noted, and the site will be reviewed to assess the natural heritage interests on the site. The site will also be reviewed in light of the SEA to ensure appropriate analysis of its development has been included. Proposed Modification Remove H2. Objector Ref 037t Policy/site ref Settlements - Nethy Bridge H2 Summary The scale of development is too great. CNPA analysis This site has outline permission for housing and throughout the forthcoming consultation modifications to the local plan will reflect the position regarding extant permissions and submitted planning applications being determined under the Highland Council Local Plan. Where possible the local plan will be used to influence the scale and design of future development to ensure that it is appropriate for the village and is matched with an appropriate level of service provision. Confirm that site has outline permission and CNP will work to influence scale and design of future development. Proposed Modification No further modication required. Objector Ref 037u Policy/site ref Policy omission Summary The is a need for an additional policy regarding permitted developments in regard to agricultural and forestry operations, hill tracks and new paths and bridges. CNPA analysis Permitted developments for all forms of development, as relevant are set out in separate legislation and regulation and developers should refer to the appropriate document to consider whether their proposal does or does not fall within the permitted development rights. To repeat these regulations here would be to add a level of duplication which the Plan is endeavouring to steer away from. In regard to hill tracks, and other operations referred to the comment is noted. However it is considered that any application for such development will be judged against all the policies in the plan and there is not a need to specifically highlight them within separate policies. The intention throughout the plan is that all policies should be taken into account when considering any development proposal. The wording within the Introduction will be amended to clarify this position. Confirm the issue of tracks and agricultural operations would be considered under all policies of the plan including specifically those regarding 'conserving and enhancing' and not under a particular policy regarding tracks. All policies of the plan must be complied with where relevant to gain permission, therefore a topic specific policy is not considered appropriate. Proposed Modification No modification proposed. Objector Ref Name David Scobbie 038 Muir Homes, Muir House Belleknowes Industrial estate Inverkeithing, Fife KY11 1HY Company Muir Homes Policy/site ref Settlements - Grantown on Spey H1, OS1 Summary H1 does not include all the land which could be developed for housing without adversely impacting on the fens and mires contained within OS1. The addition of extra land currently within OS1 would allow a more cohesive development while still protecting the wetland. The OS site should then be reduced but could be expanded to the west to incorporate land adjacent to the caravan park to safeguard the open space provision. CNPA analysis This site has a current, outstanding application and due to the timescales involved this application will be determined in line with the policies of Highland Council Local Plan. The determination of this site will however be carefully monitored to ensure that the appropriate level of detailed information is included within the future plans for the Local Plan. In the event that the detailed application is refused, the situation will be revised. Proposed Modification Include up to date position regarding extant permissions and submitted applications yet to be determined. Objector Ref Name Little Tolly Properties Ltd Agent Gordon Gauld 039 Bankhead Croft Cottage Midmar Inverurie AB51 7QD Company Gordon Gauld Architectural Services Policy/site ref Policy 25 Summary The size of the group should be reduced to reflect the traditional size of settlements in Aberdeenshire. (to 5-8). A suggested site at Waterside for affordable housing should be considered. CNPA analysis The approach to the identification of settlements outwith those identified in the deposit plan will be reviewed, and in line with the requirements of SPP1 a detailed rational behind the approach taken will be drawn up. Where it is considered that additional detail including land allocations would assist in the level of detail provided for smaller communities and help attain their aspirations, the specific identification of those settlements will be considered as appropriate through modification both Section 7 of the Plan, the policies regarding housing outwith strategic settlements, and the proposals maps. Any change to the approach taken may also impact on the SEA. Proposed Modification Add an additional policy 22 to include rural settlements and identify them in proposals maps. Reduce the number of dwellings to 3 in policy 23. Objector Ref Name Richard Renton 040 Nethybridge & Vicinity Community Council Company Nethybridge and vicinity community council Policy/site ref Settlements - Nethy Bridge Summary Land between the Mountview Hotel and Wilburn Homes should be allocated as open space and protected for community recreational use. CNPA analysis The comment is noted. A site visit will be undertaken to assess the qualities of the land suggested as open space. If considered to fit within this use the proposals map for the settlement will be amended. In the event that the land is not considered to be open space, the contribution it makes to the settlement will be assessed, and an alternative allocation considered to protect it and the contribution the land makes to the character of the settlement. An assessment of the protection already offered to the site by virtue of the planning permission granted on the adjacent site will also be made. Proposed Modification At Mountview Hotel Identify land to be protected (in line with previous planning permission ) Objector Ref Name Fergus Ewing MSP 041 Constituency Office Highland Railhouse Station Square, Inverness IV1 1LE Policy/site ref Settlements - Newtonmore/employment allocations Summary Additional land should be allocated for employment use, particularly within Newtonmore. CNPA analysis The comment is noted. Modifications will endeavour to ensure a more appropriate balance is struck between development opportunities, allocation of land for services to support this including creating the appropriate level of opportunities for employment growth, and the protection of the special qualities of the area as identified as a National Park. The wording used within policies throughout will be clarified to ensure the appropriate level of guidance is available for developers, and the Plan is easy to understand and use. As a result of this consultation process further work will be undertaken to link more closely the demand for housing to economic prosperity and the need to work within the aims of the Park. This will be linked to the work ongoing relating to sustainability. Proposed Modification Allocate employment land in Newtonmore. Objector Ref Name RG and CE Armstrong 042 59 North Bar Within Beverley East Riding of Yorkshire HU17 8DG Policy/site ref Housing (affordable) Summary Affordable homes should not be mixed through open market housing as this can adversely impact on the value of the latter. Also there should be a greater allocation of land within rural settlements to allow for development to meet local demand for housing. CNPA analysis The approach to 'pepper potting' affordable houses is one which has been tried and tested across the country for many years. However, the approach taken will be assessed on a case by case basis and a prescriptive approach will not be imposed. Proposed Modification Amend policy 21 in light of 3Dragons findings. Objector Ref Name Bryan Grozier 046 Camerary By Grantown on Spey PH26 3PR Policy/site ref Settlements - Grantown on Spey H1 Summary The allocation of land for housing in Grantown on Spey and Aviemore does not support the aims of the National Park, and the CNPA should not be pressured to allocate land by land owners. CNPA analysis This site has a current, outstanding application and due to the timescales involved this application will be determined in line with the policies of Highland Council Local Plan. The determination of this site will however be carefully monitored to ensure that the appropriate level of detailed information is included within the future plans for the Local Plan. In the event that the detailed application is refused, the situation will be revised. Proposed Modification Include up to date position regarding extant permissions and submitted applications yet to be determined. Objector Ref Name Mr D Black Agent MA Munro 047 Laggan of Clachaig Munro chartered quantity surveyors Nethybridge Ardconnel PH25 3DY Woodlands Terrace, Grantown on Spey PH 26 3JN Policy/site ref Settlements - Nethy Bridge Summary The existing land allocated in Nethy Bridge has been so for some time without development progressing. They are unlikely to be effective in the medium to long term, and are under mature woodland which impacts on the development potential for the site and the amount of affordable homes which could be developed. The CNPA is required to ensure adequate effective land is allocated and within Nethy Bridge the only other land allocated is H1 which the community wish to see retained as community use. Therefore the is no land effective in the short to medium term. As a result an additional site should be allocated at Lettoch Road . The site is outwith the 30mile speed limit as are the other sites allocated. Visibility from the site is not an issue, and the site topography would not require extensive restructuring. The site has natural defendable boundaries and there is also the opportunity to create landscaping zones within the site. It is immediately adjacent to the existing housing stock, so that ay extension of this is in accordance with the Scottish Government wish to have new developments abut onto the existing settlement. The proposed modification is supported by national planning policies – outwith the settlement limits as defined by town and village envelopes. Further, where brownfield and infill sites cannot fulfil the hosing requirement it is necessary to release greenfield land next to built up areas. Policy 5.41 of the local plan states that ‘an additional 800 houses land for which must be identified’. We fully appreciate the need for affordable housing and my client understands that I will be discussing and agreeing with you, the Planning Authority, a proportion of affordable housing on this site should this application for modifying the plan be accepted. In order for the affordable element to be viable, we would request that the whole site be zoned for residential to enable to affordable housing to work. This site is deliverable in the short term meeting the current demands for smaller family units as opposed to the larger detached bungalows and villas. CNPA recognises the rise in population and there are growing employment opportunities in the Nethy Bridge/Grantown area and there is no house building going on at present, this site can be delivered in the short term. This site fits well with the key objective of sustainability in that it is well located but also it will encourage young people to stay, return and come to Nethy Bridge in the short/longer term. A broader range of two and three bedroom houses and tenure is an important element of creating a long term sustainable population. CNPA analysis The allocated sites within Nethy Bridge will be analysed in light of the comments received. This analysis will be linked to the need for housing land within the area, and the effectiveness of the sites included in the deposit plan. The sites will also be judged against the SEA findings, the physical constraints of these sites and the requirements for effectiveness as set out in national guidance. Having assessed these sites, a review will be undertaken of the alternative land suggested to ascertain its qualities in meeting the local housing need, and the impact it would have when assessed through the SEA. Confirm that effective 5 year supply and future growth areas have been identified in line with requirements. Therefore no additional land is required to meet the demand. Proposed Modification No modificaiton proposed. Objector Ref Name W Cassells Agent MA Munro 048a Balnafettach Munro chartered quantity surveyors Cromdale Ardconnel PH26 3LW Woodlands Terrace, Grantown on Spey PH 26 3JN Policy/site ref Settlements -Cromdale Summary An additional area to the north of H1 forms part of the same field and will become redundant if H1 is developed and should therefore be included within the allocation. The topography of the site is sloping in places and would not require extensive re-structuring. It has natural defendable boundaries and there is also the opportunity to create landscaping zones within the site. Development of the site would be adjacent to existing housing stock and any extension of this is in accordance with the Scottish Government wish to have new development abut onto the existing development. The proposed modification is supported by national planning policies – outwith the settlement limits as defined by town and village boundaries. Further, where brownfield and infill sites cannot fulfil the housing requirement it is necessary to release greenfield land next to built up areas. The local plan identifies the need for an additional 800 houses and this site could in part be used for affordable housing. The site is deliverable in the short term. CNPA analysis The allocated sites within Cromdale will be analysed in light of the comments received. This analysis will be linked to the need