The proposed new town in the Cairngorms – the conservation and access implications of the An Camus Mor planning application

An Camas Mor visualisation from 2008 re-submitted February 2017.  ACM is in the Cairngorm National Scenic Area.

On Friday the Cairngorms National Park Authority Planning Committee will consider a revised planning application for An Camus Mor (see here), the proposed new town across the Spey from Aviemore. (Click here for link to the Park’s planning portal and all 236 documents associated with the application). The main change proposed by the the application is to vary planning condition 1, which restricted the development to 630 houses (out of a potential 1500)  until the impact of this initial phase of the development on landscape and ecology had been completed.   Instead the applicants, An Camas Mor Limited Liability Partnership, the development vehicle of the landowner, Johnnie Grant of Rothiemurchus, are proposing a phased approach.

 

The abandonment of the precautionary approach

 

There is no explanation, from either the applicant or the Park about why the planning application needs to be varied.   The applicant’s letter 2017_0086_DET-SECTION_42_COVER_LETTER-100124269 claims that “The proposed change to condition 1 is essential to facilitate appropriate phasing of the development as the Design Team moves towards implementation of the development” without explaining why.  The Park’s Committee Report repeats this claim without explaining what it means.

 

The Committee report then fails to consider the proposed changes in relation to the precautionary principle or the National Park’s statutory objectives, which state that when their is a conflict between any of the Park’s statutory objectives, in this case sustainable economic development and conservation, conservation should come first.    That there is a conflict is clear from para 24 of the Committee Report:

 

SNH advise that the proposal is likely to have a significant effect on:
a) The Capercaillie qualifying interest of Cairngorms SPA (Special Protection Area for birds), Abernethy Forest SPA, Kinveachy Forest SPA, Anagach Woods SPA and Craigmore Wood SPA;
b) The acidic scree, alpine and subalpine heath, blanket bog, dry heath, wet heath, plants in crevices on acid rocks, and otter qualifying interests of Cairngorms SAC; and
c) The otter, Atlantic salmon, fresh water pearl mussel, and sea lamprey qualifying
interests of River Spey SAC.

 

Under the original condition,  if the development of this site had a larger impact than was being predicted or could be mitigated – and the whole site is basically surrounded by protected sites, including those important to the Capercaillie which once again is close to extinction in Scotland – it could be halted.   Johnnie Grant is now effectively asking for this limit on the development to be waived and the Park’s officers, in recommending the application is approved, are agreeing with him.  Its difficult to see any justification for this in conservation terms.

 

So why is this happening?  The most likely explanation is that the proposed change is being driven by financiers who will want guaranteed returns.  As a result of the infrastructure costs associated with developing the site (building new roads, relocating wildlife etc), it is likely that it will only be when house numbers reach a certain figure – probably over 630 – that the profit will really start rolling in.   Hence the reason for this application.    The financiers want to remove the risk that the development will not be highly profitable and the main risk of this happening in Planning Condition 1.   Money, it appears,  is more important than conservation in our National Parks.

 

Had the National Park officers been recommending that the development be reviewed and potentially halted at each phase of the development, that would have strengthened the precautionary approach, but unfortunately that is not what is being proposed.  Once the go-ahead is given for the whole development, and the block plan for the proposed housing has already been approved, it will become impossible to stop, whatever the evidence of impacts on the natural heritage.  In effect under a phased plan all the CNPA will be able to do is comment on matters of detail, not the wider impacts of the development.

The environmental impact of the proposed development and the implications for access rights

The main new document associated with the proposal is a 240 page Habitat Regulations Appraisal (HRA) dated 20th June, but which was only made public on Monday when it was uploaded to the CNPA planning portal, and which was drafted by CNPA staff with support from SNH (Appendix 4 of the Committee Report).

