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Agenda Document Pack - Economic Development and Infrastructure Services Committee - 11/11/2025

Moray Council · 11 November 2025
Back to Economic Development and Infrastructure Services Committee — 11 November 2025 and its agenda

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Economic Development and Infrastructure Services
Committee 
Tuesday, 11 November 2025 
NOTICE IS HEREBY GIVEN that a Meeting of the Economic Development and
Infrastructure Services Committee is to be held at Council Chambers, Council
Office, High Street, Elgin, IV30 1BX on Tuesday, 11 November 2025 at 09:30. 
BUSINESS 
1. Sederunt 
2. Declaration of Group Decisions and Members Interests * 
3. Resolution
Consider, and if so decide, adopt the following resolution:
"That under Section 50A (4) and (5) of the Local Government (Scotland)
Act 1973, as amended, the public and media representatives be excluded
from the meeting for Item 12 of business on the grounds that it involves
the likely disclosure of exempt information of the class described in the
relevant Paragraphs of Part 1 of Schedule 7A of the Act.”   
4. Minute of meeting dated 2 September 2025 7 - 12
5. Written Questions ** 
6. Flood Risk Management Mid Cycle
Report by Executive Director Economy, Enterprise and Operations  
13 - 52
7. Overnight Stays by Campervans and Motorhomes
Report by Executive Director Economy, Enterprise and Operations  
53 -
104
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8. Operations and Environment and Growth, Planning and
Climate Capital and Revenue Budget Monitoring
Report by Executive Director Economy, Enterprise and Operations  
105 -
122
9. Performance Report (Environmental and Commercial
Services) - Period to September 2025
Report by Executive Director Economy, Enterprise and Operations  
123 -
130
10. Performance Report (Economic Growth and Development) -
Period to September 2025
Report by Executive Director Economy, Enterprise and Operations  
131 -
138
11. Blue Badge Disabled Persons Parking Concessions
Procedure Report
Report by Executive Director Economy, Enterprise and Operations  
139 -
202 
Item(s) which the Committee may wish to consider with the
Press and Public excluded   
12. Use of Dorenell Windfarm Funding for Core Path Activities
[Para 1]
• 1. Information relating to staffing matters; 
Information Reports - Not for Discussion at this Meeting
Any member wishing to call in a noting or information report from one
meeting shall give notice to Committee Services by 12 noon 2 clear
working days before the meeting for which the report is
published.  Please see Standing Order 38 for deadlines. The Notice
shall be countersigned by one other elected member and shall explain
the reason for call in including any action sought.   
Active Travel Strategy and Action Plan
Report by Executive Director Economy, Enterprise and Operations  
203 -
252
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Update on Wildflowers in the Landscape Report
Report by Executive Director Economy, Enterprise and Operations  
253 -
266 
Public Bodies Climate Change Report 2024-25
Report by Executive Director Economy, Enterprise and Operations  
267 -
272 
List of Property Transactions Concluded Under Delegated
Powers
Report by Executive Director Economy, Enterprise and Operations  
273 -
284 
Annual Report on Energy Consumption and Expenditure
2024-25
Report by Executive Director Education, Housing and Communities    
285 -
296 
Summary of Economic Development and Infrastructure
Services Committee functions:
Roads Authority; Lighting Authority, Reservoirs Act 1975, Public
Passenger Transport; Flood Prevention; Twinning; Piers and Harbours and
Coast Protection; Industrial and Commercial Development;
Environmental Protection; Burial Grounds; Assistance to Industry or
Commerce; Public Conveniences; Council Transportation; Catering &
Cleaning; Land Reform (Scotland) Act 2003; Countryside Amenities;
Tourism, monitoring funding from European Programmes, youth training
and employment creation scheme and provide Architectural, Quantity
Surveying, Maintenance and Allied Property Services.     
Watching the Meeting
You can watch the webcast live by going to: 
http://www.moray.gov.uk/moray_standard/page_43661.html    
Webcasts are available to view for 1 year following the meeting.  
You can also attend the meeting in person.  If you wish to attend
in person, please come to the High Street entrance door and a
member of staff will let you into the Chamber. 
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GUIDANCE NOTES 
* Declaration of Group Decisions and Members Interests - The Chair of the
meeting shall seek declarations from any individual or political group at the
beginning of a meeting whether any prior decision has been reached on how the
individual or members of the group will vote on any item(s) of business on the
Agenda, and if so on which item(s).  A prior decision shall be one that the
individual or the group deems to be mandatory on the individual or the group
members such that the individual or the group members will be subject to
sanctions should they not vote in accordance with the prior decision.  Any such
prior decisions will be recorded in the Minute of the meeting. 
** Written Questions - Any Member can put one written question about any relevant
and competent business within the specified remits not already on the agenda, to
the Chair provided it is received by the Proper Officer or Committee Services by
5pm three working days prior to the day of the meeting, please see Standing Order
36 for deadlines.  A copy of any written answer provided by the Chair will be
published on the Council’s committee management system by 12pm the day
before the meeting.  The Member who has put the question may, after the answer
has been published, may ask one supplementary question directly related to the
subject matter at the meeting, but no discussion will be allowed. 
No supplementary question can be put or answered more than 10 minutes after
the Council has started on the relevant item of business, except with the consent
of the Chair. If a Member does not have the opportunity to put a supplementary
question because no time remains, then he or she can submit it in writing to the
Proper Officer who will arrange for a written answer to be provided within 7
working days. 
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MORAY COUNCIL 
Economic Development and Infrastructure Services
Committee 
SEDERUNT 
Councillor Marc Macrae  (Chair)
Councillor Amber Dunbar  (Depute Chair)  
Councillor Peter Bloomfield  (Member)
Councillor Neil Cameron  (Member)
Councillor Tracy Colyer  (Member)
Councillor John Cowe  (Member)
Councillor John Divers  (Member)
Councillor Jérémie Fernandes  (Member)
Councillor David Gordon  (Member)
Councillor Juli Harris  (Member)
Councillor Sandy Keith  (Member)
Councillor Paul McBain  (Member)
Councillor John Stuart  (Member)
Councillor Draeyk van der Horn  (Member)
Councillor Sonya Warren  (Member)  
Clerk Name: Lissa Rowan
Clerk Telephone: 07765 741754
Clerk Email: committee.services@moray.gov.uk 
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MORAY COUNCIL 
Minute of Meeting of the Economic Development and Infrastructure Services
Committee 
Tuesday, 02 September 2025 
Council Chambers, Council Office, High Street, Elgin, IV30 1BX 
PRESENT 
Councillor Peter Bloomfield, Councillor Neil Cameron, Councillor Tracy Colyer,
Councillor John Cowe, Councillor John Divers, Councillor Amber Dunbar, Councillor
Jérémie Fernandes, Councillor David Gordon, Councillor Juli Harris, Councillor Sandy
Keith, Councillor Marc Macrae, Councillor Paul McBain, Councillor John Stuart,
Councillor Draeyk van der Horn, Councillor Sonya Warren 
IN ATTENDANCE 
Executive Director for Economy, Enterprise and Operations, Head of Operations and
Environment, Acting Head of Growth, Planning and Climate (Chief Planning Officer),
Head of Housing, Property and Communities, Service Manager (Environmental
Services), Service Manager (Economy and Enterprise), Service Manager (Property,
Estates and Assets), Chief Governance Officer (Monitoring Officer) and Lissa Rowan,
Committee Services Officer.   
1         Chair 
Councillor Marc Macrae chaired the meeting. 
2         Declaration of Group Decisions and Members Interests 
In terms of Standing Orders 21 and 23 of the Councillors’ Code of Conduct, there
were no declarations from Group Leaders or Spokespersons in regard to any prior
decisions taken on how Members will vote on any item on the agenda or any
declarations of Member’s interests in respect of any item on the agenda.  
3         Minutes of meeting of 17 June 2025 
The minute of the meeting of the Economic Development and Infrastructure Services
Committee dated 17 June 2025 was submitted and approved.   
4         Written Questions 
The Committee noted that no written questions had been submitted. 
Item 4.
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5         Update on Core Path Action Plan 2023-2026 
Under reference to paragraph 5 of the Minute of the meeting of this Committee dated
20 June 2023, the meeting had before it a report by the Executive Director for
Economy, Enterprise and Operations updating Members on the progress made with
regards the Council's Core Path Action Plan 2023-26.  
Following consideration, the Committee unanimously agreed to approve the:  
i. update provided; and 
ii. progress made with regards the core path action plan 2023-2026.   
6         Future Falconer Museum, Forres 
Under reference to paragraph 17 of the Minute of the meeting of the Policy and
Resources Committee dated 29 October 2019, the Meeting had before it a report by
the Executive Director for Economy, Enterprise and Operations informing the
Committee that a new operating model had been identified for the Falconer Museum
in Forres and approval was sought to support the transition process. 
At the invitation of the Chair, the Committee noted a statement from Councillor
Robertson regarding the Falconer Museum. Councillor Robertson welcomed the
progress made towards reopening the museum and acknowledged that it had been a
key issue raised during pre-election engagements.  
It was highlighted that the Falconer Museum holds significance not only for the local
community but also at national and international levels. Councillor Robertson
emphasised the importance of museums in supporting mental health and education,
particularly considering current pressures on the NHS. Reference was made to
recent discussions at COSLA, where the role of culture and sport in preventative
health was recognised.  
Councillor Robertson expressed thanks to Kirsty Conti, Service Manager (Economy
and Enterprise) and her team for their work in advancing the project, and also
acknowledged the contributions of former trustees Peter Taylor, Peter Grant Peterkin,
and Alexander Pollock, as well as the Friends of the Falconer for their continued
efforts in maintaining public awareness.  
It was noted that the museum has been closed since 2019 and is not expected to
reopen until 2026, resulting in a generation of primary school children missing the
opportunity to visit. The museum’s heritage was described as integral to the identity
of Forres, with references to local street names and developments that reflect its
legacy.  
In closing, Councillor Robertson urged the Committee to support the
recommendations contained within the report and thanked the Chair for the
opportunity to speak.  
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Following consideration, Councillor Bloomfield moved that the Committee agree the
recommendations as printed within the report. There being no-one otherwise
minded, the Committee unanimously agreed:  
i. to note the reports produced to guide the re-opening of the Falconer Museum
under a new operating model, as set out in Appendix 1 and Appendix 2 of the
report; 
ii. to note that the Business Model includes an Occupation Agreement in Year 1 and
Service Level Agreements (SLA) with Moray Council in Year 1 and Years 2-5 using
the existing museums annual maintenance budget to provide a diminishing grant
to the new operating body year to year; 
iii. to note there is a community group of skilled individuals ready to form the new
operating body and a specialist support network is available; 
iv. council support for Year 1 of the transition process and ‘in principle’ approval for
Years 2-5 as outlined in the Development Plan, as set out in Appendix 2 pages 33-
40 of the report, subject to a further report at end of Year 1; and 
v. to Stage 1 of the proposed rationalisation of the Moray Museum Service
Collections and notes the proposed use of the residual balance of museum
annual maintenance budget across Years 2-5. 
7         Crown Estate Coastal Community Fund 
The Meeting had before it a report by the Executive Director for Economy, Enterprise
and Operations which provided an update on the Crown Estate Coastal Community
Fund.  
During discussion, Members welcomed the funding opportunity but expressed
concern regarding the short timescale for submission of applications, which were
required by Friday 17 September, as well as the limited timeframe for completion of
works. It was noted that this may present a barrier to some Communities wishing to
apply. Further concern was raised in respect of the requirement for two quotes,
which may discourage smaller businesses from applying, and it was queried whether
micro grants could be considered where only one quote would be sufficient. In
addition, Members noted that electronic voting was being used and queried whether
alternative, more traditional voting methods would be made available to support
older members of the community.  
The Chair sought the agreement of the Committee for a short adjournment to allow
Officers the opportunity to considers these concerns. This was agreed.  
On resumption of the meeting, the Executive Director for Economy, Enterprise, and
Operations highlighted the significant resourcing challenges faced by the team in
managing successive years of grant funding, with limited capacity to process multiple
years concurrently. It was advised that while there may be scope for one or two
exceptions to meeting the deadline, this could not become standard practice due to
the impact on the team’s ability to deliver future grant processes. Members were
advised to flag any anticipated issues in meeting deadlines, and that full guidance
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would be issued by 31 January 2026 to support workload planning. 
With regard to micro grants, the Committee was informed that the minimum grant
level would be set at £10,000 and the maximum at £20,000, as smaller grants would
result in a higher volume of applications which the team would be unable to process
within existing resources. 
On the matter of quotes and estimates, it was clarified that estimates would be
accepted; however, once a grant is awarded, it cannot be increased. Communities
would therefore be required to absorb any additional costs should actual expenditure
exceed the estimated amount. 
In relation to participatory budgeting (PB), it was noted that this would be the first
time the grant stream would be delivered via PB, using the Moray Engage platform.
While Moray Engage is currently operational and being used for play park funding,
concerns were raised regarding its capacity to manage the volume of applications
and integration with other processes. Should PB prove unfeasible, a Member-Officer
Assessment Panel would be convened to assess applications, with membership
drawn from coastal communities and in line with legislative and political balance
requirements. 
It was further requested that delegated authority be granted to the Executive Director
for Economy, Enterprise and Operations, in consultation with the Chair, to make
necessary provisions regarding the voting process to ensure it is fair and inclusive. 
Following consideration, the Committee unanimously agreed: 
i. to approve the use of the 2024/25 Crown Estate allocation to administer a
Coastal Community Fund Grant Scheme that will deliver coastal community
benefit; 
ii. should PB prove unfeasible, a Member-Officer Assessment Panel would be
convened to assess applications, with membership drawn from coastal
communities and in line with legislative and political balance requirements; and 
iii. that delegated authority be granted to the Executive Director for Economy,
Enterprise, and Operations, in consultation with the Chair, to make necessary
provisions regarding the voting process to ensure it is fair and inclusive. 
8         Industrial Portfolio Annual Report 2024-25 
Under reference to paragraph 10 of the Minute of the meeting of this Committee
dated 3 September 2024, the Meeting had before it a report by the Executive Director
for Education, Housing and Communities setting out the annual performance of the
Council's Industrial Portfolio in 2024/25.  
Following consideration, the Committee welcomed the good performance of the
Council’s Industrial Portfolio and thereafter unanimously agreed to:  
i. note the Annual Report for 2024/25; and
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ii. approve the allocation of the capital expenditure as outlined in paragraph 5.38 of
the report. 
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1   
Report to: Economic Development
and Infrastructure
Services Committee 
Meeting Date: 11 November 2025  
Report by: Executive Director
Economy, Enterprise and
Operations 
Author: Will Burnish  Contact Email:  will.burnish@moray.gov.uk 
Subject: Flood Risk Management Mid Cycle 
1.  PURPOSE 
☒ For Decision      ☐  For Information 
1.1  The purpose of this report is to consider and approve the Flood Risk Management plans for
the NE Local Plan District and Findhorn Nairn and Speyside Local Plan District.  
1.2  This report is submitted to this Committee in terms of Section III (F) (19) of the Council’s
Scheme of Administration relating to exercise the functions of the Council under the Flood
Risk Management (Scotland) Act 2009. 
2.  SUMMARY  
2.1  Under the Flood Risk Management (Scotland) Act 2009, Moray Council, as Lead Local 
Authority for the Findhorn, Nairn and Speyside Local Plan District (FNS), is required to
publish an Interim Report on delivery of the Flood Risk Management Plan (the Plan) at mid
cycle.  Moray Council has prepared the Interim Report for Cycle 2 in collaboration with
SEPA, Highland Council, Cairngorms National Park Authority, and Forestry Commission
Scotland. The report details progress on implementing flood risk measures and is
scheduled for publication in December 2025, subject to committee approval.
Aberdeenshire Council is responsible for the North East (NE) Local Plan District Interim
Report, which is pending due to differing committee cycles. The proposed Committee
date for Aberdeenshire Council is 27 November 2025.    
2.2 Delivery of Actions in both Districts during Cycle 2 has been constrained by limited capital
funding from Scottish Government. Moray Council’s  proposed Flood Protection schemes
have been delayed and will now be proposed for inclusion in Cycle 3.      
Item 6.
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2
2.3 In Cycle 2 Moray Council has focused on maintaining existing flood defences, updating
flood models, and completing Scotland’s first Coastal Adaptation Plan. A reassessment of
flood risk in Aberlour was also undertaken following flooding in spring 2023.  
2.4 Nationally, the implementation of Cycle 2 has been impacted by delays in capital funding
from Scottish Government, largely due to ongoing financial commitments from Cycle 1
projects. This has disrupted the sequencing of new schemes and created a backlog of
priority Actions. Upon approval, the FNS Interim Report will be published on Moray
Council’s website, while updates to the NE Interim Report will be finalised and published
by Aberdeenshire Council. 
3.  RECOMMENDATIONS 
3.1  It is recommended that Committee agree:   
i)  the Interim Report for the FNS Local Plan District, under Section 37 of the
Flood Risk Management (Scotland) Act 2009; and 
ii)  extracts of the NE Interim Report that relate to the two Potentially Vulnerable
Areas (PVAs) in Moray, as drafted by Moray Council.   
Will Burnish
Senior Engineer, Flood Risk Management  
4.  BACKGROUND AND CONTEXT   
Flood Risk Management Plans Interim Report
4.1  On 15 November 2022 a meeting of this Committee agreed the Local Flood Risk
Management Plans for the NE Local Plan District and the FNS Local Plan District
(paragraphs 6 and 7 of the Minute  refer).  
4.2  Under Section 37 of The Flood Risk Management (Scotland) Act 2009 the Lead Local
Authority is required to undertake a review of the Plan and publish a report on the
conclusions of the review. This report must include information on the progress that has
been made towards implementing the measures identified in the Plan. This review must
be undertaken not less than two years or more than 3 years after publishing the Plan, i.e.
between December 2024 and December 2025.  
4.3  Moray Council is the Lead Local Authority for the FNS Local Plan District and is
responsible for publishing the Interim Report for this District. The Interim Report has been
drafted in consultation with the partner organisations for this District, which are SEPA,
Highland Council, Cairngorm National Park Authority, and Forestry Commission Scotland.
A copy of this report is provided in Appendix A.  
4.4  If agreed by this Committee it is proposed that the Interim Report for the FNS Local Plan
District will be published in December 2025.  
4.5  The Interim Report for the NE Local Plan District will be published by Aberdeenshire
Council.  Differences in committee cycles mean this report is not yet available, however,
extracts of the report for the two PVAs in Moray are provided in Appendix B.
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3 
FNS Local Plan District Update
4.6  The delivery of Actions within Cycle 2 has been hindered by the availability of capital
funding from Scottish Government for flood alleviation schemes; further details on this
issue can be found in paragraphs 4.12 to 4.15 below. The remaining Actions for Moray
Council in the Findhorn, Nairn, and Speyside Local Plan District include maintaining
existing flood management assets and increasing understanding. Flood Protection
Scheme Actions that have not been undertaken due to funding constraints are proposed
to be carried forward to Cycle 3. At present there has been no agreement reached on
funding flood schemes past 2026.  
4.7  In the first three years of the Plan, Moray Council updated its models for major flood
alleviation schemes, confirming they still provide the intended level of protection.
However, the findings show some vulnerability to climate change, highlighting the need for
regular reviews and possible adaptation plans. Significant capital investment was made in
2023–24 for major maintenance of flood schemes within the Local Plan District.  
4.8  Moray Council reassessed the risk from flooding of Aberlour following flooding in the
spring of 2023. The assessment looked at the impact of new developments built after the
Flood Scheme was completed. The assessment concluded that the flood scheme
continues to offer its intended level of protection, but the model review raised concerns
about altered overland flow near Linn Brae/Chapel Terrace due to development built after
the flood scheme was constructed.  
4.9  Additionally, Moray Council has completed the first Coastal Adaptation Plan in Scotland,
covering all risk areas within Moray. These Plans highlight the triggers at which Moray
Council or other responsible bodies may intervene with Actions to help adapt to the
changing coastline. These Plans will be reported separately. 
NE Local Plan District
4.10  The implementation of Actions within Cycle 2 has been impacted by limited access to
capital funding from Scottish Government for Flood Protection Schemes; additional
information on this matter is provided in paragraphs 4.12 to 4.15 below. The remaining
Actions for Moray in the NE Local Plan District focus on maintaining existing flood
management assets and enhancing knowledge in this area. Actions related to Flood
Protection Schemes that could not be progressed due to funding constraints are proposed
to be carried forward into Cycle 3.   
Funding
4.11  The implementation of Cycle 2 of Scotland’s Flood Risk Management Plans (FRMPs) has
been significantly affected by delays in capital funding availability from Scottish
Government. A key contributing factor has been the continued financial commitments
associated with projects initiated under Cycle 1. Many of these earlier schemes
experienced cost escalations and extended delivery timelines, resulting in ongoing
liabilities that have constrained the funding available for new projects.  
4.12  As a result, capital allocations intended for Cycle 2 have, in part, been redirected to
complete or settle outstanding Cycle 1 schemes. This has delayed the progression of new
projects and disrupted the intended sequencing of flood risk interventions across the
country.
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4  
4.13  Further compounding the issue, confirmation of available budgets for Cycle 2 has not
been provided in time to support early-stage procurement and design activity. This has led
to a national backlog of priority schemes that remain in development or have been paused
pending funding clarity.  
4.14  The cumulative effect of these delays is a shortfall in the delivery of Cycle 2 Actions. 
Coastal Adaptation Plans
4.15  Moray Council has successfully completed the Action to develop a Coastal Adaptation
Plan for Kingston. Furthermore, all of the remaining Coastal Adaptation Plans have been
finalised, making Moray Council the first in Scotland to achieve this milestone. These
Plans highlight the triggers at which Moray Council or other responsible bodies may
intervene with Actions to help adapt to the changing coastline. These Plans will be
reported separately. 
4.16  The Coastal Adaptation Plans will be reviewed in six yearly cycles to coincide with the
review of Local Flood Risk Management Plans, the next review will be undertaken in
2027/28. 
5.  PROPOSALS  
5.1  The Findhorn, Nairn, and Speyside Local Plan District Interim Report will be published on
the Moray Council’s website after it receives formal approval from this Committee and
Highland Council. An official press release will provide extra context for stakeholders and
interested parties. As Lead Local Authority, Moray Council is responsible for updating the
Scottish Government and SEPA on major developments and sharing relevant information
associated with the delivery of the Local Flood Risk Management Plans.  
5.2  On approval of the extracts from the NE Interim Report, these extracts will be sent to
Aberdeenshire Council. Aberdeenshire Council will then finalise and publish the updated
report on their website. This collaborative process should help keep communication clear
and maintain transparency throughout.  
6.  SUMMARY OF IMPLICATIONS  
6.1  The table below shows whether risks and implications apply if the recommendations are
agreed: 
SUBJECT YES NO
Corporate Plan and 10 Year Plan (Local Outcome Improvement Plan)  x
Policy and Legal x 
Financial  x
Risk x 
Staffing  x
Best Value and Transformation  x
Property  x
Information Communications Technology/Digital  x
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5
Equalities. Social Inclusion and Economic Impact   x
Climate Change and Biodiversity Impact  x 
6.2  Corporate Plan and 10 Year Plan (Local Outcomes Improvement Plan (LOIP))
Improved Collaborative Leadership, as part of continuous improvement through Best
Value, will better enable the Council to fulfil the ambitions set out in its strategic plans. 
a) Links to Council Corporate Plan – The proposals in this report support and contribute
to improved outcomes for communities as outlined in the following Council Plan
strategic priorities:
☐ Tackle Poverty and Inequality.
☐ Build Stronger Greener Vibrant Economy.
☐ Build Thriving, resilient, empowered Communities.   
b) Links to Local Outcomes Improvement Plan – The proposals in this report support
and contribute to improved outcomes for communities as outlined in the following
Local Outcomes Improvement Plan priorities:
☐ Developing a diverse, inclusive, and sustainable economy
☐ Building a better future for our children and young people in   Moray.
☐ Empowering and connecting communities.
☐ Improving wellbeing of our population   
6.3  Policy and Legal 
Under the Flood Risk Management (Scotland) Act 2009, Section 37, the Council, as the
Lead Local Authority, must review and publish a report on their findings and make it
available for public inspection. Section 39 requires Moray Council to cooperate in
reviewing the NE Local Plan District Interim Report so that Aberdeenshire Council, as Lead
Authority, can finalise and publish the report.  
6.4  Financial 
There is no additional pressure placed on the council in this updated report. Currently all
Flood Protection Schemes progressed by Moray Council are subject to grant funding by
Scottish Government.  The grant from Scottish Government is 80% of the cost of the
scheme and the Council funds the remaining 20%.  It should be noted that, due to the
absence of a capital grant from the Scottish Government for Cycle 2 schemes, it is now
likely that work will not commence on any of these projects, and they will therefore be
removed from the capital plan for the next three years. As a result, there is no need to
allocate 20% of the funding from within our capital plans. 
One off Costs:
Service
Area
Budget Budget
Years
Proposed
Spend this
Year
Virement
From
Other
Comments       
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6
Annually Recurring Costs:
Service
Area
Budget With
Effect
From
Annual
Net
Impact
Virement
From (if
applicable)
Other
Comments       
6.5  Risk 
Failure to produce a Section 37 Interim Report under the Flood Risk Management
(Scotland) Act 2009 would constitute a breach of statutory duty by the Lead Local
Authority. This omission would undermine transparency and accountability in flood risk
planning, obstruct public access to progress updates, and impair coordination with
stakeholders such as SEPA and the Scottish Government. It would also hinder strategic
planning for future flood risk cycles and delay the identification of priority actions,
potentially increasing vulnerability to climate change and biodiversity loss.  
6.6  Staffing 
There are no staffing implications associated with the recommendations in this report.  
6.7  Best Value and Transformation 
Any significant works identified in the Plan, such as a Flood Protection Scheme, would
only be undertaken if best value can be demonstrated through a feasibility study.  All
significant works undertaken are subject to grant funding from Scottish Government.  
6.8  Property 
There are no property implications associated with the recommendations in this report.  
6.9  Information Communications/Technology/Digital 
There are no ICT implications associated with the recommendations in this report.  
6.10  Equalities, Social Inclusion and Economic Impact 
An Equalities Impact Assessment is not needed because the recommendations in this
report do not impact on people.  
6.11  Climate Change and Biodiversity Impacts 
The Flood Risk Management Interim Report for the FNS Local Plan District, as well as the
NE Local Plan District, provides a critical assessment of the actions outlined in the current
Cycle 2 plan. This report reviews the progress made in implementing measures designed
to reduce flood risks aggravated by climate change, while also promoting nature-based
solutions. 
7.  CONSULTATION  
7.1  This report has been prepared in consultation with Executive Director Economy, Enterprise
and Operations, Head of Operations and Environment, Chief Financial Officer, Service
Manager Legal Services, R Geddes-Stewart, Senior HR Adviser, Equal Opportunities
Officer and L Rowan, Committee Services Officer and any comments made have been
incorporated into the report.   
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8.  BACKGROUND PAPERS  
8.1  Report to ED&I Committee 15 November 2022 
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Appendix A: FNS Interim Report  
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9 
FINDHORN, NAIRN 
AND SPEYSIDE 
Local Flood Risk 
Management Plan
Interirm Report 
Publish by Moray Council December 2025 
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Findhorn, Nairn and Speyside Local Flood Risk Management Plan 2022-2028: Interim Report 
10
Publication date: December 2025
Contents
1 Background ............................................................................................................ 11
2 How current is the Plan ............................................................................................ 12
3 Significant issues .................................................................................................... 12
4 Other actions .......................................................................................................... 13
5 Next steps ............................................................................................................... 14
6 Conclusions ............................................................................................................ 15
7 Assessment of progress ........................................................................................... 16
Appendix 1: Flood risk management responsibilities in Scotland and the legal requirement for
the publication of this Interim Report ............................................................................... 27
Appendix 2: Publication details ....................................................................................... 31 
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Findhorn, Nairn and Speyside Local Flood Risk Management Plan 2022-2028: Interim Report 
11
1 Background
The Interim Report is a legal requirement under Section 37of the Flood Risk Management
(Scotland) Act 2009 (the Act), which must be published between July 2024 and December
2025. This report includes a review of the Local Flood Risk Management  Plan, published in
December 2022, and information on the progress that has been made towards implementing
the actions identified in the Plan. 
Further details on flood risk management responsibilities in Scotland and the legal
requirement for the publication of this Interim Report can be found in Appendix 1. 
A copy of the Findhorn, Nairn and Speyside Local Flood Risk Management Plan can be found
at Moray Council FRM or A hard copy or the plan can be obtained from Moray Council or
Highland Council. 
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2 How current is the Plan
The Plan was published in December 2022 as a supplement to the Flood Risk Management
Plan issued by SEPA in December 2022. It outlines how the actions identified in the Strategy
will be carried out during the period from 2022 to 2028. Both the Strategy and the Plan are
informed by the National Flood Risk Assessment and the designation of Potentially Vulnerable
Areas at that time. The Plan continues to be considered appropriate based on the current
understanding of flood risk within the Findhorn, Nairn, and Speyside Plan District.
3 Significant issues
Based on a progress review of the Plan for Findhorn, Nairn and Speyside, the following key
themes and issues have been identified that have or may have an impact on the delivery of
actions to manage flood risk. Arrangements planned to deliver the remaining actions are
described below. Where these issues have had an impact on the delivery of specific actions
or actions across an LPD, this is detailed in the ‘Assessment of the progress of actions’. 
Funding of New Flood Alleviation Schemes
The distribution of capital funding through the local authority general capital grant, including
for flood protection schemes, is jointly agreed by Scottish Ministers and COSLA Leaders. 
The implementation of the 2022 Flood Risk Management Plans (FRMPs) have been
significantly affected by capital funding availability through the general capital grant for new
flood protection schemes.    
There is a commitment to fund flood protection schemes from the 2015 FRMPs first and many
of these schemes have experienced cost escalations and extended delivery timelines.  
As a result, there have been no capital allocations through the general capital grant for the
development and delivery of new flood protection schemes.  This has delayed early-stage
procurement and design activity for new flood protection schemes by other Responsible
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13
Authorities and disrupted the intended sequencing of flood risk interventions across the
country.  There is therefore a backlog of flood protection schemes that remain in development
or have been paused pending the availability of capital funding. through the general capital
grant.  
The cumulative effect of these delays is a shortfall in the delivery of the flood protection
schemes in the 2022 FRMPs. 
Flooding across Findhorn, Nairn, Speyside Region: December 2022 – July 2025
• December 2022 – January 2023: Heavy rain and snowmelt triggered surface water
flooding in Moray and the Highlands. SEPA issued multiple flood alerts for Findhorn,
Nairn, Moray, and Speyside.
• May 2023: Intense summer storms caused flooding and property damage in Aberlour
due to debris.
• 6-9 October 2023: 48 hours of heavy rain across Scotland saw more than 150mm rain
fall across the upper River Spey catchment, saturating ground conditions and flooding
susceptible areas. Severe flood warnings were issued for Aviemore, high risk locations
were evacuated and there was road and rail disruption throughout the area. 
• 18-21 October 2023 – Storm Babet: Major floods affected roads and properties;
widespread warnings were issued.
• 31 December 2024 – Hogmanay Flooding: Over 20 flood warnings were active during
an amber alert for heavy rain across Highland and Moray.
• May 2024: Ongoing rain led to repeated surface water flooding in low-lying areas of
Moray, including Elgin and Aberlour.
4 Other actions 
Moray Council 
The Council has completed the first Coastal Adaptation Plan in Scotland, covering the coastal
areas within Moray. These plans highlight the triggers at which Moray Council or other
responsible bodies may intervene with actions to help adapt to the changing coastline. 
Moray Council also reassessed the risk from flooding of Aberlour following flooding in the
spring of 2023. The assessment looked at the impact of new developments post the Flood
Scheme being completed. The assessment concluded that the flood scheme continues to
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14
offer its intended level of protection, but the model review raised concerns about altered
overland flow near Linn Brae/Chapel Terrace due to development post the flood scheme
completion. 
Highland Council
The Council has completed a Regional Coastal Change Adaptation Plan, covering coastal
flood and erosion risk areas within the Highlands. This plan is a high-level review, identifying
priority sections of coastline for more detailed Local Coastal Change Adaptation Plans in the
future, as funding allows. 
SEPA
Over the past four years, SEPA has made significant improvements in the flood forecasting
and warning service through its Flood Warning Development Framework 2022–2028. Key
achievements include:
• Scottish Flood Forecast: A new 3-day public forecast developed with the Met Office,
providing earlier and clearer flood risk information.
• MyFloodline: A redesigned registration platform that improves public access to flood
warnings.
• Regional Improvements: Enhanced forecasting systems in the Scottish Borders and
Firths of Forth and Tay to support upgraded warning services.
• AI Integration: SEPA has also embraced digital transformation and begun exploring the
use of Artificial Intelligence to enhance forecasting capabilities.
5 Next steps
A Final Report on the Plan will be published between July 2027 and June 2028.  This will
include an updated assessment of the progress made towards implementing the current
actions, a summary of the current measures which were not implemented, with reasons for
their non-implementation; and a description of any other measures implemented since the
Plan was finalised which the lead authority considers have contributed to the achievement of
the flood risk objectives.
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6 Conclusions
The majority, approximately 83%, of the actions identified in the Plan are expected to be
delivered within the timescales set when the plan was published in December 2022. 
Approximately 8% of the actions identified are delayed but expected to be delivered before
the end of cycle 2 in 2028.  Approximately 9% of the actions are not expected to be delivered
in the cycle and will now be considered for future cycles. 
In addition to funding availability for Flood Alleviation schemes, delays in implementing
actions are generally due to factors that cannot be anticipated over a six-year period, such as
funding adjustments and modifications to the scope of work after plans are published. Efforts
will continue to be made to complete the outstanding actions as efficiently as possible. 
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7 Assessment of progress
This section sets out an assessment of the progress towards implementing the actions set out
in the Plan.  There are actions that apply across all of the Findhorn, Nairn and Speyside LPD
and actions that are specific to each of the 14 Potentially Vulnerable Areas (as defined under
Section 13 of the Act), which are shown below in Figure 1. 
Figure 1: The Findhorn, Nairn and Speyside LPD with Potentially Vulnerable Areas identified
Details of Potentially Vulnerable Areas taken from Findhorn, Nairn and Speyside Flood Risk Management Strategy, SEPA (December
2015)
The actions that apply to individual PVAs are shown in Figure 2. The summary progress is
shown using the traffic light system, where each item is marked as Red, Amber or Green
(RAG) and where:
• GREEN – The action has been completed successfully or is progressing as planned. No
immediate attention is required.
• AMBER – The action is behind schedule or progressing slowly, but it is not critical.
Some attention or action is required to get it back on track.
• RED – The action is significantly behind schedule or has not started at all.
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18 
RAG Status               
Flood study
Flood warning maintenance
Strategic mapping improvements
Adaptation plan
Community engagement
Community flood alert
Data collection
Flood defence maintenance
Flood risk management review
Flood scheme or works implementation
Flood scheme or works design
Flood study (existing flood defences)
Sewer flood risk assessment 
Surface water management plan
Aberlour  GREEN      GREEN    GREEN  GREEN
Aviemore RED GREEN            
Dallas  GREEN      GREEN    AMBER  
Dalwhinnie         GREEN     
Elgin  GREEN   GREEN   GREEN  RED RED GREEN GREEN GREEN
Forres  GREEN      GREEN    GREEN GREEN AMBER
Garmouth  GREEN  AMBER          
Hopeman  GREEN      GREEN     GREEN 
Kingston  GREEN  AMBER   GREEN       
Kingussie AMBER GREEN            
Kinloss GREEN GREEN     GREEN      GREEN 
Lhanbryde        GREEN    GREEN GREEN 
Lossiemouth  GREEN GREEN          GREEN 
Muir of Ord              
Nairn AMBER GREEN GREEN           
Nethy Bridge RED GREEN            
Newmill (Nairn) GREEN        GREEN     
Newtonmore  GREEN           GREEN GREEN
Rothes  GREEN   GREEN   GREEN  RED RED GREEN  
Seatown, Lossiemouth  GREEN GREEN  GREEN     RED AMBER  GREEN 
Figure 2: Summary of progress of actions to manage flood risk in the Potentially Vulnerable Areas of the Findhorn, Nairn and Speyside LPD 
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19 
Progress with LPD-wide Actions
This section sets out an assessment of the progress towards implementing actions that apply across all the Findhorn, Nairn and
Speyside LPD over the six-year Plan, which is presented in Figure 3.
Action  Delivery Lead RAG status -
Interim
Report
Update
Awareness raising Moray Council,
Highland Council &
SEPA
GREEN Moray Council has undertaken a number of community events, with particular reference to
coastal aspirations and post-flood recovery. We are committed to promoting property flood
resilience and have worked in partnership with SEPA, Scottish Water, and the Scottish Flood Forum
at these events. 
The Highland Council continue to engage with Community Resilience Groups, helping them to
identify means to reduce flood risk themselves and become better prepared to deal with future
flooding. 
SEPA has delivered a range of awareness-raising activities through targeted campaigns and
collaborative partnerships. A key achievement has been the development of a suite of online flood
education resources for pupils in P5–P7, designed to help young people build their understanding
of flood risk and resilience. 
We have also refreshed how we communicate our flood warning and information tools to the
public, guided by a user-led approach. Our emphasis on accessibility ensures that communities are
better equipped to understand their flood risk and take action to build resilience. 
In addition, SEPA hosted its first-ever national online community event. The event attracted over
65 participants from communities across Scotland, with 96% of attendees reporting that they felt
better informed about how their community could prepare for flooding. 
Data to support
climate resilience
SEPA  AMBER SEPA is undertaking extensive work to upgrade the Hydrometric Network both in terms of
infrastructure and technology, including dramatically increasing the number of sites and utility of
near live data across numerous users. 
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A strategic vision and strategy is being developed for Hydrology Monitoring in Scotland to ensure
that our service meets future user needs in an effective and efficient way in a changing climate.
Emergency plans Moray Council,
Highland Council &
SEPA
GREEN Moray Council continues to provide support as a Category 1 responder. During the first part of the
cycle, the Council updated its emergency plan with specific regard to flooding. 
The Highland Council continues to provide support as a Category 1 responder, updating
emergency plans. 
SEPA plays a central role in Scotland’s Flood Warning Service, working in partnership with local
authorities, emergency services, and other responders under the Civil Contingencies Act 2004 to
support emergency planning and help protect communities from the impacts of flooding. 
Flood forecasting SEPA GREEN   SEPA delivers the Scottish Flood Forecasting Service in partnership with the Met Office. This
service continues to deliver daily outlooks of flood risk and potential impacts for the nation
through its 3 day Scottish Flood Forecast for the public and 5 day Flood Guidance Statement for
professional partners. Flood Alerts and Warnings are issued by SEPA's flood duty officers when
flooding is possible and/or expected.
Flood warning
development
framework
SEPA GREEN   SEPA published the Flood Warning development Framework for 2022-2028 including a
programme of works to maintain and improve SEPA's forecasting and warning services. SEPA has
developed a road map for improving surface water forecasting and SEPA now have a surface water
forecasting tool that has been developed called PREDICTOR. Further recommendations exist to
develop these surface water capabilities. 
SEPA's partnership with the Met Office continues with the publication of daily 3 day forecasts for
the public and 5 day forecasts for professional partners.
Future flood risk
management
planning
SEPA  AMBER SEPA is currently preparing the Flood Risk Management Plans for the upcoming cycle (2027–2033)
in collaboration with key stakeholders. This process includes a formal consultation phase
scheduled for 2026. The new plans will introduce key elements of the Scottish Flood Resilience
Strategy and align with the objectives of other national frameworks, such as the Scottish National
Adaptation Plan. 
Following the publication of the Scottish Flood Resilience Strategy in 2025, SEPA is embedding its
principles and ambitions into a refreshed vision and strategic direction for its flooding services.
Moray Council and The Highland Council reaffirms their commitment to supporting SEPA in the
development of Flood Risk Management Plans. The Councils will work closely with communities
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21
through consultation on the preparation of Local Flood Risk Management Plans during 2026 and
2027.
Guidance
development
SEPA & Scottish
Government 
AMBER  As part of delivering the Scottish Flood Resilience Strategy, SEPA is contributing to the
development of a flood advisory service. This includes updating and creating tailored guidance to
support flood risk management projects. In collaboration with Scottish Forestry and other UK
forestry agencies, Forest Research published the UK Forestry Standard Practice Guide in October
2022. This guide offers practical advice to landowners, land managers, and public authorities on
how to design and manage forests and woodlands to help reduce flood risk. 
Hazard mapping
updates
SEPA  GREEN  SEPA has a phased, multi year programme of hazard map updates. Updates to our coastal map for
Outer Hebrides, Orkney and North East Scotland were published in November 2023 and South
East Scotland is due to be published in 2026. A review of coastal modelling and mapping in South
West Scotland will follow.   
In February 2025 SEPA published a new national flood hazard map for surface water and small
watercourses, entirely replacing the previous surface water map release.
SEPA is updating its approach to fluvial hazard map updates including user needs analysis,
technological and methodological improvements in order to meet the next statutory hazard map
update deadline of December 2031. 
Land use planning Moray Council,
Highland Council,
SEPA & Scottish Water 
GREEN SEPA- Following the publication of the Scottish Government’s National Planning Framework 4
(NPF4) in February 2023, SEPA has undertaken a programme of updates to its land use planning
guidance on flood risk. This work, carried out in consultation with key stakeholders, has focused
on ensuring alignment with Policy 22 in particular. The programme is now largely complete, and
planning authorities are progressing with the implementation of NPF4 through the spatial
elements of their upcoming local development plans. 
Moray Council and The Highland Council continue to assess planning applications to ensure
compliance with National Planning Framework 4 (NPF4) and to confirm that new developments do
not increase flood risk to communities or existing infrastructure. The Councils are also working
closely with the Local Development Plan teams to ensure that Strategic Flood Risk Assessments
address known risks and support the creation of designated areas within Moray and The
Highlands for Making Space for Water. 
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22
Maintenance  Moray Council,
Highland Council &
Scottish Water 
GREEN Moray Council and The Highland Council continue to publish their clearance and repair schedules.
These works are based on inspections carried out under the Flood Risk Management (Scotland) Act
2009 and are prioritised according to the risk of flooding that identified issues may present.
Natural flood
management
mapping 
SEPA GREEN  SEPA is developing an improved evidence base for updating natural flood management mapping
using the Potentially Vulnerable Areas published in December 2024 and the revised National Flood
Risk Assessment data which will be available in March 2026. This will enable a focussed catchment
approach to be developed, building on the existing national approach and providing a higher
resolution of opportunity mapping.
National flood risk
assessment 
SEPA  GREEN SEPA is applying updated evidence and methodologies to produce the revised National Flood Risk
Assessment, scheduled for publication in December 2025. The underlying data informed the
identification of Potentially Vulnerable Areas for the next flood risk management cycle, which
were published in December 2024. This evidence base will also shape the objectives and actions
set out in the 2027–2033 flood risk management plans, due for release in December 2027. 
National surface
water mapping 
SEPA GREEN  In February 2025 SEPA published a new national flood hazard map for surface water and small
watercourses, entirely replacing the previous surface water map release. This new release
included publication for the first time of a future flood map, to help users understand the
potential impacts of climate change. To accompany the publication a number of improvements
were also made to the "Check an area's long term flood risk viewer".  
Reservoirs  SEPA GREEN  SEPA continues to develop its assessment of flood risk from dam failure and use these
assessments to direct a proportionate regulatory approach to ensure reservoir safety. We are
exploring the use of the UK emergency alerts service for issuing warnings in the event of a
reservoir emergency.  
Scottish Flood
Defence Asset
Database 
SEPA AMBER   SEPA’s ongoing Flood Asset Project is strengthening the quality of evidence and data management
on behalf of all flooding partners. This work will deliver an improved national database to replace
the outdated original, which is no longer available, enabling more informed decisions on asset
location, maintenance, flood warnings, risk management, and land use planning.
