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LEGAL CHALLENGE - Dossier of information on Housing Policies in the Cairngorms National Park




Essentially, the Cairngorms Campaign and its partners have objected to the scale of housing developments within the Badenoch and Strathspey in particular on three basic grounds. One is the inadequate attention given to the environmental impacts of these developments, particularly in areas with endangered species. A second is that the policy results in large scale holiday home development and experience and research elsewhere, such as in the Alps, shows this to be an unsound tourism development policy leading to major social and environmental damage and poor economic benefit to local communities.


Criticism of and resistance to these policies has been widespread and come from a range of sources including both reporters to the Public Inquiry into the Draft Local Plan. More recently, public consultations on the Park Plan posed the question as to whether consultees supported the large scale of housing development within the Park or smaller scale. According to the report by Park Planners to the Park Board, over 85% of respondents opposed the large scale of housing development. The policy remained unchanged.



1. Criticisms Offered by the Reporters to the Public Inquiry into the Draft Local Plan

Both reporters were highly critical of the whole approach of the Park Authority to large scale housing development within the Park. Emphasis in bold is by the Cairngorms Campaign – but the text is as in the quoted source


Table 1 – Quotations from the

 Reporters’ Report on the Public

 Inquiry into the Deposit Local Plan





 “we can appreciate the disquiet of some objectors who suggest that  ...  too little emphasis has been placed on the first aim of the Park: To conserve and enhance the natural and cultural heritage of the area and rather too much emphasis on the promotion of the fourth: To promote sustainable economic and social development of the area’s communities.”

7.10 p.28  of Report by the reporters to the Public Inquiry into the CNPA Local Plan


“In particular, we can understand the concerns of those who can find no support for a policy approach which is directed towards:

• encouraging population growth in the Park rather than accommodating that which is projected;

• allocating substantial areas land for market house building in the expectation that this will ensure the provision of affordable homes for young people and the working population;

• encouraging a substantial increase in homes for commuters, retired persons or those purchasing second homes which will lie empty for considerable parts of the year.”

7.11 p.29   of Report by the reporters to the Public Inquiry into the CNPA Local Plan


 “Nowhere in successive versions of the CNPLP, or in the evidence brought to the inquiry, have we been provided with a convincing explanation of why the increase in the numbers of houses required to accommodate the projected increase in population should be uplifted at all, and certainly not by the considerable amount of 50%. Similarly, we are also not convinced that an allowance [15%] should be made for uncertainty in the projections.

7.19 p.31 of Report by the reporters to the Public Inquiry into the CNPA Local Plan


 “the 15% uplift, as well as the 50% noted above, appears to have been plucked out of the air”

7.19 p.32  of Report by the reporters to the Public Inquiry into the CNPA Local Plan


 “we conclude that the local plan should guard against the incorporation of policies and proposals which, whether by accident or design, give the impression that it is a document which runs contrary to the aims of the Park and the terms of the CNPP 2007 as the strategic expression of how these aims are to be achieved. Nowhere in the CNPP 2007 can we find a strategic objective which supports policies that encourage an allocation of housing land very considerably beyond that required to accommodate a population as reasonably projected on current trends.”

7.32 p. 35 28  of Report by the reporters to the Public Inquiry into the CNPA Local Plan


 “we see no justification for CNPA to follow slavishly the content of the approved structure plans or the adopted local plans as they affect the designated area. As we have noted above, designation under the National Parks (Scotland Act) 2007 sets the Cairngorms apart from the rest of Scotland and even national planning policy cannot always be directly applied.”

7.32 p. 35   of Report by the reporters to the Public Inquiry into the CNPA Local Plan


 “we conclude that that the rationale for the calculation of the housing requirement is unconvincing”

7.33 p.35   of Report by the reporters to the Public Inquiry into the CNPA Local Plan


 “we can find no basis for the 50% allowance for second homes and vacant property even if that is prefaced as an open market housing allowance. Further, bearing in mind the adoption of the upper household projection we also have considerable doubts about the applicability of the 15% flexibility allowance.”

7.33 p.35    of Report by the reporters to the Public Inquiry into the CNPA Local Plan


 “we are in no doubt that the overwhelming weight of evidence before us leads to a conclusion that the calculation of 1568 housing units as the housing land requirement to 2016 is a substantial over estimate. ... the housing land requirement is overly generous in any context, let alone that set by the aims of the National Park.

7.33 p.35   of Report by the reporters to the Public Inquiry into the CNPA Local Plan


 “the housing requirement as adopted by CNPA for its purposes and the housing land supply as inherited from the adopted local plans and allocated in the proposals maps may well be considerably more than is justifiable.”

