SWLG Home Action Wild Land News About us

Response to Cairngorms National Park Draft Local Plan, March 2006

Cairngorms National Park Authority are developing a new Local Plan.

Response to Cairngorms National Park Draft Local Plan

We have some significant concerns about aspects of the Plan and our comments have been concentrated on these concerns, rather than looking in detail at every policy statement.

Concern 1 Landscape not prominent enough

The importance of landscape to the Park area is not recognised sufficiently. In some ways it is the very raison d'etre of the Park, along with the habitats, flora and fauna. The landscape and associated wildlife has brought the various Designations to this area. Landscape should be placed as Policy No. 1 and given a key prominence on judging development opportunities, elements of this policy and other CNP policies.

We would seek greater prominence and protection for the NSA areas within the CNP area, and not just to look at all land over 400 metres as being the same.

In conjunction with the above point, there is insufficient focus and attention on wild land, in terms of its qualities arising from its relatively untrammelled nature, its remoteness, and its giving of experiences to users of the locality. These wild land qualities could be diluted, or even lost through inappropriate or intrusive development or failure to control man-made processes operating within the CNP area.

It is often taken for granted that wild land, grand views, exciting tourist experiences will always be there, be available 'for free' in effect. This is not the case - such intangibles can be enhanced or degraded or protected or neglected - a whole range of options. We, and we hope, you, would wish to promote the positives yet we feel this is not sufficiently set out in the draft Plan

Upland vehicle tracks are a great worry and we feel there should be a strong statement that all new or upgraded track proposals would be refused for areas covered by your GP3 designation. We believe there should be no ability to have permission granted where the landowner/operator deems the track to be essential, as such a statement is an invitation to the said applicant to ensure that the application will be described as essential.

Vehicle tracks have a long-lived adverse impact on the landscape and past tracks can often only restored at enormous amounts of effort and cost.

There are a number of Policy statements which are much too vague, and give the impression that proposals will be permitted if they contribute something vague to the Area. Examples of this vagueness are in Policy 3 where if biodiversity is increased then the proposal will be more likely to be approved. Does this mean a housing development with a pond in a remote corner of the site ?

Another example is that of Policy 26 where if a farm proposal improves diversification then it could be approved easily. These general statements should be omitted or replaced with very specific requirements and linked to controls from other aspects of the Local Plan.

These generalistic type exemptions should not be allowed in an area recognised as of outstanding national worth.

We have to admit to being disappointed by the modest approach of the draft Local Plan, and the failure to put landscape, wild land and the protection of core values at its heart. Whilst the CNP Area is a dynamic, evolving locality, the key elements that have given rise to the National Park designation need to be protected and enhanced. The Plan needs to do this with more vigour, decisiveness and robustness.

Whilst we recognise the need for flexibility in many of the lower and settled parts of the CNP area, there is a lack of definitive precision in stating what will be preserved from intrusion and development, in the core wilder and remoter areas.

At root, landscape needs to be at the heart of the plan and we feel it is not, at present.

Yours Sincerely

Alistair Cant
CO-ORDINATOR
Scottish Wild Land Group
Alistair Cant
2 March 2006