for housing land within the area, and the effectiveness of the sites included in the deposit plan. The sites will also be judged against the SEA findings, the physical constraints of these sites and the requirements for effectiveness as set out in national guidance. Having assessed these sites, a review will be undertaken of the alternative land suggested to ascertain its qualities in meeting the local housing need, and the impact it would have when assessed through the SEA. Proposed Modification H1 add remaining field area within proposed site. Objector Ref 048b Policy/site ref Settlements -Cromdale Summary An additional site should be included as a housing allocation within the settlement. The current boundary stops at an illogical point 40yrds short of a heavily wooded area, and this site would take the boundary to this natural edge. The site is therefore considered an infill site to create two house plots in an area in need of additional housing land. The site topography is gently sloping in places and will not require extensive re-structuring. It has natural defendable boundaries and there is also the opportunity to create landscaping zones behind the site as my client owns the land. It is immediately adjacent to the existing housing stock, so that any extension of this is in accordance with the Scottish Government wish to have new development abut onto the existing development. The modification is supported by national planning policies – outwith the settlement limits as defined by town and village boundaries. Further, where brownfield and infill sites cannot fulfil the housing requirement it is necessary to release greenfield land next to built up areas. The local plan states the need for an additional 800 houses. This site could be used to make a contribution to the affordable housing fund. CNPA analysis The allocated sites within Cromdale will be analysed in light of the comments received. This analysis will be linked to the need for housing land within the area, and the effectiveness of the sites included in the deposit plan. The sites will also be judged against the SEA findings, the physical constraints of these sites and the requirements for effectiveness as set out in national guidance. Having assessed these sites, a review will be undertaken of the alternative land suggested to ascertain its qualities in meeting the local housing need, and the impact it would have when assessed through the SEA. Proposed Modification Amend settlement boundary to include the land. Objector Ref Name Colin Robertson 050 Priormuir, 11 Monaltrie Avenue Ballater AB35 5RX Policy/site ref Settlements - Ballater H1 Summary The development of H1 should be done in a way which does not require access through Monaltrie Avenue. Access should be provided through Craigendarroch Walk directly to Craigview Road. CNPA analysis The allocated site at Ballater will be reviewed in light of additional information being sought from the Prince’s Foundation. Additional information may then be added to reflect the findings of this study and provide a level of detail regarding mixed uses, access, densities, and areas to be protected from development. Further consultation will then be required within the community to assess the level of support for any modifications. The addition of extra information may impact both on the SEA and the Flood Risk Assessment for the site. Confirm need for traffic impact assessments and also that any proposal will have input from council roads engineers to ensure appropriate standards are met. Proposed Modification No modification proposed. Objector Ref Name James Mitchell 051 18 Seafield Court Grantown on Spey PH26 3LE Policy/site ref Settlements - Grantown on Spey H1 Summary The development of H1 would have a significant adverse impact on the economic prosperity of Grantown Campsite which in turns makes a significant contribution to the economy of the town as a whole. Its development would be contrary to the aims of the National Park and as such any development on the site should be done in sympathy with the operations of the campsite. It should be single storey as in Seafield Court and low density. There should be a ‘green’ border between it and the camp site and the undulations of the field levelled to preserve views. CNPA analysis This site has a current, outstanding application and due to the timescales involved this application will be determined in line with the policies of Highland Council Local Plan. The determination of this site will however be carefully monitored to ensure that the appropriate level of detailed information is included within the future plans for the Local Plan. In the event that the detailed application is refused, the situation will be revised. Proposed Modification Include up to date position regarding extant permissions and submitted applications yet to be determined. Objector Ref Name Bill Carr 052a Glenisla Dalwhinnie Inverness-shire PH19 1AB Company Dalwhinnie Community Council Policy/site ref Settlements -Dalwhinnie Summary The housing sites proposed would all fall below the limit for a mandatory proportion to be affordable housing but which taken together would substantially increase housing stock within the village. This approach is contrary to the CNPA’s stated philosophy of encouraging sustainable communities through the provision of affordable local housing. CNPA analysis The policies regarding affordable housing apply to all developments, regardless of size. The wording however seems to be unclear and will be amended to give greater guidance on the position. Confirm all developments will have to provide a contribution to affordable houses. The sites go towards the housing targets for the area and will therefore contribute to both sustainable communities and affordable provision. Proposed Modification No modification proposed. Objector Ref 052b Policy/site ref Settlement Boundaries Summary Wish to confirm that there are no proposed developments in the Dalwhinnie area beyond the defined settlement boundary without appropriate local consultation. CNPA analysis The designation of the settlement boundary requires additional information to clarify what development may occur within and outwith it, and to clarify the reason behind creating the boundary. Proposed Modification Include in intro to cpt 7 explanation of approach taken to proposals inside and outwith settlement boundaries. Objector Ref 052c Policy/site ref Settlements -Dalwhinnie H1 Summary Within H1 why has a density of only 6 houses been identified, which would therefore not require an 'affordable housing' component? CNPA analysis The policies regarding affordable housing apply to all developments, regardless of size. The wording however seems to be unclear and will be amended to give greater guidance on the position. Confirm all developments will have to provide a contribution to affordable houses. Proposed Modification No modificaiton proposed. Objector Ref 052d Policy/site ref Settlements -Dalwhinnie H2 Summary Why has this site been allocated? CNPA analysis The site has been included to provide a level of choice, and was considered to be a gap site where new development could compliment the character of the settlement. The allocation could be removed however, and any new development considered on its merits since the site is a small site within the settlement boundary. The sites in Dalwhinnie will therefore be reviewed to ensure that they are in line with the requirements of the community, and provide an appropriate level of guidance to comply with the requirements of SPP1. Confirm the small site was included as an infill site in the draft plan and has been carried forward from then. Proposed Modification No modification proposed. Objector Ref 052e Policy/site ref Settlements -Dalwhinnie H3 Summary How many houses will be developed on this site and how many will be affordable? CNPA analysis The policies regarding affordable housing apply to all developments, regardless of size. The wording however seems to be unclear and will be amended to give greater guidance on the position. The capacity of the site will also be reviewed in light of the comments and an indicative figure included to give greater clarity. Confirm the position regarding affordable houses in terms of sites with outline permission. Proposed Modification Clarify what extant permission is for. Objector Ref 052f Policy/site ref Settlements -Dalwhinnie H4 Summary Why on a site of this size has a density of only 6 houses been proposed, which would therefore not require an 'affordable housing' component CNPA analysis The policies regarding affordable housing apply to all developments, regardless of size. The wording however seems to be unclear and will be amended to give greater guidance on the position. Confirm all developments will have to provide a contribution to affordable houses. Proposed Modification No modification proposed. Objector Ref 052g Policy/site ref Settlements -Dalwhinnie OS1 Summary The entire area and not just the section allocated at OS1 should be protected from development. CNPA analysis In light of the comments received, the sites in Dalwhinnie will be reviewed to ensure that they are in line with the requirements of the community, and provide an appropriate level of guidance to comply with the requirements of SPP1. Amendments will then be made to reflect any additional information received from the community and the landowner. Proposed Modification Amend wording of OS1 to reflect that woodland scheme may not go ahead. Amend boundary to include the whole field. Objector Ref Name Mr George Inglis 053 25 Monaltrie Avenue Ballater AB35 5RX Policy/site ref Settlements - Ballater H1 Summary Any development on this site should not be accessed through Monaltrie Avenue, and the site should be reduced in size to remove the area to the west of the Cinder Path and the access path to Monaltrie House. CNPA analysis The allocated site at Ballater will be reviewed in light of additional information being sought from the Prince’s Foundation. Additional information may then be added to reflect the findings of this study and provide a level of detail regarding mixed uses, access, densities, and areas to be protected from development. Further consultation will then be required within the community to assess the level of support for any modifications. The addition of extra information may impact both on the SEA and the Flood Risk Assessment for the site. Confirm need for traffic impact assessments and also that any proposal will have input from council roads engineers to ensure appropriate standards are met. Proposed Modification Include reference to setting of Monaltrie House in text Objector Ref Name Mr Mark Cox 054a Balnagowan Balnagowan Brae Nethybridge PH25 3DR Policy/site ref Settlements - Nethy Bridge Summary The settlement boundary of Nethy Bridge should be amended to include Balnagowan Wood and the land to the east of the River adjacent to new housing at Lynstock Park and both these areas should be clearly identified as protected from future development of any kind as both contribute to the strategic setting of the village. CNPA analysis The comment is noted. A comprehensive review will be undertaken in Nethy Bridge to assess the importance of the various areas suggested for inclusion as open space. Where the sites are considered to fit within the use as open space the proposals map will be amended. Where the land is not considered to be open space, the contribution it makes to the settlement will be assessed, and an alternative allocation considered to protect it and the contribution the land makes to the character of the settlement. Proposed Modification Include in intro to cpt 7 para 7.5 explanation of approach taken to proposals inside and outwith settlement boundaries. Objector Ref 054b Policy/site ref Settlements - Nethy Bridge Summary The land adjacent to the MountView Hotel should be protected from future development and maintained for important amenity use. CNPA analysis The comment is noted. A site visit will be undertaken to assess the qualities of the land suggested as open space. If considered to fit within this use the proposals map for the settlement will be amended. In the event that the land is not considered to be open space, the contribution it makes to the settlement will be assessed, and an alternative allocation considered to protect it and the contribution the land makes to the character of the settlement. An assessment of the protection already offered to the site by virtue of the planning permission granted on the adjacent site will also be made. Proposed Modification At Mountview Hotel Identify land to be protected (in line with previous planning permission) Objector Ref Name Mr Steven Broadhurst 055 Kelvinbank Dell Road Nethybridge PH25 3DG Policy/site ref Settlements - Nethy Bridge Summary A number of important areas of open space have not been afforded an adequate level of protection from future development. These sites are the land adjacent to the Mountview Hotel, land adjacent to the River at the south end between Dell Road and Lynstock, and Balnagowan Woods. CNPA analysis The comment is noted. A comprehensive review will be undertaken in Nethy Bridge to assess the importance of the various areas suggested for inclusion as open space. Where the sites are considered to fit within the use as open space the proposals map will be amended. Where the land is not considered to be open space, the contribution it makes to the settlement will be assessed, and an alternative allocation considered to protect it and the contribution the land makes to the character of the settlement. Proposed Modification Include in intro to cpt 7 para 7.5 explanation of approach taken to proposals inside and outwith settlement boundaries. OS1 extend boundary at Dell Road on west side of river At Mountview