Self help  Moray Council &
Highland Council 
GREEN The Highland Council continue to sign post communities and individuals to sources of help with
respect to improving property resilience. 
Moray Council continues to operate the Property Level Protection (PLP) at-cost scheme and
provides support to individuals upon request.
Figure 3: Progress with LPD-wide Actions for the Findhorn, Nairn and Speyside LPD
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Progress with PVA-specific Actions
This section sets out an assessment of the progress towards implementing actions that
are specific to each of the 14 PVAs as shown in Figure 2. Assessments of the progress of
Red and Amber actions within each PVA are presented.
Target Area Elgin 392
Action Type Flood scheme or works design 39203
Action Delivery
Lead
Moray Council RAG Status RED
Update This action was subject to funding agreements being in place for
Cycle 2 Flood Schemes. At present, there is no indication of when
funding will be made available. Therefore, it is unlikely that this action
will be completed within the timeframe originally 
Target Area Elgin 392
Action Type Flood scheme or works implementation 39205
Action Delivery
Lead
Moray Council RAG Status RED
Update This action was subject to funding agreements being in place for
Cycle 2 Flood Schemes. At present, there is no indication of when
funding will be made available. Therefore, it is unlikely that this action
will be completed within the timeframe originally 
Target Area Garmouth 393
Action Type Adaptation plan 39301
Action Delivery
Lead
Moray Council RAG Status AMBER
Update Coastal adaptatation plans have been written but triggers have not
been prioritised, this will start 2025 
Target Area Kingussie 395
Action Type Flood study 39501
Action Delivery
Lead
Highland Council RAG Status AMBER
Update Options have been explored to implement erosion reduction
measures on the Gynack, however preffered options remain
unfeasible. 
Pitmain Estate have completed work on a flow diversion channel into
Loch Gynack which will reduce peak flood flows in the River 
Target Area Rothes 397
Action Type Flood scheme or works design 39701
Action Delivery
Lead
Moray Council RAG Status RED
Update This action was subject to funding agreements being in place for
Cycle 2 Flood Schemes. At present, there is no indication of when
funding will be made available. Therefore, it is unlikely that this action
will be completed within the timeframe originally 
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Target Area Rothes 0
Action Type Flood scheme or works implementation 39703
Action Delivery
Lead
Moray Council RAG Status RED
Update This action was subject to funding agreements being in place for
Cycle 2 Flood Schemes. At present, there is no indication of when
funding will be made available. Therefore, it is unlikely that this action
will be completed within the timeframe originally 
Target Area Dallas 421
Action Type Flood study (existing flood defences) 42103
Action Delivery
Lead
Moray Council RAG Status AMBER
Update The project has not yet commenced due to staff resourcing issues.
The works are now scheduled for delivery in the 2027–2028 period 
Target Area Forres 427
Action Type Surface water management plan 42704
Action Delivery
Lead
Moray Council RAG Status AMBER
Update Due to staffing constraints, Moray Council has been unable to
progress this project further. It is now planned to be delivered
between 2026 and 2027 
Target Area Aviemore 396
Action Type Flood study 39601
Action Delivery
Lead
Highland Council RAG Status RED
Update No works undertaken to date. Not identified in the Council capital
programme 
Target Area Nairn 428
Action Type Flood study 42801
Action Delivery
Lead
Highland Council RAG Status AMBER
Update Flood Modelling of the River Nairn and Auldearn Burn has been
undertaken. No funding curently available to progress with an Options
Appraisal.
A Coastal Study has begun for Nairn Beach, with a Dynamic Adaptive
Pathway report produced. In collaboration wit 
Target Area Nethy Bridge 434
Action Type Flood study 43401
Action Delivery
Lead
Highland Council RAG Status RED
Update No works undertaken to date. Not identified in the Council capital
programme 
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Target Area Nethy Bridge 434
Action Type Community flood alert 43402
Action Delivery
Lead
Nethy Bridge
Community
RAG Status Unknown 
Update No update provided from Nethy Bridge Community 
Target Area Kingston 463
Action Type Adaptation plan 46302
Action Delivery
Lead
Moray Council RAG Status AMBER
Update Coastal adaptatation plans have been written but triggers have not
been prioritised, this will start 2026 
Target Area Seatown, Lossiemouth 9991
Action Type Flood scheme or works design 999101
Action Delivery
Lead
Moray Council RAG Status AMBER
Update No design work has been undertaken. No funding has been secured 
Target Area Seatown, Lossiemouth 9991
Action Type Flood scheme or works implementation 999102
Action Delivery
Lead
Moray Council RAG Status RED
Update This action was subject to funding agreements being in place for
Cycle 2 Flood Schemes. At present, there is no indication of when
funding will be made available. Therefore, it is unlikely that this action
will be completed within the timeframe originally 
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List of Acronyms and Abbreviations 
FRM  Flood Risk Management 
ICS Integrated Catchment Study 
LFRMP  Local Flood Risk Management Plan 
LPD  Local Plan District 
NFM Natural Flood Management 
PVA  Potentially Vulnerable Area 
Q&S  Quality & Standards (Scottish Water) 
SEPA  Scottish Environment Protection Agency 
SR10/15  Spending Review periods for 2010-2015 and 2016-2021 for Scottish
Water capital maintenance expenditure 
SWMP  Surface Water Management Planning 
TEAMB  Tay Estuary and Montrose Basin 
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Appendix 1: Flood risk management responsibilities in Scotland
and the legal requirement for the publication of this Interim
Report  
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Flood risk management in Scotland
The Scottish Ministers, SEPA and responsible authorities must exercise their flood
risk related functions with a view to reducing overall flood risk (reference Section 1(1)
of the Flood Risk Management (Scotland) Act 2009). 
Through the preparation of a national flood risk assessment and setting of objectives
to reduce the level of flood risk by SEPA, which is published in Flood Risk
Management Strategy, and the publication of Local Flood Risk Management Plan’s
by ‘lead’ local authorities, which detail how and when the actions agreed to meet
these objectives are to be done, SEPA and all responsible authorities must act to
manage flood risk in a sustainable way. 
Flood Risk Management Strategy for Findhorn, Nairn and Speyside
Local Flood Risk Management Plan for Findhorn, Nairn and Speyside 
Legal requirement
This document sets out the conclusions of the review of the Local Flood Risk
Management Plan (LFRMP) for the Findhorn, Nairn and Speyside LPD as required
by Section 37 of the Flood Risk Management (Scotland) Act 2009 (the “Act”). 
37 Local flood risk management plans: Interim Report
(1) Not earlier than 2 years and not later than 3 years after a local flood risk
management plan is finalised, the lead authority must — 
(a) review the plan, and 
(b) publish a report on the conclusions of the review including information
on the  progress that has been made towards implementing the measures
identified in the  implementation part of the plan.
(2) The lead authority must make copies of the report available for public inspection. 
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The Findhorn, Nairn and Speyside LFRMP was published in December 2022,
therefore, the Interim Report needs to be published between December 2024 and
December 2025. The Interim Report provides a summary of the LFRMP actions
(‘measures’) and the proposed delivery timescales. 
The information on progress will include:
• an assessment of the progress towards implementing each of the actions;
• reasons for any actions where delivery is not as planned; and
• a description of arrangements planned to deliver the remaining actions and to
address delayed actions. 
The Interim Report is published by the ‘lead authority’ as defined by Section 34(9) of
the Act in partnership with SEPA and the ‘responsible authorities’, as defined by
Section 5 of the Act, will be  in the LPD. The approval of the Interim Report will be in
accordance with the agreed governance arrangements in the LPD. The responsible
authorities for the Findhorn, Nairn and Speyside LPD are:
• Moray Council (lead authority)
• The Highland  Council
• Cairngorms National Park
• Forestry Commission Scotland
• Scottish Water. 
The lead authority must also publish a Final Report on the LFRMP under Section 38
of the Act between December 2026 and December 2082 (not earlier than 5 years
and not later than 6 years from the publication of the Plan). The Final Report will
provide an assessment of current actions and a summary of current actions not
implemented, with reasons for their non-implementation. The Final Report will also
include a description of any other measures implemented, which the lead authority
considers have contributed to the achievement of the objectives summarised in the
LFRMP. 
Publication
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The published Interim Report for the Findhorn, Nairn and Speyside LFRMP will be
made available for public inspection, as per Section 37(2) of the Act, via the website
of the lead authority, Moray Council: 
www.moray.gov.uk; search for “Interim Report LFRMP”. 
Links to the published Interim Report for the Findhorn, Nairn and Speyside LFRMP
will also be provided from Scottish Government, SEPA and other responsible
authority websites. 
A hard (paper) copy of the published Interim Report for the Findhorn, Nairn and
Speyside LFRMP is also available for public inspection on weekdays between 9am
and 5pm at the following location(s): 
Council access points in Elgin, Forres, Keith and Buckie, Elgin Library and at
Highland Council’s offices in Dingwall. 
Copies of the published Interim Report for the Findhorn, Nairn and Speyside LFRMP
may also be available at offices of other responsible authorities. 
Detailed arrangements for publication of the Interim Report for Findhorn, Nairn and
Speyside LFRMP are in Appendix 2. 
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Appendix 2: Publication details 
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Flood Risk Management (Scotland) Act 2009
Publication of Interim Report for the Findhorn, Nairn and Speyside Local Flood
Risk Management Plan – 
Summary of Proposed Communications Activities 
The following communications activities will be used to publicise and make the Interim
Report available: 
• Upon finalising the Interim Report for the Findhorn, Nairn and Speyside Local FRM
Plan, Sections 37(2), 53 and 54 of the Act specifically require Moray Council, as
the lead authority, to 
o Publish an Interim Report on the Findhorn, Nairn and Speyside Local
FRM Plan;
o Make copies of the Interim Report available for public inspection free of
charge and at all reasonable times;
o Publicise the arrangements for making it available by means of a notice
in the appropriate newspapers (at least one Scottish newspaper and
such local newspapers within the LPD as considered appropriate) 
• The Interim Report for the Findhorn, Nairn and Speyside Local FRM Plan will be
published in a hard copy format and a pdf version will also be made available on
the Council’s website at Moray Council FRM 
• Hard copies of the Interim Report for the Findhorn, Nairn and Speyside Local FRM
Plan will be held and made available upon request at the Moray Council’s Access
points in Elgin, Forres, Keith and Buckie and Elgin Library. The Plan can also be
viewed at Highland Council’s offices in Dingwall. 
• A letter (with a pdf version of the report on DVD) will be sent to SEPA and the
Scottish Ministers.   
• On or before the publication date [to be advised], public notices will be placed in
the Press and Journal and The Northern Scott, fulfilling our duties to publicise the
Interim Report in accordance with Sections 37, 53 and 54 of the 2009 Act. 
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Appendix B North East Interim Report Extact
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Date Extract from the North East Interim Report:-
Target
area name
Action_ID Action type General description Delivery
Lead
RAG status RAG status comment 
Portgordon 39801 Strategic
mapping
improvements
SEPA will continue to update
flood maps based on new
information. 
SEPA GREEN The coastal flood hazard maps for the Outer
Hebrides and northeast Scotland were
updated and published in November 2023.
This action is complete.
Portgordon 39802 Sewer flood risk
assessment 
The volume of water that
would overwhelm the sewer
system and cause flooding
from manholes or inside our
homes is to be assessed, to
support understanding of the
performance of the urban
drainage network 
Scottish
Water
AMBER This action is on course to deliver within Cycle
2, however the programme of studies has
been delayed due to data sharing challenges.
This is due to a requirement to ensure
consistency of assessment by using the same
underlying datasets as SEPA's updated pluvial
mapping project.
Portgordon 39803 Flood defence
maintenance 
The existing flood defences
are to be maintained by the
asset owner to ensure they
are in good condition.  
Moray
Council
GREEN We are continuing to deliver this action by
maintaining the existing coastal defences 
Portgordon 39804 Flood warning
maintenance
The Floodline flood warning
service is to be kept
operational through
maintenance to the existing
system and updates being
undertaken as required. 
SEPA GREEN SEPA will continue to maintain the flood
warning service.
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Keith 40401 Flood warning
maintenance
The Floodline flood warning
service is to be kept
operational through
maintenance to the existing
system and updates being
undertaken as required. 
SEPA AMBER SEPA has paused the action to  investigate the
River Deveron scheme for improvement
and/or recalibration, as efforts have focused
on advancing flood forecasting and warning
systems to improve the resilience of the
services we deliver across Scotland. For
details on improvements to SEPA’s flood
forecasting and warning service, see the
'Other Actions' section.
Newmill
(Keith)
44401 Flood defence
maintenance 
The existing flood defences
are to be maintained by the
asset owner to ensure they
are in good condition.  
Moray
Council
GREEN We are continuing to maintain this flood
protection scheme in line with the operation
and maintenance manual
Newmill
(Keith)
44402 Flood warning
maintenance
The Floodline flood warning
service is to be kept
operational through
maintenance to the existing
system and updates being
undertaken as required. 
SEPA AMBER SEPA has paused the action to  investigate the
River Deveron scheme for improvement
and/or recalibration, as efforts have focused
on advancing flood forecasting and warning
systems to improve the resilience of the
services we deliver across Scotland. For
details on improvements to SEPA’s flood
forecasting and warning service, see the
'Other Actions' section.
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Buckie and
Portessie
45501 Flood scheme or
works design
The selected preferred
approach for managing flood
risk is to be designed
following the completion of
the flood study, including
consideration of the long-
term impacts of climate
change. These can include
small scale works or works to
improve catchment
management. This should
guide adaptive planning to
allow for the impacts of
climate change to be
monitored, understood and
managed. 
Moray
Council
RED This action was subject to funding
agreements being in place for Cycle 2 Flood
Schemes. At present, there is no indication of
when funding will be made available.
Therefore, it is unlikely that this action will be
completed within the timeframe originally
highlighted.
Buckie and
Portessie
45502 Flood scheme or
works
implementation
The flood scheme/works is to
be built following agreement
of the design, costs and
timescales.
Moray
Council
RED This action was subject to funding
agreements being in place for Cycle 2 Flood
Schemes. At present, there is no indication of
when funding will be made available.
Therefore, it is unlikely that this action will be
completed within the timeframe originally
highlighted.
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Buckie and
Portessie
45503 Flood scheme or
works design
The selected preferred
approach for managing flood
risk is to be designed
following the completion of
the flood study, including
consideration of the long-
term impacts of climate
change. These can include
small scale works or works to
improve catchment
management. This should
guide adaptive planning to
allow for the impacts of
climate change to be
monitored, understood and
managed. 
Moray
Council
RED This action was subject to funding
agreements being in place for Cycle 2 Flood
Schemes. At present, there is no indication of
when funding will be made available.
Therefore, it is unlikely that this action will be
completed within the timeframe originally
highlighted.
Buckie and
Portessie
45504 Flood scheme or
works
implementation
The flood scheme/works is to
be built following agreement
of the design, costs and
timescales.
Moray
Council
RED This action was subject to funding
agreements being in place for Cycle 2 Flood
Schemes. At present, there is no indication of
when funding will be made available.
Therefore, it is unlikely that this action will be
completed within the timeframe originally
highlighted.
Buckie and
Portessie
45505 Community
engagement
Community engagement is
to continue to be carried out
in the area by the responsible
authorities to raise
awareness of flood risk. 
Moray
Council
GREEN Moray Council has undertaken two
community engagement events in this area—
one focused on the implementation of the
Coastal Adaptation Plan and another on
Property Level Protection. We will continue to
carry out engagement activities as and when
appropriate.
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Buckie and
Portessie
45506 Sewer flood risk
assessment 
The volume of water that
would overwhelm the sewer
system and cause flooding
from manholes or inside our
homes is to be assessed, to
support understanding of the
performance of the urban
drainage network 
Scottish
Water
AMBER This action is on course to deliver within Cycle
2, however the programme of studies has
been delayed due to data sharing challenges.
This is due to a requirement to ensure
consistency of assessment by using the same
underlying datasets as SEPA's updated pluvial
mapping project.
Buckie and
Portessie
45507 Surface water
management
plan
Areas at risk of heavy or
prolonged rainfall causing
flooding due to water
ponding on man-made
surfaces or overwhelming
the drainage system have
been identified. Next steps in
managing such water
ponding or over-whelmed
drainage systems have been
identified and should be
implemented. The plan is to
be reviewed and updated as
needed.  
Moray
Council
GREEN We will continue to review the Surface Water
Management Plans following significant
events to determine their ongoing
appropriateness.
Buckie and
Portessie
45508 Strategic
mapping
improvements
SEPA will continue to update
flood maps based on new
information. 
SEPA GREEN The coastal flood hazard maps for the Outer
Hebrides and northeast Scotland were
updated and published in November 2023.
This action is complete.
Buckie and
Portessie
45509 Flood warning
maintenance
The Floodline flood warning
service is to be kept
operational through
maintenance to the existing
system and updates being
undertaken as required. 
SEPA GREEN SEPA will continue to maintain the flood
warning service.
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Report to: Economic Development
and Infrastructure
Services Committee 
Meeting Date: 11 November 2025  
Report by: Executive Director
Economy, Enterprise and
Operations 
Author: Paul Wolverson  Contact
Email:
paul.wolverson@moray.gov.uk 
Subject: Overnight Stays by Campervans and Motorhomes 
1.  PURPOSE 
☒ For Decision      ☐  For Information 
1.1  The purpose of this report is to inform members of the outcome of the public consultation
and seek approval on the direction of travel with regards introducing an overnight stay
initiative for campervan and motorhomes at designated sites in Moray. 
1.2  This report is submitted to Council in terms of Section III (F) (11) of the Council's Scheme
of Administration relating to exercising Council functions in relation to Open Spaces and
section (28) the promotion of tourism in Moray. 
2.  SUMMARY  
2.1  On 4 February 2025 Members of this committee approved that a public consultation
exercise be undertaken with regards the introduction of an overnight stay scheme for
campervans and motorhomes at certain designed sites across Moray. 
2.2 This reports sets out the results of the public consultation and ask Members to decide on
the direction of travel with regards the introduction of an overnight stay scheme. 
3.  RECOMMENDATIONS – 
3.1  The Committee is asked to:   
i)  Consider and note the contents of this report and the outcome of the public
consultation 
ii)  Consider the options in section 10 and Approve Option 3, the implementation
of a 12 month pilot at Burghead  
Item 7.
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iii)  Approve that the findings of the pilot are reported back to this committee to
assist in the future decision-making process and next steps with regards an
overnight stay initiative       
Author Name: Paul Wolverson
Job Title: Service Manager, Environmental Services 
4.  BACKGROUND AND CONTEXT  
4.1  A report was presented to this committee on 4 February 2025 (para 6 of the minute
refers) regarding the proposal to introduce an overnight stay initiative for campervan
and motorhomes at designated sites across Moray. A link to the report is shown here. 
4.2  Committee approved that a public consultation exercise be undertaken to gather the
views on the proposal, with the outcome of the consultation being reported to
committee to inform the decision-making process, and potential next steps, with
regards the initiative.    
5. THE PROPOSED SCHEME  
5.1 If an overnight scheme were to be introduced, it is proposed that the scheme would
follow the principles outlined below: 
• Overnight parking only 
• Only self-contained motorhomes/campervans with onboard facilities will be
allowed to use the sites 
• Restricted to one night only 
• There would be no provision of waste disposal points 
• Setting up of benches, chairs and awnings would not be permitted 
• Overnight parking charges of £7
• Overnight hours relate to 6pm to 10am 
• Restriction on the number of overnight campervan spaces
• Signage erected to signpost site users to local waste facilities and campervan
sites 
5.2 Dependant on the option selected, there will be the ability to review these principles
to ensure they remain appropriate. One such opportunity would be as part of
evaluating the outcome of a pilot scheme, if that option is selected.    
6. PROS AND CONS OF HAVING A SCHEME IN PLACE FOR OVERNIGHT STAYS AT
DESIGNATED SITES  
6.1 The pros and cons associated with having a scheme in place for overnight stays for
campervan and motorhomes are shown in the table below: 
Pros Cons
The responses from the
consultation were supportive of
introducing a scheme
May increase visitor numbers which
some residents may not like
Would mean the Council has a formal
scheme and designated parking for
Would restrict the availability of car
parking spaces for other site users
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overnight stays for campervan and
motorhomes
Would provide tourists with dedicated
sites to plan their journeys
Potential costs associated with
implementing an overnight stay scheme
include: signage, white lining
Provision of designated overnight
parking could attract visitors to an area
so boosting the local economy
Could increase workload for other
Council teams, i.e. setting up Car
Parking Orders, Enforcement of non-
payments
Could generate income for the Council
which could be used to support or
finance monitoring of the scheme
Payment would be by card only so the
method of payment would be limited
Potential to include designated sites into
the Councils current mobile app for
making car park payments
Might increase demand on services if
infrastructure or resources aren’t there
to support a new approach - e.g. waste
management, maintenance of car parks,
toilets, water supply etc 
Scheme would be limited to only a small
number of suitable sites 
7. ENFORCEMENT  
7.1 It is proposed that if an overnight parking initiative of some sort is introduced, payment
will initially be made on a voluntary basis by the user.  There will be no enforcement
against non-payments.    
7.2. In order to be able to take enforcement action against non-payment for parking, a car
parking order must be placed on the site. To be able to place a car parking order on a
site, there is a formal Car Parking Order consultation and approval process which
would need to be undertaken. 
7.3 Whilst income would be generated from any enforcement of non-payments from
overnight stays, if the primary purpose is to balance community interest and tourism,
and payment in the first instance is reliant on goodwill rather than enforcement, it is
proposed that seeking car parking orders is a secondary consideration of the scheme,
if a scheme or pilot is introduced.    
7.4 It should therefore be noted that at this stage, no matter which option is implemented,
the current position of not being able to take any enforcement regarding overnight
parking, at any Council car park without a car parking order, remains in place, and the
reliance of advisory signage is the preferred mechanism to address any issues with
non-authorised overnight parking.      
8.  COST IMPLICATIONS  
8.1 As reported in the original report on 4 February 2025 there are associated cost
implications with introducing and setting up an overnight scheme at all the proposed
locations.   The estimated set up costs for an overnight scheme across the sites
outlined in the original February report are shown below: 
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Element Cost
Signage £9,000
Demarcation of spaces £2000
Total £11,000 
8.2 However, if a pilot is introduced at Burghead, the costs can be met within existing
budgets, and using existing infrastructure such as the car park payment app.  Any
income derived from the scheme would be used to off set the cost associated with
production and installation of signage, or other associated maintenance costs during
the pilot period.    
9. SUMMARY OF CONSULTATION RESPONSES  
9.1 The public consultation ran from 15 April 2025 to 16 May 2025. A total of 2262
responses were received, with 1096 responses being received from people who
indicated that they live in Moray. A copy of the of the results is shown in the Appendix. 
9.2  For analysis purposes, the consultation responses were broken down into two
categories, these being Moray Resident Responses and the Non-Moray resident
responses.   The key points to extract from the consultation are as follows: 
• 74.47% of Moray residents responses and 95.15% of non-resident responses
supported the introduction of an overnight stay scheme (question 8)
• 87.18% of Moray resident responses and 90.76% of non-resident responses
stated that there should be a charge if a scheme is introduced (question 17)
• 54.02% of Moray resident responses and 73.88% of non-resident responses
indicated that a charge of £7 seems appropriate (question 18) 
• 68.56% of Moray residents responses and 73.78% of non-resident responses
indicated that the proposed overnight period of 6pm to 10am was appropriate
(question 20)
• 62.32% of Moray residents responses and 50.61% of non-resident responses
stated that restricting the overnight stay to one night was appropriate (question
22)
• 55.03% of Moray residents and 91.54% of non-resident responses indicated
that the introduction of an overnight scheme would encourage them to visit the
area (question 27) 
10. OPTIONS 
10.1 The options considered available are shown below: 
Option
Number
Option
1 Do not implement a formal overnight stay scheme
2 Implement the scheme across suitable sites in Moray
3 Implement a 12 month pilot scheme at Station Road car park, Burghead   
10.2 The responses from the consultation showed a majority support for the introduction of
an overnight stay initiative, though concerns were raised relating to matters such 
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environmental issues or uptake if payments are voluntary.  It is therefore recommended
that before any wholesale roll out of an overnight scheme is considered, that a pilot
scheme is introduced to allow monitoring and further assessment of both the positive
aspects, and the negative, associated with an overnight stay initiative.     
10.3 It is proposed that a pilot is run at Station Road car park, Burghead during 2026/27. The
site is selected on the following basis: 
• This site has waste facilities already located nearby at Burghead Harbour.  
• The costs associated with introducing the trial at Burghead can be met within
existing budgets. 
• Off the 83 responses received from residents who indicated they reside in
Burghead, 70% indicated that they support the introduction of a formal overnight
stay scheme.  
• Burghead and Cummingston Community Council have confirmed that they are
supportive of a pilot being trialled. 
11. REVIEW OF PILOT AND REPORT BACK 
11.1 If a pilot is implemented, in order to inform the future direction of an overnight stay
initiative it is important to be able to evaluate the successes, any learning and any
negative aspects from the pilot.  To assist with this process, a series of indicators will be
monitored during the period April 2026 to November 2026.  This period has been
selected as it viewed as the peak period for campervan users, but also, this will allow
information to be reported back to committee in time for any decision to be made with
regards an overnight stay initiative for the following year (2027/28). 
11.2 The following indicators will be included to measure the outcome of the pilot: 
• Income generated
• Number of public complaints received related to the initiative, such as littering,
noise, car parking availability, non-compliance with scheme principles.
• Number of compliments received regarding the pilot
• Any feedback from users
• Any feedback from the community 
• Observational feedback from waste and open spaces teams regarding litter,
waste or site maintenance     
• Observational accounts of the number of campervans on site. There are
insufficent resources to undertake this as a dedicated task, so monitoring will
only be done by staff when in the area and as part of their routine works.   
11.3 Any factors or new indicators that emerge during the pilot period will also be included in
the analysis. 
11.4 Following the conclusion of the pilot, a further report will be brought to this committee
outlining the findings from the pilot exercise.  This information can then be used to inform
the decision-making process with regards any wider roll out of an overnight initiative. 
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12. SUMMARY OF IMPLICATIONS 
12.1 The table below shows whether risks and implications apply if the recommendations are
agreed: 
SUBJECT YES NO
Corporate Plan and 10 Year Plan (Local Outcome Improvement Plan)  X
Policy and Legal X 
Financial X 
Risk X 
Staffing  X
Best Value and Transformation X 
Property  X
Information Communications Technology/Digital            X
Equalities. Social Inclusion and Economic Impact              X
Climate Change and Biodiversity Impact             X 
12.2 Corporate Plan and 10 Year Plan (Local Outcomes Improvement Plan (LOIP))
Improved Collaborative Leadership, as part of continuous improvement through Best
Value, will better enable the Council to fulfil the ambitions set out in its strategic plans. 
a) Links to Council Corporate Plan – The proposals in this report support and contribute
to improved outcomes for communities as outlined in the following Council Plan
strategic priorities:
☐ Tackle Poverty and Inequality.
☐ Build Stronger Greener Vibrant Economy.
☐ Build Thriving, resilient, empowered Communities.   
b) Links to Local Outcomes Improvement Plan – The proposals in this report support
and contribute to improved outcomes for communities as outlined in the following
Local Outcomes Improvement Plan priorities:
☐ Developing a diverse, inclusive, and sustainable economy
☐ Building a better future for our children and young people in   Moray.
☐ Empowering and connecting communities.
☐ Improving wellbeing of our population 
12.3 Policy and Legal 
The report sets out an approach to balance different policy interests regarding building a
stronger economy, encouraging tourism, and our approach to places and communities. 
12.4 Financial 
Any financial implications relating to this report are dependent upon the option selected. 
As set out in the report, if the decision is that a pilot is introduced there will be no budget
pressure created as costs can be met from within existing budgets. The income generated
from the pilot will be used to contribute to the cost of the signage and /or any associated
costs of the pilot . If the scheme is expanded further, then additional funding, as shown in
section 8 (cost implications section) will need to be approved by Council. 
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One off Costs:
Service
Area
Budget Budget
Years
Proposed
Spend this
Year
Virement
From
Other
Comments       
Annually Recurring Costs:
Service
Area
Budget With
Effect
From
Annual
Net
Impact
Virement
From (if
applicable)
Other
Comments       
12.5  Risk 
The risk implications arising directly from this report are that the results of the
consultation are not unanimous across communities with regards to whether overnight
stays are considered acceptable within an area.   
Without a clear and consistent position on campervan/motorhome overnight stays we
will not have a management framework in place to manage this issue and to support
communities dealing with the increase in motorhome activity. 
12.6 Staffing 
There are no staffing implications arising directly from this report. Although there could
be resource and staffing implications in the future dependant, upon whether a formal
policy is adopted, and how this is monitored and managed  
12.7 Best Value and Transformation 
Supporting local tourism in accordance with the views of local resident does meet the
criteria for Best Value and Transformation. 
12.8 Property 
There are no material property implications arising from this report.  
12.9 Information Communications/Technology/Digital 
There are no Information Communications/Technology/Digital implications arising from
this report.  The system used to take and process voluntary payments is an existing
system within the Council. 
12.10 Equalities, Social Inclusion and Economic Impact 
Concerns relating to blue badge holders were referenced in the public consultation. 
Given the sites identified will still provide adequate parking for other users, it is
considered that there will not be any equalities or social inclusion impact. 
The introduction of a formal overnight scheme may encourage tourism and by association
improved economic benefits to an area.  
12.11 Climate Change and Biodiversity Impacts 
There are no specific climate change or biodiversity impacts arising from the report
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13. CONSULTATION  
13.1 This report has been prepared in consultation with Executive Director Economy, Enterprise
and Operations, Head of Operations and Environment, Chief Financial Officer, Service
Manager: Legal Services, Open Spaces Manager, R Geddes-Stewart, Senior HR Adviser,
Equal Opportunities Officer, and L Rowan, Committee Services Officer and any comments
made have been incorporated into the report.  
14. BACKGROUND PAPERS  
14.1 Report to ED&I Committee on 4 February 2025 
Appendix 1 
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Report to: Economic Development
and Infrastructure
Services Committee 
Meeting 
Date:
11 November 2025  
Report by: Executive Director
Economy, Enterprise and
Operations 
Author: Nicola Moss and
Beverly Smith
Contact
Email:
nicola.moss@moray.gov.uk 
beverly.smith@moray.gov.uk 
Subject: Operations and Environment and Growth, Planning and Climate 
Capital and Revenue Budget Monitoring to 30 September 2025 
1.  PURPOSE 
☒ For Decision      ☐  For Information 
1.1  The purpose of this report is to scrutinise and note the quarter one and quarter two
position of 2025/26 regarding Operations and Environment and Growth, Planning and
Climate Revenue and Capital budgets.  
1.2  This report is submitted to Committee in terms of Section III (A) (2) of the Council’s
Scheme of Administration relating to the consideration of Revenue and Capital budgets
and long term financial plans.  
2.  SUMMARY  
2.1  This report provides an update on the quarter one and quarter two budgetary position
2025/2026 and comments on variances for the Revenue and Capital budgets for the
period to 30 September regarding Operations and Environment and Growth, Planning and
Climate, Revenue and Capital budgets. 
3.  RECOMMENDATIONS 
3.1  It is recommended that Committee scrutinise and note the quarter one and quarter
two budget position for 2025/2026. 
Nicola Moss, Head of Operations and Environment 
Item 8.
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Beverly Smith, Head of Growth, Planning and Climate (Chief Planning Officer)   
4.  BACKGROUND AND CONTEXT  
4.1  The Performance Management Framework 2020 (page 27) requires that progress against
Capital and Revenue expenditure and the Capital Plan is reported to the relevant Service
Committee.  Heads of Service have been tasked with reducing overspends and generally
reducing expenditure back in line with budget. 
4.2  Savings and increased charges to the Revenue budget were approved when the budget
was set by Moray Council on 26 February 2025 (paragraph 3 of the minute refers).  Updates
have gone to Moray Council quarterly as part of the full budget monitoring.  
5.  Q1 and Q2 REVENUE BUDGET PERFORMANCE  
5.1  Operations & Environment 
Quarter 1 results are often impacted by timing issues, and the position at Quarter 2 shows
that overall the services are within budget. The detail of Q1 is set out in Appendix 1. 
5.2  The table below shows Operations and Environment Revenue Budget position for Q2
2025 / 2026.  
Service Area ANNUAL
BUDGET
Q2 BUDGET Q2 ACTUAL+
COMMITTED
VARIANCE 
£000s £000s £000s £000s
Environmental
Services
19,085 8,972 8,857 115
Roads and Fleet 3,749 1,346 1,258 88
Engineering
Design
1,079 544 661 -117
Harbours and
Transportation 
6606 2750 2599 151
Operations and
Environment -
Directorate
219 112 108 4
Operations and
Environment -
Efficiency
savings
-539 0 0 0
Operations and
Environment 
Admin / Support
/H&S
543 286 266 20
Total 30,742 14,010 13,748 261
Underspend 
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5.3  Environmental Services 
The table below show Environmental Services Revenue Budget information for Q2 2025
/2026. 
Service
Area
Annual
Budget
Q2 Budget Q2 Actual +
Committed
Variance 
£000s £000s £000s £000s
Waste
Management 
8,847  4,092  4,036  56
Open Spaces 1,899 887 881 6
Building
Cleaning and
Catering
8,839 3,993 3,940 53
Total 19,085 8,972 8,857 115
Underspend 
5.4  Waste is underspent in quarters 1 and 2 by £57K. Tipping income (£70K overspend), Trade
Waste income (£29K overspend) and Green Waste income (£32K overspend) are currently
not meeting target. However recycling net income is higher due to a favourable recycling
market (£79K underspend) and the income from Dallachy gas is above budget (£10K
underspend).  Fuel costs are also less than budgeted (£91K underspend) with a
contributing factor to this being the cessation of using the BOMAG compactor at Dallachy
Landfill. 
5.5  Open Spaces  are currently achieving a slight underspent of £6,000 over quarters 1 and 2.
Income from areas such as burials are currently below target (£87,000 overspend) but this
could be due to budget profiling and the situation will be monitored over the remaining
quarters.  This overspend has been off-set by underspends in other areas such as staffing
and property costs over Open Spaces.  The impact of dealing with Storm Floris and Amy
may also impact on the budgetary position over the remaining quarters with works to
address tree damage still on-going. 
5.6  Building Catering and Cleaning are currently underspent by £53,000. The underspend over
quarters 1 and 2 has been achieved mainly due to favourable income against the budget
from the secondary school meals. The situation will continue to be monitored throughout
the remaining quarters. 
5.7  Savings position at Q2  2025/2026 
Red Saving not taken and won’t be achieved this year- if slipped into
future years details given
Amber  Saving not taken and uncertain if it will be achieved in full this year
Green Saving taken, or will be taken, in full 
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Description Amount Posted  Balance Status* Reason for balance
Approved when
2025/2026 budget
set
£000s  £000s  £000s   
Waste
Management-
Dallachy
-630 0 -630  Capping undertaken
during both Q1/Q2. 
Review of budgets to
follow in Q3 to
establish saving
figure to be posted.  
Waste Management
– Reduce HWRC
(Household Waste
Recycling Centre)
opening hours 
(close 1 weekday)
-50 -22 -28  Original template
suggested a number
of sites would close
but this proposal was
reduced. Full saving
will not be met.
Waste
Management-
Close Dallachy
HWRC
-10  -10 0  N/A
Waste
Management-
Dallachy Closure
-30 0 -30  To be reviewed along
with £630k above in
Q2
Open Spaces – full
cost recovery from
HRA (housing
revenue account) of
inspection of play
areas
-28 -18 -10  £18k taken in Q2. 
£10k currently being
retained.   
5.8  Roads Maintenance and Fleet Services 
The table below shows Roads and Fleet Revenue Budget information for Q2 2025/2026. 
Service
Area
Annual Budget Q2 Budget Q2 Actual +
Committed  
Variance 
£000s £000s £000s £000s
Roads
Management
5252 1895 2026 -131
Fleet Services  -1503 -549 -768 219
Total 3,749 1,346 1,258 88
Underspend 
5.9  The projected £131K overspend at Q2 within the roads management budget relates to
works that have been identified for repair and show as committed against the budget. Not
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all of these works will be completed to date and some will be work in progress. This will be
closely monitored through Q3 and Q4 to ensure no overspend occurs. 
5.10  There is currently a reported £219k over recovery within fleet services. This relates to
timing of internal fleet charges against service budgets. The recharges are currently being
reviewed to ensure over recovery is accounted for. 
5.11  Savings position at Q2   2025/2026 
Red Saving not taken and won’t be achieved this year- if slipped into
future years details given
Amber  Saving not taken and uncertain if it will be achieved in full this year
Green Saving taken, or will be taken, in full 
Description Amount Posted  Balance Status* Reason for balance
Approved when
2025/2026 budget
set
£000s  £000s  £000s   
Roads Management
– Roads
Maintenance hire
out of machinery
-50 0 -50  New machine was
late arriving due to
supply chain issues.
Initial Interest from
other LA’s has not
materialised to date.
Fleet – Lease
Specialist Vehicles 
-76 0 -76  It is unlikely that this
will achieve savings
this financial year but
a full review is in
progress.
Roads Management
– Gully Cleaning
-50 0 -50  This saving will be
achieved 25/26.
Roads Management
– Street Lighting
-50 -42 -8  Small variance,
however £42k saving
achieved to date.
Fleet – Restructure
DAR 
0 -24 24  N/A 
5.12  Design Consultancy 
The table below shows Design Consultancy Revenue Budget information for Q2
2025/2026. 
Annual Budget Q2 Budget Q2 Actual + 
Committed
Variance
£000s £000s £000s £000s                                        
1,079 544 661 -117
Overspend 
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5.13  The revenue budget for Engineering Design shows a £117k overspend, this principally
relates to the rate of recharging staff time to capital, and early spend on infrastructure
maintenance. At this stage the team is forecasting a balanced outturn at year end. 
5.14  Harbours and Transportation 
The table below shows Transportation and Harbours Revenue Budget information for Q2
2025/2026. 
Service
Area
Annual Budget Q2 Budget Q2 Actual +
Committed
Variance 
£000s £000s £000s £000s
Harbours and
Traffic and
Transportation
Management
6,606 2,750 2,599 151
Underspend 
5.15  There is an overall underspend of £151,000 at the end of Q2 primarily as a result of quarter
1 showing advance income from Harbour operations (film set income) and increased
income from road closures, street occupations and internal minibus hires.  The spend
profile for the remaining quarters will continue to be monitored as within the detail there
are some areas where budgets are not being met – including car park income.   
Growth, Planning and Climate
5.16  
Service
Area
Annual Budget Q2 Budget Q2 Actual +
Committed
Variance 
£000s £000s £000s £000s
Economy and
Enterprise
883 1,016 1,015 1
Strategic
Planning and
Development
122 (57) (57) 0
Moray Growth
Deal
158 84 82 2
Total 1,163 1,043 1,040 3 
5.17  The  Q1 & Q2 variance in Growth, Planning and Climate consists of a number of minor
timing variances with no issues to report.    
CAPITAL BUDGETS 
5.18  Environmental Services   
Project Capital 
Budget
2025/26
Q1
Forecast
Q1
Actual
Q2
Forecast
Q2
Actual
Q2
Variance
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£000s £000s £000s £000s £000s £000s
Waste Mgt      
Dallachy
Landfill site
final capping
1,368  20 20 870 940 -70
Upgrade
Recycling
Centres
(building)
40 12 12 0 0 0
Upgrade
Recycling
Centres 
(equipment)
25 25 25 0 0 0
Domestic
and Trade
Waste Bins
63 -23 -23 17 17 0
NESS Energy
from Waste 
150 0 0 0 0 0
Project Capital 
Budget
2025/26
Q1
Forecast
Q1
Actual
Q2
Forecast
Q2
Actual
Q2
Variance
Open
Spaces      
Cemetery
Provision in
Elgin
3,334 69 69 1,557 453 1,104 
Cemetery
Provision in
Moray
0 5 5 0 1 -1
Parks and
Open Spaces
Infrastructure 
0 0 0 0 0 0
Children’s
Play Areas 
(Scottish
Government
funded)
659 3 3 207 203 4
TOTAL  5,639 111 111 2,651 1,614 1,037 
5.19  The final capping works at Dallachy were concluded in Q2. Whilst showing an overspend in
Q2, the overall works will be within the full year budget. 
5.20  The upgrade of the recycling centre relates primarily relates to upgrading the access and
vehicle parking at Moycroft. The land has now been purchased, and the waste service is in
correspondence with Transportation on the design works for the access. It is currently
estimated that construction works will take place in quarter 4 of 2025/26. 
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5.21  New skips have been purchased for the HWRC sites using the available budget.  The
remaining budget for purchasing domestic and trade bins will be spent in the remaining
quarters of 2025/26.   
5.22  The construction work for Elgin Cemetery is on track for completion by December 2025. 
This will allow for a 12 month period for settlement before the cemetery is required for
burials (currently projected to be circa quarter 4 of 2026/2027).  The underspend in quarter
2 is a combination of delays in billing and value engineering exercises. 
5.23   As previously reported to this committee on 29 April 2025, due to the incorrect application
of capping at the beginning of the financial year, there is currently no budget allocation for
the cemetery provision in Moray or parks and open spaces infrastructure.  It is anticipated
that this will be addressed by Finance in quarter 3, and there will be a reinstatement of the
budget.  The budget will then be used, in part, to address the small amount of spend
currently showing in the cemeteries budget for quarters 1 and 2.  
5.24  The upgrade of the play areas is on track in accordance with the planned scheduled.
Further spend will be incurred in quarters 3 and 4 .  Whilst orders will be committed in
2025/26, installation timelines will mean that completion of the main play areas
scheduled for an upgrade in 2025/26 will be completed in 2026/27. 
5.25  Roads Maintenance and Fleet Services Capital   
Project Capital
Budget
2025/
2026
Q1
Forecast
Q1
Actual
Q2
Forecast
Q2
Actual
Q2
Variance 
£000s £000s £000s £000s £000s £000s
Roads
Improvements      
Carriageway
resurfacing/
reconstruction /
surface dressing
2,465 330 330 1,908 1,661 247
Drainage and
other works
270 37 37 15 8 7
Footways  50 9 9 9 19 -10
Street Lighting      
Street Lighting  522 67 67 154 274 -120
Fleet      
Vehicle
Replacement
Programme
2,361 352 352 690 888 -198
MOT Spend to
Save 
50 50 50 0 -1 1
TOTAL 5,718 845 845 2,776 2,849 -73 
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5.26  There is a £247k variance against the carriageway resurfacing/reconstruction and surface
dressing budget. This variance is attributed to timing of works being completed and claims
being progressed through the financial accounts. Programmes of work for the total budget
of £2,465m have been developed and communicated and it can be reported with
confidence that this budget will be fully spent at end of Q4. 
5.27  There is little spend in Q2 against the drainage and other works budget as this relates to
drainage/ditching works which are historically completed in the winter months. This is to
allow staff resources to focus on completing the resurfacing works during the summer
months. 
5.28  The footway budget is reporting a £10k overspend at Q2. One of the identified schemes
has been completed earlier, in conjunction with a carriageway scheme. It is projected the
£50k budget will be spent at the end of Q4. 
5.29  The street lighting column replacement budget is reporting an overspend of £120k. The
programme has been accelerated to make use of the summer weather. Resources will be
diverted onto revenue maintenance repairs and annual testing programme during the
winter months. It is not predicted to overspend at year end. 
