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 NEMT’s 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

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 Park’s “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 Park’s 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:

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 Park’s scarce public resources for nation-wide purposes which are separately funded by the Scottish Government:
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 wildness?
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 Park’s 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 Park’s special qualities, those that fit into or enhance the very special environmental / landscape requirements, and those that are based around truly sustainable tourism.
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 a hundred.
Outcome 8 (Business and communities will be successfully adapting to a low carbon economy):
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 isn’t extremely important)
Outcome 9 (The Park’s 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 Park’s 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 Glenmore corridor.

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

  1. 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.
  2. 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.
  3. 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.
  4. 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 curtailed.
  5. 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.
  6. We consider the benchmark of 25% affordable housing to be inappropriate and hence prefer Option 2 (100% affordable housing).
  7. Spatial Strategy — We support the preferred option but are not happy about the strong presumption that more development is all that matters.
  8. 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.
  9. 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.
  10. 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.
  11. 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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