 

The HRA starts out by stating that the An Camus Mor Development will have a “likely significant effect” on no less than seven protected European sites:  Abernethy Forest Special Protection Area (SPAs protect  birds); Anagach Woods SPA; Cairngorms SPA; Craigmore Wood SPA; Kinveachy Forest SPA; Cairngorms SAC (Special Area of Conservation – protects things other than birds); River Spey SAC.       Basically the reason for this is 1500 new households at An Camus Mor will go out into the neighbouring countryside, which happens to be these protected areas, to do everything from walking dogs to mountain biking (and the people likely to be attracted to live at An Camas Mor, like Aviemore, are likely to be more active than most of the population).

 

The Habitats Regulations Appraisal however says that these impacts can be mitigated.  While there is a huge amount of detail (much of which is highly debateable in the report) In a nutshell what it is saying is that the CNPA and developer can compensate for additional recreational impacts from a larger resident population around Aviemore by reducing existing recreational impacts.  The outcomes required to mitigate for An Camus Mor and the measures that will be needed to make this happen are set out for each part of each protected area (hence the length of the document).   While the Habitat Regulations Appraisal at one place suggest these outcomes only apply to An Camus Mor residents there is no way of course of differentiating between local residents and visitors and, as phrased, most of the outcomes will affect everyone.  Here is the example for Inshriach, which is not exactly next door to An Camas Mor:

What this is saying is that in order to compensate for An Camas Mor, access rights will be restricted, so off path recreational facilties will stop and both residents and visitors will have to keep to “promoted existing routes”.   This is far more draconian than the Loch Lomond and Trossachs National Park byelaws and if implemented would in effect end access rights in large parts of the Cairngorms National Park.  Worryingly, the document even states that byelaws are a measure of last resort.   So, the CNPA is in effect proposing to sacrifice access rights to enable An Camas Mor to go ahead.   This is a national scandal and should not be being decided by the Planning Committee of the National Park.

 

There are all sorts of other implications for access to, as is clear from the measures proposed for Glenmore:

 

 

What this in effect says is that in order to enable the An Camas Mor development to go ahead existing car parks will be reduced in size or blocked off completely, certain access routes will be blocked off, particularly for mountain bikers etc etc.   Just how this fits with the Cairngorm and Glenmore Strategy, which was agreed less than a year ago, in unclear.    And similar measures are proposed for much of the rest of Speyside.   The implications for recreation and tourism are huge and yet there has been no public consultation.   There needs to be and the Planning Committee should refuse to take a decision until there has been full public consultation on the CNPA’s Habitats Regulations Appraisal otherwise it will be digging a very very deep hole for itself.    I am confident that if consultation did take place on the proposed mitigation measures, the proposals will collapse.

 

So, what is the explanation for  what is going on?

 

In 2014 the Scottish Government paid Johnnie Grant £7.2m for part of the Rothiemurchus estate in a secret deal (see here).    The question as to why Johnnie Grant needed to sell this land, or why the Government needed to purchase it when it was not at any risk, has never been answered.  One possible explanation is that Johnnie Grant needed to raise funds to help finance the An Camas Mor development.  If even an element of this £7.2 has been or is going to be spent on An Camas Mor, the Scottish Government has already been effectively helping to finance the development.

 

Whatever the case, there is a statement in the applicant’s letter that since the original planning application it has had:

 

Discussions with the Scottish Government and its advisors around advancing the design
and planning process in order to get to a point where Infrastructure Loan Funding for exceptional external infrastructure can be released for this project.

 

This appears to indicate that the Scottish Government is fully behind this application.    It would take a very strong National Park Board to reject the Scottish Government’s wishes and the suspicion has to be that both senior staff and Board have not approached this according to matters of principle, but rather are doing what they have been told to do.  To repeat, because of the implications for access of their proposed mitigation measures, they are digging a very deep hole for themselves.

Osprey on post at centre ACM, June 2016 which it was still using in August 2016. Photo credit Badenoch and Strathspey Conservation Group

The suspicion of a stitch-up is re-inforced by the failure of the Committee Report to consider more up to date information on the wildlife to be found on the An Camas Mor site.  The Badenoch and Strathspey Conservation Group, who have been looking at the wildlife on the site for some time and discovered a number of species not reported in the original planning application (see here for brilliant photos of the wildlife), have been asking the Park for updated environmental surveys for some time.   Earlier this week, the CNPA at last added a survey on badgers to the planning portal but at the same time redacted most of the content.  Presumably someone doesn’t want the public to know how many badgers may be affected by the development because badgers are likely to arouse more public support than bugs.