Hotel Identify land to be protected (in line with previous planning permission ) Objector Ref Name James and Evelyn Sunley 056a 12 Lochnagar Way Ballater AB35 5PB Policy/site ref Policy 33 Summary The local plan should include more detailed policies to support industrial and tourist development to create sustainable full time employment. There is over emphasis on housing and no detail on encouraging business incentives or creating employment for people who might live in the houses proposed. Also there is little mention of the facilities and infrastructure needed to support such levels of development. CNPA analysis Modifications will endeavour to ensure a more appropriate balance is struck between development opportunities for business and tourism and the protection of the special qualities of the area as identified as a National Park. The wording used within this policy will be clarified to ensure the appropriate level of guidance is available for developers, and the Plan is easy to understand and use together with ensuring the appropriate level of protection and compliance with national and international obligations placed on the CNPA. The approach taken in the proposals maps will also be reviewed to ensure appropriate levels of clarity and guidance are included. Proposed Modification Amend proposals for Ballater to reflect work being done by Princes Foundation. Add employment proposals to proposals maps. Amend introduction to section 6 to give greater support and understanding to the tourism sector and the part it plays in the economy of the Park. Objector Ref 056b Policy/site ref Settlements omissions Crathie, Dinnet Summary Dinnet and Crathie should be identified as settlements and land identified within them for development potential. CNPA analysis The approach to the identification of settlements outwith those identified in the deposit plan will be reviewed, and in line with the requirements of SPP1 a detailed rational behind the approach taken will be drawn up. Where it is considered that additional detail including land allocations would assist in the level of detail provided for smaller communities and help attain their aspirations, the specific identification of those settlements will be considered as appropriate through modification both Section 7 of the Plan, the policies regarding housing outwith strategic settlements, and the proposals maps. Any change to the approach taken may also impact on the SEA. Confirm that some settlements will be identified including dinnet, but outwith these opportunities still exist in a much less structured way for housing and employment - the way the plan is formed therefore allows small communities a much greater degree of flexiblity than if a line is drawn on proposals maps. Proposed Modification Include some rural settlements within proposals. Objector Ref 056c Policy/site ref SEA Summary The SEA should further explain how it reaches its conclusions. CNPA analysis The comments are noted, but CNPA must refer to the responses from the 4 statutory consultees on SEA who have all commented on the clarity and soundness of the Environmental Report. The findings of the ER will impact directly on the local plan, its policies and proposals and this will be done in line with the legislative requirements and in liaison with the consultees. Proposed Modification A number of changes have been made to the SEA environemntal report, which address the concerns raised. Objector Ref 056d Policy/site ref General -layout Summary The local plan approach of having policies which apply equally across the Park is not realistic, and there should be area based policies to account for the different requirements of the various communities within the Park. The allocation of land for development must also be over a greater period of time and must include the provision of services and amenities so that new development can adequately be incorporated within the existing settlements. CNPA analysis The approach taken attempts to create a clear planning framework for the Park area as a whole. The wording of individual policies should provide sufficient flexibility to account for the needs of individual communities, but further clarity will be included as a proposed modification within the Introduction Section to further explain how to use the Plan and its policies and proposals. Further consideration will also be given to the long term future planning for the Park to ensure that land allocations are appropraite to take the Park and its various communities into a success long term future. Proposed Modification Amend 1.5 purpose of Plan to explain the role of the Plan across the Park. Include in table 4 clear timescales for short, medim and long term provision. Objector Ref 056e Policy/site ref General -Consultation Summary The consultation carried out does not represent the whole community. CNPA analysis The comment is noted. The consultation process is designed to gain a full understanding of all views within the Park and uses a variety of techniques to gain a full picture of the views of the community. It does not rely on particular events and considers all representations received of equal importance. No modification considered necessary as a result of this representation. Proposed Modification No modification needed Objector Ref 056f Policy/site ref SEA Summary The SEA assessment needs greater examination as its findings are so important to future development. CNPA analysis The comments are noted, but CNPA must refer to the responses from the 4 statutory consultees on SEA who have all commented on the clarity and soundness of the Environmental Report. The findings of the ER will impact directly on the local plan, its policies and proposals and this will be done in line with the legislative requirements and in liaison with the consultees. Proposed Modification Comments will be reviewed prior to adoption to take into account the views expressed. No modifications needed at this stage. Objector Ref 056g Policy/site ref Policy 01 Summary The wording is overly complicated and confusing. The policy seems to conflict with all other policies in the Plan and seems too powerful. CNPA analysis The comment is noted. Modifications within the Introduction and Context sections will endeavour to clarify the relationship of the Local Plan and its relationship with other documents including the aims of the Park, and the Park Plan, and also national planning guidance. Modifications will also endeavour to ensure a more appropriate balance is struck between development opportunities and the protection of the special qualities of the area as identified as a National Park. Throughout proposed modifications will endeavour to clarify while providing an appropriate level of guidance for developers and interested parties. Proposed Modification Revise policy 1 in total to reflect the various comments made and make better links with the aims of the Park. Objector Ref 056h Policy/site ref Policy 13 Summary The policy should be more specific and flood prevention measures should be identified in association with new housing land allocations. CNPA analysis The aim of the policy is to ensure that management of the water environment in line with the established legal framework which exists, and other national guidance regarding flooding and drainage. The issue of flood risk assessments will be reviewed in line with the comments received from SEPA and the appropriate changes will be made both to the policy wording and settlement proposals where necessary. Confirm in letter that SEPA comments have been taken on board to amend wording. Proposed Modification Modifications in line with SEPA information provided. Objector Ref 056i Policy/site ref Housing Summary The housing allocations should recognise the important part of the economy played by retiring people, which could be used to assist affordable housing provision. CNPA analysis Two background papers undertaken by consultants relating to population figures and affordable housing requirements are available on line. A summary of the approach taken will be appended to the Local Plan. Also amendments will be made to the introduction to the housing section to clarify the need for housing in the Park. Proposed Modification Modifications to introduction to housing section to clarify need and approach to affordable housing. Also include appendix to add further detail. Add consultants reports to the web page for general viewing. Objector Ref 056j Policy/site ref Settlements - Ballater H1 Summary The proposal for H1 should greater reflect the findings of the Prince's Foundation proposals for Ballater. CNPA analysis The allocated site at Ballater will be reviewed in light of additional information being sought from the Prince’s Foundation. Additional information may then be added to reflect the findings of this study and provide a level of detail regarding mixed uses, access, densities, and areas to be protected from development. Further consultation will then be required within the community to assess the level of support for any modifications. The addition of extra information may impact both on the SEA and the Flood Risk Assessment for the site. Confirm CNPA are keen to work with Princes Foundation to ensure good development is realised. Proposed Modification Include para in intro to Cpt 7 7.4 to promote mixed development to promote sustainable communities. Amend H1 to reduce the allocated land making provision for parking. Amend text to H1 to reflect Princes Foundation and need for sustainable communites. Amend boundary on plan to account for Games Park and Princes Foundation proposals. Objector Ref 056k Policy/site ref Policy 20 Summary The local plan should highlight the need for government agencies to help encourage new business in the form of rates relief and tax breaks. CNPA analysis The comments are noted, and whilst interesting are not linked to land use planning and so are not appropriate for inclusion within the Local Plan. The CNPA will however continue to work with partners to bring this issue to the attention of those involved to ensure the best approach is taken for businesses in the Park area. Proposed Modification Add economic development sites into settlements identified in the proposals section. Objector Ref 056l Policy/site ref Settlements - Ballater Summary The housing requirements in NEST which identify 150 homes for the Mar area more reflecting the needs of the area. The proposed 250 houses is extreme and unacceptable. CNPA analysis The scale of development is linked to work done on establishing the housing need within the area, and further work will be done to prepare information which fully explains the thinking behind the approach taken. Additional work will also be undertaken to ensure that the scale of development is not out of character with the densities currently built in Ballater. This will be done in conjunction with ongoing work with the Princes Foundation to prepare a masterplan for the site, and a long term vision for the future growth of Ballater. Confirm the housing requirement comes from various reports and studies and is based on a long term growth projection. Proposed Modification No modification proposed. Objector Ref 056m Policy/site ref Housing (need) Summary The number of affordable housing units needed in different parts of the Park are not comparable and the plan needs to identify how many LOCAL people need accommodation and employment. CNPA analysis The supply of housing land is based on studies undertaken to assess need and methods of provision in particular affordable housing. CNPA also work closely with the housing authorities to ensure the most up to date information is available on local need. Also we continue to try and influence the use of housing waiting lists. Proposed Modification No modification proposed. Objector Ref 056n Policy/site ref Policy 23,24 Summary The % of affordable houses proposed would have an adverse impact on the open market and is a form of social engineering. Within an amendment to this policy, developers will go elsewhere. The house sizes also needs to be carefully considered to reflect the local population with areas with an aging population needing more single storey developments with small gardens. Again there should be a recognition of the need for high end developments for private investment. CNPA analysis The need for a variety of house sizes was established in a paper supporting the local plan produced on behalf of CNPA and available on line for information. However the view has been taken to hold this aspiration as something to be negotiated on a site by site basis to reflect local need. The need for affordable homes does however remain a key aim of the local and national park plans and is retained in a revised form in policy 21, supported by the work of the 3Dragons study. Proposed Modification Move to supporting text of policy 21, para 5.45. In Policy 21 change % requirements to 25 (in line with national guidance) and 40 (in line with 3Dragons report) for exceptional sites. Objector Ref 056o Policy/site ref Housing (affordable) Summary The housing allocation policy must ensure that housing is for local people and essential workers and not for people from national waiting lists. CNPA analysis The role of waiting lists is important in identifying those in need. As CNPA is not the housing authority we must work with the local authorities on the use of waiting lists, and there are clear legal guidelines on this. CNPA will therefore continue to work closely with the LAs to try and secure the most appropriate end for local people in greatest need. Proposed Modification No modifications proposed. Objector Ref 056p Policy/site ref Policy 32 Summary Waste management should be consistent across the 4 local authorities. CNPA analysis The CNPA will continue to work closely