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Agenda Document Pack - Economic Development and Infrastructure Services Committee - 14/11/2023

Moray Council · 14 November 2023
Back to Economic Development and Infrastructure Services Committee — 14 November 2023 and its agenda

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Economic Development and Infrastructure Services
Committee 
Tuesday, 14 November 2023 
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, 14 November 2023 at 09:30. 
BUSINESS 
1 Sederunt 
2 Declaration of Group Decisions and Members Interests * 
3 Minute of meeting dated 5 September 2023 7 - 14
4 Written Questions ** 
5 Active Travel Strategy and Action Plan Annual Update
Report by Depute Chief Executive (Economy, Environment and
Finance)  
15 - 54
6 Road Safety Plan to 2030
Report by Depute Chief Executive (Economy, Environment and
Finance)  
55 -
124
7 Port Marine Safety Code Quarterly Report
Report by Depute Chief Executive (Economy, Environment and
Finance)  
125 -
136
8 Biodiversity Duty Report 2021-2023
Report by Depute Chief Executive (Economy, Environment and
Finance)  
137 -
154
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9 Consultation on Scotlands Strategic Framework for
Biodiversity
Report by Depute Chief Executive (Economy, Environment and
Finance)  
155 -
188
10 Public Sector Climate Change Reporting
Report by Depute Chief Executive (Economy, Environment and
Finance)  
189 -
196
11 Industrial Portfolio Annual Report 2022-23
Report by Depute Chief Executive (Economy, Environment and
Finance)  
197 -
214
12 Annual Report on Energy Strategy and Actions
Report by Depute Chief Executive (Economy, Environment and
Finance)  
215 -
236
13 Performance Report (Environmental and Commercial
Services) - Period to September 2023
Report by Depute Chief Executive (Economy, Environment and
Finance)  
237 -
242
14 Performance Report (Economic Growth and
Development Services) - Period to September 2023
Report by Depute Chief Executive (Economy, Environment and
Finance)  
243 -
248
15 Question Time ***
Consider any oral question on matters delegated to the Committee in
terms of the Council's Scheme of Administration. 
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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.     
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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 12 noon two working days prior to the day of the meeting.  A copy
of any written answer provided by the Chair will be tabled at the start of the
relevant section of the meeting.  The Member who has put the question may,
after the answer has been given, ask one supplementary question directly
related to the subject matter, 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. 
*** Question Time - At each ordinary meeting of the Committee ten minutes will be
allowed for Members questions when any Member of the Committee can put a
question to the Chair on any business within the remit of that Section of the
Committee.  The Member who has put the question may, after the answer has
been given, ask one supplementary question directly related to the subject
matter, but no discussion will be allowed. 
No supplementary question can be put or answered more than ten minutes
after the Committee 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/she can submit it in
writing to the proper officer who will arrange for a written answer to be provided
within seven 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 John Cowe  (Member)
Councillor John Divers  (Member)
Councillor David Gordon  (Member)
Councillor Juli Harris  (Member)
Councillor Sandy Keith  (Member)
Councillor Graham Leadbitter  (Member)
Councillor Paul McBain  (Member)
Councillor Shona Morrison  (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, 05 September 2023 
Council Chambers, Council Office, High Street, Elgin, IV30 1BX 
PRESENT 
Councillor Peter Bloomfield, Councillor John Cowe, Councillor John Divers,
Councillor Amber Dunbar, Councillor David Gordon, Councillor Juli Harris, Councillor
Sandy Keith, Councillor Graham Leadbitter, Councillor Marc Macrae, Councillor Paul
McBain, Councillor Shona Morrison, Councillor John Stuart, Councillor Draeyk Van
Der Horn, Councillor Sonya Warren 
IN ATTENDANCE 
The Depute Chief Executive (Economy, Environment and Finance), Head of
Governance, Strategy and Performance, Head of Economic Growth and
Development, Head of Environmental and Commercial Services, Transportation
Manager, Open Spaces Manager, Principal Climate Change Strategy Officer,
Lindsey Robinson, Committee Services Officer. 
1.         Chair 
Councillor Marc Macrae, as Chair of the Economic, Development and Infrastructure
Services Committee, chaired the meeting. 
2.         Declaration of Group Decisions and Members Interests * 
In terms of Standing Orders 21 and 23 and 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.         Resolution 
The meeting resolved 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 13 of business on the grounds that it involves
the likely disclosure of exempt information of the class described in relevant
Paragraphs of Part 1 of Schedule 7A of the Act. 
Paragraph Number of
Minute  Paragraph Number of Schedule 7a and Reason 
17  9 - Information of terms proposed or to be proposed by
or to the Authority.   
4.         Minute of Meeting dated 20 June 2023 
Item 3
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The minute of the meeting of the Economic Development and Infrastructure
Services Committee dated 20 June 2023 was submitted and approved. 
5.         Written Questions ** 
The Committee noted that no written questions had been submitted. 
6.         Rosarie Level Crossing Closure 
The meeting had before it a report by the Depute Chief Executive (Economy,
Environment and Finance) seeking approval of the Committee to begin a new
consultation process for a proposed Stopping Up Order of the C54H Crooksmill to
Muldearie Road at the Rosarie Level Crossing under Section 68(1) of the Roads
(Scotland) Act 1984: “Moray Council (C54H Crooksmill to Muldearie Road (At
Rosarie Level Crossing) – Stopping Up) Order 2023”.  
Following consideration the Committee unanimously agreed to: 
i. approve the proposed Stopping Up Order at the location shown in Appendix
1 to the report and agreed to instruct the Head of Environmental and
Commercial Services, the Head of Governance, Strategy and Performance
and the Legal Services Manager to proceed with the statutory process; and 
ii. instruct the Head of Environmental and Commercial Services and the Legal
Services Manager to make and implement the Order if, following the
consultation period, there are no outstanding objections. 
7.         Environmental and Commercial Services and Economic Growth and
Development Services (Economic Development) Capital and Revenue Budget
Monitoring to 30 June 2023 
The meeting had before it a report by the Depute Chief Executive (Economy
Environment and Finance) informing the Committee of the current position regarding
Environmental and Commercial Services and Economic Growth and Development
Services (Economic Development) Capital and Revenue Budgets. 
Following consideration the Committee unanimously agreed to note the budget
monitoring report for the period to 30 June 2023. 
8.         Elgin Parking Review 
The meeting had before it a report by the Depute Chief Executive (Economy,
Environment and Finance) setting out recommendations following feedback from
stakeholder engagement held on 12 April 2023 and a subsequent review of Elgin
parking charges. 
During consideration Councillor Dunbar, moved an update to recommendation (iii) to
read: 
Approves the revised parking charges in high and medium turnover car parks as set
out in Section 6 of this report but makes no changes to low turnover car park
charges; and given the budgetary impact, refers determination of the charges to the
next meeting of Moray Council for a final decision with a recommendation from this
committee based on its view on the charges.
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This was seconded by Councillor Bloomfield.  
Councillor Warren asked if parent and child spaces could be looked at during the
review of disabled spaces and added into the wording of paragraph 4.6.  
In response the Transportation Manager advised that parent and child spaces will
be looked at and the wording updated and the sizes of spaces reviewed during any
re-lining.  
Councillor Leadbitter sought clarification on the possibility of extending the charging
periods at Lossie Green carpark and adding street furniture to Batchen Street.  
In response the Transportation Manager advised that he would be happy to look at
the short term use of street furniture in Batchen Street and that he would provide
information to members about the potential to extend the charging times at Lossie
Green carpark and the implications for enforcement.  
Councillor Warren sought clarification as to whether Police Scotland could use
CCTV to penalise illegal parking.  
In response Councillor Macrae advised that he would write to Police Scotland to ask
the question.  
Councillor Macrae also stated that he would write to the UK Transport Minister and
Home Secretary asking for a review into the level of parking fines for enforcement
as the penalty is not sufficient to deter people from illegal parking.  
Thereafter the Committee unanimously agreed to: 
i. note the summary of feedback from the Stakeholder meeting held on 12
April 2023 and the proposed measures set out in the subsequent parking
review; 
ii. approve the approach set out in paragraph 4 of the report; and 
iii. approve the revised parking charges in high and medium turnover car
parks as set out in Section 6 of this report but makes no change to low
turnover car park charges; and given the budgetary impact, refers
determination of the charges to the next meeting of Moray Council for a
final decision with a recommendation from this committee based on its
view on the charges. 
9.         Updated Management Rules for Cemeteries and Burial Grounds 
The meeting had before it a report by the Depute Chief Executive (Economy,
Environment and Finance) informing the Committee of the proposed revised
management rules for Council owned or controlled Cemeteries and Burial Grounds,
incorporated under the Local Government (Scotland) Act 1994. 
During consideration Councillor Leadbitter asked that the rules around pets and
children under the age of 12 be highlighted to the public. 
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In response the Open Spaces manager advised that the rules would be reinforced
by signage at the entrance to cemeteries and burial grounds. 
Councillor Leadbitter further asked for exemptions for assistance dogs to be added
in. 
This was agreed by the Open Spaces manager. 
Thereafter the Committee unanimously agreed: 
i. the revised Cemetery Management Rules as outlined in Appendix I and; 
ii. that the revised Cemetery Management Rules supersede any previous
management rules for cemetery and burial grounds. 
10.         Town Centre Improvement Plans Update and Funding Opportunities 
The meeting had before it a report by the Depute Chief Executive (Economy,
Environment and Finance) updating the Committee on the establishment of a Town
Centre Taskforce and to ask Committee to approve a number of actions to support
town centre regeneration using external funding already secured, note work being
undertaken to address feedback on the unsuccessful Levelling Up Fund bid and
agree to further investigate the feasibility of a heat network for the centre of Elgin. 
Following consideration the Committee unanimously agreed to: 
i. note the setting up of a Town centre Taskforce to support town centre
regeneration across Moray; 
ii.  note the external funding secured towards town centre regeneration; 
iii. approve spend of this year’s allocation for the Place Based Investment
Programme for town centre improvements as proposed; 
iv. note proposals for future years of the Place Based Investment Fund set out
in section 6; 
v. note the external funding for town centre projects secured through UKSPF
as set out in paragraph 6.2; 
vi. delegate authority to the Head of Economic Growth and Development in
liaison with the Chief Financial Officer to vire (or transfer) money between
the projects within the Place based Investment Programme to ensure they
can be delivered and minimise the risk of underspend; 
vii. note the work being undertaken to address feedback received on the
Council’s Levelling Up Fund bid; 
viii. an annual report on TCIP progress and the work of the Taskforce being
presented to this Committee; 
ix. investigate the feasibility of a heat network for the centre of Elgin and apply
for external funding for the feasibility study subject to no additional costs
being incurred by the Council; and
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x. a copy of this report be considered at Planning and Regulatory Services
Committee as an update on the Town Centre Improvement Plan work.   
11.         Local Visitor Levy 
The meeting had before it a report by the Depute Chief Executive (Economy,
Environment and Finance) informing the Committee of the introduction of the Visitor
Levy (Scotland) Bill in the Scottish Parliament and seek approval for the
recommendations. 
During consideration Councillor Leadbitter, moved the recommendations as written
with a slight change to recommendation (v) to read: 
consider in principle the concept of raising funds through a Local Visitor Levy and,
given the potential financial implications for the Council, to refer this report on to full
Council for a decision with a recommendation from this committee as to its view on
support in principle. 
This was seconded by Councillor Warren.  
Councillor Dunbar, seconded by Councillor Bloomfield proposed an amendment to
agree none of the recommendations and instead agree the following wording: 
The Committee does not recommend implementing a Local Visitor Levy in Moray
and given the financial implications, refers this report on to Moray Council for a
decision with a recommendation from this Committee as to its view on rejecting the
levy.  
On the division there voted: 
Motion (9) Councillors Leadbitter, Warren, Cowe, Divers, Harris, Keith,
Morrison, Stuart and Van der Horn 
Amendment (5) Councillors Dunbar, Bloomfield, Gordon, Macrae and McBain 
Abstentions (0) 
Accordingly the motion became the finding of the meeting and the Committee
agreed to: 
i. note the details of the Visitor Levy (Scotland) Bill and the proposed timetable
through Parliament; 
ii. note that and expert advisory group, facilitated by Visit Scotland will be
formed to offer opportunities for consultation on the Bill; 
iii. note the requirement to conduct consultation and assess impacts on the
area before a final decision to implement a visitor levy can be made; 
iv. note that the Highlands and Islands regional Economic Partnership has
agreed to look at a consistent approach to consultation and implementation
of a visitor levy across the region; and 
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v. consider in principle the concept of raising funds through a Local Visitor
Levy and, given the potential financial implications for the Council, to refer
this report on to Moray Council for a decision with a recommendation from
this committee as to its view on support in principle. 
12.         Use of Council Buildings and Structures for Abseiling etc 
The meeting had before it a report by the Depute Chief Executive (Economy,
Environment and Finance) asking the Committee to approve an exception to the
existing policy on the use of Council buildings and structures for abseiling or similar
activities.  
Following consideration the Committee unanimously agreed to approve an
exception to the current policy on the use of Council buildings and structures for
abseiling or similar activities, for Film and Television purposes only, due to the
economic benefit screen tourism brings, as set out in paragraph 3.5 of the report. 
13.         SSEN Transmission - Community Benefit Fund Consultation 
The meeting had before it a report by the Depute Chief Executive (Economy,
Environment and Finance) asking the Committee to consider an officer response to
a SSEN (Scottish and Southern Electricity Networks) Transmission Community
Benefit Fund Consultation and update members on work being commissioned to
explore the potential to establish a new model for a strategic Socio-Economic
Benefit Fund. 
Following consideration the Committee unanimously agreed to: 
i. note the officer response set out in Appendix 1; and 
ii. note the study being commissioned into establishing a Socio-Economic
Benefit Fund. 
14.         Information Reports - if called in 
The Committee noted that no information reports had been called in. 
15.         Question Time *** 
Buckie Weighbridge 
Under reference to item 4 of the minute of the meeting held 20 June 2023,
Councillor Warren asked for an update on the Buckie Weighbridge.  
In response, the Head of Environmental and Commercial Services advised that it
was now fully calibrated and ready for use, but there are currently road works which
are blocking the road but as soon as they are completed it can be used.  
Councillor Warren sought an update on the loss of income from the delays.  
In response the Head of Environmental and Commercial Services advised that she
would circulate that information to the Committee as she didn’t have it to hand.  
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CCTV
Under reference to item 15 of the minute of the meeting held 20 June 2023,
Councillor Warren asked for an update on CCTV and whether it was now fully
operational in all towns.  
In response the Head of Economic Growth and Development advised that there was
one camera in Keith that was being repaired later that week and all of the others
were working and being monitored.  
Minute of 20 June 2023
Under reference to item 15 of the minute of the meeting held 20 June 2023,
Councillor Keith advised that it was the A9 and the A96 he was referring too.  
In response the clerk advised she would update the minute and Councillor Macrae
advised that the response to the letter he wrote to the Transport Minister was
available on CMIS.  
20 mph zones
Councillor Keith requested that the Chair write to the Scottish Government for
clarification on the funding position for 20mph zones.  
In his capacity as Chair of the Committee, Councillor Macrae agreed to do this.  
A98 
Councillor Warren sought clarification on the review of the A98, work to be done
and any safety issues.  
In response the Head of Environmental and Commercial Services advised that the
revised road safety plan would be presented to the Committee at the November
meeting.  
Invasive Species
Councillor Van der Horn sought clarification on what could be done by the Council
with regard to sightings of the Asian hornet and the New Zealand flat worm.  
In response the Head of Economic Growth and Development advised that it was not
something that was within the biodiversity remit of the Council and that responsibility
for invasive species sits with government agencies.  
Bird Flu
Councillor Warren sought clarification on the Council position for the removal of
dead birds.  
In response the Head of Economic Growth and Development advised that the
Moray Council website provided information for the public on what should be done if
dead birds are found.  He further added that the number of birds being washed up is
being monitored by Environmental Health. 
16.         Suspension of Standing Orders 
In terms of Standing Order 85, the meeting agreed to suspend Standing Order 77
and continue beyond 12.45pm in order to conclude consideration of the final item. 
17.         Hydrogen Strategy Opportunities [Para 9]
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The meeting had before it a report by the Depute Chief Executive (Economy,
Environment and Finance) informing the Committee of an opportunity to progress
the work of the Moray Hydrogen Strategy by entering a non-binding Customer
Memorandum Of Understanding (MOU) with the company detailed in para 5.1; and
by joining a consortium led by Aberdeen City Council to expand hydrogen bus
opportunities through the North East. 
During consideration the Principal Climate Change Strategy Officer advised that
recommendation (ii) and section 6 of the report were to be removed as the funding
stream indicated was no longer available. 
Following consideration the Committee unanimously agreed to sign a non-exclusive
Customer Memorandum of Understanding with the company detailed in paragraph
5.1 to allow the exchange of confidential information and data. 
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REPORT TO: ECONOMIC DEVELOPMENT AND INFRASTRUCTURE
SERVICES COMMITTEE ON 14 NOVEMBER 2023 
SUBJECT: ACTIVE TRAVEL STRATEGY AND ACTION PLAN ANNUAL
UPDATE 
BY:  DEPUTE CHIEF EXECUTIVE (ECONOMY, ENVIRONMENT AND
FINANCE) 
1. REASON FOR REPORT 
1.1 The Committee is asked to note the progress made over the past year on the
delivery of the Active Travel Strategy (ATS), which sets out the Council’s
vision and action plan over the next 5 years for Active Travel in Moray, and
approve the use of a new Prioritisation Tool which has been developed to
inform the decision making process for new Active Travel infrastructure
schemes. 
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. RECOMMENDATION 
2.1 It is recommended that Committee: 
i. note the update in Appendix 1 and progress made in delivering
the ATS Action Plan within the first year of the strategy; and 
ii. approves the use of the Prioritisation Tool, to inform the
prioritisation of new Active Travel infrastructure schemes. 
3. BACKGROUND 
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 Active Travel Strategy and
scheme list to support applications for external funding. 
3.2 Active Travel 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 or cycle over private vehicle use, it can help deliver a low
Item 5
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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 Active Travel. 
3.3 This is the first annual progress report, one year on from the approval of the
ATS in November 2022. The Annual Report for 2022/23 is attached as
Appendix 1. 
3.4 Over recent years there have been increasing numbers of requests from
members of the public for new active travel infrastructure or interventions.
Whilst there have been significant increases in the amount of Cycling Walking
and Safer Routes funding allocated, and new opportunities to bid for
competitive active travel funding, the number of schemes requested far
exceeds available funding and officer time to develop and deliver projects. 
3.5 In the absence of a national tool for evaluating and prioritising active travel
schemes, an Active Travel Prioritisation Tool (ATPT) has been developed by
officers to be used to inform decision making on which schemes will be taken
forward during the life of the current ATS. A report setting out the
development of the ATPT has been uploaded to CMIS along with the agenda,
as additional meeting document..   
4. ATS PROGRESS REPORT 
4.1 The progress report (Appendix 1) presents a summarised overview of
progress to date against the first year of the ATS Action Plan, as well as
proposed activities for supporting the next stages of the strategy. 
4.2 In the past year the following schemes have been progressed and behaviour
change initiatives delivered: 
Construction Projects 
• Thornhill Road, Elgin - Toucan Crossing
• Morriston Road, Elgin - Toucan Crossing
• Resurfacing Improvements NCN1 Garmouth to Spey Viaduct
• New cycle track and footways linking Applegrove Primary and Forres
Academy with residential areas through the south and west of Forres
• Duff Place, Elgin - new footway at Bishopmill Primary School
• High Street (East End), Elgin - Footway widening
• B9010 Main Road, Rafford – Preparatory works for new footway
• B9040 Forsyth Street, Hopeman - New footway
• C25E Roseisle – New footway along Roseisle Hall frontage.
• Participatory Budgeting Cycle Parking installation Buckie and Keith 
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Design Projects 
• St Leonards Road, Forres – Build out to assist pedestrians crossing the
road
• Victoria Roundabout, Forres - Reallocation of road space (Options
Appraisal)
• Grant Drive, Forres – Raised  crossings of side roads for pedestrians
and cyclists
• Morriston Road, Elgin – 
Raised crossings of side roads for pedestrians and cyclists
• Lossie Wynd/ Commerce Street – Improvements to cycle and
pedestrian infrastructure along the north and south links through the
city centre (Options Appraisal) 
Behaviour Change and other projects
• Expansion of Moray Bothy into Cooper Park, Elgin
• Second year running the ‘Speyside Challenge’
• Development of eight Active Travel Masterplans for settlements
• New staff pool bikes and cycle shelter
• Three ‘Bike Fest’ events held in Elgin, Forres and Aberlour
• ‘Park Smart’ run at three separate Primary schools
• Development on three new School Route Audits to evaluate the quality
of the walking environment around schools
• Most successful year to date for participation in the ‘Travel Tracker’
School engagement programme 
4.2.1 Of the above projects, the Moray Bothy project based in Cooper Park is of
particular interest. The main focus is working with local communities to bring
together organisations that promote walking, wheeling and cycling activities
and providing any additional opportunities that are required to help people get
active on wheels or by foot. Led rides are being offered to asylum seekers
twice per week. Bikes were gifted to asylum seekers by the local community
but were not accompanied by any further training. This gap has been
successfully filled with the provision of led rides which has helped participants
to familiarise themselves with the local area and routes and covered
fundamental skills to improve their confidence. Furthermore, the Bothy has
been working with individuals through ‘Spinal Injuries Scotland’ with one
participant who accessed the hub now having their own cycle to use
independently. Lastly, there are families that engage with the hub to explore
and try the different cycles to understand what best fits their needs. An
example of the positive outcomes this can bring is a family who tested various
cycles at the hub and decided to purchase a Tern bike using the Energy
Savings Trust loan. This cycle has now replaced the car for everyday journeys
to nursery. Full details of the schemes and projects can be found in Appendix
1. 
4.3      Furthermore, there may be a future opportunity to work in partnership with 
HITRANS to expand the existing Hi-Bike network currently operating in 
Inverness and Fort William (https://hi-bike.co.uk/) to include sites in Elgin. This 
is in the early stages of investigation and may be the subject of a future report 
to Committee. 
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4.4 The progress report also contains new observed cycle and pedestrian
count data from January 2021 – December 2022. Count sites within the urban 
areas are generally continuing to show an upwards trend in numbers of 
pedestrians and cyclists. However, counters on routes which people use for 
leisure purposes have shown a reduction in movements. This reduction is 
from the high level of use observed during the Covid 19 pandemic. However, 
when comparing current data to 2019 data, there is still an upwards trend in
pedestrians and cyclists using these leisure routes. 
5. ACTIVE TRAVEL PRIORITISATION TOOL (ATPT) 
5.1 A Prioritisation Tool, also known as a ‘scoring tool’ or a ‘multi criteria
assessment tool’, enables the comparison of various proposed schemes
based on the same set of criteria, and to rank the schemes on the basis of a
numerical score. This ‘score’ can be used to inform decisions on the use of
funding and staff resources. A recent example of the use of such a scoring
tool is for the allocation of funding for improvements to the Core Path Network
in Moray (see Core Paths Action Plan 2023-2036 report to this committee
dated 20 June 2023). (para 5 of the minute refers) 
5.2 Over the years, officers and communities have identified locations where new
or improved active travel infrastructure is required to support pedestrians,
wheelers and cyclists. These locations may be on routes to schools or in rural
communities where a lack of provision is a deterrent to active travel. 
5.3 More recently, as part of the review of the Local Development Plan, specific
questions have been asked during the consultation events with regard to
areas where communities perceive a need for new or improved active travel
infrastructure. However, the number of schemes identified and their
associated costs, far exceeds what could be delivered using available funding
sources and staff resources.   
5.4 The aim of the ATPT is to provide a clear and transparent process for
identifying which projects are prioritised to be taken forward for investigation,
design and ultimately construction. The Scottish Government document
‘Cycling by Design’ (2021) is the guidance used by officers to inform the
design of cycle infrastructure. The ATPT will be used until such time that a
national tool has been developed and is available for use by Local Authorities. 
5.5 The ATPT will be used to inform the decision making process with regard to
whether a scheme is progressed and its priority for resources (funding and
officer time). The delivery of schemes can be dependent on factors such as
the need to secure third party land or how a scheme fits into an overall re-
development of an area, which can also have an influence on the timescale
for its delivery. 
5.6 ATPT was developed by undertaking research into other such tools used for
prioritising active travel schemes and has been subjected to a peer review.
The peer review was important in the identification and development of the
criteria within the tool and involved a number of local stakeholders, council
officers and representatives from Sustrans. 
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5.7 The key criteria considered within the APTP are as set out below. Further
information detailing the full process of scoring an individual scheme has been
uploaded to CMIS along with the agenda as an additional meeting document.: 
Infrastructure 
• Identifying Need and potential usage through considering the
destinations which could be accessed via the scheme (e.g. schools,
work etc.).
• Demand based on the distances which would be travelled to
destinations.
• Benefit to which user groups, pedestrians only, cyclists only etc.
• Deliverability, whether there are constraints such as third party land,
challenging topography etc.
• Cost, schemes with a high cost are given a lower score to reflect the
likelihood of being funded in any one given year.
• Size of settlement to provide an indication of the number of people
likely to benefit from the scheme.
• Speed limit to identify if there are potential road safety benefits, e.g. a
segregated cycle path alongside a 60mph road would score more
highly than within a 30mph speed limit. 
Place Making 
• Potential for the scheme to encourage a modal shift from car travel to
active travel.
• Schemes which provide connections to remote areas are scored higher
than schemes in areas already well served.
• Contribution of a scheme to a neighbourhoods’ quality. 
Overarching Criteria
• General feasibility, determining if scheme could be delivered in the
short, medium or long term.
• If vulnerable user groups would be primary users of the scheme
• Scottish Index of Multiple Deprivation (SIMD) of the area served by the
scheme.
• Opportunity for Grant Funding, with schemes that meet funding criteria
being scored more highly than those which only partially meet funding
criteria.
• Future maintenance of the scheme and whether it would become part
of the public road. 
• Qualitative / overarching issues which relates to whether the scheme
fits into a wider strategy for an area. 
5.8 To date 32 schemes have been scored using the ATPT, which are from the
current Active Travel project list or have been identified through recent
community engagement and consultations. Some suggestions made by the
public have not been scored using the tool as they related to road safety or
maintenance schemes, or were for items such as cycle parking which are
being delivered through Participatory Budgeting.
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5.9 The intention of the ATPT is to influence decision making, but not for
decisions to be solely based on the results of the assessments. There will be
other influences which will mean that some proposed schemes will be
undertaken before those with a higher score. For example, the highest scoring
scheme, the Burn of Buckie Active Travel Bridge, is a complex project which
is also supported by developer obligations. It will take a number of years and
significant funding to deliver this project. Resources will be allocated to
develop the scheme. However, other smaller projects will be delivered before
it is completed. 
5.10 Members of the public can contact officers to discuss their ideas for Active
Travel schemes through sending an email to activetravel@moray.gov.uk or
during public events or consultations.  A portal for the council website is also
being developed which will provide information on each of the proposed
schemes which have been assessed, including any new proposals received
following the launch of the portal.  However, due to the high number of
schemes already identified and limited funding/staff resources, not all
schemes will be taken forward.  
6. SUMMARY OF IMPLICATIONS 
(a) Corporate Plan and 10 Year Plan (Local Outcomes Improvement
Plan (LOIP))
The Active Travel Strategy and Action Plan support Moray’s 2026
priorities for healthier citizens as well as for older people to sustain active
lives in their community. As well as supporting economic development
targets by providing greater choice for travel within and between
communities. 
The Active Travel Strategy and Action Plan also supports all four of the
priority areas of the Local Outcome Improvement Plan; 
• 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 
(b) Policy and Legal
The Active Travel Strategy and Action Plan links to National and
Regional policy objectives, as set out in the 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.  
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(c) Financial implications
The Scottish Government has committed to increasing investment to at
least £320 million or 10% of the total transport budget on Active Travel
by 2024-25. As set out in the ATS, it is intended to fund the Action Plan
through existing 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 25 miles of cycle tracks. 
There are no financial implications arising from the recommendations in
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). 
(d) Risk Implications
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 a
requirement for the new ‘Active Travel Transformation Fund’. 
(e) Staffing Implications
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 Transformation Fund will
require additional staff members/support from external consultants, the
cost of which will be included as part of any funding application. 
(f) Property
There are no property implications arising from this report. 
(g) Equalities/Socio Economic Impact
Supporting Active Travel is beneficial for public health, and helps to
tackle inequalities. Raising the profile of Active Travel choices will also
help to improve accessibility for those with mobility disabilities. The
provision of new shared use paths when developing the network in
Moray, will create better accessibility for wheelchair users. 
(h) 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 supports 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.
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(i) Consultations
The Depute Chief Executive (Economy, Environment and Finance),
Head of Environmental & Commercial Services, Legal Services
Manager, Equal Opportunities Officer, Chief Financial Officer, Committee
Services Officer (L Robinson), Strategic Planning Development Manager
and Principal Climate Change Strategy Officer have all been consulted
and their comments taken into account in this report. 
7. CONCLUSIONS 
7.1 The ATS annual update provides details of the delivery of Year 1 of the
ATS Action Plan. 
7.2 There have been many successful new and ongoing projects this past
year including the expansion of the Moray Bothy, the return of the
Speyside Challenge, development of eight new local Active Travel
Masterplans as part of the Local Development Plan review, as well as the
delivery of the first Participatory Budgeting Active Travel project. 
7.3 Furthermore, a total of 0.5 km has been added to the Active Travel
network through our construction projects, and 2 km of cycle paths
have been resurfacing and improved. 
7.4 A new Active Travel Prioritisation Tool has been developed to assist
officers in prioritising schemes and provide supporting information to
assist with decisions on which active travel schemes are taken forward
for investigation, design and ultimately construction. 
Author of Report:  Janet MacDonald, Sustainable Travel Officer  
Background Papers: Previous Committee Report 15 November 2022 for Active
Travel Strategy and Action Plan 
Ref: SPMAN-524642768-977 
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Moray Council 
ACTIVE TRAVEL STRATEGY
ANNUAL
UPDATE
2023
Item 5
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2
Moray Active Travel Strategy - ANNUAL UPDATE 2023
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Contents
Moray Active Travel Strategy - ANNUAL UPDATE 2023
1
Introduction 2
Trends in Data 3
Year 1 Action Plan 7
Funding 12 
Activity over 2023 13
CWSR 13
Moray Bothy 14
HITRANS 15
Spey Viaduct NCN1 15
Forres Academy, Roysvale and Burdshaugh 16
Participatory Budgeting 17
Staff Travel Survey 17
Staff Pool Bikes 18
School Engagement 20
Active Travel Masterplans 23
Bike Fest 24
Speyside Challenge 24 
Priorities for the year ahead 25
HITRANS Funding 26
School Engagement 26
Bikeability 27
Smart Choices Smarter Places 27
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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 delivering 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 first annual report of the strategy presents a summarised
overview of progress to date, against the 1st 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 2022 – December 2022, and
an update on both new
infrastructure provision and
active travel behaviour in Moray. 
Introduction
2
Moray Active Travel Strategy - ANNUAL UPDATE 2023
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Moray Active Travel Strategy - ANNUAL UPDATE 2023
3
Trends in Data
Active Travel monitoring is undertaken through a number of 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 (as yet there is no relevant
data published for 2022). Other programmes delivered under the SCSP 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
report provides trends and context at Local Authority level. This report would
normally give good comparison data year on year, however, this has been impacted
by the Covid 19 pandemic, and affected the changes to the methods of data collection
for a number of the report’s data sources. The Covid-19 lockdowns meant the SHS
2020 surveys switched from face-to-face interviews to a telephone survey. As a result
of the change in survey mode, the response rate and, therefore sample size, was
greatly reduced and there was a noticeable change in the profile of respondents.  At
that time, there were restrictions in movement, peoples behaviours were impacted
and not travelling to and from work. Next year’s data will be back to a larger sample
size and more representive of current behaviours. Therefore, due to the significant
reduction in the SHS sample size, no individual local authority data is available for
2021 to compare with 2022 data. However, data from the 2023 report based on 2022
figures show that 67% 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. 
Cycling Scotland - Annual Cycling Monitoring Report, Moray Trends and Context
2021
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Cycling Scotland - Annual Cycling Monitoring Report, Moray Trends and Context
2023 
Sustrans ‘Hands up Scotland Survey’ is the largest national dataset on how children
travel to school, and is an Official Statistic in Scotland. The survey is now in its 15th
year, and makes it possible to compare and review more than a decade of data on
how children travel to school in Moray. Whilst figures for walking have reduced over
the last number of years, there has been an increase in cycling, the highest recorded
since the survey began in 2008. There has been an obvious upward trend in park and
stride from 5.7% in 2008 to 11.4% in 2022. These are easily identifiable as to why
there is a slight decrease in walking. The numbers show that overall, all forms of
Active Travel are on the increase. Figures during 2020 and 2021 were higher than
normal due the impacts of Covid. Bikeability delivery has also increased from 56% in
2019 to 93% in 2022. This supports the HUSS data that cycling numbers in schools are
increasing. 
4
Moray Active Travel Strategy - ANNUAL UPDATE 2023
How pupils travelled to school - Moray
Walk
Cycle
44%
6.2%2.1%10.2%
20.1%
15.7%
1.6%0.1%
41.9%
6.0%1.9%
11.4%
20.3%
16.9%
1.6%0.1%
Scooter/Skate
Park & Straide
Driven
Bus
Taxi
Other
2021 2022
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Moray Active Travel Strategy - ANNUAL UPDATE 2023
5
Fixed count sites within the urban areas of Moray are generally continuing to show an
upwards trend in numbers of pedestrians and cyclists. Data from 2020 and 2021 are
exceptionally high but this is related to changes in travel patterns and behaviour
during the pandemic, and more people being able to work from home. Currently the
only reliable data 2022 data can be compared to is from 2019 pre-covid. This data
shows that the numbers on these commuting routes are increasing for both walking
and cycling. 