5.30  Design Consultancy  Capital  (including Harbours Infrastructure) 
Project Capital
Budget
2025/26
Q1
Forecast
Q1
Actual
Q2
Forecast
Q2
Actual
Q2
Variance 
£000s £000s £000s £000s £000s £000s
Bridges      
A941/340 New
Bishopmill
Bridge
420 4 4 46 5 41
B9015/30
Sourden
0 0 0 0 0 0
U57H/11 South
Arndilly
0 0 0 0 0 0
Removal of
Footbridges
0 0 0 0 0 0
Blackhills
Culvert
335 71 71 19 293 -274
Sanquhar Loch
Footbridge
0 0 0 0 0 0       
Road
Improvements      
B9016 Landslip
Repair
65 0 0 33 3 30
C1H Landslip 345 1 1 100 8 92
Glenlivet 70 0 0 17 18 -1
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15 Main St
Buckie retaining
wall
30 0 0 17 0 17
Buckie North
Street Wall
150 0 0 7 37 -30
Landslip
Feasibility
Studies
23 0 0 0 10 -10
A939 Landslip
Creag
Chalcaidh
Quarry
175  137 137 0 0 0       
Flood Risk and
Coastal Mgt      
Coastal
Adaption Plan
20 0 0 0 0 0
Coastal
Adaption Plan –
Real Time
Monitoring
102 13 13 53 44 9
Anti Tank
Assessment
36 0 0 0 0 0
Project Capital
Budget
2025/26
Q1
Forecast
Q1
Actual
Q2
Forecast
Q2
Actual
Q2
Variance
Lossiemouth
Christmas
Trees- Phase 2
19 1 1 0 0 0
Development of
Simple
Assessment
Guide
23 1 1 9 10 -1
Cullen Seawall
assessment
75 0 0 36 0 36
Millbuies
drawdown
75 0 0 1 0 1
Findhorn
Coastal Erosion
10 10 10 0 0 0       
Harbours      
Navigation Light
Buckie Harbour
125 0 0 125 109 16
West Pier
Buckie Harbour
0 0 0 0 0 0
Buckie
Weighbridge
22 21 21 1 0 1
Pier 1 joints 124 0 0 13 16 -3
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Harbour Capital
life expired
243 0 0 109 7 102
Pontoons  33 0 0 0 0 0
Portknockie
North Pier Wall
114 0 0 88 100 -12
Portknockie
Middle Pier
Design
35 0 0 34 12 22
Cullen Viaduct
repairs
2 0 0 1 2 -1
Cullen West
Pier
49 0 0 0 0 0       
TOTAL  2,720  255  255  709           674  35 
5.31  Although there is only a small variance across all projects, there is a pressure with
Blackhills Culvert being significantly higher than estimated for budget purposes. The
timing of other projects is being adjusted along with managing underspends from other
schemes in order to deliver a balanced outcome at year end. 
5.32  Transportation Capital - The table below shows Transportation Capital Budget
information for 2025 /2026. 
Project Capital
Budget
2025/
2026
Q1
Forecast
Q1
Actual
Q2
Forecast
Q2
Actual
Q2
Variance 
£000s £000s £000s £000s £000s £000s
Car Parks      
Multi-storey car
parks
530 2 2 97 412 -315
Car Parks 22 0 0 0 0 0
Traffic      
Road Safety
Provision
70 0 0 30 9 21
Disability
Adaptions
40 3 3 12 16 -4
New Road
Signs and
Markings
45 8 8 20 10 10
Traffic data
Collection
Equipment
20 5 5 15 0 15
Traffic Signal
Replacement
72 0 0 22 14 8
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Active Travel      
Active Travel 500 0 0 145 108 37       
TOTAL 1,299 18 18 341 569 228 
5.33  Whilst there was no variance at Q1, projected expenditure for quarter 2  and quarter 3 is
significantly higher and as expected as capital spend commences on delivery of projects.
This spend profile will continue to be monitored throughout the remaining quarters to
ensure any variances are minimised. 
The largest variance in Q2 relates to spend associated with the waterproofing works at
Batchen Lane Car Park which has progressed at speed. This will result in lower spend in
later quarters as these works represent the majority of the budget available. Other smaller
variances relate to adjustment to the spend profile as works are awarded. This will
continue to be monitored. 
Growth, Planning and Climate Capital Budget 
5.34  Economy and Enterprise Capital – The table below shows Economy and Enterprise
Capital Budget information for 2025/2026 
Project Capital
Budget
2025/
2026
Q1
Forecast
Q1
Actual
Q2
Forecast
Q2
Actual
Q2
Variance
Funded Spend £000s £000s £000s £000s £000s £000s
Town Centre
Initiative Fund
(match funding
FCHS)  Forres
Conservation &
Heritage
Scheme
304 0 0 0 0 0
PBIF Place
Based
Investment
(match funding
for FCHS)
202 0 0 0 0 0
TOTAL 506 0 0 0 0 0 
5.35  Forres Conservation & Heritage Scheme (FCHS) is a 5-year delivery programme and no
spend is forecast in Q1 and Q2.  Capital spend will commence on delivery of projects. 
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5.36  Moray Growth Deal – The table below shows Moray Growth Deal Capital Budget
information for Q1 2025/2026. 
Project Capital
Budget
2025/
2026
Q1
Forecast
Q1
Actual
Q2
Forecast
Q2
Actual
Q2
Variance 
£000s £000s £000s £000s £000s £000s
Moray Growth
Deal
10,855 1,498 1,498 1,190 1,006 184 
5.37  Underspend variance is a result of delays experienced moving the Business Enterprise
Hub delivery as this has slipped from Q2 meaning the project was unable to submit a Q2
claim and planned Digital Health expenditure moving between quarters in the financial
year. 
6.  SUMMARY OF IMPLICATIONS 
6.1  The table below shows whether risks and implications apply if the recommendations are
agreed: 
SUBJECT YES NO
Corporate Plan and 10 Year Plan (Local Outcome Improvement Plan)  X
Policy and Legal  X
Financial            X 
Risk           X 
Staffing  X
Best Value and Transformation  X
Property  X
Information Communications Technology/Digital  X
Equalities. Social Inclusion and Economic Impact  X
Climate Change, Biodiversity and Sustainability  X 
6.2  Corporate Plan and 10 Year Plan (Local Outcomes Improvement Plan (LOIP))
Improved Collaborative Leadership, as part of continuous improvement through Best
Value, will better enable the Council to fulfil the ambitions set out in its strategic plans. 
a) Links to Council Corporate Plan – The proposals in this report support and contribute
to improved outcomes for communities as outlined in the following Council Plan
strategic priorities:
☐ Tackle Poverty and Inequality.
☐ Build Stronger Greener Vibrant Economy.
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☐ Build Thriving, resilient, empowered Communities.   
b) Links to Local Outcomes Improvement Plan – The proposals in this report support
and contribute to improved outcomes for communities as outlined in the following
Local Outcomes Improvement Plan priorities:
☐ Developing a diverse, inclusive, and sustainable economy
☐ Building a better future for our children and young people in   Moray.
☐ Empowering and connecting communities.
☐ Improving wellbeing of our population 
6.3  Policy and Legal 
There are no policy or legal implications arising directly from this report.  
6.4  Financial 
The financial implications are highlighted within the report. 
One off Costs:
Service
Area
Budget Budget
Years
Proposed
Spend this
Year
Virement
From
Other
Comments
N/A N/A N/A N/A N/A N/A 
Annually Recurring Costs:
Service
Area
Budget With
Effect
From
Annual
Net
Impact
Virement
From (if
applicable)
Other
Comments
N/A N/A N/A N/A N/A N/A 
6.5  Risk 
Budget managers are aware of their responsibilities for managing budget allocations and
approval for variance will be sought from Committee in line with the Financial Regulations.  
6.6  Staffing 
There are no staffing implications arising from this report.  
6.7  Best Value and Transformation 
There are no Best Value and Transformation implications arising from this report.  
6.8  Property 
There are no Property implications arising from this report.  
6.9  Information Communications/Technology/Digital 
There are no Communications/ Technology/Digital arising from this report.  
6.10  Equalities, Social Inclusion and Economic Impact 
There are no equalities implications arising from this report because the report informs the
Committee on budget monitoring. Any identified savings proposals referenced in the repot
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will be subject to an individual integrated impact assessment (IIA) to identify any specific
impacts where relevant.  
6.11  Climate Change and Biodiversity Impacts 
There are no climate change or Biodiversity impacts arising from this report. Achieving net
zero will have significant implications for future planned capital expenditure. 
7.  CONSULTATION  
7.1  This report has been prepared in consultation with Executive Director Economy, Enterprise
and Operations, Head of Operations and Environment, Head of Growth, Planning and
Climate (Chief Planning Officer), Chief Financial Officer, Service Manager, Legal Services,
Equalities Officer, L Rowan, Committee Services Officer, R Geddes-Stewart, Senior HR
Adviser , Operations and Environment Management Team and Budget Managers.  Any
comments have been taken into consideration. 
8.  BACKGROUND PAPERS  
8.1  None.   
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Appendix 1 
Operations & Environment Quarter 1 Revenue Budget Position 
Service Area Annual
Budget
Q1 Budget Q1 Actual &
Committed 
Variance 
£000s £000s £000s £000s
Environmental
Services
18,853 3,596 3,581 15
Roads and Fleet 3,346 466 1,139 -673
Engineering
Design
1,077 298 329 -31 
Harbours and
Transportation 
6,219 1,163 1,014 149 
Operations and
Environment -
Directorate
213 52 50 2
Operations and
Environment -
Efficiency
savings
-791 0 0 0
Operations and
Environment 
Admin / Support
/H&S
528 144 140 4
Total 29,445 5,719 6,254 -535
Overspend 
Environmental Services – The table below show Environmental Services Revenue
Budget information for Q1 2025 /2026.
Service
Area
Annual
Budget
Q1 Budget Q1 Actual +
Committed
Variance 
£000s £000s £000s £000s
Waste
Management
8,832 1,198 1,198 0
Open Spaces 1,834 400 392 8
Building
Cleaning and
Catering
8,187 1,998 1,991 7
Total 18,853 3,596 3,581 15 
Underspend 
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Roads and Fleet – The table below shows Roads and Fleet Revenue Budget information
for Q1 2025/2026.
Service
Area
Annual Budget Q1 Budget Q1 Actual +
Committed  
Variance 
£000s £000s £000s £000s
Roads
Management
5,150 930 1,740 -810
Fleet Services  -1,804 - 464 -601 137
Total 3,346 466 1,139 -673
Overspend 
Engineering Design – The table below shows Engineering Design Revenue Budget
information for Q1 2025/2026.
Annual Budget Q1 Budget Q1 Actual + 
Committed
Variance
£000s £000s £000s £000s
1,077  298 329 -31 
Overspend 
Harbours and Transportation – The table below shows Harbours and Transportation
Revenue Budget information for Q1 2025/2026. 
Service
Area
Annual Budget Q1 Budget Q1 Actual +
Committed
Variance 
£000s £000s £000s £000s
Harbours and
Traffic and
Transportation
Management   
6,219  1,163  1,015  149
Underspend 
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Growth, Planning and Climate Quarter 1 Revenue Position 
The table below shows Revenue Budget information for Q1 2025/2026. 
Service
Area
Annual Budget Q1 Budget Q1 Actual +
Committed
Variance 
£000s £000s £000s £000s
Economy and
Enterprise
868 521 514 7
Strategic
Planning and
Development
13 7 7 0
Moray Growth
Deal
162 59 58 1
Total 1,043 587 579 8 
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Report to: Economic
Development and
Infrastructure Services
Committee 
Meeting
Date:
11 November 2025  
Report by: Executive Director Economy, Enterprise and Operations    
Author: Suzanne Wilson Contact
Email:
performance@moray.gov.uk 
Subject: Performance Report (Environmental and Commercial Services) –
Period to September 2025 
1.  PURPOSE 
☒ For Decision      ☐  For Information 
1.1  The purpose of this report is to scrutinise performance in areas of Service
Planning, Service Performance and other related data to the end of September
2025 and note actions being taken to improve performance where required.  
1.2  This report is submitted to Committee in terms of Section III (A) (4) of the
Council’s Scheme of Administration to monitor performance in accordance with
the Council’s Performance Management Framework.  
2.  SUMMARY  
2.1  At the end of September 2025, actions relating to the Environmental and
Commercial Services Service Plan for 2025-28 was 78% complete.  Progress
against Service Plan Priorities and operational Service Performance Indicators
is presented in the table and charts below. 
Item 9.
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3.  RECOMMENDATIONS  
3.1  It is recommended that Committee scrutinises and notes performance in
areas of Service Planning, Service Performance and other related data to
the end of September 2025 and note actions being taken to improve
performance where required   
Suzanne Wilson
Research and Information Officer 
4.  BACKGROUND AND CONTEXT  
4.1  Each service plan sets out the planned strategic and service level priorities
and outcomes it intends to deliver in the coming year aligning closely with
financial planning, corporate and community planning partnership strategic
priorities.   
4.2  Service Plan actions are weighted to reflect priority ratings.  Actions with higher
priorities receive greater weightings which contribute more to the overall
delivery of the Plan.  Progress on Service Plan priorities and outcomes and key
areas of operational performance is reported by exception, highlighting
successes and giving assurances around the challenges and actions to
support. Links to Service Plan Actions, priority ratings and weightings and
Performance Indicators can be accessed within the background papers
section of this report.  
4.3  Complaints are reported in terms of time taken to respond, outcomes and
learning points.  Links to Complaints tables can be accessed within the
background papers section of this report. 
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4.4  Latest Local Government Benchmarking Framework (LGBF) results for 2024/25
are published throughout the year with final refresh of data around June 2026. 
The full suite can be view via the LGBF Dashboard.  Published indicators for
this service have been incorporated with the relevant section of this report
depending on whether used to evidence progress against strategic, service
level or service performance priorities.  LGBF indicator targets and RAG status
in the backing tables is now based on ranking thresholds aligning with
exception reporting. 
4.5  The Sustainable Development Statement was approved by the Corporate
Committee on 5 November 2024 (para 16 of the Minute refers).  The Statement
draws out the way in which sustainable development is embedded in the
Corporate Plan 2024-29 and wider corporate policies, strategies, and plans
with progress being reported through several updates and reports, one of
which is quarter 4 performance reporting.  Service Plan actions and indicators
that underpin the delivery of Sustainable Development Goals are highlighted in
the backing table documents and comment where relevant is incorporated in
this report.  An overview of progress will be presented in the annual Corporate
Plan progress update. 
5.  PROPOSALS  
Successes – Service Plan Strategic and Service Level Outcomes and
operational Service Performance
5.1  Good progress has been made with the Bus Revolution project with all planned
milestones complete.  Recruitment challenges delayed the launch of the
weekend Speyside service (no. 691) however this is now expected to go ahead
in October.  In addition, work to support future public transport planning is
progressing with an evaluation of hidden demand and an AI simulation of
scope and costings. (Strategic Level Action ECS25-28 Strat 4.1) 
5.2  Following presentation of a business case to ECLT in June, agreement has been
reached that a Council owned Pool Car scheme is the most efficient operating
model.  To increase uptake, internal promotion of the scheme is planned
through the staff website and newsletter.  Clearer responsibility for the scheme
will also be achieved with a restructure of roles within the service.  (Service
Level Action ECS25-28 Serv 5.3.2) 
5.3  Consultation of the Buckie Harbour Masterplan, approved at the meeting of
this committee on 17 June 2025 (para 9 of the minute refers), is complete. 
Running for a period of four weeks, responses from key stakeholders such as
the Buckie Harbour Advisory Committee, local businesses and community
members and renewable sector representatives, were overwhelmingly
positive.  As delegated authority is already agreed, publication of this plan will
now go ahead alongside the commissioning of the socio-economic impact
assessment commencing in October.  (Service Level Action ECS25-28 Serv
5.4.1) 
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Challenges and actions to support – Service Plan Strategic and Service
Level Outcomes and operational Service Performance
5.4  Due to reporting deadlines, data on passenger journeys for m.connect services
is incomplete for quarter 2. While recorded passenger numbers in quarter 1
were below target, it is important to note that targets have recently been
revised following the launch of Phase 2 in May to reflect the increased service
availability. (Strategic Level PI ECSPT02) 
5.5  Competing work demands throughout the first half of 2025/26 have slowed
development of the planned Tree Strategy however assessments and proactive
works are underway at several parks in Keith, Buckie and Forres.  (Service Level
Action ECS25-28 Serv 5.1.4) 
5.6  Due to challenges around the allocated capital budget, the tender process for
construction of the new cemetery at Linkwood Road was delayed.  Following a
re-evaluation for additional funding, the contract was awarded during quarter 1
and construction of the Cemetery is now underway.  With a revised completion
date set for December 2025, and a period of ground settlement and site
establishment required, new interments are expected to be available from late
2026. (Service Level Action ECS25-28 Serv 5.1.5) 
5.7  Progress of the Coastal Adaption Plan is reported at 5% against a due date of
December 2025.  Initial drafting is complete with plans in place to finalise
content during quarter 3, ensuring the agreed deadline is met.  (Service Level
Action ECS25-28 Serv 5.2.6) 
5.8  Improving the efficiency and accuracy of Stores processes will progress out
with original completion date of September 2025.  A project mandate, covering
the required update to the Tranman system, has been shared with ICT as part
of the Business System Review process.  Work to progress this will continue
during the second half of 2025/26.  (Service Level Action ECS25-28 Serv 5.3.3) 
Complaints and MP/MSP Enquiries
5.9  Due to reporting timelines, quarter 2 complaint information is not yet available
therefore quarter 1 data is presented. 
5.10  A total of forty-six complaints were closed: 44 at Frontline and one at both
Investigative and Escalated stages.  The average response time for all stages
were well within Complaint Handling targets with Frontline complaints closed
within 2.91 days, Investigative within 15 days and Escalated within 17. 
5.11  21 complaints were Upheld or Part Upheld.  12 related to Household
Collections with complaints against staff and mess from refuse lorries most
common.  Staff have received reminders on customer service best practice
and the importance of cleaning vehicles correctly. 
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5.12  Environmental and Commercial Services received twenty-eight MP/MSP
Enquiries with twelve concerning Road Safety/Speeding in various locations
across Moray.  Other common issues were Play Parks, local Bus Services, Road
Conditions and Parking. 
Other Performance (not included in the Service Plan)
5.13  Nothing to report. 
Case Studies
5.14  Nothing to report. 
Consultation and Engagement
5.15  A well-attended Levelling Up Fund Active Travel consultation took place in July. 
Proposals for new Active Travel infrastructure linking the southern part of Elgin
to Cooper Park received support although concerns remain around parking,
traffic speed and antisocial driving.  Feedback received will be used to refine
the scheme proposals and has helped identify wider transport concerns and
ideas.   
5.16  Following confirmation of Scottish Government funding, proposals to
introduce 20mph speed limits within settlements across Moray, were
published on Moray Engage in August.  This engagement page will be kept open
for approximately 18 months whilst the temporary traffic orders are in effect. 
For the promotion of any permanent traffic orders after this date, a public
consultation will take place. 
6.  SUMMARY OF IMPLICATIONS  
6.1  The table below shows whether risks and implications apply if the
recommendations are agreed: 
SUBJECT YES NO
Corporate Plan and 10 Year Plan (Local Outcome Improvement Plan) X 
Policy and Legal  X
Financial  X
Risk  X
Staffing  X
Best Value and Transformation  X
Property  X
Information Communications Technology/Digital  X
Equalities. Social Inclusion and Economic Impact   X
Climate Change and Biodiversity Impact  X 
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6.2  Corporate Plan and 10 Year Plan (Local Outcomes Improvement Plan
(LOIP))
Improved Collaborative Leadership, as part of continuous improvement
through Best Value, will better enable the Council to fulfil the ambitions set
out in its strategic plans. 
a) Links to Council Corporate Plan – The proposals in this report support and
contribute to improved outcomes for communities as outlined in the
following Council Plan strategic priorities:
☐ Tackle Poverty and Inequality.
☒ Build Stronger Greener Vibrant Economy.
☒ Build Thriving, resilient, empowered Communities.   
b) Links to Local Outcomes Improvement Plan – The proposals in this report
support and contribute to improved outcomes for communities as
outlined in the following local Outcomes Improvement Plan priorities:
☐ Developing a diverse, inclusive, and sustainable economy
☐ Building a better future for our children and young people in  
Moray.
☒ Empowering and connecting communities.
☐ Improving wellbeing of our population 
6.3  Policy and Legal 
The Council has a statutory requirement to publish a range of information that
will demonstrate that it is securing best value and assist in comparing
performance both over time and between authorities where appropriate.  
6.4  Financial 
None arising from this report. 
6.5  Risk 
None arising from this report.  
6.6  Staffing 
None arising from this report.  
6.7  Best Value and Transformation 
How councils plan for, manage and report on performance is a key area of
focus in external audit work, particularly on best value.  
6.8  Property 
None arising from this report.  
6.9  Information Communications/Technology/Digital 
None arising from this report.  
6.10  Equalities, Social Inclusion and Economic Impact 
None arising from this report.
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6.11  Climate Change and Biodiversity Impacts 
None arising from this report. 
7.  CONSULTATION  
7.1  This report has been prepared in consultation with the Head of Operations
and Environment and relevant Service Managers and any comments made
have been incorporated. 
8.  BACKGROUND PAPERS  
8.1  Service Plan Actions
Service Plan Performance Indicators
Service Performance Indicators
Service Complaints 
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Page 131

Report to: Economic
Development and
Infrastructure Services
Committee 
Meeting Date: 11 November 2025  
Report by: Executive Director Economy, Enterprise and Operations    
Author: Suzanne Wilson Contact
Email:
performance@moray.gov.
uk 
Subject: Performance Report (Economic Growth and Development) – Period
to September 2025 
1.  PURPOSE 
☒ For Decision      ☐  For Information 
1.1  The purpose of this report is to scrutinise performance in areas of Service
Planning, Service Performance and other related data to the end of September
2025 and note actions being taken to improve performance where required.  
1.2  This report is submitted to Committee in terms of Section III (A) (4) of the
Council’s Scheme of Administration to monitor performance in accordance with
the Council’s Performance Management Framework.  
2.  SUMMARY  
2.1  At the end of September 2025, the Economic Growth & Development 2025-28
Service Plan was 25% complete.  Progress against Service Plan Priorities and
Indicators and operational Service Performance Indicators is presented in the
table and charts below.  Planning-related actions are included in the overall
achievement percentage; however, detailed exception reporting of these will
be presented to the Planning and Regulatory Services Committee on 16
December 2025. 
Item 10.
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3.  RECOMMENDATIONS  
3.1  It is recommended that Committee scrutinises and notes performance in
areas of Service Planning, Service Performance and other related data to
the end of September 2025 and note actions being taken to improve
performance where required.   
Suzanne Wilson
Research and Information Officer 
4.  BACKGROUND AND CONTEXT  
4.1  Each service plan sets out the planned strategic and service level priorities
and outcomes it intends to deliver in the coming year aligning closely with
financial planning, corporate and community planning partnership strategic
priorities.   
4.2  Service Plan actions are weighted to reflect priority ratings.  Actions with higher
priorities receive greater weightings which contribute more to the overall
delivery of the Plan.  Progress on Service Plan priorities and outcomes and key
areas of operational performance is reported by exception, highlighting
successes and giving assurances around the challenges and actions to
support. Links to Service Plan Actions, priority ratings and weightings and
Performance Indicators can be accessed within the background papers
section of this report.  
4.3  Complaints are reported in terms of time taken to respond, outcomes and
learning points.  Links to Complaints tables can be accessed within the
background papers section of this report. 
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4.4  Latest Local Government Benchmarking Framework (LGBF) results for 2024/25
are published throughout the year with final refresh of data around June 2026. 
The full suite can be viewed via the LGBF Dashboard.  Published indicators for
this service have been incorporated with the relevant section of this report
depending on whether used to evidence progress against strategic, service
level or service performance priorities.  LGBF indicator targets and RAG status
in the backing tables is now based on ranking thresholds aligning with
exception reporting. 
4.5  The Sustainable Development Statement was approved by the Corporate
Committee on 5 November 2024 (para 16 of the Minute refers).  The Statement
draws out the way in which sustainable development is embedded in the
Corporate Plan 2024-29 and wider corporate policies, strategies, and plans
with progress being reported through several updates and reports, one of
which is quarter 4 performance reporting.  Service Plan actions and indicators
that underpin the delivery of Sustainable Development Goals are highlighted in
the backing table documents and comment where relevant is incorporated in
this report.  An overview of progress will be presented in the annual Corporate
Plan progress update. 
5.  PROPOSALS  
Successes – Service Plan Strategic and Service Level Outcomes and
operational Service Performance
5.1  The pace of Moray Growth Deal activity continues to increase with the target of
7 projects in delivery by the end of this financial year on track.  A preferred
contractor is in place to lead the redevelopment of Elgin Town Hall; a service
provider has been appointed for the Manufacturing Innovation Centre for
Moray (MICM) and construction of the EY STEM hub is complete (with fit out
due late 2025).  6 of the 8 Deal projects are in delivery, with the seventh
(Business Enterprise Hub) at an advanced stage.  Work is ongoing with UHI and
Robertsons Construction to conclude the development agreement for the
South Street site.  This will be delayed due to complexities around housing
provision on the site.  (Strategic Level Action EGD25-28 Strat 4.1)   
5.2  The first milestone linked to delivery of the Community Wealth Building
Strategy and Action Plan is complete with the launch of the Community
Identified Benefits portal.  Funded by the UK Shared Prosperity Fund, this
portal allows suppliers to support communities to deliver projects and
activities.  Work is ongoing with legal and procurement to finalise the draft
Socio-Economic plan with approaches made to other councils to establish
best practice for local business development. (Strategic Level Action EGD25-
28 Strat 4.2) 
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5.3  Three actions relating to Climate Change and Biodiversity are complete. 
Following approval at Full Council on 27 August 2025 (items 11-12 refers), the
updated Routemap to Net Zero has been delivered.  Consultation will begin on
the draft Biodiversity Strategy while the Just Transition Strategy progresses to
the next phase which includes development and shortlisting of bids for the
2026/27 Just Transition Fund.  (Service Level Actions EGD25-28 Serv 5.3.1,
5.3.3 and 5.3.4). 
Challenges and actions to support – Service Plan Strategic and Service
Level Outcomes and operational Service Performance
5.4  Work to expand school aged childcare is ongoing.  The tender process for
provision in Kinloss is complete although work with the Care Inspectorate
continues.  Pilot schemes in Buckie and Forres also remain in development. 
Breakfast Club availability however is to increase with 10 schools across Moray
receiving a share of £54,000 in Bright Start Funding.  (Strategic Level Action
EGD25-28 Strat 4.4) 
5.5  Target due dates relating to two actions have been extended.  An evaluation of
the Levelling Up Fund elements of the Elgin City Masterplan has been granted
a one-year extension by the UK Government due to the programme of work to
be undertaken.  This is now expected by March 2028.  To reflect some
additional work, timelines for developing a Moray Visitor Levy have also been
revised.  Stage 1 (outline proposals) are now expected by March 2026 with
Stage 2 (12-week consultation) by September 2026.  (Strategic Level Action
EGD25-28 Strat 4.5 and Service Level Action EGD25-28 Serv 5.1.3) 
5.6  A newly created indicator to monitor modern and graduate apprenticeships is
reported below target.  With data cumulative against an annual target of 50,
this is expected at this stage and with 24 apprenticeships enrolled at the end of
quarter 2, work is on track.  (Strategic Level Performance Indicator EGD107) 
Complaints and MP/MSP Enquiries
5.7  Due to reporting timelines, quarter 2 complaint information is not yet available
therefore quarter 1 data is presented. 
5.8  During quarter 1, seven complaints were closed: one at Frontline and six at
Investigative Stage.  Average response times were slightly above Complaint
Handling targets, with the Frontline complaints taking 8 days and Investigative
complaints taking on average 21.5 days. 
5.9  Two complaints were Part Upheld.  Staff absence led to delays for one
customer while another reported an error with fees.  Apologies were provided
for both and a reimbursement made in relation to the wrongful charge. 
5.10  Economic Growth and Development received 11 MP/MSP Enquiries covering
various issues including two relating to Antisocial Behaviour and two relating to
Planning. 
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Other Performance (not included in the Service Plan)
5.11  Nothing to report. 
Case Studies
5.12  Nothing to report. 
Consultation and Engagement
5.13  The Forres Conservation and Heritage Scheme launched in September with a
community open day held at Forres Town Hall.  Information on the £1.8 million
secured funding and agreed projects was shared along with details of grants
and initiatives aimed at preserving Forres’ heritage and improving public
spaces and opportunities for learning and community engagement. 
5.14  An event aimed at developing the Elgin Regeneration Plan was held in July. 
Details of UK Government’s Plan for Neighbourhoods was shared with
feedback and ideas gathered to help finalise the plan before submission.  This
event also provided the opportunity to highlight the range of projects being
delivered through the Levelling Up Fund and the Moray Growth Deal.   
5.15  As part of the roll out of Public Service Improvement Framework (PSIF) self-
evaluation sessions, staff from Economic Growth & Regeneration have
completed the online PSIF checklist survey; covering areas such as Service
Planning, Leadership and Results.  Analysis of responses received is ongoing
with the next stages of the process to be progressed in quarter 3.    
6.  SUMMARY OF IMPLICATIONS  
6.1  The table below shows whether risks and implications apply if the
recommendations are agreed: 
SUBJECT YES NO
Corporate Plan and 10 Year Plan (Local Outcome Improvement Plan) X 
Policy and Legal  X
Financial  X
Risk  X
Staffing  X
Best Value and Transformation  X
Property  X
Information Communications Technology/Digital  X
Equalities. Social Inclusion and Economic Impact   X
Climate Change and Biodiversity Impact  X 
6.2  Corporate Plan and 10 Year Plan (Local Outcomes Improvement Plan
(LOIP))
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Improved Collaborative Leadership, as part of continuous improvement
through Best Value, will better enable the Council to fulfil the ambitions set
out in its strategic plans. 
a) Links to Council Corporate Plan – The proposals in this report support and
contribute to improved outcomes for communities as outlined in the
following Council Plan strategic priorities:
☐ Tackle Poverty and Inequality.
☒ Build Stronger Greener Vibrant Economy.
☒ Build Thriving, resilient, empowered Communities.   
b) Links to Local Outcomes Improvement Plan – The proposals in this report
support and contribute to improved outcomes for communities as
outlined in the following local Outcomes Improvement Plan priorities:
☒ Developing a diverse, inclusive, and sustainable economy
☐ Building a better future for our children and young people in  
Moray.
☐ Empowering and connecting communities.
☐ Improving wellbeing of our population 
6.3  Policy and Legal 
The Council has a statutory requirement to publish a range of information that
will demonstrate that it is securing best value and assist in comparing
performance both over time and between authorities where appropriate.  
6.4  Financial 
None arising from this report. 
6.5  Risk 
None arising from this report.  
6.6  Staffing 
None arising from this report.  
6.7  Best Value and Transformation 
How councils plan for, manage and report on performance is a key area of
focus in external audit work, particularly on best value.  
6.8  Property 
None arising from this report.  
6.9  Information Communications/Technology/Digital 
None arising from this report.  
6.10  Equalities, Social Inclusion and Economic Impact 
None arising from this report.  
6.11  Climate Change and Biodiversity Impacts
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None arising from this report. 
7.  CONSULTATION  
7.1  This report has been prepared in consultation with the Head of Growth,
Planning & Climate (Chief Planning Officer) and relevant Service Managers
and any comments made have been incorporated. 
8.  BACKGROUND PAPERS  
8.1  Service Plan Actions 
Service Plan Performance Indicators 
Service Performance Indicators
Service Complaints 
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DPIA Version 3.0  Page 1 of 64 
Report to: Economic Development
and Infrastructure
Services Committee
Meeting Date: 11 November 2025  
Report by: Depute Chief Executive
(Economy, Environment
and Finance)    
Author: Garry Macdonald Contact
Email:
Garry.Macdonald@moray.gov.uk 
Subject: Blue Badge (Disabled Person’s Parking Concessions) Procedure 
1.  PURPOSE 
☒ For Decision      ☐  For Information 
1.1  The purpose of this report is to recommend the Committee consider and adopt the
updated Blue Badge (Disabled Person’s Parking Concessions) Procedure.  This covers the
application for, assessment for, determination of eligibility and costs for a Blue Badge and,
administration by the Council of the Blue Badge ‘Scheme’.  This is in line with the current
criteria set nationally by Transport Scotland and the eligibility criteria relevant to Scotland  
1.2  This report is submitted to Committee in terms of Section III (F) (16) of the Council’s
Scheme of Administration relating to the exercise of the functions of the Council under the
Roads (Scotland) Act 1984 and other relevant legislation (please see the related Blue
Badge ‘scheme’ legislation and regulations in Sections 2 and 4 of this report).   
2.  SUMMARY  
2.1  The Blue Badge ‘Scheme’ initially, was the responsibility of the Department for Transport
(UK-wide).  However, the Blue Badge ‘scheme’ and criteria for a Blue Badge now differ
slightly between Scotland and England, with Transport Scotland now setting the criteria
for assessment and eligibility nationally, within Scotland.   
The legislation and regulations relevant to Transport Scotland and, to Blue Badge criteria,
eligibility and use in Scotland include, The Disabled Persons (Badges for Motor Vehicles)
(Scotland) Regulations 2000 (and subsequent Amendment Regulations) the Disabled
Persons' Parking Badges (Scotland) Act 2014 and The Disabled Persons (Badges for Motor
Vehicles) (Scotland) (EU Exit) Amendment Regulations 2019.   
Item 11.
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DPIA Version 3.0  Page 2 of 64 
The Blue Badge (Disabled Person’s Parking Concessions) Procedure update reflects the
change to a more Scotland-centric approach and criteria since the original procedure was
implemented.  For example, with reference to the legislation, regulations, assessment and
eligibility criteria relevant to Scotland, set by Transport Scotland and, by including
terminology specific to the Blue Badge ‘Scheme’ in Scotland. 
The Blue Badge (Disabled Person’s Parking Concessions) Procedure implements and
underpins locally; the national criteria set by Transport Scotland (and which is subject to
change from time to time).  The procedure describes the process as it is currently in
Scotland.  Subsequent reviews will reflect any future changes to the framework or criteria
made by Transport Scotland. 
A Short Life Working Group (SLWG) updated the previous procedure, and the attached,
updated procedure (Appendix 1) is the result of those meetings and discussions.  The
SLWG included, the Blue Badge (and Occupational Therapy) Team Manager, an
Independent Mobility Assessor (and Occupational Therapist) from the Blue Badge Team,
Blue Badge Team Officer, Policy Officer (Children & Families), Community Care Finance
Officer and Corporate Finance Officer.   
Input was also provided by Policy Supervising Manager and the Locality Manager providing
delegated authority to the Blue Badge team to administer the ‘scheme’ locally (with
support from Transport Scotland where required).  The updated procedure was submitted
to the Operational Management Team (OMT) for approval and was approved subject to
clarifying the ‘scheme of delegation’, and that was clarified with the Locality Manager. 
The attached, updated procedure (Appendix 1) was approved by our Legal Services Team
(Litigation) with one minor change which was implemented.  Equalities approved the
attached (Appendix 3) Integrated Impact Assessment (IIA) which includes protected
characteristics, human rights and rights of the child engaged by the application of the
procedure.  Data Protection and Information Governance colleagues approved the
attached (Appendix 4) Data Protection Impact Assessment (DPIA).       
3.  RECOMMENDATIONS  
3.1  It is recommended that Committee agrees to adopt the updated Blue Badge (Disabled
Person’s Parking Concessions) Procedure as attached at APPENDIX 1 subject to the
proposed charge for a replacement badge being agreed by Moray Council in
accordance with the Council’s process for reviewing charges, as set out in paragraph
5.2.   
Author Name: Garry Macdonald
Job Title: Commissioning & Performance Officer (Adult Care Policies & Procedures) 
4.  BACKGROUND AND CONTEXT  
4.1  The Blue Badge (Disabled Persons Parking Concessions) Scheme was introduced in 1971
under Section 21 of the Chronically Sick and Disabled Persons Act 1970 (“the 1970 Act‟).  
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DPIA Version 3.0  Page 3 of 64 
4.2  The aim of the Blue Badge ‘scheme’ is to help disabled people of any age with severe
mobility problems to access goods and services, by allowing them to park close to their
destination. The Blue Badge ‘scheme’ is open to eligible disabled people irrespective of
whether they are travelling as a driver or as a passenger  
4.3  The ‘scheme’ provides a national range of on-street parking concessions to Blue Badge
holders. It allows them to park without charge or time limit in otherwise restricted on-
street parking environments, and allows them to park on yellow lines for up to three hours,
unless a loading ban is in place 
5.  PROPOSALS  
5.1  It is proposed that the updated procedure is adopted so that administration of the Blue
Badge ‘scheme’ in Moray is fully compliant with legislation and guidance specific to
Scotland and administered locally (in line with Transport Scotland guidance and with their
support where necessary).  
5.2  The update was predominantly to bring assessment and eligibility for, and administration
of the Blue Badge ‘scheme’ in Moray, in line with legislation, regulations and guidance
specific to Scotland.  However, one material change is that a charge (the maximum charge
allowable is £20) will now be made for every replacement badge for a lost or stolen Blue
Badge.  Previously, there was no charge for the 1st replacement lost or stolen Blue Badge. 
This change was benchmarked with Aberdeenshire Council.  In accordance with the
process for agreement of charges, adoption of this procedure will be subject to the
proposed charge for a replacement Blue Badge being agreed by Moray Council when other
Council charges are reviewed in 2026.  
5.3  The proposals support the Strategic Plan for Health & Social Care 
Wellbeing pledge
‘Help communities to connect and care for each other’ 
Building resilience
‘We want people to be able to draw on their own personal assets and those in their
community …when they experience health and care challenges’. 
‘We will continue our work in tackling social isolation and improving mental wellbeing’. 
‘We will better understand and address disparity in outcomes based on protected
characteristics’. 
The proposals also support the Physical & Sensory Disability Strategy
‘Everyone in Moray should be able to live as well as possible, as independently as they can
and to have every opportunity to fulfil their potential’. 
‘Active and equal citizenship – people can participate fully in all aspects of society’. 
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DPIA Version 3.0  Page 4 of 64 
‘Moray is a community where people …have choice and control to meet their individual
needs and chosen lifestyle’. 
6.  SUMMARY OF IMPLICATIONS  
6.1  The table below shows whether risks and implications apply if the recommendations are
agreed: 
SUBJECT YES NO
Corporate Plan and 10 Year Plan (Local Outcome Improvement Plan) x 
Policy and Legal x 
Financial  x
Risk  x
Staffing  x
Best Value and Transformation  x
Property  x
Information Communications Technology/Digital             x
Equalities. Social Inclusion and Economic Impact            x 
Climate Change and Biodiversity Impact  x 
6.2  Corporate Plan and 10 Year Plan (Local Outcomes Improvement Plan (LOIP))
Improved Collaborative Leadership, as part of continuous improvement through Best
Value, will better enable the Council to fulfil the ambitions set out in its strategic plans. 
a) Links to Council Corporate Plan – The proposals in this report support and contribute
to improved outcomes for communities as outlined in the following Council Plan
strategic priorities:
☒ Tackle Poverty and Inequality.
☐ Build Stronger Greener Vibrant Economy.
☒ Build Thriving, resilient, empowered Communities.   
b) Links to Local Outcomes Improvement Plan – The proposals in this report support
and contribute to improved outcomes for communities as outlined in the following
Local Outcomes Improvement Plan priorities:
☐ Developing a diverse, inclusive, and sustainable economy
☒ Building a better future for our children and young people in   Moray.
☒ Empowering and connecting communities.
☒ Improving wellbeing of our population 
6.3  Policy and Legal 
There was a requirement to update the Blue Badge (Disabled Person’s Parking
Concessions) Procedure to ensure that administration of the Blue Badge ‘scheme’ locally,
reflected the legislation, regulations and guidance specific to Scotland.  The previous
version related to the previously, wider criteria relevant to the whole of the UK and
managed by the Department for Transport (DFT).  
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DPIA Version 3.0  Page 5 of 64 
The Blue Badge ‘scheme’ is administered locally with overall management of the ‘scheme’
sitting with Transport Scotland.  Transport Scotland requires local authorities to have in
place the relevant and appropriate procedures. 
The requirement to update the procedure was also part of a wider, internal audit that
considered all aspects of the Blue Badge process and included recommendations about
invoicing (for charges for the provision of a Blue Badge).  Those other, wider
recommendations were managed and addressed by Community Care Finance and the
Blue Badge Team.  This report and the related appendices are focussed on the
requirement to update the Blue Badge Procedure (Appendix 1). 
Please see Sections 2 and 4 of this Report for the relevant legislation and regulations that
apply to Blue Badge assessment, eligibility and administration.  
6.4  Financial 
None arising from this Report.  The only change relating to finance is that the Blue Badge
Team will now charge the maximum allowable (£20) for all replacement Blue Badges for a
lost or stolen badge.  Previously, at the team’s discretion, the charge did not apply to the
initial replacement badge, only subsequent replacement badges.  This change was
benchmarked with Aberdeenshire Council. 
One off Costs:
Service
Area
Budget Budget
Years
Proposed
Spend this
Year
Virement
From
Other
Comments
N/A N/A N/A N/A N/A 
Annually Recurring Costs:
Service
Area
Budget With
Effect
From
Annual
Net
Impact
Virement
From (if
applicable)
Other
Comments
N/A N/A N/A N/A N/A 
6.5  Risk 
None arising from this Report.  There are no fundamental changes to the procedure or
administration of the Blue Badge ‘scheme’.  There would be more risk in not updating the
procedure.  The updates are intended to increase the accuracy of the process and
procedure, with respect to the legislation and criteria governing the ‘scheme’ in Scotland
and, to take account of the framework and criteria now being set, nationally in Scotland,
by Transport Scotland.  That is very similar to but has slightly different terms and language
than other UK criteria and guidance.  
6.6  Staffing 
None arising from this Report.  The Blue Badge Team already carries out all aspects of Blue
Badge administration locally (with support from Transport Scotland where required). 
There are no significant changes to the administration process or the procedure.  It is
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DPIA Version 3.0  Page 6 of 64 
envisaged that the updates, to make the procedure and criteria more specific to Scotland,
will positively impact on staff with responsibilities for the Blue Badge ‘scheme’ by
providing clarity on the procedure in Moray and the criteria relevant to Scotland, rather
than slightly different criteria in other parts of the UK. 
6.7  Best Value and Transformation 
No implications identified.  
6.8  Property 
None arising from this Report.  
6.9  Information Communications/Technology/Digital 
The Data Protection Impact Assessment (DPIA) approval process took a bit longer for this
area of the business.  That was due to the complexities around the platform (provided by
Valtech) and associated data sharing and access agreements associated with recording
Blue Badge applications and administration.  Valtech provide different agreements for
different parts of the UK.  Data Protection colleagues met with Valtech and the Blue Badge
Team to check that the DPIA was complete and provided coverage for all data flows
associated with Blue Badge administration (and was covered by appropriate data sharing
and access agreements).  Following that meeting Data Protection colleagues approved the
DPIA.    
6.10  Equalities, Social Inclusion and Economic Impact 
Please see the approved Integrated Impact Assessment (IIA) at Appendix 3. 
6.11  Climate Change and Biodiversity Impacts 
None arising from this Report.   
7.  CONSULTATION  
7.1  This report has been prepared in consultation with the Policy Supervising Manager (Lizette
Van Zyl), based on the information provided at the SLWG stage (Chris McLeod – Blue
Badge Team Manager, Amanda Lazenby – Independent Mobility Assessor, Catherine Quinn
– Community Care Finance Officer, Doreen Sim – Blue Badge & OT Administrator, Lesley
Attridge – Locality & OT Manager) and the approval stage (OMT) and Legal Services –
Sheekha Saha) and any comments made have been incorporated into the report.   
