Additional letter of objection sent to the CNPA over ACM Monday 7 June 2010:

Badenoch & Strathspey Conservation Group

Fiodhag, Nethybridge, Inverness-shire PH25 3DJ Tel 01479 821491

Scottish Charity No. SC003846

Don McKee
CNPA
Station Square
Ballater

6.6.10

Dear Don

An Camas Mor - application for a new settlement of up to 1500 houses and associated infrastructure 09/155/CP

I am writing on behalf of BSCG to *object* to the above application for a new settlement of up to 1500 houses and business and other development at An Camas Mor. This objection is in addition to BSCG’s earlier letter submitted on 19.5.10, and relates to the lack of an established need for ACM, and the democratic deficit of determining this application before the public consultation process has been completed and the Local Plan process has run its course.

The CNPA will appreciate that the Reporters for the Local Plan Inquiry gave careful consideration to a range of concerns relating to ACM (see: at www.cairngorms.co.uk/resource/docs/publications/17122009/
CNPA.Paper.1466.Local%20Plan%20Inquiry%20Report.pdf
). The Reporters findings include the advice that “/As a result of all of this, a reevaluation of the An Camas Mòr proposal is justified and over reliance on policy history is not appropriate/.” ( see 42.37 ‘Conclusions’). The degree to which the CNPA has failed to undertake any meaningful reevaluation of the ACM project is a serious concern to BSCG.

BSCG is strongly of the view that determination of the above application should be delayed until the Local Plan process for the CNPA’s emerging Local Plan has run its course. There is an ongoing public consultation underway at the moment that does not end until early July, and after that there may or may not be a second Public Inquiry, before the emerging Local Plan can be adopted.

These are important and integral stages of the public consultation for, and public engagement with the CNPA’s first, emerging Local Plan.

If the CNPA determine this application now, this democratic consultation process becomes irrelevant and is effectively stopped dead in its tracks. The CNPA would be determining an application for which there has been no effective public consultation process in terms of including the allocation in their own emerging LP. Instead the CNPA would be relying not only on a LP that was adopted in 1997, but for which the public consultation took place in 1991 and 1992. Moreover this LP has been described by HC Councillors and planning staff as out of date, and in terms of Cambusmore, it provides an allocation for a substantially smaller number of houses than the 1500 being now applied for.

The CNPA are not including any houses for ACM within the emerging Local Plan.

According to the CNPA planners (pers com Karen Major 3.6.10) the emerging LP is due to run for only 3 years from 2011-2013 inclusive.

Over the past 33 years, from 1976-2008 inclusive, there have been 3364 houses completed in Badenoch & Strathspey according to Highland Council figures (of which the vast majority are obviously within the NP). Prior to the establishment of the NP the average number of houses completed each year was 96. From 2004-2008 (the most recent records available) the average number of completions is 134 houses/year.

Based on this information, which reflects the real housing market, it would be realistic to anticipate that the average rate of house building will be in the region of 96 - 134 houses/year in B&S over the lifetime of the emerging LP.

The CNPA has allocated 695 houses for the 3 year period (2011-2013 inclusive) of the emerging LP. This amounts to 232 houses each year, which is about double what can realistically be expected to be built.

In the past 33 years there has never been more than 211 houses built in one year, and there have only been 2 years (1989 and 2006) when the number of houses built has exceeded 200. Therefore it is completely unrealistic to suggest that 695 houses may be built during this LP.

If 134 is taken as a realistic figure, then 402 houses would be built during this LP, leaving almost 300 houses to be carried forward to the next Local Development Plan.

In addition to these approx 300 houses, a further 389 houses already have planning permission (outline or detailed permission, at sites such as Kingussie, Aviemore etc) which have not been included in the emerging LP. And over and above these two figures, there is a further 195 houses already allocated but which do not have planning permission. None of these figures include any building in ACM.

Therefore the CNPA has nearly 900 houses allocated, of which well over a third already have planning consent, over and above what is realistic to allocate for the emerging LP. 900 houses equates to about 7-8 years worth of house building, which is enough houses to see us through the first Local Development Plan (2014-2018) and half way through the *second* Local Development Plan (2019-2023).

This is without any building on ACM whatsoever.

It is worth noting that an average of 134 houses built/year is far higher than the building rate of any other rural part of Highland, and is higher than any other part of Highland at all except for Inverness South (from 2000 – 2008 inclusive). Inverness South is an urban area outwith a NP, and an area that has seen exceptional growth over the past 9 years compared to anywhere else in Highland.

In general, the CNPA will probably achieve 25%-40% affordable housing with 75%-60% open market housing. There is no credible suggestion that ACM is going to provide a higher level of affordable housing than any other development.

It is a common fallacy that by building more houses we will reduce the waiting list for affordable housing. In line with this, there may be a perception that building ACM, which will include an affordable percentage, will reduce the housing waiting list.