However, counters on routes which people use for leisure purposes have shown a 
reduction in movements. This reduction is from the high level of use observed during
the Covid 19 pandemic. There are a few exceptions to this such as at Fiddich Park and
Aberlour where numbers are either the same if not more than during Covid. This can
be attributed to the upgrade improvement works along the Speyside Way. However,
when comparing to 2019 there is still an upwards trend in Active Travel users on
these leisure routes. 
Elgin - Red Bridge East - West
Year
2018
2019
2020
2021
2022 
Elgin - Morriston Playing Fields
Year
2018
2019
2020
2021
2022
Growth D
9.33%
4.88%
52.33%
-42.75%
17.33% 
Growth D
20%
-2.78%
131.43%
-39.51%
28.57%
AADT
353
380
434
445
400 
AADT
175
190
288
311
318 
Growth D
7.62%
7.65%
14.21%
2.53%
-10.11% 
Growth D
6.06%
8.57%
51.58%
7.99%
2.25%
Bikes People
AADT
82
86
131
75
88 
AADT
36
35
81
49
63
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6
Moray Active Travel Strategy - ANNUAL UPDATE 2023
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 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
Aberlour - Fiddich Park
Year
2019
2020
2021
2022 
Aberlour - Sewage
Year
2019
2020
2021
2022
Growth D 
50%
-51.52%
112.50% 
Growth D 
94.12%
-18.18%
-3.70%
AADT
56
70
62
106 
AADT
92
93
101
96 
Growth D 
25%
-11.43%
70.97% 
Growth D 
1.09%
8.60%
-4.95%
AADT
22
33
16
34 
AADT
17
33
27
26
Bikes People
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Moray Active Travel Strategy - ANNUAL UPDATE 2023
7
Year 1 Action Plan
The tasks for year 1 Action Plan were set based on the timescale from the ATS overall
5-year action plan. All tasks committed for completion by Q3 2023 were included in
year 1. The progress on these actions is set out below. Further information on all of
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 1     Further develop the Active Travel network
A) Identify network of
routes, including the
identification and
integration of the Core
Path Network, that
connect communities
where ‘every day’
journeys could be made
by cycle or foot 
B) Develop an online
system where the
public can identify new
active travel routes
and/or enhancement to
existing routes, and
promote its use.
Achieved 
Achieved 
The network mapping of
all adopted roads and
crossings has been
completed, and will be
subject to regular
updates. Continuous
work is also ongoing to
update the core path
network. A copy of the
mapping exercise has
been shared with
Transport Scotland. 
The online system is now
live on the Council
website, and is currently
in use, supporting the
LDP consultations. 
Moray Council 
Moray Council 
Task Status of
Progress
What was achieved Lead Partner/
organisation/
team
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8
Moray Active Travel Strategy - ANNUAL UPDATE 2023
A) Identify key
settlements based on
population and current
transport network that
would benefit from a
coordinated approach
to Active Travel
infrastructure provision,
including cycle parking,
based on the 20-
minute neighbourhood
concept
Achieved 12 settlements all with a
population of 1200 or
over have been
identified to have AT
Masterplans. 8 have
been delivered in 23/24
alongside the LDP
consultations, and the
following 4 will take place
in the next year. This has
been funded through the
regional transport
partner HITRANS.
Moray Council
Task Status of
Progress
What was achieved Lead Partner/
organisation/
team
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
– Public Perception
Survey to be
undertaken on a bi-
annual basis 
On track for
achievement 
Work is ongoing with all
partners on events and
activities promoting
Active Travel. Three Bike
Fests have been held in
Elgin, Aberlour and
Forres with Outfit Moray
and Cycling UK, Police
Scotland and along with
other partner
organisations. The Public
perception survey is
currently in draft, and is
aimed to be shared with
the public in Nov 23.   
Moray Council 
Task Status of
Progress
What was achieved Lead Partner/
organisation/
team
Action 2     Develop Active Travel Masterplans for key settlements in Moray 
Action 4     Encourage and facilitate walking and cycling as leisure and tourist                    
activities to provide benefits to health and local economy 
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Moray Active Travel Strategy - ANNUAL UPDATE 2023
9
B) Develop a
community
engagement
programme to link with
national campaigns i.e.
Walk to Work Week,
Cycle to Work Week and
Clean Air Day etc. 
On track for
achievement
with risk of
some delay 
A community
engagement programme
is planned for 2024, due
to be completed by end
of 2023. This will be a
manageable events
programme for the
public, with support from
partners such as NHS,
Sustrans, HITRANS,
Cycling UK etc. 
Moray Council 
Task Status of
Progress
What was achieved Lead Partner/
organisation/
team
B) Determine locations
for additional cycle
parking at transport
interchanges/key
destinations, where
appropriate in
consultation with the
landowner and/or
surrounding
businesses.
Achieved
/Ongoing
The Participatory
Budgeting trial projects
in both Keith and Buckie,
where cycle parking
needs and locations
were identified have now
been completed.
Through the LDP
consultations for AT
Masterplans, cycle
parking demand in other
communities will also be
identified.
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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Moray Active Travel Strategy - ANNUAL UPDATE 2023
Action 6     Work with local employers (including Moray Council) and their staff                    
to encourage more walking and cycling to and from work 
A) Work with local
employers to achieve
Cycling Scotland’s “Cycle
Friendly” employer
status. 
B) Provide support,
guidance and
assistance for
employers to develop
or review their Travel
Plan. Cluster
organisations and
smaller businesses may
be targeted for joint
travel plans. 
F) Encourage a member
of Moray Council Senior
Management to act as
an ‘Active Travel
Champion’ to
demonstrate Council
commitment to Active
Travel. 
On track for
achievement
with risk of
some delay 
On track for
achievement
with risk of
some delay 
Not
commenced
yet,
rescheduled
to Q1 2024 
This task had been
paused for the update
work on the Sustainable
Travel website to take
priority. 
However, guidance and
updates for employers
will be published on the
Council website by the
end of FY year 23/24. 
This task had been
paused for the update
work on the Sustainable
Travel website to take
priority. 
However, guidance and
updates for employers
will be published on the
Council website by the
end of FY year 23/24. 
Moray Council   
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 2023
11
Action 7     Work with students and school pupils, staff and parents to                    
encourage more walking, cycling and scooting to and from school/                    
further education 
G) Audits of safe routes
to school will be carried
out for all Moray
schools within a 3 mile
radius.
Achieved Safer Route Audits have
now been completed at
three primary schools,
Portknockie, Milnes and
Cluny. A further 5 are
scheduled for 23/24. 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 
Task Status of
Progress
What was achieved Lead Partner/
organisation/
team
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Moray Active Travel Strategy - ANNUAL UPDATE 2023
All of the below projects (excluding the staff travel survey) have been funded
externally through various funding streams. Below is a list of the funders and funding
amounts so far this year; 
Funding
Paths for All, 
SCSP
£90,200
HITRANS,
Active Travel Improvements
£36,000
HITRANS, 
Path improvement fund
£25,000
Cycling Scotland, 
Bikeability
£53,600
Cycling, Walking, Safer Routes,
Transport Scotland
£616,000
Sustrans, 
Network Development Team
£169,742
Cycling Scotland, 
Pool Bikes and Bike Shelter
£31,500
Places For Everyone, 
Sustrans
£344,000
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Moray Active Travel Strategy - ANNUAL UPDATE 2023
13
CWSR
The Cycling, Walking, Safer Routes (CWSR) fund is a ring-fenced capital grant from
Transport Scotland and was established in 2001 for infrastructure projects.
Allocations have been provided on an annual basis in recent years. The allocation for
2022/23 is £612,852, a significant increase on the 2021/22 allocation of £421,000. 
The programme of works for this fund during FY 22/23 included the following
projects; 
Construction Projects - 
Thornhill Road, Elgin - Toucan Crossing
Morriston Road, Elgin - Toucan Crossing
Duff Place, Elgin - new footway at Bishopmill Primary School
High Street (East End), Elgin - Footway widening
B9010 Main Road, Rafford – Preparatory works for new Footway
B9040 Forsyth Street, Hopeman - New Footway
C25E Roseisle – New Footway 
Design Projects – 
St Leonards Road, Forres – Traffic Calming
Victoria Roundabout, Forres, Reallocation of road space
Grant Drive, Forres – Raised Cycle Crossings
Morriston Road, Elgin – Raised Cycle Crossings
Lossie Wynd/ Commerce Street – Improvements to cycle and pedestrian
infrastructure along the north and south links through the city centre (Options
Appraisal) 
There is an understanding that this fund will continue to increase significantly in
coming years to align with commitments made for active travel to represent 10% of
the Scottish Government’s Transport Budget by 2024/25. 
Activity during 2023
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Moray Active Travel Strategy - ANNUAL UPDATE 2023
Moray Bothy
The Bothy, which is now in its
second year, is continuously
increasing opportunities for all
living in Moray to become involved
in walking and cycling for everyday
local journeys. In March 2023 the
Bothy held the successful launch of
the ‘Cooper Park Active Travel Hub’
that was very well attended with an
estimated 150 people engaged. The
Hub is now beginning to take form
and working well, and is open to the
public three afternoons a week. 
As well as the launch of the Hub,
the bothy has delivered four led
rides, nine cycle confidence sessions, five pop up events, two Dr Bike sessions and
seven Bike loans. Some of the led rides have taken place with Elgin Youth Café,
Asylum Seekers and Spinal Injuries Scotland. The adult cycle training sessions have
mainly been offered alongside bike loans. This is a 2- hour session allowing
participants to get to know the bikes, maintenance checks, road positioning, riding in
traffic, right of way and bike security. This is completed in advance of the bike loan
ensuring that loanees are equipped with the skills they need. Bike loans have mainly
been done from the Hub in Cooper Park and the Peoplehood container at Buckie.
Most now start with a come and try session at one of the locations and if they think it
is something they would use a bike loan is arranged. 
Below is feedback shared from a participant of the Bike loan scheme; 
“As well as the very positive impact on motivating me to cycle more and drive less,
my partner, who had not been on a bike for over two years has had his interest in an
e-bike rekindled having also borrowed the one I had. Due to age-related health
issues, he has been limited him to a one hour walk a day, but the use of the e-bike
had him out for 2 x 2-hour cycles in one day and able to go much further than
previously which has had an immediate impact on his wellbeing and mental health.
He is now making plans to get an E-bike as he sees the many benefits for his health,
and it will also mean he can make short journeys by E-bike and not car”. 
Recruitment of volunteers has been low so far, but this is a priority for the project and
a plan for recruitment is currently being developed which is hoped will bring success
over the forthcoming project year. 
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Moray Active Travel Strategy - ANNUAL UPDATE 2023
15
HITRANS
In February 2023 HITRANS funded monitoring counters were installed at Belts Road.
The corner of the Belts Road, C19E Scotstoun Hill to Fernyfield Road, was built up
during the building of the new roundabout and this has caused a lack of visibility of
vehicles coming from the other direction. It is being considered whether or not to
close this road off to vehicular traffic, as it is a narrow road currently used as a short
cut. This will enable cyclists and pedestrians using the Elgin to Lhanbryde Cycle Path
to move freely across the public road. The monitoring equipment will show how all
users (ped/ cyclists/vehicles) are interacting, and will inform how any scheme is
brought forward and what kind of intervention is required. 
In March 2023 HITRANS also funded the purchase of a new 40ft container to support
the expansion of the Moray Bothy programme. Previously, the bothy was run without
a physical location so was not as easily visible, accessible or centrally located. There
are now two shipping containers, based in Cooper Park Elgin, which allows the public
better access to come borrow and try out bikes free of charge. 
Spey Viaduct NCN1 
In January 2023, funding of £98,131
was secured through the Sustrans
Network Development team to do
upgrade works along the NCN1 from
Garmouth car park to the Spey
viaduct. This is a popular walking and
cycling route for both residents and
visitors, and this section of the route
had been highlighted as a hazard and
danger for both pedestrians and
cyclists through the ATS consultation.
The total length of path resurfaced
was 688m. This also included the
removal of tree roots. There will be
two additional phases to this project
where the path will continue to be
resurfaced and any tree roots
removed. This will be split into sections; from the Viaduct to the junction with the
Speyside Way route (phase 2) which is 302m, and finally from the Speyside Way to the
B9104 (phase 3), which is 343m. Phase 2 works began mid October and is hoped to
be completed by the Christmas holidays. This is again fully funded by Sustrans costing
£71,742, and Phase 3 will aim to be completed before Q1 of FY 24/25 at a cost of
£54,156. 
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16
Moray Active Travel Strategy - ANNUAL UPDATE 2023
Forres Academy Roysvale and Burdshaugh
A number of different studies (Forres 2020 Vision; Forres Active Travel Audit (Feb
2012); Moray Council Active Travel Route Feasibility Study for Forres (March 2019) and
Moray Local Development Plan 2020) identified routes around Forres which would
enhance the active travel network. The Forres – Forres Academy, Roysvale and
Burdshaugh improvement scheme was identified by analysing where people were
walking and cycling from to get to the schools in Forres. 
The footbridge across the Burn of Mosset was replaced by Springfield Properties in
early 2020, as part of their planning obligations to provide a suitable link to Forres
Academy from new developments in the south of Forres. An opportunity arose for the
Council to further enhance the route to Forres Academy and Applegrove School
through a funding application to Sustrans Places for Everyone grant fund.  A total of
£422,000 was awarded to design, develop and construct new cycle track and footways
linking Applegrove primary and Forres Academy with residential areas through the
south and west of Forres. 
Construction completed in July 2023 and has further joined up the active travel
network in Forres, as the shared use path now provides a safer direct link to both
Forres Academy and Applegrove Primary from the surrounding residential areas
encouraging pupils to walk or cycle to the school. The shared use path also links the
community and residents of surrounding areas to The Forres Swimming Pool and
fitness centre, which thereby encouraging a modal shift to active travel journeys. 
Visualisation of how
scheme would look
Completed scheme
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Moray Active Travel Strategy - ANNUAL UPDATE 2023
17
Participatory Budgeting
Participatory Budgeting (PB) is a way for people to directly vote on how money should
be spent. During 2023/24 a pilot project was trialled in Keith and Buckie using
Participatory Budgeting to expand the community network related to active travel,
and allocate the budget available for cycle parking and repair station infrastructure.
The reason for choosing this focus was based on public and stakeholder feedback
from the draft Active Travel Strategy (ATS), received March 2022). Cycle parking and
repair station infrastructure emerged as a priority in the feedback, and would be
deliverable within this year’s budget. 
The overall budget for this pilot project was £50k, and was split equally between both
communities at £25k each. A local stakeholder group was set up for each area and
consultation events with the public took place, both in person and online, throughout
February – May. The Buckie PB was completed following the final public votes on
preferred cycle parking and location. A tender process was undertaken and Broxap
were awarded the contract. Installation of all cycle parking and repair stations in
Buckie are due to begin works mid-November and completed by the end of the
month. 
The pilot project in Keith is also currently in progress, and works have now gone out
to tender. Due to delivery and installation timescales, work is not expected to take
place until January 2024. 
Staff Travel Survey
As part of Moray Council Staff Travel Plan, employees were invited to complete a
travel survey throughout May 2023.  The Council Travel Plan was renewed in 2021 and
the first staff travel survey was undertaken to see how the COVID-19 pandemic
changed the way staff travel to/from work and on council business and how they may
travel once all restrictions were lifted. As part of the ongoing monitoring and review
programme and with seeing a return to office and hybrid based working, a repeat
staff travel survey was held for all employees based at HQ and Annexe.  This enables
a greater understanding of how staff travel to work, and when undertaking council
business, as well as finding out what would make alternative options more attractive. 
In total, 237 staff responded to the survey. 167 respondents were based at Moray
Council Headquarters and/or the HQ Annexe, which provides a survey response rate
for the two locations of 20%. 
are hybrid
working.
29% 8% 63%
of respondents are
fully office working
are fully home
working and
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Key findings from the survey were: 
The data will be used to identify any new opportunities that will benefit staff
behaviours. It will also show trends in travel, commuting behaviour and is a good tool
for measuring and comparing results when carried out on a regular basis. The data
will also be shared with colleagues managing the ‘Smarter Working’ project to help
deliver excellent services and support flexible and hybrid working. 
Staff Pool Bikes
The Climate Change and Active Travel Strategy, and Council Travel Plan have all set
targets and actions to increase cycling/walking rates and reduce CO2 emissions. As
staff are now largely either hybrid or fully office working, many staff have already
reduced the amount of travel to work. It was a good time to encourage employees to
make those short business trips by bike to reduce car journeys, as well as improving
health and well-being. Whilst there are some longer distance journeys being made for
business purposes with pool cars, there a number of trips that are under 5km that
can be swapped to bike. 
In late 2022 an application was made to
Cycling Scotland’s ‘Cycle friendly employer’
fund for grant funding towards a new fleet
of staff pool bikes. The old feet was over 6
years old and in need of replacing to try
and encourage more engagement and use
of the pool bike scheme. Once the grant
was awarded two new electric bikes and six
standard push bikes were purchased, as
well as a new bike shelter in Jan 2023 to
accommodate them. The new bikes have
waterproof panniers, locks, helmets, and
lights provided to assist staff in their
journeys 
18
Moray Active Travel Strategy - ANNUAL UPDATE 2023
Of those respondents who
currently travel to work
regularly or occasionally
(92%) the majority drive
alone (75%)
The main reasons for the choice of respondents’ mode of travel are
convenience/flexibility; distance between home and work; and lack of
viable travel alternatives.
15% 5%1% <1%
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Moray Active Travel Strategy - ANNUAL UPDATE 2023
19
The Launch of the pool bikes took place on Wednesday
17th May, and was well attended by staff and councillors.
The launch included a staff led ride, as well as the
opportunity to find out how to use the ebikes and a
general Q&A session.   
To achieve an increase in cycling, there are plans to
provide  further staff led rides to give staff knowledge of
local cycling routes, offer cycle confidence sessions (1:1
or group sessions) and offer Dr Bike checks to provide
staff with good maintenance skills and knowledge to use
the bikes. 
Staff make approximately 2,500 miles for business travel
every month by car. The aim is to replace between 2.5% and 5% of those miles to
cycling through the pool bike scheme. Ongoing monitoring and evaluation will take
place bi-annually of the uptake of the pool bike scheme. 
GET ON YER BIKE!
STAFF
POOL17
BIKE
LAUNCH
MAY
12-2PM
councillors carpak
Come along and see our new
fleet of pool bikes, including
ebikes, ready to use for all
your short business trips.
12 - 1pm - Q&A
1 - 2pm Led staff ride
For more information, please contact
janet.macdonald@moray.gov.uk
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School Engagement
Living Streets Travel Tracker Programme
This is the eighth year that WOW – The year-round walk to school challenge and the
WOW Travel Tracker have been used in primary schools across Moray Council. By the
end of June 2023, there were 20 schools in Moray registered in the WOW programme
with 19 tracking at over 10% engagement. Two new schools have joined the
programme during the year, making it the most successful year of the programme so
far. This year saw 3980 children engaged in the project, 106,272 sustainable and
active travel journeys made as well as 2031 children choosing to walk or cycle to
school. 
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
20
Moray Active Travel Strategy - ANNUAL UPDATE 2023
The number of children
engaged in the project 
The number of sustainable
and active travel journeys 
Modal shift compared to
previous year 
The number of people
choosing to walk or cycle
3674 
1800 regularly engaged 
87,043 journeys
counting towards
badges for the period 
1% increase 
1584 children
3980 
2308 regularly engaged 
106,272 journeys
counting towards
badges for the period 
0% Change 
2031 children
2021 - 22
17 schools registered
2022 - 23
20 schools registered
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Moray Active Travel Strategy - ANNUAL UPDATE 2023
21
The Living Streets mascot, Strider, has
visited seven schools in Moray this year.
The visits included Moray Council’s climate
change event at Milne’s Primary school;
assemblies at Lhanbryde Primary and
Bishopmill Primary; school gate events,
including road safety week, at Linkwood
Primary, New Elgin Primary and
Mosstodloch Primary; and line dancing at
Findochty Primary, Bishopmill Primary and
at the launch of the Cooper Park Active
Travel Hub. 
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 Park Smart has run successfully at three separate schools, Bishopmill,
Greenwards and Mosstodloch. Each school produces a short evaluation report with
the findings of the initiative, and pledges to develop a School Travel Plan upon
completion. Each of the schools reported a reduction in congestion around the school
gates, with some being significantly more than others. However, all reported an
increase in active trips and a decrease in non-active trips in the immediate period
following the initiative. 
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Moray Active Travel Strategy - ANNUAL UPDATE 2023
Safe Route Audits
Living Streets staff, along with school staff and pupils, completed School Route Audits
at three schools, Cluny, Milne’s and Portknockie Primary. 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 the Cycling, Walking Safer Routes
(CWSR) spend. 
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. However, with the
increasing costs yearly of resources, transport and delivery, Outfit Moray absorbed
additional costs in both 21/22 and 22/23 to enable delivery. In the long term, this is
not sustainable if it is expected to achieve the ATS target of 95% of all schools
delivering L2 Bikeability by 2027. 
In 22/23 Bikeability level 2 was delivered to 31 of the 45 primary schools, engaging
with a total of 940 pupils. This is slightly down on last year, despite still being on
target), but is a result of a reduction in the number of funded co-ordinator hours for
Outfit Moray, and at times a reduction and lack of volunteers/ school staff, willing or
allowed, to support the programme. It is essential that schools support delivery of
Bikeability to reduce costs so targets can be achieved. 
21/22                                     22/23 
Total Schools                  30                                           31 
Total pupils                     955                                         940
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Moray Active Travel Strategy - ANNUAL UPDATE 2023
23
Cycle Parking Infrastructure
Following a successful application to Cycling Scotland for cycle parking infrastructure
for Speyside High School, an Anti-Vandal Wardale Cycle Shelter was purchased and
installed by Broxap. The shelter has a capacity for up to 14 cycles, and as there was
previously no cycle parking facility at the school, this was a barrier impacting on
young people being able to cycle to and from school. As well as serving the school,
the cycle parking will also be available to users of the Speyside Community centre
that is located on the same campus. 
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, but 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. 
Active Travel Masterplans
Work on the review of the Moray Local Development Plan
started this year, and is expected to be adopted in 2027. The
LDP will shape how land and buildings are used over the
next 10-20 years, which affects people's lives including
work, travel, and access to open space, play and health. As
part of the LDP, work has begun alongside colleagues in
planning to develop local Active Travel Masterplans
through community engagement. Since March 23, eight
community events have been held in Forres, Aberlour,
Dufftown, Elgin, Lossie, Fochabers, Keith and Buckie.
Through these events, feedback has been gathered from
the public on where there are missing links in the active
travel network and where improvements can be made.
This includes new routes, improvements on existing
routes, cycle parking infrastructure and any behaviour
change ideas. The 2nd phase of this project will be drafting up all the information
received and putting together a short masterplan document for each community. 
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24
Moray Active Travel Strategy - ANNUAL UPDATE 2023
Bike Fest
As part of the development of the programme of
community events, this year three ‘Bike Fests’
were held alongside the Moray Bothy and
delivered by Cycling UK. They were delivered in
Elgin, Forres and Aberlour. Outfit Moray, Bike
Revolution, Tyred N Cranky and Police Scotland
supported the events.
The events had Dr
Bike sessions, a skills
course, led rides,
ebike try-outs and the
opportunity to register your bike for free through ‘Bike
Registration’ with Police Scotland. The events were well
attended and engaged with over 400 people. 
Speyside Challenge
Following on from the success of last year’s Speyside Challenge, it returned for the
second time this September. The challenge is about encouraging users of the
Speyside Way to take up the challenge throughout the whole of September, and
promotion of the Speyside Low Carbon Hub. The challenge itself is to log the most
distance covered, or the most journeys, by foot or bike, on the popular route that is
now part of the Speyside Low Carbon Hub, to be in with a chance of winning one of
eight prizes. The challenge is free to join and allows participants to challenge
themselves personally or compete within a workplace. 
This year saw participants logging a total of 2,427kms, almost 100kms more than last
year. And a total of 236 journeys were recorded, with 35 challengers involved. The
challenge helps to promote an important active travel route that can reduce carbon
emissions from daily travel. 
There were twelve prize-winners all in receipt of Moray Loves Local gift vouchers. See
all results at www.speysidechallenge.com
2022
2023 316kg CO2
saved
2,354km
travelled
206 
journeys
306kg CO2
saved
2,427km
travelled
236 
journeys
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25
Moray Active Travel Strategy - ANNUAL UPDATE 2023
The Scottish Government announced increased funding for active travel in its draft
budget proposal for 2023-24, with almost £190m allocated for active travel. It was
also agreed that at least £320m or 10% of the total transport budget would be
allocated to Active Travel by 2024-25. 
This year saw the introduction of Transport Scotland’s new Active Travel
Transformation Fund. The Active Travel Transformation Fund has a budget of
£20million. 
The 2023/24 Transformation Fund included funding available to partners: 
to support the delivery of eligible construction-ready AT schemes in 2023/24, and
as a secondary aim
to support those unsuccessful in applying for additional budget to deliver
construction-ready projects in 2023/24 to progress towards successful applications
in future years, helping to ensure that a wider pipeline of projects is being
developed ahead of the budget commitment for 2024/25.   
As the funding for 23/24 was prioritising construction and ‘shovel ready’ projects, a
decision was taken to not take forward an application this year. There are currently a
number of completed designs for medium size projects ready to take forward, so
work is ongoing in putting together pipeline projects for the coming years through
this fund. Below is a list of some of the larger pipeline projects, which may be
constructed through this new funding stream in future years; 
Forres, Market Street roundabout - Road Space reallocation to pedestrians and
cyclists
Dufftown, Maltkiln Bridge - New footbridge on existing walking route, so
pedestrians do not have to walk on the carriageway.
Lossiemouth, Coulardbank Road - Safety, convenience and connecting
communities: from North Covesea Terrace through to the high school there is no
proper connection in terms of a safe cycle and pedestrian path. Two options: a
segregated track parallel to Coulardbank Road on its south flank, or widening
South Covesea Terrace to allow for adding a wide enough shared path, which then
bends south to the high school. 
The newly developed Active Travel Prioritisation Tool will also be key in future years
when considering any new active travel infrastructure schemes or interventions, such
as cycle lanes, shared pathways and controlled crossings. Schemes taken forward will
be subject to the scoring outcome from the tool as well as budget availability and
officer capacity. 
Priorities for the Year Ahead
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26
Moray Active Travel Strategy - ANNUAL UPDATE 2023
The CWSR grant fund for 23/24 will be split across six infrastructure projects in 23/24
and five design projects. These include; 
Construction
Lang Walk, Elgin – Footway widening
Coulardbank Road, Lossiemouth - Toucan crossing
Fochabers, Pedestrian Island upgrades
B9010, Rafford – New Footway
C225E, Roseisle – New Footway
War memorial, Garmouth – New Footway 
Design
Victoria roundabout and St Catherines Road, Forres – Reallocation of roadspace
St Leonards Road, Forres – Build out to assist pedestrians crossing the road
Coulardbank Road, Lossiemouth – Cycle track design options
Barhill Road/ Golfview Drive, Buckie – Road spaces reallocation
Linkwood Road, Elgin – Pedestrian island 
Some of the work on these projects is likely to continue into financial year 2024/25. 
HITRANS Funding
Through HITRANS funding for 23/24 it is planned to make improvements on an active
travel route on Turner Street, Keith linking to the hospital. There are concerns of
safety on this route due to anti-social behaviour and a lack of lighting. Therefore, new
LED lighting  will be installed along this section to improve safety of pedestrians.
Completion of the Active Travel Masterplans for all the communities consulted with
through the LDP review is planned for the end of FY 23/24. 
A new path improvement fund has become available through Transport Scotland,
administered by HITRANS which will help to improve existing local paths within and
between communities, improving the usability and accessibility of paths for more
people. An application was successful in securing £25,000 for 23/24 and through this
fund both the Alexandra Road underpass in Elgin, and an 800m section of the Elgin –
Lossie cycle path near Spynie Woods will be resurfaced. The Alexandra Road path is a
busy Active Travel route used by both pedestrians and cyclists to access public
transport connections at Elgin Bus Station. It also allows the public to avoid crossing
the A96 to access the town centre. This will make the route suitable for wheelchair
users, pushchairs, and less able users. The Elgin – Lossie cycle track is a popular
commuting route linking two communities, giving the public access to jobs and public
transport connections. Improving this section will make the path more accessible to
more people for walking, wheeling and cycling. 
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Moray Active Travel Strategy - ANNUAL UPDATE 2023
27
School Engagement
Support for nineteen primary schools in Moray will be available to participate in WOW
for the 2023/24 session. In addition, it is planned to carry out five school route audits,
as well as developing seven active travel zone leaflets, and running the Park Smart
initiative at four schools during the 2023/24 session. 
In addition, this year one secondary school will be supported with a 1-day event
focussing on S1 and S2 pupils. This will take place in May 2024 during senior pupils’
exam leave. Information will be sent to a number of secondary schools to gauge
interest in participating. 
Bikeability
For the school year 23/24, a successful application was made to Cycling Scotland to
continue to deliver Bikeability level 2 across schools in Moray. Despite a reduction by
a third in the budget for Bikeability, an award of £57,576 was received, £4,000 more
than 22/23. This will allow delivery of Level 2 to 35 primary schools across Moray and
engagement with over 875 pupils. 
Smarter Choices Smarter Places (SCSP)
Moray Council will continue to grow the wide programme of activities that provides
opportunities for sustainable and active travel for all. The programme for 23/24 will
offer a variety of schemes to target different population groups. This year will again
see the continued use of Travel Tracker/WoW in schools, delivered in partnership with
Living Streets. It is also planned to work directly with whole school communities and
local partners such as Outfit Moray, as well Moray Councils Climate Change team, to
roll out further active and sustainable travel activities and events such as Bike Doctor
sessions delivered alongside the Bikeability programme, as well as school events and
assemblies that promote Active Travel. Additional events will be held to expand the
‘Moray Bothy Project’ will be delivered by Cycling UK, where the Bothy bikes will be
available for use in other communities across Moray. Continued promotion for the
Council's Demand Responsive Transport bus service to run a Saturday service
operating in the Forres area will be ongoing to encourage use of sustainable transport
in rural Moray. These initiatives will result in a measurable increase in the number of
active and sustainable travel journeys made, where walking, cycling and bus usage is
a mode of choice for local journeys across Moray.
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Moray Active Travel Strategy - ANNUAL UPDATE 2023
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Moray Active Travel Strategy - ANNUAL UPDATE 2023
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REPORT TO:  ECONOMIC DEVELOPMENT AND INFRASTRUCTURE
SERVICES COMMITTEE ON 14 NOVEMBER 2023 
SUBJECT:  ROAD SAFETY PLAN TO 2030 
BY:  DEPUTE CHIEF EXECUTIVE (ECONOMY, ENVIRONMENT
AND FINANCE) 
1. REASON FOR REPORT 
1.1 To seek approval of the Committee for the draft Moray Road Safety Plan to
2030 to be the subject of further stakeholder consultation and inform the
committee of the outcome of investigation of reported injury accidents on the
A98 Fochabers to Aberdeenshire boundary road.   
1.2 This report is submitted to Committee in terms of Section III (F) (15) the
Council's Scheme of Administration relating to the duty of the Council as
Roads Authority. 
2. RECOMMENDATION 
It is recommended that Committee: 
i) approves the draft Road Safety Plan to 2030 attached as
APPENDIX 1 for consultation with stakeholders and; 
ii) notes the outcome of the investigation of reported injury
accidents on the A98 over the ten year period 2013 to 2022.  
3. BACKGROUND 
3.1 There have been six previous Road Safety Plans prepared for Moray, the
most recent being published in 2018 and covering the period 2018 to 2022
starting in the New Year. The Joint Community Council will be included in this
consultation as one proposed action is to work jointly with Police Scotland to
develop community road safety champions who would become the focal point
for engagement and the dissemination of road safety information. 
3.2 In Moray the trend in accident and casualty data is generally downwards, with
some exceptions. It is the random  nature of road accidents along with events
such as weather, Covid 19, large scale sporting and entertainment events and
changing travel patterns which all contribute to how many people are injured
on our roads. 
Item 6
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3.3 The draft Plan demonstrates that overall injury accident rates in Moray remain
significantly lower than the rates for the whole of Scotland. Furthermore, in
Scotland as a whole the majority of injury accidents occur on the urban road
network, whereas in Moray (in keeping with other similar rural authorities) the
majority of injury accidents occur on rural roads, as demonstrated in the table 
below: 
Percentage of casualties by Built up or Non-built up road 2014-2021 
Any speed limit
of 40 mph or
under
50 or 60 mph
speed limit
70 mph speed
limit
Moray 29% 71% 0%
Scotland 60% 33% 7% 
3.4 It should be noted that across Scotland the five year injury accident rates have
been affected by the changes in travel patterns during 2020 and 2021
associated with the Covid-19 pandemic. When these years are included in the
analysis of the reported injury accidents, the results show good progress
towards the targets set in the national Road Safety Framework to 2030.
However the most recent accident data from 2022 shows an increase in rates
as travel behaviours return to those experienced prior to the pandemic. 
3.5 The draft Road Safety Plan highlights the following areas where actions could
be taken to work towards the target injury accident rates as set in the Roads 
Framework to 2030: 
• The prevalence of accidents on rural roads; 
• Ongoing maintenance of the road network;
• Driver behaviour and speed management;
• On-going education of road users; and 
• Provision of infrastructure for vulnerable road users (cyclists,
pedestrians etc. 
Rural Roads and the Maintenance of the Road Network 
3.6 There are generally no discernible ‘clusters’ of accidents on the rural roads in
Moray. Therefore maintenance of rural roads is the primary means of
mitigating against the risk and severity of accidents on our rural roads as
opposed to site specific engineering interventions. Ensuring that the condition
of road surfaces does not adversely deteriorate, that road signage, markings
and cats eyes are visible to road users, surface water is managed and road
side vegetation is cut back can all have positive consequences on the number
and severity of accidents when carried out effectively. 
Driver behaviour, speed management and On-going education of road users 
3.7 Every road user has a responsibility to ensure that they are competent, paying
full attention to the road ahead and the task in hand, adapting to the
conditions, travelling at appropriate speeds, are not impaired by alcohol or
drugs (including prescribed medications), are not distracted by in-vehicle
technology and are giving sufficient room to other road users, no matter what
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their mode of travel.  There are various national road safety campaigns which
deliver targeted messaging on safe road use. 