8.  BACKGROUND PAPERS  
8.1  List any background papers (that are not appendices) here 
All relevant information is held within the appendices 
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DPIA Version 3.0  Page 7 of 64 
Appendices 
Appendix 1 – Blue Badge (Disabled Person’s Parking Concessions) Procedure 
Blue Badge (Disabled Persons’ Parking
Concessions) Procedure 
This document is available in different formats and languages on request. Please
contact equalities@moray.gov.uk.    
Version Number: V0.7 Draft
Approved by: Council Committee DD/MM/2025
Effective from: Date of Approval
Date for Review: 2 Years from implementation (or sooner if required)
Owner: 
BlueBadges@moray.gov.uk, Community Care Finance
Team and the Commissioning & Performance Officer
(Policies/Procedures)
Integrated Impact
Assessment (IIA) Approved by Equal Opportunities 05/02/2024
CRWIA Children’s Rights are included in the
IIA  05/02/2024
GDPR Compliant Approved 27/04/2025
FOI Compliant As above
Version Number History of Amendments Date
V0.7  Review and update of the previous
Version Appendix/Policy 0.6 Apr 2025 
More specific to the criteria in
Scotland (Transport Scotland) and
divergence from that in England (DfT) 
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DPIA Version 3.0  Page 8 of 64 
Contents
1. Introduction to the Blue Badge Scheme ........................................................................... 9
2. Key Information Resources and Regulations .................................................................... 9
3. Related Legislation Policies and Procedures .................................................................. 10
4. The Application Procedure ............................................................................................ 11
4.1  Apply Online ........................................................................................................... 11
4.2  Paper Application ................................................................................................... 12
4.3  Handling Initial Enquiries ........................................................................................ 12
5. Eligibility for a Blue Badge (Individual and Organisational) .............................................. 12
5.1  Eligible Without Further Assessment ....................................................................... 12
5.2  Subject to Further Assessment ............................................................................... 13
6.   The Assessment Procedure ............................................................................................. 14
7. Review of Decision ........................................................................................................ 15
8.   Badge Issue Fee .............................................................................................................. 15
9.  Re-application Process .................................................................................................... 16
10.  Replacement Blue Badges ............................................................................................. 16
11.   Return of Unexpired Badges .......................................................................................... 17
12.   Display of Blue Badges .................................................................................................. 17
13.   Power to Inspect the Blue Badge.................................................................................... 17
14.   Complaints ................................................................................................................... 17
15.   Misuse of the Blue Badge .............................................................................................. 18
16.  Equalities and Human Rights ......................................................................................... 18
17.  Data Protection and Freedom of Information .................................................................. 19
18.  Implementation plan ..................................................................................................... 20 
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1. Introduction to the Blue Badge Scheme
The Blue Badge (Disabled Persons’ Parking Concessions ‘scheme’) was introduced in
1971 under Section 21 of the Chronically Sick and Disabled Persons Act 1970 (“the
1970 Act‟). The aim of the scheme is to help disabled people with severe mobility
problems to access goods and services, by allowing them to park close to their
destination. The scheme is open to eligible disabled people irrespective of whether they
are travelling as a driver or as a passenger.
The scheme provides a national range of on-street parking concessions to Blue Badge
holders. It allows them to park without charge or time limit in otherwise restricted on-
street parking environments, and allows them to park on yellow lines for up to three
hours, unless a loading ban is in place. 
Transport Scotland are responsible for the legislation (see Section 3 of this document)
which sets out the framework for the scheme nationally and provides support to local
authorities to help them deliver it.  An overview is available on the Transport Scotland
website here and includes some of the criteria Transport Scotland sets around
eligibility, fees for badges, use of a badge and parking concessions available nationally.   
Further information for the public is available on the Scottish Government website here
and on the Moray Council website here.
Transport Scotland works closely with local authorities to ensure the scheme is
delivered consistently and fairly across the country and provides local authorities with a
platform to share experiences, pose questions and seek guidance from their peers.
Local Authorities are responsible for the day-to-day administration and enforcement of
the scheme. They are responsible for determining and implementing administrative,
assessment and enforcement procedures which they believe are in accordance with
the governing legislation.  
2. Key Information Resources and Regulations
The following publications relate to the Blue Badge Scheme: 
• Eligibility for, applying for, using and renewing a Blue Badge – Scot Gov website
• "Rights and responsibilities of a Blue Badge holder" which includes the powers of
Police  officers, traffic wardens, parking attendants and civil enforcement officers
to inspect the badge.
• ‘Using a Blue Badge in the European Union’
• Using your Blue Badge in Scotland (where you can/can’t park)
• V188 Form - Exemption from Vehicle Tax for Disabled People 
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• Roads for All: Good Practice Guide for Roads (Transport Scotland)
• Blue Badge Scheme (Scotland) - Code of Practice for Local Authorities
(staff/admin-facing) 
The underlying legislation to the Code of Practice:-
The Disabled Persons (Blue Badge for Motor Vehicles) (Scotland) Regulations
2000 (legislation.gov.uk)   
3. Related Legislation Policies and Procedures
Legislation (Human Rights, Equalities, Data Protection & Freedom of
Information)  
• Human Rights Act 1998
• Equality Act 2010
• EU Convention of the Rights of Persons with Disabilities
• European Convention of Human Rights
• Data Protection Act 2018 and GDPR;
• Freedom of Information (Scotland) Act 2002; 
Primary legislation (Blue Badge) 
• The disabled person’s parking badge scheme came into operation on 01
December 1971 by way of regulations made under Section 21 of the Chronically
Sick and Disabled Persons Act 1970 
Secondary legislation made by the Scottish Ministers
• The Disabled Persons (Badges for Motor Vehicles) (Scotland) Regulations 2000 
• The Disabled Persons (Badges for Motor Vehicles) (Scotland) Amendment
Regulations 2002 
• The Disabled Persons (Badges for Motor Vehicles) (Scotland) Amendment
Regulations 2007
• The Disabled Persons (Badges for Motor Vehicles) (Scotland) Amendment (No. 2)
Regulations 2011 
• The Disabled Persons (Badges for Motor Vehicles) (Scotland) Amendment
Regulations 2018
• The Disabled Persons (Badges for Motor Vehicles) (Scotland) (EU Exit)
Amendment Regulations 2019
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Welfare Reform changes amending the above legislation: 
• The Welfare Reform (Consequential Amendments) (Scotland) Regulations 2013 
Other relevant legislation
• Road Traffic Regulation Act 1984 
• Regulation of Investigatory Powers (Scotland) Act 2000 
• The Local Authorities' Traffic Orders (Exemptions for Disabled Persons) (Scotland)
Regulations 2002
• Disabled Persons’ Parking Badges Act 2013
• Disabled Persons' Parking Badges (Scotland) Act 2014 
Low Emission Zones
Scottish Low Emission Zones (LEZs) are being introduced to major Scottish
cities. To improve air quality LEZs set an environmental limit on certain city
roads, restricting access for the most polluting vehicles.
• The Scottish LEZ Exemption System is now live for personal Blue Badge holders to
register their vehicles for a LEZ exemption.
• The Vehicle Checker is now live on the official LEZ website which allows members
of the public to enter their vehicle registration number to check if their vehicle will
comply with LEZ standards.
• More information on the Blue Badge exemption can be found on the Blue Badge
Exemption page of the official LEZ website. 
Relevant Policies, Procedures, Practical Guidance  
• Case Recording Procedure
• Supervision Policy and Procedure
4. The Application Procedure  
4.1  Apply Online
Those resident in Scotland can make some (see 4,2 for exceptions) applications
online for a new Blue Badge via: https://www.mygov.scot/applgy-blue-badge or
via the Moray Council website,
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4.2  Paper Application
The paper application can be sourced from the blue badge service at The Annex
Moray Council Office, High Street, Elgin, IV30 1BX, by telephoning 01343 563483
or emailing BlueBadges@moray.gov.uk . Please note: ‘Risk in Traffic’
applications and applications by Organisations can only be submitted in paper
form.  
4.3  Handling Initial Enquiries
Initial enquires can be made by phoning the blue badge telephone number:
01343 563483 or by emailing blue badges BlueBadges@moray.gov.uk.  This
complements information about Blue Badges on the council website, including
some Frequently Asked Questions (FAQs) about the Blue Badge Scheme,
available on the Moray Council website.  
5. Eligibility for a Blue Badge (Individual and
Organisational)  
Applicants can apply on the basis of:
Individual
5.1  Eligible Without Further Assessment
A badge may be issued without further assessment if the applicant meets the
current criteria set out in the Scottish Government website here (see ‘who
automatically gets a Blue Badge’)
These applicants are required to complete an ‘Automatic Criteria Form’ and
submit this along with:
• Proof of residency or indicate their consent by ticking the box on the form
allowing the Blue Badge team to check residency against the council tax
database, or school role for under 16s (note: this is the Local Authority’s
responsibility to collect and it is mandatory to have this proof before a
badge is awarded. Transport Scotland decides, on a National level, the
exact forms of proof required and this is subject to change).
• A certified copy of a proof of identity (note: a list of options/documents for
providing proof of identity are set out in the notes that are sent along with
the application form)
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• A passport style/size photo (passport quality and in colour) with their name
printed on the back
• Evidence of eligibility under one of the criteria (this is a link to the criteria
section of the Scottish Government website) and as stated on the
application form.  Evidence of the full mobility award must be enclosed or
uploaded with the application 
5.2  Subject to Further Assessment
If the applicant does not automatically qualify, they may still qualify if they meet
one or more of the current criteria set out in the Scottish Government website
here (see ‘who else could get a Blue Badge’)
If none of the criteria apply, the applicant is unlikely to meet the eligibility
criteria, therefore will be unlikely to qualify for a Blue Badge.
All of the application forms have guidance inside explaining what the applicant
needs to enclose as proof of eligibility and identity.  
Organisational 
An ‘organisation‟ is defined in legislation as meaning an organisation concerned
with the care of disabled persons to which a disabled person’s badge may be
issued.
Organisational badges will only be issued to organisations which:
• Care for and transport disabled people who would meet one or more of the
eligibility criteria for an individual blue badge; and
• Have a clear need for an organisational badge rather than using the
individual blue badges of people it is transporting
It is the responsibility of the local authority to come to an eligibility decision.  The
Blue Badge OT makes the decision.  The delegated authority to do so derives
from applying Transport Scotland criteria/code of practice and from the local
authority, via the Service/Locality Manager working closely with the Blue Badge
OT/Blue Badge Service Manager.  The eligibility decision is based on local
knowledge, the information provided by the organisation in the application form
and Transport Scotland criteria.  Please note: these applications can only be
made in paper form (see section 4.2).
The Blue Badge service can be contacted as per the contact details in Sections
4.2/4.3.        
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6.   The Assessment Procedure
All ‘subject to further assessment applications’ will be screened using a national
desk-based screening tool by an Occupational Therapist.  The Blue Badge OT has
delegated authority to make decisions through applying Transport Scotland
criteria/code of practice and from the local authority, via the Service/Locality Manager
working closely with the Blue Badge OT/Blue Badge Service Manager.  The Blue Badge
OT carries out Independent Mobility Assessments (IMA) and makes eligibility decisions. 
Occupational Therapists are dual trained in both physical and mental health. The OT will
take into account the information provided by the applicant, any further information
sought from the applicant, an Independent Mobility Assessment – in appropriate cases
– and Transport Scotland’s criteria.  The Local Authority follows Transport Scotland’s
advice on the level of skills and training required for Independent Mobility Assessors
(IMAs). At this stage applications may be approved (and notified to The Blue Badge
Service Manager and Blue Badge Officer), refused or be referred for further assessment 
It is good practice (2012 independent review) for local authorities to provide
scope for an applicant to be referred for certification by an Independent Mobility
Assessor, if they are unable to make a clear and robust decision on eligibility
using crosschecking or desk-assessment.  
All of the information required, initially, by the Independent Mobility Assessor is
contained in the completed application form.  Criteria for eligibility (and proof of
residency/identity) is subject to change by Transport Scotland.  
Independent Mobility Assessments will be offered at an accessible venue with a
suitable parking space for the applicant to use.  
In addition to a potential Independent Mobility Assessment, the applicant may also be
given information on other Occupational Therapy and Community Care services that
may be of benefit to them. In some cases, they may be signposted/directed to other
appropriate services.  If alternative formats/languages are required for any information
provided, contact the Equal Opportunities Officer at equalopportunities@moray.gov.uk. 
Where an application is refused, the applicant will be informed (by the Blue Badge
OT/Service) in writing of the decision, with the reason for declining the application
(noting the reasons for the decision with reference to the Transport for Scotland
Criteria). The applicant will also get information about the Review of Decision process
(see below).
Approved applications are processed in line with Transport Scotland guidance via a UK
centralized service for printing, manufacturing and dispatching of Blue Badges.  The
booklet ‘rights and responsibilities’ is dispatched with the Blue Badge. 
Item:
Page: 16
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7.  Review of Decision  
The Review of Decision process is as follows:
Stage 1- If a Review of Decision request is received in writing within 28 days following
the guidance format (of required content/new information) as stated in the refusal
letter, a Review of Decision may be completed.   A review of all documentation/previous
assessments is completed and if further assessment such as a mobility assessment is
required, the applicant is notified.   A senior regulated health professional (Blue Badge
Service Manager), as part of the review decision assessment process, considers all
information submitted in support of a request for a review of decision.  The manager
then makes the eligibility decision (the delegated authority to do so comes from
applying Transport Scotland criteria/code of practice and from the Local Authority, via
the Service/Locality Manager working closely with the Blue Badge OT/Blue Badge
Service Manager).  Applicants are notified of the decision in writing with reference to the
Transport Scotland criteria.
Stage 2- Following refusal after an Independent Mobility Assessment, if a Review of
Decision request is received in writing within 28 days following the guidance format (of
required content/new information) as stated in the refusal letter, a Review of Decision
may be completed in line with Transport Scotland criteria and guidance. The Blue Badge
Service Manager, as part of the review decision process, considers all information
submitted in support of a request for a review of decision and makes an eligibility decision
(see part 1 above for information about the delegated authority to do so).  Applicants are
notified of the decision in writing with the reasons for the decision (with reference to
Transport Scotland Criteria). 
Where an application is unsuccessful, there is no current timescale for an applicant to
wait before submitting another application.  However, future applications are generally
made when the applicant has a material change in their circumstances relevant to Blue
Badge applications/eligibility. 
8.   Badge Issue Fee 
Blue Badges issued in Moray are currently subject to a fee of £20 (current maximum fee
under the regulations), paid before the issue of the Badge.  The fee is for the issue of
Badges, not an application fee.
The fee applies to new Blue Badges, re-applications (renewing) Blue Badges and all
replacement Blue Badges (replacements for all lost or stolen Blue Badges) and is the
same for 12 month, 18 month, 1, 2 and 3 year Blue Badges.  
There used to be no fee, at our discretion, for the first replacement of a lost or stolen
Blue Badge but this has been changed (see above). Lost or stolen badges should be
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reported to the Blue Badge service telephone number: 01343 563483 or by emailing
blue badges BlueBadges@moray.gov.uk.   
9.  Re-application Process 
The holder can re-apply by contacting the Blue Badge Service (01343 563483 or
BlueBadges@moray.gov.uk).  
Badge expiry dates are printed on all Blue Badges.  Applicants should re-apply in all
cases where their Blue Badge is expiring.  Re-applications will be treated as a first
application and will go through the same application and assessment process as
described above. The applicant will be required to include all supporting
documentation with their application as outlined in Section 5. 
For an automatic eligibility, with NFA, up to four weeks processing time is required to
ensure continued use of a valid (not an expired) Blue Badge.  
For a subject to further assessment re-application, the processing time required can be
up to a maximum of 16 weeks.  The public will be informed of the current processing
time on the Council website. Applicants will be able to contact the Blue Badge team
who will be able to give an update on the application and an approximate time for
processing, if they are able to do so. 
Individuals need to use a valid Blue Badge when parking in a designated area, so an
expired badge should not be used.  Individuals cannot have two valid badges so the
date will follow on from the last badge’s expiry date. 
No reminders are issued from the Blue Badge Team in Moray. It is the applicant’s
responsibility to apply in a suitable time. The date of expiry is on the Blue Badge itself. 
10.  Replacement Blue Badges
If a Blue Badge is lost or suspected stolen (see Section 8 for possible fee), this must be
reported to the Blue Badge service (telephone number: 01343 563483 or by emailing
blue badges BlueBadges@moray.gov.uk).  
The badge holder needs to tell us if it’s lost or stolen or too faded to read. Transport
Scotland guidance directs the local authority to update the National Database to show
the old badge is no longer eligible. 
When a holder contacts us for a replacement badge the administrator will go to the
Transport Scotland website and order a replacement.  The administrator will then note
this on Social Work Information Systems.  There is a £20 fee for a replacement for all
lost or stolen Blue Badges. 
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11.   Return of Unexpired Badges
Unexpired badges are to be returned as soon as possible by the holder (or their
authorized representative) when no longer required (for example, after a badge holder
passes away or there is a change in material circumstances linked to the badge holder’s
eligibility – as described in the ‘terms of use’ of the badge).  The badge should be
returned to the Blue Badge Service, Moray Council, The Annex, High Street, Elgin, IV30
1BX to mitigate the risk of improper use.     
12.   Display of Blue Badges
When using the parking concessions, the holder must display the badge on the
dashboard or facia panel, where it can be clearly read through the front windscreen. If
there is no dashboard or facia panel in the vehicle, the holder must still display the
badge in a place where it can be clearly read from outside the vehicle. The front of the
badge should face upwards.
The side showing the photograph should not be visible through the windscreen.
The holder must also ensure that the details on the front of the badge remain legible.  If
they become illegible, through fading or wear and tear, the holder must return the badge
to the council (see above for the address) so a new badge can be issued. Displaying a
badge that is illegible may result in a parking fine.       
13.   Power to Inspect the Blue Badge 
Police officers, traffic wardens, parking attendants and civil enforcement officers have
the power to inspect the badge. These people should produce an identity card with their
photograph on it to prove they are who they say they are. If any of these people ask to
see the badge, the badge holder must show it to them. If the badge holder does not,
they could be in breach of the law and could result in a fine up to £1,000.  Enforcement
officers also have the right to retain the badge, without police presence, if they have
reasonable grounds to do so. 
14.   Complaints
The complaints procedure applies when an applicant is unhappy with the way the
process has been conducted, rather than being unhappy about the eligibility decision
itself (unhappiness with the eligibility decision is dealt with by the Review of Decision
process – see Section 7).
Where there is dissatisfaction with the way the process has been conducted, please
see the above link for information including ‘How to Complain’ and the ‘Model
Complaints Handling Procedure MCHP – Implementation Guide’.    
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See also information about the Scottish Public Services Ombudsman (stage 3 of the
Local Authority Model Complaints Handling Procedure).        
15.   Misuse of the Blue Badge
Any suspected misuse of Blue Badges concerning on street parking should, in line with
Transport Scotland guidance, be referred to Police Scotland.
Moray Council car park attendants may ask to see the Blue Badge for any car parked in
Council Car Park disabled bays.  In the first instance, car park attendants will refer
misuse of blue badges to the Blue Badge issuing team.  When the Blue Badge team is
notified of potential misuse, a letter is sent to the badge holder reminding them of their
responsibilities and potential consequences of misuse.  A spreadsheet is held within
the department with badge holders’ details, allowing simple oversight of any repeat
incidences of misuse of the badge.  Repeat incidences of misuse by the same badge
holder will result in a referral to Police Scotland. Misuse issues should also be sent to
the Fraud inbox managed by the Local Authority Corporate Investigations Team.
Some examples of ‘misuse’ are set out in the rights and responsibilities.
An excess charge notice can be levied for cars parked in car park disabled bays without
a valid Blue Badge.        
16.  Equalities and Human Rights
Section 149 of the Equality Act 2010 imposes a duty any public body to have due regard,
in the exercise of its functions, to the need to:
(a) Eliminate discrimination, harassment, victimisation and any other conduct
that is prohibited by or under this Act. 
(b) Advance equality of opportunity between persons who share a relevant
protected characteristic and persons who do not share it; and 
(c)Foster good relations between persons who share a relevant protected
characteristic and persons who do not share it. This is known as the general
public sector equality duty.
In 2012 the Scottish Government adopted the Equality Act 2010 (Specific Duties)
(Scotland) Regulations which laid out a number of statutory duties for public bodies in
Scotland. These specific public sector equality duties were designed to assist public
bodies in meeting their general duties and they include the duties to:
• Where and to the extent required to fulfil the general equality duty, assess the
impact of applying a proposed new or revised policy or practice against the
needs of the general equality duty.
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• In making the assessment, consider relevant evidence relating to persons who
share a protected characteristic (including any evidence received from those
persons).
• In developing a policy or practice, take account of the results of any assessment
in respect of that policy or practice.
• Publish, within a reasonable period, the results of any assessment where it
decides to apply the policy or practice in question.
• Make arrangements to review, and where necessary, revise any policy or practice
that it applies in the exercise of its functions.
Aligning with this, the development of our policies includes, where applicable, an
Integrated Impact Assessment (formerly the Equal Opportunities Impact Assessment).
Approved by the Equal Opportunities Officer, the outcomes of the assessment can be
requested by emailing equalopportunities@moray.gov.uk.
The Human Rights Act 1998 and the rights covered by the Act can be found here
https://www.equalityhumanrights.com/en/human-rights/human-rights-act
The Human Rights Act 1998 sets out the fundamental rights and freedoms that
everyone in the UK is entitled to. It incorporates the rights set out in the European
Convention on Human Rights (ECHR) into domestic British law. The Human
Rights Act came into force in the UK in October 2000.]
The Human Rights covered by the Act can be viewed on the EHRC website here. 
17.  Data Protection and Freedom of Information
Moray Council is committed to protecting personal information in compliance with Data
Protection legislation. Further information on Data Protection is available on the
Information Management pages of the Council’s website.
Data protection legislation, including the Data Protection Act 2018 (DPA) and UK
General Data Protection Regulation (UK GDPR), provides a framework to ensure
Personal Data is handled properly. 
The legislation provides individuals with legal rights about the way their information is
handled and used, to give them greater control over their personal data. These include: 
• the right to be informed as to how their personal information is being collected
and used
• the right of access to their information 
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• the right to have their information rectified if it’s factually inaccurate or
incomplete
• the right to request that, in some circumstances, their information is deleted or
to stop using it
• the right to restrict how their information is processed in certain circumstances. 
• the right to object 
• the right to withdraw freely given consent; the right to data portability and rights
in relation to automated decision making and profiling. 
When personal information is to be collected a privacy notice will be made available to
people who use the service to explain how their information may be collected, used,
stored, shared and securely disposed of, the legal basis for doing so and what their data
subject rights are.
As a Local Authority Moray Council is subject to the Freedom of Information (Scotland)
Act 2002. This Act gives individuals the right to access information held by the Council.
Guidance and information on requests is available on the Council’s website. This
Procedure can be made publicly available if requested, unless it is exempt i.e. if it is
intended for use of staff only. 
18.  Implementation plan
1. Title of document Blue Badge (Disabled Persons’ Parking Concessions)
Procedure
2. Owner of document BlueBadges@moray.gov.uk. Community Care Finance
(with support from Adult and Children & Families Policy
Officers)
3. What is it? (e.g. new policy,
updated policy, guidance etc.)
Updated Procedure
4. Where is it stored?  Intranet 
5. What is the implementation
date/timeframe?
Council Committee approval date
6. Dissemination methodology (e.g. Cascade through snr officers and individual services,
team meeting approach, Locality approach, Launch event, Focus Groups, Event based
approach, 7 min Briefings)
Cascade through Service Managers, Team Managers and Senior Social Workers. Highlight at
the Practice Governance Board Meetings. Team Managers may want to table the Procedure
update at monthly team meetings.  Send out to all teams and available on the intranet.
7. Stakeholders (audience), their roles and responsibilities
All employees to apply the Procedure to ensure appropriate application of eligibility and
assessment for and, administration of the Blue Badge Scheme in Moray. 
8. Training Needs Assessment
Nature Scope Delivery Format Resource
One-off  Single Agency X Self-led  Met within existing X
Ongoing X Multi-agency  Facilitated X Resource required 
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Details
BlueBadges@moray.gov.uk (and Community Care Finance) can advise all teams on the
application and administration of the Blue Badge ‘scheme’ and can distribute the updated
Procedure to all relevant teams.
The updated Procedure may be discussed at Team Meetings. 
Where necessary/requested, the Social Work Training Team may provide training for staff
involved in application and administration of the Blue Badge ‘scheme’.
9. Impact: What would you expect to see as a consequence and where would you look for
impact? (e.g. case file reading, recording processes, Focus groups of parents/carers and
families, and staff)
The consistent application (eligibility, assessment, decision review, re-application,
replacement, fees etc.) and administration of the National Blue Badge ‘scheme’ at the local
level in Moray.
This will be evident from Supervision, Case Recording, Audit, Review & Update of the
Procedure. 
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Appendix 2 – Procedure Update Summary 
Revised Procedure Summary 
Blue Badge (Disabled Persons Parking Concessions) Procedure   
FAO: the Chief Social Work Officer (CSWO), Operational
Management Team (OMT), Policy Supervising Manager and Council
Committee 
Rationale for development or revision 
The need for an updated Blue Badge (Disabled Person’s Parking Concessions) Procedure
arose, partially, out of an Internal Audit of the Blue Badge Process in 2023 and the resulting
recommendations within the final report.  The Short Life Working Group (SLWG) agreed the
final draft of the updated procedure.  Litigation (Legal Services) also reviewed the procedure
and provided a small amount of feedback.  This resulted in one small edit to the updated
procedure (and to the complementary Council Committee Report).   
The intention now is to take the completed draft update (and complementary documents –
Integrated Impact Assessment, Data Protection Impact Assessment and Council Committee
Report) to the appropriate Council Committee for approval.  OMT has reviewed the
documents and asked us to clarify one issue around delegated authority. This was clarified
and incorporated into the documents.     
The need for an update also arose from identification that the legislation and guidance
referenced in the previous version, related more to the previous process in England/UK. 
There had been diversification since then, including legislation specific to the ‘scheme’ in
Scotland, made by the Scottish Ministers.  Transport Scotland had also taken over the
management of the ‘scheme’ in Scotland with criteria specific to Scotland (formerly reserved
to the UK Department for Transport).     
The final audit report included a number of other, related, recommendations such as the
invoicing process when there is a fee for a Blue Badge.  However, this summary focuses
specifically on the recommendation to update the Blue Badge (Disabled Person’s Parking
Concessions) Procedure and the contents therein.
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A small SLWG (including a Blue Badge Officer, Community Care Finance, Blue Badge
Service Manager, Blue Badge Occupational Therapist/Independent Mobility Assessor, Social
Workers, Team Managers and Policy Officers from Adult & Children & Families Services)
worked on the updated, draft procedure.   
An Integrated Impact Assessment (formerly an Equality Impact Assessment), including both
Human Rights and the Rights of the Child that are engaged by the procedure, was
completed, sent to and approved by Equalities.   
A Data Protection Impact Assessment (DPIA) (due to the data relating to a person’s health
and mobility that we share with agencies such as Social Security Scotland) was drafted and
shared with colleagues from Data Protection and Information Governance. In this instance
the process of approving the DPIA was more complex.  This was due to the various existing
Data Sharing/Accessing/Processing Agreements and the relevant Department for Transport
and Transport Scotland contracts and subcontracts. Once the 3 following data
sharing/processing issues were clarified, the DPIA was agreed and approved by Data
Protection, 
• Clarification about an individual’s data that we share with Social Security Scotland
• Clarification on our relationship with Valtech (this is related to the data processing in
administering Blue Badge applications and, relates to the Data Processing
Agreement and Access Agreement between the Local Authority and Valtech.  Valtech
provides this data processing platform in all UK nations with separate agreements for
each nation)
• Clarification of whether applications can be completed via GOV.UK. 
These were clarified in discussion between the Blue Badge Service and Data Protection. 
The Data Protection Impact Assessment has now been approved. 
Summary 
The updated procedure more accurately reflects the current legislation, guidance,
terminology and eligibility criteria (a link to up-to-date criteria on the Scottish Government
web site has been added) specific to Scotland.  There are some small differences when
compared to England and the rest of the UK.   
It also reflects the updated role of Transport Scotland in managing the ‘scheme’ in Scotland,
setting criteria specific to Scotland and providing guidance for Local Authorities (who
administer the ‘scheme’) in Scotland.    
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The updated procedure reflects some changes to current practice and processes including,
the current ‘review of decision’ process, how a replacement Blue Badge is processed and,
how an initial, physical Blue Badge is produced and sent once an application is approved.  It
also clarifies the re-application process for Blue Badges that are reaching expiry date.  The
section on misuse of a Blue Badge has also been updated in line with Transport Scotland
guidance.   
The update also provides information about the latest/more recent changes such as those
relating to Low Emission Zones. 
The update also removes the temporary processes engaged at the time of Covid-19.  For
example, it removes the temporary process that was in operation at that time in relation to
presenting in person for an Independent Mobility Assessment.   
Intended impact/outcomes 
The updated procedure meets the relevant recommendation within the Final Report from
Internal Audit, for an up-to-date Blue Badge (Disabled Persons Parking Concessions)
Procedure for Moray, reflecting current processes in Moray. 
It also fully reflects the move away from the management of the ‘scheme’ by the UK
Department of Transport, with Transport Scotland taking over this role in Scotland nationally. 
The update accurately reflects the current legislation and guidance specific to the ‘scheme’ in
Scotland and, reflects any difference in terminology and eligibility criteria compared to that in
the rest of the UK.     
The update provides staff with accurate information in relation to the current process and
procedure in Moray and, the current eligibility criteria nationally in Scotland.  This helps to
make the process more efficient from the perspective of staff administering the ‘scheme’ and
assessing applicants for eligibility. 
This procedure (similar to Transport Scotland’s Code of Practice for Local Authorities and
Criteria) is intended for staff administering the ‘scheme in Moray, rather than being public
facing.   Information for the public/applicants for a Blue Badge is provided via the application
form (and the other guidance/information sent with the form).  It is also provided via the
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public facing leaflets, booklets and guidance referenced within the updated procedure (and
available to the public online or in booklet/leaflet form).     
Controversies, challenges or potential risks 
The update of the procedure will reduce the risk of maladministration of the ‘scheme’.  The
previous document did not fully reflect the current process in Moray or fully reflect the
legislation, guidance, eligibility criteria and management of the ‘scheme’ specific to Scotland. 
The update does reflect these. 
By doing so, it will more accurately ensure that Human Rights and the Rights of the Child
that are engaged by the procedure are protected.  This is described more fully in the
Integrated Impact Assessment.  This will also ensure those who are eligible in Scotland are
able to access and use a Blue Badge. 
This procedure is a council-wide procedure, rather than being specific to Health & Social
Care Moray.  Therefore, final approval is being sought through the relevant Committee.   
Please see the Committee Report.  It includes clarification on the ‘scheme of delegation’,
the delegated authority to make eligibility decisions on behalf of the council and via Transport
Scotland’s Code of Practice and Criteria.  The Blue Badge OT/Independent Mobility Assessor
and Blue Badge Service Manager make these eligibility decisions based on information from
the application, requests for further information and where appropriate, an Independent
Mobility Assessment.  Delegated authority to make these decisions is via application of the
Transport Scotland Code of Practice and Criteria and locally, through the Locality Manager
working closely, where required, with the OT service, Blue Badge OT and Blue Badge
Service Manager.   
Author:  Garry Macdonald, Commissioning & Performance Officer (Adult Care
Policies & Procedures) 
Date: 27//04/2025 
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Appendix 3 – Integrated Impact Assessment (approved by Equalities) 
INTEGRATED IMPACT ASSESSMENT COVERING 
• EQUALITIES & SOCIO ECONOMIC DUTIES
• HUMAN RIGHTS AND RIGHTS OF THE CHILD 
STAGE 1 - DO I NEED AN INTEGRATED IMPACT ASSESSMENT?   
Name of policy or proposal:   Blue Badge (Disabled Persons’ Parking Concessions)
Procedure 
Is this a  Mark X  below
New activity, programme or policy? 
Change to an existing activity, programme or policy? X
Budget proposal?   
Duties: tick the boxes you think apply No Maybe                                                                                                                                             Yes
Equalities: Will your proposal have an impact on groups with
protected characteristics? 
Consider the impact of your proposal on people and how they
access your services and information without barriers. 
X
Socio-economic 
Not every person/family has access to regular income or savings.
Will your proposal have an adverse impact on them
X  
Does your proposal impact on the human rights of people?    X
Does your proposal impact on the rights of children and young
people 
X
Reasoning
Briefly describe your reasoning for the responses given above: 
The Blue Badge (Disabled Persons‟ Parking) Scheme was introduced under Section 21 of the
Chronically Sick and Disabled Persons Act 1970  (“the 1970 Act‟). The aim of the scheme is
to help disabled people (including young children) with severe mobility problems to access
goods and services, by allowing them (or those driving them) to park close to their
destination. The scheme is open to eligible disabled people irrespective of whether they are
travelling as a driver or as a passenger.
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The scheme provides a national range of on-street parking concessions to Blue Badge
holders. It allows them (or those driving them) to park without charge or time limit in
otherwise restricted on-street parking environments, and allows them to park on yellow lines
for up to three hours, unless a loading ban is in place. 
By it’s very nature and the people it is intended to support, this scheme engages the;
• Human Rights Act 1998 
• Equality Act 2010 
• EU Convention of the Rights of Persons with Disabilities 
• UN Convention on the Rights of the Child 
Including General Principles 1 and 2 and… 
Article 2, Article3, Article 15 and Article 31 
• European Convention of Human Rights 
Article 6 (which includes access to Appeals/Complaints Processes)
Article 14 (by way of Article 8) 
There is, in some cases such as a new badge or the second or subsequent replacement for a
lost badge, a £20 one off fee.  There is no ongoing or regular socio-economic impact. 
If you have answered “maybe” or “yes” to any of the Stage 1 questions above
then proceed to complete the Stage 2 Integrated Impact Assessment questions
below. 
If you have answered “no” to the Stage 1 questions above then provide the details below
and submit to [email] 
Lead Officer for developing the Procedure  Blue Badge Service, Community Care Finance
staff with support and input from;  Garry
Macdonald (Adult Care Policies and
Procedures), Children & Families Policy Team,
Social Work Teams, Policy Supervising
Manager and Chief Social Work Officer. 
Other people involved in the screening (this
may be council staff, partners 
or others i.e. contractor or community) 
As above plus, the update is linked to an
internal audit (2023) of the Blue Badge
Scheme Procedure.
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Date  25/01/2024 
STAGE 2: INTEGRATED IMPACT ASSESSMENT 
Brief description of the affected service
1. Describe what the service does: 
This Procedure and the administration of it, ensures that Blue Badges are provided to those
who are eligible and seeks to ensure that Blue Badges are used appropriately.  It does so by
setting out the application process, eligibility criteria (both, without further assessment and
with further assessment of eligibility/mobility), how the further assessment works (including
Independent Mobility Assessments) and who conducts it, appeals process/complaints
procedure, renewal and replacement of badges, display of badges, misuse of badges, power
to inspect badges (and who by).   
Ensures that the administration of the Blue Badge Scheme is aligned with current
Legislation, Regulations, Guidance and Codes of Practice;
• Section 21 of the Chronically Sick and Disabled Persons Act 1970
• The Local Authorities' Traffic Orders (Exemptions for Disabled Persons) (Scotland)
Regulations 2002
• The Disabled Persons (Badges for Motor Vehicles) (Scotland) Regulations 2000 
• Disabled Persons' Parking Badges (Scotland) Act 2014 
• The Disabled Persons (Badges for Motor Vehicles) (Scotland) Amendment
Regulations 2018
• The Disabled Persons (Badges for Motor Vehicles) (Scotland) (EU Exit) Amendment
Regulations 2019 
• Blue Badge Scheme (Scotland) - Code of Practice for Local Authorities 
It also provides access to further information about the Blue Badge Scheme to aid
understanding of it: 
• Can I get a Blue Badge? leaflet
• Rights and responsibilities of a Blue Badge holder 
• Using a Blue Badge in the European Union
• Using your Blue Badge in Scotland (where you can/can’t park)
• V188 Form - Exemption from Vehicle Tax for Disabled People 
• Department for Transport's “Inclusive Mobility” Guide (Section 8 is on Car Parking) 
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2. Who are your main stakeholders? 
●  Adults in the local council area who have physical or mental health disability or mobility        
issues    
●  Children, including young children in the local area who may have physical or mental 
health disability or mobility issues    
●  Families, friends, unpaid carers and others who may be driving a passenger who may        
be eligible for a Blue Badge    
●  Organisations in the local area who may be supporting adults and children who would        
otherwise be eligible for a Blue Badge, but who are provided with Blue Badge eligible        
transport by such organisations    
● Moray Council Teams including Community Care Finance, Adult and Children        
and Families Social Work Teams, Team Managers and Support Staff    
●  External, commissioned service providers and independent sector organisations (as        
in point 4 for example) 
3. What changes as a result of the proposals? Is the service reduced or removed? 
There are no material or significant changes regarding eligibility and no reduction or removal
of services/support as a result of this update.  This is an update to the Blue Badge Scheme
Procedure itself to ensure that eligibility and administration are in line with current
legislation, regulations, guidance and code of practice.  This is also a requirement from the
Internal Audit process.   
4. How will this affect your customers? 
The ultimate intention remains the same, where appropriate, Blue Badge parking
concessions will be available for adults and children who have physical or mental health
disability or mobility issues that make them eligible.  That is whether they are driving
themselves or they are passengers being driven by family, unpaid carers or organisations
supporting them, including by provision of appropriate transportation.     
As before, the Procedure also provides access to information that enables appropriate use of
the Blue Badge and information about misuse of the Blue Badge as well as information about
appeals and complaints should ineligibility be assessed for some people. 
We monitor the application of and outcomes from the Procedure through; 
●  Blue Badge service at The Annex Moray Council Office, High Street, Elgin, IV30 
1BX, 01343 563483, Blue.Badges@moray.gov.uk who are responsible for the        
processing and administration of applications, referring for assessment, providing       
Blue Badges, taking return of Blue Badges and processing renewals or 
Replacements (and recording of/processing of lost or stolen Badges).    
● Information Systems Reports/Data (linked to assessments and eligibility for Blue       
Badges) 
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● Community Care Finance administration of the payments for new, renewal and       
replacement of Blue Badges (where a fee is appropriate) and recording and reporting       
to Corporate Services any misuse issues relating to the use of a Blue Badge     
5. Impact on staff providing the service 
No major changes – the eligibility and administration process involves no significant changes
as a result of this update. 
6. Please indicate if these apply to any of the protected characteristics
Protected groups Potential impacts and considerations
Race  
Disability  Applicants for a Blue Badge are likely to have a
physical or mental health disability or mobility issue
that they think makes them eligible for parking
concessions. 
However only some applicants will be eligible without
further assessment (for example, in receipt of the
mobility component, with enough points via
assessment, of DLA, PIP or ADP benefits). In Scotland
new applicants apply for ADP and those in receipt of
PIP are being transferred across to ADP. 
Of those who require further assessment, including an
Independent Mobility Assessment, not all will
ultimately be eligible, but they may still have physical
or mental health disability or mobility issue. 
Carers (for elderly, disabled or
minors)
Unpaid carers (as well as family) may be involved in
driving an adult or child who is or may be eligible for a
Blue Badge  
Sex 
Pregnancy and maternity (including
breastfeeding) 
Sexual orientation 
Age (include children, young people,
midlife and older people)
Blue Badge parking concessions are available to
people of all ages if they have a physical or mental
health disability or mobility issue that makes them
eligible for a Blue Badge  
Religion, and or belief 
Gender reassignment 
Inequalities arising from socio-
economic differences 
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Human rights
List of convention rights Describe, where applicable, if and how
specific rights are engaged  
Article 5: Right to liberty and
security
Not engaged 
Article 6: Right to a fair trial This applies to the rights of the adult/child or
their authorised representative to appeal a
decision about eligibility for a Blue Badge via the
established Appeal Panel process, or to make a
complaint (i.e. about staff practice or conduct
through the complaints procedure that is
compliant with the Model Complaints Handling
Procedure for Local Authorities) 
Article 8: Right to respect for private
and family life, correspondence and
the home
May be engaged if a Blue Badge parking
concession enables someone with a physical or
mental health disability or mobility issue, to be
at a place where they are able to conduct their
private business and/or maintain contact with
family and friends. 
Article 10: Freedom of expression Not engaged
Article 11: Freedom of assembly
and association
May be linked to Article 8 and association with
friends, family and other entities/groups in their
community 
Article 12: Right to marry Not engaged (no pun intended)
Article 14: Prohibition of
discrimination (in relation to the
convention rights)
Related to and in conjunction with Articles 8 and
11 
Article 1 of Protocol 1: Protection of
property
Not engaged 
Article 2 of Protocol 1: Right to
education
Could potentially be engaged if a parking
concession was necessary to attend a place of
education in person
Article 3 of Protocol 1: Right to free
elections by secret ballot
Not engaged 
Children’s Rights and Wellbeing 
Relevant articles – UNCRC 
Article 2 – Non discrimination This would be engaged on the grounds of
physical and mental health disability or
mobility issues – and access to Blue
Badge parking concessions so as not to
discriminate against or prevent a child
(and those driving them such as a parent)
to go about their life with dignity and
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respect, to access activities, access
crucial services important to their
wellbeing and conduct their private
business etc. 
Article 12 – Respect of the views of the
child 
Not necessarily engaged
Article 3.1 – Best interest of the child May be linked to Article 2 i.e. similar
activities may be in the child’s best
interests and accessible via Blue Badge
parking concessions 
Article 6.2 – Right to survival and
development
Not necessarily engaged however, some
activities accessible via parking
concessions may support the child’s
development   
7. Evidence. What information have you used to make your assessment? 
Performance data  
Internal
consultation
With Community Care Finance Manager and Community Care
Finance Officers, Blue Badge Service Officers and Blue Badge OT/
Service Manager, Children and Families Policy Team and Children
& Families Staff and Team Managers, Litigation/Legal Services,
Policy Supervising Manager, Head of Service 
Consultation with
affected groups 
Local statistics 
National statistics 
Other Considering the relevant Legislation, Regulations, Guidance and
Codes of Practice as set out above in stages 1 and 2 
8. Evidence gaps 
Do you need additional information in order to complete the information in the previous
questions?  No.  There is no significant change to eligibility or administration of the Blue
Badge Scheme.  It is an update of the Policy. 
9. Mitigating action 
Can the impact of the proposed policy/activity be mitigated?  Please explain 
See sections 1 and 4 for an explanation of what the Procedure does and the outcomes
sought through its application. 
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Of those people who require further assessment, including an Independent Mobility
Assessment, not all will ultimately be eligible, but they may still have physical or mental
health disability or mobility issue. 
To ensure that everyone is assessed appropriately, where it is required, an Independent
Mobility Assessment (IMA) is carried out by an Occupational Therapist, trained in conducting
IMAs for Blue Badge eligibility, in line with established standards for assessment.   
Where there is an appeal against ineligibility, a further IMA will be conducted in appropriate
cases (assessed as required by the OT) and in some cases the further IMA will be with a
specialist, where there is a mental health disability/mobility issue. 
There is an established Appeals process and Appeals Panel (including OT and legal
participation) for appeals in relation to eligibility.   
In terms of staff practice and conduct, applicants also have access to the established
complaints procedure which is complaint with the Model Complaints Handling Procedures
for Local Authorities. 
For those people who are ineligible but who may have a need for other support for disability
and mobility issues, they will be signposted to other services and support including
‘universal services’ such as advice, information, assessment of care needs,
appropriate/relevant independent support organisations etc. 
They will also be signposted to appropriate and relevant benefits information and advice.         
10. Justification
If nothing can be done to reduce the negative impact(s) but the proposed policy/activity must
go ahead, what justification is there to continue with the change?   