with its local authority partners to ensure a consistent approach to reached across the Park. The wording of the policy will be reviewed to ensure this is achieved through the local plan where possible. Proposed Modification Add para to clarify role of waste plan and strategies. Objector Ref 056q Policy/site ref Settlements - Ballater Summary Land should be identified for the development of hotel and hostel accommodation within Ballater. CNPA analysis Modifications will endeavour to ensure a more appropriate balance is struck between development and tourism opportunities and the protection of the special qualities of the area. Within Ballater, general policies have been included to do this, rather than identify a particular site which may be considered by some as restrictive. However work will continue with the local chamber of commerce to ensure that the approach taken meets with the aspirations of the local community. Confirm that policies ( esp 33 and para 6.3 and 6.4) aim to promote development such as tourism rather than shoe horn proposals into particular sites. Proposed Modification Include para in intro to Cpt 7 7.4 to promote mixed development to promote sustainable communities. Objector Ref 056r Policy/site ref Policy 34 Summary A road should be created between Braemar and Glen Feshie and on to Kingussie to link both sides of the Park to improve access. CNPA analysis The policy is worded to consider applications for development which impact on outdoor access. Should a proposal come forward as mentioned in the representation it would be considered on its merits and judged against this policy and the others of the local plan. No modification considered necessary as a result of this representation. Confirm this would be considered on its merits if a proposal came forward but it would be unlikely to be supported due to the impact it would have on landscape, wildness, etc. Proposed Modification No modification considered necessary as a result of this representation. Objector Ref 056s Policy/site ref Settlements - Ballater Summary The local plan should identify sites to meet local aspirations for recreational development including an outdoor activity centre, indoor sports centre, theatre, cinema etc. CNPA analysis Modifications will endeavour to ensure a more appropriate balance is struck between development and tourism opportunities and the protection of the special qualities of the area. Within Ballater, general policies have been included to do this, rather than identify a particular site which may be considered by some as restrictive. However work will continue with the local chamber of commerce to ensure that the approach taken meets with the aspirations of the local community. Confirm that policies (esp 34 and 35) aim to promote development such as recreational developments rather than direct them particular sites. Proposed Modification Include para in intro to Cpt 7 7.4 to promote mixed development to promote sustainable communities. Objector Ref 056t Policy/site ref Settlements - Ballater Summary Provision should be made within the Local Plan for football pitches and other outdoor projects including supporting the Ballater Games. CNPA analysis The allocated site at Ballater H1 will be reviewed in light of additional information being sought from the Prince’s Foundation. Additional information may then be added to reflect the findings of this study and provide a level of detail regarding mixed uses, access, densities, and areas to be protected from development. Further consultation will then be required within the community to assess the level of support for any modifications. The addition of extra information may impact both on the SEA and the Flood Risk Assessment for the site. Proposed Modification Amend H1 to reduce the allocated land making provision for parking. Include reference to need for recreational land within masterplan. Objector Ref 056u Policy/site ref Settlements - Ballater H1 Summary The density of H1 is out of keeping with surrounding developments in Ballater. The proposal should reflect the findings of the Prince's Foundation study of Ballater and the Aberdeenshire allocation previously agreed. CNPA analysis The allocated site at Ballater will be reviewed in light of additional information being sought from the Prince’s Foundation. Additional information may then be added to reflect the findings of this study and provide a level of detail regarding mixed uses, access, densities, and areas to be protected from development. Further consultation will then be required within the community to assess the level of support for any modifications. The addition of extra information may impact both on the SEA and the Flood Risk Assessment for the site. The design of new development will support Ballater and care will be taken to ensure the character of the planned settlement and the conservation will be protected Proposed Modification Amend supporting text to H1 to refer to ongoing work of princes foundation - and refer specifically to density of new development and the comparison to the existing density of Ballater. Objector Ref Name Clare Jenkins 057 6 Railway Cottages Newtonmore PH20 1AR Policy/site ref Housing (Sustainable Communities) Summary The local plan should not be making any provision for the development of second homes which add little to the economy and exacerbate house price rises. The policies should promote sustainable communities and protect the special qualities of the Park. CNPA analysis Amend table 2 to reflect issue of sectors of the market not controlled by the planning system. Proposed Modification Clarify table 2. Objector Ref Name Nick Semple 058 1 Lettoch Road Nethybridge PH25 3EJ Policy/site ref Settlements - Nethy Bridge Summary Affordable housing should be made available for young local people and should not be linked to local authority waiting lists. This may be achieved through the allocation of land within Nethy Bridge to a housing association or similar to develop housing for the community CNPA analysis The CNPA will continue to work closely with the 4 local authorities, social housing providers and private developers to ensure the most appropriate affordable housing approach to meet the needs of people in the National Park. In terms of land allocations, work will continue to target areas of demand and allocate land in those areas as appropriate and to match demand. Confirm approach taken regarding affordable houses and allocations. Proposed Modification No modification proposed. Objector Ref Name Sheena Semple 059 1 Lettoch Road Nethybridge PH25 3EJ Policy/site ref Policy 04 Summary The allocation of ancient woodland should be reviewed to accurately reflect what is important on the ground. CNPA analysis The comments regarding the datasets are noted and work will continue between the CNPA and its partners to ensure that this is addressed to allow the best information to be available to inform the development process. Within the terms of the policy the wording will be reviewed to ensure it is reasonable, clear, and delivers the intentions of the policy. The wording proposed will be assessed as part of this review. Proposed Modification 4.20 add for clarity that datasets are flawed and site inspections are needed to establish the qualities of each site, but that the datasets are used as a starting point. Objector Ref Name Catherine Johnson 061 Shieldaig Station Road Newtonmore Policy/site ref Settlements - Newtonmore Summary Land previously identified in the draft local plan should be reinstated within the settlement boundary of Newtonmore and allocated as open space. CNPA analysis The comment is noted. A site visit will be undertaken to assess the qualities of the land suggested as open space. If considered to fit within this use the proposals map for the settlement will be amended. In the event that the land is not considered to be open space, the contribution it makes to the settlement will be assessed, and the settlement boundary may thereafter be amended. For clarity additional text will be added to the plan to explain the level of protection offered to sites on the boundary of settlements identified in the Plan. Proposed Modification Include land within settlement boundary to be protected from development. Objector Ref Name Alistair McLeod 062 Strathkinness Seafield Avenue Grantown on Spey Policy/site ref Settlements - Grantown on Spey H1 Summary The land for housing should be allocated as open space/amenity use to protect the natural break between the housing and caravan park. The development of housing would create intolerable levels of traffic and would be dangerous. CNPA analysis This site has a current, outstanding application and due to the timescales involved this application will be determined in line with the policies of Highland Council Local Plan. The determination of this site will however be carefully monitored to ensure that the appropriate level of detailed information is included within the future plans for the Local Plan. In the event that the detailed application is refused, the situation will be revised. Proposed Modification Include up to date position regarding extant permissions and submitted applications yet to be determined. Objector Ref Name Catharine Hilary Mordaunt 063a 62 Corrour Road Aviemore PH22 1SS Policy/site ref Settlements - Aviemore H2/H3 Summary H2 and H3 should not be used for development as it would increase traffic problems in the area, and there would be no natural break in housing development in the area. The site should be allocated as amenity space. CNPA analysis The modifications need to reflect the latest position regaring the extant permissions, and currently submitted but yet to be determined applications which will be determined under the Highland Council local plan. The need to respect the role the site plays in creating a setting for Aviemore should be retained. The importance in assessing the flood risk in the determination of any application on the site should also be retained. Proposed Modification Modifications to include up to date position regarding extant permissions and submitted applications yet to be determined. Make reference to important issues including flooding, landscaping and natural heritage. Objector Ref 063b Policy/site ref Settlements - Aviemore H2/H3 Summary No further development should be carried out in Aviemore to provide housing for second homes. CNPA analysis The modifications need to reflect the latest position regaring the extant permissions, and currently submitted but yet to be determined applications which will be determined under the Highland Council local plan. The need to respect the role the site plays in creating a setting for Aviemore should be retained. The importance in assessing the flood risk in the determination of any application on the site should also be retained. Proposed Modification Modifications to include up to date position regarding extant permissions and submitted applications yet to be determined. Make reference to important issues including flooding, landscaping and natural heritage. Objector Ref Name Mrs A Ritchie 064 Collie Ghlas Dell Road Nethybridge PH25 3DG Policy/site ref Settlements - Nethy Bridge Summary I support the Local Plan in its efforts to protect the special qualities of the Park. CNPA analysis No modification considered necessary as a result of this representation. Proposed Modification No further action required. Objector Ref Name Robin J L Melville Land Management (Scotland) Ltd 64a High Street Laurencekirk AB30 1BJ Policy/site ref Settlements omissions Dinnet Summary Dinnet should be identified as a settlement and land allocated for 60 dwellings to support local proposals for economic development. CNPA analysis The approach to the identification of settlements outwith those identified in the deposit plan will be reviewed, and in line with the requirements of SPP1 a detailed rational behind the approach taken will be drawn up. Where it is considered that additional detail including land allocations would assist in the level of detail provided for smaller communities and help attain their aspirations, the specific identification of those settlements will be considered as appropriate through modification both Section 7 of the Plan, the policies regarding housing outwith strategic settlements, and the proposals maps. Any change to the approach taken may also impact on the SEA. Proposed Modification Identify Dinnet within settlement proposals. Objector Ref Name Serena Humphrey 066a Rhu-na-Haven Aboyne AB34 5SD Policy/site ref Settlements - Ballater H1 Summary The allocation of H1 cannot be supported by adequate infrastructure and employment opportunities. The new developments will be bought by retiring people and be second homes and will end in destroying the character of the village. CNPA analysis The allocated site at Ballater will be reviewed in light of additional information being sought from the Prince’s Foundation. Additional information may then be added to reflect the findings of this study and provide a level of detail regarding mixed uses, access, densities, and areas to be protected from development. Further consultation will then be required within the community to assess the level of support for any modifications. The addition of extra information may impact both on the SEA and the Flood Risk Assessment for the site. Confirm the housing requirement comes from various reports and studies and is based on a long term growth projection. The design of new development will support Ballater and care will be taken to ensure the character of the planned settlement and the conservation will be protected Proposed Modification Amend supporting text to H1 to refer to ongoing work of princes foundation - and refer specifically to density of new development and the comparison to the existing density