3.8 The setting of speed limits is determined using national guidance, which takes
into consideration the roadside environment and how this will be viewed by a
driver. Where there is more roadside activity and therefore a greater likelihood
of vehicles joining a road at a junction, pedestrians crossing a road, cyclists
using the carriageway, a driver will perceive a greater level of ‘risk’ and is
more likely to be travelling at a lower speed. 
3.9 The enforcement of speed limits is carried out by Police Scotland and Safety
Cameras Scotland. Enforcement is focussed at locations where there is
evidence of a significant number of vehicles are travelling at excessive and/or
at locations where there is a history of injury accidents where excessive speed
has been noted as a contributing factor. These locations tend to be on rural
sections of road. The draft Road Safety Plan includes an action to continue to
support the Safety Camera programme. 
3.10 The delivery of road safety education would be through the sharing of road
safety messages from national campaigns and working with our partners to
deliver specific campaigns and activities. It is also proposed to seek local
community Road Safety Champions through the training of volunteers from
Community Councils so they understand road safety and can disseminate
information to the wider community. A similar approach to developing Road
Safety Champions could be embedded within schools and other education
settings. 
3.11 Continuation of the existing relationships and joint working with Police
Scotland to share information and data, along with areas of concern raised by
members of the public where there is a perception of excessive vehicle
speeds, anti-social driving etc. will support education campaigns and the
proposed introduction of community Road Safety Champions. 
Provision of Infrastructure for Vulnerable Road Users 
3.12 The number of injury accidents reported in Moray which involve a vulnerable
road user (pedestrian, cyclist, horse rider etc.) remains significantly lower than
Scotland as a whole. However National Transport Strategy 2, supported by
funding provided by Scottish Government seeks to increase the number of
everyday journeys undertaken by foot and cycle and through wheeling. The
provision of segregated infrastructure for these user groups reduces the risk
of injury accidents and in turn, increases the likelihood that people will choose
to travel by those modes of transport. 
3.13 The safety of these vulnerable users groups will be a key consideration in the
development of proposals for new/improved active travel infrastructure, in
particular users with impaired mobility and pedestrians. The plan has been the
subject of an Integrated Impact Assessment (APPENDIX 2).  
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3.14 At present the draft Road Safety Plan to 2030 is awaiting completion of
infographics and revisions to the layout of the draft Plan. After the layout has
been completed, consultation with stakeholders involved in the development
of the draft plan will take place, along with consultation with the Joint
Community Council. 
3.15 The final approved Plan will be published on the Council website and used to
support applications to the Scottish Government’s Road Safety Improvement
Fund. The plan will be subject to a mid-term review in 2027 to assess
progress against national targets and to see where joint working has been
successful/could be enhanced 
4. A98 FOCHABERS TO CULLEN ROAD – REPORTED ACCIDENTS 
4.1 Concerns have been raised regarding the number of reported accidents on
the A98 Fochabers to Cullen Road (see Question raised at Moray Council
committee on 28 September 2022, para 25 of the minute refers). The A98
connects to the A96 (Trunk Road) at Fochabers and passes through the
coastal plain and into Aberdeenshire. The road is a strategic route which
carries traffic accessing the harbours, distilleries and bringing goods and
services into the area. It is a former Trunk Road and is therefore designed to a
high standard, with ease of movement being the priority. The roadside
environment generally has wide verges, good forward sightlines and
appropriate warning signage and, where necessary, vehicle restraint systems.
However on certain sections of the road there are a series of side road
junctions and individual property accesses. 
4.2 The draft Road Safety Plan (see table on page 22) sets out the accident rates
per kilometre per year for the A class roads in Moray, including the A98 and
the rate for similar roads A class roads for the whole of Scotland for the
period. 
4.3 Further information, including a summary of the reported injury accidents on
the A98 between Fochabers and the Aberdeenshire boundary has been
uploaded to CMIS along with the agenda, as an additional meeting document.
The number of accidents reported over the ten year period from 2013 to 2022
is too low to infer any statistical significance or discernible pattern. 
4.4 As indicated in paragraph 3.12, ensuring the roads are well maintained can
reduce the numbers and severity of accidents. The A98 is a strategic road
which on its eastern section carries some 9,000 vehicles per day and
therefore should be prioritised in terms of ensuring that road markings and
signage are in good condition, surfaces offer good skid resistance and good
visibility is provided through the control of roadside vegetation. In terms of
providing good visibility, it is also important that individual property accesses
and private roads have good visibility in both directions and that obstructions
out with the roadside verge are removed. 
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4.5 Finally, concerns have been raised regarding the speed of traffic using the
A98, in particular where it passes through Arradoul. Within Arradoul there is a
permanent traffic counter which also measures vehicle speeds. Observed
speeds from this counter show that within the 50mph speed limit in Arradoul
average vehicle speeds are below the speed limit. It is however
acknowledged that there is a small number of drivers who travel at excessive
vehicle speeds on the A98. The Scottish Road Safety Camera Partnership
and has three sites on the A98, at Slackend, near Broadley and near Carnoch
Farm, which seek to address this driver behaviour through speed enforcement
and education. 
5. SUMMARY OF IMPLICATIONS 
(a) Corporate Plan and 10 Year Plan (Local Outcomes Improvement
Plan (LOIP))
The key policy documents which are relevant to Road Safety are the
LOIP September 2021, the Moray Corporate Plan 2024 and the Moray
Economic Strategy. 
(b) Policy and Legal
Council has a duty under Section 39 of the Road Traffic Act 1988 to
prepare and carry out a programme of measures designed to promote
road safety. 
(c) Financial implications
There are no financial implications arising from this report. However
revenue budgets for the maintenance of road safety measures such as
road markings, cats’ eyes and road signs have reduced since approval
of the last Road Safety Plan. The allocation of revenue and capital
budget is a matter for corporate prioritisation in the budget setting
process, and applications for external funding are made wherever
possible. 
(d) Risk Implications
There are no new risk implications arising from this report. 
(e) Staffing Implications
There are no staffing implications as this process forms part of existing
duties. However any reduction in staff resources will have an impact on
the ability to deliver the plan. 
(f) Property
There are no property implications arising from this report. 
(g) Equalities/Socio Economic Impact
An Integrated Impact Assessment has been undertaken and no negative
impacts on any protected groups were found. An action in the Road
Safety is to provide active travel infrastructure which would be utilised by
users with protected characteristics (Disability and Age). An individual
Equalities Impact Assessment will be undertaken as individual schemes
are developed to seek to maximise the benefits of each scheme. 
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(h) Climate Change and Biodiversity Impacts
An action in the Road Safety is to provide active travel infrastructure.
Promoting Active Travel is one of the key actions in the Council’s
Climate Change Strategy. Provision of dedicated active travel
infrastructure can provide a positive impact on the climate through
enabling and encouraging alternative modes of travel through Moray.
Reduced emissions supports nature recovery and the overall
improvement of environments. 
(i) Consultations
Police Scotland, Scottish Fire and Rescue Services, Transport Scotland,
Amey Limited, North Safety Camera Unit, the Scottish Ambulance
Service, NHS Grampian, Moray Council Education and Environmental
Health officers have been consulted and their comments incorporated in
the plan. 
The Depute Chief Executive (Economy, Environment & Finance), Head
of Environmental and Commercial Services, Legal Services Manager,
Chief Financial Officer, Equalities Officer and Committee Services
Officer (L Robinson) have been consulted and any comments taken into
consideration. 
6. CONCLUSION 
6.1 The draft Moray Road Safety Plan covers the period up to 2030, when it
is anticipated that the next Scottish Road Safety Framework to 2040 will
have been published. 
6.2 The draft plan takes into account the Safe System approach to Road
Safety which was introduced in the Scottish Road Safety Framework to
2030. The draft Plan also promotes joint working with neighbouring local
authorities and other public sector bodies. 
6.3 Available accident data up to 2022 has been reviewed and presented in
the draft Road Safety Plan. The review shows downward trends in the
number of accidents and a reduction in the number of people injured or
killed. 
6.4 Accident rates in Moray remain significantly lower than rates across
Scotland, in particular the rates involving pedestrians and cyclists. The
trend for accidents across Scotland is for more accidents to occur in the
urban environment as opposed to on rural roads. However in Moray the
majority of accidents occur on rural roads. 
6.5 There are no discernible clusters of injury accidents in Moray. However
the on-going maintenance of road markings, cats’ eyes and roads
signage, the management of surface water and the cutting back of
vegetation on rural roads can all contribute to keeping accident rates
low. Any requests for capital funding will be made through the capital
planning process to develop and implement road safety schemes
identified during the plan period.  Applications will be made to the Road
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Safety Improvement Fund for any improvement schemes which meet the
fund criteria. 
6.6 Stakeholder consultation will take place for 8 weeks, after which the
updated Road Safety Plan will be reported to this committee.
It is proposed to review the plan mid- term (2027) against the national
targets and to see where joint working has been successful/could be
enhanced. 
6.7 A review of reported injury accidents occurring on the A98 Fochabers to
Cullen road has been undertaken for the period 2013 to 2022. The results
of this review shows no discernible patterns or clusters of reported
accidents, no requirement to reduce the speed limit in Arradoul and no
site specific mitigation measures. 
Author of Report: Elaine Penny, Engineer (Traffic)
Background Papers: Scotland’s Road Safety Framework to 2030 
Ref:    SPMAN-524642768-980 
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NOTE: Awaiting Infographics and layout review. 
Moray Road Safety Plan
to 2030 
Item 6
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Table of Contents 
Executive Summary ......................................................................................... 1
Introduction ...................................................................................................... 5
Strategic Partnerships and Frameworks ....................................................... 8
Scotland’s Road Safety Framework .............................................................. 8
Local Partnership Forum North ................................................................... 10
Road Safety North East Scotland (RSNES) ................................................ 10
Local and Regional Policies and Context .................................................... 13
Accidents in Moray ........................................................................................ 15
Accidents and casualties ............................................................................ 15
Casualties in Built up versus Non-built up areas ......................................... 18
Casualties by home residence .................................................................... 21
Risk by road type ........................................................................................ 22
Casualties by road user type ...................................................................... 24
Age (Pre, young and older drivers) ............................................................. 24
The Cost of Accidents ................................................................................. 25
Issues and Actions ........................................................................................ 27
Issues ......................................................................................................... 28
Safe Road Use ........................................................................................... 28
Safe Vehicles .............................................................................................. 32
Safe Speeds ............................................................................................... 32
Safe Roads and Roadsides ........................................................................ 34
Post-Crash Response ................................................................................. 35
What we are going to do ................................................................................ 37
Future Targets ................................................................................................ 40
Glossary of Terms .......................................................................................... 41
Organisations Involved ................................................................................. 42 
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Executive Summary
This Moray Road Safety Plan covers the period up to 2030, when it is anticipated
that the next Scottish Road Safety Framework to 2040 will have been published.
The Plan takes into account the Safe System approach to Road Safety which
was introduced in the Scottish Road Safety Framework to 2030 (published in
2021).
Safe System/Vision Zero has a long-term goal for a road traffic system which is
eventually free from death and serious injury. It involves an important paradigm
shift from trying to prevent all collisions to preventing death and mitigating serious
injury in road traffic collisions, a problem which is largely preventable based on
current knowledge. 
Source: Loughborough University Design School Safe System Course, 2017, with PACTS
modifications, 2022 
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Available accident data up to 2022 has been reviewed and is presented in the
plan. The Scottish Road Safety Framework sets the baseline period which all
local authorities are required to use in their Road Safety Plans. Analysis of the
accident data shows that trends are downward with a 59% reduction in the
number of accidents between the baselines for the previous plan (2004-2008)
and this plan (2014-18), with a consequent reduction in the number of people
injured by 57%. The same figure for the whole of Scotland is 40%.
The biggest reduction is in slight injuries, which could be due to underreporting
as a result of changes to data collected after Police Scotland’s formation in April
2013. There is, however, also a 31% reduction in the number of people killed.
This is likely due to a number of factors including better in car safety, medical
attention post-crash and engineering improvements to prevent the accident
happening in the first place. The incidence of serious injuries has remained
broadly similar. 
The previous 5 years figures (2018-22) have been significantly affected by
COVID19 travel restrictions with 2020 and 2021 recording the lowest ever
casualty figures across Scotland. In 2022, across Scotland, apart from fatalities,
the figures are still lower than they were prior to the pandemic.
However whilst the overall number of reported accidents is low compared to the
rest of Scotland, in Moray over 70% of casualties are injured on non-built up roads
(rural roads) compared to just a third of casualties for Scotland as a whole. It is
therefore important to consider the relative risk, rurality and specific
characteristics of injury accidents in Moray when developing interventions, as
opposed to following the Scotland wide approach.
There is no discernible pattern or cluster of reported accidents on the rural roads.
Therefore rather than focussing on specific engineering interventions at a
particular location, it is recommended to continue to view our rural routes as a
whole and look to ensuring that they remain fit for purpose with surfacing and
road markings in good condition, signage being clear and not obstructed by
vegetation and, where required, drainage interventions to reduce risks from
surface water and icing. Accident records and complaints from the public will be
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used to focus resources at locations or on routes where there is an increased risk
of accidents. Road condition surveys will be used to provide further evidence of
the need to prioritise a location/route.
The Plan also indicates that the provision of dedicated active travel infrastructure
to support movements on the road network by vulnerable users will be pursued
to provide an environment where users are more confident and therefore more
likely to travel by foot, wheeling or cycling. This infrastructure will focussed in
areas which serve vulnerable users, e.g. young or older persons, and be
delivered using external funding sources and the Road Safety capital funding.
The Scottish Government Road Safety Framework encourages a partnership
approach with neighbouring authorities and other public sector bodies. Actions
within this Plan include joint working with the Education and Lifelong Learning
Service with respect to providing road safety education within the school setting
to children and pre and new drivers, along with joint working with Police Scotland
with respect to participating in ongoing campaigns and roadside education of
drivers, and the delivery of New Driver interventions.
An appropriate level of capital budget will also be required to implement
improvement schemes identified through the investigation of accidents which
occur during the lifetime of the plan. The types of improvement schemes could
relate to minor junction improvements, facilities to assist pedestrians and/or
cyclists crossing the road, the provision of improved sightlines at junctions,
improvement plans for routes and so forth. Applications will also be submitted to
the Scottish Government Road Safety Improvement Fund for schemes which
meet the fund criteria (mainly across the rural network).
The changes in travel behaviours during 2020 and 2021 as a result of the Covid
19 pandemic have led to significant reductions in the number of reported
accidents during those two years. It is therefore proposed to undertake a mid-
term review of the plan in 2027 to review Moray’s progress towards the national
interim targets for 2030 and to see where joint working has been successful/could
be enhanced. 
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Introduction
This is the seventh Road Safety Plan for Moray, the previous plans being
prepared in 1997, 2000, 2004, 2007, 2011 and 2018, respectively. Each previous
plan laid out a framework of policies and actions to improve road safety over the
life of that plan. This plan seeks to review road safety activity in Moray and create
and maintain partnerships which will help develop proportionate interventions to
continue to improve road safety in Moray. It is also the first plan which will see
the focus on the safe system approach set out in Scotland’s Road Safety
Framework to 2030 ‘Together, making Scotland’s roads safer’.
The Plan is produced to meet the council’s statutory duty under Section 39 of the
Road Traffic Act 1988 to prepare and carry out a programme of measures
designed to promote road safety.
The Council is required to carry out studies into accidents arising out of the use
of vehicles on roads for which they are the Roads Authority and must, in light of
those studies, take such measures as appear to be appropriate to prevent such
accidents, including:
• the dissemination of information and advice relating to the use of roads,
the giving of practical training to road users or any class or description of
road users; 
• the construction, improvement, maintenance or repair of and other
measures taken in the exercise of their powers for controlling, protecting
or assisting the movement of traffic on roads; and 
• in constructing new roads, must take such measures as appear to be
appropriate to reduce the possibilities of such accidents when the roads
come into use.
Road Safety sits within a wider context of policies and activities undertaken by
local authorities and public bodies, as shown in the diagram below:
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Source: Scotland’s Road Safety Framework to 2030
The new Road Safety Framework promotes partnership working ‘Together,
making Scotland’s roads safer’. However, it is also the responsibility of road users
to ensure that their vehicles are road worthy, they have a valid licence for the
type of vehicle they are using and that they are fit and competent to safely operate
a vehicle. 
There are strong interrelationship between the various groups and bodies with
respect to Road Safety as demonstrated in the following diagram: 
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Although there are these relationships, each body has its own clear area of
responsibility.
Whilst the Trunk roads throughout Moray are the responsibility of Transport
Scotland, and are managed and maintained on their behalf by Amey, all the
statistics quoted in this plan are for both trunk and local roads. This goes back to
the council responsibility for road safety on all the roads within its area. 
This Plan has been produced by the Moray Council’s Transportation team in
conjunction with local representatives of Police Scotland; Transport Scotland
Amey; NHS Grampian; Scottish Fire and Rescue Service; The Scottish
Ambulance Service, North East Safety Camera Unit and other Council services,
such as Education and Lifelong Learning.  
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Strategic Partnerships and Frameworks
Scotland’s Road Safety Framework
Scotland’s Road Safety Framework to 2030 - Together, making Scotland's roads
safer, was published by Transport Scotland in February 20211. It heralds a new
approach to road safety by introducing the Safe System approach at a national,
regional, local and even individual level. The following diagram sets out the five
pillars of the Safe System:   
1 Scotland's Road Safety Framework to 2030
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The Framework also proposes new targets.2 to 2030. These interim targets are
‘milestones’ or ‘check points’ for the Framework’s long term goal of moving close
to zero fatalities and serious injuries in road transport by 2050.
It should be noted that within the Framework the baseline for accident data used
to assess progress towards the above interim targets has been set as the years 
2 Scotland's Road Safety Framework to 2030
Scotland’s Road Safety Framework Targets
Our Targets
Interim Targets to 2030
50% reduction in people killed
50% reduction in people seriously injured
60% reduction in children (aged <16) killed
60% reduction in children (aged <16) seriously injured 
Intermediate Outcome Targets
• 40% reduction in pedestrians killed or seriously injured
• 20% reduction in cyclists killed or seriously injured
• 30% reduction in motorcyclists killed or seriously injured
• 20% reduction in road users aged 70 and over killed or
seriously injured
• 70% reduction in road users aged between 17 to 25 killed or
seriously injured
• Percentage of motorists driving/riding within the posted speed
limit
• The casualty rate for the most deprived 10% SIMD areas is
reduced to equal to the least deprived 10% SIMD areas.
Intermediate Measures
• Casualty rate per 100 million vehicle kilometres for cyclists
killed and seriously injured
• Casualty rate per thousand population for pedestrians killed
and seriously injured
• Number of people killed and seriously injured in collisions
where at least one driver/rider was driving for work, not
commuting
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2014 to 2018. The previous baseline for the Scottish Government Road Safety
Framework to 2020 covers the years 2004 to 2008.  
Local Partnership Forum North 
In a wider context, and to improve communications between national and local
level government, Transport Scotland’s Road Safety Framework has developed
three Scottish local partnership forum groups. The North Unit comprises the
Councils of:
• Aberdeenshire
• Aberdeen
• Angus
• Perth & Kinross
• Moray
• Highland
• Comhairle nan Eilean Siar
• Shetland Islands,
• Orkney Islands.
These forums allow operational partners to discuss specific interventions and
compare the types of road users who are injured. It is important that these links
are developed as approximately a third of all Moray residents injured each year
in road accidents are on a trunk roads. This pattern is similar across the
neighbouring local authorities, who are also part of the Local Partnership Forum
North and the Road Safety North East Scotland groups.
Road Safety North East Scotland (RSNES)
Across the North East of Scotland, agencies have been working in partnership
since Local Government reorganisation in 1996 to reduce the number and
severity of casualties on our road network. This culminated in a Joint Public
Sector Group formalising a partnership which is now known as Road Safety North
East Scotland (RSNES). From the peak road casualty figures in 2004-2006 the
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group has steadily reduced the number and severity of casualties in the
intervening years. The latest strategy for the RSNES was approved in summer
20173
The group comprises partners including the three north east local authorities;
(Aberdeen City, Aberdeenshire and Moray Councils), NESTRANS, North Safety
Camera Unit. NHS Grampian, Police Scotland, Road Safety Scotland, Scottish
Fire and Rescue Service and Transport Scotland, all of which have a role in road
safety.
The group monitors ongoing accident and casualty trends and collaborates on
campaigns and research. Robert Gordon University are currently working on a
number of research projects on behalf of the RSNES in relation to young driver
interventions, motorcycle crashes4 and interventions5 and the general downward
trend of casualties across the North East compared to Scotland as a whole. 
Prior to 2020, Aberdeenshire Community Safety Partnership alongside RSNES
delivered the young driver intervention ‘Safe Drive, Stay Alive’. However, in 2018
Transport Scotland commissioned a research report from TRL (Transport
Research Laboratory) which reviewed the effectiveness of pre–driver
interventions. The report6 was critical of the type of Safe Drive interventions as
there was little evidence that the main premise of any intervention should be ‘do
no harm’ was fulfilled. 
With this in mind Police Scotland in Ayrshire developed a new type of young
driver intervention, ‘New Driver Scheme’, which was evaluated by Research
Scotland. The new intervention was more targeted and delivered face to face with
an experienced police officer. This has now been rolled out across Scotland and
was introduced in the North East in 20227. 
3 North East Scotland Road Casualty Reduction Strategy 2017
4 Motorcycle Safety Strategies in North East Scotland. Caroline Hood RGU
5 Rider Refinement North 2022:independent evaluation report, Caroline Hood RGU
6 Review and assessment of pre-driver, TRL, PPR838
7 New Driver Scheme launch
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The RSNES group also shares successes in engineering interventions and best
practice. 
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Local and Regional Policies and Context
At a local level, the key policy documents which are relevant to road safety are: 
• The Local Outcome Improvement Plan V2 (Moray Community Planning
Partnership) September 2021
• Moray Corporate Plan 2024 (Moray Council)
• The Moray Economic Strategy (Moray Council) 
This plan is consistent with the priorities of the Moray 10 year Plan – the Council’s
Local Outcome Improvement Plan V28 through
• Building a better future for our children and young people in Moray by:
promoting and supporting safer environments and communities; and
• Empowering and connecting communities through the Moray Economic
Strategy 20229 by: supporting productivity growth through enhancing critical
infrastructure. 
The Council’s Corporate Plan for 202410 also indicates that it ‘will continue to
provide services which support economic growth and well-being, such as …,
maintaining an efficient road network …. These activities directly support national
objectives.’
In terms of regional policy, Moray is part of HiTrans Regional Transport
Partnership area. This Plan is consistent with the aims and objectives of the
HiTrans Regional Transport Strategy11 draft May 2017 (an updated strategy is
expected), and the second Moray Local Transport Strategy12 which states at Sub-
Objective S2 that we will: 
8 Local Outcome Improvement Plan V2, Moray Community Planning Partnership
9 Moray Economic Strategy 2022
10 Corporate Plan 2024
11 HiTrans Regional Transport Strategy
12 Moray Local Transport Strategy
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Develop solutions to traffic safety and capacity problems within
Moray and work with the Scottish Government, developers and
others to minimise predicted problems.
The speed of traffic through built up areas is a concern raised by many
communities in Moray. However it is on the rural roads outwith built up areas
where speed tends to be a factor in road accidents. Enforcement of traffic speeds
is carried out by Police Scotland and their Moray Local Policing Plan13 supports
the aims of this document through Operation CEDAR. 
Operation CEDaR (Challenge, Educate, Detect and Reduce) is the north road
safety strategy aimed at casualty reduction and improving safety on the roads
within the Police Scotland North Command area (which Moray and North East
local command areas fall under). Operation CEDaR is delivered through local
initiatives which are specifically aligned to the issues identified in each Police
Scotland Division. Where appropriate these initiatives will involve local policing
teams and partner agencies to reduce the number of people killed and seriously
injured in the area and improve the behaviour of drivers of all ages behind the
wheel. Locally Police Scotland partner with DVSA, DVLA and NESCAMP as well
as schools on occasion. 
13 Moray Local Policing Plan 2023-2026
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Accidents in Moray
It is important that any actions arising from this plan are designed to address
issues identified through the consideration of recorded accident data. The
following section investigates the recorded accident data provided to Moray
Council from Police Scotland, seeks to understand the data and identify patterns
and trends.
Accidents and casualties
Police Scotland collect information on all accidents reported to them, either at the
scene of an injury accident or reported by a member of the public after the event.
This information is then analysed by both police officers and roads engineers to
determine locations on the road network which show clusters of accidents;
different types of accidents and groups of road users who may be particularly at
risk.
The number of accidents and casualties vary quite considerably from year to year
as a result of weather and other external factors which can affect the number and
type of journeys made. This can affect the reliability of any conclusions drawn on
one particular year’s data. This is especially true in areas which are largely rural
and dependent on local conditions, as opposed to large urban areas where
journey patterns are fairly stable.
Analysis of accident data is usually carried out over a three or five-year period. 
The following graph (on page 17) shows the trends in reported accidents in Moray
over the period 2004 to 2022. There are a number of points on the graph where
there is a significant increase or decline in the number of reported accidents.
These points have been highlighted and reasons for the anomalies/change given
on the graph.
Additionally, from July 2019 Police Scotland introduced a nationwide accident
and casualty data recording system called CRaSH (Collision Reporting and
Sharing). The way serious casualties are now being recorded is based on specific
injury types and the system then categorised the casualty by killed, seriously or
slightly injured. Before this system was introduced, the classification of the injury
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was assessed by the attending police officer. The same system has been
gradually rolled out across Great Britain and the effect has been that casualties
previously categorised as slight were now being recorded as serious, leading to
an overall increase in the serious injury numbers. The Department for Transport
has subsequently adjusted the originally recorded figures and these are the ones
being used to measure the future targets against. The graph shows the adjusted
trend lines for serious and slight casualties. The 2020 - 22 numbers are not
adjusted as the new system was in place during that period. 
The adjusted trend lines follow the same pattern as that originally recorded, but
are higher for serious casualties and lower for slightly injured. The reduction in
Killed and Seriously injured casualties (KSI) between the two baselines in
Moray is around 9% with the recorded figures. For Scotland this figure is around
37%. The adjustments haven’t been made before 2006, so the adjusted base
for 2004-08 is not available to calculate the reduction. For all casualties in
Moray the reduction is around 57% which compares with around 40% for all
Scotland. 
The Moray data is a very small sample size and is prone to fluctuation. This can
explain some of the variation between Moray and the whole of Scotland. The
following sections seek to explain this in more detail. 
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All data in this plan is quoted for a 5 year period 2018-2022 to allow comparison
of 5 year data with national information in Reported Road Casualties Scotland.14
The COVID19 pandemic has skewed these figures due to restrictions on travel
and movement during both 2020 and 2021. Future years’ figures will be more
representative when compared to the baseline of 2014 to 2018 (set in the Road
Safety Framework to 2030), although it should be noted that overall travel
patterns are changing with the move to more hybrid working and online shopping.
Scottish Government are also seeking to reduce vehicle-kilometres by 20% by
2030. Measures to support that aim will be likely to have a further impact on travel
behaviours. Therefore travel patterns may never wholly revert back to travel
patterns observed prior to the pandemic.
Casualties in Built up versus Non-built up areas
Built up roads are defined as those having a 40mph speed limit or less and non-
built up are national speed limit or 50mph. The pattern of where casualties are
injured on the road network is very different in Moray when compared to Scotland
as a whole. Between 2014 and 2018 (Road Safety Framework to 2030 baseline)
over 70% of Moray casualties were injured in accidents occurring on rural roads,
compared to just a third of casualties for Scotland as a whole, as illustrated in the
diagrams below: 
14 Reported Road Casualties Scotland
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15 
15 MAST Online Road Safety Analysis
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As the data for Scotland as a whole shows higher accident rates in built up areas
than on rural roads, Scottish Government is developing a National Strategy for
20mph, which would see the current limit of 30mph on most urban roads, being
reduced to 20mph as standard to support reduction in the number and severity
of accidents in built up areas.. 
Research carried out in the 80s, 90s and 00s identified fatality risk for pedestrians
being struck by passenger vehicles travelling at certain speeds.16 Results varied
markedly but the general conclusion was that there is a low gradual risk for impact
speeds up to 20mph, thereafter some studies suggest that this low risk rises as
speeds increase towards 30mph and in some locations/instances the risk rises
more steeply. This suggests that there are many other factors involved in
accidents on built up roads rather than just speed. 
Within Moray around 12% of accidents in built up areas have identified speed as
a contributory factor. Whereas on rural roads, speed is a factor in around 30% of
reported injury accidents.
This indicates that with 70% of injury accidents occurring on rural roads in Moray,
and 30% of those accidents having speed as a contributing factor, accident
reduction in Moray should be focussed on rural roads rather than in built up areas. 
Around one third of Moray residents injured in Scotland are injured on a Trunk 
16 The role of speed in the frequency and severity of Road Traffic Collisions, NI Assembly
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Road. Within Moray itself one third of those injured are also injured on a Trunk
Road. This indicates that the partnership approach with Transport Scotland and
Amey is crucial to assisting in reducing accidents and their severity in Moray. 
Casualties by home residence
Across Scotland during the baseline period (2014-18) only 1% of people injured
in road accidents in Scotland, were injured in Moray. Moray has approximately
2.9% of the Scottish Road network17 and 2% of the Scottish population.18 This
shows that the relative risk of being involved in a crash in Moray is between half
and a third of the rest of Scotland.
The chart below indicates where those injured in Moray come from. 
Source: MAST by Agylisis (2014-18)   
17 Scottish Transport Statistics 2022 Table 4.2
18 Scotland’s Census 2022 – Rounded population estimates
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Risk by road type
The table below shows the relative risk for injury accidents when travelling on ‘A’
class roads within Moray for the Road Safety Framework to 2030 base line period
of 2014 to 2018. This risk is calculated separately for urban and rural sections of
road and is related to the length of the relevant section of road to give a
comparable rate per kilometre.
Baseline Period 2014-2018 (totals)
Road
No
Urban
Casualties
Rural
Casualties
Total
casualties
Urban length
(km)
Rural length
(km)
Urban rate
(cas/km/pa)
Rural rate
(cas/km/pa)
A95 0 10 10 0.5 13.7 0.00 0.15
A95(T) 4 30 34 2.8 34.7 0.28 0.17
A96(T) 34 85 119 8.7 54.5 0.78 0.31
A98 1 21 22 1.6 19.3 0.12 0.22
A920 1 0 1 0.0 6.1 0.00 0.00
A939 0 7 7 0.9 17.2 0.00 0.08
A940 0 2 2 2.2 20.9 0.00 0.02
A941 15 59 74 10.3 47.0 0.29 0.25
A942 4 1 5 6.1 5.0 0.13 0.04
A990 1 0 1 3.0 2.8 0.07 0.00
B roads 16 98 114 43.7 254.2 0.07 0.08
All
other
roads
72 33 105 374.7 1128.7 0.04 0.01
All
Roads 148 346 494 454.5 1604.1 0.07 0.04 
The Scottish rate for all rural ‘A’ roads is 0.27 casualties/km per annum. The A96
then A941 have the highest per kilometre rates in Moray. The A96 at 0.31
casualties/km per annum is higher than the Scottish rate for all A roads, with the
A941 is a little below the Scottish rate. The next A class road, the A98, has a rate
well below that of the A96, A941 and the overall rates for A class roads in
Scotland.
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Considering where the driver associated with a casualty lives on each route
provides further insight into accident trends and patterns. Since 2014 (to 2021),
for injury accidents on the A95 and A96, 55% involve Moray drivers. For the A98,
this figure increases to 73% of drivers involved in an injury accident living  in
Moray and for the A941 the proportion increases again to 80% of drivers. Across
the ‘A’ road network the average is 65% drivers residing in Moray followed by
18% from Aberdeen, Aberdeenshire and Highland and 13% either unknown or
outwith Scotland. 
Source: MAST by Agylisis (2014-18) 
This indicates that the injury accidents reported on rural roads such as the A98
and A941 where there are higher rates per kilometre per annum are more likely
to involve drivers who are local residents and should be familiar with the road
network.
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Casualties by road user type
Looking at specific categories of road users, when compared to Scotland, the
relative risk of being injured in an accident in Moray is much lower than the whole
of Scotland as shown in the diagram below. 
Source: MAST Scotland database, Road Safety Analysis Ltd. 19 
Comparing Moray with similar authorities, (Aberdeenshire, Stirling and the
Borders) with respect to rurality, proportion of rural roads in their network, and
population profile and population density shows similar accident and casualty
trends to Moray.
It is therefore important to consider the relative risk, rurality and specific
characteristics of injury accidents in Moray when developing interventions, as
opposed to following the Scotland wide approach.
Age (Pre, young and older drivers)
Moray’s population has remained virtually unchanged in the past 10 years 20 and
currently (2022) stands at 93,400. Population estimates for Scotland indicate that 
19 MAST Online Road Safety Analysis
20 Scotland's Census 2022 - Rounded population estimates
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the population is aging with over 20% being over 65 years old compared to 16.1%
10 years ago and just 12.1% 50 years ago. In Moray the figure is about 23%.
The aging population presents its own challenges with respect to road safety.
Driver training for those who have been driving for some time, is difficult to ‘sell’,
and issues such as eyesight and prescription drugs require careful handling. Joint
working with the NHS and other parties is required to persuade individuals to be
aware of these issues.
The younger population, under 25, is around 23,900 or around 25% of the
population. This is a reduction from 29% in 2011.
Schools, and their role in providing Road Safety advice is crucial to pre drivers
and young people in general. Curriculum based material is available nationally
from Road Safety Scotland. Joint working with Education and Lifelong Learning
to develop Road Safety Champions who can share and provide advice on this
material to their fellow pupils is one way to disseminate road safety messages to
this age group.
Accidents involving young drivers has reduced by over 80% in the past 15 years.