 

More importantly, the Badenoch and Strathspey Conservation Group had been asking for a copy of the Habitats Regulations Assessment for weeks.  The CNPA refused to provide this, on the grounds they planned to publish this,  which they eventually did this Monday – despite the massive implications for access rights.   The CNPA apparently expects the BSCG and Cairngorms Campaign, both of  have both asked to address the Committee on Friday, to be able to assimilate and respond to this 240 page document in four days.  That’s not right, although this situation has been partly mitigated – excuse me using that term – because SNH, to their credit, did agree to release the information.

 

Why the secrecy? I had expected better of the CNPA.  And what is the CNPA scared about?     I hope I have provided enough information here for some Board Members to start asking some searching questions.

 

The level of support for the proposals

 

Despite a sustained local campaign to raise support for the proposal – see the ACM leaflet May 2017  which was delivered to every house in the Aviemore area – there were only 12 general expressions of support for the revised An Camas Mor planning application. “Of those supporting, nine were from individuals (eight from Aviemore and one from Pitlochry) and the remainder werefrom Visit Scotland, Scottish Tourism Alliance and Aviemore Sports Centre”    This compares to 23 general objections of which “16 were from individuals (from Aviemore, Kingussie, Nethy Bridge, Aboyne, Bettyhill, Broughty Ferry, Comrie, Ellon, Dunblane, Glasgow, Inverness, Limekilns in Fife, East Molesey in Surrey, Kendal and Wirral in Merseyside). The remainder were from the North East Mountain Trust, Scottish Wildlife Trust, Scottish Campaign for National Parks, The Cairngorms Campaign, Butterfly Conservation Scotland and the Badenoch and Strathspey Conservation Group.”

 

This is hardly an indication of high levels of support for the proposals, a factor which usually influences the politicians.   Part of the reason why may be because people working in Aviemore who currently don’t have suitable housing are not convinced that An Camas Mor will meet their housing needs.  When they learn it may affect their access rights too – and there is a much higher proportion of people who mountain bike in Aviemore than the rest of the country – they might actually start to oppose the whole development.   I hate to say this, but it looks like someone in the CNPA has reached the same conclusion, which is why the Habitats Regulation Appraisal has only been published at the last minute (I am happy to give the Park a right of reply on parkswatch to explain their position).

 

The wider picture

 

The big question is why, having created National Parks to protect parts of Scotland which are particularly important for conservation and recreation, are they in a position where much of their time and resources is devoted to developing new towns, leisure developments like Flamingo Land and inappropriate developments up mountains?.  Surely our National Parks were created to do things differently?

 

I can understand our politicians wanting to create jobs and build better places for people to live – I think this is necessary too – but to do this in the same old ways, basically giving land over developers to produce yet more inappropriate developments, shows a complete lack of imaginative thinking or ideas of how to promote sustainable economic development.      Both our National Parks need an alternative economic strategy, and to pioneer new paths to sustainable economic development.

 

Added to the inappropriateness of developments such as An Camas Mor, is the fact that its located adjacent to Glenmore, the place most under pressure in the whole of the Cairngorms National Park.  Why then is the CNPA directing development to the very area that can least support it?   There are plenty of other places, such as Dalwhinnie and Laggan, which could sustain further development and if developed would help spread visitor load.    Instead, the implications for all those who currently enjoy visiting Glenmore is that in order to offset the impact of more people living locally (and cycling or walking their dog in Glenmore) new visitor management measures will be introduced which will have a drastic impact on access rights.   This means this development has implications for the whole recreation community, including people who go to Glenmore to enjoy wildlife.

 

The big test for the CNPA on Friday is whether it will put the needs of the developer and the wishes of politicians before  its duty to promote conservation and public enjoyment of the countryside.