of Ballater. Add employment opportunities in proposals maps. Objector Ref 066b Policy/site ref Settlements omissions Dinnet Summary Dinnet should be identified as a settlement and land should be identified for housing development to invigorate the area and support local businesses. CNPA analysis The approach to the identification of settlements outwith those identified in the deposit plan will be reviewed, and in line with the requirements of SPP1 a detailed rational behind the approach taken will be drawn up. Where it is considered that additional detail including land allocations would assist in the level of detail provided for smaller communities and help attain their aspirations, the specific identification of those settlements will be considered as appropriate through modification both Section 7 of the Plan, the policies regarding housing outwith strategic settlements, and the proposals maps. Any change to the approach taken may also impact on the SEA. Proposed Modification Identify Dinnet within settlement proposals. Objector Ref Name Mr Peter Smith 067 Brackenburn Nethybridge PH25 3DB Policy/site ref Settlements - Nethy Bridge C1 Summary The reference to affordable housing for the community should be removed and the site should be protected from development. CNPA analysis The inclusion of the reference within the supporting text of Proposal C1 was intended to allow a degree of flexibility to future development options. However, there is a general view that this reference is unhelpful and misleading, and as a result consideration will be given to the removal of the final sentence of Proposal C1. Proposed Modification Remove reference to housing in the text to C1 Objector Ref Name Mrs Julie Smith 068 Brackenburn Nethybridge PH25 3DB Policy/site ref Settlements - Nethy Bridge C1 Summary Further development will destroy the character of Nethy Bridge and the reference to affordable housing for the community should be removed and the site should be protected from development. CNPA analysis The inclusion of the reference within the supporting text of Proposal C1 was intended to allow a degree of flexibility to future development options. However, there is a general view that this reference is unhelpful and misleading, and as a result consideration will be given to the removal of the final sentence of Proposal C1. Proposed Modification Remove reference to housing in the text to C1 Objector Ref Name Mrs EM Farnell 069 Woodcutter’s cottage 2 Lettoch Road Nethybridge PH25 3EJ Policy/site ref Settlements - Nethy Bridge Summary A number of important areas of open space have not been afforded an adequate level of protection from future development. These sites are the land adjacent to the MountView Hotel, land adjacent to the River at the south end between Dell Road and Lynstock, and Balnagowan Woods. Further, reference to affordable housing for the community in C1 should be removed and the site should be protected from development. CNPA analysis The comment is noted. A comprehensive review will be undertaken in Nethy Bridge to assess the importance of the various areas suggested for inclusion as open space. Where the sites are considered to fit within the use as open space the proposals map will be amended. Where the land is not considered to be open space, the contribution it makes to the settlement will be assessed, and an alternative allocation considered to protect it and the contribution the land makes to the character of the settlement. The inclusion of the reference within the supporting text of Proposal C1 was intended to allow a degree of flexibility to future development options. However, there is a general view that this reference is unhelpful and misleading, and as a result consideration will be given to the removal of the final sentence of Proposal C1. Proposed Modification Include in intro to cpt 7 para 7.5 explanation of approach taken to proposals inside and outwith settlement boundaries. OS1 extend boundary at Dell Road on west side of river At Mountview Hotel Identify land to be protected (in line with previous planning permission ) Remove reference to housing in the text to C1. Objector Ref Name George E Nutt 070 Woodcutter’s cottage 2 Lettoch Road Nethybridge PH25 3EJ Policy/site ref Settlements - Nethy Bridge Summary A number of important areas of open space have not been afforded an adequate level of protection from future development. These sites are the land adjacent to the Mountain View Hotel, land adjacent to the River at the south end between Dell Road and Lynstock, and Balnagowan Woods. Further, reference to affordable housing for the community in C1 should be removed and the site should be protected from development. CNPA analysis The comment is noted. A comprehensive review will be undertaken in Nethy Bridge to assess the importance of the various areas suggested for inclusion as open space. Where the sites are considered to fit within the use as open space the proposals map will be amended. Where the land is not considered to be open space, the contribution it makes to the settlement will be assessed, and an alternative allocation considered to protect it and the contribution the land makes to the character of the settlement. The inclusion of the reference within the supporting text of Proposal C1 was intended to allow a degree of flexibility to future development options. However, there is a general view that this reference is unhelpful and misleading, and as a result consideration will be given to the removal of the final sentence of Proposal C1. Confirm approach to non designated woodland and retaining trees on development sites by way of condition. Proposed Modification Include in intro to cpt 7 para 7.5 explanation of approach taken to proposals inside and outwith settlement boundaries. OS1 extend boundary at Dell Road on west side of river At Mountview Hotel Identify land to be protected (in line with previous planning permission ) Remove reference to housing in the text to C1. Objector Ref Name Mrs Ann E Nutt 071 Woodcutter’s cottage 2 Lettoch Road Nethybridge PH25 3EJ Policy/site ref Settlements - Nethy Bridge Summary A number of important areas of open space have not been afforded an adequate level of protection from future development. These sites are the land adjacent to the Mountain View Hotel, land adjacent to the River at the south end between Dell Road and Lynstock, and Balnagowan Woods. Further, reference to affordable housing for the community in C1 should be removed and the site should be protected from development. CNPA analysis The comment is noted. A comprehensive review will be undertaken in Nethy Bridge to assess the importance of the various areas suggested for inclusion as open space. Where the sites are considered to fit within the use as open space the proposals map will be amended. Where the land is not considered to be open space, the contribution it makes to the settlement will be assessed, and an alternative allocation considered to protect it and the contribution the land makes to the character of the settlement. The inclusion of the reference within the supporting text of Proposal C1 was intended to allow a degree of flexibility to future development options. However, there is a general view that this reference is unhelpful and misleading, and as a result consideration will be given to the removal of the final sentence of Proposal C1. Remove reference to housing in the text to C1. Confirm approach to non designated woodland and retaining trees on development sites by way of condition. Proposed Modification Include in intro to cpt 7 para 7.5 explanation of approach taken to proposals inside and outwith settlement boundaries. OS1 extend boundary at Dell Road on west side of river At Mountview Hotel Identify land to be protected (in line with previous planning permission ) Objector Ref Name Rachel Gallagher 072 1 Lettoch Road Nethybridge Inverness-shire PH25 3EJ Policy/site ref Settlements - Nethy Bridge Summary There should be no further development proposals for Nethy Bridge at this time to allow recent developments to be properly integrated into the village and allow for the proper phasing of future infrastructure requirements. CNPA analysis The sites currently allocated within the deposit local plan all have outline planning permission for housing development, granted under the terms of the Highland Council Local Plan. The detailed applications for these sites will be carefully monitored to assess whether the CNPA local plan can be considered as material in their determination. Where applications are currently registered they will be determined in line with the policies of the Highland Council Plan. In the event that the detailed applications are refused, the situation will be revised. Confirm in letter sites allocated, permissions granted, approach being taken for life of Plan. Proposed Modification No further action required. Objector Ref Name Donside Community Council 073a c/o Mrs M Henderson 3 Kingsford Road Alford Company Donside Community Council Policy/site ref Policy 24 Summary Further clarity is required on what is meant by the various technical terms used within the Affordable Housing policies. A more flexible set of rules may be worth considering to promote valuable development taking place. CNPA analysis The findings of the work undertaken by the 3Dragons will influence the affordable housing policy and ensure appropriate statistical support for the approach. Proposed Modification Reduce the requirements to 25% in line with national guidance and 40% in exceptional circumstances and in line with the findings of the 3Dragons report. The details of forms of delivery will be included in the housing appendix. Objector Ref 073b Policy/site ref Settlements omissions Strathdon Summary Strathdon should be identified as a settlement. CNPA analysis The approach to the identification of settlements outwith those identified in the deposit plan will be reviewed, and in line with the requirements of SPP1 a detailed rational behind the approach taken will be drawn up. Where it is considered that additional detail including land allocations would assist in the level of detail provided for smaller communities and help attain their aspirations, the specific identification of those settlements will be considered as appropriate through modification both Section 7 of the Plan, the policies regarding housing outwith strategic settlements, and the proposals maps. Any change to the approach taken may also impact on the SEA. Proposed Modification Identify Bellabeg within settlement proposals. Objector Ref 073c Policy/site ref Policy 26 Summary Additional housing in the countryside should be facilitated whether or not it is linked to business development, where no environmental reason exists to prevent development. CNPA analysis The approach taken in policy 26 will be reviewed to ensure it allows for the appropriate level of development and is flexible enough to support local people in their own communities. The wording will also be reviewed against national guidance on the issue of rural development to ensure the appropriate level of clarity is provided to developers in line with SPP1. Proposed Modification Revise policy 23 to reduce the size of groups to 3. Policy 24 add additional para c) taking on need to include brownfield land or reuse of redundant sites to create some more opportunities. Objector Ref Name Ballater (RD) Ltd Agent Bryan Wright 076 7 Bridge Street Pronybeg Ballater Ballater AB35 5QP AB35 5XB Company Ballater (RD) Ltd Policy/site ref Settlements - Ballater H1 Summary There is no evidence to support the requirement for such a large development within Ballater. The site as allocated covers the car parking used for the Ballater Games. This should not occur. The density proposed is not in keeping with a rural settlement and the development of this site would have an adverse impact on the character of the village. The site is also within the flood plain and development would not only impact on the site itself but have knock on effects elsewhere. The site should not be designated unless the risk of flooding is at an acceptable level. The site should instead be used to provide environmental and recreational assets needed to serve the growth in the village seen during the past 7 years. CNPA analysis The allocated site at Ballater will be reviewed in light of additional information being sought from the Prince’s Foundation. Additional information may then be added to reflect the findings of this study and provide a level of detail regarding mixed uses, access, densities, and areas to be protected from development. Further consultation will then be required within the community to assess the level of support for any modifications. The addition of extra information may impact both on the SEA and the Flood Risk Assessment for the site. Confirm the housing requirement comes from various reports and studies and is based on a long term growth projection. Confirm ongoing work regarding flood risk assessment and discussions with SEPA regarding this issue. Confirm approach to developer contributions for new development to support services. Confirm the policy for affordable houses supported in the plan. Confirm that although holiday homes cannot be controlled, affordable homes can and this will form part of any development. Proposed Modification Amend supporting text to H1 to refer to ongoing work of princes foundation - and refer specifically to density of new development and the comparison to the existing density of Ballater. Amend proposals map to reflect need for parking. Include reference to ensure design of new development will support Ballater and care will be taken to ensure the character of the planned settlement and the conservation will be protected Objector Ref Name Gordon Findlay 24 Pannanich Road Ballater AB35 5PA