There are many factors which have contributed to this including the rising cost of
insurance and fuel along with interventions previously carried out by the Police
before 2013. In the years during COVID19 the reduction is 50% over the 2014-
18 average. The introduction of free bus travel to under 22 year olds in January
2022 may also be a factor in this reduction. 
The Cost of Accidents
The UK Government produces figures each year which reflects on average how
much an accident costs to society. It takes into account the costs of the police
and other emergency services, medical costs, lost output (e.g. loss of earning
capacity), damage to property, and a sum which reflects the effects of pain, grief,
suffering etc. i.e. the emotional impact of an accident. Average costs are shown
below for Scotland21, according to the severity of the injury. 
21 Reported Road Casualties Scotland 2021, Table 10
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Severity of Accident Cost
Fatal £ 2,309,788
Serious £ 273,510
Slight £ 27,985 
Over the past five years, the cost of accidents in Moray amounted to some £15
million. 
The Council is committed to improving road safety and has approved capital
funding of £188,000 for 2023/24. On-going Capital funding will be required to
ensure that any required engineering improvements identified through the life of
the Road Safety Plan can be developed and delivered. Transport Scotland,
through Amey, has also programmed engineering improvements for the two
Trunk Roads in Moray namely A96 Inverness to Aberdeen road and A95
Aviemore to Keith road. This expenditure has been complemented both by the
financial support and manpower resources of the police, fire, ambulance, health
board and other council services in education, enforcement and encouragement.
The Scottish Government has recently introduced a new Road Safety
Improvement Fund as part of the funding to support the Road Safety Framework.
Funding has been secured for 2023/24 for two improvement schemes in Moray;
the first for works at the A940 at Glenernie and the second to improve road
markings (lining) and cats eye upgrades on A940 and A941. 
Furthermore, progress on improving the cycle and walking network has been
given a major boost by the increases in Cycling, Walking and Safer Routes
funding which has been received for Scottish Government as a ring fenced grant
annually since 2001. Although primarily for improvements to the active travel
network, these have a positive road safety benefit for these vulnerable road users
and help pedestrians, cyclists and wheelers to feel more confident when using
the road network.  
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Issues and Actions
The aim of this plan is to contribute to the delivery of Scotland’s Road
Safety Framework to 2030 with the vision ‘For Scotland to have the best
road safety performance in the world22.
This is to be achieved through: 
• Safe Road Use
• Safe Vehicles
• Safe Speeds
• Safe Roads and Roadsides
• Post-Crash Response 
Road safety is defined as any policy, project, plan, programme or strategy which
aims to reduce the number and severity of road traffic casualties or reduces road
danger with better education or through the design, building, operation or use of
the road system. 
There are a number of measures which can be used to help reduce the number
and severity of road accidents. These fall into three broad categories:
• Education
• Engineering
• Enforcement
The behaviour of road users is influenced by educational methods and
engineering measures. Enforcement of the traffic legislation is necessary when
that behaviour is irresponsible or dangerous. However, the aim of the education,
engineering and enforcement measures are to encourage everybody to adopt
safer practices when on their daily journeys. 
22 Scotland's Road  Safety  Framework to 2030
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Issues
The main issues identified from the data are:
• The prevalence of accidents on rural roads;
• Ongoing maintenance of the Road network;
• Driver behaviour and speed management;
• Ongoing education of road users; and
• Provision of cycle and walking infrastructure. 
The following sections describe the interventions which are currently being
pursued by the key public bodies involved in the development of this plan to
address the above issues. The interventions are grouped under the Safe System
areas set out in Strategic Framework and Partnerships section of this Plan.
Safe Road Use
This is achieved from road users who decide the most sustainable way to travel,
know and comply with road rules and take responsibility for the safety of
themselves and others, especially the vulnerable.
Safe road users are competent at all levels, including: paying full attention to the
road ahead and the task in hand; adapting to the conditions (weather, the
presence of other users, etc.); travelling at lower speeds; not driving while
impaired through drink, drugs (including medicines) or fatigue; not being
distracted by in-vehicle technology (mobile phones, entertainment systems, ‘sat
navs’, etc.); and giving sufficient room to all other road users, no matter what their
mode of travel.
Throughout Moray we are continuing to improve the active travel network to help
users make sustainable choices. Many of these improvements are funded from
external grants for example Sustrans, Places for Everyone and the annual ring-
fenced grant from Scottish Government for Cycling, Walking and Safer Routes
projects. 
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There are various local and national campaigns on safe road use such as the
National ‘Think! Campaigns covering areas such as The Highway Code, mobile
phone use, Seat belts, speeding on rural roads, vehicle safety checks,
motorcycling, country road driving, drug and drink driving, cycle safety and
education and games for primary aged children.23
In Scotland, a similar organisation, Road Safety Scotland was launched in 1985
as The Scottish Road Safety Campaign, becoming Road Safety Scotland in 2005.
Road Safety Scotland (RSS) is part of Transport Scotland, the Scottish
Government’s transport agency.24.
RSS’s work is based on research and evaluations of previous campaigns and
road safety initiatives. The most recent campaigns have been around: 
• Use of Seatbelts;
• Young Driver Campaigns;
• Driver Fatigue:
• Road User Advice;
• Children and Educators:
• Cycling:
• Horses and Road Safety; and 
• In Car Child Safety.
Seatbelts
It only takes seconds to put on a seatbelt. But it’s a simple act that could save
your life. On average 13%25 of those killed on roads in Scotland over the last five
years were not wearing a seatbelt. Seat belt wearing became compulsory in
1983. 
23 Think campaign website https://www.think.gov.uk/ 
24 Road Safety Scotland website https://roadsafety.scot/campaigns/ 
25 PACTS: Seat Belts – time for action
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Young Drivers Campaigns
Young drivers have been identified nationally as being over represented in the
casualty statistics. In the early 2000’s Moray and across the north east had a real
issue with young drivers crashing. This was tackled by campaigns with the Police
and education events such as Safe Drive, Stay Alive. However, numbers have
reduced considerably and are no longer the major issue they once were. This
should not lead to complacency and Road Safety Scotland’s (RSS) campaigns
should continue to be supported. The RSS ‘Drive like Gran’s in the Car’
campaigns cover subjects such as
• Drink Driving
• Drug Driving
• Speeding 
• Distraction
• Vulnerable road users (motorcyclists, cyclists, pedestrians and horse
riders)
The campaign concentrates on messages such as “Crash and you’ll no be able
to come round for my mince and tatties!”26 and uses humour to get the road safety
messages across.
Driver Fatigue
Driver fatigue causes hundreds of road accidents each year. And these accidents
are roughly 50% more likely27 to result in death or serious injury. When drivers
fall asleep, the police find no signs of braking, or any avoiding actions, so there
is a tendency to result in higher-speed collisions. This is a particular concern for
Moray with long distances to travel to the central belt for work and deliveries. 
Whilst, it has been difficult to identify this specific issue in the accident statistics 
26 Young drivers drink driving campaign
27 Driver fatigue campaign
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to date, driver fatigue .will remain a focus when analysing data and supporting
any national campaigns. 
Road User Advice
Road Safety Scotland provides advice to drivers, by life stage, behaviour and for
other road users and for visitors on driving in Scotland. 28 Older Drivers are of
particular concern across Scotland. In Moray, however, the numbers are low and
the older population is not over represented in the accident data. There are some
concerns about people driving longer than they should, particularly with poor and
failing eyesight. This may be a result of the rurality of Moray and having limited
public transport alternatives. 
Children and Educators
Road Safety Scotland aims to provide road safety learning at every level,
engaging children and young people. RSS Children and Educators. The learning
resources link to the seven principles of Curriculum for Excellence. 
Cycling
Most accidents to cyclists in Scotland happen on built up roads. Cycling Scotland
provides training and information to help improve cyclists’ safety. In Moray,
Primary Schools participate in Bikeability training for pupils and the Moray Bothy
project provides road safety advice for new and returning cyclists, including led
rides to help build confidence.
Horses and Road Safety
Working with the equestrian community can to encourage a high level of safety
awareness among riders. The British Horse Society (BHS) has been awarded the
Prince Michael International Road Safety Award for its contribution to Road
Safety. Visit Equestrians on the road. The BHS have undertaken joint road safety
campaigns with local authorities in England and it is understood that they are 
28 RSS Road User Advice
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seeking to engage with Transport Scotland to undertake similar joint road safety
campaigns in Scotland.
In-Car Child Safety 
RSS is a key partner in the Scottish In-Car Child Safety Campaign. This is an
ongoing campaign aimed at improving the safety of all children in vehicles. A
major element of this is the provision of advice and information on the correct
fitting of child car seats visit Good Egg Car Safety or Carrying Children Safely. In
Moray partnering with Good Egg through their training programme will enable the
local delivery of this advice. Specific training provided by Good Egg will be sought
for the Road Safety Officer. 
Safe Vehicles
Well-maintained vehicles reduce the risk of collisions and, in the event of a
collision, reduce the harm to road users, including pedestrians, cyclists, horse
riders, motorcyclists and vehicle occupants. 
Police Scotland target drivers of vehicles with expired MoT certificates as these
vehicles are more likely to be less well maintained. Under inflated tyres can
contribute to both vehicle and cycle accidents.
In vehicle safety has been improving steadily with the introduction of seatbelts,
airbags, lane control and other vehicle control measures. 
As mentioned above the correct fitting of child car seats is crucial to improving in
vehicle safety. The Euro NCAP safety ratings can inform potential owners of the
safety features in vehicles. 
Safe Speeds
The aim is that road users understand and travel at appropriate speeds to the
conditions and within the speed limits. 
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Traffic survey information is collected regularly and used to respond to complaints
about speeding and, where appropriate, this data is shared with Police Scotland.
Traffic speed and volume data is also collected before and after proposed
schemes and developments to inform the decision making process and reflect on
a scheme’s outcomes. It also helps determine the appropriate speed limits to post
for built up areas, in particular where new developments are taking place at the
edge of settlements. Existing speed limits are regularly reviewed for new
developments or as the result of concerns raised by communities. 
The key factors that should be taken into account in any decisions on local speed
limits are:
• history of collisions;
• road geometry and engineering;
• road function;
• composition of road users (including existing and potential levels of
vulnerable road users);
• existing traffic speeds; and
• roadside environment.
Enforcement of posted speed limits is carried out by both Police Scotland and
Safety Cameras Scotland. Safety Cameras Scotland is the collective name for
the North, East and West Safety Camera Units. This is an arms-length
organisation governed by Transport Scotland through the Scottish Safety
Camera Programme, but working within Police Scotland.
The site selection process for the Safety Camera unit is based on accidents and
where they happen. The process for determining new sites is shown below is
described in Appendix 1. 
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Safe Roads and Roadsides
This aim of the Safe System seeks to provide roads that are self-explaining in
that their design encourages safe and sustainable travel so that they are
predictable and forgiving of errors.
With the majority of accidents resulting in people being injured happening on rural
roads in Moray, this is where the majority of interventions have taken place in the
past, including Route Accident Reduction Plans (RARPs). The most recent of
these was on the B9008 and involved review of the road markings, in some
places removing the centreline and replacing with edge lines to reduce verge
overrun. This was done at locations where the road width is less than 5.5m wide
and hence too narrow to allow 2 vehicles to pass safely. Signing was also
reviewed to give a consistent message and highlight features such as narrow
bridges and bends where accidents have happened. This type of work has been
carried out on the A roads in the past, but requires ongoing maintenance to keep
the messages clear and consistent. 
Adequate and appropriate road maintenance is crucial to achieving safe roads
and roadsides. Potholes, poor conditions of the surface, low skid resistance,
overgrown verges, poor drainage, lack of visibility, no footway or cycle route, worn
road markings, unclear signing and trees can all contribute to crashes happening
on rural roads, before driver error or inappropriate speed comes into the situation. 
Recently, funding from the Road Safety Improvement Fund (RSIF) has become
available for specific schemes. Improving the road markings (centreline and edge
lines) and cats’ eyes on both the A941 and A940 were the main schemes to
receive funding from the RSIF in 2023/24, which works undertaken which will
have a direct impact on providing safer roads and roadsides. 
Through the Moray Active Travel Strategy consultations and focus groups a clear
desire was identified for inter-settlement cycle infrastructure and this will
contribute to both the road safety and climate change agenda by providing
sustainable commuter routes. However, such schemes have high costs and often
require third party land. The Council will continue to support community groups
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with this aim and may seek specific funding to support their delivery, where there
is a clear positive Business Case.
Transport Scotland is responsible for the trunk roads within Moray. These are the
A96 and the A95 from Keith to the Highland Council boundary. 
Transport Scotland, through its Operating Companies, undertakes an annual
review of collisions on the trunk road network to identify cluster sites, or routes
with recorded collisions that may be worthwhile of further investigation. The
screening process, together with a detailed understanding of collision trends
around the network, results in a prioritised programme of sites that are
investigated further. This evidence-led approach ensures that resources can be
targeted at locations where the greatest potential for casualty reduction is
available. This approach has been successful in reducing casualties across
Scotland’s trunk road network.
Amey (Trunk Road Operating Company for the North East) apply the Safe
System approach as described in Scotland’s Road Safety Framework to 2030 to
deliver an evidence-led casualty reduction programme to work towards meeting
the Scottish Government’s casualty reduction interim targets to 2030.
Carrying out Safety Audits on new schemes can identify issues which may cause
accidents and seek to reduce them before the scheme is fully operational. Safety
Audits will be undertaken on significant schemes promoted by the council. 
Developers are required to provide and act on Safety Audits for their works on
the public road and where they are creating new sections of public road. These
will continue to be a requirement to support Planning Applications and
applications for Road Construction Consent. 
Post-Crash Response
When a crash happens the response ranges from no emergency services
attending to all of them being present and can include the air ambulance. 
It is vital to work with the emergency services and the National Health Service
(NHS) to enable the best possible response to collisions, ensure victims are
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effectively cared for, and facilitate meaningful investigations into the causes and
potential solutions for the future. Health outcomes for victims rely on the ability of
the system to quickly locate and provide emergency first responder care, in order
to stabilise victims and transport them to hospital for further specialist treatment.
Each of the services have a local service plan:
• Police Scotland through their Moray Local Policing Plan29 
• Scottish Fire and rescue Service through their Local Fire and Rescue Plan
• Scottish Ambulance Service in Our 2030 strategy with respect to Major
incidents30
• NHS Grampian
These services and the aftercare are crucial to the outcome of any casualties. 
29 Moray Local Policing Plan 2023-2026
30 Scottish Ambulance Service - Our 2030 Strategy
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What we are going to do
Although the number of people injured on Moray’s roads is low, there is no room
for complacency. There are ongoing concerns such as the aging population and
the ongoing climate crisis which is encouraging the wider use of sustainable
forms of travel such as walking and cycling. Rural roads remain a concern as this
is where the majority of crashes happen in Moray and in particular on the Trunk
Road network.
Journeys to school by sustainable means have remained broadly unchanged at
around 50%. However, the numbers of pupils being driven has gradually crept up
over the years along with those being driven part of their journeys at the expense
of travel by bus. This could be a reflection of ‘parental choice’ with School buses
not being available to out of zone pupils. 
Actions
The following key actions have been identified based on the analysis of the
accident data, the aims of the Road Safety Framework to 2030 and the joint
working partnerships within the RSNES group.
Action Target Date Who Safe
System
Contribute to the North East
Scotland Road Safety Strategy 
tbc All  Safe Road
Use; Safe
Speeds;
Safe Roads
and
Roadsides,
Post-crash
response
Investigate options for a Moray
Road Safety Group and better
connections with the Trunk
Road operating company 
Moray Council
Transportation
and Transport
Scotland/Amey
Safe Road
Use; Safe
Speeds;
Safe Roads
and
Roadsides,
Post-crash
response
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Continue to carry out road
accident analysis on an annual
basis and otherwise as identified
and to use this information to
carry out effective and
appropriate AIP engineering
measures.
On-going
throughout
the term of
the Plan to
2030.
Moray Council
Transportation,
Amey./
Transport
Scotland
Safe Roads
and
Roadsides
Support the North Safety
Camera Unit to identify sites for
enforcement and to make
representations to the Scottish
Safety Camera Programme
Office to consider appropriate
criteria for speed camera sites.
On-going
throughout
the term of
the Plan to
2030.
Police
Scotland,
Moray Council
Transportation,
Amey /
Transport
Scotland
Safe
Speeds
To continue to support Road
Safety Scotland
On-going
throughout
the term of
the Plan to
2030.
Moray Council
Transportation,
Police
Scotland,
Transport
Scotland
Safe Road
Use
Support Police Scotland with
their Motorcycle operation in a
bid to reduce accidents
On-going
throughout
the term of
the Plan to
2030.
All and
involving this
road user
group
Safe Road
Use; Safe
Speeds
Concentrate resources on
reducing the number and
severity rural accidents,
particularly those associated
with speed.
On-going
throughout
the term of
the Plan to
2030.
All  Safe Roads
and
Roadsides
Review young and pre-driver
interventions, e.g. Police
Scotland New Driver Scheme;
and monitor the effectiveness.
By 2025 All Safe Road
Use; Safe
Speeds
Investigate proposals for local /
school Road Safety Champions
By 2025 Council Safe Road
Use
Review how best to deliver road
safety advice and information
By 2024 Council, Safe Road
Use
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Support national campaigns On-going
throughout
the term of
the Plan to
2030.
All Safe Road
Use
Police Scotland to continue to
take a ‘hard line’ approach to
young drivers involved in risky
or antisocial behaviour
On-going
throughout
the term of
the Plan to
2030.
Police
Scotland
Safe Road
Use
Seek to develop Community
Council understanding of
accident risks and traffic
speeds, and have ‘Champions’
who can assist with
disseminating of Road Safety
campaigns and information
2024 All Safe Road
Use
Continue to seek funding to
construct off road cycle tracks to
provide segregation for
vulnerable road users
On-going
throughout
the term of
the Plan to
2030.
Roads Safe Roads
and
Roadsides
Investigate options for the
delivery of adult and secondary
school cycle training
2025 Council Safe Road
Use 
A mid-term review of progress towards the Road Safety Framework to 2030
targets and the above actions will be undertaken during 2027. This date has
been chosen as by then there will be 3 to 5 years of accident data available
which have not been impacted by the changes in travel behaviours by the
Covid-19 pandemic. 
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Future Targets
In 2040 the Scottish Government is due to set new targets and through the North
East Scotland Road Casualty Reduction groups, council officers will seek to
inform and influence these new targets.
Once the new Road Safety Framework to 2040 has been published, an updated  
Road Safety Plan will be produced in 2031/32 to coincide with any new targets. 
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Glossary of Terms
AIP - Accident investigation and prevention
Fatal casualty – a casualty who dies within 30 days of an injury being sustained
Fatal accident – an accident where at least one casualty is fatally injured
Serious casualty – a casualty who requires an overnight hospital stay or has a
major bone fracture
Serious accident – an accident where at least one casualty is seriously injured
Slight casualty – a casualty who sustains minor injuries or bone fractures, not
requiring an overnight hospital stay.
Slight accident – an accident where at least one casualty is slightly injured
KSI – Killed or seriously injured
AA – Automobile Association
DSA – Driving Standards Agency
NESCamp – North East Safety Camera Partnership
HiTrans – Highlands and Islands Regional Transport Partnership
NESTRANS - North East Scotland Regional Transport Partnership 
RSS – Road Safety Scotland
ACPO(S) – Association of Chief Police Officers in Scotland
ORR - Occupational Road Risk  
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Organisations Involved
Moray Council, Transportation Service, Traffic and Public Transport Sections
Moray Council, Education Service
Moray Council, Community Safety
Police Scotland
•  Aberdeen and North East Division Community Safety
• Road Policing Division
• North Safety Camera Unit
NHS Grampian
Scottish Fire and Rescue Service
Scottish Ambulance Service
Transport Scotland
Amey Limited, Trunk Road operating company 
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Appendix 1
Safety Cameras Scotland – Site selection process. 
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Through targeted camera enforcement and improving driver behaviour the aim
of Safety Cameras Scotland is to reduce the number of casualties on Scotland's
roads. This means the cameras are sited in the areas most in need in terms of
road casualty reduction, and deployed primarily where they will have the
greatest casualty and collision reduction potential.
Criteria for enforcement locations are set out in the Scottish Safety Camera
Programme Handbook and include:
• a history of injury collisions - have people been injured on this road and
how severely?
• speed profile - is there a problem with speed on this road?
• agreement from partners - do Police Scotland and the Roads Authority
agree that a safety camera is the right solution?
• enforcement strategy - what will be the best type of camera for this
location?
• site review - an annual review - is this camera reducing injury collisions?
Whilst regular enforcement locations follow the process above, in order to meet
demands the programme is able to offer short term and flexible deployment
locations that should be utilised where and when appropriate.
• Short Term Deployments - To improve operational effectiveness and
deployment flexibility, there will be occasions when short-term mobile
enforcement deployments are required. The Programme therefore
includes flexibility to reallocate provision in response to emerging issues
or one-off/short-term events where the expected change in traffic
behaviour has raised road safety concerns from stakeholders. Any
deployments of this manner are limited to a maximum period of 1 month.
• Flexible Deployments - A number of enforcement hours will be available
for deployments in support of improving driver behaviour and speed limit
compliance in high footfall areas where active travel could be encouraged
by lower speeds while reducing risk exposure. Flexible deployments
should be based around a clearly evidenced prioritisation considering
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speed and risk factors and will require a recent speed survey to evidence
the issue of speed.
Police Scotland Road Policing have responsibility for enforcement on fast roads.
We use Randomised Scheduled Enforcement Strategy (RSE)
This strategy has been utilised worldwide and targets high-risk locations at
specific times to create an image of police omnipresence. By applying this
concept, motorists will become increasingly uncertain and/or unable to predict the
location of enforcement activity, therefore positively influencing driver behaviour.
The locations and days identified each month are supported by analytical data
from collisions for that month in the previous 5 years.
Local Policing Teams have the ability to enforce speed limits within the built up
area. 
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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: 
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 actions from the Road Safety Plan to 2030 include providing infrastructure for
vulnerable road users, which include children and persons with impaired
mobility/senses.  The provision of such infrastructure will be to the benefit of these
groups. 
Item 6
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There would be no adverse socio-economic impact from the actions within the plan
asprovision of active travel infrastructure will also support travel for low income
groups who often do not have access to a vehicle.   
Likewise the Plan does not have any implications on Human Rights or the Rights of
Children. 
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 contract  Diane Anderson
Other people involved in the screening
(this may be council staff, partners 
or others i.e. contractor or community) 
Elaine Penny
Date 16 October 2023 
STAGE 2: INTEGRATED IMPACT ASSESSMENT 
Brief description of the affected service
1. Describe what the service does: 
The Transportation Service is responsible for Road Safety. 
Road Safety is a statutory duty and the Council is obliged under the Road Traffic Act
1988 (Section 39) to prepare and carry out a programme of measures designed to
promote road safety and prevent accidents. It is further recommended that each
Local Authority produce a Road Safety Plan which sets out the strategy for improving
safety and identifies clear targets. In this instance the targets are informed by the
Scottish Government Road Safety Framework to 2030. 
This is the seventh Road Safety Plan for Moray. 
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2. Who are your main stakeholders? 
Road users, by all modes of transport, across Moray.
Road safety partners - Police Scotland, Fire and Rescue Service, NHS Grampian,
Transport Scotland 
3. What changes as a result of the proposals? Is the service reduced or removed? 
There are no changes to the service resulting from the new Road Safety Plan. 
4. How will this affect your customers? 
As there is no change to service, there will be no impact on customers. 
5. Impact on staff providing the service – None duties with respect to Road Safety remain
unchanged. 
6. Please indicate if these apply to any of the protected characteristics
Protected groups Potential impacts and considerations
Race  
Disability  An action of plan is to provide more active travel
infrastructure to support movement by walking,
wheeling and cycling. The needs of mobility and
visually impaired road users will be taken into
account in the design of this infrastructure. 
Carers (for elderly, disabled or
minors) 
Sex 
Pregnancy and maternity (including
breastfeeding) 
Sexual orientation 
Age (include children, young
people, midlife and older people)
An action of plan is to provide more active travel
infrastructure to support movement by walking,
wheeling and cycling. The needs of road user,
(children, young people, midlife and older people)
will be taken into account in the design of this
infrastructure. 
Religion, and or belief 
Gender reassignment 
Inequalities arising from socio-
economic differences
An action of plan is to provide more active travel
infrastructure to support movement by walking,
wheeling and cycling. This is a benefit as persons
with a low income are less likely to have access to a
vehicle. 
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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 
Article 6: Right to a fair trial 
Article 8: Right to respect for
private and family life,
correspondence and the home 
Article 10: Freedom of expression 
Article 11: Freedom of assembly
and association 
Article 12: Right to marry 
Article 14: Prohibition of
discrimination (in relation to the
convention rights) 
Article 1 of Protocol 1: Protection
of property 
Article 2 of Protocol 1: Right to
education 
Article 3 of Protocol 1: Right to free
elections by secret ballot 
Children’s Rights and Wellbeing 
Relevant articles – UNCRC 
Article 2 – Non discrimination 
Article 12 – Respect of the views of the
child 
Article 3.1 – Best interest of the child 
Article 6.2 – Right to survival and
development 
7. Evidence. What information have you used to make your assessment? 
Performance data 
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Internal
consultation
This is the seventh Road Safety Plan for Moray. Internal
consultation and consultation with key stakeholders/partners
(e.g. Police Scotland) has been part of the development of this
plan. 
Consultation with
affected groups 
No direct consultation has been undertaken. However the
provision of active travel infrastructure is part of the Active
Travel Strategy which has been the subject of public and
stakeholder consultation.
Local statistics Accident data
National
statistics
Accident data
Other 
8. Evidence gaps 
Do you need additional information in order to complete the information in the previous
questions? 
No 
9. Mitigating action 
Can the impact of the proposed policy/activity be mitigated?  Please explain 
Proposed active travel infrastructure will support travel by foot, cycle, wheeling by
vulnerable road users including mobility/visually impaired persons, children and young
people, midlife and older people. 
The design of this infrastructure will take into consideration the needs of these groups. 
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?   
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SECTION 3 CONCLUDING THE IIA 
Concluding the IIA 
1. No potential negative impacts on any of the protected groups were
found.
X
2. Some potential negative impacts have been identified.
The impacts relate to: 
Reducing discrimination, harassment, victimisation or other conduct
prohibited under the Equality Act 2010 
Promoting equality of opportunity 
Fostering good relations 
3. The proposals interfere with human rights and/or the rights of the
child 
4. Negative impacts can be mitigated the proposals as outlined in
question 8 
5. The negative impacts cannot be fully mitigated but are justified as
outlined in question 9. 
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:
An action in the Road Safety is to provide active travel infrastructure which would be
utilised by users with protected characteristics (Disability and Age). An individual
Equalities Impact Assessment will be undertaken as individual schemes are developed to
seek to maximise the benefits of each scheme for these user groups. 
Date of Decision: 16 October 2023 
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Sign off and authorisation: 
Service Transportation
Department Economic and Commercial Services
Policy/activity subject to IIA 
We have completed the integrated impact
assessment for this policy/activity. 
Name: Diane Anderson
Position: Senior Engineer Transportation 
Date: 16 October 2023
Authorisation by head of service  Name: Nicola Moss
Position: Head of Environmental and
Commercial Services
Date:16 October 2023
Permission to publish on website - 
Please return this form to the Equal Opportunities Officer, Chief Executive’s Office. 
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Page 1 of 5
A98 Fochabers to Aberdeenshire boundary 
Review of Reported Injury Accidents 2013 to 2022 
Concerns have been raised with regard to the number of accidents occurring on
the A98 in recent years and a commitment was made to undertake a review of
the accidents to establish if there were any trends or patterns which would
inform any requirement for mitigation measures. 
The A98 is a strategic route starting at the A96 in Fochabers, passing through
an area of forestry commission land (Whiteash Hill Wood) and along the coastal
plain to Cullen and the Moray boundary beyond. The road is a strategic route
which carries both local and longer distance traffic, including commercial
vehicles accessing harbours, distilleries and agriculture. 
Traffic Flows and Vehicle Speeds 
There are two permanent traffic counters sited on the A98; one in Arradoul and
the other just to the east of B9018 junction between Cullen and the Moray
boundary. These counters provide information on traffic volumes, the types of
vehicles on the road and vehicle speeds. The following table summarises
observed traffic counts and speed data from these two sites. 
A98 Permanent
Count Sites 
AADT*
(vehicles) 
Average
Speed (mph)
85th Percentile
Speed (mph)
Arradoul (50mph) 9061 EB 46.9 52.6
WB 48.5 54.7
East of B9018 4368 EB 51.1 59.1
WB 51.4 59.3
* Annual Average Daily Traffic 2022
EB = Eastbound
WB - Westbound 
Speed Limits 
Speed limits on the public road network are informed by the roadside
environment and the level of ‘activity’ adjacent to the public road. The A98 is a
former Trunk Road which has been the subject of improvements over the years
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Page 2 of 5
to improve its alignment. The road is generally 7 metres wide with ample
roadside verges. However on certain sections of the road there are frequent
side road junctions (mainly private roads/tracks) and properties with direct
accesses onto the road. 
In 2009/2010 officers undertook speed limit reviews for all ‘A’ and ‘B’ Class
Roads in Moray using the Scottish Government assessment criteria set out in
their documents ‘Setting Local Speed Limits’ as described in the report to this
committee on 13 October 2009 (Para 9 of the minutes refer). 
The assessment included consideration of the speed limit in the rural settlement
of Arradoul and found that when assessed against the criteria, the national
speed limit could be considered. However as average (mean) speeds were
between 41mph and 50mph, the existing 50mph speed limit, which has been in
place since June 2001, was retained. 
Reported Injury Accidents 
Accidents are rare, random, multi-factor events always preceded by a situation
in which one or more road users have failed to cope with their environment.
When compared to Scotland as a whole, accident rates on all roads in Moray
are low (see draft Road Safety Plan to 2030 Table on page 22). 
When the numbers of reported injury accidents are low, the lack of statistical
evidence means that it is difficult, if not impossible, to draw meaningful
conclusions. Nevertheless, the draft Road Safety Plan highlights that 73% of
drivers involved in reported injury accidents on the A98 reside in Moray, which
indicates that drivers involved in accidents are likely to be familiar with the road. 
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Page 3 of 5
Over the ten year period 2013 to 2022 there have been 33 injury accidents
reported on the A98, resulting in 63 people being injured. Over the early years
of this period a further 23 damage only accidents have been recorded. Damage
only accidents are no longer recorded by the police and therefore the
information is only useful to augment the injury accidents. 
Recorded accidents on A98 Fochabers to Aberdeenshire 2013-2022 
Fatal Serious Slight Damage Only Grand Total
2013  3 3 16 22
2014  3 2 3 8
2015  1 4 2 7
2016 1 1 1 1 4
2017  1 1 1 3
2018 1    1
2019 1 3 2  6
2020  1   1
2021   1  1
2022 1 1 1  3
Grand Total 4 14 15 23 56 
Recorded casualties on A98 Fochabers to Aberdeenshire 2013-2022 
Fatal Serious Slight Grand Total
2013  5 6 11
2014  3 4 7
2015  1 4 5
2016 1 3 1 5
2017  1 3 4
2018 1   1
2019 1 9 10 20
2020  2 4 6
2021   1 1
2022 1 1 1 3
Grand Total 4 25 34 63 
Of the 4 accidents involving someone being killed one was a single vehicle, one
involved multiple vehicles and a motorcycle. None were at a public road
junction. 
Of the remaining 29 injury accidents, 14 involved serious injury. This is where
one party received wounds involving a broken major bone or overnight stay as a
minimum. 
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Of the 33 injury accidents recorded in total:
• 2 involved pedestrians (1 in Cullen and 1 near Cullen);
• 1 involved a cyclist;
• 21 were not near a junction;
• 10 happened in the woods between A96 Fochabers East roundabout
and Mill of Tynet (including 3 of the 4 fatal accidents);
• 4 happened around Mill of Tynet;
• 7 between Mill of Tynet and Arradoul;
• 1 in Arradoul;
• 9 between Arradoul and Cullen;
• 2 in Cullen;
• 25 happened during daylight hours; and 
• 2 within street lit areas during darkness. 
The diagram below shows  the  locations of accidents reported between 2013
and 2022: 
Consideration of the above accidents shows no discernible pattern of accidents
and no one location where there is a cluster of reported injury accidents. 
There have been reports of concerns about ‘near misses’ at certain locations on
the A98. These locations are generally where there are side roads (private) or
individual accesses onto the A98. The presence of turning vehicles can
increase the risk of an accident but there are measures that can be taken to
reduce this risk including but not limited to, ensuring forward sightlines of
stationary vehicles waiting to turning into a side road/access are available and
ensuring that side roads and accesses have good visibility in both directions
where they join the public road. 
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In order to minimise the numbers of new turning movements on the A98 into
and out of private accesses and side roads, successive Local Development
Plans have included a policy to only permit new accesses onto the A98 where
there is a significant economic benefit or the access it to facilitate an allocated
site within the plan (see Policy PP3 b) i). 
Furthermore where proposed development would utilise an existing access,
officers seek the provision of the required visibility splays and where this cannot
be provided, object to the proposed development. 
Where there is a history of reported injury accidents at a private access, the
Roads Authority has the powers to seek the closure of such an access on road
safety grounds. However there is a requirement to provide an alternative route if
one does not already exist. This approach is generally the last resort, and only
taken forward when all other options have been exhausted. 
There have also been concerns raised regarding the speed of traffic on the A98
being a contributing factor to reported injury accidents and ‘near misses’. It is
recognised that there are sections of the road (generally the long straight
sections of road where forward sightlines are good) where a number of vehicles
have been observed driving at excessive speeds. There are therefore three
Road Safety Camera sites in operation on the A98; one at Slackend, one near
Broadley and one near Carnoch Farm with the aim of improving driver
behaviour by targeting those travelling at excessive speeds. Further information
on Road Safety Cameras can be found in the draft Road Safety Plan to 2030. 
Finally, there have been concerns raised regarding a recent accident on the
A98 in Arradoul. The Council has yet to receive the report from Police Scotland
for this particular accident. Anecdotal evidence states that excessive vehicle
speeds may have been a contributing factor. Council officers have passed the
data collected from the permanent traffic count site in Arradoul to Police
Scotland so they can use it to inform their accident reporting. 