See section 9 for mitigating factors.  The update is also a requirement of an internal audit. 
SECTION 3 CONCLUDING THE IIA 
Concluding the IIA 
1. No potential negative impacts on any of the protected groups were
found. 
2. Some potential negative impacts have been identified.
The impacts relate to:
X
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Particularly to people who may have a physical or mental health disability
or mobility issue and who are assessed as ineligible for a Blue Badge and
parking concessions.  Please see section 9 for mitigations that may be
appropriate to each individual and which they will be signposted/referred
to or supported with.   
Reducing discrimination, harassment, victimisation or other conduct
prohibited under the Equality Act 2010
Disability – see section 6
X
Promoting equality of opportunity
See section 6 and the link to protection of human rights
X
Fostering good relations 
3. The proposals interfere with human rights and/or the rights of the child
The Proposals are intended to protect the rights of the child 
4. Negative impacts can be mitigated; the proposals are outlined in
question 9 
5. The negative impacts cannot be fully mitigated but are justified as
outlined in question 9 
X
6. Further consultation with affected groups is needed. 
7. It is advised not to go ahead with the proposals. 
Decision
Set out the rationale for deciding whether or not to proceed with the proposed actions: 
There is a requirement to update the Blue Badge Scheme Procedure based on both the need
for periodic review and the internal audit of the process.  This is to ensure that eligibility to
and administration of the Blue Badge Scheme is aligned with the most recent legislation,
regulations, guidance, code of practice and current internal practice/processes.   
The ultimate intention remains the same, where appropriate, to make available to adults and
children who are eligible, Blue Badge Scheme parking concessions to mitigate physical and
mental health disability or mobility issues, to ensure they are not discriminated against
because of disability and to protect their human rights. 
To encourage appropriate use of the Blue Badge and discourage inappropriate use. 
To enable access to relevant appeals and complaints procedures as discussed earlier. 
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In meeting those requirements, we have set out in Section 9 the mitigating actions that
underpin the application of the Procedure and mitigate as far as possible the potential
negative impacts of the Procedure. 
Date of Decision:  25/01/2024 
Sign off and authorisation: 
Service Health and Social Care Moray
Department Moray Council, Children and Families and Adult
Social Work, Community Care Finance and
Blue Badge Service.
Policy/activity subject to IIA Blue Badge Scheme (Disabled Peoples’ Parking
Concessions) Procedure
We have completed the integrated impact
assessment for this policy/activity. 
Name: Garry Macdonald
Position: Commissioning & Performance Officer
(Adult Social Care Policies and procedures)
Date: 25/01/2024
Authorisation by head of service  Name: 
Position:  
Date:
Permission to publish on website – yes
Please return this form to the Equal Opportunities Officer, Chief Executive’s Office. 
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Appendix 4 – Data Protection Impact Assessment (approved by the Data Protection
Team) 
Information Assurance Group
Data Protection Impact Assessment 
(DPIA) on: Blue Badge (Disabled
Persons’ Parking Concessions)
Procedure 
Link to Product Website <INSERT LINK TO PRODUCT WEBSITE HERE>
Link to Product Privacy
Policy
Privacy Notice Adult
Social Care Case Management v1.1.pdf  
A new privacy notice, specific to the Blue Badge scheme, will
be completed by Data Protection/Blue Badge Service 
Author Garry Macdonald
Commissioning and Performance Officer
Adult Social Work
Version Draft Version 0.1
Date 27/04/2025 
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A DPIA is a tool designed to identify and minimise the data protection risks of a project or
process.  They are required for any processes that are likely to result in a high risk to
individuals and will assist the Council in adopting a ‘privacy by design’ culture.  For more
information, please see Appendix A. 
To identify whether you need to carry out a DPIA, please complete the question below
and the initial screening questions, these will indicate if any further steps in the DPIA are
required.   
NOTE for Education/Schools:
Schools and Early Learning Centres should contact LearnTech@moray.gov.uk before
starting a DPIA to avoid duplication of work, as another school may have already
completed/be in the process of completing a DPIA since more than one school may
require access to websites and applications.  
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Step 1: Description of the project/resource
Provide a brief description of the project, and, explain the aims and benefits.  Where
suitable, please link or refer to documents such as a project proposal, host site etc. 
If the DPIA relates to a resource, please describe what the resource/system will do, how
it will be used and who will require access.  Please also describe how the resource will be
accessed.
The draft Blue Badge Procedure does not constitute a new process or procedure, it is an
update to the current Procedure and contains some changes to ensure it is up-to-date and
Scotland-centric (as the Scheme requirements/criteria are set by Transport Scotland
rather than the Department for Transport.  The requirement to make some changes
resulted from an Internal Audit with a completion date at the end of April 2024.   
The Audit recommendations are wider than the Procedure update, such as
updating/clarifying the invoicing process, however, this DPIA is concerned with the update
of the Procedure.  
The Blue Badge (Disabled Persons Parking Scheme) was introduced in 1971 under Section
21 of the Chronically Sick and Disabled Persons Act 1970 (“the 1970 Act‟). The aim of the
scheme is to help disabled people of any age with severe mobility problems to access
goods and services, by allowing them to park close to their destination. The scheme is
open to eligible disabled people irrespective of whether they are travelling as a driver or as
a passenger. 
The scheme provides a national range of on-street parking concessions to Blue Badge
holders. It allows them to park without charge or time limit in otherwise restricted on-
street parking environments and allows them to park on yellow lines for up to three hours,
unless a loading ban is in place. 
The Procedure sets out the relevant legislation, regulations and criteria (set by Transport
Scotland) governing assessment for, eligibility to and use of Blue Badges for both
individuals and for organisations providing transport for people who would be eligible for a
Blue Badge. 
The Procedure also sets out the application process, eligibility criteria both without further
assessment (i.e. in receipt of the enhanced rate mobility element of Adult or Child
Disability Payment) and with further assessment by an Independent Mobility Assessor
(IMA) in relation to the person’s mobility/disability if the person is not automatically
eligible.   It also covers renewals; replacement badges, any charges for a new badge or a
second or subsequent replacement badge and the appeals process. 
Some of these functions are, in essence, legal obligations of the local authority. In order to
fulfil them, employees of the department collect information from children and adults (or
their authorised representatives or parents), employees and other/partner organisations.
Data gathering, recordkeeping, and analysing information are fundamental for the
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provision of support, be that directly through working with adults and children or indirectly
by commissioning services and improving the quality of service.     
The variation of the existing procedure relates more to ensuring that the process is
accurate, up-to-date and is Scotland-centric.  This is due to Transport Scotland now
leading on this and setting criteria, as opposed to the Department for Transport (UK) doing
so.  There is different terminology and some differences in criteria between England and
Scotland when it comes to assessment and eligibility.     
However, it is clearer now that a reasonably significant number of people (in the
thousands) will apply for and be in receipt of a Blue Badge.  In administering the scheme
and determining eligibility, this will involve the Council sharing sensitive health
information with, for example, benefits agencies.   
Therefore, the risk appears to be significant and, in my view, this change to the Procedure
would be subject to a full DPIA.   
Step 2: Screening Questions
There are two sets of screening questions, they will signpost whether a full, brief or no
DPIA is required. 
Set A (directs to Full DPIA)
Does the project involve any of the following? Yes
(tick)
No (tick)
1) Evaluation or scoring, profiling and predicting 
- Especially from aspects concerning the data subject’s economic
situation, health, personal preferences, interests, reliability,
behaviour, location or movements. 
In this case, some further assessment of health/mobility by an
IMA to determine eligibility for a Blue Badge
√ 
2) Automated decision making 
- Any processing of personal data that has zero human involvement.
E.g. an online HR recruitment test in which the data subject
completes a series of multiple choice questions which
automatically determine whether the subject proceeds to the next
stage of the recruitment process or not. 
√
3) Systematic monitoring 
- Processing used to observe, monitor or control data subjects. E.g.,
CCTV in a public area. Includes any monitoring in circumstances
where the subject may not be aware that their data is being
collected. 
√
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4) Data processed on a large scale 
You should consider:
A) The number of data subjects involved in the process
B) The volume and range of personal data involved
C) How long will the processing activity be in place for (e.g. will this
affect data subjects on an indefinite basis or over many years?)
D) The geographical extent of the processing activity (consider this
in combination with other factors – e.g. if Moray-wide is it collecting
data from a significant proportion of the people within Moray?) 
A significant amount of data subjects, sensitive health data and
potentially data sharing over a number of decades for some
individuals. 
√ 
5) Re-using old dataset(s) for a new, completely different purpose
from which it was first intended 
- An example of this would be using a database of unsuccessful
applicants for a job as the basis for a mailing list advertising a ‘job
club’ or similar employment help scheme. The data subject
provided their information in order to apply for the job only: it should
only be used and retained for this purpose alone. 
- However, using information collected as part of the housing
benefit assessment to verify eligibility for another entitlement is a
reasonable enough expectation and so is not a “completely
different purpose”. There is a question in Screening Questions Set B
for these types of instances. 
- Includes combining two data sets previously used for different
purposes and/or originating from different controllers 
√
6) Data primarily concerning vulnerable data subjects 
- Note that this is distinct from the earlier question on sensitive data
in general. This is concerned with who the data subject is about
rather than what the data is. 
- This includes any vulnerable groups of people (e.g. the elderly,
asylum seekers, patients etc.) and children in general. It also
includes areas where the imbalance of power between the Council
and the data subject can be seen as greater and thus leave them
‘vulnerable’ by being unable to consent to or oppose the process.
For example, it would be difficult for an employee to oppose
personal data being processed for HR reasons. 
√
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If the answer to any of these questions is “Yes”, a full DPIA should be carried out. 
If the answer to none of these questions is “Yes”, complete Set B
Eligibility to a Blue Badge (for example, issues with
mobility/disability), in my view, would not necessarily equate to
someone being a ‘vulnerable’ person. 
7) Applying novel/innovative technologies 
- E.g. facial recognition software, biometric technology, other novel
ways of collecting personal data. 
- This does not include collecting information through a different
medium, such as online rather than by using paper forms. 
√
8) Sharing data outside of the United Kingdom (UK)/European
Union(EU)/European Economic Area (EEA) 
- Note that this may include third party services based outside of the
UK/EU/EEA. For example, if you are using a system run by a Russian
company it is possible that the personal data you enter into the
system is held on their Russian-based servers. 
- This does not include instances where you are sharing a data
subject’s own personal data with themselves. 
√
9) When the processing in itself prevents data subjects from
exercising a right or using a service or a contract 
- This includes processing performed in a public area that people
passing by cannot avoid, or processing that aims at allowing,
modifying or refusing data subjects’ access to a service or entry into
a contract. An example of this is a bank screening its customers
against a credit reference database in order to decide whether to
offer them a loan or not. Another example would be if the Council
banned a service user from a certain building, but also ran a
consultation that could only be accessed by visiting that building. 
√
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Set B (directs to Brief DPIA)
If the answer to any of these questions is “Yes”, a brief DPIA should be carried out.
Does the project involve any of the following? Yes (tick) No
(tick)
1) Sensitive data 
- This includes data regarding:
(a.) Racial or ethnic origin
(b.) Political opinions
(c.) Religious or philosophical beliefs
(d.) Trade union membership
(e.) Genetic and/or biometric data for the purpose of uniquely
identifying a person
(f.) Data concerning a person's health
(g.) Data concerning a person's sex life or sexual orientation
(h.) Data relating to criminal convictions and offences or related
security measures 
(f) data concerning a person’s health 
√ 
2) A new collection of personal information 
- For example, collecting information about individuals’
locations or for a new ‘opt-in’ process, mailing list or similar. 
√
3) Re-using old dataset(s) for a new purpose, but one which is
related to the purpose for which the data was first gathered 
- For example, using information collected as part of the housing
benefit assessment to verify eligibility for another entitlement 
√
4) Using a third-party contractor when processing personal
information 
- For example, outsourcing HR functions or storing information in
the cloud. 
√
Note: Question 5 will not apply if this is a brand-new process,
and no data has as yet been collected 
5) A change in the way personal information is stored or secured 
- For example, transferring the storage of personal information
into the cloud, or the implementation of a policy that effects a
change to the way personal information is stored or secured.   
√
Note: Question 6 will not apply if this is a brand-new process
and no data has as yet been collected 
6) A change to the way that personal data is currently collected. 
- For example, collecting information online rather than on paper
forms.   
√
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If the answer to none of these questions is “Yes” then send the DPIA form to
dataprotection@moray.gov.uk.   
Step 3: Full and Brief DPIA
1. Summarise why you have identified the need for a DPIA; is it for part of a process, a
new project, or for a proposed alteration to an existing process? 
Although someone eligible for a Blue Badge would not necessarily constitute a person
who is ‘vulnerable’, the fact that we share sensitive health data about individuals with
agencies such as Social Security Scotland (in determining eligibility), along with the
number of data subjects involved, dictates that a full DPIA is required.   
This alteration/update of the Procedure has clarified these issues, leading to this
decision to complete a full DPIA. 
2. Describe the flow of information – include where it comes from, who collects it and
how, where it’s stored, how it’s used, who manages it at each stage of the process,
when and how it’s deleted or archived.  A diagram, flow chart or link to relevant
websites or documents might be useful here.
For a full DPIA this needs to be as thorough as possible.
Data flow
draft.docx 
3. How are data protection and privacy currently managed in relation to this process or
activity? Show where the change that the project involves will fit with the current
systems. 
No change – the update to the Blue Badge Procedure has not changed the
management of these aspects 
4. Is the project a one-off initiative or part of an ongoing system? 
Ongoing system 
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5. Is the information being processed already collected/held? (Yes/No)
Some of the information being processed is already held and some is new data. 
In terms of the former (held), employees (e.g., social workers) currently process (e.g.,
analyse and assess) already held information as part of working with adults and
children using the service. For example, we may already have information regarding
someone’s mobility issues and/or eligibility to mobility elements of certain benefits. 
Furthermore, quality and performance monitoring activities are conducted on
information that we already hold. For example, Information Systems Officers use data
from Social Work Information Systems to support reporting requirements (i.e. to the
Scottish Government); quality assurance workers audit casefiles that are
subsequently analysed by Consultant Practitioners for improvement, quality
assurance and monitoring purposes. 
In terms of processing new information, employees (e.g., social workers, reviewing
officers, community care officers, Independent Mobility Assessors and Blue Badge
team staff) speak to new and existing service users on a daily basis. They, and other
employees (including admin teams), process the gathered information. The
processing includes analysis of individual circumstances (including mobility/health
circumstances) enabling the formulation of eligibility decisions and/or effective
support plans (where necessary and appropriate); processing also includes the
analysis of information to monitor and improve the quality of the service. 
New information (e.g., opinions/feedback about internal procedures; professional
experiences) may also be collected from employees. The employees themselves and
their line managers as well as the quality assurance team can process such
information. Furthermore, a third party (e.g., Care Inspectorate) may process the
data. 
6. Who are the main stakeholders (Council department(s), Schools, third parties/other
organisations involved) and what are their roles in the project?
Adult and children Service Users – provide (themselves or via their authorised
representatives or parents) accurate and up-to-date information in order to receive
the most appropriate support possible and to contribute to organisational
development 
Adult and Children & Families Social Work Departments - their responsibility is to
gather necessary information and feedback from service users (their authorised
representatives) and employees, maintain the data sets’ accuracy and safe storage. It
is also their responsibility to process this information in order to:
- Provide appropriate and effective services, support and planning for adults
and children 
- Outsource/commission services, where appropriate, in a most efficient way
- Monitor and improve the service and practice 
Other agencies (in particular in relation to Blue Badge, Social Security Scotland,
Department of Work & Pensions, NHS Grampian, Third Sector
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Organisations/Partners) - the information sharing with other agencies is two-way;
their role is to provide accurate information (i.e. health data about individuals) and
contribute to its processing by Social Work; it is also their role to accurately and
safely store the information they receive from Social work (i.e. as a result of an
application to the Blue Badge team and/or an assessment of eligibility by an
Independent Mobility Assessor) 
Scottish Government – they ask for data and prescribe how we hold it 
Care Inspectorate – they ask for information and process it for quality assurance
purposes 
Service providers – i.e. those applying for and eligible for an Organisational Blue
Badge to provide transport for individuals who would be eligible for a Blue Badge (to
safely store the information they receive from social work and to use it to provide the
contractually agreed service). E.g. a taxi service, a minibus for blue badge service
users. 
7. Who will be the Asset Owner/person responsible for the data? (e.g. head teacher,
head of dept) 
Chief Social Work Officer. Ultimately, CEO Moray Council 
8. How many data subjects (individuals) are likely to be affected by the project? 
Several thousand – both existing and new Blue Badge holders 
9. Do the data subjects include children (under 12 years old) or any other vulnerable
group(s)? 
Yes – children under 12 are entitled to a Blue Badge if they are eligible (some are
automatically eligible i.e. in receipt of the enhanced mobility rate of Child Disability
Payment)
yes – those with medical/health needs might be vulnerable. 
10. What timescales are involved; is there a target implementation date? 
Ongoing 
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STEP 4: Personal Data (Brief and Full DPIA)
11. What personal data will be collected?  E.g. names, email addresses, NI numbers, gender,
health information, criminal offences etc.  Note what is required and what is optional.   
For Blue Badge, data may include: 
Names, contact details (email addresses, telephone numbers, postal addresses),
date of birth, place of birth, Driving Licence Number, NI numbers, health information,
mental health information, disability information. NHS Number. Proof of address,
proof of identity, and image of the data subject (mug shot) 
If a form is completed on someone else’s behalf, then:
• For the person completing form: Names, contact details (telephone, email
address), Relationship to applicant.
• Information about the counter signatory professional: Names, Job title, Date of
last contact with applicant, Registration number, Organisation they work for,
contact details (Work telephone number and Email address)
• For organisational applications: Name of the organisation, Charity number (if
applicable), Name of main contact, Current address & postcode, Contact
details (Telephone number and Email address)
12. How will the information be collected/where does the data come from? 
Please see the flowchart in Step 3, Table 2. 
The information comes from service users, employees (including Independent
Mobility Assessors) and other agencies; it is collected via conversations/assessment,
application forms and online applications etc. 
13. If reused, is the use or collecting method different? 
The information is re-used for quality assurance and improvement as well as
reporting purposes. In such cases, the collection method is no different.   
14. Where will the data be stored and in what format?  E.g. Shared drive spreadsheet,
national database, paper files in locked cabinet in dept’s office, online website hosted
within EU. 
Please see the flowchart in Step 3 Table 2. 
All case recording/data, where possible, is stored on the CareFirst, internal networks
and/or physical forms. 
CareFirst is a web based, case management system comprising a suite of integrated
modules covering the full spectrum of children and adult services client groups.
CareFirst is UK based. 
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The internal network is an organisation-owned and organisation-controlled system
where the establishment, maintenance, and provisioning of security controls are
under the direct control of organisational employees or contractors. Social work’s
servers are in Moray. 
Paper files are held in locked cabinets in Moray Council premises, and in the
Council’s Closed Records Stores. 
15. What measures are in place to ensure the information is accurate and up to date?  Can
incorrect information be amended? 
Badges are renewed on a regular basis (1, 2 or 3 years depending on the type of
badge) 
16. Who will have access to the information (whether inside or outside the Council)?  E.g.
NHS, data subjects (including parents for school pupils) 
Data is only directly accessible to authorised and trained staff within the Council’s
Social Work Department. 
However, we do share information with third parties (e.g., NHS Grampian, Scottish
Government, Social Security Scotland, DWP and other agencies as previously stated,
commissioned service providers etc.) as discussed below. 
17. Are any other third party processors or sub-processors used to process data at any
point?  If so, please identify all of these, where they are located and the role they
perform in processing personal data.   
Other agencies such as Social Security Scotland and the DWP (health information,
eligibility to mobility components of disability benefits) as well as the Scottish
Government may also process data that we share with them.  For the former, it is
usually in relation to assessment and eligibility for a Blue Badge, to ensure that
service users are appropriately and effectively supported by multiple agencies (e.g.,
both Health and Social Work may jointly support the adult). The Scottish government,
on the other hand, processes information we share with them for monitoring (e.g.,
National Indicators) and service planning purposes. 
18. Does any part of the data leave the Council’s ICT infrastructure? 
Yes, as per above.   
19. Does any part of the data leave the UK, European Union (EU) or European Economic
Area (EEA)? This includes via a sub-processor or third party. 
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No. Servers are in Moray, and we aim to only use UK-based services for any other data
collection and processing 
20. If a new process how will the data subjects be informed of any changes? 
Not a new process.  Please see the overarching Privacy Notice (which is to be
updated) attached earlier in this document 
21. How is the information managed and protected?  Any security features?  For example
encryption of the personal data or pseudonymisation (removing personally
identifiable information fields and replacing with pseudonyms)? How is the personal
data backed up and can it be restored timeously?   
The collected information’s storage is well-protected.   CareFirst, our primary storage,
is owned and secured by OLM. It is password protected and only trained staff with ICT
‘permissions’ can access it.  Access to the internal networks is also subject to ICT
‘permissions’ such as access, edit and change ‘permissions’.  All laptops in
employees’ homes are VPN protected, so that remote access to internal networks is
safe.  Paper files, as noted previously, where they need to be kept, are placed in
locked storage and all staff are GDPR trained. The use of non-encrypted USBs is not
allowed. 
We also aim to ensure that we share information in a safe manner through a
combination of encryption, removal of identifiers (aggregating information), and
pseudonymisation: 
- We use encrypted emails to share information where the identifiers are
included 
- We remove identifiers in instances where data is reported in an aggregated
form (e.g., Scottish government, FOI requests – including the exclusion of low
numbers)
- We pseudonymise information where the data is processed and reported for
quality assurance/improvement purposes (e.g., reflective case discussions)
- Information sharing by social workers, whilst not password protected, is
governed by data sharing procedures, including the data protection breach
management guidance and process. 
Personal information is automatically backed up over-night.   
22. How long will the information be retained and how will it be disposed of or archived? 
Does it align with the Council’s Retention Schedules (Available here)? 
TO BE ADDED TO RETENTION SCHEDULE. Currently kept for closure +7yrs, then
destroy. 
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STEP 5: Legal Basis (Brief and Full DPIA)
Check how your proposal measures up against the data protection requirements.  The
questions follow the guidance information:
Legal Basis
It is unlawful to process personal data without having a valid legal basis.    
For personal data that does not relate to any of the special categories the legal basis for
the proposed processing must be one or more from the following list.
Please note that ‘data subject’ means the person to whom the personal data relates.  
• 6(1)(a) – Consent of the data subject
• 6(1)(b) – Processing is necessary for the performance of a contract with the data
subject or to take steps to enter into a contract
• 6(1)(c) – Processing is necessary for compliance with a legal obligation
• 6(1)(d) – Processing is necessary to protect the vital interests of a data subject or
another person
• 6(1)(e) – Processing is necessary for the performance of a task carried out in the
public interest or in the exercise of official authority vested in the controller
• 6(1)(f ) – Processing is necessary for the purposes of legitimate interests pursued
by the controller or a third party, except where such interests are overridden by the
interests, rights or freedoms of the data subject.
In many cases condition 6(1)(e) will be the most relevant. 
For personal data that relates to any of the special categories the legal basis for the
proposed processing must be one or more from the following list:
• 9(2)(a) – Explicit consent of the data subject, unless reliance on consent is
prohibited by EU or Member State law
• 9(2)(b) – Processing is necessary for carrying out obligations under employment,
social security or social protection law, or a collective agreement
• 9(2)(c) – Processing is necessary to protect the vital interests of a data subject or
another individual where the data subject is physically or legally incapable of
giving consent
• 9(2)(d) – Processing carried out by a not-for-profit body with a political,
philosophical, religious or trade union aim provided the processing relates only to
members or former members (or those who have regular contact with it in
connection with those purposes) and provided there is no disclosure to a third
party without consent
• 9(2)(e) – Processing relates to personal data manifestly made public by the data
subject
• 9(2)(f) – Processing is necessary for the establishment, exercise or defence of
legal claims or where courts are acting in their judicial capacity
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• 9(2)(g) – Processing is necessary for reasons of substantial public interest on the
basis of UK law which is proportionate to the aim pursued and which contains
appropriate safeguards
• 9(2)(h) – Processing is necessary for the purposes of preventative or occupational
medicine, for assessing the working capacity of the employee, medical diagnosis,
the provision of health or social care or treatment or management of health or
social care systems and services on the basis of UK law or a contract with a health
professional
• 9(2)(i) – Processing is necessary for reasons of public interest in the area of
public health, such as protecting against serious cross-border threats to health
or ensuring high standards of healthcare and of medicinal products or medical
devices
• 9(2)(j) – Processing is necessary for archiving purposes in the public interest, or
scientific and historical research purposes or statistical purposes in accordance
with Article 89(1)
The ICO advises that public authorities will find using consent as a legal basis difficult. 
So if the proposed processing is to use consent as its legal basis you need to indicate
why this is necessary and seek the advice of the DPO.
‘Sensitive data’ includes:
• special categories of data as defined in Article 9 i.e. racial or ethnic origin,
political opinions, religious or philosophical beliefs, trade union membership,
genetic data, biometric data, data concerning health or data concerning sex life
or sexual orientation.
• personal data relating to criminal convictions or offences;
• data which may more generally be considered as increasing the possible risk to
the rights and freedoms of individuals, such as electronic communication data,
location data, financial data (that might be used for payment fraud). 
23. What is the legal basis (see above) for processing the personal data? 
We have multiple legal bases for collecting and processing personal data; these
include:
• 6(1)(e) – Inc for Care & Support (i.e. issuing Blue Badges for parking concessions
if eligible) 
The Disabled Person's Parking Badges (Scotland) Act 2014
Chronically Sick and Disabled Persons Act 1970 and the Disabled Persons (Badges for
Motor Vehicles)
Chronically Sick and Disabled Persons Act 1970 
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24. What is the legal basis for processing any special category data? 
We also have multiple legal bases for the collection and processing of any special
category data; these include:
• 9(2)(g) 
25. If you are relying on consent to process personal information, how will this be
collected and what provision will be made for people to withdraw their consent? 
What if consent is withheld or withdrawn?
n/a
26. How will you tell individuals about the use of their personal information?  E.g. privacy
notices
Privacy Notices:
27. If you already hold or process this information, is there any significant change being
made that data subjects would need to be informed about?  How will you inform
those affected about the change? 
There are no changes being made to the procedure or data processing that data
subjects need to be informed about.   
STEP 6: Consultation (Full DPIA)
The DPIA should consider and be representative of every aspect of the process. For this
reason it is strongly recommended that you consult with any other departments or
partners involved in the process when completing the DPIA. This section should be
used for reporting who you have consulted with and the discussions, recommendations
and other salient points that have arisen. You should first familiarise yourself with all of
the steps of the Full DPIA process so you will know which issues require consultation. It
is more helpful to think of this not as a single distinct step, but as an ongoing part of the
Full DPIA.
28. Who has been consulted and what issues were discussed?  Have any assurances,
demands or concerns been raised, and if so how have they been resolved? 
A wide range of employees were consulted in this DPIA exercise. This includes:
- Social Work Service Managers
- Social Workers in Adult Services and Children & Families
- Community Care Finance Staff and Corporate Finance
- Blue Badge Team staff and administrators
- Independent Mobility Assessor
- Occupational Therapy Team Manager
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- Policy Teams (Adults and Children & Families)
- Records and Heritage Manager, and Data Protection Officer
- Information Governance Officer 
Additionally, some assurance was previously provided, including:
- The exclusive use of servers in Moray or in the UK
- The timely back-up of personal data
- The consistent inclusion of privacy notices in contracts outsourcing services
- Clarity around the access CareFirst owner would have to our data
- Clarity around retention schedules
- Clarity around data breach processes, which also outlines steps to decrease
the likelihood of future data breaches 
29. Is there any other pertinent information about what exactly happens to the
information during the process?  E.g. is the personal information used by a third
party with whom we have no direct control or agreement in place? 
No  
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STEP 7: GDPR requirements (FULL DPIA)
Third Parties:
The Council needs to be able to demonstrate robust arrangements with any third parties
who process data on our behalf. This could include software developers, public sector
partners (e.g. Scottish Government, NHS), private service providers etc.
30. Will any third parties be processing personal data? 
Yes. These include – Social Security Scotland and the DWP: Scottish Government,
NHS Grampian 
31. If so is the arrangement set out as part of a contract, data sharing agreement or
similar, and, are there pertinent clauses or details regarding data protection?   
Data sharing agreement 
32. If the arrangement is not part of a contract, data sharing agreement or similar please
specify nature of the current arrangement and state if a new agreement is required. 
New Technology
33. Does the project involve using new technology that might be perceived as being
privacy intrusive?  For example, the use of CCTV, Automatic number plate
Recognition (ANPR), body worn cameras, biometrics or facial recognition? 
Nothing new under the Procedure update 
Public Impact
34. As a local authority we need to be aware of the extent and severity of the impact this
project will have on the affected individuals.  Will this project have minimal impact
on individuals?  Will it have some impact on individuals and potentially raise public
concerns?  Or will it have a high impact on individuals and potentially raise negative
media publicity?  Are there any current issues of public concern that should be taken
into consideration? 
The aim of social work/Independent Mobility Assessor intervention is to support
children and adults to achieve their assessed, agreed, personal outcomes in various
aspects of their lives.  It is also to ensure their rights are protected in certain
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circumstances – such as automatic (or assessed) eligibility to a Blue Badge for
parking concessions. 
As set out earlier in the form, we primarily collect and process information to protect
children and adults from harm and to support them and their families in appropriate
ways.  As a result of this work, we hope to see children and adults safe and well, and
an improvement in their and their families’ situation. This includes a protection of
their rights, including Human Rights as set out in the Integrated Impact Assessment
for the Blue Badge Procedure. 
The aim of the Blue Badge scheme is to help disabled people of any age with severe
mobility problems to access goods and services, by allowing them to park close to
their destination. The scheme is open to eligible disabled people irrespective of
whether they are travelling as a driver or as a passenger. 
A breach of their information (including sensitive health information) can have high
and negative consequences, including facing prejudice and stigmatisation.  This
could also lead to negative or unwanted media publicity.  A loss of trust between
service users and a service can negatively impact the ability of the Council to provide
that service. These, in turn, can have a negative impact on individuals’ mental and
physical health.  As such, we aim to have robust processes in place to avoid data
breaches, as noted earlier in the form. 
There are no known current issues of public concern that need to be taken into
consideration. 
Data Subject’s Rights
The data subjects have certain rights relating to the information held on them. These
rights can vary, chiefly depending on the legal basis for processing but also on other
factors. Not all of these rights will apply all of the time, but you should be prepared to be
able to fulfil the main ones.
• Right of access: requires you to respond to Subject Access Requests (i.e. provide
a copy of all of the information held on a particular individual). Almost always
applies.
• Right to rectification: requires you to update their information upon request.
Almost always applies.
• Right to erasure (the ‘right to be forgotten’): requires deletion of personal data
held on the subject. Applies when the legal basis is Consent and, in certain
cases, Legitimate Interests.
• Right to object: in certain circumstances, requires a halt all processing of their
personal data. 
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• Right to restrict processing: in certain cases, requires that an individual’s data is
marked as ‘not to be processed’ and that no action is performed on the marked
data.
• Right to data portability: in certain cases, requires that we provide the personal
data we hold on an individual in a structured, commonly used and machine
readable format.  Only applies to entirely automated processes.
35. In the cases where the data subject’s rights apply, will fulfilling any be problematic? 
Right to erasure (the ‘right to be forgotten’): these requests would be considered on a
case by case basis, nonetheless it is unlikely to be applicable to the vast majority of
personal information held. 
Right to object: stopping the processing of personal information may halt the
provision of appropriate support that Social Work can provide/facilitate to data
subjects i.e. provision of a current, approved Blue Badge; it may also hinder adult
protection procedures.   Again, it is unlikely to be applicable in most cases. 
Right to restrict processing: restrictions in the processing of personal information may
halt the provision of appropriate support and it may hinder adult protection
procedures.  Again, it is unlikely to be applicable in most cases. 
Data Breaches
All known or suspected data breaches must be investigated and those that are likely to
cause any harm or distress must be reported by the DPO to the Information
Commissioner’s Office within 72hrs. Guidance on this is available on the intranet here,
nonetheless:
36. If a data breach were to occur how would this be flagged up?  Who within the Council
would be initially made aware of a known or suspected breach?  If external company is
being used are there any reassurances, and, what contact details are there? 
Standard Council procedures followed, and if any data is shared with external parties,
then agreed procedures will be followed (e.g. as per DSA/ISP/Contract) 
Standard Council Procedures to be followed including the data protection breach
management reporting, guidance and process. 
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STEP 8: Risk Assessment (Full DPIA)
This section is for reporting the exact privacy risks and issues that have arisen so far, as
well as any others that are pertinent to the project.  For each risk there should be a
matching recommendation or action for how to mitigate it.  Mitigation solutions should
be practical and sustainable.  Reviewing the project once it is operating will help to
identify whether the mitigations are working as planned. 
A privacy risk is the risk that a proposal will fail to meet a data subject’s reasonable
expectations of privacy - for example, the Council failing to comply with Data Protection
legislation, or unreasonably intruding into a data subject’s personal affairs.  Consider
the direct risks from the proposal as well as any consequential effects. 
The following list is of some potential solutions to risks that you may identify. Note that
this list is not exhaustive:
• minimise the amount of personal information collected 
• better and clearer communication with data subjects 
• design the system to provide better security 
• provide training and support for staff to help them get it right 
The best opportunity to identify risks is during consultation. Workshops with the key
people involved in the project, interviews with individuals likely to be affected by the
proposal and conducting a joint review of the documents and procedures relating to the
project are some of the ways that can identify the risks. 
The data protection requirements provide a good framework for asking the right
questions, both legal and non-legal, about the impact on the people involved. 
Description
Likeliho
od
Impact
Risk
rating (L
x I ) Mitigation/
Actions
Residual
Risk
Risk
Owner
Date
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Example only:
Staff not aware of
their obligations when
recording personal
data.  Medium
High
High
All staff to
undertake GDPR e-
learning.
Training guides will
be provided to all
staff involved in the
process.
Medium
Educ. 25/5/18
Data breach due to
employee negligence
(e.g., sending emails
to the wrong
recipients) 
M H MH All staff are trained,
guidance and case
recording
procedure
documents are
available, and the
process to report
suspected/known
breaches is clear
and accessible
including via the
Interchange. 
L SW 27/04/25
CareFirst/Shared
Drive access
disrupted
L H M Backups secured
by ICT, local
knowledge within
the workforce for
the most vulnerable
service users. 
Business
Continuity Plan.
L SW 27/04/25
Accuracy of
information (inc
addresses/numbers
etc)
H M MH Single source of
truth (CareFirst) to
be regularly
updated. Set
procedures for
communications:
e.g. for leaving
voicemails, sending
letters etc.
L SW 27/04/25
Access to /Permission
to access information
M H MH ICT provide
‘permissions’ of
various levels
(including ‘view’,
‘write’ and
L SW 27/04/25
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‘change/edit’) for
information
systems. 
Letters sent to be
marked “for
addressee
only/P&C/Return
address etc”
Access to Records,
inc CareFirst – staff
looking up
inappropriate records
L H M Training is required
before access
given. As above re
permission types.
Records can be
restricted via a
restriction request
form. CareFirst
monitored.
L SW 27/04/25
Physical information
security (paperwork
left on top of car,
cafes, trains etc)
L H M Training and
guidance provided
on how to prevent
such data
breaches/reduce
impacts. 
Procedures include
the requirement to
take only the
required
information out of
the office (i.e. home
visits) and
anonymised where
possible. Use the
Closed Records
Store. 
M SW 27/04/25
Loss of paper files;
e.g. fire at Closed
Records Store, Office
buildings etc
L H MH Various safety
measures in place
on building
security,
information on
where/what
records are stored. 
L SW 27/04/25
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Most paper files are
linked to an
overarching
electronic file on
information
systems.
Information stored in
incorrect places – use
of own devices 
L H M ‘How To’ guides on
case recording and
CareFirst/Informati
on Systems.  No
forwarding of
personal/case info
to personal
devices/ emails is
permitted. 
L SW 27/04/25
Sharing information
between partner
organisations
L M M Information Sharing
Protocols, DSA’s
and Verification
checks in place
when discussing
service user info.
L SW 27/04/25
Information not
received in a timely
manner; either from
partner organisation,
or a concern not
suitably reported
M H H Concerns handled
swiftly, clear
communication
channels between
partner agencies
(for example, Multi-
Agency and Multi-
Disciplinary Team
discussion of an
adult protection
concern report) in
the context of
policies/procedure
s
M SW 27/04/25 
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STEP 9: DPO Advice and Sign off (Brief and Full DPIA)
Once you have completed this DPIA, please return it to the DPO.
Residual risks accepted by:
Contact/Approver/Manager  Chief Social Work Officer
DPIA Status Head of Service and Chief Social Work Officer
Date Final Version 1.0
If there are any residual high risks, the DPO must consult the ICO before
proceeding any further. 
DPO Advice:
Name: Alison Morris, Information Governance Manager & DPO
Date: 6th Aug 2024 
Summary of
Advice:
DPIA has been approved following clarification of,
• Data shared with Social Security Scotland and Scottish
Government 
• Blue Badge Service and data processing relationship with Valtech 
• Whether applications can be progressed via Gov.uk https://apply-
blue-badge.service. 
It’s fine to continue with the DPIA with the following caveats:
• New Privacy Notice required specifically for Blue Badge(s) – to be
completed by Data Protection
• The various Blue Badge forms should be reviewed with new links
to the bespoke Privacy Notice added (at a later date once PN is
completed)
• Sign updated agreement with Valtech (Data Protection Team) 
If anything significant changes then this DPIA should be updated and
reviewed, otherwise this DPIA should be updated and reviewed in 3
years’ time. 
Advice Accepted / Overruled   If overruled, you must explain your
reasons
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By: Name of person accepting or overruling:
Reason for
overruling: 
Date of next
DPIA review:
As above
(Education
only) Link to
RAG List
Guidance: 
When completed please save, rename to DPIA <insert the name of the
project/software/process>
and email dataprotection@moray.gov.uk
Thank you. 
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Appendix A: DPIA Introduction 
A Data Protection Impact Assessment (DPIA) is designed to consider potential data
protection and the privacy impacts of processes and projects; they are a method of
recording identified risks, issues and the safeguarding factors introduced to alleviate
such concerns or potential impacts.  They will assist the Council in adopting “privacy by
design” for any new initiatives that involve personal data as well as consider the potential
data protection and privacy impacts of our decisions, and, demonstrate that we have
done so, as well as comply with data protection legislation. 
All new processes or changes to existing processes involving personal data must undergo
the initial screening questions, which will indicate whether any further steps in the DPIA
are required.  Completing a DPIA offers several practical benefits.  It can identify
problems and opportunities early, which should make it easier and cheaper to address
them.  It is more efficient to build in good privacy management throughout a project,
rather than trying to bolt it on at the end.  It will not be possible to identify and eliminate
every risk, or identify every opportunity, and a DPIA does not aim to do so.  However, it
gives a good chance of identifying the most serious and the most likely problems. 
This template covers the initial screening questions and two levels of DPIA; a brief and a
full DPIA. Data protection legislation requires a full DPIA to be completed to assess
proposed measures that pose particular risks relating to how personal data is used.  For
brief DPIAs only some of the sections are required (Steps 1-5 and 9), whilst all sections
are required for a full DPIA. 
It is essential that the Data Protection Officer (DPO) has oversight of the scope of the
process or project and is able to input as necessary, although the responsibility for
completing the DPIA in a timely manner ultimately falls with the department with chief
responsibility for the process or project.  The DPO signs off DPIAs, however, it is up to
departments to implement recommended caveats and mitigations, if departments do
not plan to do so they should document this at Step 9 of the DPIA. 
A DPIA does not set out to identify and eliminate every possible privacy risk: its role is to
identify genuine risks that are not unreasonably small or remote.  They should be kept up
to date throughout the lifespan of the process or project and reflect any relevant changes;
contact the DPO to make these updates.  It is recommended to revisit DPIAs on a regular
basis. 
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At any stage advice and guidance is available by emailing dataprotection@moray.gov.uk. 
The Council’s DPO is Alison Morris, Records and Heritage Manager.
NOTE for Education/Schools:
Schools and Early Learning Centres should contact LearnTech@moray.gov.uk before
starting a DPIA to avoid duplication of work, as another school may have already
completed a DPIA since more than one school may require access to websites and
applications. 
When completed please save, rename to DPIA <insert the name of the
project/software/process>
and email dataprotection@moray.gov.uk.
Thank you. 
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Definitions 
Data subject – A living individual to whom personal data relates.
Data controller – A body that determines the purposes for and manner in which personal
data is used. This includes employees of the data controller.  The Council is considered
to be the data controller for most of its activities that involve personal data.
Data processor – A third-party body who processes information on behalf of the data
controller. This only applies to third-parties with who a formal contract is in place.  In most
cases you will be a controller who processes their own data rather than purely a
processor, unless a third party has provided you with personal data and there is a legal
contract with them that specifies what you are required to do with this data.
Personal data - Any information relating to a data subject, particularly information that
can be used to identify them.  This ranges from name, age, address and other contact
details to health records, HR records, IP addresses and opinions about the individual.
Process/data process/processing – Relates to any activity you perform on or uses
personal data.  This includes storing and gathering the data.
Data Protection Officer (DPO) – Moray Council’s designated individual, who is
responsible for signing off the outcomes of the DPIA process, is the Records and Heritage
Manager, dataprotection@moray.gov.uk.
Data Protection Legislation primarily includes: Data Protection Act 2018 (DPA) and the
United Kingdom General Data Protection Regulation (UK GDPR). 
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Report to: Economic
Development and
Infrastructure Services
Committee 
Meeting
Date:
11 November 2025  
Report by: Executive Director
Economy, Enterprise
and Operations 
Author: Janet MacDonald  Contact
Email:
Janet.macdonald@moray.gov.uk 
Subject: Active Travel Strategy and Action Plan 
1.  PURPOSE 
☐ For Decision      ☒  For Information 
1.1  The purpose of this report is to note the progress mae over the past year on the
delivery of the Active Travel Strategy, which sets out the Council’s vision and action
plan over 5 years from 2022 - 2027 for Active Travel in Moray.  
1.2  This report is submitted to Committee in terms of Section III (F) (17) of the Council's
Scheme of Administration relating to traffic management functions.   
2.  SUMMARY  
2.1  The Active Travel Strategy annual update provides details of the delivery of Year 3 of
the  Action Plan. 
2.2  There have been many successful new and ongoing projects this past year including
the return of the Speyside Challenge, the delivery of many Active Travel school
initiatives, community Bike Fests and the completion of four construction schemes
including raised crossings along Morriston Road. 
2.3  The focus for new infrastructure in the past year was on more localised interventions
i.e. crossings and improvements, rather than construction of new paths. Therefore, a
total of only 170 m has been added to the Active Travel network through our
construction projects.   
3.  BACKGROUND AND CONTEXT  
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3.1 The Active Travel Strategy (ATS) is a 5-year plan from 2022 to 2027 which aims to
build on the increase in walking and cycling seen over the period covered by the
previous ATS, as well as meeting the Scottish Government requirement for Councils to
have developed an ATS and scheme list to support applications for external funding.  
3.2  Active Travel (AT) has many benefits to both communities and individuals and has a
number of positive outcomes for public health, social inclusion, reducing the
environmental impact of transport and for supporting local economic activity. By
choosing to walk, wheel or cycle over private vehicle use, it can help deliver a low cost,
high return for society as a whole and on individual health. Key policies within the
National Planning Framework 4 (Policy 13 Sustainable Transport and Policy 15 Local
Living and 20 Minute Neighbourhoods) also reiterate the importance and benefits of AT.  
3.3 This is the third annual progress report, three years on from the approval of the ATS in
November 2022. The Annual Report for 2024/25 is attached as Appendix 1. 