7.34 p.36  of Report by the reporters to the Public Inquiry into the CNPA Local Plan


we recommend that paragraphs 5.35 to 5.40 should be deleted

from the Deposit Local Plan Modifications (1st and 2nd) along with Tables 2, 3, and 4. All of this material should be replaced with text and associated tables that explains the assessment of housing land requirements in the National Park and the housing land allocations to particular settlements, in a manner which complies with the

requirements of SPP 3: Planning for Homes, with the terms of the CNPP 2007, and which incorporates the most up to date information available to CNPA including the various housing land audits.”

Para 7.37 p. 38 of Report by the reporters to the Public Inquiry into the CNPA Local Plan

This from the reporters recommendations. Paragraphs 5.35 to 5.40 and Tables 2, 3, and 4 comprise the entire section in the CNPLP entitled “Housing Land Requirement and Supply” (p.41-43 CNPLP)





2. Lack of Justification for the Large

 Scale Housing Development with the

 National Park in the Light of

 Population Changes and Housing

 Provision within it.


The large growth in projected housing requirements, upon which the CNPA bases its planning, derives from future population projections prepared by the General Register Office for Scotland.  However, the GROS warns that its population projections for areas like National Parks “have limitations” and “are likely to be less reliable than those for larger areas”. The GROS says “The projected population increase is driven by net in-migration, which is assumed to be 200 per year”. This statement is found in sections 2 and 5, General Register Office for Scotland Population Projections and is qupted in the Background Evidence 1 to Main Issues Report for the CNPA Local Plan


This is quite an assumption on which to base such a major and controversial policy in a National Park, but also self–fulfilling –if you build lots of houses in the National Park, it is likely people will buy them for holiday homes or for commuters into Inverness. Badenoch and Strathspey is the chief focus of large scale housing development in the National Park and the main area of dispute between the CNPA and objectors. Analysis of the statistics on population changes in either official census reports and/or Highland Council Housing Completion tables show there is a long history of overprovision of houses in this area. The full tables are in Appendix 1 but the figures show that:-


1. That population growth in Bad.&Strath. (6.86%) was the highest of any district in Highland (similar to Inverness, 6.82%) and probably, (not checked) the highest of any rural district in Scotland. (24b Census summary Highland)


2. The increase in population in Bad.&Strath 1981 to 1991 was 1145, from 9863 to 11,008. During approximately the same period (1981-1991 inc.) housing completions  totalled 1208, showing that 1.06 houses were built for every increase in population of one person.


3.  The increase in population in Bad.&Strath 1991 to 2001 was 755, from 11,008 to 11,763. During approximately the same period (1991-2000 inc.) housing completions totalled 867, showing that 1.15 houses were built for every increase in population of one person.


4. Unfortunately, the 2011 census results for Scotland are not yet available, but the above trends appear to be continuing, with 1041 houses built in the period 2001-2010 inc.).


5. The total population of Scotland in 2001 was 5,062,011, and the total number of households was 2,192,246, giving an average occupancy rate of 2.31 persons per household.


6. The increase in population of Bad. & Strath. of 1900 (1145+755) persons, had they been accommodated at the average Scottish rate of 2.31 persons per household, would have required 822 houses to be built. Instead, 2075 (1208 + 867) houses were built, 1253 more than would have been required for that purpose.


7. Thus there is a long history of building not only more houses than are required by the local population, but more houses than are required even when taking inmigration into account.


Although the above figures are taken from either official census reports or Highland Council Housing Completion tables, the figures should be regarded as approximate, as slight changes in the figures do occur. However, such changes are slight and do not at all alter the overall conclusions arrived at above. If the policy did result in adequate provision of affordable housing to local people this might be justifiable, but all the evidence is that it does not. Figures from Highland Council for example show a fall in number of people on the housing list of less than 2% over the period of application of this policy even prior to the existence of the National Park. More recently, at a local meeting with Park Planners, representatives of environmental groups asked what evidence had been gathered or existed that the policy actually gave less well off people and/or local residents access to housing. The planners admitted they had no such evidence. As an interesting specific example, eight “affordable” houses built in Boat of Garten have been sold – only two to local families and one of these was bought for renting by a family that makes income this was.



3. The Park Authority’s Housing

 Policies in Relation to the Relative

 Importance of the Four Aims of the

 National Park – Development versus

 Environmental Protection


The significance of the Park Authority’s statements on this are unclear.


