PLANS, PLANS AND MORE PLANS
That well-known housing agency, the Cairngorms National Park Authority, operates
with a large number of plans, strategies andframeworks. The main ones are the
Park Plan and the Park Local Development Plan - which is to replace the Park
Local Plan, which is being challenged in the Court of Session.
Everything clear so far?
The Draft Cairngorms National Park Plan 2012-2017 was issued for public consultation
in autumn 2011. At the same time, a 116- page Main Issues Report
was put out for consultation as the first formal stage of the Local Development
Plan (LDP), accompanied by a Monitoring Report, an interim Environmental Report
of the Strategic Environmental Assessment, an interim Habitats Regulations Assessment
and an Equalities Impact Assessment.
This article summarises NEMTs submissions to both consultations.
The National Park Plan Consultation
This was structured around a number of questions, proposed outcomes, and work
packages Full details of the Plan, the Consultation and all Responses can be
found at http://www.cairngorms.co.uk/park-authority/national-park-plan/cairngorms-national-park-plan-2012-2017.
- Question 1: What makes the National Park Special to you?
- The Draft Plan says (p. 13) that we know [that] the National
Park is special for its natural heritage [and] .. also. for its cultural
heritage and recreation opportunities. We agree with this sentiment,
but stress that we should be interpreted as the Scottish and UK
people as a whole, with lesser though due regard to (a) others such as foreign
visitors and residents and (b) Park residents. We support the (implied?) prioritisation
of the Parks special qualities, but in general we are not
convinced that this attempt to supplant or complement the objectives of the
Park as laid down in the relevant Act is very useful.
- Question 2: Do you agree with these descriptions of the special qualities?
- The special qualities of the Park are summarised
in four key themes (an odd word?), viz. (in brief) its mountains,
habitats, landscape and wildness and space. We agree with these
descriptions, and are particularly glad to see its mountains listed first,
even though (or because?) these provide the basis for most of the Parks
special habitats and landscapes, and almost all of its wildness and
space. The lower parts of the Park are not in themselves highly special
as a whole, particularly where these are dominated commercial plantation,
communications (roads, rail, pylons, etc.), hydroelectric installations, standard
modern buildings, etc. The Plan therefore needs to (i) protect and where appropriate
(which will be seldom) enhance the special qualities of the mountains,
while (ii) seeking to upgrade the qualities of many lower areas where past
degradation has taken place, and may still do so.
- Question 3: Are there other special qualities you think should be explicitly
identified in the National Park Plan?
- We are not convinced by the rather purple prose (p. 14, and Table 2.1 on
p. 15) derived from a 2010 study. Phrases such as Strong juxtaposition
of contrasting landscapes and The harmony of complicated
curves mean very different things to different people. We would
like remoteness (of areas, not settlements) to be given higher
priority in the document as a whole; while the long walk in concept
has its critics, there is no doubt that physical remoteness brings its own
mental and physical health benefits, as well as biophysical ones such as low
disturbance levels to soils and wildlife.
- Question 4: Do you think the long-term outcomes should be updated and condensed?
- We welcome the reduction in the number of long-term outcomes from 23 to
10, particularly the removal of those unlikely to be achieved (e.g. consistently
exceeds residents and visitors expectations ; outcome
17, p.18) or marginally relevant (learning and knowledge;
outcomes 22 and 23, p. 18).
- Question 5: Do you agree the set of 10 outcomes provides the right focus
for the next five years?
- We particularly support the following outcomes:
- 2: The quality and connectivity of habitats will have improved, enhancing
the landscape at a Park scale
- 3: The species for which the Cairngorms National Park is most important
will be in better conservation status in the Park
- 4: The qualities of wildness in the Park will be greater.
We are concerned that the following outcomes focus too much on local as opposed
to national objectives (which should dominate for a National Park), and may
simply utilise some of Parks scarce public resources for nation-wide
purposes which are separately funded by the Scottish Government:
- 5: There will be a better targeted programme of advice and support for
land managers in the Park that delivers the National Park Plan
- 6: The economy of the Park will have grown and diversified, drawing
on the Parks special qualities
- 8: Business and communities will be successfully adapting to a low carbon
- 9: The Parks communities will be more empowered and able to develop
their own models of sustainability
- Question 6: Which are the most important outcomes to you?
