2 Nairn CC’s urge Nairn’s 4 local Councillors not to approve an ‘unfit for purpose’ Local Development Plan on Wed 1 Dec

On Wednesday 1 December – Nairn’s 4 Highland Councillors will be asked by Highland Council at the Nairnshire Local Area Committee to review and approve the ‘ Nairn section’ of a proposed new ‘Inner Moray Firth Local Development Plan’

See the Agenda here for Thursday 1 Dec Nairnshire Committee.

If Councillors ‘rubber stamp’ the IMFLDP2 for Nairn at this point, this ‘Local Plan’ could be set in stone for a decade by Highland Council in Spring 2022 after a final phase of public consultation.

There are also sections for Cawdor and Auldearn before the Nairnshire Committee for decision- but the wording of the ‘Nairn’ town section which our Highland Councillors are being asked to approve, is as follows

6.11 ‘ In Nairn, the recommendation is to support ongoing regeneration of the town centre
together with larger, strategic development which can deliver the necessary
infrastructure and become fully integrated with the town’s existing built fabric and
transport network. As such, we propose to allocate Nairn Town Centre for a flexible
range of uses and the eastern quarter of the former Showfield and Achareidh for
relatively small-scale housing. The strategic, longer term vision for Nairn includes land
at Granny Barbour Road to the east and Sandown to the west, the latter subject to
ongoing consideration of Common Good Land issues. Both sites are considered to
have the ability to provide the necessary levels of infrastructure to fully address the
impacts of development and integrate them within the town. Despite land at Nairn
South being in close proximity to key facilities, its reallocation is not supported as
significant transport related concerns remain including the ability of the network to
accommodate large scale growth and the deliverability of appropriate solutions.
Although Delnies has an extant planning permission (in principle), it is also not
recommended for reallocation due to it being detached from the town and concerns
over its deliverability’

Earlier in 2021 the draft part of the IMFLDP for Nairn, with priorities similar to above, was rejected by almost everyone from Nairn who submitted comments to the ‘Main Issues Report’ public consultation(Nairn comments linked here). This included the two community councils elected by the public to represent the town- Nairn River CC and Nairn West and Suburban CC.

The current final draft of this ‘new’ Local Development Plan, looks very much like the previous ‘old style’ one for the current decade, despite a completely new Scottish Planning Framework coming into force from 2022, with community led Local Place Planning at its heart.

Local community councils and others have pointed out that the proposed IMFLDP is not fit for purpose, because it does not include any commitments for Nairn over the coming decade, which address new Scottish Government planning priorities of Infrastructure First, a ‘green’ future, and town centre regeneration of existing buildings over out of town new build development.

All these things are needed to ‘future proof’ our town whose roads, drainage, sewerage and community facilities (including health and education) are already not coping with current demands and need serious investment.

The A96 through town is gridlocked, and we have the highest flood risk in Highland outside Inverness with no prevention measures yet on the table yet to protect vulnerable areas like Fishertown, Riverside, Balmakeith and Alton Burn.

The prospect of further ‘developer led’ intensive house building for Nairn before a new A96 bypass is in place(which could be 10 years away beyond the scope of this ‘new’ plan), is unthinkable, with a legacy of problems emerging at Lochloy where 1000 new homes were built on Highland Council’s watch, without delivery of the required infrastructure which a growing community needs (social rented housing, a school, and community facilities, proper access roads).

The two Nairn community councils have sent a joint letter to Nairn’s 4 Councillors in advance of the 1 Dec Nairnshire Committee, to make clear that Nairn’s community deserves better from the local development planning process, than what is currently on the table for IMFLDP2.

We asked that a Local community led Place Plan be developed as a priority to address Nairn’s pressing needs for Infrastructure First and a Green future. This Local Place Plan should inform any future Local Development Plan for the wider Inner Moray Firth area. Not the other way around, as it is clear that ‘top down’ and ‘developer led’ planning has not served Nairn well in the past.

The two Nairn CC’s have asked Councillors to consider their decision carefully on IMFLDP2, taking account of these concerns, and to show local leadership by standing up for Nairn communities.

Joint letter to Nairn Highland Councillors from 2 Nairn CCs

Date: 23 November 2021

To: Nairn Councillors:  T. Heggie, P. Saggers, L. Macdonald, L. Fraser

Dear Highland Councillors of Nairn and Cawdor Ward

INNER MORAY FIRTH LOCAL DEVELOPMENT PLAN 2

We understand that the Nairnshire Area Committee will consider and be asked to agree the latest recommendations for the IMFLDP – Nairn section – at its next meeting on 1 December, 2021.