The latest Scottish Government planning advice, namely Scottish Planning Policy (SPP), published February 2010, para.138 states: "In circumstances where conflict between the [National Park] objectives arises and cannot be resolved, the 2000 Act requires that the conservation of the natural and cultural heritage should take precedence."  This is the Scottish equivalent of the Sandford Principle.


The Draft National Park Plan, on page 10 Under “National Park principles” and headed “Our Environment” states,

“The conservation and enhancement of the environment is central to National Parks. This underpins delivery of all four aims and is integral to sustainable development approaches.”


But page 9 under “The Aims of the National Park” states,

“The principle of giving greater weight to conserving and enhancing the natural and cultural heritage where there is a conflict between the aims should not be seen as a last resort, or drawn upon only in extreme cases. Nor, on the other hand, should it be seen as a starting point which gives ‘priority’ to one aim. Instead it is integral to the way that both National Park Authorities

make ongoing decisions about management. It offers a way of reducing or removing conflict in order to reach a point through which all four aims can be delivered.”


It is utterly unclear as to what this last means, particularly in reference to the previous two statements.


4. The Park Authority’s Housing Policies in the Light of International Experience and Research on Sustainable Tourism Development.


Globally, tourism has been shown to have an inherent strong tendency to ovedevelop and damage the very environmental resources of landscape, wildlife etc on which it is based. Are parallel scenes now gradually unfolding in Badenoch and Strathspey in the Cairngorms National Park?  Are such insights being applied? These important international findings have major implications for any strategy on tourism development and hence, in this case also for housing policy in Badenoch and Strathspey and clear warnings that this is so have long been cited.


In 1980, Getz (16) completed a three-year study of tourism development there. He concluded that, to date, the benefits brought by tourism and related developments outweighed the problems and costs created. Getz, reporting his conclusions in the Scottish Geographic Magazine, warned, “Promotion of new developments in tourism and increased demand cannot be justified on the basis of benefits to the host population in Badenoch and Strathspey unless concrete measures are taken to disperse demand more widely. The continuing concentration of growth and visitors at and near Aviemore will have adverse ecological and social effects on that central portion of the district while depriving peripheral settlements of potentially life giving all-year jobs.”  But Aviemore Highland Resort has now received planning permission for the second phase of its development plans - a massive £80 million mixed use development comprising residential, retail, office, community, leisure and environmental improvements, roads, additional lodges and hotel extensions to create a new village centre including 60,000 sq feet of retail space, 40,000 sq feet of office space, 280 homes and a seven story block of holiday apartments. 


In contrast, at the same time as Getz completed his work, the situation caught the attention of Fritz Schwarzenbach, then a leading expert on Alpine development. He and others regarded Aviemore then as having international significance as a classical example of bad tourist development. In 1983, Watson and Watson (17), considering the implications of their study tour of Swiss Alpine Tourism Development for Scotland, drew attention to how Alpine research showed how over-development of tourism damages communities. Once, for example, the number of tourist beds exceeds the number of resident beds by about 2:1, local people find themselves permanent strangers in their own community and community identity and cohesion erodes. Aviemore passed that ratio in the early 1980s!


Recent studies on the hard versus soft tourism discussion have included Badenoch and Strathspey. (18) Here, hard tourism is overwhelmingly dominant, due to the development of Aviemore. Daily spending by tourists accommodated in “hard tourism” development, it was found, is about twice that by those in “soft tourism” accommodation, but against that, operators of soft tourism “purchase less than a quarter of their inputs from outside the regional economy in both study areas, whereas this figure is much higher for hard tourist businesses.”  Partly due to this, soft tourism makes up for the difference in spend as it generates more jobs per unit of spend. Even more importantly, it is also known that quite small increases in local spend greatly stimulate the local economy. To this also can be added the profits of hard tourism go largely to distant shareholders and the control of decisions on development passes to the, usually distant, management of the large companies. Commenting on this hard tourism the authors say, “This industry was not the product of endogenous enterprise, and has been nurtured and developed by significant public sector investment, effectively creating an externally owned, enclave economy associated with tourism.” The issue of economy versus dependency comes in clearly.


The development of the global market for tourism has now placed strong pressures on the older mountain resorts in the Alps in an era of raised environmental awareness, forcing them strongly to rethink their values and address environmental and community issues.  Recent publications[1] describe initiatives like the “Green Villages in Austria.” Tourism, as Watson and Watson (17) found, is an industry of fashions and these change. Alpine experience shows that resorts that retain a strong traditional sense of place and amenity, like Grantown-on-Spey, are positioned to move on to a new tourism, but those that have developed, like the architecturally incoherent, concreted Aviemore, have great problems.