- Outcome 4: The qualities of wildness in the Park will be greater.
Wildness implies natural processes and there is little scope for its enhancement
by human intervention. We consider Landscape Quality and Wildness to be important
qualities of the area. Both are difficult to quantify, but all development,
including enhanced access is likely to reduce these qualities.
The greatest threat to the area is the reduction in wildness. Development
should be confined to low ground, with protection of the core areas.
- Outcome 2 (The quality and connectivity of habitats will have improved,
enhancing the landscape at a Park scale)
- is very important and vital to efforts on Outcome 3 below. However, Work
Package 1 (identifying opportunities for expansion and connection} underpins
this whole Outcome and needs to be specially pursued and protected. The suggested
targets of 5% are rather unambitious: 10% would be more appropriate.
- Outcome 3 (The species for which the Cairngorms National Park is most important
will be in better conservation status in the Park)
- is supported, but the work packages are OK but are very consultative, lacking
input to SMART targets. The proposed indicators and targets are measuring
inputs and not outcomes.
- Outcome 4 (The qualities of wildness in the Park will be greater)
- is an extremely important Outcome and, in our view, absolutely key to the
success of the Park. However, the work packages fall far short of what is
needed. For example, the piece on hill tracks talks about following best practice
in the design of hill tracks. This fundamentally misses the point that any
new hill track, no matter how well designed, destroys the quality of wildness
in the area. Woodland creation, provided that it is appropriate woodland,
is a positive step. What about removal of features that are presently degrading
- Outcome 5 (There will be a better targeted programme of advice and support
for land managers in the Park that delivers the National Park Plan):
- We are deeply suspicious of the motives of a proportion of the land managers
in the Park, e.g. their attempts to justify new hill tracks. However, we agree
that there is a substantial proportion with the right motives and hence we
support this Outcome.
- Outcome 6 (The economy of the Park will have grown and diversified, drawing
on the Parks special qualities):
- We do not support this Outcome as presently worded. We believe that the
wording needs to be tighter to ensure that business success is not measured
across all businesses but reflects those businesses that add to rather than
drawing on the character of the park, e.g. those that use the
Parks special qualities, those that fit into or enhance the very special
environmental / landscape requirements, and those that are based around truly
- Outcome 7 (Settlements and built developments will retain and enhance the
distinct sense of place and identity within the landscapes of the Park):
- We are doubtful that any new settlements and some new built developments
can retain and enhance as is suggested. The indicator is rather
narrow and should be wider than just high street improvement projects. In
addition, the target is just to complete all projects. That could be one or
- Outcome 8 (Business and communities will be successfully adapting to a low
- There is nothing here of specific relevance to the Park. It should not be
assumed that the Park has a special role to play in this area and should simply
acknowledge that it will follow national programmes. The problem with this
sort of outcome is that it attracts scarce resources away from locally more
important issues (without in any way, saying that at a national level, this
isnt extremely important)
- Outcome 9 (The Parks communities will be more empowered and able to
develop their own models of sustainability)
- needs to be tightened up. As written, this could lead to a series of self-governing
communities, inwardly focused and lacking any cohesion to the wider park,
following a non- national agenda. We support empowering communities but within
a clear framework with national goals.
- Outcome 10 (The Parks recreation opportunities will have improved
the health and enjoyment of residents and visitors)
- needs to be dove-tailed into the national framework. For example, park resources
should be used to increase public awareness of the health benefits of recreation
activities. Why should park resources be used to increase the health of either
residents or visitors over and above existing national and local authority
spending? Development of the core path network needs to be taken carefully,
e.g. upgrading the Speyside Way is something that we would support but developing
paths, as opposed to maintaining them, in the sensitive inner core would be
something that we oppose. Core paths are important access routes, but beyond
this have limited relevance to much of the core area of the Park. We maintain
that it should be possible to avoid conflict with other land users. Apart
from between recreational users, most interaction occurs at access points
and in non-core areas. Management of this appears to be well handled by the
LOAF. We would be interested to hear about new approaches that
might be used to manage pressures at honey pots, including the
As detailed in our response to the Main Issues paper, we cannot
support the development of a new town. While supporting the quantity of affordable
housing, we believe that the proposed total expansion in housing is inappropriate.