Policy/site ref Settlements - Ballater H1 Summary There is no need for such a large scale development in Ballater. Also why do we need low cost housing as there is no great number of people on the waiting list. There is no employment within the area and poor public transport links. Any jobs in tourism are poorly paid. Also the allocation marked on the plan is vague and should indicate accesses and design, since the density would suggest a large housing scheme out of character with Ballater. CNPA analysis The allocated site at Ballater will be reviewed in light of additional information being sought from the Prince’s Foundation. Additional information may then be added to reflect the findings of this study and provide a level of detail regarding mixed uses, access, densities, and areas to be protected from development. Further consultation will then be required within the community to assess the level of support for any modifications. The addition of extra information may impact both on the SEA and the Flood Risk Assessment for the site. Confirm the housing requirement comes from various reports and studies and is based on a long term growth projection. Confirm access issues etc will be addressed once more developed proposals are being considered - this stage is to establish the use of the land and also the scale of development. Proposed Modification Amend supporting text to H1 to refer to ongoing work of princes foundation - and refer specifically to density of new development and the comparison to the existing density of Ballater. Include reference to ensure the design of new development will support Ballater and care will be taken to ensure the character of the planned settlement and the conservation will be protected Objector Ref Name Michael F Franklin 078 40 Pannanich Road Invercauld Park Ballater AB35 5PA Policy/site ref Settlements - Ballater H1 Summary The density proposed for the site is out of keeping with similar sized sites elsewhere in the Park. The first priority should be to create the necessary recreational space and parking area and assign what is left. Although some low cost housing is needed in the area the allocation is excessive. The site also lies within the flood plain and any development should be subject to a detailed flood risk assessment carried out in a rigorous way. CNPA analysis The allocated site at Ballater will be reviewed in light of additional information being sought from the Prince’s Foundation. Additional information may then be added to reflect the findings of this study and provide a level of detail regarding mixed uses, access, densities, and areas to be protected from development. Further consultation will then be required within the community to assess the level of support for any modifications. The addition of extra information may impact both on the SEA and the Flood Risk Assessment for the site. Confirm the housing requirement comes from various reports and studies and is based on a long term growth projection. Confirm ongoing work regarding flood risk assessment and discussions with SEPA regarding this issue. Confirm approach to developer contributions for new development to support services. Confirm the policy for affordable houses supported in the plan. Confirm that although holiday homes cannot be controlled, affordable homes can and this will form part of any development. Proposed Modification Amend proposals map to reflect need for parking. Amend supporting text to H1 to refer to ongoing work of princes foundation - and refer specifically to density of new development and the comparison to the existing density of Ballater. Include reference to ensure the design of new development will support Ballater and care will be taken to ensure the character of the planned settlement and the conservation will be protected Objector Ref Name Mrs Sally Leslie Melville Agent James Carnegie-Arbuthnott 079 South Cantray Buccleuch Town and Country Croy 43 Melville Street Inverness Edinburgh IV1 2PW EH3 7JF Policy/site ref Settlements - Newtonmore Summary Additional land adjacent to H1 should be included to meet long term demands and H1 and H2 should meet current demand. CNPA analysis The comments are noted, and a comprehensive review will be undertaken in Newtonmore to ensure there is an adequate amount of land allocated for both housing and employment opportunities to meet local demand, matched with an assessment of land used for open space and landscaping which add to the overall character of the settlement. Within this review the issues of access and flood risk will also be considered together with the other issues raised throughout the plan including affordability, design, and balance of house sizes, and the appropriate amendments made. This will include a survey and review of the additional land suggested. Confirm housing allocations are based on need etc, and based on the work of the various studies. The long term growth of Newtonmore will therefore be assessed in line with normal monitoring of the local plan, and should existing allocations be taken up within the plan period future revisions and modifications to any future plan will consider additional land for the long term. However confirm view that effective 5 year supply has been met and that medium term growth is also met (table 2-4) Proposed Modification No modification proposed. Objector Ref Name Lord Hogg of Cumbernauld 080 26 Pannanich Road Ballater AB35 5PA Policy/site ref Settlements - Ballater H1 Summary Support for the comments made by James Sunley. CNPA analysis No modification considered necessary as a result of this representation. Proposed Modification No further action required. Objector Ref Name Mr R Lawson 081 Nethybridge Pottery Grantown on Spey PH26 3NH Policy/site ref Settlements - Nethy Bridge Summary The settlement boundary should be protected and the recent levels of development capped. Outwith the boundary there should be a presumption against dispersed or ribbon development. A number of important areas of open space have not been afforded an adequate level of protection from future development. These sites are the land adjacent to the Mountview Hotel, land adjacent to the River at the south end between Dell Road and Lynstock, and Balnagowan Woods. Further, reference to affordable housing for the community in C1 should be removed and the site should be protected from development. CNPA analysis The designation of the settlement boundary requires additional information to clarify what development may occur within and outwith it, and to clarify the reason behind creating the boundary. In respect of open space, a comprehensive review will be undertaken in Nethy Bridge to assess the importance of the various areas suggested for inclusion as open space. Where the sites are considered to fit within the use as open space the proposals map will be amended. Where the land is not considered to be open space, the contribution it makes to the settlement will be assessed, and an alternative allocation considered to protect it and the contribution the land makes to the character of the settlement. The inclusion of the reference within the supporting text of Proposal C1 was intended to allow a degree of flexibility to future development options. However, there is a general view that this reference is unhelpful and misleading, and as a result consideration will be given to the removal of the final sentence of Proposal C1. Confirm designations such as SSSi are not responsibility of CNPA but can pass comment to SNH Proposed Modification Include in intro to cpt 7 para 7.5 explanation of approach taken to proposals inside and outwith settlement boundaries. At Mountview Hotel Identify land to be protected (in line with previous planning permission ) Remove reference to housing in the text to C1. Objector Ref Name Penny Lawson 082 Easter Culreach Grantown on Spey PH26 3NH Policy/site ref Settlements - Nethy Bridge Summary The settlement boundary should be protected and the recent levels of development capped. Outwith the boundary there should be a presumption against dispersed or ribbon development. A number of important areas of open space have not been afforded an adequate level of protection from future development. These sites are the land adjacent to the MountainView Hotel, land adjacent to the River at the south end between Dell Road and Lynstock, and Balnagowan Woods. Further, reference to affordable housing for the community in C1 should be removed and the site should be protected from development. CNPA analysis The designation of the settlement boundary requires additional information to clarify what development may occur within and outwith it, and to clarify the reason behind creating the boundary. The comments regarding open space are noted and a site visit will be undertaken to assess the role the land in question plays as open space. In the event that it is considered to add positively to the character of the area, and is an area of open space, the appropriate modifications will be made to the proposals map. In the event that the land does not constitute open space the contribution it makes to the settlement will be assessed, and an alternative allocation considered to protect it and the contribution the land makes to the character of the settlement. . The inclusion of the reference within the supporting text of Proposal C1 was intended to allow a degree of flexibility to future development options. However, there is a general view that this reference is unhelpful and misleading, and as a result consideration will be given to the removal of the final sentence of Proposal C1. Proposed Modification Include in intro to cpt 7 para 7.5 explanation of approach taken to proposals inside and outwith settlement boundaries. OS1 extend boundary at Dell Road on west side of river At Mountview Hotel Identify land to be protected (in line with previous planning permission ) Remove reference to housing in the text to C1. Objector Ref Name Jane Linda Cox 083a Balnagowan Nethy Bridge PH25 3DR Policy/site ref Settlements - Nethy Bridge Summary A number of areas of open space should be protected from future development. These are Balnagowan Woods, land to the east and north of H2, and land to the south of Lettoch Road. CNPA analysis The comment is noted. A comprehensive review will be undertaken in Nethy Bridge to assess the importance of the various areas suggested for inclusion as open space. Where the sites are considered to fit within the use as open space the proposals map will be amended. Where the land is not considered to be open space, the contribution it makes to the settlement will be assessed, and an alternative allocation considered to protect it and the contribution the land makes to the character of the settlement. Proposed Modification Include in intro to cpt 7 para 7.5 explanation of approach taken to proposals inside and outwith settlement boundaries. Objector Ref 083b Policy/site ref Settlements - Nethy Bridge Summary Land between Mountview Hotel and Wilburn Homes should be protected from future development and allocated as protected open space. CNPA analysis The comment is noted. A site visit will be undertaken to assess the qualities of the land suggested as open space. If considered to fit within this use the proposals map for the settlement will be amended. In the event that the land is not considered to be open space, the contribution it makes to the settlement will be assessed, and an alternative allocation considered to protect it and the contribution the land makes to the character of the settlement. An assessment of the protection already offered to the site by virtue of the planning permission granted on the adjacent site will also be made. Proposed Modification At Mountview Hotel Identify land to be protected (in line with previous planning permission ) Objector Ref Name Mark Cox 084 Balnagowan Balnagowan Brae NethyBridge PH25 3DR Policy/site ref Settlements - Nethy Bridge Summary The village boundary should be extended to include the whole of the 'Nursery' and the whole should be protected as open space. CNPA analysis The comment is noted. A comprehensive review will be undertaken in Nethy Bridge to assess the importance of the various areas suggested for inclusion as open space. Where the sites are considered to fit within the use as open space the proposals map will be amended. Where the land is not considered to be open space, the contribution it makes to the settlement will be assessed, and an alternative allocation considered to protect it and the contribution the land makes to the character of the settlement. Proposed Modification OS1 extend boundary at Dell Road on west side of river Add to intro of section 7 para 7.5 pproach to development within and outwith settlement boundary. Objector Ref Name George M Cowie 085 Garden House Morven Way Ballater AB35 5SF Policy/site ref Settlements - Ballater H1 Summary The land allocated has to accommodate parking for the Games and landscaping to the west, and the density of 250 is therefore unreasonable. Land should also be protected to the west of Monaltrie House to protect the setting of this listed building. However the space remaining would in fact be more appropriate in scale to Ballaters needs, and the proposal should therefore be reduced in area, reduced in number of houses proposed, include parking for the games and landscaping, and any development should protect the setting of Monaltrie House and the views from the top of the hill on A93 east of the Pass of Ballater. CNPA analysis The allocated site at Ballater will be reviewed in light of additional information being sought from the Prince’s Foundation. Additional information may then be added to reflect the findings of this study and provide a level of detail regarding mixed uses, access, densities, and areas to be protected from development. Further