The new draft Cairngorms National Park Local Development Plan 2020 was launched for consultation on 25 January (see here) and we all have until 5 April 2019 to plough through the 228 pages and the myriad of supporting documents and make our comments.  This document is the outcome of the Main Issues Report which was published (see here) for consultation last winter.

The CNPA was certainly thorough in ensuring I was aware of this consultation as I received both a letter, as my property shares a boundary with one of the proposed development sites, and an email, as I had commented on part of the Main Issues Report consultation.  Excellent communication.  However I started to have concerns on downloading the consultation documents and comparing the section on Grantown on Spey with the letter I received. Within minutes I was finding what I would call ‘schoolboy’ errors.

 

Labelling errors and omissions

1. My notification letter (Fig 2) labels the  Community Use area (in pink) C1, but this is labelled C2 in the Plan (Fig 1).
2. Fig 1 shows two H1 areas (red/brown – housing allocation), but one of these should be labelled H2.
3. The section dealing with H2 (see Fig 3 below) is missing the site map (the empty grey box below)
4. The key in Fig 1 for the settlement boundary is in the wrong colour (pale blue instead of white). The conservation area is indicated with a similar dashed pale blue line, which is hard to see and the key for the conservation area boundary doesn’t look anything like how it is depicted on the map.   These inaccuracies/instances of poor design, though more minor, can easily lead to confusion.

Fig 3: Grantown on Spey H2 proposed development area  LDP (Page 112).

 

Other concerns

Fig 4: Grantown on Spey H1 Housing area from consultation LDP with arrow added

1. It is unclear why there are two shades of red/brown for the H1 housing area (see Fig 4). In particular the  darker red/brown area (arrowed).
2. The dashed white line in Fig 1 which is intended to show the indicative line of the long awaited steam railway is in the wrong place. Persons knowing the area could interpret this as a re-alignment of the proposed railway – through mature woodland to get to the proposed terminus at C2 rather than following the existing disused track line.
3. Fig 5 (below) shows the page covering the Caravan Site. Again, the meaning of the two different colours of purple shading is unclear particularly when there are two separate blocks of dark purple.  There is a licence boundary for the Caravan Site, and I understand that the owners do own land outside of that licenced area.  To aid the understanding of persons reading this page, the current licenced area should have been clearly shown, plus any area into which it was proposed to extend the licenced site.  It also should have been made clear that any extension of the Caravan Site licenced area requires a planning permission.

Fig 5: Grantown on Spey T1 Caravan Park from consultation LDP (page 113)

4. Both maps showing the H1 and T1 sites (Figs 4 & 5) have the attached words, “Natura site affected Spey SAC Mitigation required (see table 4)” and a yellow/brown icon of a digger. The meaning of the digger icon is not explained and it is unclear where table 4 is in the document [Ed. a five minute word search found several references to Table 4 in the plans for local communities and eventually located it on page 86 – not easy!].
5. The second page of my notification letter (which is not reproduced here) states, “The site was identified as a Preferred Site in the Main Issues Report or during its consultation….. All sites have undergone a site assessment process.  Our full assessment is set out in the Site Assessment Report, which we have published for consultation alongside the Proposed Plan”.  I have checked through the 3 part Site assessment reports and cannot find the assessments for Grantown on Spey H1 or T1 sites.  In particular, the proposed extension of the Caravan Site (T1 – see Fig 5) is onto land which forms part of the ecologically sensitive Mossie area, but there is no mention anywhere I can see of the need for ecological reports on flora and fauna.  As an aside it is sad to see the current state of the land proposed for the Caravan Site extension.  This has been used for several year now as a storage and dumping area by the operators, without any enforcement by Highland Council or CNPA.

 

Advice on reading and commenting on this consultation LDP

Despite these errors and omissions, or maybe because of them, it is important that community groups and individuals living and working in the CNPA, and other parties interested in the wellbeing of the Cairngorms National Park, take time to read and understand what is being presented in this draft local development plan, which will cover proposed developments over the next 5-10 years.  So far I have only read through a very small part of the consultation document and I have found numerous errors, omissions or unclear presentation of facts. What confidence can there be in the accuracy of rest of this weighty document?

Clarity is important so the meaning of the LDP is absolutely clear.   If you read the post last week on the Balavil road (see here), you will see how the CNPA planners have twisted the meaning policy 5.2 of the draft LDP – which creates a presumption against new roads – to support  a new one into a Wild Land Area.  It is these acts by planners (and there are numerous others) that bring the Local Development Plan and associated planning processes into disrepute. Plans should mean what they say.

I recommend that this consultation document and the supporting documents are closely scrutinised over the consultation period and that comments, concerns and support where applicable are sent to CNPA.  There is also the opportunity to participate in drop in events – see https://cairngorms.co.uk/consultation/proposed-plan/#events.