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REPORT TO: ECONOMIC DEVELOPMENT AND INFRASTRUCTURE
SERVICES COMMITTEE ON 14 NOVEMBER 2023 
SUBJECT: PORT MARINE SAFETY CODE QUARTERLY REPORT 
BY:  DEPUTE CHIEF EXECUTIVE (ECONOMY, ENVIRONMENT AND
FINANCE) 
1. REASON FOR REPORT 
1.1 To inform the Committee on matters of Marine Safety and compliance with the
Port Marine Safety Code (PMSC) for the period Q1 and Q2 year 2023/24. 
1.2 This report is submitted to Committee in terms of Section III (F) (25) of the
Council's Scheme of Administration relating to the functions of Council as
Statutory Harbour Authority (SHA). 
2. RECOMMENDATION 
2.1 Committee is asked to consider and note the safety performance,
fulfilling its function as Duty Holder under the Port Marine Safety Code. 
3. BACKGROUND 
3.1 Under the statutory requirements of the Port Marine Safety Code (PMSC) the
organisation (Moray Council) must appoint a duty holder to ensure
compliance with the PMSC is achieved. The organisation must provide a
report on PMSC performance annually as a minimum. 
3.2 The role of Duty Holders is held by Members of this committee. The role
requires accountability for ensuring the organisation’s compliance with the
PMSC. 
3.3 The Council, in its capacity as a Statutory Harbour Authority, is committed to
undertaking and regulating marine operations to safeguard all its harbour
areas, the users, the public and the environment through its Safety
Management System (SMS). 
Item 7
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4. Q1/2 Review 
4.1 The following sections of the report set out an overview of marine safety
performance for Q1 and Q2 of 2023/24. 
PMSC Audit 
4.2 A full annual audit of Moray Council compliance with PMSC was carried out
by Marex Marine within their capacity as designated person. The Audit was
conducted at Buckie Harbour Office on 27 March 2023 and concluded that the
Moray Council harbours are compliant with the Port Marine Safety Code. 
4.3 The Audit process made observations, mainly clerical in nature, which are
provided in the table below. 
Observations from PMSC Audit: 
Observation Progression
Review Harbour Bye-laws with
particular regard to continued relevancy
Progression in reviewing Bye-laws with
aim to deliver to legal services at end of
Q4 2023/24
Consider cyber security protocols Addition of cyber security policy to be
added to SMS during review cycle.
Risk assessment review required Annual Risk assessment review was
delayed from February but carried out
in June 2023 continuous review
required to be seen in 2024 Audit. 
Key Performance Indicators  
4.4 Details of the Council’s compliance with PMSC are provided below. 
Q1/Q2 Accident, Incident and Near Miss Statistics 
4.5 Incident statistics Summary Table 
Quarter Injuries Incidents Near Misses
1 0 0 1
2 1 0 0 
4.6 Near Miss: 
On 14 April 2023 a near miss occurred with a vessel leaving berth with
divers ready to work. A vessel asked via radio for permission to leave
berth and depart for sea. The watchkeepers checked traffic and gave
permission for the vessel to depart. Approximately 20 minutes after this
divers engaged in repair works to the North pier asked for clearance to
enter the water. Permission was given believing entrance was clear.
Before entering water divers noticed vessel still manoeuvring and
abandoned entry preparations. The harbour office was notified of the
near miss and report made. No injuries occurred. Lack of sight from
temporary harbour office was determined to be root cause of the near
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miss. As a result of the near miss, all staff were reminded that traffic
clearance and movements must be confirmed fully by sight and radio
before any works can be initiated.  
4.7 Accident:  
On 13 September 2023 works commenced by street lighting service on
North Pier to repair pier lighting. On confirmation that all relevant health
and safety controls had been met, work commenced. During the works,
an employee fell from approximately 2 metre height sustaining an arm
injury. The casualty was taken to hospital and diagnosed with broken
arm. As a result of the injury, the employee required long term absence
from work for recovery. Street lighting service have completed the
relevant incident reports with Harbourmaster being forwarded the
information for PMSC reporting requirements. 
Aids to Navigation 
4.8 As a Local Lighthouse Authority, Moray Council is required to report the
availability of all of its navigational lights to the Northern Lighthouse Board in
March of each year. 
4.9 New solar powered lights are currently being installed in Burghead and
Buckie. The new solar powered lighting will decrease the number of faults
observed and as a result lead to an increase in the availability figures for all
navigational aids. This work has been funded by Scottish Government Marine
Fund Scotland Scheme and installation will be completed after completion of
harbour office move and appropriate weather conditions exist with a target
completion by end of December 23. 
4.10    Buckie navigational light installed June 2023: Notice to Mariners 04 2022 was
issued on the 15 of December 2022 notifying all mariners that the Mucks
Navigation light is extinguished.  A suitable temporary replacement was
located and installed on the next weather/tidal window which occurred on 14th
of February 2023.  While this light was not the correct sequence it helped
highlight the Mucks to vessels.  The correct light, once purchased, was
installed in June 2023 
4.11    Due to shore side power issues, power had to be isolated to the Buckie West
pier (green) navigation lights due to safety requirements. Installation of the
new solar light was completed on the 31st of July 2023.  This changed the
sequence from 2 fixed green lights to a single flashing green light. 
Preparations are being made for the other lights which will be completed after
the power upgrade is complete. 
4.12    Burghead navigation solar lights installed October 2023: Notice to Mariners
02 2021 was issued on the 8th of September 2021 notifying all mariners that
the Burghead Navigation light is extinguished.  This light was re-instated on
the 4th of October 2023 to the same sequence and range as before. Three
additional lights in Burghead were changed over to solar lights at the same
time, all the sequences remain the same as previous with a slight change in
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the range of these lights. The appropriate notifications have been made to the
Northern Lighthouse Board. 
4.13 The table below summarises the availability of Navigational lights under
Moray Council’s responsibility. 
The ‘Availability Objective’ is calculated over a rolling 3-year period. This
means that over this period a Cat 1 Aid to Navigation needs to be functional
for 99.8% of the time. 
Pilotage 
4.14 Pilotage is not compulsory at Buckie harbour, therefore, not all cargo
movements require the services of a pilot. The number of pilotage acts carried
out in quarters 1 and 2 of 2023/24 was 20 acts of pilotage in relation to 27
vessel movements, 3 of which were at night. 
Training 
4.15 There are currently two full time members of staff deemed competent to pilot
restricted to daylight hours. Currently, one additional pilot unrestricted is also
retained on staff only for pilotage duties. Training will begin for other harbour
staff during Q3/4 with 2 new harbour assistants beginning training as soon as
possible. 
4.16 Refresher training for Port Facility Security officer has been completed by
Harbourmaster. Full Port Facility Security training was also completed by 2
members of staff who are awaiting required documentation from government
to finalise the accreditation. Currently harbours are compliant with PMSC and
International ship and port facility code (ISPS) the additional trained staff will
provide resilience and shared responsibilities.
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4.17 Training has also been completed during Q1/2 as follows:
• First Aid for 3 staff members.
• VHF training for 2 staff members
• Powerboat level 2 training for 1 staff member
• International convention on standards of training, certification and
watchkeeping for seafarers (STCW) refresher training for 1 staff
member. 
Staffing 
4.18 Currently recruitment for a new harbour assistant is underway with interviews
scheduled for mid-November. 
4.19 Recruitment for MV Selkie staff has been delayed due to prioritisation of
staffing issues within the harbour office however, a new recruitment round for
vessel master is being planned to be undertaken during Q3/4.   
Conservancy 
4.20 Dredging has continued during Q1 and Q2 of 2023/24, with priority given to
Buckie basin 4 and Burghead channel when weather and tide permitted. 
4.21 From 1 April 2023 to 30 September 2023 the total amount of spoil removed to
designated spoil grounds was 6,820 Tonnes (Q1 2040 Tonnes, Q2 3,960
Tonnes) over 39 digging days. This includes the harbours at Burghead and
Buckie (see table 2 para 4.26). 
4.22 Burghead groyne regeneration project was completed at the end of June 23
within budget. 
4.23 In Buckie the current depth under chart datum is officially 2.5 Metres with
relevant Notice to Mariners promulgated. There has been significant
improvement in the depth of the channel as a result of work carried out in
2022/23. Indication from Selkie and pilot boat sounding is that depth under
chart datum exceeds 2.5 metres. These soundings have been confirmed by a
bathymetric survey completed in September with no depth less than 2.5
metres in the navigational channel. External contractor dredging works are
being completed during October 2023 to bring all depths to a minimum of 3.0
Metres in the channel and basins 1 and 2 with Selkie continuing work in Basin
3 and 4 as well as works in Burghead. 
4.24 There is a Notice to Mariners published warning vessels of the fluctuating
depths within the entrance channel of Burghead advising all mariners to
contact Harbourmaster for accurate information and tidal information. Once
works have been completed in all areas relevant Notice to mariners will be
completed with updated controlling depths.
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4.25  The priority areas for dredging remain Burghead (sand bank approaching
harbour entrance) and Buckie. The agreed capital works to undertake
outsourced dredging, (agreed on 29 June 2022 paragraph 22 of the minute
refers,) is currently progressing with vessel Aase Hoj which arrived 03
October carrying out works in Buckie harbour currently. The planned works
are estimated to take up to 1 month and will incorporate work to dredge all
harbour basins in Buckie utilising a combination of Selkie and the external
vessel. Other dredging requirements include:   
o Hopeman: Awaiting Marine licence which is planned to include ability to
dispose of spoil on Land. Expected imminently, once received plans for
land based dredging to be completed in Q1 2024/25 will be finalised.
Dredging by sea planned for Q3/4 2023/24 by use of Selkie.
o Findochty: Entrance channel works planned for Q3 2023/24. 
Selkie 
4.26 MV Selkie has completed works within Buckie and Burghead during Q1/Q2 of
2023/24. The table below summarises the work carried out during this period: 
Table 1: Days worked and total tonnage removed comparison
Year Days
working
Weather
days
Maintenance Working
days %
Tonnage
Removed
2023/24
Q2
19 8 2 66 3,960
2023/24
Q1
20 5 14 51 2,860
2023/24
Q4
17 25 7 35 2,440
2022/23
Q3
23 13 14 46 3,240
2022/23
Q2
24 17 14 44 3,260
2022/23
Q1
30 12 20 48 3,460
2021/22
Q4
24 30 9 38 3,330 
Table 2: Summary of works carried out per harbour during Q1 and Q2
Q1 Cumulative
working days
Cumulative
weather days
Cumulative
maintenance
days
Tonnage
removed
Buckie 15 5 14 2,040
Burghead 5 0 0 820
Total (%) 20 (51) 5 (13) 14 (36) 2,860 
Q2 Cumulative
working days
Cumulative
weather days
Cumulative
maintenance
days
Tonnage
removed
Buckie 19 8 2 3,960
Total (%) 19 (66) 8 (28) 2 (6) 3,960 
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4.27 During the Q1/ Q2 period of 2023/24 there has been an improvement on
working days compared to the previous quarter (Q4 2022/23, 35% see Table
1 para 4.25). This improvement in working day percentage has resulted in a
large tonnage of spoil deposited particularly in Q2 with 3960 tonnes taken to
spoil in only 19 days of work. 
4.28 The updated figures for the current year 2023/24 are now 50% working days
30% weather days and 20% maintenance days (unplanned). This is just
reaching the target KPI of 50% working days (see paragraph 4.33). 
Table 3: Comparison of working days compared to weather and maintenance
Year Days working % Weather days % Maintenance %
2023/24
current Total
50 30 20
2023/24 Q2 66 28 6
2023/24 Q1 51 13 36
2022/23 Total 46 25 29
2022/23 Q4 35 51 14
2022/23 Q3 46 26 28
2022/23 Q2 44 31 25
2022/23 Q1 48 20 32 
4.29 The plan for increased efficiency moving forward is to maximise the number of
days crewed on vessel as much as practically possible whilst adhering to
contractual rest day requirements. Scheduling of large scale maintenance
during crew rest days (unmanned days) so that maximum digging day
availability exists. Scheduling of the vessel to maximise days on board where
weather is expected to be the best  
Environmental Considerations 
4.30 There has been continuing work carried out with the focus on lowering carbon
emissions and promoting overall environmentally sound practices within the
harbours. This includes work currently progressing to upgrade the electrical
infrastructure available within Buckie harbour, allowing less reliance on fossil
fuel generators for power. This work is due to be completed by end of Q3. 
4.31  KPI Summary Table  
KPI Progress at the end of Q2 Completion Target Date 
Conservancy 
Buckie Channel Depth 3.0M Current official depth
improved to 2.5M confirmed
by bathymetric survey.
External dredging programme
continuing work
31/12/23
Buckie Basin 1/2/ depth 3.0M Current depth 2.2M Review of progress 31/10/23
Fully achieved by 31/12/23
Provide 0.3M channel
Burghead
Current depth 0.0M Review of progress 31/10/23
Fully achieved by 31/03/24 
Productivity 
Maintenance days less than Currently 20% for 2023/24 Continuous review
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KPI Progress at the end of Q2 Completion Target Date
20%
Working days greater than
50%
Currently 50% for 2023/24 Continuous review
Total minimum tonnage
removed above 14,120 Tonnes
(aspirational target 18,000
Tonnes)
End of Q2 6,820 (annual
projection therefore 13,640)
31/03/24
Total working days above 77
(target 100)
39 end of Q2 (therefore on
track to reach KPI)
31/03/24 
Staffing 
Full Time master recruitment campaign (long
term skilled agency worker
currently)
30/09/22 postponed due to
staffing issues within harbour
office and long term absence.
reviewed target 31/03/24 
Safety management/
Maintenance 
SMS review and Update Reviewed and awaiting audit
review by designated person
to be carried out Feb 24
15/02/24
Full Risk assessment update annual review completed. 31/10/23 
Financial 
Lower Running costs to within
Budget
To be reviewed 31/03/24 
4.32 Graph of Selkie Working day % trends per quarter 
0
10
20
30
40
50
60
70
2021/22 2022/23 Q1 2022/23 Q2 2022/23 Q3 2022/23 Q4 2023/24 Q1 2023/24 Q2
Working Days Maintenance Days Weather days
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4.33 The general pattern of Selkie working day availability compared across
quarters is showing an overall decrease in unplanned maintenance days and
overall increase in working days. There is however still continued
improvement required to maintain the desired KPIs highlighted in the table in
paragraph 4.34 above now that they have been reached in q2. The anomaly
in Q4 was a result in delays for parts from a supplier which resulted in
increased unplanned maintenance days. A trend graph will continue to be
added in future reports to highlight progress toward KPIs identified for working
day and maintenance day targets. 
5. General Safety Updates 
Safety related works 
5.1      There have been a number of jobs completed during Q1/2 improving safety 
conditions within all harbours, these works include: 
• Various lighting repairs in all harbours.
• Remove protruding piece of rebar at Buckie causing a health and
safety risk.
• Housekeeping across all harbours ensuring all areas are safe and
clean.
• Move and replace cargo vessel fenders in Buckie.
• Replace lifebuoy ropes in all harbours where needed.
• Install handrails to allow safer egress.
• Capital works to install rock armour completed in Findochty allowing
the road to be opened again.  
• Full survey of all anchors, chains and under sides of the Findochty
pontoons carried out by a dive team. Some components also replaced
by same team.
• Change out various rope ladders across all harbours.
• Various pieces of safety equipment replaced on Pathfinder and annual
midterm survey completed with only minor issues which were all
corrected within 2 weeks.
• All ice machines and chills inspected by specialist to ensure they were
working in a safe and efficient manner
• Modifications made to the rescue ladders on the pontoons at Findochty
so the bottom rung sits lower in the water making getting onto it easier.
• Repairs to boards on Findochty pontoons
• New ground chain and risers installed to the Portknockie Pontoons to
reduce the swing at the bottom of the tide.
• Steelwork protruding from the pier in Cullen removed to make it safer
for those jumping in.
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Master action List 
5.2       List of safety related jobs required to be completed in all harbours comprising the Master action list:
Priority category Number of safety
related jobs
needing
completion at
beginning of Q1
Number of safety
related jobs still
outstanding at
end of Q2
Total  safety
related jobs
completed during
Q1/2
1 17 0 17
2 46 15 31
3 40 18 22
4 29 16 13
Totals 132 49 83 
5.3      Master action list is a list of all safety related jobs required within the harbours
segregated in to 4 categories. Category 1 deemed the most important. 
• There are no remaining priority 1 items 
Signage 
5.4       New signs were received and installed at all harbours. This included: 
1. Signs to restrict general access to the pontoons.
2. Harbour operations signs.
3. Designated visitor berths.
4. Operational speed restrictions. 
6. Buckie Harbour Operational Update 
6.1 All leases and relevant legal papers have been concluded and signed with
respect to offshore wind energy Operation and Maintenance (O&M) base.
Work to begin on new office buildings and quayside assets for offshore wind
base are now well underway. 
6.2 Buckie harbour office now temporarily located within the former Buckie Drifter
building and remains fully operational in shared building with Offshore wind
energy company as new office buildings are developed for Harbour office and
Offshore wind O&M base, this is due to be completed by end of Q4 
6.3 New weighbridge constructed and completed to west side of existing
Fishmarket building providing new improved weighbridge facility. Facility has
safer accessibility as well as closer proximity to cargo handling facilities and
eventual harbour office location. Due to identified issues with calibration
weighbridge was not operational during Q1/2. This has now been resolved
and weighbridge is now operational. 
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6.4 Electrical infrastructure upgrade works currently in progress due to be
completed Mid November. 
7. Objectives identified for remaining quarters of 2023/24 
• Undertake further reviews of Marine Policy and Harbour Bye-laws. 
• Review training requirements and request necessary training. 
• Continue momentum of Pilot training and accreditation leading to 2 fully 
competent Pilots within the Harbour team by end of Q3. 
8.  SUMMARY OF IMPLICATIONS 
(a) Corporate Plan and 10 Year Plan (Local Outcomes Improvement
Plan (LOIP)
Sustainable harbours maintained to operate safely and efficiently
contribute to the economic development of Moray. 
(b) Policy and Legal
Non-compliance with the PMSC will have legal implications. 
(c) Financial implications
Non-compliance of the PMSC may have financial implications. 
(d) Risk Implications
Failure to comply with the PMSC could result in prosecution of the
authority. 
(e) Staffing Implications
No staffing implications arise from this report. 
(f) Property
There are no property implications arising from this report. 
(g) Equalities/Socio Economic Impact
There are no specific equalities matters, however, the Equalities Officer
has been consulted and comments incorporated into this report. 
(h) Climate Change and Biodiversity Impacts
There are no climate change and biodiversity implications arising from
this report. 
(i) Consultations
The Depute Chief Executive (Economy, Environment and Finance),
Head of Environmental and Commercial Services, Legal Services
Manager, Head of Financial Services, Committee Services Officer (L
Rowan), and Equalities Officer have all been consulted and their
comments incorporated into this report. 
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9.       CONCLUSION 
9.1 The Council is currently deemed to be compliant with the PMSC, 
however, work to maintain a safe environment remains an ongoing 
matter in a dynamic environment. Diligent staffing and constant 
monitoring and risk assessing will be utilised to maintain compliance as 
demands evolve. 
Author of Report: Stuart Akass, Development and Operations Manager
(Harbours)
Background Papers: 
Ref: SPMAN-524642768-985 
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REPORT TO: ECONOMIC DEVELOPMENT AND INFRASTRUCTURE
SERVICES COMMITTEE 14 NOVEMBER 2023 
SUBJECT: BIODIVERSITY DUTY REPORT 2021-2023 
BY:  DEPUTE CHIEF EXECUTIVE (ECONOMY, ENVIRONMENT AND
FINANCE) 
1. REASON FOR REPORT 
1.1 To ask the Committee to agree the content of the council’s Biodiversity Duty
Report 2021-2023. 
1.2 This report is submitted to Committee in terms of Section III (F) (13) of the
Council's Scheme of Administration relating to matters regarding
environmental protection. 
2. RECOMMENDATION 
2.1 It is recommended that Committee agree the content of the Biodiversity
Duty Report 2021-23 set out in Appendix 1 that will be issued to the
Scottish Government. 
3. BACKGROUND 
3.1 Biodiversity loss and ecosystem collapse are one of the most severe and
likely risks to humanity. In recognition of this, under the Nature Conservation
(Scotland) Act 2004, all public bodies in Scotland have a duty to further the
conservation of biodiversity when carrying out their responsibilities. In
accordance with the Wildlife and Natural Environment (Scotland) Act 2011
public bodies must also publicly report its compliance with this biodiversity
duty. 
3.2 Biodiversity duty reports are required every three years, and are not only
about protecting biodiversity through managing specific sites, habitats and
species but also aim to: 
• Increase the level of understanding and connection between people and
the living environment. 
• Promote consideration of all our impacts on the natural world through our
actions and decisions, including through procurement and use of
resources; and,
Item 8
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• Encourage staff, partners and customers to engage with, understand and
consider biodiversity. 
3.3 On 2 February 2023 Moray Council formally recognised that we are facing a
nature emergency (para 9 of the minute refers). Our economies, livelihoods
and well-being all depend on nature, which is being lost at an alarming rate.
Biodiversity underpins our economy, for example our food and drink
production rely on healthy soils, pollination and clean water. Nature is also our
greatest store of carbon and is a cost effective way to mitigate the impacts of
extreme weather such as flooding and heatwaves. The social and cultural
value of nature further extend to improved health and wellbeing as well as
educational outcomes. 
3.4 The council’s statutory responsibilities and influence over these areas are
wide ranging, from land regulation through planning to direct impacts as a
land owner. The Biodiversity Duty Report set out in Appendix 1 will be issued
to the Scottish Government and made publicly available on the Council’s
website on 1 January 2024. 
4. HIGHLIGHTS OF THE BIODIVERSITY REPORT 
4.1 Action to protect and enhance biodiversity 
4.2 Much of the activity outlined in the report was already reported to this
committee on 2 May 2023 (para 20 of the minute refers) but the report
provides additional detail on;
• Implementation of the National Planning Framework 4 (NPF4) this
year, with significantly stronger policies on biodiversity and climate
change;
• Developments within the gathering of evidence for the next Local
Development Plan and Moray Nature Network;
• Nature positive management of council land, including wildflower
program, improvement of key nature sites, invasive non-native species
removal, installation of rain gardens and supporting communities to
grow food on council land;
• Work with communities to identify and implement improvements in
public spaces, schools and new developments;
• Participation in the North East Scotland Biodiversity Partnership’s work
to engage individuals, communities, businesses and developers to take
action on the priorities for nature in our local area. 
The report acknowledges the challenges to effectively deliver this work with
the limited resources available. 
Mainstreaming within Moray Council 
4.3 The report summarises policies, plans, guidance and strategies that are
embedding biodiversity considerations within council decisions and actions.
These include: supplementary planning guidance and NPF 4, the Climate
Change Strategy, climate change and biodiversity implications section within
committee reports, adjusted operational procedures for grass cutting, training
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delivered including Carbon Literacy and a new staff e-module on climate
change. 
Climate change adaptation and nature based solutions 
4.4 The Climate Change Strategy and its delivery plan acknowledge climate
change and biodiversity loss as twin crises requiring a combined response.
Reducing carbon emissions and adapting to the impacts of climate change
both require us to work with nature and this is recognised across a number of
strategies and plans. Opportunities for synergies between these to deliver
nature based solutions to climate change are currently being explored. 
4.5 The main climate impacts relevant to biodiversity in Moray in the next three
years are also highlighted in the report as:
• Extreme weather events, such as flooding, damage and loss of forests
caused by storms and of forest/heath/dune habitats caused by wildfires
• Ecosystem changes increasing the risk of invasive species and
diseases as well as disrupted synchronisation of various species and
their emergence/breeding/food sources. 
Engagement and understanding 
4.6 This section of the report acknowledges the limited resources the council has
to deliver environmental engagement. It does highlight some excellent
examples of where good work has been possible, including high quality
outdoor learning provided by some schools, engagement undertaken by the
North East Biodiversity Partnership , community engagement (particularly for
the Local Development Plan), celebrating successes through press and social
media, and staff undertaking learning/ sharing opportunities. 
Research and monitoring  
4.7 A range of research has been undertaken in 2023, driven by a number of
interlinking statutory duties covering requirements for the Evidence Report for
the next Local Development Plan, the introduction of NPF4, the Climate
Change (Scotland) Act 2009 and efforts to meet the council’s emissions
reductions target, and the expected increase in responsibilities for public
bodies under the new Scottish Biodiversity Strategy. The studies outlined in
the report have involved extensive desk based research and initial ecological
surveys in order to advance the council’s understanding of biodiversity within
Moray. 
4.8 Monitoring has been a challenge to resource, however the Nature Restoration
Fund has enabled some ecological surveys of key nature sites to be
commissioned.. There are plans to develop performance indicators that will be
essential for measuring the impact of biodiversity enhancements through
planning, within the Nature Network, and carbon offsetting projects.   
Future challenges 
4.9 Future challenges were identified as: 
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• Staff capacity and resource pressures to deliver direct enhancements
and engagement/ training
• Delivery and monitoring of ‘enhancement’ via NPF4
• Development and monitoring of the Nature Network
• Collaborative and co-ordinated working across departments 
• Achieving carbon insetting by investing in natural capital enhancements
• Adapting to climate impacts using Nature based Solutions (especially
school estate and mitigation of flood risk)
5. SUMMARY OF IMPLICATIONS 
(a) Corporate Plan and 10 Year Plan (Local Outcomes Improvement
Plan (LOIP))
Action on biodiversity loss supports the delivery of corporate plan
priorities for people, place and the future by; improving health and
wellbeing, strengthening communities, minimising harm and costs arising
from climate change impacts and creating economic opportunities. 
(b) Policy and Legal
Public bodies in Scotland are required to further the conservation of
biodiversity and to publicly report compliance with this duty under the
following legislation:
• Nature Conservation (Scotland) Act 2004 
• Wildlife and Natural Environment (Scotland) Act 2011 
• NPF 4
• Local Development Plan 2020 
(c) Financial implications
The Nature Restoration Fund direct grant allocations of £471,000 over
the reporting period have made delivery of a range of practical actions
possible. Without this funding, it is difficult to see how the council could
have meaningfully contributed to furthering the conservation of
biodiversity on its own land given funding constraints. 
(d) Risk Implications
Challenges have been highlighted within the report which may pose a
risk to the council’s compliance with the Biodiversity Duty in future. 
(e) Staffing Implications
The council has endeavoured to deliver its basic statutory duty with
constrained resources over the period 2021-23. It should be recognised
that statutory responsibilities for biodiversity have significantly increased
through NPF4 and are likely to increase further through the adoption of
the Scottish Biodiversity Strategy and the proposed Natural Environment
Bill. Current staffing levels would be unable to absorb additional duties
without additional funding being provided..   
(f) Property
The future challenges highlighted in 4.9 may impact on the enhancement
of council land. 
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(g) Equalities/Socio Economic Impact
Equal access to quality greenspace is important for health, wellbeing,
community cohesion, child development and limiting harm from pollution.
Improving biodiversity presents opportunities to reduce inequality. 
(h) Climate Change and Biodiversity Impacts
The council’s duties and activities have a significant impact on the
biodiversity of Moray. 
The risks associated with the loss of vital ecosystem services range from
disrupted food systems and water supplies to increased damage
resulting from climate change impacts and reduced capacity to absorb
carbon emissions. Failure to act now will lead to catastrophic
implications on our economy and the health and wellbeing of future
generations. 
Full delivery of the council’s Biodiversity Duty is therefore of vital
importance and the future challenges highlighted in 4.9 should be noted. 
(i) Consultations 
The Depute Chief Executive (Economy, Environment and Finance),
Head of Economic Growth and Development, the Legal Services
Manager, Environmental Protection Manager, Open Spaces Manager,
Chief Financial Officer, Lissa Rowan (Committee Services Officer) and
Equal Opportunities Officer have been consulted and comments
received have been incorporated into the report. 
6. CONCLUSION 
6.1 The council’s Biodiversity Duty Report 2021-23 outlines the actions
taken to protect, enhance and restore biodiversity. 
6.2 Statutory obligations related to biodiversity have increased over the
reporting period. While understanding of, and action taken to reverse,
biodiversity loss has also increased, this has been delivered within
existing staff capacity. 
Author of Report: Sophie Ward, Climate Change Strategy Officer
Background Papers: Economic Development and Infrastructure Services
Committee, 2 May 2023 
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MORAY COUNCIL
BIODIVERSITY DUTY REPORT
2021-23
Item 8
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1 Contents
2 Introduction .................................................................................................................................... 2
2.1 Moray Council’s Biodiversity Duty .......................................................................................... 2
3 Actions to protect and enhance biodiversity .................................................................................. 2
3.1 Biodiversity enhancement though the planning process ....................................................... 2
3.2 Nature Positive Management of Council Land ....................................................................... 4
3.3 Work with Communities ......................................................................................................... 6
3.4 Partnership working ................................................................................................................ 6
4 Mainstreaming biodiversity within the organisation ...................................................................... 6
5 Climate change adaptation and nature based solutions ................................................................ 7
5.1 Main climate related risks ....................................................................................................... 7
6 Public engagement and workforce development ........................................................................... 7
6.1 Community engagement ........................................................................................................ 8
6.2 Outdoor learning ..................................................................................................................... 8
6.3 Opportunities to celebrate successes ..................................................................................... 8
6.4 Participation in the North East Scotland Biodiversity Partnership (NESBiP) .......................... 9
6.5 Workforce development ......................................................................................................... 9
7 Monitoring and research ................................................................................................................ 9
7.1 Research .................................................................................................................................. 9
7.2 Monitoring ............................................................................................................................ 10
8 Highlights ...................................................................................................................................... 10
9 Future challenges .......................................................................................................................... 10 
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2 Introduction 
Biodiversity loss and ecosystem collapse are one of the most severe and likely risks to humanity1.
Under the Nature Conservation (Scotland) Act 2004 all public bodies in Scotland have a duty to
further the conservation of biodiversity when carrying out their responsibilities. In accordance with
the Wildlife and Natural Environment (Scotland) Act 2011 public bodies must also publicly report its
compliance with this biodiversity duty. This report outlines how the Moray Council has fulfilled its
biodiversity duty over the period 2021 to 2023. 
2.1 Moray Council’s Biodiversity Duty 
Moray Council covers an area of 2238 square kilometres, with a predominantly rural population of
just over 96,000. It is an area of rich landscapes including mountains within the Cairngorm National
Park, 28% forest cover and a diverse coastline and marine ecosystem. There are 49 protected areas
within Moray.
As a large organisation, the council covers a wide range of services and operations that have an
environmental impact and is committed to acting on the causes of climate change and biodiversity
loss, and to take action to adapt to climate impacts.  
The council has a responsibility as a planning authority through the preparation and delivery of the
Local Development Plan and through delivery of National Planning Framework. Both include polices
which aim to protect and enhance biodiversity. The next Local Development Plan will facilitate the
creation and conservation of a Nature Network to support connectivity between protected areas
and between urban-rural areas. The Moray Forestry and Woodland Strategy informs woodland
creation and related activities, and the council also administers Tree Preservation Orders. Strategic
plans for areas at risk of coastal change are currently at consultation stage and the council has active
flood risk management plans. 
The council is also responsible for the management and maintenance of all council open spaces
including parks, woodlands, cemeteries, school grounds, road verges and play areas, and for delivery
of a Core Paths Plan. There are also opportunities to enhance biodiversity through working with
partners and communities to deliver place based projects. 
As an education authority the council has a duty to connect young people with nature through the
Curriculum for Excellence in Outdoor Learning and Learning for Sustainability.
3 Actions to protect and enhance biodiversity  
Recognition of the scale and pace of biodiversity loss are driving Moray Council to take action. The
main developments are outlined in the following sections, but a broader, strategic approach is
currently being explored to bring these various streams together. This approach will deliver multi
benefit natural capital, enhance and link spaces for nature, tourism, recreation, health, learning,
develop local supply chain and nature based skills (see in particular the work highlighted in sections
3.1 and 7.1).
3.1 Biodiversity enhancement though the planning process 
Moray Council’s existing local development plan policies aim to protect and enhance biodiversity,
including through connectivity and the use of nature based solutions. These are now being delivered 
1 https://www.weforum.org/reports/global-risks-report-2023/digest 
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in conjunction with the strengthened biodiversity policies within the National Planning Framework
(NPF4). 
The council is undertaking a range of work to embed the urgency of reversing biodiversity loss and
restoring nature through the next Local Development Plan due to be published in 2027. 
• Local habitats and species data is being collated and mapped. This evidence will be used in
the evidence report for the new local development plan and forms the first stage of
opportunity mapping for a Moray Nature Network. The next stage, including consultation
with key stakeholders, is due to take place in 2024. 
• The revised Woodland and Forestry Strategy brings together opportunities for biodiversity,
carbon reduction, health and wellbeing as well as skills development and the economy. The
strategy will support the Scottish Biodiversity Strategy’s action to: “Ensure that productive
forests and woodlands deliver increased biodiversity and habitat connectivity as well as
timber production”. 
• A baseline review of natural capital was undertaken in 2023, identifying opportunities for
carbon sequestration and biodiversity enhancement on both Moray Council land and across
the Moray area. The study recommended a biodiversity first approach to pursuing
opportunities for carbon offsetting and will inform climate mitigation, adaptation and
biodiversity enhancements as well as development of the green economy and skills. 
• The public call for ideas has also highlighted opportunities for supporting nature across
Moray that will be fed into the plan. 
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3.2 Nature Positive Management of Council Land 
A living lawn and wildflower program was introduced in 2020 to
support the national strategy for action on pollinators. New sites
have been added each year, with 27 areas across Moray now
benefitting from wildflower planting and/or adjusted mowing
patterns covering an area of 5.5ha. Simple signage has engaged
public support for these improvements and more areas will be
introduced as they are identified and subject to funding.
Part of Quarry Wood SSSI, an area of ancient upland oak
woodland is under council ownership however limited resources
have prevented active management of the site in recent years.