4.  ATS PROGRESS REPORT  
4.1 The progress report (Appendix 1) presents a summarised overview of progress to date
against the third year of the ATS Action Plan, as well as proposed activities for
supporting the next stages of the strategy. 
Funding 
4.2 A new fund was introduced at the beginning of 2024 for FY 2024/2025. Active Travel
Tier 1 (ATIF 1) which is a direct grant from Transport Scotland and is allocated on an
annual basis. This is now the second year of funding through ATIF1which is distributed
and allocated directly to each Local Authority on a weighted pro rata basis.  
4.3 Tier 1 allocation for 2025/2026 is £500,000, a slight increase on the 2024/2025
allocation of £433,813. 
4.4 The funding mechanism for Behaviour Change projects has also changed, with funding
being distributed again for a second year through the Regional Transport Partnerships
‘People and Place’ programme. The Council has also been awarded £106,998 for
2025/26 from Transport Scotland as a Local Authority direct award (LADA) for active
and sustainable transport to complement the HITRANS funding, and to support the
delivery of active travel initiatives across Moray. 
4.5 The Active Travel Infrastructure Fund (ATIF Tier 2) was introduced in 2023/204.The
fund is available to support the delivery of eligible construction-ready Active Travel
schemes. In February 2024 an application was submitted for a medium sized ‘shovel
ready’ project to be funded and completed in 2024/2025. A total of 70 applications were
received by Transport Scotland, with a funding request of nearly £60million. The budget
for ATIF Tier 2 was £20million. An award was granted in November 2024 to provide
raised crossings alongside roads from the A96 to Brumley Brae along Morriston Road.
The project was completed in March 2025. An additional 3 applications to this fund
were submitted in February for 2025/2066. This included two construction projects and
one design project. To date, no awards have been confirmed for medium scale ATIF2
projects. 
4.6 Over the three financial years from 2023/24 to 2025/26, the total confirmed funding
income for active travel initiatives in Moray now amounts to £2.722 million. This
includes:
• 2023/24: £1.2 million — which included funding from the now-discontinued
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Sustrans Places for Everyone programme
• 2024/25: £742,000 — including the first year of ATIF Tier 1 funding (£433,813)
• 2025/26: £780,000 — comprising ATIF Tier 1 (£500,000), LADA direct award
(£106,998), and additional funding through the People and Place programme 
Programme delivery 
4.7 In the past year the following schemes have been progressed, and behaviour change
initiatives delivered through ATIF 1 and 2, as well as LADA and People and Place fund: 
Construction Projects 
• Rafford – New footway
• Coulardbank Road, Lossiemouth – Toucan crossing at Lossiemouth High
School
• Ferry Road and Balnageith Road, Forres - Re-alignment of the junction to
provide wider active travel path and new uncontrolled crossings
• Morriston Road – Raised crossings 
Design Projects
• Victoria Roundabout, Forres - Reallocation of road space (alternative
option for traffic signals)
• Linkwood Road, Elgin - Pedestrian island and associated road alignment
• Coulardbank Road, Lossiemouth - Cycle track options between the A941
and Muirton Road
• Victoria Road junction, Forres – Road space reallocation
• St Peters Road/Barhill Road/Golf View Drive, Buckie – Pedestrian
improvements at junction 
Behaviour Change and other projects
• Over two hundred events and activities held by Moray Bothy, Cooper
Park – Led rides, cycle confidence sessions, Ebike loans, maintenance
lessons and pop up community events
• Launch of public ebike hire scheme Hi-Bike in Elgin
• Fourth year of the ‘Speyside Challenge’
• Four ‘Bike Fest’ events held in Cullen, Fochabers, Aberlour and Rothes
• Active Travel Breakfast at Bishopmill Primary
• Bike Bus initiative Dyke Primary
• Development on four new School Route Audits to evaluate the quality of
the walking environment around schools
• Feasibility study for improvements on NCN1 route Portknockie –
Findochty
• New Elgin cycle barrier replacements
• Installation of cycle parking and repair stations at 3 new locations
• Moray Council staff travel survey
• Update of Active Travel pages on Moray Council website 
4.8 Of the above projects, the launch of Hi-Bike is of particular interest to note. The
initiative was due to be officially opened by Fiona Hyslop MSP, Minister for Transport in
September 2025. However, due to last minute parliamentary business this has had to
be cancelled, and the launch will be rescheduled. The HITRANS trial expansion of the
Hi-Bike electric bike hire scheme in Elgin, will build on its success in Inverness and Fort
William. Seven docking locations have been strategically selected to serve key
residential, educational, and recreational areas, including UHI Moray, Elgin Railway
Station, and Cooper Park. 
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4.9 The Elgin Hi-Bike expansion is expected to deliver a range of social, environmental,
and economic benefits:
• Reduced Carbon Emissions: By encouraging a shift from car journeys to Ebike
use, the scheme supports local and national climate targets.
• Improved Accessibility: The locations have been chosen to ensure broad
access across Elgin, including underserved residential areas and key transport
hubs.
• Health and Wellbeing: Promoting active travel contributes to improved physical
and mental health for users.
• Economic Uplift: Increased footfall in the town centre and local parks may
benefit nearby businesses and services.
• Transport Integration: The scheme complements existing public transport
options, offering a flexible and sustainable first/last-mile solution.
• Data-Driven Planning: Usage data from the trial will inform future infrastructure
investments and potential permanent expansion. 
4.10 It is also worth highlighting the successful application to Transport Scotland’s new
Active Travel Infrastructure Fund (ATIF) Tier 2 in February 2024 secured £152,298 to
install raised crossings at four junctions along Morriston Road. This funding enabled a
key improvement to the shared path, addressing safety and accessibility concerns
raised by cyclists and other users. The raised table crossings will enhance route
continuity, reduce vehicle speeds, and improve access for pedestrians, cyclists, and
wheelchair users. These upgrades also strengthen connections to schools, leisure
facilities, and National Cycle Network Route 1. 
4.11 The progress report contains new observed cycle and pedestrian count data from
January 2024 – December 2024. Fixed count sites within the urban areas of Moray are
continuing for a third year to show an upwards trend in the number of pedestrians and
cyclists. Those that have not increased, have generally stayed the same, with no
obvious concerning decreases in usage. Many counter sites are now showing figures
higher than during the Covid–19 pandemic where figures were exceptionally high, so
the trend is promising. 
Data 
4.12 Counters on routes which people use for leisure purposes had previously shown a
reduction in movements in 2022, but 2023 data showed an increase in cycling in 4 out
of the 6 leisure routes, with slightly higher figures than pre-covid. 2024 data shows that
numbers have largely remained the same on most of these leisure routes. However
there has been a decrease in use at some locations, including in the number of
pedestrians at Fiddich Park, Craigellachie. Several of the counters on the upgraded
section of the Speyside Way between Craigellachie and Cragganmore, continue to
show a yearly increase in pedestrians and cyclists’ usage since 2022. This can be
partly attributed to the upgrade improvement works along the Speyside Way, but also
because of our annual ‘Speyside Challenge, which is held every September between
Craigellachie and Cragganmore. September figures at each of the counter locations
have generally seen an increase across the last 4 years with the challenge proving
increasingly popular with local residents. When comparing 2018 and 2019 to current
data there is now an overall picture of increasing active travel across both our urban
and leisure routes. 
Next Steps 
4.13 In line with the Moray Local Development Plan review, preparation for the next Active
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Travel Strategy (ATS) covering the period 2028 to 2038 will begin in 2026. This
process will involve a comprehensive review of the current strategy, including all
objectives and actions, to assess progress, identify gaps, and ensure alignment with
emerging local and national policy priorities. The updated strategy will reflect new data
trends, infrastructure developments, and behaviour change insights gathered through
monitoring tools such as fixed counters, school travel surveys, and workplace
engagement. It will also incorporate feedback from community consultations, lessons
learned from the delivery of the current ATS, and integration with other key documents
such as the Active Travel Masterplans, the People and Place programme, and the
evolving priorities of Transport Scotland and HITRANS. Particular attention will be
given to ensuring the strategy remains inclusive, evidence-led, and responsive to the
needs of all users, including those underrepresented in active travel. A refreshed
Monitoring and Evaluation Framework will also be developed to support robust
performance tracking over the next decade.  
5.  SUMMARY OF IMPLICATIONS  
5.1 The table below shows whether risks and implications apply if the recommendations
are agreed: 
SUBJECT YES NO
Corporate Plan and 10 Year Plan (Local Outcome Improvement
Plan) 
X
Policy and Legal  X
Financial  X
Risk  X
Staffing  X
Best Value and Transformation  X
Property  X
Information Communications Technology/Digital             X
Equalities. Social Inclusion and Economic Impact            X 
Climate Change and Biodiversity Impact           X 
5.2 Corporate Plan and 10 Year Plan (Local Outcomes Improvement Plan (LOIP))
Improved Collaborative Leadership, as part of continuous improvement through Best
Value, will better enable the Council to fulfil the ambitions set out in its strategic plans. 
a) Links to Council Corporate Plan – The proposals in this report support and
contribute to improved outcomes for communities as outlined in the following
Council Plan strategic priorities:
☐ Tackle Poverty and Inequality.
☐ Build Stronger Greener Vibrant Economy.
☐ Build Thriving, resilient, empowered Communities.   
b) Links to Local Outcomes Improvement Plan – The proposals in this report support
and contribute to improved outcomes for communities as outlined in the following
Local Outcomes Improvement Plan priorities:
☐ Developing a diverse, inclusive, and sustainable economy
☐ Building a better future for our children and young people in   Moray.
☐ Empowering and connecting communities.
☐ Improving wellbeing of our population 
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5.3 Policy and Legal 
The Active Travel Strategy and Action Plan links to National and Regional policy
objectives, as set out in the ATS strategy document, and Action 31 in the Moray Local
Development Plan 2020 Delivery Programme and Action Plan – Encourage Active
Travel. As well as Policy 13 Sustainable Transport, and Policy 15 Local Living and 20
Minute Neighbourhoods within NPF4. 
There are no legal implications arising from this report.  
5.4 Financial 
There are no financial implications arising from this report. However, it should be
noted that comprehensive delivery of the Action Plan will be contingent on ongoing
successful sourcing of additional grant funding (subject to Council approvals). 
As set out in the ATS, it is intended to continue to fund the Action Plan through existing
and any new AT funding streams, as well as applications for external grant funding
when the opportunity arises. 
With the increase of planned infrastructure, a bigger proportion of maintenance budget
will be needed to be spent in the future on any new Active Travel routes, including
winter maintenance and gritting. Roads Maintenance are currently responsible for over
38 miles of cycle track both remote and adjacent to the road. 
One off Costs:
Service
Area
Budget Budget
Years
Proposed
Spend
this Year
Virement
From
Other
Comments
n/a     
Annually Recurring Costs:
Service
Area
Budget With
Effect
From
Annual
Net
Impact
Virement
From (if
applicable)
Other
Comments
n/a     
5.5 Risk 
Without an up-to-date Active Travel Strategy and Action Plan, there is a risk of a
fragmented approach to the provision of Active Travel infrastructure and Behaviour
Change programmes, which may not fully capitalise on existing and future funding
opportunities. Having an Active Travel Strategy, and list of identified schemes has been
highlighted as an ongoing requirement for the Scottish Government’s ‘Active Travel
Infrastructure Fund’.  
5.6 Staffing 
The delivery of the ATS and building of new infrastructure is dependent on the current
level of staff resources being maintained. Significant projects bid for through the Active
Travel Infrastructure Fund will require additional staff members/support from external
consultants, the cost of which will be included as part of any funding application.  
5.7 Best Value and Transformation 
Not applicable.  
5.8 Property
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There are no property implications arising from this report.  
5.9 Information Communications/Technology/Digital 
Not applicable.  
5.10 Equalities, Social Inclusion and Economic Impact 
Supporting and raising the profile of Active Travel is beneficial for public health, helps to
tackle inequalities, enhance inclusion and enhances accessibility for all.  The provision
of new shared use paths when developing the network in Moray, will create better
accessibility.
This evidences the Council’s consideration of and compliance with the public sector
equality duty in terms of eliminating discrimination and promoting equal opportunities
while helping to reduce any socio-economic disadvantage.  
5.11 Climate Change and Biodiversity Impacts 
Promoting Active Travel is one of the key actions in the Council’s Climate Change
Strategy. The Active Travel Strategy and Action Plan can provide a positive impact on
the climate through enabling and encouraging alternative modes of travel through
Moray. Reduced emissions support nature recovery and the overall improvement of
environments. Where appropriate, new Active Travel infrastructure will seek to provide
areas for biodiversity e.g. by provision of rain gardens as part of any surface water
management proposals. 
6.  CONSULTATION  
6.1 This report has been prepared in consultation with Executive Director Economy,
Enterprise and Operations, Head of Operations and Environment, Chief Financial
Officer, Service Manager Legal Services, R Geddes-Stewart, Senior HR Adviser, Equal
Opportunities Officer, Service Manager Strategic Planning and Development and
Principal Climate Change Strategy Officer, and L Rowan, Committee Services Officer
and any comments made have been incorporated into the report.   
7.  BACKGROUND PAPERS  
7.1 Report to EDandISCommittee on 15 November 2022
Report to EDandIS Committee on 14 November 2023
Report to EDandIS Committee on 12 November 2024 
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Moray Council
ACTIVE TRAVEL STRATEGY
ANNUAL
UPDATE
2025
Appendix 1
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2
Moray Active Travel Strategy - ANNUAL UPDATE 2025
Bikefest 2025
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Contents
Moray Active Travel Strategy - ANNUAL UPDATE 2025
1
Introduction 2
Trends in Data 3
Year 2 Action Plan 10 
Funding 16 
Activity during 2024 17
Active Travel Tier 1 Funding 17
Tier 2 Active Travel Infrastructure Fund 18
HITRANS 19
Moray Bothy 20
Hi-Bike 23
NCN1 Portknockie to Findochty 24
Morrison Road - Raised crossings 24
Rafford - New footway 25
School Engagement 26
Active Travel Information Documents 31
Bike Fest 32
Speyside Challenge 34 
Priorities for the year ahead 35
ATIF Tier 1 Direct Award 35
Active Travel Infrastructure Fund (ATIF Tier 2)
Update 35
Future Pipeline Projects for ATIF Tier 2 
consideration 36
HITRANS 37
Preparing the next Active Travel Strategy 37 
Summary 38
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Moray’s 5-year Active Travel Strategy (ATS) 2022-2027, approved in Nov 2022, sets out
a vision to ‘create a culture and environment where active travel is embedded within
our communities as the automatic and obvious choice for everyday journeys to
school, work and leisure by: providing a safe, integrated and accessible network for
all.’ It also includes a set of six objectives from which an Action Plan has been
developed, with the detailed steps that need to be carried out to achieve the
objectives. 
A Monitoring Plan is an essential part of an ATS and is one of the key requirements
outlined in guidance published by Sustrans and Transport Scotland. It is important to
ensure an effective monitoring and evaluation framework is in place for assessing
progress in the delivery of the vision and objectives of the Strategy. 
Although annual reporting on the Action Plan is managed by the Sustainable Travel
officer, delivery of the targets within relies on continual input and partnership
working from relevant Moray Council departments, external partners and funding
bodies, local businesses and residents to highlight, inform and provide feedback on
how improvements can be made. 
This is now the third annual report of the strategy which
presents a summarised overview of progress to date,
against the third year of the ATS Action Plan, as
well as plans for next steps of the strategy. 
This report also includes observed cycle
and pedestrian data count from
January 2024 – December 2024, and
an update on both new
infrastructure provision and
active travel behaviour in Moray. 
Introduction
2
Moray Active Travel Strategy - ANNUAL UPDATE 2025
Bikefest 2025
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Moray Active Travel Strategy - ANNUAL UPDATE 2025
3
Trends in Data
Active Travel monitoring is undertaken through several various data sources. This
includes local sources such as Travel Tracker in Primary schools, Bikeability quarterly
stats, staff travel surveys and data from fixed site counters that collect both cycle and
pedestrian data. National sources are also assessed at regular intervals such as Scottish
Household Survey, Hands Up Scotland Survey, Cycling Scotland’s Annual Monitoring
update and Scottish Census Survey. Travel to work data for the 2022 Scottish census
was released in September 2024. 
Other behaviour change initiatives delivered under HITRANS ‘People and Place’
programme also provide data on the number of participants, or types of journeys made,
adding to the overall picture of active travel in Moray. 
As mentioned, one of the data sources comes from the Scottish Household Survey
(SHS) that is used by Cycling Scotland in their Annual Cycling Monitoring report. This
survey has an annual sample size of around 10,000 households with an overall
response rate of around 46% and provides trends and context at Local Authority level.
Data from the 2024 report based on 2023 figures show that 60% of all journeys made
in Moray are under 5km.  Pre covid figures from 2019 show that this is a big increase
in shorter journeys from 52% in 2019. 2023 Has also seen a large increase in
employees who regularly or usually cycle to work at 9.2%, compared to 5.5% in 2019.
The Scottish Household Survey (SHS) and Scotland's Census, while both important
sources of data for active travel, can produce different results due to their differing
methodologies and purposes. The SHS is a continuous survey designed to provide
ongoing insights into various aspects of Scottish life. In contrast, the Census is a large-
scale headcount conducted every ten years to provide a detailed snapshot of the
population at a specific point in time. These differences in approach can lead to
variations in the data collected by each source. 
Cycling as the main
mode of travel to
work in Moray was
1.7%,
higher than the
Scottish national
average of
1.4%
Walking was
8.8%
higher than the
national average of
7.3%
Percentage of
journeys under
5km in Moray is
31% 
which is the
same as the
Scottish average
Scottish Census Survey
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Council Staff Travel Surveys takes place every 2 years in 2021, 2023 and 2025.
Between 2023 and 2025, there has been a noticeable shift in work and travel
behaviours. The proportion of individuals working exclusively from home declined
from 7% to 4%, indicating a move towards more hybrid working arrangements. Active
travel has seen a positive trend, with cycling to work increasing from 5% to 8%, while
walking continues to be the most popular form of active commuting. 
Public transport usage has also grown, with bus travel rising from less than 1% in
2023 to over 5% in 2025. Meanwhile, residential street parking has increased by 7%,
reflecting changes in commuting patterns. Since the restoration of Rose Cottage as a
cycle parking facility, its usage has significantly increased—now used by 8 out of 15
staff who cycle to work, compared to just 2 out of 14 in the 2023 staff travel survey. 
Travel for Council business has increased, with daily travel rising from 5% to 8%.
However, a larger proportion of individuals—32% in 2025 compared to 26% in 2023—
report never travelling for Council business. Notably, cycling for Council-related travel
has grown from less than 1% to over 5% during the same period. 
The 2024 Hands Up Scotland Survey (HUSS) results have now been published,
offering valuable insights into how pupils travel to school across the country. This
year’s data shows that active travel modes—including walking, cycling, and
scootering—account for 47.4% of school journeys, a decrease from 52.9% in 2023.
This shift is largely attributed to changes in how secondary pupils travel, with a
notable increase in those being driven to school, rising from 13.7% in 2023 to 21.2%
in 2024. Bus usage among this group also rose by 2 percent over the same period.
4
Moray Active Travel Strategy - ANNUAL UPDATE 2025
How pupils travelled to school - Moray
Walk
Cycle
42.9%
7.3%2.7%12.5%
18%
14.8%
1.6%0.3%
38.1%
6.8%
2.5%
13.9%
20.7%
15.9%
2.0%0.1%
Scooter/Skate
Park & Stride
Driven
Bus
Taxi
Other
20232024
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Moray Active Travel Strategy - ANNUAL UPDATE 2025
5
In contrast, primary school travel patterns have remained relatively stable.
Encouragingly, there has been an increase in Park and Stride and a slight decrease in
pupils being driven, suggesting that behaviour change initiatives are having a positive
impact at the primary level. It is also worth noting that the overall school response
rate to the survey was 8% lower than in 2023, which may have influenced some of the
year-on-year comparisons. 
Looking more closely at the mode of travel data: 
Walking to school remains the most common form of active travel, with 38.1% of
pupils walking in 2024. Although this represents a decrease of 4.8 percentage
points from 2023, it continues to be a key mode of travel for many students. 
Cycling to school saw a small decline of 0.5 percentage points, with 6.8% of pupils
cycling in 2024, indicating a relatively stable uptake of this active option. 
Scootering or skating to school remained unchanged at 2.5%, showing consistent
interest in these fun and active travel methods. 
Park and Stride increased by 1.4 percentage points to 13.9%, reflecting a growing
preference for combining car travel with walking, which supports both convenience
and physical activity. 
Being driven to school rose by 2.7 percentage points to 20.7%, suggesting that
more families are opting for this method, potentially due to changing schedules or
logistical needs. 
Bus travel increased by 1.1 percentage points, reaching 15.9% in 2024,
highlighting a growing reliance on public transport as a practical and accessible
option. 
Taxi use also saw a slight increase of 0.4 percentage points, now accounting for 2%
of school journeys, indicating a small but notable rise in this flexible transport
choice. 
Overall active travel (walking, cycling, scootering/skating) experienced a decrease
of 5.5 percentage points, now at 47.4%. Despite this, nearly half of all students
continue to travel to school in an active way. 
Private motorised transport usage has grown by 3.2 percentage points since
2015, now at 22.7% in 2024, reflecting broader societal trends and highlighting the
importance of continued efforts to promote sustainable travel options. 
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6
Moray Active Travel Strategy - ANNUAL UPDATE 2025
In the 2024/25 academic year, 1,055 pupils completed Bikeability Level 2 and 793
completed Level 1 across Moray. A total of 42 out of 44 schools participated in the
programme—an increase from 40 schools the previous year, representing a 4.55%
rise in participation. Over 320 pupils took part in Learn to Cycle sessions, and P1–P3
cycling was delivered in 30 schools. These figures reflect the highest delivery rates to
date and demonstrate continued growth in cycling education across the region. 
Fixed count sites within the urban areas of Moray are continuing for a third year to
show an upwards trend in the number of pedestrians and cyclists. Those that have
not increased (around 40%), have generally stayed the same, with no obvious
concerning decreases in usage. Many counter sites are now showing figures higher
than during the Covid–19 pandemic where figures were exceptionally high, so the
trend is promising. There has been a particularly large increase of cyclists outside
Elgin Library (40%) for the 2nd year in a row which, given its location, may indicate
growth in the numbers of people commuting into Elgin from areas to the north. This
is also nearly 50% higher numbers than during the covid-19 pandemic. Waulkmill site
in Elgin has also seen a significant increase (30%) of pedestrians in 2024, the highest
figures in 6 years. 
Elgin-Library
Year
2019
2020
2021
2022
2023
2024 
Elgin-Waulkmill
Year
2019
2020
2021
2022
2023
2024
Growth D
-7.35%
0.00%
0.00%
-46.03%
70.59%
20.69% 
Growth D
-20.00%
112.50%
-45.10%
182.14%
-
30.38% 
AADT
510
327
415
288
403
569 
AADT
129
151
109
7
-
30 
Growth D
-6.76%
-35.88%
26.91%
-30.60%
39.93%
41.19% 
Growth D
-5.84%
17.05%
-27.81%
-93.58%
-
328.57%
Bikes People
AADT
63
63
63
34
58
70 
AADT
24
51
28
79
*
103
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Moray Active Travel Strategy - ANNUAL UPDATE 2025
7
Counters on routes which people use for leisure purposes had previously shown a
reduction in movements in 2022, but 2023 data showed an increase in cycling in 4 out
of the 6 leisure routes, with slightly higher figures than pre-covid. 2024 data shows
that numbers have largely remained the same on most of these leisure routes, with
some decrease’s notable, especially in pedestrian figures at Fiddich Park. Reasons for
this is unknown at the moment, but there has been a 90% reduction in usage.
However, of particular interest is that several of the counters on the upgraded section
of the Speyside Way between Craigellachie and Cragganmore, continue to show a
yearly increase in pedestrians and cyclists’ usage since 2022. This can be partly
attributed to the upgrade improvement works along the Speyside Way, but also
because of our annual ‘Speyside Challenge, which is held every September between
Craigellachie and Cragganmore. September figures at each of the counter locations
have generally seen an increase across the last 4 years with the challenge proving
increasingly popular with local residents. When comparing to 2018 and 2019 to
current data there is now an overall picture of increasing active travel across both our
urban and leisure routes. 
Aberlour Park
Year
2020
2021
2022
2023
2024 
Cragganmore
Year
2022
2023
2024 
Dalmunach
Year
2022
2023
2024
Growth D
153.85%
-21.21%
-7.69%
37.50%
-27.27% 
Growth D
-
125%
0% 
Growth D 
160%
15.38%
AADT
113
122
122
229
108 
AADT
15
26
44 
AADT
14
22
22 
Growth D
46.75%
7.96%
0.00%
87.70%
-52.84% 
Growth D 
73.33%
69.23%’/ 
Growth D 
57.14%
0.00%
AADT
33
26
24
33
24 
AADT
4
9
9
AADT
5
1315
Bikes People
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Moray Active Travel Strategy - ANNUAL UPDATE 2025
Elgin - Lossiemouth
Year
2019
2020
2021
2022
2023
2024 
Cullen
Year
2019
2020
2021
2022
2023
2024
Growth D
-8.11%
30.88%
-17.98%
-9.59%
7.58%
-100.00% 
Growth D
27.27%
78.57%
-20.00%
-15.00%
11.76%
-47.37%
AADT
68
89
73
66
71
0
AADT
14
25
20
17
19
10
Bikes
Garmouth
Year
2019
2020
2021
2022
2023
2024 
Kinloss - Findhorn
Year
2019
2020
2021
2022
2023
2024
Growth D
7.14%
46.67%
-20.45%
-14.29%
6.67%
-
Growth D
-4.40%
32.18%
-18.26%
-7.45%
4.60%
-9.89%
AADT
30
44
35
30
32
*
AADT
87
115
94
87
91
82
Bikes
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9
Specific data for each counter can be found in Appendices 1 and 2 attached to this
report. Where some months are marked with an * this is because of the counters
failing, or the data having been corrupted. 
All the above data feed into the below overall Council Key Performance Indicators
(KPI’s); 
KPI 1:  Modal share of active travel journeys to education
KPI 2:  Modal share of active travel journeys to work
KPI 3:  Number of active travel journeys recorded at fixed site counters
KPI 4:  Length of new active travel routes developed on:             
1) Public Road Network             
2) Core Path Network
Bike Port, Mosstodloch
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Moray Active Travel Strategy - ANNUAL UPDATE 2025
Year 2 Action Plan
The tasks for year 3 of the Action Plan were set based on the timescale from the ATS
overall 5-year action plan, which also included a small number of tasks carried over
from year 2. The progress on these actions is set out below. Further information on all
the actions can be found within the ATS. 
The status of progress against each task has been rated using a Traffic Light system.
The ratings are defined as follows: 
BLUE      Target achieved; 
GREEN   On track for achievement; 
AMBER  On track for achievement but with some delay or uncertainty; 
Action 2     Develop Active Travel Masterplans for key settlements in Moray
B) Consult with relevant
communities and
stakeholders to
identify demand for
movement and
‘missing’ links in the
network
On track for
achievement
– ongoing
task
Consultation for all 8
agreed communities
completed. Additional
Active Travel Masterplan
documents for Forres
and Lossiemouth now
completed as included in
appendix of report for
approval. This now bring
the total to 3 completed
masterplans Remaining
community documents,
and engagement for
additional 4
communities will follow
in 2026 and 2027.
Moray Council
Task Status of
Progress
What was achieved Lead Partner/
organisation/
team
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Task Status of
Progress
What was achieved Lead Partner/
organisation/
team
Action 3     Embed Active Travel opportunities within new developments 
Moray Active Travel Strategy - ANNUAL UPDATE 2025
11
a) Apply Local
Development Plan
policies to ensure
that residential
streets are
designed to
encourage walking
and cycling over
the use of the
private car by
providing well
connected, safe
and appealing
routes. 
b) Ensure that
developments that
are adjacent to un-
developed sites
make allowance
for future-
connections for
pedestrians and
cyclists.
On track for
achievement
– ongoing
task
This is an ongoing task
with meetings between
Transport Planning officers
and Active Travel officers. 
Some key links with TP and
AT;
Active Travel Buckie
document and Application
21/01224/APP – Developer
obligations towards a new
Active Travel Bridge over
Burn of Buckie 
Forres South
Developments –
Contributions and forward
funding to deliver a new
signalised junction to
improve/prioritise
pedestrian crossing
movements. 
Elgin South –
New/extended cycle paths
provided along Linkwood
Road and Birnie Road 
Findrassie – New cycle
paths within development
which will form part of a
connected network of
active travel routes across
the north of Elgin and
improvements to routes
connecting the site with
existing development and
routes to the south.
Moray Council
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Moray Active Travel Strategy - ANNUAL UPDATE 2025
Action 4     Encourage and facilitate walking and cycling as leisure and tourist                    
activities to provide benefits to health and local economy 
A) Continue partnership
working with local
organisations Outfit
Moray, NHS
Grampian and
Cycling UK Moray to
organise events and
activities to trial
electric bikes, pedal
bikes etc. to promote
the health benefits
of cycling and
walking to residents
and visitors to the
area 
e) Support Third Parties
seeking to provide
simple and
affordable bike and
eBike hire stations at
key locations in
Moray. 
Achieved 
On track for
achievement 
Work is ongoing with all
partners on events and
activities promoting
Active Travel.  In May this
year a showcase event for
funders and partners was
held with over 50 in
attendance from various
organisations and
charities to illustrate the
breadth of the work being
undertaken through the
Moray Bothy and the
numerous success
stories. 
Four Bike Fests have been
held in Cullen, Fochabers,
Rothes and Aberlour with
Outfit Moray and Cycling
UK, Moray CAN (TSI), UHI
Moray as well as other
partner organisations. 
The Speyside Challenge
returned for a 4th year in
September and was the
most successful to date. 
The HITRANS and Moray
Council trial for a new Hi-
Bike scheme in Elgin is
due to launch end
September 2025 across
seven locations. The
transport minister will be
officially opening the
project. 
Moray Council 
Moray Council 
Task Status of
Progress
What was achieved Lead Partner/
organisation/
team
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Moray Active Travel Strategy - ANNUAL UPDATE 2025
13
Task Status of
Progress
What was achieved Lead Partner/
organisation/
team
h) Work together with
bus operators to
support and
encourage additional
Bikes on Buses
services across
Moray 
On track for
achievement
with some
delay or
uncertainty 
Project to install bike
racks on the No 35 route
has begun and was due
to complete in June.
However, due to some
delays with Stagecoach
this has been delayed
with no confirmed date
yet agreed. It is hoped it
will be completed by
October.
HITRANS with
support
Moray Council 
b) Determine locations
for additional cycle
parking at transport
interchanges/key
destinations, where
appropriate in
consultation with the
landowner and/or
surrounding
businesses. 
e) Ensure all new
developments
provide secure cycle
parking as set out in
the Moray Local
Development Plan
On track for
achievement 
Achieved 
An audit of existing cycle
parking infrastructure
was completed
December 2024, to
review where the gaps
across the network and
key destinations are. A
funding application was
submitted to HITRANS in
June for new cycle
parking and storage as
well as repair stands and
pumps across a variety
of locations in Moray.
These will include
schools, health and
workplace settings. 
Same as Action 3. Work
is ongoing and new
planning requests are
reviewed to ensure the
correct provision of cycle
parking is available 
Moray Council
with support
from HITRANS 
Moray Council 
Task Status of
Progress
What was achieved Lead Partner/
organisation/
team
Action 5     Provide new/improved cycle parking/ facilities at key destinations                    
and transport interchanges in Moray 
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14
Moray Active Travel Strategy - ANNUAL UPDATE 2025
a) Work with local
employers to achieve
Cycling Scotland’s
“Cycle Friendly”
employer status. 
d) Promote the use of
Council pool bikes to
encourage staff to
undertake shorter
work-related
journeys by bike. 
Part
achieved –
ongoing task 
Achieved 
Work on the new
Sustainable Travel has
been completed and
published on the website
and provides
information on what we
can offer to workplaces
for Travel Planning
Connectivity, People and
Place - Moray Council.
We have also partnered
up with TravelKnowHow
Scotland (funded by
HITRANS) to work with
six workplaces across
Moray using a tool to
work with organisations
looking at commuting. 
Staff led rides and
confidence sessions have
been offered to staff as
part of the work of the
Council Travel Plan
working group. Articles
have been included in
Connect and many
promotional material
shared regularly on
Interchange.
Moray Council 
Moray Council 
Task Status of
Progress
What was achieved Lead Partner/
organisation/
team
Action 6     Work with local employers (including Moray Council) and their staff                    
to encourage more walking and cycling to and from work 
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Moray Active Travel Strategy - ANNUAL UPDATE 2025
15
c) Continue to
deliver and
promote
Bikeability Level
2 in primary
schools 
f) Continue
running
educational
events like ‘Park
Smart Moray’ to
encourage more
pupils to travel
actively to
school. 
g) Audits of safe
routes to school
will be carried
out for all Moray
schools within a
3 mile radius. 
Achieved 
Achieved 
Achieved 
Partnership working with Cycling
Scotland and Outfit Moray has
continued for both funding and
delivery of Bikeability across
schools in Moray. Funding for
25/26 academic year was
confirmed in August of £81,920.
This is a very slight decrease on
last year’s award due to no
funding needed this year for a
new fleet of bicycles. 
19 out of 19 funded schools
using Travel Tracker with more
than 60% of them tracking at
over 50%. A 4 week Bike Bus was
held at Dyke Primary, as well as
an Active Travel breakfast at
Bishopmill which was covered
across various media. New Elgin
held a road safety week and
during health week, the pupils
of Hopeman Primary met to
walk to school together on the
walking bus. 
Safer Route Audits have now
been completed at an additional
four schools this FY, bringing the
completed total to twelve. They
are Keith, Burghead, Pilmuir and
Applegrove primary. This task
will require input and support
from the schools and is
supported by colleagues at
Living Streets. Ongoing work on
this programme is subject to
external grant funding. 
Moray Council
supported by
Cycling
Scotland and
Outfit Moray 
Moray Council 
Moray Council 
Task Status of
Progress
What was achieved Lead Partner/
organisation/
team
Action 7     Work with students and school pupils, staff and parents to                    
encourage more walking, cycling and scooting to and from school/                    
further education
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Moray Active Travel Strategy - ANNUAL UPDATE 2025
All of the below projects have been funded externally through various funding
streams. Below is a list of the funders and funding amounts so far this year;
Funding
Transport Scotland,
Local Authority Direct
Award (LADA) 
£106,999
Cycling Scotland,
Bikeability 
£81,920
HITRANS,
Cycle Parking
Infrastructure 
£93,287
Transport Scotland, 
Active Travel 
Tier 1 Funding 
£500,000
Transport Scotland, Active
Travel Infrastructure Fund
(ATIF)  Tier 2 
£TBC
Sustrans, 
NCN Improvements 
£TBC
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Moray Active Travel Strategy - ANNUAL UPDATE 2025
17
Active Travel Infrastructure Fund (ATIF 1)
ATIF 1 funding was introduced at the beginning of 2024 for FY 2024/2025, to replace
the previous Cycling Walking Safer Routes (CWSR) fund from Transport Scotland and
is now in its 2nd year. Following approval through both Transport Scotland and COSLA
processes, the total funding provided directly to LAs through Tier 1 in 2025-26 is £37.5
million – an increase from the £35 million provided in 2024-25. 
The fund is provided as part of the General capital grant from Transport Scotland for
infrastructure projects, with fund objectives to design, develop and deliver Active
Travel interventions that will enhance the safety and accessibility of existing
infrastructure, or introduce new provision to travel safely and more conveniently. 
Allocations are provided on an annual basis. The allocation for 2025/26 is £500,000,
which is an increase on the 2024/2025 CWSR allocation of £433,813 but still lower
than previous years. This has been allocated following the same methodology that
was introduced in 2024-25, including elements to take account of population pro rata,
population density and income deprivation. 
The distribution methodology for the Tier 1 Fund, as agreed with CoSLA, sees funding
allocated on a weighted, pro rata basis as follows (increased to a minimum £200,000
allocation where required): 
54% population: This retains a large amount of continuity from previous CWSR
funding and reflects the fact that LAs of all types require funding. 
40% urban population: Inclusion of this indicator reflects the focus on investment
in Active Travel infrastructure being prioritised in more densely populated areas
with the greatest potential for modal shift. 
6% income deprivation: The National Transport Strategy states that actions will
be targeted towards those needing most help, including those living in poverty. 
Active Travel is the most affordable form of transport in many cases and this
allocation will help ensure that those on low incomes are able to benefit from
improved infrastructure. 
Activity during 2024
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18
Moray Active Travel Strategy - ANNUAL UPDATE 2025
The weightings have been chosen to give roughly equal per-person allocations from
the formula element, so about £2.80 per person, double that for urban population or
deprived non-urban, and three times that if both urban and deprived. Transport
Scotland will continue to undertake an annual assessment process regarding how the
funding has been utilised, and this will inform future decisions whether to increase
the amount of funding to be provided in ATIF 1. Transport Scotland will continue to
engage with Local Authority partners on expenditure and outcomes throughout the
financial year. 
The first ATIF 1 funded programme of works during FY 24/25 included the following
projects; 
Construction Projects – 
Rafford – New footway
Coulardbank Road, Lossiemouth – Toucan crossing
Ferry Road and Balnageith Road, Forres - re-alignment 
Design Projects – 
Linkwood Road, Elgin - Pedestrian island
Coulardbank Road, Lossiemouth - Cycle track options
Victoria Road junction– Road space reallocation
St Peters Road, Buckie – Pedestrian improvements 
ATIF 2 Active Travel Infrastructure Fund
In 2024-25, The Scottish Government launched the ATIF 2 Construction Fund and is
now the primary source for the Scottish Government to fund ‘shovel ready’ active
travel infrastructure. This is a shift from the previous approach where Sustrans
administered Scottish Government funding through its Places for Everyone
programme, which ended in 2024. 
In February 2024 an application was submitted for a medium sized ‘shovel ready’
project to be funded and completed in 2024/2025. A total of 70 applications were
received by Transport Scotland, with a funding request of nearly £60million. The
budget for ATIF 2 was £20million. An award was granted in November 2024 to
complete raised crossings alongside roads from the A96 to Brumley Brae along
Morriston Road. The project was completed in March 2025. 
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Moray Active Travel Strategy - ANNUAL UPDATE 2025
19
HITRANS 
Funding 
Funding for Behaviour Change projects also changed in 2024, with funding being
distributed through the Regional Transport Partnerships (HITRANS). The People and
Place delivery model initiated in 2024-25 is a joined-up delivery system which has two
components: The ‘People and Place Regional Transport Partnership (RTP) Programme’,
and the ‘People and Place Local Authority Direct Award’ (PPLADA). 
The purpose of the People and Place programme is to deliver place-based sustainable
and active travel behaviour change projects that will support people to make more of
their daily journeys by walking, wheeling, and cycling, and to bridge the gaps that exist
between those journeys and the public transport network with options that are more
sustainable than the motor car. The funding helps coordinate delivery, alongside
Local Authorities, of the People and Place Programme, comprised of interventions
identified from the 2024/25 transitional year (Year 1) by continuing with the same four
key themes in Year 2: 
Schools and Young People
Workplaces
Accessibility and Inclusion
Capacity and Capability Building 
This means that except for a small number of programmes (e.g. accredited training
programmes with a strong emphasis on safety like Bikeability), there are no
programmes directly funded by Transport Scotland. However, unlike previous years,
funding through PPLADA is for behaviour change programmes only, with no support
available for maintenance of infrastructure schemes as seen last year in resurfacing
the Elgin to Lossiemouth cycle path and the Alexandra Road underpass. 
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Moray Bothy
The Bothy, which is now in its fourth year, is continuously increasing opportunities for
all living in Moray to become involved in walking and cycling for everyday local
journeys. Since the recruitment of the new Development officer in June 2024, there
has been a notable fast pace of delivery with led rides growing in number and the
demand for adult cycle training increasing. This is indicative of the increased
awareness of the presence of the Hub in Cooper Park and all that is on offer. This
year alone has seen the Bothy engage with just under 1000 people, with 304 cycling
activities delivered. 
There have been two pop up events held in Glenlivet and Tomintoul. Both attracted a
good number of participants. The event in Tomintoul, which was run alongside the
Cairngorm 2030 project officer, saw more than 20 people engage with e-bike try-outs,
a led ride, and security marking for their bikes. 
A series of women’s basic maintenance sessions delivered in partnership with Outfit
Moray also proved to be popular with all three sessions provided sold out. There are
five more of these sessions planned for the remainder of the year due to the
overwhelming popularity and demand that these created. 
The Bothy has continued to strengthen partnerships with the offer of a fleet loan.
Moray Sports Centre have been provided with a small fleet of balance bikes to allow
them to run sessions for under 5s. A local outdoor nursery took a loan of some
balance bikes and a Tern cargo bike for six weeks, and there are discussions around
loaning some bikes to the Moray Art Centre at the Findhorn Community. There has
also been further ongoing work this year with the Active Recovery Moray group.
Further e-bikes have been loaned to allow people who have suffered because of
addiction to get out into the hills on some led mountain bike rides. 
There has been a continuation of the winter rides at the Moray Sport Centre into the
springtime, so that older children and adults with additional needs have been able to
get on a range of adaptive bikes provided by the Moray Connecting Communities
project, the sports centre itself, and our charity partners,
Outfit Moray. The bike fleet has been upgraded,
including receipt of an additional Van Raam e-trike,
and a Van Raam Fun2Go side-by-side e-tandem,
which has been out on loan to a family
throughout March. 
20
Moray Active Travel Strategy - ANNUAL UPDATE 2025
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A second round of sessions has been completed with people from the criminal justice
system, with some new participants along to try out some e-bikes. This work will
continue into the new project year, and it is hoped that some of the participants
might be able to benefit from e-bike loans to provide access to free transportation for
job interviews and meetings. 
Work has continued with local education providers, and the development officer has
put on a range of events at the local college, (UHI Moray); providing students with the
opportunity to try out an e-bike and take home some safe cycling merchandise. 
There has been a continued focus around supporting local businesses with bike
loans, travel planning and cycle training, and the groundwork that has been done will
continue into Q1 of the next project year. 
Most enquiries for bike loans have been via the Hub at Cooper Park. This provides the
Development Officer with the opportunity to explore the type of cycle that would best
fit the individual's needs. The park setting of the Hub is also ideal for individuals to try
out a few different cycles in a safe environment. Follow-up surveys are sent to
participants roughly 3 months after intervention. Although response rates are still
relatively low, the responses received have been positive. For example, respondents
cycling more regularly, feeling more likely to cycle for transport in the future and
feeling more confident and more motivated to cycle. 
“Having the loan of an e-bike has enabled me to get out 
and about when suits me... I’ve saved money by not getting 
public transport and my health must have benefited from not
being so sedentary as well as getting to enjoy the lovely quiet 
cycle routes that I didn’t know existed. A fabulous gift.” 
e-bike loan & confidence session participant 
The growth in the numbers accessing the Hub has been notable aided by an increase
of promotional events and work with partners. It has been recognised that
engagement with local groups has had a positive impact, and the Bothy will continue
to sustain and develop these links further to ensure we reach those that are
underserved and underrepresented in active travel due to financial exclusion, culture,
health conditions and disability. 
Moray Active Travel Strategy - ANNUAL UPDATE 2025
21
Hub - Cooper Park
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Moray Bothy Case Study
We have also been collecting case studies to further demonstrate the impact that the
project is having in Moray. A 51yr old female user of the hub had cycled for several
years but recently noticed that cycling a standard bike was becoming more
challenging – especially on longer journeys. She was interested in finding out if an e-
bike might be right for her. 