However, the effect on affordable housing requirement as a result of growing the population of the NP through the addition of some 1500 houses will be to expand the waiting list, not reduce it. There will be more people living in the Park meaning, over time, more local people entering the housing market for the first time, and more elderly people requiring social housing too – two significant groups of people requiring affordable housing.

Therefore, far from reducing the demand for affordable housing, building more houses simply fuels an increased demand.

It should also be noted that houses are allocated on a points basis, and it is a relatively small number of points that are gained by requesting a house in your own area. Therefore, as has already been experienced by communities in Badenoch & Strathspey, local people may not be allocated the affordable houses that are built in their community.

In view of the above points and given considerations of natural justice, BSCG is very concerned that the CNPA should not undermine its own Local Plan process by determining the biggest application it will almost certainly ever decide on, based on a grossly out of date Local Plan for which many people now around had no opportunity to consult on, and for which there is demonstrably no need for many years to come and several Local Plans hence. Instead the determination should be delayed to allow the CNPA’s own Local Plan, including the public consultation, to be completed in the proper fashion.

Best wishes

Gus Jones

(Convener)

CC J Whittle (R & R Urquhart)

A recent photo of the slender groundhopper /Tetrix subulata/ at its newly discovered Scottish stronghold on lowland heath at the threatened An Camas Mòr site in Strathspey.  BSCG is grateful to Buglife (the Invertebrate Conservation Trust ) and the UK Orthopteran recording scheme  for assistance with identification of this find.  So far this year this species has only been recorded on the ACM site in Strathspey but the first find was at Boat of Garten in 2008 and finds now considered to be this species have also been made since then at the Mossie Grantown -on-Spey and at the threatened School Wood site in Nethybridge.

slender groundhopper - tetrix subulata 20100607 1995833942

Copyright 2010 BSCG, may be used for reporting purposes with copyright credited.

See more at An Camas Mòr gallery.

BSCG has advised the CNPA today  (18 May) that the blaeberry bee  has now been photographed at School Wood a site threatened by development in Nethybridge. Despite recommendations by Scottish Government Reporters School Wood controversially remains allocated for housing in the Cairngorms National Park Local Plan.
 
 
Caption blaeberry  bee  /Bombus monticola/ (credit BSCG)

BSCG has advised the CNPA today  (18 May) that the blaeberry bee  has now been photographed at School Wood a site threatened by development in Nethybridge. Despite recommendations by Scottish Government Reporters School Wood controversially remains allocated for housing in the Cairngorms National Park Local Plan.

 bombus monticola 20100518 1191861422

Blaeberry  bee / Bombus monticola © BSCG

green tiger beetle - cicindela campestris 20100609 1871364749

© 2010 BSCG Gus Jones BSCG

Green tiger beetle Cicindela campestris on An Camas Mòr site. This attractive beetle is exceptionally  common on parts of this site that is threatened by major housing development. Some 120 species of beetle including 3 nationally scarce species  were reported from  a survey undertaken in early June and late July 2008 at this  threatened  site that it can be safely assumed  supports even greater invertebrate biodiversity than has so far been recorded. Tiger beetle is an apt name for this predatory beetle, the only member of its family known form the north of  the UK. BSCG has recorded tiger beetles  at other sites threatened by controversial development including at Carrbridge  and Nethybridge.


bill mcdermott 20100510 1475250691

At our Residency Criteria in National Parks talk today Bill McDermott, Chairman of Scottish Campaign for National Parks who worked for many years in the Peak District National Park as an Assistant National Park Officer, said "Despite what Danny Alexander MP was apparently told by the National Park staff, there is no legal reason why the CNPA could not adopt residency criteria. These would restrict availability of new build houses to people living within the National Park or with certain connections to it. Residency criteria would stop the present excessive development that is currently  destroying the natural and culteral heritage of the National Park."
 
 
Residency criteria are successfully  established on the east side of Loch Lomond and English and Welsh national parks.
At our Residency Criteria in National Parks talk today Bill McDermott, Chairman of Scottish Campaign for National Parks who worked for many years in the Peak District National Park as an Assistant National Park Officer, said "Despite what Danny Alexander MP was apparently told by the National Park staff, there is no legal reason why the CNPA could not adopt residency criteria. These would restrict availability of new build houses to people living within the National Park or with certain connections to it. Residency criteria would stop the present excessive development that is currently  destroying the natural and cultural heritage of the National Park."

Residency criteria are successfully  established on the east side of Loch Lomond and English and Welsh national parks.

black grouse male blackcock -tetrao tetrix 20100510 1024626892

Black grouse male (blackcock) - Tetrao tetrix. Photo: Gus Jones BSCG

BSCG are concerned that development proposals at An Camas Mor would destroy habitat for this magnificent woodland grouse.

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