As the SSSI is in ‘unfavourable declining condition’, a new
management plan and restoration operations have recently
begun. Again, the sooner the site comes under active
management the lower the cost of restoration will be.
Another large area of council land, Millbuies, now has a plan in
place to protect and enhance the woodland and loch for both
nature and public enjoyment. Restructuring of the woodland for
biodiversity benefit and resilience to climate impacts has begun,
starting with the replacement of commercially planted Sitka
spruce stands with mixed native broadleaves and Scots pine,
and a gradual transition towards continuous cover forestry. Nest
boxes for bats, kestrel and barn owls have also been installed
and R. ponticum removal undertaken.
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The Wards wildlife site, an urban wetland and predominantly
wild space also has a new management plan in place, with
community engagement and gradual wetland improvements
currently underway. Wetland scrapes have been created and
local provenance wildflowers planted. Swift boxes have been
installed on two council owned buildings adjacent to the
wetland.
Two rain gardens have been created at Clovenside cemetery and
Forres Academy to mitigate flooding as a result of heavy rainfall.
The areas have been planted with native trees and a mix of
wildflowers.
The use of glyphosate based herbicides to treat unwanted
vegetation is being monitored, with its application being
minimised where practical. This involves recognition of the value
that flowering plants offer to pollinators and tolerance of a
greater presence of weeds. Reductions of glyphosate application
include; limited strimming around tree bases, signs, benches and
drain covers instead; all play areas except for those where
weeds can easily establish and need to be controlled for the
safety surfacing to be effective; using alternative methods such
as mulching shrub beds to suppress weed growth.
The Core Path network is positively managed to enhance
biodiversity and the council continues to support communities
to deliver on the ground projects including Elgin allotments,
REAP’s therapeutic garden and various community orchards and
other edible planting in suitable locations.
The council has undertaken control of Giant hogweed, Japanese
knotweed, Himalayan balsam and Rhododendron ponticum on
council land and through supporting the work of the Scottish
Invasive Species Initiative (SISI). Invasive species control now,
and the co-ordinated approach of SISI in particular, will avoid
escalating future costs to the council and general public.
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Much of the above work has only been possible due to the Scottish Government’s Nature
Restoration Fund direct grant, and even so there have been challenges. Limited staff resources
across several services and short delivery windows for the grant have restricted what can be
achieved. 
Going forward there are plans to combine projects and add value through collaboration, for example
the Nature Network, Open Space Strategy and Moray Growth Deal Housing Mix Delivery project and
town centre improvement plans.
3.3 Work with Communities
Sites included in the wildflower program have been identified in consultation with communities,
with some areas being led by and delivered by community groups. A map of wildflower areas has
recently been added to the council’s website to support public engagement. 
Many schools have been taking opportunities to improve outdoor learning environments to support
deliver of this approach to learning which is embedded in the curriculum (see 6.2 below). These
spaces often directly enhance biodiversity in addition to connecting young people with nature and
developing green skills within the young workforce. 
The Moray Growth Deal projects are developing learning opportunities, such as innovative design in
the Housing Mix project to maximise access to nature, and plans for a dedicated outdoor learning
hub for young children.  
Biodiversity is a key benefit identified within the Moray Food Growing Strategy. The council supports
communities to deliver on the ground projects including Elgin allotments, Greenfingers therapeutic
horticultural project and REAP’s therapeutic garden and various community orchards and other
edible planting in suitable locations.
3.4 Partnership working 
The council contributes to and participates in the management of the North East Scotland
Biodiversity Partnership (NESBiP). NESBiP produced and maintains an action plan, which outlines the
habitats and species in most need of urgent local action. The resources provided by the partnership
support developers to make locally significant improvements to biodiversity within new
developments, and also guide and engage individuals and communities to take local action.
Successful social media channels and engagement events provide support and education for the
public to help nature through volunteering, citizen science and home gardening. 
4 Mainstreaming biodiversity within the organisation 
Moray Council is working to embed biodiversity considerations throughout a number of policies,
plans, guidance and strategies with the limited resources available. 
• The Climate Change Strategy, published in 2021, highlighted biodiversity as a key theme.
The associated action plan now includes several actions that recognise the council’s
existing action on biodiversity, providing a governance structure for monitoring progress
in this area.
• All committee reports are now required to identify climate change and biodiversity
implications.
• The wildflower programme has involved changing management practices on council
land, with operational staff delivering the ongoing maintenance of these areas including
reduced mowing and the use of new cut and lift machinery. 
• The council agreed to further reduce the use of herbicide use through a managed
approach in certain settings and is monitoring the cost and effectiveness of alternative
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approaches. It is recognised that glyphosate based herbicides may need to be phased
out in the near future. 
• Carbon Literacy training and a short e-module have highlighted the importance of using
nature based solutions to climate change to staff and elected members. 
• Supplementary planning guidance on biodiversity continues to be delivered alongside
NPF4. New biodiversity guidance and training for planners is currently in development. 
Moray Council aims to produce a Biodiversity Strategy in 2024. Multiple strategies, policies and plans
currently cover the protection and restoration of nature, but a focused strategy will synthesise the
key actions and support the delivery of a landscape scale approach via the Moray Nature Network.
5 Climate change adaptation and nature based solutions
The Climate Change Strategy and its delivery plan acknowledge climate change and biodiversity loss
as twin crises requiring a combined response, including the vision to ‘work to retain, protect and
enhance biodiversity across Moray’. Actions from the climate change delivery plan include
management of council land to maximise carbon sequestration as well as biodiversity benefit and
working with partners to develop a Nature Network. The Climate Change Strategy also includes an
action to identify adaptation work happening across the organisation, including identifying
opportunities for nature based solutions. The adaptation project is at an early stage and resources
have yet to be identified to develop and deliver an action plan. Collaborative working will be
essential to deliver adaptation work, bringing together multiple benefits wherever possible. 
The preparatory work undertaken for the next local development plan outlined in section 2.1 will
inform how nature based solutions to climate change will be delivered. Some of the strategies and
plans currently in development to support this are the forthcoming Nature Network Map,
Biodiversity Strategy, Woodland and Forestry Strategy, Regional Coastal Change Adaptation Plan,
Open Space Strategy and Regional Spatial Strategy. As referenced in section 2, the council is
exploring ways to fund and deliver these together as one project.
5.1 Main climate related risks
The main climate impacts relevant to biodiversity in Moray in the next three years are likely to be; 
6 Public engagement and workforce development 
Moray Council no longer has any staff delivering the traditional role of rangering, but does monitor
wildlife and deliver environmental education and engagement when capacity and resources allow. 
Extreme weather events
•damage and loss of forests caused by storms
•forest/heath/dune habitats caused by wildfires
•damage and loss of habitat and soil structure caused by flooding (though can have positive
effects on ecosystems too)
Ecosystem changes caused by a warmer climate and shifting seasons
•increase of suitable conditions for invasive species and diseases
•disrupt the synchronisation of various species and their emergence/breeding/food sources.
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6.1 Community engagement
Initial engagement for the Local Development Plan has included biodiversity and greenspace as a key
topic. Information has been shared with and sought by the public at open events, and digital call for
ideas. The responses so far have shown that the climate and nature crisis is one of the highest
priorities for the people of Moray when considering planning issues. Comments included embedding
nature based solutions, ensuring new developments provide habitat and nature networks and that
greenfield development is restricted. A number of ambitious nature projects/ visions were proposed
that would bring together nature and community.
Workshops have also been held with schools, supporting young people to consider ways to reverse
biodiversity loss, such as through nature networks and changing land management and building
practices. Engagement with elected members through workshops and reports have highlighted the
key issues and opportunities involved in delivering biodiversity enhancement through the planning
process. 
6.2 Outdoor learning
Schools across Moray are delivering outdoor learning projects that are connecting young people
with nature. 
• Outdoor learning environments have been improved, for example through the installation
and restoration of ponds at several schools, new sensory gardens and pupils planting trees
to commemorate Queen Elizabeth.     
• Students Duke of Edinburgh program take part in expeditions along the Moray Coast and
along the River Spey or Cairngorm National Park, for example. The design of the expeditions
is to encourage young people to engage with the outdoors and start to appreciate the value
of preserving it.  Environmental projects that explore issues relating to biodiversity and land
management.  
• Field trips to deliver relevant curriculum elements within the local context. 
• Outdoor Discovery sessions, gardening and Forest School sessions in primary schools give
young people a better understanding of the nature that surrounds them. 
6.3 Opportunities to celebrate successes 
Projects to improve biodiversity on council land are highlighted to the public through press releases
and social media channels. Clearer information has been added to the council’s website, explaining
Speyside High pupils participating in a
Day of Nature Connection with a local
estate to create various homes for
nature.
Logie Primary pupils improving the
area around their wildlife pond
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the action the council is taking as well as signposting ways for individuals to take action or learn
more. 
The council participated in a climate change film created by the Moray Firth Coastal Partnership
which highlights the local impacts of climate change and some of the action being taken locally to
address it. The film has been promoted to teachers to use as an educational resource, as well as
promoted to council staff and the wider public. 
6.4 Participation in the North East Scotland Biodiversity Partnership (NESBiP)
NESBiP undertakes a wide range of projects to raise the profile of locally and nationally important
species and habitats, encourage data recording and facilitate joint working on Local Biodiversity
Action Plan (LBAP) priorities across the region. Key engagement activities include the hosting of a
wildlife gardening Facebook group alongside a main Facebook page that highlights relevant
information and events etc. 
6.5 Workforce development 
Learning for Sustainability and Forest School training undertaken?
Training and guidance for planners in delivery of biodiversity enhancement through NPF4 is
currently being developed. 
Contributed to the North East Scotland Biodiversity Partnership’s annual seminars, in 2023 the topic
was pollinators, giving Moray Council an opportunity to showcase the living lawn and wildflower
programme. Council staff and elected members were invited to the event to learn and share best
practice from across the region. 
7 Monitoring and research
7.1 Research
The introduction of NPF4, efforts to meet the council’s net zero target and the expected increase in
responsibilities for public bodies under the new Scottish Biodiversity Strategy have driven a range of
research in 2023. The studies outlined in 2.1 have involved extensive desk based research and initial
ecological surveys in order to advance the council’s understanding of biodiversity within Moray.
• A biodiversity study involving desk based research and engagement with key stakeholders
establishing priority species and habitats was carried out, in addition to ecological surveys of
former SINS sites and 5 key growth sites identified in the local development plan. The output
of this work will be used in the Evidence Report for the next local development plan and
provide a foundation of knowledge to inform planning decisions going forward. The maps
will also, alongside other relevant resources, form the starting point for the first Moray
Nature Network. 
• Natural capital investment opportunities have been identified through mapping GIS data,
and consultation, recommending that biodiversity improvements and carbon offsetting
could be delivered together.  
• Similarly, the new Woodland and Forestry Strategy, currently in draft, aims to support the
delivery of mitigating and adapting to climate change and reducing biodiversity loss
alongside social and economic outcomes.  
• Ecological surveys of two key nature sites, Millbuies and the Wards, have identified
enhancement opportunities as part of renewed management plans. A woodland
management plan for Quarry Wood SSSI has also recently been submitted to Sottish
Forestry. This will enable active management of invasive tree species in the ancient oak
woodland. 
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7.2 Monitoring 
Monitoring has been a challenge to resource, however the Nature Restoration Fund has enabled
some to take place through those projects. There are plans to develop performance indicators that
will be essential for measuring the impact of biodiversity enhancements through planning, within
the Nature Network, and carbon offsetting projects.  
Ecological surveys of all wildflower and living lawn sites have been carried out to determine quality
and identify management recommendations. Water level monitoring has been installed at the
Wards wetland to inform future management decisions.  As both of these have only recently
undertaken no trends have been identified yet. 
Areas of concern flagged by casual observation on council managed land include a risk of lowering
water levels at the Wards wetland and spread of giant hogweed along active travel routes.
Additionally, NatureScot assessment of Quarry Wood SSSI (part of which is under council ownership)
is that this was in unfavourable declining condition in 2006. 
All contracted ecologists undertaking surveys for the projects on council land as well as for the
Biodiversity Study have been asked to submit the records to NESBReC. Occasional records are
submitted by council staff directly.
8 Highlights 
Moray Council has endeavoured to fulfil its Biodiversity Duty with constrained resources over the
reporting period. Despite challenges including limited staff capacity and short timescales for the
(very welcome) Nature Restoration Fund grant, this report has shown that lots has been achieved.
Some most important highlights include:   
9 Future challenges 
Statutory responsibilities for biodiversity have significantly increased during the reporting period
through the introduction of NPF4 and are likely to increase over the next three years. Some of the
The Climate Change Strategy and aligning of biodiversity as
a priority within its delivery plan and therefore
strengthening governance structure for biodiversity activity.
Delivery of the Nature Restoration Fund direct grant across a diverse range of projects
has brought multiple benefits in addition to enhancing biodiversity. Projects have both
engaged the public with nature and reduced risk of escalated costs in future.
The development of the wildflower and living
lawn programme achieved with limited resources
and through good engagement with the public.
The creation of three new management plans for popular natural areas owned
and managed by the council mean there are actions ready to be delivered as
funding becomes available. Several improvements have already been achieved.
Biodiversity featuring as a key theme within the Local Development Plan
engagement during 2023 and the background work being undertaken for
evidence report studies and early work on Nature Network
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main challenges anticipated are listed below. 
Development, delivery and
monitoring of the Nature
Network
Staff capacity and resource
pressures to deliver direct
enhancements and
engagement/ training
Collaborative and co-
ordinated working across
departments
Achieving carbon insetting
Delivery and monitoring of
‘biodiversity enhancement’
via NPF4
Adapting to climate impacts
using Nature based
Solutions (especially school
estate and mitigation of
flood risk)
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REPORT TO: ECONOMIC DEVELOPMENT AND INFRASTRUCTURE
SERVICES COMMITTEE 14 NOVEMBER 2023 
SUBJECT: CONSULTATION ON SCOTLAND’S STRATEGIC FRAMEWORK
FOR BIODIVERSITY 
BY:  DEPUTE CHIEF EXECUTIVE (ECONOMY, ENVIRONMENT AND
FINANCE) 
1. REASON FOR REPORT 
1.1 To ask the Committee to agree the response to the Scottish Government’s
Consultation on Scotland’s Strategic Framework for Biodiversity. 
1.2 This report is submitted to Committee in terms of Section III (F) (13) of the
Council's Scheme of Administration relating to matters regarding
environmental protection. 
2. RECOMMENDATION 
2.1 It is recommended that the Committee agree the response to
Consultation on Scotland’s Strategic Framework for Biodiversity that
will be submitted to the Scottish Government. 
3. BACKGROUND 
3.1 On 2 February 2023, when the Council declared a nature emergency, it also
welcomed the revised national Scottish Biodiversity Strategy and forthcoming
statutory targets for public bodies, including local authorities, required to meet
the challenges of the nature crisis. 
3.2 This Scottish Government consultation is seeking views on a range of topics
and proposals related to biodiversity and tackling the nature emergency in
Scotland. 
3.3 It covers three parts of the Biodiversity Strategic Framework:
• The Scottish Biodiversity Strategy which sets out the vision to halt and
reverse biodiversity loss;
• The first five-year Delivery Plan which contains the actions to deliver
the vision; and
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• The proposed Natural Environment Bill which will provide a framework
for establishing statutory nature targets to drive delivery and the
transformational change we need. 
3.4 Many topics and proposals will directly impact on the council as a public body
that has responsibilities as a regulator, land manager and educator and more. 
3.5 The consultation is wide ranging and includes a significant volume of
information. Given limited staff resource and other priorities, the proposed
response has been limited to those areas with greatest implications for the
council. The deadline for responses is 14 December 2023.  Given constraints
on officer resources, should Committee be unable to identify and agree upon
any amendments felt necessary to the response, it is proposed that the
response is instead submitted as an officer response, allowing individual
members and groups to then submit their own responses. 
4. KEY POINTS 
Scottish Biodiversity Delivery Plan 
4.1 The Scottish Biodiversity Strategy to 2045: tackling the nature emergency sets
out evidence based goals for Scotland to be Nature Positive, halt biodiversity
loss by 2030 and restore and regenerate biodiversity by 2045. 
4.2 It is proposed that the council responds in support of the strategy and delivery
plan. They are highly ambitious, as required by the urgency of the situation,
but how the actions will be delivered is not yet clear. 
4.3 What is evident is that the council will have to play a key role in delivering a
co-ordinated approach through the Local Development Plan and its
subsequent delivery that achieves multiple benefits for people and nature.
This will require local authorities to be properly resourced. 
4.4 Nature Networks will have an especially high impact but it is not clear how
these will be funded and a clear overall picture is required. Consistent funding
streams will be required for all stakeholders. 
4.5 Delays to the adoption of a standard biodiversity metric for Scotland risk the
ability to halt biodiversity loss by 2030. Local authorities and developers need
a consistent metric, training and support. 
4.6 An action to implement nature-positive amenity grassland management
strategies, while welcomed, will require extensive public engagement at the
local level 
4.7 The section on investing for nature should have a clearer vision for co-
ordinated funding and does not highlight the role that local investment through
the planning system can play. Investment in skills also needs to be considered
more broadly and bring young people in before school leaving age to show
them the opportunities available in rural areas. 
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4.8 The short-term nature of the Nature Restoration Fund is a concern, though it
is acknowledged that this funding has been incredibly valuable. The Town
Centre Improvement funding was highlighted as a positive example of long
term funding certainty. 
4.9 It is pleasing to see the addition of an objective on the indirect drivers of
biodiversity loss and recognition of the importance of connecting people with
nature as this is important for long lasting change to be possible.  Policy
mechanisms for delivering this include NPF4 and Nature Networks and the
Climate Adaptation Programme which can be well aligned to deliver but again,
need resourcing, especially for meaningful engagement with communities. 
4.10 Many of the actions require a co-ordinated approach alongside local
knowledge and skills that should be delivered by urban/countryside rangers. 
4.11 While outdoor learning and learning for sustainability are already embedded
within the Curriculum for Excellence, the actions outlined are not ambitious
enough and should more clearly commit to delivering climate adapted school
grounds that provide quality opportunities for children to connect with nature
on their own as well as when guided within a class. 
Nature Networks Policy Framework
4.12 The recently published Nature Network Framework states that every local
authority will have a spatially defined network by 2030. These are similar to
what would often be referred to as wildlife corridors, linking nature rich areas
together in ways that deliver multiple benefits for people and nature. The
design, co-ordination, and delivery of Nature Networks at the local level will be
led by Local Authorities. 
4.13 Local Development Plans will play a key role (and Nature Networks are
already embedded throughout NPF4), however there is not enough clarity on
where the finance will come from for the connecting strands between the
protected / nature rich sites. Again, a big picture, co-ordinated approach that
combines multiple benefits and outcomes is required. 
4.14 It is also unclear how Nature Network sites (that are not designated sites) will
be protected – clearly a need for regulation but also risk that restrictions could
deter landowners. With protection also comes a requirement for monitoring –
and meanwhile there is no resource or expertise within the council to deliver
this. 
4.15 The principle that Nature Networks must be delivered from the bottom up is
very welcome, however lack of resourcing risks this not being done
meaningfully or being rushed. 
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Statutory Targets for Nature Restoration 
4.16 The proposed Natural Environment Bill will set out high level targets next year. 
A legislative approach is welcomed, as mainstreaming biodiversity has been
too slow as we continue to lose biodiversity at pace. Concern remains that it
may be too slow to meet the 2030 target to halt biodiversity loss. All previous
comments regarding resourcing are essential for this approach to be
deliverable. 
4.17 It is also essential that the targets align across policy areas, as is improving
the understanding and application of multiple or co-benefits that are wider.
Health and education are key areas that could have synergistic targets. 
4.18 It was noted that no targets are identified for the indirect drivers of biodiversity
loss, however these are crucial to transformational change in the long term
and there are many ways these could be measured.   
5. SUMMARY OF IMPLICATIONS 
(a) Corporate Plan and 10 Year Plan (Local Outcomes Improvement
Plan (LOIP))
Action on biodiversity loss supports the delivery of corporate plan
priorities for people, place and the future by; improving health and
wellbeing, strengthening communities, minimising harm and costs arising
from climate change impacts and creating economic opportunities. 
(b) Policy and Legal
Public bodies in Scotland are required to further the conservation of
biodiversity and the council has declared a nature emergency. 
Some of the policies and legislation relating to biodiversity that are
particularly relevant include;
Nature Conservation (Scotland) Act 2004 
Wildlife and Natural Environment (Scotland) Act 2011 
Scottish Biodiversity Strategy to 2045 
National Planning Framework 4
Local Development Plan 2020
Nature Networks Framework
Pollinator Strategy for Scotland 
Local natural heritage designations 
Climate Change (Scotland) Act 2009 and 2019 
Moray Climate Change Strategy 
Moray Woodland and Forestry Strategy 
Moray Food Growing Strategy 
Curriculum for Excellence through Outdoor Learning 
Scotland’s Natural Health Service
Scotland's National Strategy for Economic Transformation 
(c) Financial implications
There are no immediate financial implications, however Scotland’s
Strategic Framework for Biodiversity sets out a number of actions that
will increase the responsibilities on local government. 
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Local authorities have been identified as the delivery leads for Nature
Networks and this will be a big project. There is a need for the council to
work collaboratively and creatively across departments and with partners
to draw in funding and pool resources. 
Biodiversity enhancement and stopping biodiversity loss will require
experts from a variety of services across the Council to work together to
efficiently and effectively deliver change. This may mean having to
reprioritise areas of work to facilitate the change. 
It is essential that any new duties placed on the Council or duties that
are enhanced through guidance and strategies are fully funded and
resourced. 
(d) Risk Implications
At current resourcing levels, the Council does not have the resources to
take on additional duties . This has been highlighted in the consultation
response.. 
There is a reputational risk should the council not support strong and
urgent action to reverse biodiversity loss, particularly following the
declaration of a nature emergency. 
(e) Staffing Implications
The council has been endeavouring to deliver its Biodiversity Duty with
limited resources for many years. Statutory responsibilities for
biodiversity have already significantly increased through NPF4 and, as
this consultation sets out, are likely to increase further through the
adoption of the Scottish Biodiversity Strategy and the proposed Natural
Environment Bill. 
Statutory targets for nature restoration will mean the need to introduce
measures and monitoring. The forthcoming Moray biodiversity strategy
could set framework for this but ecological expertise as well as additional
resources will be required to deliver all this as current staffing levels
would be unable to absorb additional duties.   
(f) Property
The council is already beginning to manage its land positively for nature,
but it should be noted that this approach will need to be extended and
mainstreamed across all services in a similar way to the action being
taken to decarbonise Council services. Targets for the improvement of
public land for biodiversity may be introduced. 
(g) Equalities/Socio Economic Impact
Equal access to quality greenspace is important for health, wellbeing,
community cohesion, child development and limiting harm from pollution.
Improving biodiversity presents opportunities to reduce inequality. 
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(h) Climate Change and Biodiversity Impacts
The council’s duties and activities have a significant impact on the
biodiversity of Moray.  
The risks associated with the loss of vital ecosystem services range from
disrupted food systems and water supplies to increased damage
resulting from climate change impacts and reduced capacity to absorb
carbon emissions. Failure to act now will lead to catastrophic
implications on our economy and the health and wellbeing of future
generations. 
The adoption of the Strategic Framework outlined in the consultation will
therefore have a very positive impact on reducing biodiversity loss and
mitigating and adapting to climate change, should it be adequately
resourced. 
(i) Consultations
The Depute Chief Executive (Economy, Environment and Finance),
Head of Economic Growth and Development, the Legal Services
Manager, Environmental Protection Manager, Open Spaces Manager,
Chief Financial Officer, Lissa Rowan (Committee Services Officer) and
Equal Opportunities Officer have been consulted and comments
received have been incorporated into the report. 
6. CONCLUSION 
6.1 A response to the Consultation on Scotland’s Strategic Framework for
Biodiversity has been prepared. The response welcomes the ambitious
vision and actions it proposes, however voices strong concern around
the funding of delivery. The response asks for a big picture approach to
be taken that supports multiple social and environmental benefits to be
delivered simultaneously. 
6.2 The council’s statutory responsibilities have already increased
significantly in the last 12 months and it is clear that this trend will
continue and this must be factored into decisions around how to
improve council services. 
Author of Report: Sophie Ward, Climate Change Strategy Officer and Matthew Watt,
Planning Officer
Background Papers: 
Ref: 
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1 
Respondent Information Form 
Tackling the Nature Emergency - Consultation on Scotland’s Strategic
Framework for Biodiversity 
Please Note this form must be completed and returned with your response.
To find out how we handle your personal data, please see our privacy policy:
https://www.gov.scot/privacy/ 
Are you responding as an individual or an organisation?   
Individual 
Organisation
Full name or organisation’s name 
Phone number 
Address 
Postcode 
Email Address 
The Scottish Government would like your 
permission to publish your consultation 
response. Please indicate your publishing 
preference: 
Publish response with name 
Publish response only (without name) 
Do not publish response
Moray Council
Moray Council Headquarters
High Street, Elgin 
IV30 1BX 
Information for organisations:
The option 'Publish response only (without
name)’ is available for individual
respondents only. If this option is selected,
the organisation name will still be
published. 
If you choose the option 'Do not publish
response', your organisation name may still
be listed as having responded to the
consultation in, for example, the analysis
report. 
Item 9
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2 
We will share your response internally with other Scottish Government policy teams
who may be addressing the issues you discuss. They may wish to contact you again
in the future, but we require your permission to do so. Are you content for Scottish
Government to contact you again in relation to this consultation exercise? 
Yes 
No 
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3 
Tackling the Nature Emergency: Consultation on Scotland’s
Strategic Framework for Biodiversity 
Questions 
We are inviting responses to this consultation by 14 December 2023. 
You are not required to answer every question in the consultation. The consultation
is set out in sections to help you identify matters in which you may have a particular
interest. 
Please note that Section 1 of the consultation document does not contain any
questions, so question numbering starts from Section 2. 
Section 2 – Scottish Biodiversity Delivery Plan 
Question 2a: Have we captured the key actions needed to deliver the objective:
accelerate restoration and regeneration? 
• Yes
• No
• Unsure 
Please explain the reasons for your response: 
• We are extremely supportive of the delivery plan and the need to accelerate
restoration and regeneration. 
• A concern would be how to ensure areas outwith the six large landscape
projects are equally catered for and resourced. 
Question 2b: Are the key actions, to support the objective: accelerate
restoration and regeneration, sufficient to put Scotland on track to ending the
loss of biodiversity by 2030? 
• Yes
• No
• Unsure 
Please explain the reasons for your response: 
• As delivery partners/leads are not identified at this point it is difficult to see
where accountability and responsibility will lie and how this will actually be
delivered. 
• The Local Authority is a key player in delivering the key actions through a
coordinated approach, via the Local Development Plan and Regional Spatial
Strategy. While it is recognised that this specific delivery plan aims to
enhance biodiversity across Scotland, there are a multitude of other benefits
from the enhancement of land associated with enhanced biodiversity. I.e.
access to open space, physical and mental health wellbeing etc. However, the
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4 
successful delivery of these benefits must be supported through proper
resourcing for Local Authorities, both financial and people. 
• We appreciate the funding received through the Nature Restoration Fund and
recognise that there are a number of other funding streams available to both
the Local Authority, landowners and other stakeholders. However, to
successfully utilise the various funding steams and ensure a joined-up
approach, there is a clear need to develop a comprehensive plan for delivery
to achieve the outcomes. 
• In terms of delivery, the biggest barrier we see is resourcing; financial and
people, including delivering with landowners. Furthermore, staff within Local
Authorities and the wider public sector require upskilling to ensure outcomes
are met.i.e. Scotland is not meeting its tree planting target at the current time,
additional targets will be hard to meet because investment in skills
development is not sufficient.
• On the ground delivery at current rate not enough to end biodiversity loss by
2030 as a result of resourcing etc. 
Question 2c: Which actions do you think will have most impact?
Please state the actions and explain the reasons for your response: 
Statutory targets. Good guidance and strategies have been available for many years,
but biodiversity continues to be lost, therefore it is critical that we have statutory
targets.   
Question 2d: Have we captured the key actions needed to deliver the
objective: protect nature on land and at sea across and beyond protected
areas? 
• Yes
• No
• Unsure 
Please explain the reasons for your response: 
• The flexibility and positive approach to the expansion or development of new
NNR + new management plans is encouraging. 
• It is good to recognise support for local authorities in land use decision
making, but implementation is important. 
• Again, good to recognise that building skills and capacity across planning
system is critical. Can national program of training for NPF4 and biodiversity
metric be held regularly for planners and developers?
• The recognition for long term maintenance plans to be submitted regularly
(and supporting finance) is welcomed.  However this should include a plan for
monitoring as well.
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5 
• Amenity grassland management – good to highlight the importance of this but
resources in landscape teams a significant issue and public engagement
needs targeted resourcing for this as it is a dividing issue within communities. 
• ‘Explore options for developing a biodiversity metric’ not strong enough
language. Suggest a metric be implemented by 2025 to ensure all developers
in Scotland can use it across any LA. Interim measure could be use, for
example English BNG as adapted in Aberdeenshire guidance. 
• ‘Consistent approach… Standardised monitoring by 2030’  - Again, not soon
enough.
• The successful delivery of these actions will be reliant on significant,
consistent funding streams being made available for a wide range of
stakeholders. The development of an overall picture should ensure that
funding is targeted and all biodiversity enhancements contribute to the
objectives in a timeous manner. 
Question 2e: Are the key actions, to support the objective: protect nature on
land and at sea across and beyond protected areas, sufficient to put Scotland
on track to ending the loss of biodiversity by 2030? 
• Yes
• No
• Unsure 
Please explain the reasons for your response: 
Lots of good actions but resources, across a number of stakeholders will be required
to deliver and ensure the outcomes are met. 
Question 2f: Which actions do you think will have most impact?
Please state the actions and explain the reasons for your response: 
Identify, expand and enhance Nature Networks and ecological connectivity…
Incorporating and embedding Nature Networks into policy e.g. Local Development
Plan will mainstream biodiversity action 
Question 2g: Have we captured the key actions needed to deliver the
objective: embed nature positive farming, fishing and forestry? 
• Yes
• No
• Unsure 
Please explain the reasons for your response: 
• AECS needs to be part of the Nature Networks to ensure a joined up
approach between all stakeholders. 
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6 
• More emphasis on increasing woodland cover – landowners including public
sector need to be involved 
• Could be requirement that new woodlands include areas that will be included
within Nature Networks and managed to benefit biodiversity 
Question 2h: Are the key actions, to support the objective: embed nature
positive farming, fishing and forestry, sufficient to put Scotland on track to
ending the loss of biodiversity by 2030? 
• Yes
• No
• Unsure 
Please explain the reasons for your response: 
If a long term, consistent funding mechanism is delivered to support these actions
and good communication to support communities and landowners with change, then
some of these actions could help to reverse biodiversity loss. 
Question 2i: Which actions do you think will have most impact?
Please state the actions and explain the reasons for your response: 
Ensure that forests and woodlands deliver increased biodiversity and habitat
connectivity alongside timber and carbon outcomes 
Introduce an agricultural support framework which delivers for nature restoration and
biodiversity alongside climate and food production outcomes 
Question 2j: Have we captured the key actions needed to deliver the objective:
protect and support the recovery of vulnerable and important species and
habitats? 
• Yes
• No
• Unsure 
Please explain the reasons for your response: 
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
………………………………………………………………………………… 
Question 2k: Are the key actions, to support the objective: protect and support
the recovery of vulnerable and important species and habitats, sufficient to put
Scotland on track to ending the loss of biodiversity by 2030? 
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7 
• Yes
• No
• Unsure 
Please explain the reasons for your response:
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
………………………………………………………………………………… 
Question 2l: Which actions do you think will have most impact?
Please state the actions and explain the reasons for your response:
…………………………………………………………………………………………………
…………………………………………………………………………………………………
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Question 2m: Have we captured the key actions needed to deliver the
objective: invest in nature? 
• Yes
• No
• Unsure 
Please explain the reasons for your response:
• Biodiversity Investment Plan is definitely needed. There needs to be a big
picture for delivery of this with identified funding streams and co-ordinated
approach across multiple areas through planning policy and community led
regeneration etc.
• No mention of local investment through the planning system –developer
contributions, offsetting, community benefit etc. Lots of potential here for
bringing things together.
• Skills development really important and welcomed. Also a role for skills
development: agencies like DWP here. Linking land management and future
skills to curriculum and targeting young people from early years right through
to entering workforce– mechanisms already there but not being utilised
strongly enough yet. Would help retain young people in rural areas. 
Question 2n: Are the key actions, to support the objective: invest in nature,
sufficient to put Scotland on track to ending the loss of biodiversity by 2030?
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• Yes
• No
• Unsure 
Please explain the reasons for your response: 
• The Nature Restoration Fund has been extremely valuable and could
continue to achieve much if longer timescales provided. However what
happens after the £65 million NRF is over? There is a concern that this is not
guaranteed. Long term funding (not just annual grants allocated within that
financial year) needs to be guaranteed that enables long term planning,
project delivery and monitoring.
• Funding so far has provided a number of benefits, therefore continued and
increased delivery of co-benefits to maximise return on investment should be
supported
• It will be very difficult to achieve the above objective by 2030 unless
significant investment is made to support delivery including increasing staff
resources across the public sector.   
Question 2o: Which actions do you think will have most impact?
Please state the actions and explain the reasons for your response:
…………………………………………………………………………………………………
…………………………………………………………………………………………………
……………………………… 
Question 2p: Have we captured the key actions needed to deliver the
objective: take action on the indirect drivers of biodiversity loss? 
• Yes
• No
• Unsure 
Please explain the reasons for your response: 
• Very pleased to see the addition of this action on the indirect drivers and
recognition of the importance of connecting people with nature for long lasting
change to be possible. 
• Mainstream biodiversity through the national planning framework and Nature
Networks, Climate Adaptation Programme etc is welcomed. A need for
engagement with elected members and the public and to make full use of the
co-design process. Also needs resourcing to be meaningful.