Our local development officer worked with her to ensure she was cycling safely and
confidently and to determine which bike would best suit her needs. Starting with a
step-through e-bike, she began to build her confidence, and, with the loan, she was
soon able to start cycling more often and for longer journeys. 
“Cycling lessons with [the development officer] have been super helpful. 
I’m 51 and it’s a great refresher for my cycle awareness. [The loan] has
made a big difference. I am able to be out and about socialising, 
working and [going to] college. I’m able to commit to my weekly 
cleaning job… I wasn’t managing to get there every week before. 
I’m able to save money on bus fares.” 
As well as enabling her to maintain commitments and attend work, she has felt a
notable improvement in her health and wellbeing. 
“It’s improved my health and wellbeing, reduced isolation and [I’m] more
social, I’m able to visit friends. Really, it’s a totally different experience to be
able to have reliable, safe transport that’s a joy to cycle about on. I’m
getting good exercise, connecting with people and saving money.” 
This case study highlights the importance of receiving tailored support with bike loans
to ensure that individuals’ feel safe and confident and that their needs are being met.
It also demonstrates the sizeable difference that that support can have on someone’s
ability to access work, save money, visit friends and improve their health and
wellbeing in the process. 
22
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Hi-Bike
As part of HITRANS’ continued commitment to promoting sustainable travel across
the Highlands and Islands, the Hi-Bike electric bike hire scheme will launch a trial
expansion into Elgin in November 2025. Building on the success of the scheme in
Inverness and Fort William, this initiative aims to provide residents, students, and
visitors with a low-carbon, accessible transport option. Seven strategic locations have
been selected for the initial rollout, ensuring coverage across key residential,
educational, and recreational areas 
Seven strategic locations have been selected for the initial rollout, ensuring coverage
across key residential, educational, and recreational areas: 
1.  UHI Moray – supporting student and staff travel. 
2.  Elgin Train Station – facilitating onward journeys for rail passengers. 
3.  Springfield Drive – serving a densely populated residential area. 
4.  Glassgreen – improving access in the southern part of the town. 
5.  Pinefield Estate – connecting communities in the east of Elgin. 
6.  Cooper Park – encouraging leisure use and active travel. 
7.  Plainstones – providing a central hub in the heart of Elgin’s town centre. 
The official launch event will take place at the UHI Moray docking station, marking a
significant milestone in the region’s active travel strategy. Representatives from
HITRANS, Moray Council, and the local community will gather to highlight the
importance of sustainable transport and the role of e-bikes in reducing carbon
emissions and improving accessibility. The event is expected to attract positive
attention from both the community and local media, with enthusiasm for the
scheme’s potential to enhance mobility and connectivity across Elgin. Attendees will
also have the opportunity to explore the new docking stations and learn how to
access the bikes via the mobile app. 
This expansion will be closely monitored to assess usage patterns, community
engagement, and operational performance, with the potential for further
development based on demand and feedback. 
Moray Active Travel Strategy - ANNUAL UPDATE 2025
23
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NCN1 Portknockie to Findochty
The Portknockie to Findochty stretch of the NCN1 route is approximately 3km
long and connects the two villages via a coastal, cliff front path constituted
of compacted subbase. The path is popular with walkers and cyclists
completing the Moray Coast Trail which sees an average of 23000
users per year. Recently the NCN1 route in Moray has seen upgrades
to the Cullen to Portknockie stretch and also the Garmouth viaduct
to the West of Moray. These projects have received positive
responses from the stakeholders, local users and residents of the
area and have been utilised by a variety of users. 
Following on from these upgrades, Sustrans commissioned Moray
Council to undertake a high-level feasibility study for the NCN1 route
between Portknockie and Findochty, Moray. The established route is
highlighted for upgrade to meet the NCN principles. The aim of the
feasibility study was to lay out and understand the varying factors that may
influence the NCN1 Portknockie to Findochty upgrade project, and to allow Sustrans
to assess options for future opportunities for improvement. 
Morriston Road, Elgin – Raised sideroad crossings on Cycle Path
Following a successful application to Transport Scotland’s Active Travel Infrastructure
Fund (ATIF) Tier 2 in February 2024, funding of £152,298 was awarded to install raised
sideroad crossings at four junctions along Morriston Road. 
Over recent years, the shared path on the north side of Morriston Road had
undergone improvements. However, feedback from cyclists indicated concerns about
the stop-start nature of the route, particularly at junctions with McIntosh Drive, Tait
Avenue, and the access to The Eight Acres. Despite changes to the Highway Code
granting priority to pedestrians and cyclists at such crossings, confusion among road
users remained. 
To address these issues, the junctions were upgraded to raised table crossings. This
intervention clearly established pedestrian and cyclist priority, enhancing safety and
continuity along the route. 
The raised crossings delivered several benefits: 
Improved safety for pedestrians and cyclists through reduced vehicle speeds at
junctions.
Smoother journeys for cyclists and wheelchair users by eliminating the need to
navigate dropped kerbs.
Encouragement of active travel by creating a more accessible and attractive
route.
These improvements also strengthened connections to nearby primary and
secondary schools and provided a direct link to National Cycle Network Route 1
(NCN1), improving access to the leisure centre, playing fields, and the wider town
centre.
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Rafford – New footway
Rafford is a small settlement located approximately 2.5 miles southeast of Forres. The
village does not have its own school; pupils travel to Forres for both primary and
secondary education. The B9010 road runs through the village, which comprises two
distinct areas: Upper Rafford and Lower Rafford. Lower Rafford is home to the
recently closed Rafford Parish Church, while Upper Rafford hosts the well-used
Rafford Village Hall, which serves the local population of around 1,000 residents as
well as neighbouring communities. 
In late 2021, council officers met with two members of the Community Council who
relayed concerns from residents regarding speeding, particularly in Upper Rafford.
Following discussions and speed surveys, it was determined that the primary issue
was not excessive speed itself, but rather poor pedestrian visibility and a lack of
footpaths near the main housing access, which contributed to a perceived sense of
danger. 
At the time, significant timber extraction was taking place in the Dallas area to the
east, with heavy vehicles using the B9010 through Rafford to access the A96 and
routes to the south. It was agreed that the most effective solution would be to
provide a footway alongside the road to improve pedestrian safety. 
Initial plans focused on constructing a footway on the south side of the road to
connect the existing pavement with a proposed development site opposite the Village
Hall. However, negotiations with landowners were unsuccessful. The Community
Council then proposed an alternative route on the north side of the road, where four
property owners generously agreed to sell portions of their land to facilitate the new
pavement. 
Construction was carried out in phases. In 2023, a dense
tree hedge and its roots were removed to allow for the
installation of a new drainage system and approximately
170 metres of footway. The full project was completed by
mid-2024. 
Feedback from the community since completion has been
overwhelmingly positive, with the new pavement reported
to be well-used and appreciated by residents. 
Moray Active Travel Strategy - ANNUAL UPDATE 2025
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School Engagement 
Living Streets Travel Tracker Programme
2024/25 marked the tenth consecutive year of participation in WOW – the year-round
walk to school challenge and the use of the WOW Travel Tracker in primary schools
across Moray Council. By the end of June 2025, a total of 18 schools were registered in
the programme—the maximum number of places available under current funding. 
Engagement levels saw a slight decrease compared to the previous year, with 3,752
children participating in 2024/25, down from 4,198 in 2023/24. This reduction was
attributed to two fewer schools receiving funding, as the programme and budget
were expanded to include other local authorities within the region. Despite this,
participation levels remained consistent with previous years and, in some respects,
exceeded expectations. 
Throughout the year, a total of 122,024 sustainable and active travel journeys were
recorded. Additionally, over 3,000 children logged active travel for short local
journeys, reinforcing the continued success of the programme in promoting healthier,
more sustainable travel habits among young people. 
This year the Living Streets school coordinator has continued to support established
and newly engaged schools to use the Travel Tracker through a variety of means. 
These include: 
Strider visits
School assemblies
Parental engagement at schools
Walk to School Week resources and support.
School route audit activities
Active travel zone maps 
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Activity
Keith Primary Strider visit – Living Streets mascot Strider made a surprise
appearance at a special assembly to congratulate the pupils on their walking and
wheeling to school throughout the year. 
Lhanbryde Primary Health week - As part of Lhanbryde Heath week in May, Living
Streets were delivered road safety and mental health workshops for the whole
school. 
Mosstodloch Primary Badge Winner PR event -
The June 2025 WOW badge design was designed by
Anna from Mosstodloch. To celebrate her amazing
achievement and winning design, a celebration
assembly was held with the whole school and
Strider presented her with a voucher for a surfing
lesson for her and two friends and a bag of Art
supplies for the school. The free surfing lesson was
kindly donated by New Wave surf school in
Lossiemouth. The Northern Scot covered the story. 
Hopeman Primary Walking bus and parents meet
- During health week, the pupils of Hopeman Primary
met to walk to school together on the walking bus.
Pupils, teachers, parents and pooches met at the
seafront to walk to school, where Strider was in the
playground waiting. 
New Elgin Primary road safety week - As part of
New Elgin’s road safety week, Living Streets were
invited to design and deliver bespoke workshops
and classroom sessions over 2 days to the whole
school. In the autumn term the Junior road safety
officers designed a Scavenger hunt for delivery over
road safety week. The Scavenger hunt activity was
set up for the whole school to take part in their
class groups over the two days. 
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Bishopmill Primary Active Travel breakfast - Bishopmill
pupils, their parents/carers and staff met at Eight Acres hotel to
walk to school as part of a walking bus. Bishopmill Junior road
safety officer’s designed Walking Bingo cards for the pupils to
play enroute, highlighting the new road infrastructure
improvement works recently completed on Morriston Road
through ATIF Tier 2 funding. The Walking Bingo cards proved to
be a great way to highlight the improvement works in a fun
and interactive way. 
The mile long route culminated in an Active Travel Breakfast in the school hall with
the breakfast menu, comprising of healthy and nutritious food chosen by the JRSO’s.
The pupils had a selection of fruit, porridge, cereals, yoghurts,
croissants, fruit juice and water. 
As the pupils left to start their school day, they received a bike
reflector and a reflective sticker of their choice to continue their
good active travel habit into the spring. 
STV news was present to capture the event and interviewed staff,
Junior Road Safety officer representatives and Living Streets. 
Park Smart
Park Smart is a Road Safety and Active Travel initiative that aims to reduce congestion
and improve safety at the school gate. The purpose of Park Smart is to get parents to
think about their behaviour whilst actively promoting walking to school or park and
stride as the easier, safer and most stress-free option. School gate parking is an area
of concern across many schools in Moray that affects the safety and well-being of
both Adult and Child pedestrians and cyclists alike by blocking sight lines and
increased pollution. 
Park Smart is a flexible initiative that can be run on a cyclical basis i.e. re-run when or
if congestion problems return and is supported by colleagues at Police Scotland. The
programme currently runs on a three-week basis and covers raising awareness,
enforcement and then evaluation on the final week. 
This year there has been one additional Park Smart held at Burghead Primary.
This occurred due to concerns brought to the attention of the Parent
Partnership by parents/ carers that individuals were parking on the
zigzags outside the school. At the end of the initiative responses
from parents say they were very pleased to see the school thinking
about road safety and safety of the pupils. The school produced
a short evaluation report with the findings of the initiative, and a
pledge to develop a School Travel Plan stating that it was a very
worthwhile project where the pupils and parents gathered
valuable information about parking, coming to school safely
and the importance in making the healthy choice in coming to
school. 
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29
School Route Audits
Living Streets staff, along with school staff and pupils, completed School Route Audits
at four schools, Burghead, Pilmuir, Applegrove and Keith. This now brings us to twelve
schools across Moray with a completed Safe Route Audit. The Living Streets School
Route Audit (SRA) methodology is a way of effectively involving pupils, parents, and
other community stakeholders in the process of evaluating the quality of the walking
environment around schools. SRAs explore the walking routes to schools from the
viewpoint of current and prospective users. With Living Streets staff acting as
facilitators, the groups considered different audit categories including crossing points,
facilities and signage, traffic issues, places to play and socialise and footway
conditions. The findings from these audits will help feed into future infrastructure
improvements around schools and help to inform future ATIF Tier 1 projects. 
Bikeability 
Bikeability Scotland is the national cycle training programme for schoolchildren. It is
designed to give children the skills and confidence they need to cycle safely on the
roads, and to encourage them to carry on cycling into adulthood. Just like learning to
swim, learning to cycle safely is an essential life skill.
Outfit Moray delivers Bikeability across schools in Moray on behalf of Moray Council,
through annual funding provided by Cycling Scotland. Without this funding it would
not be possible to deliver this essential skill to pupils across Moray. Cycling education
across Moray has reached new heights during the 2024/25 academic year, with a
record level of participation in Bikeability Level 2 training for Primary 6 pupils. This
year: 
This has led to a significant improvement in pupils’ cycling confidence, road safety
awareness, and decision-making skills. 
Much of this success is attributed to early engagement through assemblies and pre-
training talks, which encouraged the majority of schools to complete
the classroom-based pre-course work.
42 out of 44
schools 
took part in the
programme –
the highest delivery
rate to date at 96%
793 
pupils completed
Bikeability 
Level 1
1,055 
pupils completed
Bikeability 
Level 2
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Crucially, this level of delivery was made possible thanks to an increase in funding,
following a successful application to Cycling Scotland for the 2024/25 academic year.
These outcomes build on years of sustained investment in cycling education,
including: 
Learn to Cycle programmes
ASN (Additional Support Needs) cycling
P1–P3 cycling sessions
Bikeability Level 1
Support from Cycling Scotland, alongside additional funding from charitable
sources, has enabled continued development of cycle skills across Moray. 
In addition to Bikeability, Outfit Moray delivered: 
Early years cycling in 8 nurseries
P1–P3 cycling in 30 schools
Learn to Cycle sessions for over 320 pupils
Inclusive ASN cycling in 10 schools
Bike maintenance workshops in 10 schools
Local led rides for Bikeability 2 pupils, helping them identify safe cycling routes
in their communities
To further strengthen local cycling capacity, the following training courses were also
delivered: 
Cycle Trainer Courses
Cycle Ride Leader Courses
BSI Instructor Courses
Looking ahead, the continuation of these achievements will depend on the availability
of ongoing funding at current or increased levels. It is also essential that schools
continue to actively support the delivery of Bikeability to help manage costs and
ensure targets are met. However, challenges remain, particularly around
the availability of volunteers and school staff—some of whom are either unable or
not permitted to assist with programme delivery. Addressing this gap will be key to
sustaining and expanding the programme in future years 
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31
School Travel Plans
Schools across Moray are encouraged to develop their own School Travel Plan (STP). A
STP can include a range of measures. Raising awareness is often one of the main
things that this can do. This might mean raising awareness of road safety, the benefits
of active travel or how transport impacts the environment. The need for travel plans
has arisen due to growing concerns over: 
Increasing congestion associated with the ‘school run’.
Pupil health concerns and lack of exercise.
Children’s reduced opportunities to gain important road sense and independence.
Road safety issues and concerns partly generated by school run related traffic. 
Currently there are four schools developing their Travel Plan, one of which is in final
draft status, however no school has an up-to-date Travel Plan document. This is not a
mandatory requirement, and therefore schools do not always have the time or
resource available, so do not see this as a priority task. In order to address the
concerns above it is important that schools support the development of a School
Travel Plan. All schools who take part in any of the active travel behaviour change
initiatives are advised that a condition of the support is to develop a School Travel
Plan. 
Active Travel Information Documents
Following the consultation work that took place throughout 2023 as part the review of
the Moray Local Development Plan (LDP), the first completed Active Travel Masterplan
for Buckie document has now been finalised and shared with the local community.
The document includes a holistic review of Active Travel in Buckie and covers new
routes, improvements on existing routes, cycle parking infrastructure and behaviour
change programmes. Forres and Lossiemouth are in development and scheduled to
be completed by the end of 2025, while the remaining communities Aberlour,
Dufftown, Elgin, Fochabers and Keith are due to be completed across 2026 and 2027.
Updates on the documents will be provided through the Town Centre Improvement
Plans. 
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Bike Fest
As part of Moray Council’s ongoing commitment to
promoting active travel and community engagement,
four Bike Fests were successfully delivered between
May and September 2025 in Cullen, Fochabers,
Aberlour, and Rothes, engaging an estimated 500
visitors across all locations. These events were
organised in partnership with Cycling UK, Outfit
Moray, and the Moray Bothy project, with additional
support from Bike Revolution, Tyred N Cranky, Moray
Climate Action Network, and UHI Moray. 
Each Bike Fest offered a vibrant mix of activities
designed to appeal to a wide audience and encourage
participation in cycling and active travel. The
programme included: 
Dr Bike sessions for free bike checks and minor
repairs 
Cycle skills courses for children and adults 
Led rides showcasing local routes 
BMX lessons and demonstrations 
Yoga sessions to promote wellbeing 
E-bike try-outs to introduce low-carbon travel options 
The events were well attended, with strong engagement from families, local residents,
and community groups. Anecdotal feedback highlighted the value of
having inclusive, fun, and educational activities that catered to
all ages and abilities. The presence of multiple partners
helped showcase the breadth of support available for
active travel in Moray and strengthened local
collaboration. 
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33
Bike Fests also served as a platform to promote other initiatives such as the Moray
Bothy Hub, Hi-Bike scheme, and cycling education programmes, reinforcing the
region’s strategic approach to embedding active travel into everyday life. 
Looking ahead, the success of the 2025 Bike Fests provides a strong foundation for
future events. Recommendations include: 
Expanding the number of locations to reach more communities 
Increasing promotion through schools and workplaces 
Enhancing data collection to better understand participant demographics and
impact 
Continuing to integrate behaviour change messaging and local travel planning
support 
These events have proven to be a valuable tool in raising awareness, building
confidence, and fostering a culture of cycling and walking across Moray. 
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Speyside Challenge
The Speyside Challenge returned for its fourth year this September, continuing to
inspire active travel along the Speyside Way as part of the Speyside Low Carbon Hub
initiative. The challenge encourages participants to log journeys by foot or bike, either
individually or as part of a workplace team, with eight prizes up for grabs.
This year saw 66 participants take part — while slightly down from last year’s 86, it
still represents a remarkable increase from 2023’s 35 participants, showing sustained
growth and interest in the initiative. 
Participants logged an impressive 5,948 km of active travel. Although just shy of last
year’s 7,000 km, this is still over 3,000 km more than 2023, reflecting a strong
commitment to low-carbon travel. In total, 523 active travel journeys were recorded,
helping to save an estimated 892 kg of CO₂ by switching from motorised transport to
walking and cycling. 
The challenge continues to play a vital role in promoting the Speyside Way as a key
active travel corridor, demonstrating how local engagement can contribute
meaningfully to carbon reduction and healthier travel habits. 
Feedback received from the
local community has been
overwhelmingly positive, with
participants stating they now
look forward to having the
challenge as a regular in the
Speyside community calendar. 
This year there was 16 prize-
winners all in receipt of 23
different Moray Loves Local gift
vouchers, as well as a grand
prize of a £500 voucher to
spend at local retailer
‘Skedaddle Speyside.’  
See all results at www.speysidechallenge.com/results 
2023 2,427km
travelled
236 
journeys
316kg CO2
saved
2024 1,402kg CO2
saved
7,908km
travelled
568
journeys
2025 5,948km
travelled
523
journeys
892kg CO2
saved
“We were absolutely delighted to have
been asked to be part of the Speyside
Challenge, I personally have taken part in
the past and this event is a fantastic way
of motivating people to get active and
move. Whether it be running, walking or
cycling, being active is great for
promoting a healthier lifestyle both
mentally and physically. We look forward
to welcoming one of the lucky winners
into our store”.
Skedaddle Speyside owner Sally Bruce
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Priorities for the Year Ahead
Moray Active Travel Strategy - ANNUAL UPDATE 2025
35
ATIF Tier 1 Direct Award 
As previously noted, the allocation for 2025/2026 was £500,000, a welcome increase
from the £433,813 allocated in 2024/2025. Looking ahead to 2026/2027, there is some
uncertainty around the funding level, but based on the current distribution
methodology, it is expected to be similar to this year’s allocation.
In preparation, work is already underway to develop a portfolio of shovel-ready
projects that can be progressed as soon as funding becomes available. 
The Tier 1 award for 2026/2027 will be allocated across two infrastructure projects: 
Lossie Wynd / Commerce Street, Elgin (LUF Project) – Contribution towards
improvements to cycle and pedestrian infrastructure along the north and south
links through the city centre. 
Boroughbriggs Road, Elgin – Installation of build-outs to enhance pedestrian
safety and traffic calming.
Active Travel Infrastructure Fund (ATIF Tier 2) Update
The Active Travel Infrastructure Fund (ATIF Tier 2) is designed to support the delivery
of eligible, construction-ready active travel schemes, as well as projects at the design
stage. In February 2025, an application was submitted for funding to support two
construction projects and one design project, with the aim of completing them during
the 2025/2026 financial year. 
It was initially anticipated that grant award letters would be issued by April 2025.
However, no awards have been made to date. Due to ongoing Scottish Government
budget constraints, it is now expected that funding may not be available for
2025/2026. As a result, delivery of the proposed projects within this timeframe is no
longer feasible. 
These projects will therefore be prioritised for funding in 2026/2027, subject to
budget availability: 
Coulardbank Road, Lossiemouth – A new cycle track connecting North Covesea
Terrace to Lossiemouth High School, addressing the lack of a safe pedestrian and
cycle route. Two options are under consideration:
1. A segregated cycle track running parallel to Coulardbank Road on its southern
side.
2. Widening South Covesea Terrace to accommodate a shared-use path, which
would then curve southward toward the school. 
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This project will be delivered in phases. 
Morriston Road Cycle Track (Design) – A proposed cycle route from Brumley Brae
to the A941. 
Future Pipeline Projects for ATIF Tier 2 Consideration
The following larger-scale projects are in the pipeline and may be considered for
future ATIF Tier 2 funding: 
Victoria Road Junction, Forres – Road space reallocation to improve active travel
access.
Maltkiln Bridge, Dufftown – Construction of a new footbridge to remove the need
for pedestrians to walk on the carriageway.
C1E Garmouth Road (Lhanbryde to Muiryhall Farm) – New footway connecting
the village to the Core Path leading to Urquhart.
South Street, Elgin (Dr Gray’s to Hay Street) – Footway widening and crossing
improvements.
Barhill Road / St. Peter’s Road / Golfview Drive Junction, Buckie –
Enhancements to pedestrian routes through the junction.  
Additional Active Travel Projects via Levelling Up Fund (LUF)
Work is also progressing on several active travel initiatives funded through the
Levelling Up Fund for Moray: 
Lossie Wynd / Commerce Street, Elgin – Upgrades to cycle and pedestrian
infrastructure along the north and south city centre links.
Elgin City Centre – Installation of rise-and-fall bollards.
Moss Street, Elgin – Road space reallocation to support active travel.
Laichmoray and Edgar Road Roundabout, Elgin – Junction improvements to
enhance safety and accessibility. 
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37
HITRANS
Through the HITRANS People and Place programme for 2026/27, the priorities for the
year ahead will be structured around four key themes. These include Capacity &
Capability Building, which focuses on strengthening local skills, resources, and
partnerships to support sustainable transport initiatives; Active Schools & Young
People, which aims to promote active travel among children and young people
through targeted engagement, education, and infrastructure improvements; Active
Workplaces & Communities, which seeks to encourage walking, cycling, and other
forms of active travel within workplaces and local communities by supporting
behavioural change, facilities, and collaborative projects; and Accessibility & Inclusion,
which ensures that all interventions are designed to be inclusive and equitable,
addressing barriers to active travel and improving access for people of all ages,
abilities, and backgrounds. 
The HITRANS budget is relatively small and must be distributed across five local
authorities, each covering a large geographical area. As a result, the People and Place
programme will concentrate on delivering activities in targeted locations where
impact can be maximised. Behaviour change programmes are most effective when
tailored to specific behaviours within defined areas. In Moray, the key projects for the
coming year include the continuation of the Moray Bothy, the development of Hi-Bike
membership—particularly the expansion of the Speyside Bike Share scheme—and
improvements in transport integration, such as the cycle parking programme.
Additional initiatives include the Smart Travel Choices programme, the WoW
programme, the School Travel Tracker, and support for Bikeability pre-Level 2 through
Learn to Ride sessions and Dr Bike maintenance events. These projects will be
delivered alongside the Local Authority Direct Award (LADA), which will provide
additional support to ensure effective implementation and delivery. 
Preparing the Next Active Travel Strategy (2028–2038)
In line with the Moray Local Development Plan review cycle, preparation for the next
Active Travel Strategy (ATS) covering the period 2028 to 2038 will begin in 2026. This
process will involve a comprehensive review of the current strategy, including all
objectives and actions, to assess progress, identify gaps, and ensure alignment with
emerging local and national policy priorities. The updated strategy will reflect new
data trends, infrastructure developments, and behaviour change insights gathered
through monitoring tools such as fixed counters, school travel surveys, and workplace
engagement. It will also incorporate feedback from community consultations, lessons
learned from the delivery of the current ATS, and integration with other key
documents such as the Active Travel Masterplans, the People and Place programme,
and the evolving priorities of Transport Scotland and HITRANS. Particular attention
will be given to ensuring the strategy remains inclusive, evidence-led, and responsive
to the needs of all users, including those underrepresented in active travel. A
refreshed Monitoring and Evaluation Framework will also be developed to support
robust performance tracking over the next decade. 
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Moray Active Travel Strategy - ANNUAL UPDATE 2025
This third annual update of Moray’s Active Travel Strategy (ATS) highlights continued
progress across infrastructure delivery, behaviour change initiatives, and strategic
planning. Key achievements include: 
Infrastructure Delivery: Completion of raised crossings on Morriston Road and a
new footway in Rafford, alongside ongoing development of Active Travel
Masterplans for key settlements.
Behaviour Change: Record participation in Bikeability training, expansion of the
Hi-Bike scheme into Elgin, and successful community events such as Bike Fests and
the Speyside Challenge.
Monitoring & Data Trends: Increased cycling and walking rates across Moray, with
positive trends in fixed counter data and travel-to-work statistics exceeding
national averages.
School Engagement: Strong uptake of the Living Streets Travel Tracker, Park Smart
initiatives, and Safe Route Audits, with 96% of schools participating in Bikeability.
Funding & Partnerships: Over £780,000 secured from external sources including
Transport Scotland, HITRANS, and Cycling Scotland, supporting both infrastructure
and behaviour change programmes.
Future Priorities: Focus areas for 2026/2027 include shovel-ready projects under
ATIF Tier 1 and Tier 2, continued delivery through the Levelling Up Fund, and
targeted behaviour change programmes via HITRANS’ People and Place
framework. 
Moray continues to build momentum in embedding active travel into everyday life,
with strong community engagement, cross-sector collaboration, and a growing
portfolio of impactful projects. 
The delivery of the Active Travel Strategy (ATS) will build on this momentum, driving
forward outcomes that support healthier lifestyles, safer streets, and a cleaner
environment. Active travel is not just a mode of transport—it’s a catalyst for positive
change. It enhances public health, enriches the places we live, and opens up access to
green spaces and community connections. It also plays a vital role in addressing
inequalities by creating more opportunities for safe, attractive, and enjoyable walking,
wheeling, and cycling for everyone. 
As outlined in the ATS, the Action Plan will continue to be supported through existing
funding streams, with additional external grant applications pursued wherever
opportunities arise. This approach ensures that Moray remains well-positioned to
deliver meaningful, inclusive, and lasting improvements for all who live, work, and
visit here.
Summary
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October 2025
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Report to: Economic Development
and Infrastructure
Services Committee 
Meeting Date: 11 November 2025  
Report by: Executive Director
Economy, Enterprise and
Operations, 
Author: Paul Wolverson Contact
Email:
Paul.wolverson@moray.gov.uk 
Subject: Update on Wildflowers in the Landscape 
1.  PURPOSE 
☐ For Decision      ☒  For Information 
1.1  The purpose of this information report is to provide an update on the wildflower areas
across Moray.  
1.2  This report is submitted to Committee in terms of Section III (F) (11) of the Council’s
Scheme of Administration relating to exercising the functions of the Council in relation to
Parks, Open Spaces and Tree/Woodland management and maintenance.   
2.  SUMMARY  
2.1  The introduction of wildflowers areas commenced in 2016.  An expansion of the wildflower
areas was approved in 2020. This report seeks to provide Members with information on the
expansion of the sites, where the sites are located and how such sites can be managed in
the long term. 
3.  BACKGROUND AND CONTEXT  
3.1 In 2016 what was previously an annual bed on the Esplanade, Lossiemouth was sown with
a Wildflower mix. In the same year, what were shrub bed areas in Lossie Wynd Car Park,
Elgin were replaced with wildflower mixes.  
3.2 On 1 December 2020 a report was presented to the Economic Growth, Housing and
Environmental Sustainability Committee on the introduction of wildflowers areas in the
landscape (para 19 of the minute refers).  A link to the report is shown here.  
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3.3 The report identified the many benefits of introducing wildflower areas in terms of
improving the biodiversity of open spaces which in turn benefits wildlife and people.  The
report outlined that an information report would be made available to Members after the
five-year programme to provide an update on the effectiveness of the proposals.       
3.4 There are now 46 wildflower and living lawn areas  (41 wildflower areas and 5 living lawns)
across Moray.  The total area covered by wildflowers areas or living lawns is nearly 70,000
square metres, which is the equivalent in size to around 10 football pitches. 
3.5 A list of the sites where wildflower/living lawns areas are located is shown in Appendix 1. 
These areas display a ‘managed for wildlife’ sign to inform the public of how these areas
are being managed.    
3.6 There have been many lessons learnt from the development of these sites, including how
the establishment of wildflower areas in particular are reliant on the right soil conditions
to become established. 
3.7 These areas have primarily been developed and established through the efforts and
support of the Open Spaces team, the Climate Change team and the local communities. 
Whilst most of these areas have received positive feedback, there has been some negative
comments regarding such issues as perceived disparity of service relating to the lack of
service provided by the Council to maintain an area. 
4. RECOGNITION OF ACHIEVEMENTS 
4.1 To showcase, and in recognition of the good work and achievements by the Council with
regards wildflower areas, a recent article was published by NatureScot on their social
media blog.  A copy of the blog is shown in Appendix 2. 
5. DIFFERENCE BETWEEN WILDFLOWER AREAS AND LIVING LAWNS  
5.1  In general terms a wildflower area is intentionally planted, or grown from seed, with a
diverse mix of native wildflowers species.  These areas often need initial, or annual,
ground preparation and require low nutrient levels to allow the wildflowers species to
thrive.  These areas are generally more costly to maintain than a living lawn.  
5.2 A living lawn is an existing grassed area where the mowing is reduced or eliminated to
allow existing or newly introduced wildflowers and other plants to grow, promoting a
diverse, wildlife-friendly habitat within a traditional grassy area. 
6. STRATEGIC POSITION MOVING FORWARDS  
6.1 The current wildflower areas are now established and are a testament to the collaborative
efforts by the Council and the community. Wildflower areas are generally more expensive
to develop and maintain, particularly in the first year, than traditional grassed areas.
Therefore based on the level of resources currently available, and that the management of
these sites in their current form require little more investment, in terms of cost, time and
resource, the focus will be on maintaining and improving these areas, rather than
expanding the wildflower network. 
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6.2 The Nature Restoration Fund has been used to invest in machinery and staff resources to
allow many of the wildflower sites to be established and managed. This source of funding
is not guaranteed into the future and any changes in availability of funding could have
implications on the management of these areas. 
6.3 It is recognised that wildflower/living lawn areas bring significant benefits in biodiversity
terms, and support the Scottish Pollinator Strategy, the Council’s statutory Biodiversity
Duty and the Climate Change Strategy action to increase nature positive management of
Council land.  The development and expansion of such sites is most beneficial where
appropriate frameworks and processes are in place to manage any expansion.  This will
ensure sites are viable, sustainable and are akin to the wider strategic picture.    
6.4 Since the original ‘wildflowers in the landscape’ report, a number of developments
regarding wildflower/living lawns have been reported to Members via the Climate Change
team workstreams, such as nature restoration projects updates, biodiversity reports, and
nature networks information.    
6.5 The latest strategy which includes references to the importance of wildflower areas is the
Council’s Draft Biodiversity Strategy 2026-2036, which was approved by Council on 27
August 2025 (para 13 of the minute refers), and is currently out for public consultation
until 28 November 2025.  The revised Biodiversity Strategy 2026-2036 will be presented to
Council for approval in due course, once the consultation responses have been reviewed
and considered.  
6.6 To ensure that any development in wildflowers/living lawn is in keeping with Biodiversity
Strategy 2026-2036, is financially sustainable, and is inclusive of feedback from relevant
stakeholders, consideration will be given by the climate change team, in collaboration
with Officers of the Open Space team, to develop a suitable selection process for any
further development of sites. This will be reported to Council alongside the revised
Biodiversity Strategy. 
7. SUMMARY OF IMPLICATIONS  
7.1 The table below shows whether risks and implications apply if the recommendations are
agreed: 
SUBJECT YES NO
Corporate Plan and 10 Year Plan (Local Outcome Improvement Plan)  X
Policy and Legal X 
Financial  X
Risk  X
Staffing  X
Best Value and Transformation X 
Property  X
Information Communications Technology/Digital             X
Equalities. Social Inclusion and Economic Impact           X 
Climate Change and Biodiversity Impact           X 
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7.2 Corporate Plan and 10 Year Plan (Local Outcomes Improvement Plan (LOIP))
Improved Collaborative Leadership, as part of continuous improvement through Best
Value, will better enable the Council to fulfil the ambitions set out in its strategic plans. 
a) Links to Council Corporate Plan – The proposals in this report support and contribute
to improved outcomes for communities as outlined in the following Council Plan
strategic priorities:
☐ Tackle Poverty and Inequality.
☐ Build Stronger Greener Vibrant Economy.
☐ Build Thriving, resilient, empowered Communities.   
b) Links to Local Outcomes Improvement Plan – The proposals in this report support
and contribute to improved outcomes for communities as outlined in the following
Local Outcomes Improvement Plan priorities:
☐ Developing a diverse, inclusive, and sustainable economy
☐ Building a better future for our children and young people in   Moray.
☐ Empowering and connecting communities.
☐ Improving wellbeing of our population 
7.3 Policy and Legal 
The Council has a statutory duty under the Nature Conservation (Scotland) Act 2004 to
further the conservation of biodiversity when carrying out its duties.  Maintaining and
enhancing wildflower areas will make a positive contribution towards the duty. 
7.4 Financial 
There are no financial implications associated with this report. 
One off Costs:
Service
Area
Budget Budget
Years
Proposed
Spend this
Year
Virement
From
Other
Comments       
Annually Recurring Costs:
Service
Area
Budget With
Effect
From
Annual
Net
Impact
Virement
From (if
applicable)
Other
Comments       
7.5 Risk 
There are no risks associated with this report.  
7.6 Staffing 
There are no staffing implications associated with this report.   
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7.7 Best Value and Transformation 
Applying this co-ordinated and strategic approach to expanding wildflowers areas will help
achieve best value.  
7.8 Property 
There are no property implications associated with this report.  
7.9 Information Communications/Technology/Digital 
There are no Information Communications/Technology/Digital implications associated
with this report.  
7.10 Equalities, Social Inclusion and Economic Impact 
The wildflower initiative supports equality and inclusion. Lack of access to the natural
environment has evidenced links to poverty, inequality and poor educational, wellbeing
and health outcomes.  
7.11 Climate Change and Biodiversity Impacts 
The proposals aim to provide a strategic approach to improving biodiversity and nature
networks which contributes to the Council Climate Change functions. 
8. CONSULTATION  
8.1 This report has been prepared in consultation with Executive Director Economy, Enterprise
and Operations, Head of Operations and Environment, Chief Financial Officer, Service
Manager Legal Services,  R Geddes-Stewart HR Adviser, Equal Opportunities Officer,
Service Manager Democratic Services, Open Spaces Manager, Principal Climate Change
Strategy Officer and L Rowan, Committee Services Officer and any comments made have
been incorporated into the report. 
9.  BACKGROUND PAPERS  
9.1 None.   
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Appendix 1 
Area Location Area at 2025 (m2)
Aberlour Speyside Way 180
Buckie Queen Street Orchard 180
Craigellachie Fiddich Park 120
Craigellachie Hill street 60
Dyke Village Hall 400
Elgin  Lossie Wynd car park 80
Elgin  Cooper Park 21500
Elgin  Reikit lane 500
Elgin  Glen Moray Drive 9500
Elgin  Sandy Road 6000
Elgin  North Street Bishopmill 350
Elgin  Elgin Cemetery North 200
Elgin  Lang Walk 350
Elgin  Trinity Road 150
Elgin  The Wards (area 1) 200
Elgin  The Wards (area 2)  
Elgin  The Wards (area 3)  
Elgin  The Wards (area 4) 200
Elgin  Cooper Park ex aviary site 90
Elgin  Cooper Park by tennis courts 70
Elgin  Banked areas on Springfield Rd (extension of Sandy
Road area) 1400
Elgin  Dovecot Park 550
Elgin  Mart Park 300
Elgin  Glen Lossie Drive 200
Fogwatt Millbuies Estate 400
Forres Bogton playing field 10500
Forres North Road 100
Forres Croft Road 60
Forres St Leonards Road 200
Forres Sanquhar Pond 40
Forres Castlehill 3400
Forres Sanquhar Road 400
Forres Sanquhar Road 120
Forres Applegrove gardens 40
Forres Clovenside Cemetery (rain garden) 400
Forres Mannachie Park living lawn 7452
Forres Mannachie Park Bulb mix 150
Forres Mannachie Park (wildflower turf) 400
Garmouth South Road 1600
Garmouth Mill Lane, Spey Street 24
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Keith Old cemetery terraces 40
Kingston Playing field 400
Lossiemouth Esplanade  80
Rafford Bank below Church Terrace 500
Rothes Provost Christie Drive 60
Rothes A941 Elgin Road 600 
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Appendix 2 
Moray’s Living Lawns 
Posted on Sep 1, 2025 
What have Forres, Elgin, Lossiemouth, Buckie and Rothes got in common? Well,
amongst other things, they are all locations in the Moray district where you can find
ambitious, pollinator-friendly, approaches to greenspace management. 
It is reckoned that not far short of 70,000 square metres are now being managed in
Moray specifically to benefit nature and pollinating insects. As you can imagine these
sites vary in location, size, and appearance. 
One approach taken embraces the concept of Living Lawns. Working hand-in-hand with
communities, and seizing the opportunities presented by the likes of the Scottish
Government’s Nature Restoration Fund, the council has been steadily making changes
to the way greenspaces are managed across the area. Relaxed mowing regimes lie at
the very heart of this attitude. 
The Living Lawns idea mirrors successful work carried out the Royal Botanic Gardens in
Edinburgh where a highly-visible living lawn demonstrated how less mowing, longer
growing grasses and a swathe of plants beneficial to pollinators such as clovers,
dandelions and yarrows (to name but a few) could provide much needed forage for
hard-pressed pollinators. 
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One of the largest sites of this nature lies in the very heart of Elgin, where 21,500 square
metres of Cooper Park have been given over to nature-friendly management. Cooper
Park has long been a focal point in this significant community and the living lawn here is
managed by the council’s Lands Park Team, with help from Moray College. It’s been a
great example of providing for nature since 2021 and like many floral areas in an urban
setting it is well liked by locals and a fine example of how the old-fashioned intensive
mowing of parks can be changed without any loss of popularity. 
The park isn’t the only success story in Elgin. At nearby Reikit Lane verge areas under
pollinator-friendly care have almost doubled since 2021. The sympathetically managed
verge approach is increasingly popular in Scotland, and these green corridors are
welcomed by those with concerns around connectivity of pollinator-friendly sites. 
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A dozen or so miles to the east of Elgin lies Forres, and again pollinator provision is on
the increase here. The town’s Bogton Playing field boasts a 10,000 square metre site
which is increasingly providing a colourful haven for pollinators. Since 2022 intensive
sward management has been stopped and cutting reduced to just one annual event.
This relaxed approach has allowed wild orchids to thrive and in a recent enhancement
the area was over-seeded with yellow-rattle, that well known ‘meadow-maker,’ by an
enthusiastic and supportive local community. 
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The Bogton stie is complemented by similar positive steps in small sites on Croft Road,
Castlehill, and Mannachie Park and this variety of sites in close proximity is good news
for pollinators. 
Across the district projects of various sizes have popped up. In Aberlour and
Lossiemouth well-maintained meadows are flourishing. Meanwhile in Buckie the
approach was to maximise the opportunity afforded by the Queen Street Orchard where
ethe introduction of a carpet of perennial native wildflowers has been a welcome
development. 
Since 2023 an additional 30 sites have been identified as being suitable for new
wildflower areas. Their creation often works because it involves both community and
council participation. 
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Change was afoot in Moray three hundred years ago when the imposition of a malt tax
caused uproar. Three centuries on we live in more sedate times, and whilst there is a bit
of a stir as pollinator friendly actions gather momentum, we can safely say that they
grab the public’s imagination for all the right reasons. 
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Find out more: 
Moray Nature Networks Plans 
Moray Council Nature and Biodiversity pages 
Further information 
The bulk of the main sites have used the general seed mixes below: 
Cornfield Annual Mix 
Get Nectar-rich Quick Mix 
Yellow Rattle (Rhinanthus minor) 
Pollinator-friendly plants thriving in Moray … Angelica, Betony, Bush Vetch, Cow Parsley,
Cat’s-ear, Cuckoo Flower, Cowslip, Devil’s-bit Scabious, Greater Bird’s-foot Trefoil,
Hedge Bedstraw, Hybrid Avens, Kidney Vetch, Lady’s Bedstraw, Lesser Knapweed,
Marjoram, Meadow Buttercup, Meadow Cranesbill, Meadowsweet, Ox-eye Daisy, Red
Campion, Red Clover, Self-heal, Square-stemmed St. John’s Wort, Tansy, Teasel,
Valerian, Water Avens, Yarrow, Yellow Rattle
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Report to: Economic Development
and Infrastructure
Services Committee 
Meeting Date: 11 November 2025  
Report by: Executive Director
Economy, Environment
and Operations 
Authors: Rod Lovie  Contact Email: Rod.Lovie@moray.gov.uk 
Subject: Public Bodies Climate Change Report 2024-2025 
1.  PURPOSE 
☐ For Decision      ☒  For Information 
1.1  The purpose of this report is to inform the Committee of the Council’s Public Sector
Report on Compliance with Climate Change Duties for 2024/25.  
1.2  This report is submitted to Committee in terms of Section III (F) (33) of the Council’s
Scheme of Administration relating to providing, developing and monitoring the Council’s
Economic Development and Infrastructure Services. 
2.  SUMMARY  
2.1  All public sector bodies are required to publish annual climate change reports by 30
November. This report gives a summary of the Public Bodies Climate Change Report 2024-
2025. 
2.2 Since last year there has been a 6% decrease in emissions. These are mainly from a
reduction in kerosene use and gas for heating as well as a reduction in commercial waste
going to landfill due to the closure of the Nether Dallachy landfill site. Compared to last
year there has been an increase in diesel usage although the levels of use are still less
than 2 years ago. 
2.3 The report will be updated with greenhouse gas conversion factors for 2024 and submitted
to Scottish Government by 30 November 2025. Any changes in conversion factors are not
expected to significantly alter the emissions calculations.
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3.  BACKGROUND AND CONTEXT  
3.1  The Climate Change (Duties of Public Bodies: Reporting Requirements) (Scotland) Order
2015 requires public sector bodies to publish annual climate change reports.  This is
intended to demonstrate compliance with public sector bodies’ climate change duties, to
engage leaders and encourage action to be taken to reduce carbon emissions. 
3.2  The Council has a duty under Section 44 of the Climate Change (Scotland) Act 2009 to
contribute to reducing Scotland’s greenhouse gas emissions, contribute to helping
Scotland adapt to a changing climate, and to act in a way it considers most sustainable.  
