Letter to Peter Marshall, Brenda Murray & Robert Wills of the Planning Department at Perth & Kinross Council
Dear Colleagues
Proposed LDP2 Supplementary Guidance on Landscape
I refer to your email of 19 August 2019 regarding the start of consultation on the above, with comments required by 30 September 2019. In the briefing note attached you state that, considering the short timeframe since adoption of guidance in 2015 on the application of Policy 37, a full review of Local Landscape Areas is not considered to be required. I wish to challenge strongly this view, which does not take account of my previous representations made and which I am enclosing for referral.
I made clear in my email of 6 August 2019 on the LDP2 Examination Report that I maintain strong objection to LDP2 not containing a provision to review Local Landscape Area designations and their need for protection from inappropriate development. I also stated this in my letter to Murray Lyle, Leader of the Minority Administration at Perth & Kinross Council, on Regional Parks in Scotland of June 2019.
I would, however, be content for this issue to be addressed under Supplementary Guidance, rather than at debate on LDP2 at Full Council on the 25 September 2019, if Perth & Kinross planning would commit to addressing the local landscape designations for Kinross-shire that are the subject of my representations to date.
By way of brief summary on this matter I would ask you to note the following from the representations enclosed.
- The Kinross Area Local Plan 2004 included extensions to the AGLV’s to the shire’s hill and river borders after a hard-fought community campaign.
- Between 2009 and Spring 2014, a period of five years, no progress was made in addressing the issue of the loss of AGLV’s and their replacement by Local Landscape Areas by Perth & Kinross Council and I sought participation in the Review Panel then.
- Despite strong representation in 2014 from myself, Cleish and Fossoway Community Councils within the Review Panel, the consultants excluded from designation the former AGLV’s of Cleish Hills and Devon Gorge, despite strong evidence that they met most of the evaluation criteria for designation.
- I remained highly critical of the consultant’s exercise in February 2016, especially ignoring cross-boundary designations.
- Since March 2015, local members have been repeatedly blocked from getting a review of this flawed exercise and righting a clear wrong decision!
- Between July 2017 and February 2018 I maintained objections to LDP2 if no review of landscape designations took place, also citing previous requests for the Ochil Hills to be considered for Regional Park status and to look at extending the Lomond Hills Park to Lochleven; this latter issue being mirrored by the draft Review enclosed in my letter to Murray Lyle of June 2019 afore-mentioned.
- The need for Local Landscape Areas to be protected against inappropriate development does not seem to have been addressed by the Reporters Examinations of July 2019, which is very concerning when I had highlighted in August 2017 that the loss of the former AGLV’s of Cleish Hills and Devon Gorge from landscape designation suddenly resulted in them featuring as areas with highest capacity for windfarm development in Map 6.1 of Renewable Energy Supplementary Guidance. I was alarmed by this prospect and maintain the strongest objection to it.
I would ask why is it necessary to review all local landscape designations if the only requests for a review relate to the exclusion of the former AGLV’s referred to? Why also, do we need to use consultants for such an exercise, when we have expertise within Perth & Kinross Council on these issues? I believe the case has been made for the Cleish Hills and Devon Gorge to be re-assessed and for the Regional Park issues afore-mentioned to be looked at within the Supplementary Guidance you are consulting on and I formally request that you do so. Clarity on your position before 25 September 2019 would be helpful.
I remain
Yours sincerely
Cllr Michael Barnacle
Independent Member for Kinross-shire
Previous Background Correspondence
Spring 2014 Article on Landscape Designation – The Kinross-shire Experience
19 January 2015 Letter to Graham Esson re Draft Supplementary Guidance on Special Landscape Areas
23 March 2015 Letter/Email to members of Enterprise and Infrastructure Committee on Landscape Guidance
11 February 2016 Letter to Cleish and Fossoway Community Councils and Kinross Civic Trust re Supplementary Guidance for LDP1 and emerging LDP2 on Landscape
14 July 2017 Letter to Peter Marshall and Brenda Murray on LDP2 (re ER6 Landscape Designations)
31 August 2017 Letter to Peter Marshall and Brenda Murray re Renewable and Low Carbon Energy Supplementary Guidance
31 August 2017 Letter to Peter Marshall and Brenda Murray re LDP2 (re ER6 Landscape Designations)
2 February 2018 Letter to Brenda Murray and Peter Marshall re Proposed LDP2 (re Policy 31D and 37 on Spatial Framework for Wind Energy and Landscape)
21 February 2018 Email to Peter Marshall re Consultant’s study and need for review of Local Landscape Designations
18 February 2019 Email to Scottish Government Reporters Unit re background correspondence to Perth & Kinross Council LDP2 Representations forwarded to them re Policy 31D on Local Landscape Areas (Issue 14)
13 June 2019 Letter to Councillor Murray Lyle on Regional Parks in Scotland to which I have not received a response
6 August 2019 Email to Brenda Murray re LDP2 Examination Report Highlights (re Issue 14 A Low Carbon Place)
Email Circulation: Councillor Murray Lyle, Councillor Xander McDade, Councillor Callum Purves, Councillor Willie Robertson, Councillor Colin Stewart, Councillor Richard Watters
Email CC:
Kinross Civic Trust, Friends of the Ochils, John Mayhew APRS, Roseanna Cunningham MSP, Luke Graham MP, Cleish Community Council, Fossoway Community Council, Glenfarg Community Council, Kinross Community Council, Milnathort Community Council, Portmoak Community Council