consultation will then be required within the community to assess the level of support for any modifications. The addition of extra information may impact both on the SEA and the Flood Risk Assessment for the site. Confirm allocation is phased for the long term growth of the village. Also confirm detail such as landscaping would be considered only after the concept of development on the site is established through the Plan. Proposed Modification Amend boundary on plan to account for Games Park and Princes Foundation proposals. Objector Ref Name Alexander Copland 086 Roslin Lodge School Lane Ballater Policy/site ref Settlements - Ballater H1 Summary Adequate space should be identified within the map to ensure parking is protected for the Ballater Games. CNPA analysis The allocated site at Ballater will be reviewed in light of additional information being sought from the Prince’s Foundation. Additional information may then be added to reflect the findings of this study and provide a level of detail regarding mixed uses, access, densities, and areas to be protected from development. Further consultation will then be required within the community to assess the level of support for any modifications. The addition of extra information may impact both on the SEA and the Flood Risk Assessment for the site. Proposed Modification Amend H1 to include additional land for making provision for parking. Amend text to H1 to reflect Princes Foundation and need for sustainable communites. Objector Ref Name Ralph C Wylie 087 1 Braeriach Road Kincraig Kingussie PH21 1QA Policy/site ref Settlements -Kincraig H1, H2 Summary Recent development in Kincraig has been out of keeping with the village and new development should not add to this style of development. Any new development at H1 should strictly adhere to policy 18 regarding design standards with imaginative and good quality design. The density should be reduced to no more than 30 dwellings. Development at H2 would not consolidate the village and would detract from the amenity of the school, thus being contrary to policy 18. CNPA analysis The sites have been allocated in light of the findings on housing need for the area, and further information will be provided to ensure that this work is transparent and easy to understand. The sites will then be reviewed to ensure that the appropriate amount of land is included to meet this demand. The policies regarding the design apply to all developments, and any application for development must adhere to these. This includes policy 18. Confirm that to gain permission developments will have to comply with all relevant policies of the plan, and the 4 aims of the Park, and this will include issues relating to design and sustainable development. Proposed Modification Remove H2. Objector Ref Name George Ritchie 088 Bellerive Dell Road Nethy Bridge PH25 3DG Policy/site ref Settlements - Nethy Bridge Summary The reference to affordable housing for the community should be removed and the site should be protected from development. CNPA analysis The inclusion of the reference within the supporting text of Proposal C1 was intended to allow a degree of flexibility to future development options. However, there is a general view that this reference is unhelpful and misleading, and as a result consideration will be given to the removal of the final sentence of Proposal C1. Proposed Modification Remove reference to housing in the text to C1. H2 clarify wording in terms of outstanding permissions and if any influence to the landscaping of the development can be insisted through the plan. Objector Ref Name Mrs Fiona Powell 089 1 Meadow Gardens Hopeman Elgin IV30 5PN Policy/site ref Policy 24 Summary The policy will place too high a financial burden on the developer; force the developer to pass costs on to the purchaser increasing the cost of housing and stifle the construction industry in the Park leading to potential job losses. The proposal for individuals to contribute to affordable housing puts an additional financial burden on people who are often self building as they cannot afford any other form of housing. This model should not be used across the park just because it is used in Aberdeenshire. Some additional information on what the contribution might be would be helpful. It would be helpful to include a table indicating examples based on the differentials between the benchmark cost of a Communities Scotland home and the price of an equivalent unit on the open market. Also a definition of what a Sec 75 agreement is would be useful. Linking houses to businesses can have a serious impact on the value of the property and present difficulties for raising mortgages, loans, etc. Proposed changes are therefore remove or reduce the requirements on developers to contribute to affordable housing; remove the requirement for the single development builder to make a financial contribution towards affordable housing; and remove the suggestion of using Section 57 agreements to link single house developments to rural businesses. CNPA analysis The findings of the work undertaken by the 3Dragons will influence the affordable housing policy and ensure appropriate statistical support for the approach. Confirm that the contribution would be agreed in protocol with the LAs and board. Seek further detail from Aberdeenshire on the actual figures. Also confirm legal agreements currently exists, and are the only constructive method of ensuring the house remains with the business and is not built and just sold on. Proposed Modification Reduce the requirements to 25% in line with national guidance and 40% in exceptional circumstances and in line with the findings of the 3Dragons report. 5.50 clarity that the contribution can be waived if the applicant agrees to make the unit affordable in the event of future sales ie enter a sec 75 agreement that would pass on the benefit to others. Objector Ref Name Frank Jemmett 090 1 Rhuarden Court Grantown on Spey PH26 3DA Policy/site ref Settlements - Grantown on Spey H1 Summary Development at H1 would exacerbate current traffic management problems within Grantown at the junction with High Street/The Square and also at Seafield Avenue. Any new development must therefore ensure adequate improvements to these junctions and other possible traffic management solutions. CNPA analysis This site has a current, outstanding application and due to the timescales involved this application will be determined in line with the policies of Highland Council Local Plan. The determination of this site will however be carefully monitored to ensure that the appropriate level of detailed information is included within the future plans for the Local Plan. In the event that the detailed application is refused, the situation will be revised. Proposed Modification Include up to date position regarding extant permissions and submitted applications yet to be determined. Objector Ref Name Dr Sheila Sedgwick 091a Ballater & Crathie Community Council Girnoc Shiel Glengirnoc, by Ballater AB35 5SS Company Ballater & Crathie Community Council Policy/site ref Housing (Sustainable Communities) Summary The plan focuses too heavily to housing provision and not enough on employment opportunities and incentives. Also there is little focus on the need to provide adequate infrastructure to support new housing development. All these should be intrinsically linked. CNPA analysis The plan must ensure adequate housing provision. However additional focus will be placed on employment provision. The CNPA continue to work closely with infrastructure providers to build into their investment programmes sufficient capacity to meet the needs of the local plan. Proposed Modification Include employment land in proposals maps. Objector Ref 091b Policy/site ref Settlements - Ballater Summary The settlement boundary of Ballater should include the Craigendarroch complex and the wooded area around the school. There are also omissions including the battlefield site and souterrain. Crathie should be included as a settlement. CNPA analysis The boundary of Ballater has been drawn to include the main settlement and housing areas which form the village. This is in on way to imply that certain other developments do not play a key role in supporting the village, particularly economically. In regard to Crathie, the approach to the identification of settlements outwith those identified in the deposit plan will be reviewed, and in line with the requirements of SPP1 a detailed rational behind the approach taken will be drawn up. Where it is considered that additional detail including land allocations would assist in the level of detail provided for smaller communities and help attain their aspirations, the specific identification of those settlements will be considered as appropriate through modification both Section 7 of the Plan, the policies regarding housing outwith strategic settlements, and the proposals maps. Any change to the approach taken may also impact on the SEA. onfirm that settlement boundary has been drawn to exclude the SSSI. Also confirm that Crathie as a disperced settlement would be better served within a settlement boundary, as it allows a much greater degree of flexiblity for incremental growth which supports the settlement -policy 25 and 26. Proposed Modification Redraw settlement boundary to include woodland around school Objector Ref 091c Policy/site ref General -layout Summary The approach to create policies which apply across the park does not allow for flexibility within individual communities. CNPA analysis The approach taken attempts to create a clear planning framework for the Park area as a whole. The wording of individual policies should provide sufficient flexibility to account for the needs of individual communities, but further clarity will be included as a proposed modification within the Introduction Section to further explain how to use the Plan and its policies and proposals. Proposed Modification Amend 1.5 purpose of Plan to explain the role of the Plan across the Park. Objector Ref 091d Policy/site ref SEA Summary The SEA must be more carefully examined as its findings will have a major impact on the area as a whole. CNPA analysis The comments are noted, but CNPA must refer to the responses from the 4 statutory consultees on SEA who have all commented on the clarity and soundness of the Environmental Report. The findings of the ER will impact directly on the local plan, its policies and proposals and this will be done in line with the legislative requirements and in liaison with the consultees. Proposed Modification Comments will be reviewed prior to adoption to take into account the views expressed. No modifications needed at this stage. Objector Ref 091e Policy/site ref Policy 11 Summary There are 4 conservation villages CNPA analysis The comment is noted. The conservation areas are marked on the proposals maps. No modification considered necessary as a result of this representation. Proposed Modification No further action required. Objector Ref 091f Policy/site ref Policy 13 Summary The policy regarding flooding needs more careful consideration to ensure that sites are not allocated in areas at risk from flooding and appropriate levels of protection are included in all developments. CNPA analysis The aim of the policy is to ensure that management of the water environment in line with the established legal framework which exists, and other national guidance regarding flooding and drainage. The issue of flood risk assessments will be reviewed in line with the comments received from SEPA and the appropriate changes will be made both to the policy wording and settlement proposals where necessary. Confirm modifications will be in light of comments received from SEPA and also approach to flood risk assessments. Proposed Modification No further work required. Objector Ref 091g Policy/site ref Settlements - Ballater Summary The housing policies should reflect the important role retired people make to the economy, and the value added to houses which could be used to support affordable houses. CNPA analysis The approach to housing policy endeavours to recognise all sectors of the market, and provide a policy basis to meet the needs of all communities in their housing need. The approach tries to redress the current imbalance between cost of housing and those in need of affordable housing. However this is in no way to underplay the key role played by the open market sector including those who retire within or to the area. The wording of the supporting text will be amended to better reflect the various sectors within the housing sector. Confirm that only a portion of the land allocated would be for affordable houses and the remainder will be for open market housing which will support the economy and housing markets in the village. Proposed Modification No modification proposed. Objector Ref 091h Policy/site ref Settlements - Ballater H1 Summary The work of the Prince's Foundation should be better reflected in the housing proposals for Ballater. CNPA analysis The allocated site at Ballater will be reviewed in light of additional information being sought from the Prince’s Foundation. Additional information may then be added to reflect the findings of this study and provide a level of detail regarding mixed uses, access, densities, and areas to be protected from development. Further consultation will then be required within the community to assess the level of support for any modifications. The addition of extra information may impact both on the SEA and the Flood Risk Assessment for the site. Proposed Modification Include para in intro to Cpt 7 7.4 to promote mixed development to promote sustainable communities. Amend H1 making provision for parking. Amend text to H1 to reflect Princes Foundation and need for sustainable communites. Objector