3.3  Moray Council submitted its first mandatory report on its compliance with climate change
duties to the Scottish Government in November 2016, covering the period 2015/16, and
has subsequently submitted its annual reports on time each November. 
4.  PERFORMANCE AND UPDATES  
4.1 A copy of the Council’s Public Sector Report on Compliance with Climate Change Duties
is due to be submitted to the Scottish Government by 30 November 2025. has been
uploaded to the Committee Management Information System (CMIS) and is available as
an additional meeting document in Section 8 Background Papers. 
4.2 In 2024/25, the Council’s recorded carbon emissions were 17,726 tonnes of carbon
dioxide equivalent (tCO2e) – a decrease of 1,132tCO2e (-6%) compared to reporting year
2023/24.  A summary of changes by emissions source, illustrating how emissions have
changed between the reporting years is provided in Appendix 1. 
4.3 The decrease in the Councils recorded carbon emissions are principally from the closure
of the Nether Dallochy landfill site. There was a spike in commercial and industrial waste
going to the site before it was closed during this year. The commercial waste uplifted by
the Council is now treated by the NESS Energy from Waste facility, which processes non-
recyclable waste to produce electricity for the national grid, and heat for a district heating
network. Emissions from the disposal of commercial and industrial waste have reduced
by 27% compared to the 2023-24 reporting year, from 3,462 to 2,543 tCO2e. With the
closure of the Nether Dallochy landfill site, the emissions from commercial and industrial
waste are expected to reduce further in 2025-26. 
4.4 Emissions from natural gas have reduced by 5%. This is thought to be a combination of
reducing set temperatures, more active management of heating systems, and another
relatively mild winter. The reduction in the burning of kerosene for heat has seen emissions
fall by 206 tCO2e. This is primarily due to less down time of biomass boilers as kerosene is
used as a backup heat source. The subsequent increase in woodchip and wood pellets
has led to an increase of around 1.4 tCO2e giving a substantial overall saving in emissions. 
4.5 The highest number of full-time equivalent (FTE) staff employed during the 2024/25
financial year was 3,737.14, a very slight decrease of 61.46 FTE since the previous report.
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This figure is used to calculate the carbon emissions resulting from commuting and
homeworking, and as such both have reduced slightly. 
4.6 The largest increase in emissions was from diesel usage. This has gone up by 7% after
falling by 12% in 2023/24. Part of the unexpectedly large reduction in 2023/24 was due to
seasonal weather changes. For example, the milder winter resulted in lower gritter
mileage. The assumption for 2024/25 is that some of these previous reductions have been
corrected. 
4.7 The Council’s solar PV projects generated 53,616 kWh of renewable electricity in 2024/25.
This represents an increase of 4% in renewable energy generated compared to 2023/24.
This is on top of an increase of 32% in 2023/24. 
4.8 The Public Bodies Climate Change Report also included information about climate
adaptation work the Council has been undertaking. Data from SEPA was used to inform
coastal and flood resilience planning, addressing projected risks according to climate
scenarios, with Scotland’s first Coastal Change Adaptation Plans adopted in Moray in
2024. Information gathering for a Local Climate Impact Profile used historical data to
assess services being impacted and highlight what risks are likely to increase due to
climate change. Adaptation action was carried out as part of service delivery across most
services, but additionally, external funding was secured from the Coastal Change
Adaptation Fund for a number of case studies and partnership working with communities. 
5.  NEXT STEPS AND FUTURE REPORTING  
5.1  The template for the Public Bodies Climate Change Report has still to be updated for
2024/25 with new carbon conversion factors. Local Authorities have been advised to
prepare reports using last year’s templates as an interim measure until the templates for
2024/25 are released and then the data can be copied over to the new template.
Therefore, the numbers in this report could change as the conversion factors are updated.
However, any changes in conversion factors are not expected to significantly alter the
emissions calculations and will not significantly alter the summary of information in this
report. 
5.2  The statutory annual climate change reporting is fulfilled by the Council’s climate change
officers with officers working across the Council having a responsibility to provide all
necessary information required for submission. 
5.3  Data collected for the purposes of annual climate change reporting will also continue to
be used to inform updates to the Council’s Climate Change Plan and Routemap to Net
Zero Carbon Emissions, due to be reported in March 2025. 
6.  SUMMARY OF IMPLICATIONS  
6.1  The table below shows whether risks and implications apply if the recommendations are
agreed: 
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SUBJECT YES NO
Corporate Plan and 10 Year Plan (Local Outcome Improvement Plan)  X
Policy and Legal  X
Financial  X
Risk  X
Staffing  X
Best Value and Transformation  X
Property  X
Information Communications Technology/Digital             X
Equalities. Social Inclusion and Economic Impact   X
Climate Change and Biodiversity Impact  X 
6.2  Corporate Plan and 10 Year Plan (Local Outcomes Improvement Plan (LOIP))
Improved Collaborative Leadership, as part of continuous improvement through Best
Value, will better enable the Council to fulfil the ambitions set out in its strategic plans. 
a) Links to Council Corporate Plan – The proposals in this report support and contribute
to improved outcomes for communities as outlined in the following Council Plan
strategic priorities:
☐ Tackle Poverty and Inequality.
☒ Build Stronger Greener Vibrant Economy.
☐ Build Thriving, resilient, empowered Communities.   
b) Links to Local Outcomes Improvement Plan – The proposals in this report support
and contribute to improved outcomes for communities as outlined in the following
Local Outcomes Improvement Plan priorities:
☒ Developing a diverse, inclusive, and sustainable economy
☒ Building a better future for our children and young people in Moray.
☐ Empowering and connecting communities.
☒ Improving wellbeing of our population 
6.3  Policy and Legal 
The Climate Change (Duties of Public Bodies: Reporting Requirements) (Scotland) Order
2015 requires that public bodies prepare a report on compliance with climate change
duties as set out by the Climate Change (Scotland) Act 2009. 
The Climate Change (Duties of Public Bodies: Reporting Requirements) (Scotland)
Amendment Order 2020 requires that the body to provide further details within its
mandatory reporting on climate change duties.  
6.4  Financial 
There are no financial implications arising from this report. 
6.5  Risk 
There are no risk implications arising from this report.
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6.6  Staffing
The Public Bodies Climate Change Duties Reporting requires staffing input from the
climate change team and officers from across services. 
6.7  Best Value and Transformation 
Contributing to the achievement of sustainable development through continuous
improvement in performance is a key component of the Council’s Best Value duties set
out by the Local Government in Scotland Act 2003.  
6.8  Property 
There are no property implications arising from this report.  
6.9  Information Communications/Technology/Digital 
There are no ICT implications arising from this report.  
6.10  Equalities, Social Inclusion and Economic Impact 
There are no equalities, social inclusion and economic implications arising from this
report.  
6.11  Climate Change and Biodiversity Impacts 
There are no additional climate change and biodiversity implications arising from this
report. 
7.  CONSULTATION  
7.1  This report has been prepared in consultation with the Executive Director - Economy,
Environment and Operations, Chief Governance Officer, Acting Head of Growth, Planning
and Climate, Energy Officer, the Sustainable Travel Officer, the Senior Project Officer
Active Travel Strategy, Service Manager Roads & Fleet, and the Equal Opportunities Officer
and any comments made have been incorporated into the report.  
8.  BACKGROUND PAPERS
8.1  Moray Council’s Public Sector Report on Compliance with Climate Change Duties 
Climate Change Strategy 2020-2030 
Route Map to Net Zero Update 2024 
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Appendix 1: Overview of Emissions by Source 
Emission
type Emission source 2023-24
(tCO2e)
2024-25
(tCO2e) Change %
Change
Fuels Burning oil (Kerosene) 644 437 -206 -32%
Waste Commercial and industrial waste 3462 2541 -921 -27%
Water Water treatment 23 19 -4 -18%
Water Water supply 13 10 -2 -18%
Bioenergy Landfill gas 3 3 0 -13%
Waste Mixed dry recyclates - Recycled 21 19 -2 -9%
Waste Organic: food and drink waste -
Composting 70 64 -6 -9%
Waste Clothing - Recycled 2 2 0 -6%
Fuels Natural gas 4185 3964 -221 -5%
Waste Metal: steel cans - Recycled 2 2 0 -5%
Waste Paper and board: mixed - Recycled 89 86 -3 -3%
Transport -
car Average car - Unknown 292 285 -7 -2%
Transport Staff commuting emissions 2098 2064 -34 -2%
Homeworking Homeworking (equipment + heating) 902 887 -15 -2%
Hotel stay Hotel stay - UK 3 3 0 0%
Electricity Transmission and distribution - Electricity:
UK 246 249 3 1%
Electricity Electricity: UK 2841 2874 33 1%
Waste Household/Municipal/Domestic waste 385 389 4 1%
Bioenergy Wood chips 15 15 0 1%
Fuels Marine fuel oil 54 56 1 3%
Waste Glass - Recycled 61 63 2 3%
Waste Metal: aluminium cans and foil (excl.
forming) - Recycled 2 2 0 4%
Fuels Petrol (average biofuel blend) 33 35 2 6%
Waste Metal: scrap metal - Recycled 17 18 1 6%
Fuels Diesel (average biofuel blend) 3333 3566 233 7%
Waste Organic: garden waste - Composting 20 22 2 9%
Waste WEEE - mixed - Recycled 16 18 2 12%
Bioenergy Wood pellets 9 10 1 13%
Waste Plastics: average plastics - Recycled 11 14 2 18%
Transport -
public National rail 3 3 1 23%
Transport -
public
Flights - Domestic, to/from UK - Average
passenger 4 6 2 37%
Waste Batteries - Recycled 0 0 0 139%      
TOTAL   18858 17726 -1132 -6%       
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Report to: Economic Development
and Infrastructure
Services Committee
Meeting
Date:
11 November 2025      
Report by: Executive Director
Economy, Enterprise and
Operations        
Author: Ian Walker Contact
Email:
ian.walker@moray.gov.uk 
Subject: List Of Property Transactions Concluded Under Delegated Powers 
1. PURPOSE 
☐ For Decision      ☒  For Information 
1.1 This report is submitted to the Economic Development and Infrastructure
Services Committee in terms of Section III F (5) of the Council’s Scheme of
Administration relating to industrial and commercial development. 
2. SUMMARY  
2.1 The purpose of this report is to inform the Committee of property transactions
which have been dealt with under delegated powers. 
3. BACKGROUND AND CONTEXT  
3.1 In terms of the Council’s Scheme of Delegation, the Head of Housing and
Property has delegated authority to conduct rent reviews and fix new rents.  
3.2 In terms of the Council’s Scheme of Delegation, the Head of Housing and
Property has delegated authority to grant wayleaves or servitudes over Council
owned property.  
3.3 In terms of the Council’s Scheme of Delegation, the Head of Housing and
Property has delegated authority to grant leases, licenses or other occupation
agreements of land and buildings for 25 years or less duration where the initial
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rent does not exceed £35,000 per annum and sites on long term building
leases of up to 125 years duration where the initial rent does not exceed
£35,000 per annum. 
4. PROPOSALS  
4.1 APPENDIX 1 – rent reviews  
4.2 APPENDIX II – servitudes and wayleaves  
4.3 APPENDIX III – leases 
5. SUMMARY OF IMPLICATIONS  
5.1 The table below shows whether risks and implications apply if the
recommendations are agreed: 
SUBJECT YES NO
Corporate Plan and 10 Year Plan (Local Outcome Improvement Plan) ✓ 
Policy and Legal  ✓
Financial ✓ 
Risk  ✓
Staffing  ✓
Best Value and Transformation  ✓
Property  ✓
Information Communications Technology/Digital  ✓
Equalities. Social Inclusion and Economic Impact   ✓
Climate Change, Biodiversity and Sustainability  ✓ 
5.2 Corporate Plan and 10 Year Plan (Local Outcomes Improvement Plan
(LOIP))
Improved Collaborative Leadership, as part of continuous improvement
through Best Value, will better enable the Council to fulfil the ambitions set
out in its strategic plans. 
a) Links to Council Corporate Plan – The proposals in this report support and
contribute to improved outcomes for communities as outlined in the
following Council Plan strategic priorities:
☐ Tackle Poverty and Inequality.
☒ Build Stronger Greener Vibrant Economy.
☐ Build Thriving, resilient, empowered Communities.   
b) Links to Local Outcomes Improvement Plan – The proposals in this report
support and contribute to improved outcomes for communities as
outlined in the following local Outcomes Improvement Plan priorities:
☒ Developing a diverse, inclusive, and sustainable economy
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☐ Building a better future for our children and young people in
Moray.
☐ Empowering and connecting communities.
☐ Improving wellbeing of our population   
5.3 Policy and Legal 
None.  
5.4 Financial 
The transactions detailed in APPENDICES I, II, and III will generate an
income to the Council. 
One off Costs:
Service
Area
Budget Budget
Years
Proposed
Spend this
Year
Virement
From
Other
Comments       
Annually Recurring Costs:
Service
Area
Budget With
Effect
From
Annual
Net
Impact
Virement
From (if
applicable)
Other
Comments       
5.5 Risk 
None.  
5.6 Staffing 
None.  
5.7 Best Value and Transformation 
None.  
5.8 Property 
None.  
5.9 Information Communications/Technology/Digital 
None.  
5.10 Equalities, Social Inclusion and Economic Impact 
None.  
5.11 Climate Change and Biodiversity Impacts 
None. 
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6. CONSULTATION  
6.1 None. 
7. BACKGROUND PAPERS  
7.1 None.   
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APPENDIX I
REPORT TO THE ECONOMIC DEVELOPMENT AND INFRASTRUCTURE SERVICES COMMITTEE ON 11 NOVEMBER 2025 
LIST OF RENT REVIEWS OF BUILDINGS AND SITES - SUBMITTED FOR NOTING 
1. Ref No.
2. Valuer’s Ints.
1. Address
2. Tenant
1. Building (m²) 
2. Site (Ha)
1. Date of Entry
2. Review Period
Interval
1. Previous Rent
2. New Rent
Remarks
1. DU/1/101 
2. SOAND
1. 3 Dufftown Industrial Estate,
Dufftown 
2. Mike Neary
1. - 
2. 0.07Ha
1. 1/4/07 
2. 5 years
1. £1,600 p.a. 
2. £2,370 p.a.
Permitted Use:
Recycling Centre.
1. MW/580/1 
2. SOAND
1. Nether Dallachy Landfill Site,
Spey Bay 
2. Crown Estate Commissioners
1. - 
2. 31.54Ha
1. 1/4/93 
2. Annually
1. £24,437.50 p.a. 
2. £26,304 p.a.
Permitted Use:
Council landfill
site.
Council are tenant
of Crown Estate
Scotland.
1. FR/4/102 
2. AGREIG
1. 1A Waterford Circle, Forres 
2. Ewan Tulloch
1. N/a 
2. 0.08Ha
1. 25/10/04 
2. 5 years
1. £2,450 p.a. 
2. £2,870 p.a.
Permitted Use:
Use classes 4, 5 & 6
of T & CP (Use
Classes)(S) Order
1997 as amended.
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1. EL/1/230 
2. SADEWO
1. 9 Chanonry Road South, Elgin 
2. David McCrea
1. 110sqm 
2. -
1. 1/4/16 
2. 3 years
1. £9,700 p.a. 
2. £10,250 p.a.
Permitted Use:
Storage and
distribution unit
with showroom and
ancillary sales
associated with the
tenant’s
horticultural and
hydroponics
business.
1. EL/5/123 
2. SADEWO
1. 10 Pinefield Parade, Elgin 
2. Carmichael Holdings
(Scotland) Ltd
1. - 
2. 0.06Ha
1. 12/5/05 
2. 5 years
1. £2,375 p.a. 
2. £2,700 p.a.
Permitted Use:
Flooring
contractor’s
business.
1. ME/482/7 
2. SADEWO
1. Rothiemay and District
Playgroup, Rothiemay Primary
School, Rothiemay 
2. Rothiemay and District
Playgroup
1. 44sqm 
2. -
1. 2/8/21 
2. None
1. £774 p.a. 
2. £1,032 p.a.
Permitted Use:
Childcare Nursery.
1. KE/410/2 
2. SADEWO
1. Nursery in Community Centre,
Keith 
2. Keith Play Centre Ltd
1. 
2. -
1. 2/8/21 
2. Annually
1. £4,800 p.a. 
2. £6,400 p.a.
Permitted Use:
Childcare Nursery.
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1. FR/1/205 
2. AGREIG
1. 10-11 West Road, Forres 
2. Speyside Brewing Co Ltd
1. 364sqm 
2. 0.06Ha
1. 10/5/22 
2. 3 years
1. £25,500 p.a. 
2. £29,500 p.a.
Permitted Use:
Brewing facility for
tenant’s business.
1. EL/1/210 
2. SADEWO
1. 4 Chanonry Road South, Elgin 
2. Loomis UK Ltd
1. 538sqm 
2. 0.14Ha
1. 18/12/15 
2. 3 years
1. £35,500 p.a. 
2. £42,500 p.a.
Permitted Use:
Use as a secure
distribution and
storage depot.
1. FR/3/102 
2. AGREIG
1. 5 Waterford Way, Forres 
2. George Smith
1. 101.5sqm 
2. 0.03Ha
1. 11/5/90 
2. 5 years
1. £1.350 p.a. 
2. £1,850 p.a.
Permitted Use:
Premises for timber
buildings
manufacturing
business.
1. KE/1/230 
2. SADEWO
1. 10 Westerton Road North,
Keith 
2. Simply Delicious (Keith) Ltd
1. 52.3sqm 
2. 0.01Ha
1. 4/8/06 
2. 3 years
1. £3,900 p.a. 
2. £4,440 p.a.
Permitted Use:
Storage of dry
foods and frozen
foods plus parking
of 2 catering vans.
1. BK/750/91 
2. AGREIG
1. Pier 3 Buckie Harbour, Buckie 
2. Ocean Winds UK Ltd
(07101190)
1. - 
2. 0.27Ha
1. 21/9/23 
2. Annually
1. £10.240 p.a. 
2. £10.590 p.a.
Permitted Use:
Windfarm
maintenance.
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1. EL/1/303 
2. SADEWO
1. 20 Chanonry Road North, Elgin 
2. Scottish Hydro Electric Power
Distribution plc
1. - 
2. 0.81Ha
1. 10/11/14 
2. 5 years
1. £25,600 p.a. 
2. £33,200 p.a.
Permitted Use:
Workshops,
warehouse and
yard with ancillary
offices for use as a
depot.
1. EL/1/121 
2. SADEWO
1. 4 Chanonry Street, Elgin 
2. Gary Stewart McKnockiter and
Walter Ritchie
1. - 
2. 0.04Ha
1. 22/6/00 
2. 5 years
1. £2,070 p.a. 
2. £2,400 p.a.
Permitted Use:
Joiners workshop
(sublease user).
1. EL/5/117 
2. SADEWO
1. 23 Perimeter Road, Elgin 
2. Barry Paul Williamson and
Danny Williamson
1. - 
2. 0.04Ha
1. 1/7/85 
2. 5 years
1. £2,655 p.a. 
2. £2,950 p.a.
Permitted Use:
Workshop and
store.
1. EL/1/226 
2. SADEWO
1. Unit 6, 2 Chanonry Road North,
Elgin 
2. WiFi Scotland LLP (S0306648)
1. 50sqm 
2. -
1. 1/7/22 
2. 3 years
1. £3,960 p.a. 
2. £4,750 p.a.
Permitted Use:
Use as a workshop,
store and office
associated with the
tenant’s telecoms
business.
1. MO/482/1 
2. AGREIG
1. Mosstodloch Primary School
Nursery, Mosstodloch 
2. Garmouth and Kingston
Playgroup
1. 55sqm 
2. 0.01Ha
1. 2/8/21 
2. Annually
1. £4,272 p.a. 
2. £5,696 p.a.
Permitted Use:
Childcare facility.
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1. BK/482/5 
2. AGREIG
1. Portessie Primary School
Nursery, Buckie 
2. Portessie Playgroup
1. 68sqm 
2. -
1. 2/8/21 
2. Annually
1. £1,893 p.a. 
2. £2,524 p.a.
Permitted Use:
Childcare facility.
1. PK/482/2 
2. AGREIG
1. Portknockie Primary School
Nursery, Portknockie 
2. Portknockie Playgroup
1. 74.3sqm 
2. -
1. 2/8/21 
2. Annually
1. £2,910 p.a. 
2. £3,880 p.a.
Permitted Use:
Childcare facility.
1. KE/1/110 
2. SADEWO
1. 9 Westerton Road South, Keith 
2. Glenmoir Storage Ltd
(SC627367)
1. - 
2. 0.22Ha
1. 3/5/19 
2. 3 years
1. £5,990 p.a. 
2. £6,850 p.a.
Permitted Use:
Siting storage
containers and
ancillary offices. 
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APPENDIX II 
REPORT TO THE ECONOMIC DEVELOPMENT & INFRASTRUCTURE SERVICES COMMITTEE ON 11 NOVEMBER 2025 
GRANT OF SERVITUDES AND WAYLEAVES 
Officer Intls  File Ref  Address Description Price  Comments
CQ Electricity
Wayleaves
4 March Road West
Buckie
AB56 4BU
Wayleave (Electricity) £85.60 Wayleave to SSEN in connection
with neighbouring properties
installation of electric vehicle
charging infrastructure. 
CQ Electricity
Wayleaves
Town Hall
1 Trinity Place
Elgin
IV30 1UL 
Wayleave (Electricity) £255.60 Wayleave to SSEN for required re-
alignment of HV cabling in
connection with Town Hall
extension works. 
CQ Electricity
Wayleaves
Town Hall
1 Trinity Place
Elgin
IV30 1UL 
Wayleave (Electricity) £4.26 Wayleave to SSEN for required HV
cabling link in connection with
South Elgin Strategy Project works. 
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APPENDIX III 
REPORT TO THE ECONOMIC DEVELOPMENT AND INFRASTRUCTURE SERVICES COMMITTEE ON 11 NOVEMBER 2025 
LIST OF LEASES OF BUILDINGS AND SITES – SUBMITTED FOR NOTING 
1. Reference No. 
2. Officer’s Ints
1. Address 
2. Tenant
1. Building (m²) 
2. Site (Ha) 
1. Date of Entry 
2. Review Period
Rent
(per annum)
Remarks
1. EL/1/235 
2. SADEWO
1. 19 Chanonry Road South,
Elgin 
2. Sam Jarockyj
1. 110sqm 
2. 9.36Ha
1. 1/6/25 
2. 3 years
£11,200 Permitted Use:  Store &
workshop for landscape
gardening.
1. Street Traders 
2. CQ
1. The Slappy, Station Road,
Burghead 
2. Ms J Price - Orka Sauna
Ltd (SC837114)
1. N/a 
2. 0.0001
1. 18/7/25 
2. N/A
£650 Permitted Use:  Mobile
vendor permission to
site on and trade from
Council ground.  Vendor
holds a valid Street
Traders Licence.
1. KE/3/258 
2. SADEWO
1. Units N & M Isla Bank
Mills, Keith 
2. Oakwood Cooperage Ltd
(SC596065)
1. 342.7sqm 
2. 0.03Ha
1. 30/8/24 
2. 3 years
£22,000 Permitted Use:  Metal
fabricators workshops
and store. 
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1. BK/750/79 
2. CQ
1. 2 Old Station Yard, Buckie 
2. Charlie’s Tale Ltd
1. 163sqm 
2. 0.022Ha
1. 16/6/25 
2. N/A
£880 (for
period)
Permitted Use:  Short
term (1 month)
occupation licence to
store gear in connection
with on-location film
production. 
1. FR/4/203 
2. AGREIG
1. 5 Waterford Circle, Forres 
2. Steven Hart
1. 70sqm 
2. -
1. 21/7/25 
2. 3 years
£7,500 p.a. Permitted Use: 
Motorcycle detailing.
1. LH/1/202 
2. AGREIG
1. Unit 2 Lhanbryde
Industrial Estate,
Lhanbryde 
2. Nigel Campbell
1. 46.5sqm 
2. 0.01Ha
1. 1/8/25 
2. 3 years
£4,180 p.a. Permitted Use: 
Automotive workshop
and diagnostic centre
by appointment only.
1. LO/1/203 
2. SOAND
1. Unit 3 Coulardbank
Industrial Estate,
Lossiemouth 
2. Friendly Access
1. 70sqm 
2. 0.02Ha
1. 28/7/25 
2. 3 years
£7,000 p.a. Permitted Use:  Storage
and maintenance of
surf school equipment. 
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Report to:  Economic Development
and Infrastructure
Services Committee
Meeting Date:  11 November 2025 
Report by: Executive Director
Education, Housing and
Communities    
Author:  Iain Highet Contact Email:  iain.highet@moray.gov.uk 
Subject:  Annual Report on Energy Consumption and Expenditure 2024 - 2025 
1.  PURPOSE 
☐ For Decision      ☒  For Information 
1.1  The purpose of this report is to note the annual energy and water performance of the
Council’s non-domestic building portfolio in 2024/25.  
1.2  This report is submitted to Committee in terms of Section III (F) (34) of the Council’s
Scheme of Administration relating to the monitoring of the Council’s Economic
Development an Infrastructure Services.   
2.  SUMMARY  
2.1  The Annual Energy Report for 2024/25 sets out within the report the annual utility
consumption and expenditure for consideration. 
2.2 In 2024/25 the Council’s energy consumption in non-domestic operational properties
decreased by 4% when compared to the previous year.  The water consumption fell by
18%.  
2.3 In 2024/25 the total cost of utilities including Street Lighting increased from £6,524,643 in
2023/24 to £7,128,364 equivalent to 9.3%.   
3.  BACKGROUND AND CONTEXT  
3.1 Annual reports have been presented to Committee since 2006; the last report was
submitted for noting to this Committee on 12 November 2024. This report is submitted as
the Council’s Annual Energy Report for 2024/25.
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3.2 Improving energy efficiency not only minimises costs, but it also reduces on-going carbon
emissions in the most cost-effective manner.  
3.3 During the financial year 2024/25 the Council’s expenditure on utilities (including street
lighting) was approximately £7.13M, with associated carbon emissions of 7.6 tonnes
CO2e. 
4.  PERFORMANCE  
4.1 Table 1 provides a summary of the Council’s utilities consumption, costs and emissions
during 2024/25. Heat refers to kWh from Biomass plant. 
Table 1
Annual Report Figures 24-25
Commodity 
Consumption
(kWh/m3)
Net Cost 
(£) Carbon (tonnes CO2e)
Heat 2,377,928 £218,584                      27 
Oil  1,772,544 £104,648                    437 
Gas  21,669,630 £1,373,211                3,963 
Electricity  11,641,880 £4,024,047                2,623 
Street Lighting and Unmetered
Elec  2,236,649 £771,791                    504 
Water (m3) 102,983 £636,083                      34 
Totals   £7,128,364                7,589 
4.2  The operation of the Council’s non-domestic building’s utility cost was £6,356,573 with
further expenditure of £771,791on street lighting and unmetered electricity.  
4.3 Combined Energy Consumption - Table 2 below provides a comparison of energy
consumption between 2023/24 and 2024/25 for individual utilities. 
Table 2
Consumption     
Utility 23-24 24-25 Difference  %
Heat 2,245,882 2,377,928 132,046 6%
Oil  2,509,728 1,772,544 -737,184 -29%
Gas  22,875,985 21,669,630 -1,206,355 -5%
Electricity  11,481,741 11,641,880 160,139 1.4%
Overall Building Total (kWh) 39,113,336 37,461,982 -1,651,354 -4.2%
Street Lighting and Unmetered
Elec  2,238,586 2,236,649 -1,937 0%
Overall Total (kWh) 41,351,922 39,698,631 -1,653,291 -4.0%
Water (m3) 125,787 102,983 -22,804 -18.1% 
4.4  The combined energy consumption from the Council’s buildings for 2024/25 was
37,461,982 kWh, compared with consumption of 39,113,336 kWh for 2022/23, equivalent
to a 4.2% decrease. Street Lighting consumption has stabilised as LED replacement
schemes conclude.  
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4.5  Heating Related Energy Consumption - To take account of weather conditions a
measure termed “Degree Days” is utilised to incorporate the effect of warmer or colder
conditions – permitting a comparison of heating related efficiency. 
4.6  Graph 1 below shows the Council’s weather adjusted historic heating consumption. 
Graph 1 
4.7 Heating accounts for a significant proportion of the Council’s energy consumption.  The
weather in 2024/25 was 2% warmer than in 2023/24 and the graph above shows a weather
adjusted decrease in heating consumption of 4.6% compared to the previous year. This
can largely be attributed to improved heating controls in some schools, through
monitoring and management of heating systems, and the vacating of some office
buildings.  
4.8 Heating Policy -No changes to the current heating policy are proposed in this year’s
report.  
4.9 Electricity Consumption - Graph 2 shows the Council’s building estate historic electricity
consumption. 
Graph 2
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4.10 The Council’s electricity consumption including Electric Vehicle (EV) charging excluding
Street Lighting was 11,641,880 kWh in 2024/25 compared to 11,481,741 kWh in 2023/24 a
160,139 kWh or 1.4% increase when compared to the previous year. This increase can be
attributed to an increase in EV charging and the method used to calculate this, and
increased utilisation of office space.  
4.11 Electric Vehicle Charging - EV charging consumption increased from 544,371 kWh in
2023/24 to 606,912 kWh in 2024/25. An increase of 11.5%.  
4.12 Removing this from the building estates electricity consumption it reduces the total
increase of electricity consumption from 1.4% to 0.9%.  However, it is important to note
that the first year of including EV consumption in this annual report was 2023/24, since
then there has been a slight change in how this is measured that has influenced
consumption figures. In future reporting this same methodology should be followed and
2024/25 consumption used as a baseline. 
4.13 Water Consumption - Graph 3 shows the Council’s historic water consumption. 
Graph 3 
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4.14  The Council’s water consumption was 102,983 m3 in 2024/25 compared with 125,787m3 in
2023/24 a decrease of 18.1%. This can be attributed to the repair of leaks that had caused
issues in the previous year and water efficiency projects.  
4.15 Carbon Emissions - Table 3 outlines carbon emissions resulting from utility consumption,
providing a clear overview of environmental impact associated with utility use attributed to
Moray Council building related operations.  
4.16 Table 3
Figures are in tonnes of CO2e
Utility 23-24 24-25 Difference  %
Heat                       24  27  3  12%
Oil                     619  437  -182  -29%
Gas  4,185  3,963  -221  -5%
Electricity  2,378  2,410  33  1%
Electricity TandD Losses                     206  213  7  4%
Street Lighting and Unmetered Elec  464  463  -0  0%
Street Lighting and Unmetered Elec TandD
Losses                       40  41  1  2%
Water                       22  16  -6  -29%
Water Treatment                       25  18  -7  -28%
Overall Total C02e                  7,963  7,589  -373  -5%
Total Scope 1 C02e                  4,828  4,428  -400  -8%
Total Scope 2 C02e                  2,841  2,874  32  1%
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Total Scope 3 C02e                     293  288  -5  -2%
Electricity Transmission and Distribution (TandD) Losses refer to the energy lost during the transfer of
electricity from power plants to end user through power lines and transformers. There is a requirement to
report emissions from these losses as Scope 3 emissions. 
4.17  Overall emissions in 2024/25 decreased by 5% compared with 2023/24. Direct Scope 1
emissions dropped by 8%. Contributory factors that affect the reduction in carbon
emissions include:
• Reduced Gas and Oil consumption used for building space heating has reduced
Scope 1 emissions.
• The Scope 3 emission reduction from reduced water consumption is offset by an
increase in the conversion factors for water treatment, as well as an increase in
conversion factor of Electricity TandD losses.  
5. UTILITY MANAGEMENT  
5.1 Utility Expenditure - In 2024/25 the Council’s total utility bill amounted to £7,128,364 an
increase of £603,721 (9.3%) compared to 2023/24 - with buildings constituting the largest
element at £6,356,573.  
5.2 Table 4 below gives a breakdown of costs.
Table 4
Utility 23-24 24-25 Difference  %
Heat £198,233 £218,584 £20,351 10%
Oil  £169,909 £104,648 -£65,261 -38%
Gas  £1,325,949
£1,373,21
1 £47,262 4%
Electricity  £3,549,851
£4,024,04
7 £474,196 13%
Water £619,417 £636,083 £16,666 3%
Overall Total - Buildings Only (£) £5,863,359
£6,356,57
3 £493,214 8.4%
Street Lighting and Unmetered Elec  £661,284 £771,791 £110,507 16.7%
Overall Total (£) £6,524,643
£7,128,36
4 £603,721 9.3% 
5.3  The Scottish Government have a national framework in place with Total Energies Gas and
Power for the supply of natural gas, EDF Energy Ltd for electricity and Business Stream Ltd
for water.  These frameworks have been in place since 2024, 2019 and 2020 respectively,
and are used by 98% of Scottish Public Sector organisations.  
5.4 Scottish Procurement (SP) have a Risk Management Committee (RMC) who oversee
policy, procedures and the purchasing strategy. Gas and electricity are purchased up to
2.5 years in advance, this has provided a high level of protection by purchasing over a long
period of time.  SP give the Council a fixed wholesale price of gas and electricity for the
fiscal year.  
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5.5 The wholesale cost of gas and electricity for Moray Council was fixed for the fiscal year
2025/26 in March 2025. The total unit cost for electricity has been set at 24.047 p/kWh this
equates to a 21% decrease in the cost of electricity. The total unit price for gas is
3.96p/kWh, this equates to an 16% decrease in the cost of Gas, this is however off set by
increase in standing charges. 
5.6 Gas and electricity standing charges vary across the Council’s sites depending on the size
and type of the supply. Electricity consumption charges also vary depending on the site
and what time of day the electricity is used. Therefore, it is not possible to give one simple
cost of energy across the entire portfolio. One way to quantify the price is to calculate a
pence per unit (PPU) cost. The PPU for this financial year 2025-26 is based on billing up to
the end of August. This gives a good idea of the change in energy costs, however this may
change between now and the end of the year as consumption increases over the winter
months.  
5.7 
5.8 Future Budget Guidance - Using the advice from SP and inflationary rates some guidance
on the future budgets required is set out in Table 5. These figures have been arrived at
using 2024-25 consumption. Costs have been arrived at using a percentage uplift based
on costs so far this year, advice from SP and RPI inflationary rates.  
5.9 Table 5
Utility 2025-26 2026-27 2027-28
Heat £220,770 £229,821 £239,244
Oil  £103,602 £107,849 £112,271
Gas  £1,450,111 £1,189,091 £1,129,056
Electricity  £3,339,959 £3,223,728 £3,116,056
Water £686,970 £755,667 £831,233
Overall Total - Buildings Only (£) £5,801,411 £5,506,156 £5,427,861
Street Lighting and Unmetered
Elec  £640,587 £618,294 £597,643
4.83 4.85 4.95 5.17 7.36 8.52 9.19 9.28
5.31 4.85 3.93 5.86 7.47 6.93 5.90 5.73
2.84 3.05 2.73 2.67
7.03 6.29 6.34 6.71
13.70 14.77 16.02 15.99
18.61
31.00
34.57
29.33
-
5.00
10.00
15.00
20.00
25.00
30.00
35.00
40.00
Av PPU 18-
19
Av PPU 19-
20
Av PPU 20-
21
Av PPU 21-
22
Av PPU 22-
23
Av PPU 23-
24
Av PPU 24-
25
Av PPU 25-
26
PENCE PER KWH
FISCAL YEAR
AVERAGE ENERGY COST PER UNIT (KWH)
MORAY COUNCIL
Heat Oil Gas Electricity
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Overall Total (£) £6,441,997 £6,124,451 £6,025,504 
5.10 The figures in Table 5 are estimates based on the available guidance at the time of writing.
The actual out-turn may vary greatly as consumption changes according to building use,
weather conditions and non-energy costs are applied to invoices. The energy markets
remain volatile, as market prices remain sensitive to geopolitical events and supply risks
to meet demand.  
5.11 Renewable Energy Generation Revenue - The Council currently operates 2 biomass
heating systems, at Speyside and Milne’s High Schools and Solar PV in Elgin High School
that benefit from Renewable Heat Incentive (RHI) and Feed in Tariff (FIT). 
5.12 For the 2024/25 period the Council received combined Renewable Heat Incentive (RHI)
payments of £144,825. The increase is due to less down time of plant for maintenance
than previous years.  
5.12 Table 6 
Total RHI Income  23-24 24-25 Difference  %
Milnes HS £56,920 £67,621 £10,701 19%
Speyside HS  £73,903 £77,204 £3,301 4%
Total RHI Income £130,823 £144,825 £14,002 11% 
5.13 The Council operates a single site which benefits from the Feed in Tariff (FIT) scheme. This
is the Solar PV array on Elgin High School. Table shows the FIT amount. The increase in
payments is down to weather conditions and inflationary increase.  
5.14 Table 7 
Total FIT Income 22-23 23-24 Difference %
Elgin HS  £2,067.68 £2,393.09 £325.41 14% 
5.15 Invoice Processing -All utility invoices go directly to the Energy Team for verification and
validation prior to centralised authorisation and payment.  Utility invoices are processed,
checked and uploaded onto the Council’s monitoring and targeting system – TEAM Sigma. 
The software automatically performs validation checks on the data received, highlighting
any abnormalities for the Energy Team to investigate.  
5.16 During 2024-25 the active management, checking and validation of utility consumptions
and invoices identified over £112,627 of erroneous charges which were resolved by the
Energy Team.  
6. ENERGY INITIATIVES  
6.1 Small energy efficiency projects in 2024/25 had a capital cost of £47,702.  These projects
are expected to save an estimated £11,911 per year and 6633 Kg CO2e.  
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6.2 
6.3 A report titled LED Replacement Programme Corporate Building, was reported to and
approved at Moray Council on 13 August 2024 (para 13 of the minute refers). This report
gave delegated authority to the Head of Housing, Property and Communities  and the
Chief Financial Officer to approve the progression of projects that meet the Council’s
spend to save principles in line with the Council’s standard governance processes
including ancillary project management governance.  
6.4 LED projects already complete this financial year. - Moray Council HQ, HQ Annexe,
Ashgrove Depot, Buckie Sports Pitches. Design work and contractor engagement is
ongoing with an aim to replacing all of the lighting where appropriate. 
6.5 A report titled Programme to Install Solar Photovoltaics on Council assets was reported to
and approved at Moray Council on 13 August 2024 (para 14 of the minute refers).  This
report gave delegated authority to the Head of Housing, Property and Communities and
the Chief Financial Officer to approve the progression of projects that meet the Council’s
spend to save principles in line with the Council’s standard governance processes
including ancillary project management governance.  
6.6 Solar PV projects on the rooftops of Ashgrove Depot, HQ, HQ Annexe and Elgin Library are
complete or scheduled to complete Q2 / Q3 2025/26. Design work and planning to install
Solar PV where appropriate on council properties is ongoing.  
6.7 As approved by this Committee, 14 November 2023, Annual Report on Energy Strategy and
Actions (para 13 of the minute refers), the Energy Team has made a successful application
to Salix for the Scotland’s Public Sector Decarbonisation Fund. A grant of £593,880 was
awarded towards building fabric improvements and changing to a zero direct emissions
heating system in Cullen Primary School.  This grant was successfully claimed and paid to
the Council in Q1 2025/26. Works are ongoing.  
6.8 A successful grant fund application was made to the Scottish Government Heat Network
Support Fund. A feasibility study into the creation of a heat network in the centre of Elgin
has been produced.  Officers have requested an addendum to this study.  When this has
been received and findings presented further reports will be presented to Council with the
findings and potential next steps required to progress the project. 
7. SUMMARY OF IMPLICATIONS  
Site / Project Capital cost Savings Unit Annual £ Savings
Annual Kg
CO2e Savings Funding Source
Pinefield Store LED replacement £3,949.21 5,363         
Electricity
kWh £1,394.38 1133 Energy
Cooper Park Depot LED replacement £1,960.00 2,216         
Electricity
kWh £576.16 468 Energy
Burnie Day Centre LED replacement £3,674.18 2,453         
Electricity
kWh £637.78 518 Energy
Buckie HS Sports Pitches LED replacement £27,323 15,540       
Electricity
kWh £4,040.40 3283 Sport & Culture
Shore st depot LED Replacement £1,696 2,115         
Electricity
kWh £549.90 447 Energy
Andersons Primary School Urinals £4,052.04 2,190          Water M3 £4,159.00 722 Business Stream
Mosstowie Primary School Tabs £1,987 73               Water M3 £94.00 24 Business Stream
Rothiemay Primary School Taps £2,560 114             Water M3 £459.00 38 Business Stream
Total £47,202 £11,911 6633
Energy Efficiency Projects 2024-25
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7.1 The table below shows whether risks and implications apply if the recommendations are
agreed: 
SUBJECT YES NO
Corporate Plan and 10 Year Plan (Local Outcome Improvement Plan)  X
Policy and Legal  X
Financial X 
Risk X 
Staffing  X
Best Value and Transformation X 
Property  X
Information Communications Technology/Digital  X
Equalities. Social Inclusion and Economic Impact   X
Climate Change and Biodiversity Impact X 
7.2 Corporate Plan and 10 Year Plan (Local Outcomes Improvement Plan (LOIP))
Improved Collaborative Leadership, as part of continuous improvement through Best
Value, will better enable the Council to fulfil the ambitions set out in its strategic plans. 
a) Links to Council Corporate Plan – The proposals in this report support and contribute
to improved outcomes for communities as outlined in the following Council Plan
strategic priorities:
☐ Tackle Poverty and Inequality.
☐ Build Stronger Greener Vibrant Economy.
☐ Build Thriving, resilient, empowered Communities.   
b) Links to Local Outcomes Improvement Plan – The proposals in this report support
and contribute to improved outcomes for communities as outlined in the following
Local Outcomes Improvement Plan priorities:
☐ Developing a diverse, inclusive, and sustainable economy
☐ Building a better future for our children and young people in   Moray.
☐ Empowering and connecting communities.
☐ Improving wellbeing of our population  
7.3 Policy and Legal 
This report has no specific implications relating to Policy and Legal.  
7.4 Financial 
In 2024/25 the Council’s total utility bill amounted to £7,128,364 compared to £6,524,643
in 2023/24, an increase of £603,721 (9.3%). Utility spend in 2025/26 is predicted to
decrease to an estimated £6,441,997. During 2024/25 the active management, checking
and validation of utility consumptions and invoices identified over £112,627 of erroneous
charges.   
7.5 Risk 
While budget guidance is contained within this report, there’s significant risk of costs to
increase. Consumption can be affected by weather conditions. Energy markets are
volatile, and prices can be changed dramatically by the geopolitical situation.
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7.6 Staffing 
There are no staffing implications.  
7.7 Best Value and Transformation
Reducing utility spend provides best value.  
7.8 Property 
There are no property implications.  
7.9 Information Communications/Technology/Digital 
There are no information communication technology and digital implications.  
7.10 Equalities, Social Inclusion and Economic Impact 
There are no equalities, human rights, or socio-economic implications.  
7.11 Climate Change and Biodiversity Impacts 
Reduction in energy consumption and energy efficiency projects will contribute to
achieving net zero and the developing LHEES strategy will assist in setting out strategic
cohesion in achieving reductions in climate emissions. 
8. CONSULTATION  
8.1 This report has been prepared in consultation with, the Head of Housing, Property and
Communities, the Chief Financial Officer, the Acting Head of Growth, Planning and
Climate (Chief Planning Officer), the Service Manager Property, Estates and Assets, the
Principal Climate Change Strategy Officer, the Service Manager Legal Services, the Equal
Opportunities Officer, and Lissa Rowan, Committee Services Officer have been consulted
and any comments made have been incorporated into the report.   
9. BACKGROUND PAPERS  
9.1 Annual Report on Energy Consumption and Expenditure – Economic Development and
Infrastructure Services Committee 12 November 2024   
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