Park and ride, EV charging and a hotel at Tore: NPF4 policy 13 in practice.

What the reporter decided

The reporter identified three issues: whether this was an appropriate location for the uses proposed, whether the development would be compatible with the principles of local living, and whether there was sufficient infrastructure (paragraph 2). The development plan comprised NPF4, the Highland-wide Local Development Plan 2012, the Inner Moray Firth Local Development Plan 2 (2024) and adopted supplementary guidance (paragraph 1).

Local Development Plan 2 describes Tore as strategically placed for employment and the road network, but notes that it has few jobs, that its roads inhibit active travel, and that only very limited infill development should be promoted there (paragraph 5). Against that background, the reporter concluded that, although some elements of the scheme accorded with the plan and offered local benefits, the proposal as a whole did not (paragraphs 22 and 37).

The mobility hub and policy 13(a)

NPF4 policy 13(a) supports proposals that improve, enhance or provide active travel infrastructure, public transport infrastructure or multi-modal hubs, including electric vehicle charging infrastructure and forecourts (paragraph 7). Local Development Plan 2 also supports mini park and ride sites on strategic routes and charging infrastructure at key destinations, although its transport strategy map is indicative and does not identify Tore specifically (paragraphs 8 to 10).

The reporter also took into account a 2023 study of bus improvement options around Inverness. It is not part of the development plan and was given limited weight, but it had been publicly consulted on and concluded that a transport hub around Tore would be the most effective of five options at reducing bus journey times and private traffic entering the city (paragraph 10). The principle of a public transport hub and charging at Tore was found to accord with NPF4 policies 1, 2 and 13(a), and with Local Development Plan 2 policies 9 and 14 (paragraph 11).

Employment uses and sustainable travel

Local Development Plan 2 policy 7 supports industrial development on unallocated sites if, among other things, the location supports sustainable travel. As the later policy, it took precedence over the more restrictive NPF4 policy 26 (paragraphs 12 and 13).

The reporter found that the location did not currently support sustainable travel. The nearest bus stops were 200 metres away on the A9, with no adequate pedestrian connection to the site. The site could be made more sustainable, but only if the charging hub and park and ride came forward early and traffic management on the surrounding A roads allowed people to reach it on foot and by wheel (paragraph 14). The employment uses ultimately failed on other limbs of the policy: the potential effects on nearby homes, some within 30 metres, could not be properly assessed without knowing the end users, and the ecological evidence was out of date, with no Habitats Regulations Appraisal (paragraphs 15 to 18).

The hotel and policy 13(d)

The small retail and food and drink units were treated as likely to be ancillary to the hub. The hotel was not. At around 61 bedrooms, it would become a destination in its own right, and guests, particularly those heading north, could readily use it as a stop-over before travelling on by car. Encouraging that would be contrary to NPF4 policy 13(d), which does not support significant travel generating uses in locations that would increase reliance on the private car (paragraphs 7 and 20).

No competent sequential or impact assessment had been provided under NPF4 policy 27 and Local Development Plan 2 policy 6, and the site was not a town centre location (paragraph 21). The reporter concluded that the site was unlikely to be a sustainable location for a hotel, even as a later phase (paragraph 22).

Local living at the roundabout

The reporter's description of the existing pedestrian environment is direct. There are no signalised crossings on any arm of the roundabout, and no crossing point on the A9 arm to the south east. Moving between the bus stops on that section of the A9 requires walking around the whole roundabout and crossing four A roads. Traffic is continuous, the environment is hostile, and the reporter noted that a 2021 study for Transport Scotland described pedestrians having to run to cross the A9 (paragraphs 23 and 24).

The scheme proposed two additional crossings, on the A835 and the A832. The reporter accepted these would offer some improvement to north and south permeability, and would also benefit National Cycle Route 1. However, the A835 crossing was likely to be hazardous until a planned 40mph limit was introduced, and the A832 crossing remained at 60mph. Their effectiveness depended on Transport Scotland's improvement scheme for the roundabout, which includes signalisation and lower speed limits but has no agreed timescale, and over which neither the appellant nor the council has control (paragraphs 23, 25, 26 and 28).

The decision refers to the local living policy as NPF4 policy 20. Local living and 20-minute neighbourhoods is policy 15 of NPF4, and the reasoning is plainly directed at that policy. Nothing in the outcome appears to turn on the reference.

Points of interest and doubt

The decision recognises a genuine tension. A park and ride serving Inverness is most effective where the trunk roads converge, and Tore was identified by the 2023 study as the best of the options considered. Yet the same roads make the location hostile to walking, wheeling and cycling, and the plan treats Tore as unsuitable for growth. The reporter's approach was to accept the transport infrastructure on its merits while declining to treat it as justification for the other uses packaged with it.

A promoter might reasonably say that the commercial uses were needed to fund the hub, and that refusing the scheme as a whole loses the infrastructure the reporter found to be supported. The decision does not address viability or cross-subsidy, and on the evidence before the reporter there was no basis to do so. It also leaves open whether a smaller proposal, centred on the hub with genuinely ancillary uses, would succeed.

Finally, the reliance on Transport Scotland's roundabout scheme is significant. Where the acceptability of a site depends on improvements to the trunk road network with no committed programme, a reporter is unlikely to assume they will happen. Contributions towards transport improvements were offered, but the reporter considered that they could not overcome conflicts with the plan of a fundamental kind (paragraph 34).

Practical points

• Test each use against policy 13 separately. Infrastructure supported by 13(a) does not carry significant travel generating uses that 13(d) would not support.
• Show genuinely ancillary uses as ancillary. The small retail and food and drink units were accepted on that basis; the hotel was not.
• Address local living on the ground. Crossing points, speed limits and routes to bus stops were central. Proposed crossings on high-speed roads need to be safe in the conditions that will exist when they open.
• Do not rely on uncommitted trunk road schemes. If the scheme depends on Transport Scotland works without a programme, set out how it would function without them, or how delivery would be secured.
• Use supporting studies, but understand their weight. The 2023 bus study helped establish the case for a hub, but it was not part of the development plan and carried limited weight.
• At permission in principle stage, provide enough to judge the effects. Unknown end users, out-of-date ecology and no Habitats Regulations Appraisal all counted against the scheme.