15 Comments on “The proposed new town in the Cairngorms – the conservation and access implications of the An Camus Mor planning application

  1. Bad news for everyone; locals, wildlife, visitors, habitat and land users.
    The only people it suits seem to be the money men.

  2. I’m horrified but not surprised. CNPA has always given the impression of being” an old boys club” I live in Kingussie which is about to see a not dissimilar stance for unrealistic amounts of new housing. The values I moved here for are systematically being dismantled. Im moving.

  3. I have to say I do see some merit in the creation of a new, planned village in the area. The obvious natural attractions of the local hills, lochs, rivers, straths and climate mean the local population is not just growing in line with the national average but is increasing massively as people choose – not unreasonably – to move into the area. If we accept that x thousand new homes are going to be built in the not too distant future, is it not better that they are clustered round an appropriately proportioned village centre with services to match? Would I want to see housing built for 500 people at Glenmore? And Tulloch? And Alvie, Kincraig, Dulnain … ? If the housing capacity has to come, then surely it is better that it is planned with a view towards the likely population in 2050 than forever building new layers and “schemes” around the existing villages and ribbons of development along all the roads …
    If we DON’T think this many new homes should be built at all in the area, then that is a different argument and poses some very difficult questions. Who should be “allowed” to live here – 3rd generation locals only? Those who can pay silly money for a house/ 2nd house? I don’t think it is a simple issue!

    1. The question posed in your final paragraph was addressed by the CNPA in the draft of its first Local Plan: to have a “residency criteria” for those wishing to purchase new-build dwellings. Such a policy would restrict ability to purchase newly built dwelling to those already living in the NP, or with a defined connection to it (for example, having secured a job in the park or having lived there previously for a certain number of years). That would have the effect of i) reducing the number of dwelling needed to be built and ii) reducing the market for, and thus the cost, of any dwellings that were built.
      That sensible policy, that would have enabled the CNPA to claim that it was upholding the conservation aims of the NP, was opposed by large landowners and developers and the Scottish Government. Hence the present appalling situation.

  4. A truly excellent article which I hope all members of the CNPA Planning Committee read before Friday. If the An Camus Mor planning application is approved, I believe the Cairngorms National Park will no longer be a credible National Park. As someone directly involved in the tourism industry, most of our guests (especially guests from abroad) are amazed that such a huge development is even being contemplated.
    For many years now, our Scottish Government has placed more emphasis on economic development than on conserving and enhancing the natural and cultural heritage in our largest National Park. Building An Camus Mor will clearly conflict with the conservation aim of the National Park and therefore must be rejected. If the planning application is granted, then we will need to rename CNPA as Cairngorms New Town Planning Authority.
    Scotland is facing a real crisis in the over-development of tourism in several areas of Scotland – one of these is the Cairngorms National Park, particularly the area around Aviemore. The addition of 1500 houses, with the likely imposition of a wide range of restrictions on access to places currently popular with visitors to ‘compensate’ for lost habitats etc. will just exacerbate problems that are already present. We urgently need to understand the pressures tourism is placing on our sensitive and fragile ecology of the National Park and develop a truly sustainable tourism strategy, before we consider building 1500 houses in an already highly populated part of the Park. The Scottish Government and Visit Scotland doesn’t seem to have any sustainable policy for tourism – they just want short term growth at all costs.
    Given the recent experiences of the permitted environmentally insensitive ground clearance in preparation for a 53 house development in Grantown-on-Spey, if the CNPA Planners are allowed to ‘oversee’ the construction of An Camus Mor the scar on the landscape will be present for many years for our visitors to see as they travel to Glenmore, Cairngorm Mountain and the surrounding area. I am convinced that the building of An Camus Mor will have a major detrimental effect on tourism in this part of our National Park – far less the detrimental effect on our critically endangered wildlife and habitats.
    The CNPA, the Scottish Government and all of us lucky enough to live within the Cairngorms National Park need to waken up now – before it is too late.