We are not convinced of the need for this scale of development.
Comments on the Main Issues Report
- The majority of the document deals with developments within the Park, and
we suggest that more emphasis should be given to conservation issues (especially
but not only within the Special Qualities section) in order to
produce a more balanced document.
- We are surprised that Cairngorm Mountain itself is not identified and analysed
as a Main Issue. It is the icon of the Park and it is what most Scottish people
think of when the National Park is mentioned. It has a chequered development
history with the hugely controversial funicular railway development, and the
company is now looking to diversify into summer activities. Any further development
of the mountain needs to be treated very carefully and is likely to cause
significant controversy. Given the likelihood that trends and fluctuations,
both financial and climatic, are likely to trigger further proposals, the
Park Authority should have a clear strategy for the way forward.
- We note that there is a significant move towards providing additional spatial
guidance (in the form of maps of special qualities, particularly wildness)
within the Main Issues Report. It is something that we have long argued for
and think that it is to be welcomed. It will be important to make sure that
this spatial guidance is focused on protecting the core areas of the Park
rather than simply giving carte blanche to any development in the periphery.
- There is heavy focus on more housing, which is undoubtedly a main
issue for the Park. While we fully support the idea of more affordable
housing for Park residents who will provide essential services, we cannot
believe that a massive increase in housing for the retirement, second-home
and holiday-let markets is the best way to achieve this. The Park should not
put itself in the position of acquiescing in high effective economic demand
for more housing to be constructed for the wealthier and more mobile sections
of the national and international community; not only is this likely to damage
the quality of the Park, but the more successful the Park, the higher such
demand (as opposed to need) is likely to be. A ratio of three
full-price houses to one affordable house is poor and certainly not best practice.
We suggest that the proposed increase in full-price housing be drastically
- The document refers to the National Benchmark for affordable housing, which
we believe is inappropriate. Given the special qualities of the Park, a much
greater proportion of affordable housing within any allowed new housing development
is required, and a much reduced supply of new full-price housing.
- We consider the benchmark of 25% affordable housing to be inappropriate
and hence prefer Option 2 (100% affordable housing).
- Spatial Strategy We support the preferred option but are not happy
about the strong presumption that more development is all that matters.
- An Camas Mor is fundamentally wrong in concept. The Park does not need a
large-scale new town in such a prominent and central location. This might
be appropriate for the development of an area of lesser conservation importance
outside the Park and with already good transport connections (to limit further
traffic). Development of the existing centres, to improve services and Park-
friendly ambience, is one thing; building a whole new urban area
within the Park is another. If more emphasis was placed on needed affordable
housing and less on full- price housing wanted only as positional goods
by the relatively wealthy and economically inactive, there would no need for
An Camas Mor.
- Support for Rural Areas We believe that the preferred option is too
loose and open to abuse and hence we prefer Option 2. We agree that Landscape
Character Assessment is a good tool for this situation, and when used wisely
would give an appropriate answer. However, such assessment is controversial
(would a landscape gain or lose in character if new buildings were to replace
current ruins?), and it is too easily manipulated so that we could end up
with, e.g. single new buildings in rural areas. Restricted development as
in Option 2 would allow the addition of a house to say 5 existing houses or
a building to support a small local rural business.
- Connectivity and Communications We find this too general to be of
any use. A footpath/cycleway from Dulnain Bridge to Grantown is a good idea
and would be fully supported. However, improving the road network, with or
without developer contributions, will simply generate additional traffic with
consequent additional emissions, etc. We do not support improving the road
network, except for dualling the whole of the A9 through-route.
- Developer Contributions - We are concerned that this as a slippery slope
leading to An Camas Mor proposals. Developer Contributions should be for affordable
housing only and not considered as conventional contributions.
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