• ‘Engage and strengthen the connection between people and communities
with nature’ should include provision for local level: Fund rangers in every LA
area (not all areas currently provide this service) – make this a statutory role
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to deliver key actions within this objective and some of those that directly
improve biodiversity. 
• ‘Explore opportunities to further develop Curriculum for Excellence...’ a very
important action and is worded too weakly. Need for Scotland wide program
to adapt school grounds for climate change and biodiversity to provide safe
places for children to connect with nature on their own as well as when guided
within a class. Upskill all teachers so outdoor learning delivery is as
widespread as possible. 
Question 2q: Are the key actions, to support the objective: take action on the
indirect drivers of biodiversity loss, sufficient to put Scotland on track to
ending the loss of biodiversity by 2030? 
• Yes
• No
• Unsure 
Please explain the reasons for your response: 
Greater regulatory and fiscal controls required to ‘Address unsustainable supply and
demand to reduce biodiversity impacts’   
Question 2r: Which actions do you think will have most impact?
Please state the actions and explain the reasons for your response:
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
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Section Three – Nature Networks Policy Framework 
Question 3a: Do you have any comments on the Nature Networks Framework? 
Please provide any comments: 
• Pleased to have this further guidance but many questions about delivery and
resourcing. 
• How will Nature Networks be protected through policy and planning levers?
Will this restriction on management of land discourage landowners from
wanting to contribute to Nature Networks? 
• Where will the public finance come from? Big picture, co-ordinated approach
that combines multiple benefits and outcomes is required – Framework
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10 
doesn’t give enough detail or evidence enough joined up thinking that
includes the income generation through planning etc.  
• Truly bottom up approach resource intensive and a risk that funding and
capacity not sufficient. E.g. additional NRF grant for nature networks this year
very welcome but completely unrealistic that it could be spent within 9
months, especially given no advance notice to plan for it. 
• How will monitoring of sites be funded – no resource for that at local authority
level.   
Section Four – 30 by 30 Policy Framework 
Question 4a: Do you have any comments on the 30 by 30 Framework? 
Please provide any comments: 
• It is noted that the emphasis is on priority funding for 30 x 30 sites – this is
welcomed, but will this curtail finance for the wider NN. 
• In terms of site selection – no mention of landowners, these are critical
stakeholders to identify further sites and ensure a full 30 x 30 framework is
delivered. 
• It is important to recognise dynamic changes in terms of changes to the 30 x
30 network over the long term.   
Section Five – Impact Assessments – Part A
Question 5a: What are your views on the accuracy and scope of the environmental
baseline set out in the environmental report?
…………………………………………………………………………………………………
…………………………………………………………………………………………………
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Question 5b: What are your views on the predicted environmental effects as set out
in the environmental report?
…………………………………………………………………………………………………
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…………………………………………………………………………………………………
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Question 5c: What are your views on the reasonable alternatives as set out in the
environmental report?
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Question 5d: What are your views on the proposals for mitigation and monitoring of
the environmental effects set out in the environmental report?
…………………………………………………………………………………………………
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…………………………………………………………………………………………………
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Question 5e: Do you think that any of the provisions in the SBS or Delivery Plan will
have any adverse effects on business? 
• Yes
• No 
• Unsure 
If yes, please provide any comments: 
…………………………………………………………………………………………………
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…………………………………………………………………………………………………
…………………………………………………………………………………………………
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Question 5f: Are there any additional actions or changes to existing actions which
can be taken through the Delivery Plan to benefit business?
• Yes
• No
• Unsure 
If yes, please provide any comments:
…………………………………………………………………………………………………
…………………………………………………………………………………………………
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Question 5g: Do you think that any of the provisions in the SBS or Delivery Plan will
have any adverse effects on socio-economic equality? 
• Yes
• No 
• Unsure 
If yes, please provide any comments:. 
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
………………………………………………………………………………… 
Question 5h: Are there any additional actions or changes to existing actions which
can be taken through the Delivery Plan to benefit socio-economic equality?
• Yes
• No
• Unsure 
If yes, please provide any comments:
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………
Question 5i:  Do you think that any of the provisions in the SBS or Delivery Plan, will
have any adverse impacts on people with protected characteristics?
• Yes
• No
• Unsure 
If yes, please provide any comments:
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
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Question 5j: Are there any additional actions or changes to existing actions which
can be taken through the Delivery Plan to benefit people with protected
characteristics?
• Yes
• No
• Unsure 
If yes, please provide any comments:
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………
Question 5k:  Do you think that any of the provisions in the SBS or Delivery Plan,
will have any adverse impacts on island communities? 
• Yes
• No
• Unsure 
If yes, please provide any comments:
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………
Question 5l:  Are there any additional actions, or changes to existing actions, which
can be taken through the Delivery Plan to ensure that there are no adverse effects
for Island communities? 
• Yes
• No
• Unsure 
If yes, please provide any comments:
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
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Question 5m:  Do you think that any of the provisions in the SBS or Delivery Plan,
will have any adverse impacts on child rights and wellbeing? 
• Yes
• No
• Unsure 
If yes, please provide any comments:
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………
Question 5n: Are there any additional actions or changes to existing actions which
can be taken through the Delivery Plan to benefit child rights and wellbeing?
• Yes
• No
• Unsure 
If yes, please provide any comments: 
Use this Delivery plan to strengthen curriculum links and outdoor learning – funding
to improve outdoor learning environments 
Section Six – Statutory Targets for Nature Restoration
Question 6a: Do you agree with this approach to placing targets on a statutory
footing? 
• Yes
• No
• Unsure 
Please explain the reasons for your response: 
• Very much welcome this approach and agree need for targets to drive action,
however significant additional resources would be required at local
government level for staffing and delivery. 
• There needs to be legislative footing to ensure long term success. 
• Investment and accountability are key for deliverability, this can be assured
through statutory targets 
• Also a need for more urgency in the interim as 2030 extremely close (for
example still no metric for biodiversity enhancement) so vital years will be lost
during this crucial decade. 
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Question 6b: Do you agree with the criteria set out for the selection of targets? 
• Yes
• No
• Unsure 
Please explain the reasons for your response: 
Alignment across policy areas essential, as is improving the understanding and
application of multiple or co-benefits that are wider. Health and education are key
areas that could have synergistic targets. 
Question 6c:  Do you agree statutory targets should include a combination of
outcome targets and output targets? 
• Yes
• No
• Unsure 
Please explain the reasons for your response: 
• Input targets have been a challenge on local authority level – extremely short
timescales for Nature Restoration Funding have limited quality outcomes. So
presume a combination would help resolve this issue, but would need to be
combined with greatly extended and more flexible grant terms so that projects
can be planned and based on evidence rather than whatever can be done in a
short timescale during the particular season available.
• A positive example of how this could work is the Town centre improvement
funding which brings longer term funding certainty with a split between
revenue and capital (25%/75%) over 10 year period. 
Question 6d: Is the list of potential target topics sufficiently comprehensive in
terms of the focus of proposed target areas and overall scope?  
• Yes
• No
• Unsure 
Please explain the reasons for your response. If you answered “No”, please provide
details of any target topics which you think are missing from the list.
Good list, covers broad measures but public awareness, education etc also need
targets - 
‘Engage and strengthen the connection between people and communities and
nature’ and ‘Embed biodiversity and nature in curriculum development’ could be
harder to quantify but it’s important these have targets and are supported by
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16 
legislation with a system to monitor. Contribution of school playgrounds to the other
target topics, and link to nature based skills sector and employment/ training
statistics could work?   
Question 6e: Do you have any other comments on the list of potential target
topics?
• Yes
• No 
If you answered “Yes”, please provide your comments below.
…………………………………………………………………………………………………
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Question 6f: Do you agree with the proposal to have the smallest feasible
number of targets which reflects the complexity of nature restoration? 
• Yes
• No
• Unsure 
Please explain the reasons for your response:
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
………………………………………………………………………………… 
Question 6g: Do you agree statutory targets should align with the 2030 and
2045 timescales set out in the Strategy? 
• Yes
• No
• Unsure 
Please explain the reasons for your response:
Agree with approach, but there is a need for urgency to address biodiversity decline,
especially through planning and other complex delivery mechanisms.   
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Question 6h: Do you agree the Bill should allow for the review of statutory
targets? 
• Yes
• No
• Unsure 
Please explain the reasons for your response: 
The bill should include flexibility to ensure targets are reviewed and updated, when
required. This needs to be driven by science constantly improving and changing 
Question 6i: Do you agree that reporting on targets should align with existing
Biodiversity reporting requirements? 
• Yes
• No
• Unsure 
Please explain the reasons for your response: 
Public bodies are key to delivering much of the delivery plan and targets will help
ensure that biodiversity duties are fulfilled consistently and contribute to delivering
the national strategy provided sufficient funding is made available to local authorities
for this purpose.     
Question 6j: Do you agree that an Independent Review Body is needed to
report on Government’s progress in meeting the statutory targets? 
• Yes
• No
• Unsure 
Please explain the reasons for your response:
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
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Section Seven – National Parks
Question 7a: Do you agree that the purpose of National Park authorities
should be amended in order to emphasise the important leadership role that
National Park authorities need to play in restoring nature and in mitigating and
adapting to climate change?
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• Agree
• Partially agree
• Partially disagree
• Disagree
• Don’t know 
Please explain the reasons for your response:
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………
Question 7b: Do you agree with these suggested changes to the first National
Park aim? 
• Agree
• Partially agree
• Partially disagree
• Disagree
• Don’t know 
Please explain the reasons for your response:
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………
Question 7c: do you agree with the suggested change to the second National
Park aim? 
• Agree
• Partially agree
• Partially disagree
• Disagree
• Don’t know 
Please explain the reasons for your response:
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
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…………………………………………………………………………………………………
………………………………………………………………………………… 
Question 7d: Do you agree with the suggested change to the third National
Park aim? 
• Agree
• Partially agree
• Partially disagree
• Disagree
• Don’t know 
Please explain the reasons for your response:
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
………………………………………………………………………………… 
Question 7e: Do you agree with the suggested change to the fourth National
Park aim? 
• Agree
• Partially agree
• Partially disagree
• Disagree
• Don’t know 
Please explain the reasons for your response:
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
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Question 7f: Do you agree that the National Park ‘principle’ set out in section
9(6) of the 2000 Act should be retained? This would mean that, if there is a
conflict between the National Park aims, greater weight should be given to the
first aim which would seek to protect, restore and enhance the natural assets,
biodiversity and ecosystems within the National Park. 
• Agree
• Partially agree
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20 
• Partially disagree
• Disagree
• Don’t know 
Please explain the reasons for your response:
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
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Question 7g: Do you agree that public bodies operating within the National
Park should have regard to the proposed National Park aims? 
• Agree
• Partially agree
• Partially disagree
• Disagree
• Don’t know 
Please explain the reasons for your response:
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
………………………………………………………………………………… 
Question 7h: Do you agree that public bodies operating within the National
Park should have regard to the National Park principle? 
• Agree
• Partially agree
• Partially disagree
• Disagree
• Don’t know 
Please explain the reasons for your response:
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
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…………………………………………………………………………………………………
………………………………………………………………………………… 
Question 7i: Do you agree that the duty on public bodies operating within
National Parks should be strengthened so they have an obligation to support
and contribute to the implementation of National Park Plans rather than having
regard to these plans? 
• Agree
• Partially agree
• Partially disagree
• Disagree
• Don’t know 
Please explain the reasons for your response:
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
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Question 7j: Do you agree with the proposal that National Park Authorities
should be able to enforce byelaw breaches within National Parks by issuing
fixed penalty notices rather than referring them to local Procurators Fiscal? 
• Agree
• Partially agree
• Partially disagree
• Disagree
• Don’t know 
Please explain the reasons for your response:
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
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Question 7k: Do you think that any other changes should be made to the
general powers of National Park authorities? 
• Agree
• Partially agree
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• Partially disagree
• Disagree
• Don’t know 
Please explain the reasons for your response:
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
………………………………………………………………………………… 
Question 7l: Do you agree with the proposed changes to the governance of
National Parks? 
• Agree
• Partially agree
• Partially disagree
• Disagree
• Don’t know 
Please explain the reasons for your response:
………………………………………………………………………………………………
………………………………………………………………………………………………
………………………………………………………………………………………………
………………………………………………………………………………………………
………………………………………………………………………………………………
……………………………………………………………………………………………… 
Question 7m: Do you have any other comments that you would like to make
about the aims, powers and governance of National Parks?
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
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Section Eight – Impact Assessments – Part B
Question 8a:  Do you think that any of the proposals in Part B, will have any
adverse impacts on human rights? 
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• Yes
• No
• Unsure 
If yes, please provide any comments:
…………………………………………………………………………………………………
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Question 8b:  Are there any additional actions, or changes to existing actions, which
can be taken through the proposals in Part B to ensure that there are no adverse
effects for people’s human rights?  
• Yes
• No
• Unsure 
If yes, please provide any comments:
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
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Question 8c:  Do you think that any of the proposals in Part B, will have any
adverse impacts on people with protected characteristics?
• Yes
• No
• Unsure 
If yes, please provide any comments:
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
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Question 8d: Are there any additional actions or changes to existing actions which
can be taken through the proposals in Part B to benefit people with protected
characteristics?
• Yes
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• No
• Unsure 
If yes, please provide any comments:
…………………………………………………………………………………………………
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…………………………………………………………………………………………………
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Question 8e: Do you think that any of the proposals in Part B will have any adverse
effects on socio-economic equality? 
• Yes
• No 
• Unsure 
If yes, please provide any comments: 
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
………………………………………………………………………………… 
Question 8f: Are there any additional actions or changes to existing actions which
can be taken through the proposals in Part B to benefit socio-economic equality?
• Yes
• No
• Unsure 
If yes, please provide any comments:
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
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Question 8g:  Do you think that any of the proposals in Part B, will have any
adverse impacts on island communities? 
• Yes
• No
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• Unsure 
If yes, please provide any comments:
…………………………………………………………………………………………………
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…………………………………………………………………………………………………
…………………………………………………………………………………………………
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Question 8h:  Are there any additional actions, or changes to existing actions, which
can be taken through the proposals in Part B to ensure that there are no adverse
effects for Island communities?  
• Yes
• No
• Unsure 
If yes, please provide any comments:
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………
Question 8i:  Do you think that any of the proposals in Part B, will have any adverse
impacts on child rights and wellbeing? 
• Yes
• No
• Unsure 
If yes, please provide any comments:
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
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Question 8j: Are there any additional actions or changes to existing actions which
can be taken through the proposals in Part B to benefit child rights and wellbeing?
• Yes
• No
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• Unsure 
If yes, please provide any comments:
…………………………………………………………………………………………………
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…………………………………………………………………………………………………
…………………………………………………………………………………
Question 8k: Do you think that any of the proposals in Part B will have any adverse
effects on business? 
• Yes
• No 
• Unsure 
If yes, please provide any comments: 
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
………………………………………………………………………………… 
Question 8l: Are there any additional actions or changes to existing actions which
can be taken through the proposals in Part B to benefit business?
• Yes
• No
• Unsure 
If yes, please provide any comments:
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………
Question 8m: What are your views on the accuracy and scope of the environmental
baseline set out in the environmental report?
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
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…………………………………………………………………………………………………
………………………………………………………………………………… 
Question 8n: What are your views on the predicted environmental effects as set out
in the environmental report?
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
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Question 8o: What are your views on the reasonable alternatives as set out in the
environmental report?
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Question 8p: What are your views on the proposals for mitigation and monitoring of
the environmental effects set out in the environmental report?
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REPORT TO: ECONOMIC DEVELOPMENT AND INFRASTRUCTURE
SERVICES COMMITTEE ON 14 NOVEMBER 2023 
SUBJECT: PUBLIC SECTOR CLIMATE CHANGE REPORTING 
BY:  DEPUTE CHIEF EXECUTIVE (ECONOMY, ENVIRONMENT AND
FINANCE) 
1. REASON FOR REPORT 
1.1 To inform the Committee of the Council’s Public Sector Report on Compliance
with Climate Change Duties 2022/23 and updates to the reporting
methodology and statutory duties. 
1.2 This report is submitted to Committee in terms of Section III (F) (33) of the
Council's Scheme of Administration relating to reviewing or preparing a
Climate Change Strategy to provide framework for actions aimed at reducing
carbon emissions and actions to restore biodiversity. 
2. RECOMMENDATION 
2.1 It is recommended that Committee: 
i) considers and notes the Council’s Public Sector Report on
Compliance with Climate Change Duties 2022/23; and 
ii) considers and notes updates made to the reporting methodology
for 2022/23 and statutory duties. 
3. BACKGROUND 
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. 
Item 10
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3.3 The Council submitted the first mandatory report on 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 as due to be submitted to the Scottish Government by 30
November 2023 has been uploaded to the Committee Management
Information System (CMIS) and is available as an additional meeting
document. 
4.2 A data error discovered within a waste dataset led to the Council’s carbon
emissions for the previous reporting year being understated by 74.5 tonnes of
carbon dioxide equivalent (tCO2e). The Council’s carbon emissions for
reporting year 2021/22 were therefore 24,565 tCO2e. Officers will update the
Scottish Government regarding this error alongside this year’s statutory
reporting. 
4.3 In 2022/23, the Council’s recorded carbon emissions were 25,565 tonnes of
carbon dioxide equivalent (tCO2e) – an increase of 1,000 tCO2e (4.1%)
compared to reporting year 2021/22.  A summary of changes by emissions
source, illustrating how emissions have changed between the reporting years
is provided in Appendix 1. Many of the increases in carbon emissions during
this reporting year are Scope 3 type emissions. Scope 3 emissions are
indirect emissions of the Council from within its value chain. Whilst not all
Scope 3 emissions are included within the Council’s 2030 net zero target, it
continues to have a statutory duty to monitor, record and reduce these
emissions.
4.4 The increase in the Council’s recorded carbon emissions during 2022/23 is
principally the result of a significant return to ‘business as usual’ working
practices across the organisation following the Covid-19 pandemic.  This trend
has surpassed forecasted expectations and next steps will be discussed as
part of the update to the Council’s Climate Change Plan and Routemap to Net
Zero Emissions.
4.5 2022/23 was the first year that emissions associated with staff commuting to
and from Council premises have been reported.  This represented a carbon
increase of 1,658 tCO2e.  This emission source is calculated based on results
of the Council’s annual staff travel survey, as well as an audit of vehicles
within staff car parks. It is envisaged that further increases in this emission
source will occur within the next reporting year as actions to maximise building
occupancy progress but will represent a saving on fully office based
scenarios. 
4.6 Diesel and petrol consumption has increased, in part due to greater use of
pool vehicles for business travel.  A change in legislation has required the use
of diesel instead of gas oil in plant and machinery which has also contributed
to this increase, though this is partially offset by a decrease in gas oil
emissions.
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4.7 Increased corporate travel bookings through a return to in-person meeting
arrangements has also contributed to an increase in emissions.  Grey fleet
mileage (personal vehicles used for business purposes), hotel stays, short-
haul flights and rail journeys have led to a collective increase of 193 tCO2e.
This increase was to be expected as we returned to new hybrid patterns of
working but with increased business activity requiring travel. The Council’s
Travel Plan Steering Group will discuss this issue and potential solutions on
23 November 2023.
4.8 The highest number of full time equivalent (FTE) staff employed during the
2022-23 financial year was 3,800, an increase of 38 FTE since the previous
report.  This is not considered to be a significant variance.  This figure is used
to calculate the carbon emissions resulting from homeworking. 
4.9 The methodology for calculating homeworking emissions has now changed
nationally, taking account of hybrid working patterns which are now more
\clearly defined. This source represented carbon emissions of 7.6 tCO2e,
calculated using the new national emissions multiplier of 0.34075 kgCO2e per
FTE working hour (estimated).
4.10 Several energy saving projects and initiatives were carried out in 2022/23: 
• LED lighting replacement;
• Water tap replacements;
• Boiler replacements;
• Heating controls updated. 
These changes represented an estimated carbon saving of 3.4 tCO2e. 
4.11 The Council’s annual procurement report highlights the number of contracts
with environmental/climate change conditions attached. This included 26
contracts in the reporting year, broken down by conditions as follows: 
• 7 x energy;
• 11 x greenhouse gases;
• 5 x waste; and
• 3 x sustainable construction. 
4.12 All of the data used within the submission was obtained from previous
compliance reports and from sections within the Council which collect data as
part of their operational functions.  In some cases, data used within the
submission has been the basis for papers approved by Council committees. 
4.13 To ensure the accuracy and reliability of the reporting, it is important that the
data and information used is validated.  From this reporting year, officers have
arranged with colleagues in Aberdeenshire Council to conduct mutual external
peer-review of the reporting dependent on workload capacity in respective
teams.
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5. NEXT STEPS 
5.1 The data collected as part of the Public Bodies Climate Change Reporting will
be used to inform updates to the Council’s Climate Change Plan and
Routemap to Net Zero which will be reported to a meeting of this Committee
in spring 2024. 
5.2 In the meantime, the Committee should be aware that the continuing trend of
returning to a ‘business as usual’ working practice is a risk to the Council in
terms of achieving its own and subsequent national statutory emissions
targets.  The Council’s climate change officers have worked alongside key
services to consider what measures would be most helpful and achievable to
address this situation. 
5.3 Emissions from fossil fuel based heat sources continue to represent a
significant proportion of the Council’s carbon emissions.  Taking all steps to
decarbonise building heating systems is necessary to achieving local and
national net zero targets. 
HEAT IN BUILDINGS
5.4 Under the Heat Networks (Scotland) Act 2021, the Council now has a
statutory duty to produce a building assessment report for each of its buildings
to check if they are suitable to connect to a heat network.  The reports will
provide important data for heat network zoning by highlighting opportunities
where buildings can reasonably benefit from low carbon district heating. 
5.5 The data collected can then be used to develop heat network zones, which
are areas where there is a high concentration of buildings that could be
connected to a heat network.  This can help to make heat networks more
cost-effective and efficient, and can also encourage investment in local heat
network projects. 
5.6 The heat network reports will be produced and submitted to the Scottish
Government by the Council’s climate change and energy officers as soon as
reasonably practicable and thereafter at intervals of five years in line with the
statutory duty. 
6. FUTURE REPORTING 
6.1 The Council will continue to be required to publish annual climate change
reports as per the Climate Change (Duties of Public Bodies: Reporting
Requirements) (Scotland) Order 2015 and Climate Change (Duties of Public
Bodies: Reporting Requirements) (Scotland) Amendment Order 2020.  This
statutory reporting will be fulfilled by the Council’s climate change officers. 
6.2 Officers working across the Council will therefore continue to have a
responsibility to provide all necessary information required for submission as
part of the statutory annual climate change reporting.
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6.3 Data collected for the purposes of annual climate change reporting including
areas showing increases will continue to be used to inform updates to the
Council’s Climate Change Action Plan and Routemap to Net Zero Carbon
Emissions. 
7. SUMMARY OF IMPLICATIONS 
(a) Corporate Plan and 10 Year Plan (Local Outcomes Improvement
Plan (LOIP))
This reporting demonstrates the Council’s progress in contributing to
Scotland’s ambitious greenhouse gas emissions targets. 
The Council’s Corporate Plan 2019-2024 identifies the environment as a
key principle in the delivery of the Council’s priorities: 
“Environment – look after the world we live in to protect it for our future” 
and for Moray Council to be: 
“A resource efficient, carbon neutral council that works with partners to
mitigate the worst effects of Climate Change, to create a resilient, fair
and more sustainable future for everyone within Moray”. 
(b) Policy and Legal
The Climate Change (Scotland) Act 2009 places a duty on public bodies
to act in the way best calculated to contribute to the delivery of
Scotland’s climate change targets; in the way best calculated to help
deliver any programme for climate change adaptation laid before the
Scottish Parliament; in a way it considers most sustainable. 
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. 
(c) Financial implications
There is potential for significant financial cost to the Council to offset
carbon emissions in the future which is being considered as part of the
Climate Change Routemap progress reporting. 
(d) Risk Implications
There is a risk that avoidable financial costs could be incurred by the
Council in the future if actions are not taken to reduce carbon emissions.
The approach to this is being monitored through Climate Change
Routemap Updates. 
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(e) Staffing Implications
There are no staffing implications. 
(f) Property
There are no property implications. 
(g) Equalities/Socio Economic Impact
There are no equalities/socio economic impact implications. 
(h) Climate Change and Biodiversity Impacts
The recommendations within this report are intended to reduce the
Council’s carbon emissions. The upcoming revision to the Council’s
Climate Change Action Plan & Routemap to Net Zero document will
include updated emissions forecasting and actions, taking account of the
data and recommendations arising from this report. 
(i) Consultations
The Depute Chief Executive (Economy, Environment and Finance), the
Head of Economic Growth and Development, the Corporate
Management Team, the Legal Services Manager, the Energy Officer, the
Equal Opportunities Officer, the Senior Organisational Development
Adviser, the Sustainable Travel Officer, the Senior Project Officer Active
Travel Strategy and the Democratic Services Manager. 
8. CONCLUSION 
8.1 The submission of the Public Sector Report on Compliance with Climate
Change Duties 2022/23 to the Scottish Government in November 2023
will fulfil the Council’s statutory climate change reporting obligation.
8.2 The Council will continue to be required to submit annual Public Sector
Reports on Compliance with Climate Change Duties.
8.3 Data collected for the 2022/23 submission reveals that a return to
‘business as usual’ has led to an increase in the Council’s carbon
emissions, and next steps are suggested to address this. 
Author of Report: George Gunn, Climate Change Officer
Background Papers: As referred to within this report.
Ref: 
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Emission source Type 2021/22 emissions (tCO2e) 2022/23 emissions (tCO2e) % Change Change (tCO2e)
Landfill gas kWh Scope 1 0.7                                               -                                               -100.00% -0.70
Clinical Waste - Other Scope 3 77.2                                             -                                               -100.00% -77.20
Gas oil litre Scope 1 278.3                                           0.1                                               -99.95% -278.17
Homeworking emissions Scope 3 1,128.5                                       7.6                                               -99.32% -1120.87
Mixed recycling Scope 3 16.0                                             1.6                                               -89.96% -14.39
Clothing (Closed loop recycling) Scope 3 10.7                                             1.7                                               -83.84% -8.97
Marine Fuel Oil litres Scope 1 111.8                                           56.0                                             -49.93% -55.82
Biomass (Wood Pellets) kWh Scope 1 15.0                                             7.6                                               -49.11% -7.37
Plastics (Average) Recycling Scope 3 15.4                                             8.3                                               -46.17% -7.11
WEEE (Mixed) Recycling Scope 3 24.0                                             17.5                                             -27.18% -6.52
Water - Treatment Scope 3 23.2                                             18.5                                             -20.19% -4.68
Gas oil kWh Scope 1 856.8                                           704.9                                           -17.73% -151.91
Metal Cans (Mixed) & Metal Scrap Recycling Scope 3 21.2                                             17.5                                             -17.24% -3.65
Organic Food & Drink Composting Scope 3 73.9                                             63.0                                             -14.73% -10.88
Glass Recycling Scope 3 70.1                                             60.2                                             -14.07% -9.86
Water - Supply Scope 3 11.7                                             10.3                                             -12.32% -1.44
Natural Gas Scope 1 4,722.7                                       4,321.6                                       -8.49% -401.06
Grid Electricity (generation) Scope 2 2,909.8                                       2,670.6                                       -8.22% -239.22
Grid Electricity (transmission & distribution losses) Scope 3 257.5                                           244.3                                           -5.13% -13.20
Organic Garden Waste Composting Scope 3 83.2                                             81.0                                             -2.63% -2.19
Paper & Board (Mixed) Recycling Scope 3 93.4                                             91.3                                             -2.23% -2.08
Biomass (Wood Chips)kWh Scope 1 20.2                                             20.3                                             0.32% 0.1                       
Refuse Commercial & Industrial to Landfill Scope 3 2,335.8                                       2,438.9                                       4.41% 103.1                  
Refuse Municipal to Landfill Scope 3 8,110.2                                       8,802.2                                       8.53% 692.0                  
Petrol (average biofuel blend) Scope 1 27.7                                             30.4                                             9.64% 2.7                       
Diesel (average biofuel blend) Scope 1 3,001.3                                       3,770.3                                       25.62% 769.0                  
Grey fleet (average car) mileage Scope 3 263.8                                           423.3                                           60.48% 159.5                  
Short-haul flights (Economy class) Scope 3 1.7                                               2.9                                               71.59% 1.2                       
Hotel stays - UK Scope 3 1.9                                               3.6                                               88.84% 1.7                       
Rail (National Rail) Scope 3 0.9                                               31.0                                             3349.61% 30.1                     
Staff commuting emissions Scope 3 Not previously reported 1,658.0                                       n/a 1,658.0               
TOTALS: 24,565                                        25,565                                       
Item 10
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REPORT TO:   ECONOMIC DEVELOPMENT AND INFRASTRUCTURE
SERVICES COMMITTEE ON 14 NOVEMBER 2023 
SUBJECT: INDUSTRIAL PORTFOLIO ANNUAL REPORT 2022/23 
BY:  DEPUTE CHIEF EXECUTIVE (ECONOMY, ENVIRONMENT
AND FINANCE) 
1. REASON FOR REPORT 
1.1 This report sets out the annual performance of the Council’s Industrial
Portfolio in 2022/23 and seeks approval in principle for a related sale of
property. 
1.2 This report is submitted to the Committee in terms of Section III A (3) of the
Council’s Scheme of Administration relating to the acquisition or sale of
property up to a value of£100,000. 
2. RECOMMENDATION 
2.1 It is recommended that the Committee:- 
(i) considers and notes the Annual Report for 2022/23; 
(ii) welcomes the good performance of the Council’s Industrial
Portfolio; and 
(iii) agrees in principle to the sale of the property in Lossiemouth as
detailed in paragraph 6.3 of this report. 
3. BACKGROUND 
3.1 The Council’s industrial portfolio comprises a range of industrial land and
buildings throughout Moray including all of the principal settlements.  At 31
March 2023, the Council’s industrial portfolio comprised 174 industrial
buildings with a total floor area of 29,664m²; 130 development and ground
leases with a total site area of 21.81 hectares and a stock of serviced and
unserviced land for future development totalling 18.6 hectares.  The
distribution of industrial buildings, industrial sites and development land in
Moray is detailed in APPENDIX I.
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3.2 Annual reports have been presented to Committee since 2002; the last report
was presented to the Economic Development and Infrastructure Committee
on 6 September 2022 as an information report.  This report is submitted as
the Council’s Annual Industrial Portfolio Report for 2022/23, providing a
summary of the portfolio’s performance and main issues, but is on the main
agenda given recommendation (iii). 
4. PERFORMANCE  
Rental Income
4.1 The total gross rental income for the past 6 years is set out below:- 
2017/2018  £1,756,000
2018/2019  £1,930,000 
2019/2020  £1,954,000
2020/2021  £1,940,000
2021/2022  £2,066,000
2022/2023  £2,085,000  
4.2 Rental income was impacted by the Covid lockdown in 2020/21 and there was
considerable uncertainty over the medium/long term impact on the portfolio.
However, the portfolio has recovered well and rental income continues to
grow – increasing by £19,000 in 2022/23 and exceeding the target of
£2,023,000 by £62,000. Rental growth in 2022/23 was restricted by the sale of
properties and difficulties encountered by a number of tenants that survived
the Covid lockdowns, but did not fully recover, resulting in more turnover of
tenants than usual. 
4.3 The portfolio’s annual income has increased by £895,000 over the last 10
years and APPENDIX II illustrates the gross rental income generated by the
industrial portfolio over the period 2012/13 to 2022/23.   
4.4 The net rental income after deduction of property running costs, staff,
administrative and capital financing costs in 2021/22 was £1,390,000. This is
a decrease of £30,000 from 2021/22 - due to cost increases including staff
wages, energy costs, non-domestic rates costs and greater use of external
solicitors due to in house staff shortages. APPENDIX II illustrates the net
rental income generated by the industrial portfolio over the period this has
been recorded - 2013/14 to 2022/23. 
4.5 It is very difficult to compare the rental of the industrial portfolio objectively
over a number of years as its composition changes due to the sale of
properties, addition of new properties and the refurbishment and repair of
existing properties.  However, APPENDIX III demonstrates how increases in
rental achieved at rent review for industrial premises (3 yearly rent reviews)
and for industrial sites (5 yearly rent reviews) compare to the Consumer
Prices Index (CPI) over the corresponding periods. 2022/23 was the first year
recorded that the rise in the CPI outstripped rents, reflecting a dramatic
increase in the CPI.  
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Debt
4.6 Debt increased significantly due to the impact of the coronavirus on tenants
and the Estates team has deployed considerable resources (working
corporately with Legal Services and Finance) to work with tenants to minimise
arrears. A range of measures are used to safeguard the Council’s interests if
discussions with tenants fail to reach satisfactory outcomes. 
4.7 Progress has been made and the level of rent/insurance arrears was 4.42% at
31 March 2023, down from 6.71% at 31 March 2021.   
The % debt on this basis for the last six years is as set out below:- 
2017/18 - 4.66%
2018/19 - 6.99%
2019/20 -  7.06%
2020/21 - 8.7%
2021/22 - 6.71%
2022/23 - 4.42% 
Occupancy
4.8 The occupancy levels of Council industrial buildings in recent years are set
out below:- 
Year % of floorspace occupied % of buildings occupied
2017/18 94.4% 92.7%
2018/19 83.57%* 93.18%
2019/20 93.54% 95.48%
2020/21 88.84% 93.71%
2021/22 92.45% 92.57%
2022/23 90.19% 88.51% 
* The floor area occupancy figures for 2018/19 were skewed as a result of the
former sawmill at Waterford Circle in Forres (which was by far the largest in
the portfolio) becoming vacant. 
4.9 At 31 March 2023 the occupancy rate in terms of buildings occupied was
88.51% compared to the target of 80%. 
4.10 As stated at paragraph 4.2 above there was more turnover of tenants than
usual in 2022/23 due to difficulties encountered by a number of tenants that
survived the Covid lockdowns, but did not fully recover.   