Housing development locally, is mainly large-scale development, mainly for holiday homes, and hence as pointed out, is de facto a hard tourism development strategy largely in the hands of large developers. Krippendorf held that sustainable communities should be characterised by small-scale developments, in harmony with sensitive, rural environments. This has been supported by other Alpine researchers, who have found that, where development takes place through small-scale local builders, these firms can then sustain themselves through work on maintenance and improvement of established properties. In contrast, large-scale developers must constantly seek new developments and create a continuous pressure for development.


This issue is now pressing in Badenoch and Strathspey. Local builders have opposed plans by Muir Homes to build 193 houses at Grantown on Spey. 30 building firms are reported as objecting to the Local Plan, as they fear major builders will monopolise housebuilding. A spokesman for the objectors is quoted  “Without a supply of small building sites to sustain local builders, their firms will undoubtedly falter and in some cases may fail”. (Strathspey and Badenoch Herald January 2 2009) The local community at Boat of Garten has opposed another large development there, and large-scale developers have already bought up much of the land allocated for housing around communities like Kingussie. A recent, web-based poll by The Strathspey and Badenoch Herald produced an 80% vote against large housing developments in the area.


It is clear that the fundamental issues raised by tourism researchers in the Alps and elsewhere have relevance to the situation in Badenoch and Strathspey and indeed to the entire Cairngorms National Park. The development of the global market for tourism has now placed strong pressures on the older mountain resorts in the Alps in an era of raised environmental awareness, forcing them strongly to rethink their values and address environmental and community issues. 


Recent publications describe initiatives like the “Green Villages in Austria.” (19) support the findings described earlier.  It might be possible for the Cairngorms National Park Authority to consider these carefully and yet derive the same tourism policy and inextricably linked housing policy in its Local Plan, though it would be difficult to see how. What is not possible is to arrive at such policies without careful consideration of these issues and no such consideration has been evident either in the Authority’s Sustainable Tourism report, not in preparation of its Local Plan.


On these grounds, the Cairngorms Campaign urged that the current housing and tourism development and housing policies were rejected and reconsidered in the light of our understanding of the principles of sustainable tourism development.


The housing development policy has negative impacts at the local level. The housing development we have sited is concentrated in the Straths around the main settlements, particularly in the district of Badenoch and Strathspey. In the straths lie the great majority of the broadleaved woodland of the Cairngorms, the bulk of its ancient pinewoods, and open grasslands, often in close proximity to these settlements. The recent work of the Badenoch and Strathspey Conservation Group and Buglife has demonstrated the underestimated richness of the biodiversity of these areas. Many of these areas around settlements are now coming under pressure for a series of large scale and smaller housing development proposals that in Badenoch and Strathspey, in-toto, are having a major impact on this varied and highly valued environment. 


The built environment of the Straths includes classical examples of planned villages like Grantown-on-Spey and Ballater, a distinctly Scottish cultural feature where the design of settlements encompassed a sense of architectural and social cohesion, a sense of place, often centred on communal features like central public squares and parks. Aviemore, in contrast, entirely lacks these features and seems to exemplar an architectural and communal incoherence.


The environment of the Straths is significant for more than its high biodiversity. Despite the emphasis in much tourism marketing literature for example on the high mountain areas, it is the environment of the Straths which the visiting tourist chiefly experiences. It is also the environment that daily surrounds local residents and provides them with a diversity of open accessible green spaces, various forest and woodland areas, waterways, lochans and other natural and semi natural features. Such an environment has an enormous experiential value for people as well as for biodiversity and science. Increasingly, studies are showing the close relationship between human wellbeing, as opposed to just health, and peoples’ exposure to a diverse green environment. It is particularly important that children growing up locally have access to this rich range of recreational opportunities and direct experiences of the natural world that enhances their development and lives enormously. It is instructive to contrast the diversity of such opportunities for such experiences facing small children growing up of children growing up in these traditional planned villages like Kingussie or Grantown on Spey as they stand with those slowly being increasingly inaccessible to children growing up in sprawling, rapidly expanding Aviemore. !  These assets should therefore be carefully protected for sound social and economic reasons but large-scale housing development around such settlements damage their sense of place and community and reduce access to these assets.


This is yet another reason to reject the Tourism/Housing Policies in the Local Plan envisaging large scale housing development around such communities largely to provide holiday homes.




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