Both Nairn Community Councils wish to reiterate our rejection of the ‘old style’ IMFLDP for Nairn as unfit for purpose and not in compliance with the ‘Infrastructure First – Green approach’. The Scottish Government intend the new planning system (National Planning Framework 4) to commence in June 2022 and work is already advanced in Nairn to develop and prepare a Local Place Plan, which should inform the Local Development Plan from the bottom up. Please reflect this in your decision making on 1 December to ensure that any new Local Development Plan adopted fully meets Nairn’s current needs.

The Nairn community is now suffering multiple infrastructure crises due to inadequate provision of roads, water supply, sewage, drainage/flood prevention, schools, doctors/dentists to name but a few.

Nairn is not receiving its fair share of Highland budgets, and this too is now biting hard into the provision of local services and amenities.

Many of these problems have accelerated into crises because of poor decision making by Highland Councillors and significant failures in cohesive local development planning.

For example, Lochloy has seen 1000 new homes built since 2000, accommodating over a quarter of Nairn’s population, and creating significant road congestion in and out of town, with only one access road and no school, no shop nor community facilities on the estate. New residents are experiencing problems with recent sewage overflow and pump failures, water supply and surface drainage issues.

The people of Nairn expect its Ward Councillors and Highland Council to:

• fully embrace and commit to delivering all the principles of the new Scottish planning system;
• comply with the spatial principles for Scotland 2045, contained within the NPF4, soon to be consented by Parliament i.e. Compact Growth, Balanced Development, Conserving and Recycling Assets, Urban and Rural Synergy, and Just Transition;
• proactively support the development of a Local Place Plan for Nairn; and
• commit to and deliver an Infrastructure First approach to all development planning prior to any further major development being considered for Nairn.

Lessons must be learned from Lochloy to prevent any further failures of development planning in Nairn.

We look to you as our Ward Councillors to show local leadership by standing up for Nairn and doing what is right for its residents.

Yours sincerely

Hamish Bain , Chair                                       Alastair Noble  , Vice Chair 

Nairn River Community Council                     Nairn West and Suburban Community Council

Additionally on Monday 29th November Nairn West and Suburban Community Council met and agreed to send an additional message to Highland Councillors prior to their important decision on 1 Dec on IMFLDP2. This calls into question the housing need projections for Nairn in IMFLDP2 which are based on a recently revised Highland wide Housing Needs and Demand Assessment(HNDA) – which has not yet been authorised or approved as ‘robust and credible’ by the appropriate national body.

Email from NWSCC to 4 Nairn Highland Councillors ( 30/11/21)

Dear Councillors,
At NWSCC meeting last night we discussed the housing figures in the proposed IMFDP which you are discussing tomorrow.
I have for three months been asking to see the HNDA on which the figures are normally based, and only today received the necessary papers from Scott Dalgarno after confirming with the director of the Centre for Housing Market Analysis that he had received a copy of HC HNDA and if it had been approved as Robust and Credible.
The answer which I got was that the HNDA draft version 1 was unacceptable, and a second draft had been submitted in October.  This has not yet achieved Robust and Credible certification and therefore reference in the IMFDP to housing figures ‘based on’ the HNDA are totally inappropriate, as the HNDA as of now has no standing.
As you may be aware the HNDA is supposed to be the first building block of a development plan, and the fact that Land allocations are being made without an approved HNDA in place means that the housing figures and land allocations in the plan are based on nothing but supposition and developer pressure.
For instance, the draft HNDA figures for 10 years housing in Nairn are 376.  Somehow in the IMFDP this figure has metamorphosed into 513 with no explanation whatsoever other than ‘policy adjustments’  What policy?  Where is it described?
The policy which is most important to Nairn at present is Infrastructure First, and the fact that you are being asked to approve land allocation for major developments which grossly exceed the housing need before there is any commitment to sort traffic congestion, water and sewage, flooding, schools, health services and environmental issues is totally inappropriate.
NWSCC asks that you take a step back and consider whether Nairn should be going down the route of a local place plan which would address these issues and take a holistic view of the next few years, not a developers charter as we clearly have in the IMFDP.
KInd regards, Joan Noble (on behalf of NWSCC)

See also recent coverage from Inverness Courier Nairnshire Edition of local community council concerns re the serious risks for Nairn of adopting a flawed Local Development Plan which could enable more ‘developer led planning’ to go ahead instead of prioritising ‘Infrastructure First’ and a ‘community led’ approach to local planning.