  5. Replying to Hamish, The requirement to build houses shouldn’t be the same for a National Park as they are for the Shires and Councils otherwise what is the point in them having the development planning? At the moment the so called demand for housing comes across from the Scottish Government to the Councils and in Highland’s case they pass some of this onto the CNPA. The CNPA’s own numbers show the population isn’t changing but the type of house is – generally to smaller homes. A National Park needs to think differently about housing if it is to meet its aims. The CNP needs quality social housing held in perpetuity (not sold on to private ownership) so that seasonal workers can find somewhere to rent and the housing lists can be addressed. There is no evidence to support gross open market development meets this need. In fact, it is the opposite and evidence shows neither of those needs are met. The CNPA board needs to step up to the demands of being a National Park Authority. In the case of An Camas Mor the developer is even going to the Scottish Government for money to cover the infrastructure costs, as the article says. How mad is this? Why not use the taxpayers money to supply social housing and not subsidise developer’s, land owners and second home owners pockets. There are much more effective ways to provide housing within the CNP but it requires a lot of detailed thinking and work with the existing settlements. Involve bodies with the local knowledge to build what is needed in places that fit in with all the things that made the Cairngorms such an attractive place. Any planning authority can build suburbia. CNPA inherited An Camas Mor when the Park Authority was formed and they have just carried on the same old process.

    1. In reply to Susan, Highland Small Communities Housing Trust are a partner in An Camas Mòr, in order to do just as you say above and protect the houses for locals in perpetuity. They also just launched a survey in order to get a very clear idea of what the housing needs actually are in the area. You can find the survey here if you are interested. http://hscht.polldaddy.com/s/an-camas-mor-potential-resident-survey. The Park was set up to look after sustainable communities and natural heritage in equal measures. If you read the Park Policies on sustainable communities and housing development you will see that they mirror the Scottish Government recommendations to find collaborative ways and mechanisms to tackle the housing shortage problem and that is exactly what An Camas Mòr is – a collaborative project. It is not a gross open market development as you described it above and will certainly not be suburbia. If you want to see the concepts behind the plan there is a lot of great info here. https://www.facebook.com/ancamasmor/ and here, https://www.ancamasmor.com/

      1. But what enforceable measures actually exist to ensure that thus housing is actually occupied locally. There exists a real mechanism in Cumbria for example, so why not a similar one here? Without such, why won’t thus simply become another holiday estate like the other developments?

  6. This is by no means atypical of Johnny Grant but as regards the CNPA, it is outrageous. Aviemore and surrounds can’t cope with visitor numbers at the moment, never mind another thousand or so homes. But, the trajectory is clear; the dualling of the A9 and, of course, a new Bridge over the Forth, makes Aviemore a very attractive place to live, while I suspect the Governments economic onus will serve very well in facilitating this attraction, i.e. favouring developments like this.

  7. ..And what about the other real issue. Vehicles .
    Cars are not going away , maybe electric but we all have one or two !
    cars busses and lorries and bikes… Only one vehicle bridge!. And the B970 .is this safe and sustainable?

  8. The hard facts of the matter are that Jonny Grant was given the nod for this development even before the Cairngorms National Park was established. Despite our objections to the whole concept of effectively having a new town inserted into the middle of a national park, objections I may say which were upheld by the original inspectors to the first Local Plan Inquiry, it is clear that the Park Authority will use any excuse to push this through.
    This is not a party political point since it covers all parties apart from the Greens.

    Bill McDermott
    Scottish Campaign for National Parks

  9. I am rarely surprised at the duplicity of the current Scottish Government when it comes to environmental issues. Shame on the Park authority for failing in their protective duty. This development was never about local housing demand and everytime I hear Mr Grant suggest that this development is welcomed by the local community I cringe. I certainly sympathise with the respondent who suggested that this is a betrayal of the values which led many of us to live in this area. Free access to the hills and countryside is an issue which many generations have fought to gain. The Scottish Government are very ready to suggest we have the best access rights of any western country. It seems however that this “right” can be set aside if it inconveniences developers and compromises profit. I look forward to supporting the inevitable local opposition movement.

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