Ref 091i Policy/site ref Policy 20 Summary Additional thought is needed to ensure appropriate provision is made for commercial development. The local plan should highlight the need for tax incentives and rate improvements. CNPA analysis The comments are noted, and whilst interesting are not linked to land use planning and so are not appropriate for inclusion within the Local Plan. The CNPA will however continue to work with partners to bring this issue to the attention of those involved to ensure the best approach is taken for businesses in the Park area. Confirm that we will continue to work with the Local Authorities to promote sites where appropriate. Proposed Modification Add economic development sites into settlements identified in the proposals section. Objector Ref 091j Policy/site ref Housing (land supply) Summary The housing requirements identified in NEST better reflect the actual need for the Mar area and in turn Ballater. CNPA analysis Table 2 is based on work undertaken by consultants and available on line to consider the issue of need and housing land. The plan therefore allocates sufficent and adequate land for housing development. Proposed Modification No modification proposed. Objector Ref 091k Policy/site ref Housing (affordable) Summary There should be greater clarity on how the housing requirement for each area has been calculated. The requirement for affordable housing mixed throughout developments will have an adverse impact on the value of open market houses. There should also be a better understanding of the size requirements within individual communities. What ever development occurs it should be in keeping with the character of the settlement, and should ensure that low cost and affordable houses are truly for local people and essential workers. CNPA analysis Amend policy to reflect findings of 3Dragons work on affordable housing provision.Two background papers undertaken by consultants relating to population figures and affordable housing requirements are available on line. A summary of the approach taken will be appended to the Local Plan. Also amendments will be made to the introduction to the housing section to clarify the need for housing in the Park. The approach to 'pepper potting' affordable houses is one which has been tried and tested across the country for many years. However, the approach taken will be assessed on a case by case basis and a prescriptive approach will not be imposed. Proposed Modification Amend policy 21 in light of 3Dragons findings. Modifications to introduction to housing section to clarify need and approach to affordable housing. Also include appendix to add further detail. Add consultants reports to the web page for general viewing. Objector Ref 091l Policy/site ref Settlements - Ballater Summary Land should be allocated within Ballater for the development of hotel and hostel accommodation. CNPA analysis Modifications will endeavour to ensure a more appropriate balance is struck between development and tourism opportunities and the protection of the special qualities of the area. Within Ballater, general policies have been included to do this, rather than identify a particular site which may be considered by some as restrictive. However work will continue with the local chamber of commerce to ensure that the approach taken meets with the aspirations of the local community. Confirm that policies ( esp 33 and para 6.3 and 6.4) aim to promote development such as tourism rather than shoe horn proposals into particular sites. Proposed Modification Include para in intro to Cpt 7 7.4 to promote mixed development to promote sustainable communities. Objector Ref 091m Policy/site ref Settlements - Ballater Summary The proposal at H1 should include an appropriate allocation for parking for the Ballater Games. The density should be adjusted accordingly to reflect the reduction in the size of the site. Within Ballater there should also be provision made for recreational and social activities such as a sports centre, outdoor centre, cinema, etc. The local plan should also make reference to ongoing community aspirations such as football pitches and a woodland project. CNPA analysis The comment is noted, and amendments will be included to the proposals maps to highlight the needs of the community and the various uses to which the site is put. The amendments will take into account the ongoing work of the Princes Foundation to prepare a masterplan and vision for the future growth of Ballater, and a design guide for the development of the site. Confirm the housing requirement comes from various reports and studies and is based on a long term growth projection. Confirm community needs assessments will address the need for facilities and develop appropriate plans for such developments which will be supported by local plan policies. Proposed Modification Amend supporting text to H1 to refer to ongoing work of princes foundation - and refer specifically to density of new development and the comparison to the existing density of Ballater. Amend proposals map to reflect need for parking. Objector Ref 091n Policy/site ref Settlements - Ballater H1 Summary The proposed density of the site H1 would not be in character with Ballater and the proposal does not identify supporting facilities such as shops and land for amenity use. The site is not in line with the site identified in the Aberdeenshire Plan. The proposal should better reflect the findings of the Prince's Foundation. CNPA analysis The allocated site at Ballater will be reviewed in light of additional information being sought from the Prince’s Foundation. Additional information may then be added to reflect the findings of this study and provide a level of detail regarding mixed uses, access, densities, and areas to be protected from development. Further consultation will then be required within the community to assess the level of support for any modifications. The addition of extra information may impact both on the SEA and the Flood Risk Assessment for the site. Confirm allocation is phased for the long term growth of the village. Confirm where the housing figures come from, and the demand for affordable homes in Ballater and the role of the this plan and the aberdeenshire plan. Proposed Modification Amend boundary on plan to account for Games Park and Princes Foundation proposals. Include employment land within village boundary. Objector Ref Name Frank Bardgett 092a Boat of Garten Community Council Tigh an Iasgair Boat of Garten PH24 3BY Company Boat of Garten Community Council Policy/site ref Policy 25 Summary Additional clarity is required to explain the different housing options proposed by policy 25 and 26 in regard to the scale appropriate to the setting. Specific mention should be included of the settlements to which policy 25 refers. Additional information should also be given on how the policies link together, for example the impact on the landscape. Paragraph 5.62 should therefore read “They include settlements such as Dinnet, Laggan Bridge, Gergask, Drumuillie and Street of Kincardine.”. CNPA analysis The approach to the identification of settlements outwith those identified in the deposit plan will be reviewed, and in line with the requirements of SPP1 a detailed rational behind the approach taken will be drawn up. Where it is considered that additional detail including land allocations would assist in the level of detail provided for smaller communities and help attain their aspirations, the specific identification of those settlements will be considered as appropriate through modification both Section 7 of the Plan, the policies regarding housing outwith strategic settlements, and the proposals maps. Any change to the approach taken may also impact on the SEA. Proposed Modification Add an additional policy 22 to include rural settlements and identify them in proposals maps. Reduce the figure here to 3 in policy 23. Add to policy regarding groups 'and does not detract from the landscape setting' Objector Ref 092b Policy/site ref Policy 24 Summary To ensure that appropriate developer contributions are made which reflect the community needs, para 5.55 should be amended to read “If a community needs survey (prepared within the previous three years) or other information on local housing need collated by the Cairngorms National Park Authority or by the Local Authority or relevant Community Council (also within the previous three years) shows a strong need for a community to have either additional affordable housing or very different composition of tenures, the planning authority will seek additional contributions from developments. The planning authority may also take into account submissions received once the plans are publicly available”. CNPA analysis The intention of policy delivery is to match developer contributions against community need, assess through community assessments. With specific regard to housing, the policies will also assessed against the most up to date housing need information and work will continue with the housing developers, both private and public sector, and the local authorities to secure a consistent method of collecting this information across the Park. Proposed Modification Refer to the use of community needs assessments in the revised housing appendix. Objector Ref 092c Policy/site ref Settlements - Boat of Garten C1 Summary The community wish to see included the development of a new primary school to support the sustainable growth of the community. C1 should therefore clarify that development on this site could include a school if so desired by the community. The wording should therefore read “ This site would be appropriate for a replacement for Deshar Primary School”. CNPA analysis The proposed wording and in a review of this site, the wording will be considered. Work will continue with the Highland Council to ensure that the approach taken and wording included is the most appropriate to meet the needs of all interested parties. Proposed Modification Include reference to possible use of land as school site. Objector Ref 092d Policy/site ref Settlements - Boat of Garten Summary The community wish to see greater emphasis within the proposals maps to secure the balance of activities and uses within the village. The general wording of resisting change of use is not strong enough. The proposals maps and supporting text should therefore be amended as follows: BG/OS1: Milton Loch and associated woodland and habitats are protected from development. BG/OS2: The Playing field is protected as recreational/open space. BG/OS3: The curling rink and adjoining woodland are protected as recreational / open space. BG/OS4: The grounds of the Gold and Tennis club, including the Golf course, are protected as recreational / open space BG/ED1: The Caravan and Camping site is retained for business/ tourism use. BG/ED2: The building of the Boat of Garten Hotel is retained for business/tourism use. BG/ED3: The Boat of Garten Station and the associated yards of the Strathspey steam railing are retained for business/ tourism use. BG/ED4, ED5 and ED6: The premises in Deshar Road currently occupied by the Post Office, Anderson’s restaurant and M&B Stores are retained for business/ tourism use. BG/ED7: The sawmill is retained for commercial use. CNPA analysis The level of detail on the proposals maps in support of the local plan will be reviewed in light of the representations received to allow for an appropriate level of detail to guide developers and clarify future development opportunities to communities. As part of this review a survey of the proposed sites in this representation will be undertaken to ascertain their qualities in meeting the development and other needs of the community and the impact it would have when assessed through the SEA. Proposed Modification Include area at station and camp site as Economic Development land. Include playing fields as open space. Add para 7.5 to confirm position outwith settlement boundary where other suggestions are not identified. Objector Ref Name Mr Alan Billington 093 Ellen-Brae Nethy Bridge PH25 3DB Policy/site ref Settlements - Nethy Bridge C1 Summary The site should be protected from development and must not be decrofted but protected for future generations. It should be protected as open space. CNPA analysis The inclusion of the reference within the supporting text of Proposal C1 was intended to allow a degree of flexibility to future development options. However, there is a general view that this reference is unhelpful and misleading, and as a result consideration will be given to the removal of the final sentence of Proposal C1. Proposed Modification Remove reference to housing in the text to C1 Objector Ref Name Mrs Olwen Billington 094 Ellen-Brae Nethy Bridge Inverness-shire PH25 3DB Policy/site ref Settlements - Nethy Bridge C1 Summary The reference to affordable housing for the community should be removed and the site should be protected from development. CNPA analysis The inclusion of the reference within the supporting text of Proposal C1 was intended to allow a degree of flexibility to future development options. However, there is a general view that this reference is unhelpful and misleading, and as a result consideration will be given to the removal of the final sentence of Proposal C1. Proposed Modification Remove reference to housing in the text to C1 Objector Ref Name Kay Briggs 095 Dalwhing Mill House Glen Tanar Aboyne AB34 5ET Company Mid Deeside Community Council Policy/site ref General Summary Support for the policies of the deposit local plan. CNPA analysis No modification considered necessary as a result of this representation. Proposed Modification No further action required. Objector Ref Name Mr & Mrs Houston 096 28 Craigendorroch Walk Ballater AB35 5ZB Policy/site ref Settlements - Ballater H1