Arguably the most important item on the agenda of the Cairngorms National Park Authority Board Meeting on Friday (link to papers) was the Local Development Plan. The current five year plan was approved two and a half years ago but the consultation for the next one is due to start at the end of the year. The Board was being asked to consider the draft “Main Issues Report” for consultation. It contains many important issues (which I will come back to) and a significant discussion about An Camas Mor.
When the CNPA Board renewed the planning permission for An Camas Mor for a paltry £203 under Section 42 of the Planning Act in the summer, part of their argument was they had no choice but to do so. This was because the land at An Camas Mor was set aside for housing in the existing Local Development Plan. There is a danger here of a circular argument, planning permission is granted because a new town at ACM is in the Local Development Plan and then the Local Development Plan allocates the site for a new town because……its been granted planning permission. This could go on for years!
In what I see as a significant development the Main Issues report identifies a way out of this circular argument based on the Scottish Government’s targets for new build housing in the National Park:
We will continue to work with the site owners and their design team to deliver An Camas Mòr. However, it is also possible that An Camas Mòr will not be delivered. The next Local Development Plan needs to be able to adapt to those circumstances if they happen and have alternative ways of meeting the National Park’s housing land requirements in the event that the site is unable to be developed.
The argument is that if ACM is not built, the CNPA’s proposed housing targest would be missed so the CNPA is suggesting setting aside alternative land for housing. Its suggestion is land at the northern edge of Aviemore which, it says:
“is close to the existing road network, mains water supplies, sewage infrastructure and electricity supplies and would link to existing services and facilities in Aviemore.”
In other words, the infrastructure costs associated with development would be signficantly less and so make the development more likely to go ahead. If that is the case, however, why not just choose the site now and ditch ACM?
There is lots of other interesting information in the report (the CNPA is in a different league to the Loch Lomond and Trossachs National Park Authority when it comes to providing evidence about its plans – the draft LLTNPA National Partnership contains no proper evidence). This evidence I believe will further assist with opening up a debate about whether ACM is a sensible solution to the Park’s housing problems. Take the chart above (which excludes ACM which is projected to provide 50 accommodation units a year till it reaches 1500). This shows that in 2020 and 2021 new housing completions will exceed the Park’s target and by my reckoning this surplus offsets the shortfall between 2023 and 2026. From then on the projected shortfall is only 20 houses a year, far less than the 50 a year ACM claims it will provide. So, why is ACM needed on the Park’s projected “Annual Housing Land Requirement”?
If the Park’s projections of either demand or supply are wrong and fewer new houses are needed – for example if the number of vacant houses in the National Park could be reduced – there would be no justification for ACM at all.
The Local Development Plan is also proposing to increase the proportion of affordable housing in new housing developments from the Scottish benchmark of 25% to 45% in Aviemore and Blair Atholl because of the shocking levels of low pay in the National Park (average pay is well below the Scottish average). Now, I think this is a commendable move in the right direction, even if its not clear if this applies to ACM as well as Aviemore. It should do though and, if it did, it would be very interesting to know if ACM would still go ahead (because of the high cost of new infrastructure).
Although the CNPA is saying in the Main Issues Report that it will do all it can to facilitate ACM, the logic of the Plan and the evidence seems to me to point to a different conclusion: that is it would be much better use of public money to plan for social housing elsewhere NOW and not wait for ACM to fail. This would also avoid an access stushi and, most important of all, the destruction of one of the finest areas of regenerating native woodland (see here) in the National Park. The consultation on the Local Development Plan offers an opportunity to stop the new town madness that is An Camas Mor and for the CNPA to meet its objectives both for conservation and sustainable development.