Dave Windle
Full Reply (PDF)
We support the proposal to identify a limited number of smaller sites in existing communities and agree that further work needs to be done to identify solutions to the second home issue.
We welcome the proposal for a uniform increase in the affordable housing requirement to 45% in four principal settlements. The threshold to gain exemption from this should remain high.
We have not commented on the individual proposals as these are best addressed by the local communities concerned.
We support the desire to "support or contribute to a year-round economy" and to encourage low-cost visitor accommodation.
The plan should discourage stand-alone developments which do not offer nearby economic opportunities (such as House of Bruar, just off the A9 but with almost no local community) and are likely to degrade the rural environment.
The priority given to retail, tourism and leisure, appears to neglect other sources of economic growth such as adding value to locally produced raw materials, or consultancy-type or household/business services.
The policy says all the right things, with the presumption against removal of woodland, and the reference to the four statutory aims of Scottish National Parks and the need to give greater weight to conservation where conflict between different aims arises. It would be good to reiterate this sentiment under Policy 4.2 "National designations" as it is particularly relevant here. It is hoped that this principle, along with that of the precautionary principle, will go some way to moderating the 'get-out clauses' attached to most policies on the conservation of protected sites and species.
Considering the large proportion of designated sites/features which are not in favourable conservation status, it would be better to see a net environmental gain/benefit approach to mitigation/compensation, rather than taking an approach of "equal quality". The LDP should promote policies which will encourage proponents of development (who will commercially gain from such development) to make efforts to not only minimise the damage they might do, but also to contribute to the enhancement / recovery of adjacent areas – for example, through habitat restoration activities. This could assist with meeting favourable conservation status targets for Natura 2000 sites.
It is noted that the term climate change appears throughout the LDP, but not once in this section. If the potential cumulative effects of developments are to be effectively assessed and mitigated, then it is essential to consider the additional pressures which a changing climate is placing on habitats and species, and, consequently, their reduced resilience to impacts from development. Such issues will become even more important in the period 2020-2025.
We welcome the recognition of landscape as the prime characteristic of the National Park, and agree that it should be strongly protected. Tight control is required, as it is hard to envisage development (in planning terms) that does not detract, often irreversibly, from large-scale wildness.
With regard to hill tracks, we applauded the 'presumption against new constructed tracks in open moorland' in the Park Partnership Plan. However, we think that aspects of the wording in the draft LDP dilute this and suggest strengthening the "presumption whilst allowing for exceptional circumstances.
Given the growing problem of damage caused by excessive ATV use and its emerging implications for the Park in planning terms, we think that this must be included, and suggest the addition of:
"The use of ATVs in open moorland over time can cause significant damage to peat and soils and create visually intrusive scarring. This has recently emerged as a justification for constructing new tracks in planning applications. The National Park will work with the relevant statutory bodies, landowners and other interested parties to find solutions to this problem."
Most authorities on renewable energy acknowledge that renewable energy alone will not bring about the required reduction in carbon emissions. Demand reduction is an integral part of the equation. This section should contain proposals for, e.g. installing improved insulation, when existing housing, retail and commercial stock is modified.
Tracks and associated "borrow pits" are often the most visually intrusive aspects of small-scale hydro. To reduce the impacts on landscape, any new tracks required should be of ATV width, and access to intakes close to existing tracks should be via footpaths only.
NEMT is pleased to note the presumption against large-scale commercial wind farms.
Resilience to the changing climate will not be improved by using renewable energy. It will be improved by, e.g., improving flood plain management to cope with larger peak flows.
This policy provides good guidance on the use of resources as well as approaches to safeguard them in the National Park. However, aspects of this policy could be strengthened by some re-phrasing, clarification of statements, and some inclusions on natural flood management (NFM).
There is no acknowledgement of the principle of integrated catchment management of land and water resources, which is Scottish Government policy and a principle encouraged by SEPA and SNH.
The availability of SRDP and Water Environment Funding for restoration and NFM begs the question of why so little of it is taken up with new restoration initiatives in the Park.
Some aspects of the policy set out good guidelines but have opt-out clauses
which compromises the protection which the policy is meant to offer. There are
other parts which use the terms "appropriate" or "significant" without expanding on the exact meaning, perhaps to be intentionally vague. It is understood that precise conditions cannot be described. However, it would
be useful for all stakeholders if reference could be made to relevant standards,
guidance or best practice.
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