Capital Receipts
4.11 The sale of industrial land and buildings has generated capital receipts to the
Council over the past 6 years as follows:- 
2017/18 -   £70,500
2018/19 -  £0
2019/20 -   £417,000
2020/21 -   £605,250
2021/22 -  £23,900
2022-23 -  £320,125  
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4.12 The following properties, which were identified in the 2021/22 annual review of
the portfolio as suitable for sale, were disposed of in 2022/23 - 2 Dufftown
Industrial Estate, 9 Linkwood Place, Elgin and Land at March Road West,
Buckie.   
Development
4.13 In recent years the Council has invested in general upgrading works to the
Industrial Portfolio to ensure the properties remain responsive to future
business needs.  During 2022/23, the Council invested £67,000 of revenue
and £39,000 of capital in the Industrial Portfolio and in supporting industrial
development across Moray through a range of projects including roof repairs,
electrical repairs/upgrades, new fencing, new doors, foul water
repairs/upgrades, estate road repairs, exterior painting and design work to
create new yards for let. 
4.14 Refurbishment works ensure properties continue to meet business needs and
safeguard future rental income.  Officers will continue to work with tenants on
the most appropriate ways to deliver improvements to properties, including
agreeing where appropriate for tenants to do works in return for
commensurate temporary reductions in rental, or capital payments. 
4.15 Whilst the revenue repairs budget is sufficient at present to meet ongoing
repairs and maintenance needs, as the portfolio expands and the newer units
age, there will likely be a future requirement to increase the revenue repairs
budget. 
5. TRENDS AND CHALLENGES 
Coronavirus
5.1 The coronavirus pandemic and associated restrictions had adverse impacts
on the majority of tenants.  All bar a few suspended trading during the first
national lockdown from 23 March 2020 until mid July 2020 and many
continued to experience trading difficulties thereafter. 
5.2 The level of rental debt increased significantly during the first lockdown and
officers worked closely with tenants to agree phased repayments. As shown
at paragraph 4.7 above, the portfolio’s debt has reduced, as most tenants
managed to make phased repayments. Officers have closely monitored the
impact of the phasing out of government Covid support packages and
continued to work closely with a number of tenants struggling to recover.   
5.3 There was a greater level of lease terminations than usual in 2022/23 which
was partly due to tenants who failed to fully recover from Covid ceasing to
trade. 
Economy
5.4 There is continuing global and national uncertainty surrounding the war in
Ukraine and recovery from the Covid-19 pandemic.  Despite nationally low
growth and high inflation, the Moray commercial property market is
considered to be currently stable, but officers will continue to monitor closely
any impacts on local businesses and knock on effects for the industrial
portfolio. Fears of weaker demand, increased voids, increased debt levels and
pressure on rents have so far not materialised locally - there is currently good
demand for units and rentals have continued to increase. 
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Supply of Properties
5.5 Although for decades there has been very little private sector provision of
industrial property to let in Moray, 36 units for speculative let were completed
by private developers in Elgin in the last 3 years.  These have been facilitated
by public sector investment in infrastructure to provide serviced sites.  Officers
are aware that a number remain vacant, indicating that there are sufficient
units (if not an oversupply) in the town. Officers will continue to monitor the
situation and take account of this in assessing future property needs and
impact on occupation and rentals of Council properties. 
5.6 Elgin Business Park was developed by Saltire Properties with infrastructure
funding assistance from Highlands and Islands Enterprise to meet a shortage
of industrial development land in the town. The Park has been very successful
and very few sites remain available. This reflects pent up demand from
businesses seeking to invest in developing their own bespoke premises,
which were previously frustrated by the lack of suitable sites. The Council’s
Employment Land Audit 2023 (which was informed by a Property Needs
Study by Ryden Property Consultants) states that due to the take up of sites
at Elgin Business Park it is anticipated that the level of immediately available
land in Elgin will reduce significantly over the next few years and bringing
forward and servicing new sites will be critical to maintaining supplies. 
5.7 The Employment Land Audit also highlights significant shortages of general
industrial land in Speyside and Forres that requires to be urgently addressed.   
5.8 In 2022/23 the industrial portfolio continued to meet its objectives of:- 
(i) minimising the number of vacant properties as far as is consistent with
current market conditions; and 
(ii) maximising overall rental income and thereby minimising the cost of the
service. 
5.9 However, there remain concerns about a shortage of industrial development
land and units in various locations and it is very unlikely that the private sector
will invest given the relatively high risks and low returns on capital costs. 
5.10 The following actions by the Council are aimed at addressing supply issues:- 
(i) a major extension of March Road Industrial Estate in Buckie has
provided a supply of industrial development land in East Moray;  
(ii) officers continue to work with private developers to facilitate the provision
of new business units; 
(iii) officers are trying to identify potentially suitably sites as part of work on
the next Moray Local Development Plan (which has begun), for
medium/long term development by the public and /or private sector;
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(iv) potential further opportunities to acquire and develop land and buildings
will be considered as part of the Council’s asset management
rationalisation programme. A review of the Council’s depot and storage
properties is expected to be presented to this committee meeting, which
will include identifying opportunities to relocate Council services currently
occupying industrial portfolio property; and 
(v) existing properties will be repaired and refurbished as required. 
Expansion of the Portfolio
5.11 Officers have investigated options/opportunities to expand the portfolio to
address shortages of available property and generate additional rental income
to the Council. These are summarised below. 
5.12 Forres – working in partnership with Highlands and Islands Enterprise (HIE) it
was proposed to purchase and develop land zoned for industrial purposes on
the outskirts of Forres with a view to creating a new industrial estate and
expansion of the adjacent Business Park. The landowners were willing in
principle to sell the land.  However, HIE withdrew from the project citing
budgetary pressures. Site investigations revealed large areas of peat and clay
and these factors, combined with general construction cost inflation, mean the
project is not financially viable at present. 
5.13 Speyside – despite extensive efforts over many years no suitable sites have
been identified. Recently, officers investigated a potentially suitable site in
Speyside with a view to the Council purchasing land and providing serviced
sites and business units. However, access difficulties, abnormal site specific
development costs, combined with general construction cost inflation, mean
the project is not financially viable at present. 
5.14 Buckie - the Council’s 20 industrial units in Buckie have been virtually fully let
for a number of years. When tenants vacate buildings they are readily re-let
and it is expected that demand will increase due to Buckie’s development as a
base for offshore wind operations creating supply chain opportunities. Officers
investigated proposals to build more small units on Council owned land at
Rathven Industrial Estate. However, construction cost increases mean the
project is not financially viable at present. 
5.15 Officers will continue to investigate any opportunities for expansion of the
portfolio, albeit it is unlikely that any financially viable projects will be
forthcoming in the short term at least. 
5.16 Any proposals for funding future development of the Industrial Portfolio will be
brought forward through the Council’s asset management, capital planning
and economic development capital fund processes.   
Age and Condition
5.17 A significant amount of the portfolio was provided during the 1960s and 1970s
and condition surveys circa 2009 identified significant amounts of backlog
maintenance/repair. Although tenants are obliged to carry out some of the
outstanding repairs/maintenance where their lease includes an obligation to
maintain and repair the property, some of the outstanding works, particularly
those of an inherent nature, due to the age of the property require to be
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addressed by the Council. The Council pursued a refurbishment programme
over several years to ensure properties continued to meet the needs of
businesses. The works carried out were predominantly to the fabric of the
properties – replacing roofs and windows, as well as estate road upgrades.   
5.18 Further condition surveys have been delayed due to staffing shortages. 
However, officers are aware that the electrical systems in many units are
dated and a prioritised programme of upgrades is now being implemented.     
Rentals
5.19 The rental generated by the industrial portfolio continued to grow in 2022/23,
but as predicted in last year’s annual report this was tempered by the sale of
rental generating properties and a residue of Covid impacted tenants. As also
forecast in last year’s annual report, inflation outstripped rental growth in
2022/23 for the first time since the initial Annual Industrial Report in 2002. As
is illustrated in APPENDIX III this was due to the dramatic rise in the
Consumer Price Index rather than changes in rental growth trends. 
5.20 Barring an unforeseen change in circumstances, the rent of the industrial
portfolio is expected to continue to grow in 2023/24. 
5.21 In Elgin, the construction by the private sector of 36 new units has not
materially impacted demand and rents for the Council’s properties in the town.   
Occupation of Industrial Portfolio Properties by Council Services
5.22 At 31 March 2023, 12 of the Council’s properties were occupied by Council
services, which is contrary to the objectives of the portfolio to maintain an
adequate supply of affordable premises in appropriate locations within Moray
and maximise overall rental income. However, the vast majority of these
properties are within the scope of the current review of Council depots and
stores being taken forward by the Head of Housing and Property and it is
planned that where opportunities arise officers will seek to relocate Council
services to free the properties for letting to private enterprises. 
5.23 Occupation of industrial units by Council services has occurred in a piecemeal
fashion over many years. In order to take a strategic asset management
approach any new requests by Council services will be considered by the
Asset Management Working Group.   
Energy Efficiency
5.24 Since 2018 in England and Wales there has been a prohibition on letting
properties with Energy Performance Certificates (EPCs) worse than E ratings. 
In 2018 the Scottish Government consulted on draft proposals to make non-
domestic properties more energy efficient and further consultations were
delayed due to the coronavirus.  It is unclear at this stage if proposals will be
targeted at CO2 producing heating systems of which there are 19 industrial
units, or impact more widely on the portfolio which has approximately 63 units
with heating systems. Officers will continue to monitor developments closely
whilst investigating cost effective means to comply.   
5.25 Officers are monitoring current Scottish Government consultations on revised
EPC methodology.  
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Mosstodloch Industrial Estate
5.26 This estate has suffered flooding on several occasions during periods of
exceptional rainfall, despite significant investment by the Council in upgrading
the surface water drainage system.  A major adjacent business has installed
various water/drainage alleviation measures, which have mitigated flooding at
this location. That business is seeking to expand its operations in
Mosstodloch, including comprehensive flood solutions within its proposals and
officers continue to liaise with the company.  
Budgetary
5.27 Budget pressures limited opportunities to further develop the portfolio for
several years, but recently monies, including additional funding for economic
recovery, were allocated in the Capital Plan. However, due to the difficulties
encountered with expansion proposals as detailed above, as well as the
Council’s financial pressures, the monies have been reprogrammed to future
years, when potential projects can be reviewed in terms of need, financial
viability and available budgets at that time.   
5.28 A number of industrial portfolio developments were funded with assistance
from the European Union.  The audit processes for a number of the funding
schemes have now been completed with the others due to be complete in the
next 1-2 years.  As such, conditions attached to European funded projects
may no longer apply and the Scottish Government will be consulted on a
case-by-case basis if any change of use of properties that were funded by the
2007- 2013 European funding programme are proposed. Opportunities to
potentially secure funding for industrial development from the UK Shared
Prosperity Fund, the Place Based Investment Fund and the Just Transition
Fund appear very limited.     
2023/24 Projects
5.29 Monies have been allocated in the current capital programme to carry out
condition surveys and for the refurbishment of the portfolio.  The condition
surveys have been delayed due to staff shortages, but meantime officers have
identified the following projects:- 
a) Create secure yards at Rathven Industrial Estate, Buckie.  
b) Upfill site at Chanonry Road North, Elgin.
c) Upgrade road, circulation and parking areas at 4-8 Chanonry Road South,
Elgin.
d) New fencing, gates and roller door at unit in Buckie.
e) Upgrading of yards at Waterford Circle and Greshop, Forres. 
f) Remove glass entrance atriums and create additional parking at various
units at Isla Bank Mills Industrial Estate, Keith.
g) Roof upgrades at Isla Bank Mills Industrial Estate, Keith.
h) Create new vehicular entrance to Unit F Isla Bank Mills Industrial Estate,
Keith.  
i) Lighting, windows and insulation upgrades at units at Isla Bank Mills
Industrial Estate, Keith. 
j) Electrical upgrades of various units.
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6. ANNUAL REVIEW 
6.1 Officers keep the performance of the portfolio and its constituent parts under
constant/ongoing review to ensure it continues to fulfil the objectives of the
Portfolio (as detailed in section 7 below) and give consideration to proposals
to maintain its ability to meet those objectives. 
6.2 The main criteria are income generation compared to costs/risks (such as
repairs, void periods and empty property rates) and potential to release
development value. 
6.3 A review of the portfolio has been carried out concluding that all the portfolio’s
constituent properties should be retained with the exception of the following
properties.   
• Rothes Industrial Estate – the estate comprised 2 small industrial
units and 2 site leases all of which had been leased to Forsyths
Engineering for many years, as well as a telecoms site lease. As
approved by the Economic Development and Infrastructure
Services Committee at its meeting on 7 February 2023 (para 20 of
the Minute refers) the Council sold the estate on 26 June 2023 to
Forsyths for £245,000. The rental income foregone is £16,200 per
annum. As these properties had been leased and occupied by
Forsyths for many years the sale will not impact on the availability
of commercial properties to let to small businesses in Speyside.
The sale of these properties was linked to the acquisition from
Forsyths, by the Council, of land at McLaren’s Brae, Buckie to
facilitate offshore wind farm operations at Buckie Harbour.     
• 7 Coulardbank Industrial Estate – this property is leased for five
years from 1 July 2021 at a rent of £28,800 per annum. The
tenant wishes to build an extension to facilitate business growth,
but would like greater security of tenure for his investment. It is
proposed that this Committee agrees in principle to officers
negotiating main terms with the tenant for a sale of the building,
conditional on a 99 year ground lease – with a view to reporting
provisionally agreed main terms to the Corporate Committee. 
7. SUMMARY OF IMPLICATIONS 
(a) Corporate Plan and 10 Year Plan (Local Outcomes Improvement
Plan (LOIP))
The management and development of the Industrial Portfolio supports
the LOIP priority of “a growing, diverse and sustainable economy” as
well as the priority of the Corporate Plan of promoting economic
development and growth.  It also accords with the aim of the Moray
Economic Strategy of facilitating economic growth and diversification of
the local economy.  
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(b) Policy and Legal
The policy objectives of the industrial portfolio are as follows:- 
a) To maintain an adequate supply of affordable premises in
appropriate locations within Moray;
b) To minimise the number of vacant properties as far as is consistent
with current market conditions; and
c) To maximise overall rental income and thereby minimise the cost of
the service. 
(c) Financial Implications
Gross rental income in 2022/23 was £2,085,000 and net rental income
£1,390,000. 
A number of revenue and capital works were delayed due to various
factors, including difficulties securing contractors and £138,000 of
capital has been carried forward into 2023/24.   
The allocations in Table 1 below have been made in the capital plan for
2023/24. 
Table 1
Item Monies
Serviced Sites Elgin £24,000
Road Upgrades £10,000
Refurbishments £164,000 
Revenue expenditure on repairs and maintenance is forecast to be
within the current budget of £70,185 in 2023/24. 
Proposals for future years’ capital developments will be taken forward
through the Council’s financial planning process. However, recent
assessments of potential development projects concluded that rental
income compared to construction costs, ongoing management costs
and risks, was insufficient, rendering the projects financially unviable.
The timescales for returns on investment are incompatible with the
Council’s current budgetary situation in an area where intervention is
discretionary. 
(d) Risk Implications
The main risks are detailed above in Section 5 of this report. 
(e) Staffing Implications
The Estates Team manages the Industrial Portfolio on behalf of the
Council.  Workload within the team is at capacity and timescales are
having to be extended on priority tasks.   
Any expansion of the industrial portfolio would require additional staff
resource. 
Legal Services staff continue to be involved in formalising lease
agreements and pursuing rent arrears where necessary. 
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(f) Property
The property implications are as detailed in this report. 
(g) Equalities/Socio Economic Impact
There are no equalities or socio economic issues arising from this
report. 
(h) Climate Change and Biodiversity Impacts
No climate change or biodiversity implications have been identified
relating to the recommendations of this report. 
(i) Consultations
The Head of Housing and Property Services, the Chief Financial
Officer, the Property Asset Manager, the Legal Services Manager, the
Head of Development Services, the Equal Opportunities Officer and
Caroline O’Connor, Committee Services Officer have been consulted
and their comments incorporated in this report as appropriate. 
Discussions continue to take place regularly with Highlands and
Islands Enterprise (HIE) to ensure a co-ordinated and complimentary
approach to property provision. HIE concentrates on the provision of
larger, higher specification/amenity properties, whereas the Council
focuses on smaller more general industrial properties. 
Officers continue to liaise regularly with private sector developers/
providers of industrial property. 
8. CONCLUSIONS 
8.1 The Industrial Portfolio exceeded targets for rental income and
occupancy in 2022/23.   
8.2 To ensure the portfolio continues to meet business needs a programme
of works is in place to improve the condition of the Council’s existing
industrial buildings.  The projects have been delivered within budget
and ensure the Council’s portfolio continues to meet business needs
and support economic development in Moray. 
Author of Report:  Stuart Beveridge, Asset Manager (Commercial Buildings)
Background Papers:  None
Ref: SPMAN-1285234812-1406 
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APPENDIX I
INDUSTRIAL PORTFOLIO ANNUAL REPORT 2022/23
ANALYSIS OF PORTFOLIO AS AT 31 MARCH 2023
Serviced Unserviced
Settlement No. Floor Area (m2) No. Total Area (Ha) (Ha) (Ha)
Elgin 65 9,807 72 9.99 0.67 0.94
Forres 24 3,008 15 3.61 0 0
Buckie 20 2,896 9 3.32 6.65 7.96
Keith 38 11,155 12 1.52 0.54 1.84
Lossiemouth 13 1,394 9 0.97 0.00 0.00
Other 14 1,405 13 2.40 0.00 0.00
TOTAL 174 29,664 130 21.81 7.86 10.74
ALL LET FUTURE
INDUSTRIAL BUILDINGS INDUSTRIAL SITES INDUSTRIAL DEVELOPMENT LAND
Item 11
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0
200
400
600
800
1000
1200
1400
1600
1800
2000
2200
2400
2008/09
2009/10
2010/11
2011/12
2012/13
2013/14
2014/15
2015/16
2016/17
2017/18
2018/19
2019/20
2020/21
2021/22
2022/23
Appendix II
Rental Income
Gross  Rental Income
Net Rental Income
Item 11
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APPENDIX IIIAnnualised Rental Growth
0.00
1.00
2.00
3.00
4.00
5.00
6.00
7.00
2011-12
%
Increase
3 Year Reviews
Rental
RPI
0.00
1.00
2.00
3.00
4.00
5.00
6.00
7.00
8.00
9.00
2011-12
%
Increase
5 Year Reviews
Rental
RPI
0.00
1.00
2.00
3.00
4.00
5.00
6.00
7.00
8.00
9.00
2009-10
2010-11
2011-12
2012-13
2013-14
2014-15
2015-16
2016-17
2017-18
2018-19
2019/20
2020/21
2021/22
2022/23
%
Increase
3 Year Reviews
Rental
RPI
0.00
2.00
4.00
6.00
8.00
10.00
12.00
14.00
16.00
18.00
2009-10
2010-11
2011-12
2012-13
2013-14
2014-15
2015-16
2016-17
2017-18
2018-19
2019/20
2020/21
2021/22
2022/23
%
Increase
5 Year Reviews
Rental
RPI
Item 11
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REPORT TO:   ECONOMIC DEVELOPMENT AND INFRASTRUCTURE SERVICES
COMMITTEE ON 14 NOVEMBER 2023 
SUBJECT:  ANNUAL REPORT ON ENERGY STRATEGY/ACTIONS 
BY:  DEPUTE CHIEF EXECUTIVE (ECONOMY, ENVIRONMENT AND
FINANCE) 
1.  REASON FOR REPORT 
1.1 This report sets out the annual energy and water performance of the Council’s
non-domestic building portfolio in 2022/23.
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 and Infrastructure Services. 
2.  RECOMMENDATION 
2.1 It is recommended that Committee:- 
(i) considers and notes the Annual Energy Report for 2022/23 set out in
the report; 
(ii) notes that in 2022/23 the Council’s energy consumption in non-
domestic operational properties decreased by 7%, and the energy
bill increased by 41.4% (£1,368,365); 
(iii) approves the update of Energy Policy at APPENDIX I to align with the
mandatory targets set by the Scottish Government and agrees that
officers review the Energy Policy and Strategy annually in order to
align its goals with the Route Map to Net Zero; and 
(iv) notes the making of a SALIX grant application as set out in
Paragraph 7.6. 
3. BACKGROUND 
3.1 Annual reports have been presented to Committee since 2006; the last report
was submitted for noting to this Committee on 15 November 2022 (paragraph 9
of the minute refers).  This report is submitted as the Council’s Annual Energy
Report for 2022/23. 
Item 12
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3.2 Improving energy efficiency not only minimises costs, but also reduces on-going
carbon emissions in the most cost-effective manner. 
3.3 During the financial year 2022/23 Moray Council’s expenditure on utilities
(including street lighting) was approximately £5.1M, with associated carbon
emissions of 9,494 tonnes CO2. 
4. PERFORMANCE 
Consumption and Costs 
4.1 Table 1 provides a summary of the Council’s utilities consumption, costs and
emissions during 2022/23. Heat refers to kWh from Biomass plant. 
Table 1 
4.2 The operation of the Council’s non-domestic buildings cost £4,672,128 with
further expenditure of £434,574 on street lighting and unmetered electricity. 
Combined Energy Consumption
4.3 Table 2 below provides a comparison of energy consumption between 2021/22
and 2022/23 for individual utilities. 
Table 2 
4.4 The combined energy consumption from the Council’s buildings, for 2022/23 was
39,820,214 kWh compared with consumption of 42,806,079 kWh for 2021/22,
equivalent to a 6.6% decrease. 
Commodity
Consumption
(kWh/m3)
Net Cost
(£)
Carbon
(tonnes CO2)
Heat 1,924,450 £141,560 29                   
Oil 2,744,999 £204,952 759                 
Gas 23,675,047 £1,664,088 4,355              
Electricity 11,475,718 £2,135,121 3,525              
Street Lighting & Unmetered Elec 2,334,269 £434,574 717                 
Water (m3) 102,588 £526,407 108                 
Totals £5,106,702 9,494             
Annual Report Figures 22 -23
Utility 21-22 22-23 Difference %
Heat 2,324,492 1,924,450 -400,042 -17%
Oil 3,336,476 2,744,999 -591,477 -18%
Gas 25,784,297 23,675,047 -2,109,250 -8%
Electricity 11,360,814 11,475,718 114,904 1.0%
Overall Building Total (kWh) 42,806,079 39,820,214 -2,985,865 -7.0%
Street Lighting & Unmetered Elec 2,343,106 2,334,269 -8,837 0%
Overall Total (kWh) 45,149,185 42,154,483 -2,994,702 -6.6%
Water (m3) 106,151 102,588 -3,563 -3.4%
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4.5 The graph below shows the Council’s total energy consumption in its non-
domestic buildings against a 2008/09 baseline, compared to the 2% energy
consumption reduction target and predicted increases, (based upon Government
forecasts of a Business-as-Usual uplift of 0.7% per annum). This baseline will be
adjusted in light of the policy at Appendix 1 if approved. 
4.6 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. 
4.7 The graph below shows the Council’s weather adjusted heating consumption for
the last 11 years. 
35,000,000
40,000,000
45,000,000
50,000,000
55,000,000
NUAL ENERGY CONSUMPTION (KWH)
TOTAL ACTUAL BUILDING ENERGY
CONSUMPTION V PREDICTED & 2% ENERGY
REDUCTION TARGET
Total Energy Consumption (KWh) Predicted (BAU) Energy Consumption (KWh)
2% Per Annum Energy Reduction Target
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4.8 Heating accounts for a significant proportion of the Council’s energy
consumption.  The weather in 2022/23 was 5% warmer than in 2021/22 and the
graph above shows a weather adjusted decrease in heating consumption of
5.4% compared to 2021/22. This can be attributed to the effect of reducing the
temperatures in our buildings and heating settings being optimised.   
4.9 Table 3 summarises the absolute and relative variations in gas consumption for
the various property groupings within the Council’s property estate. 
Table 3 
Property Grouping
Consumption
21-22 kWh
Consumption
22-23 kWh
kWh
Difference
%
Difference
Community Centres            469,547            463,681  -        5,866  -1.3%
Day Centres         1,030,133            874,367  -    155,766  -17.8%
Libraries            704,831            541,672  -    163,159  -30.1%
Offices          1,343,695        1,306,435  -      37,260  -2.9%
Primary Schools          7,874,244        7,004,574  -    869,670  -12.4%
Residential Homes             934,389            837,020  -      97,369  -11.6%
Secondary Schools &
Swimming Pools       12,254,424      11,517,421  -    737,003  -6.4% 
4.10 Main points to note in relation to table 3 are as follows:- 
• The decrease in consumption can be attributed to a mixture of warmer
weather conditions and management of heating controls.
• Schools account for the largest decrease in consumption in volume terms. 
• The decrease in consumption in Libraries is from savings made in Elgin
Library from a mixture of reducing temperatures and managing heating
settings.
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Water Consumption
4.11 The Council’s water consumption for 2022/23 was 102,558m3 compared with
consumption of 106,151m3 for 2021/22, a decrease of 3,563 m3, equivalent to a
3.4% decrease. Replacement taps in primary schools and monitoring of water
consumption by the energy team identifying and dealing with issues early are
responsible for this saving. 
Street Lighting
4.12 The management and maintenance of street lighting is undertaken by Direct
Services.  The associated energy consumption in 2022/23 was 2,334,269 kWh,
0.4% lower than the 2021/22 consumption of 2,343,106 kWh.  It is expected that
this will remain stable as the LED replacement programme completes. Electricity
consumption has dropped by 67% compared to that being used prior to the
project starting in 2017. 
Carbon
4.13 Carbon dioxide emissions provides a single common denominator between
disparate activities such as electricity, transport and waste recycling.  Table 4
details the carbon emissions associated with energy and water consumptions
attributable to Moray Council building related operations (figures are in tonnes of
CO2). 
Table 4 
4.14 Greenhouse Gas emissions are categorised into three scopes. Scope 1 are
direct emissions from onsite fuel combustion and company vehicles. In this case
the Scope 1 emissions come from Gas, Oil and biomass boilers used to heat our
buildings.  Scope 2 emissions are indirect emissions from purchased grid
supplied electricity.  Scope 3 emissions are other indirect emissions from the
wider supply chain.  In this case the emissions from Grid bought Electricity
transmission and distribution losses, Water supply and water treatment of the
waste water we produce.  
Utility 21-22 22-23 Difference %
Heat 35                      20              -15 -42%
Oil 857                   759            -98 -11%
Gas 4,723                4,355         -367 -8%
Electricity 2,412                2,219         -193 -8%
Electricity T&D Losses 213                   203            -10 -5%
Street Lighting & Unmetered Elec 498                   493            -5 -1%
Street Lighting & Unmetered Elec T&D L 44                      41              -3 -6%
Water 12                      10              -1 -12%
Water Treatment 23                      19              -5 -20%
Overall Total C02e 8,817                8,120         -697 -8%
Total Scope 1 C02e 5,615                5,135         -480 -9%
Total Scope 2 C02e 2,910                2,712         -198 -7%
Total Scope 3 C02e 292                   273            -19 -7%
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4.15 Previous iterations of this report have reported emissions as one single figure. It
is important to differentiate between the emission scopes and report as such. 
This is important as: 
• Reductions or changes in the conversion factors may give false reductions
as it may look like savings have been made when they have not.
• In order to meet the council’s Net Zero targets it is the Scope 1 emissions
that need to be prioritised for reduction. 
4.16 Carbon emissions from the Council’s non-domestic buildings and street lighting
in 2022/23 were overall 8% lower than in in 2021/22.  Contributory factors which
would have affected the above performance include: 
• The reduction in demand for heating highlighted in paragraph 4.8 has
caused the majority of the reduction in overall emissions and Scope 1
emissions.
• A reduction in the UK Government carbon conversion factor for electricity
has reduced the Scope 2 and Scope 3 emissions associated with
electricity despite a nominal increase in consumption.
• A combination of reduced water consumption and a reduction in the
carbon conversions factor for water and water treatment have contributed
to the reduction in emissions from water use. 
5. UTILITY MANAGEMENT 
Utility Expenditure
5.1 In 2022/23 the Council’s total utility bill amounted to £5,106,702 an increase of
£1,410,566 (38.2%) compared to 2021/22 - with buildings constituting the largest
element at £4,672,128. Table 5 below gives a breakdown of costs. 
Table 5 
Utility 21-22 22-23 Difference %
Heat £120,070 £141,560 £21,490 18%
Oil  £195,372 £204,952 £9,580 5%
Gas  £688,094 £1,664,088 £975,994 142%
Electricity  £1,816,774 £2,135,121 £318,347 18%
Water £483,453 £526,407 £42,954 9%
Overall Total - Buildings Only (£) £3,303,763 £4,672,128 £1,368,365 41.4%
Street Lighting & Unmetered Elec  £392,373 £434,574 £42,201 10.8%
Overall Total (£) £3,696,136 £5,106,702 £1,410,566 38.2% 
5.2 Table 6 shows 2021/22 consumption but costed at 2022/23 rates thus showing
the financial saving of the reduction in consumption noted earlier based on stable
prices.  An overall saving of over £220,000 has been made, the majority of these
savings coming from provision of heat.  
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Table 6 
5.3 Cost of Energy 
The Scottish Government have a national framework in place with Total Energies
Gas & Power for the supply of natural gas, EDF Energy Customers Ltd for
electricity and Business Stream Ltd for water.  These frameworks have been in
place since 2018, 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 is
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.  Therefore the impact of the high
cost of energy on the council has been partially mitigated.  SP’s due diligence
means that there are no security of supply concerns for Natural Gas or
Electricity.  Our suppliers are stable and not exposed to the financial pressures
which have seen smaller energy firms collapse. 
5.5 The wholesale cost of gas and electricity for Moray Council was fixed for
the fiscal year 2023/24 in April 2023.  Gas was set at 4.1277p/kWh and
Electricity at 16.0169 p/kWh. This does not include the non-energy charges that
are included in the invoices the Council pays. This represents a rise in the price
of electricity of 43% and a reduction in the cost of gas by 22%. 
Scottish Procurement periodically updates on price forecasts for the electricity
and gas contracts. The most recent, Contract notice #56 was released in July
2023.  It predicts the cost increase set out below.   
2024-25
Variance to
2023-24
2025-26
Variance to
2024-25
Gas 31% -22%
Electricity 13% -7% 
Utility
21-22 kWh
with 22-23
Cost 22-23 Actual Difference
Heat £170,987 £141,560 -£29,427
Oil £249,114 £204,952 -£44,162
Gas £1,812,344 £1,664,088 -£148,256
Electricity £2,113,742 £2,135,121 £21,379
Water £544,692 £526,407 -£18,284
Overall Total - Buildings Only (£) £4,890,879 £4,672,128 -£218,751
Street Lighting & Unmetered Elec £435,948 £434,574 -£1,374
Overall Total (£) £5,326,827 £5,106,702 -£220,124
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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 2023-24 is based on billing up to the end of July.  This gives a
good idea of the change in energy costs however may change between now and
the end of the year as consumption increases over the winter months. 
Future Budget Guidance 
5.7 Using the advice from Scottish procurement and the current inflationary rates
some guidance on the future budgets required is set out in table 7. These figures
have been arrived at using 2022-23 consumption.  Gas, costs have been
estimated using the calculator provided by Scottish Procurement.  Electricity
costs have been arrived at using a percentage uplift.  Oil, heat and water have
been calculated using CPI rates of 8.7% for April 2023, 6.1% as the rate for uplift
for 2023-24 to 2024-25 and 2.6%. Based on the Office of Budget Responsibility’s
June 2023 forecast, worst case scenario.  
Av PPU 22-23 Av PPU 23-24 Unit Variance % Variance
Biomass 7.36               8.52 1.16               13.7%
Oil 7.47               6.93 0.54-               -7.7%
Gas 7.03               6.29 0.74-               -11.7%
Electricity 18.61             31.00 12.39             40.0%
Water 513.13          542.18 29.05             5.4%
4.74 4.83 4.85 4.95 5.17
7.36 8.52
4.74 5.31 4.85 3.93 5.86 7.47 6.93
2.40 2.84 3.05 2.73 2.67
7.03 6.29
13.22 13.70 14.77 16.02 15.99
18.61
31.00
-
5.00
10.00
15.00
20.00
25.00
30.00
35.00
Av PPU 17-18 Av PPU 18-19 Av PPU 19-20 Av PPU 20-21 Av PPU 21-22 Av PPU 22-23 Av PPU 23-24
PENCE PER KWH
FISCAL YEAR
AVERAGE ENERGY COST PER UNIT
(KWH)
THE MORAY COUNCIL
Heat Oil Gas Electricity
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Table 7 
Utility 23-24 24-25 25-26
Heat £153,876 £163,262 £167,507
Oil  £222,783 £236,373 £242,518
Gas  £1,161,541 £1,479,649 £1,195,785
Electricity  £3,053,223 £3,450,142 £3,208,632
Water £572,205 £607,109 £622,894
Overall Total - Buildings
Only (£) £5,163,628 £5,936,535 £5,437,337
Street Lighting &
Unmetered Elec  £621,441 £702,228 £653,072
Overall Total (£) £5,785,069 £6,638,763 £6,090,409 
5.8 The figures in Table 7 are estimates based on the available guidance at the time
of writing. The actual outturn 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.  
Renewable Energy Generation Revenue
5.9  The council currently operates 2 biomass heating systems at Speyside and
Milne’s High Schools and a solar thermal system at Forres Swimming Pool. 
5.10  For the 2022/23 period the Council received combined Renewable Heat 
Incentive (RHI) payments of £108,294. 
Table 8 
Total RHI Income  21-22 22-23 Difference  %
Milnes HS £52,127 £38,752 -£13,375 -26%
Speyside HS  £49,473 £69,542 £20,069 41%
Forres Pool £912 £0 -£912 -100%
Total RHI Income £102,512 £108,294 £5,781 6% 
5.11 The reduction in payments for Forres Pool relate to a malfunction in the system,
then delays in repair due to supply chain issues in getting a replacement pump. 
The maintenance team are working with the supplier to find a replacement part,
so far this has been unsuccessful. 
5.12 The reduced and increased RHI payments from installations from Milnes High
School and Speyside High School respectively are due to a mixture of energy
management savings, weather conditions, and the amount of gas or oil used
while maintenance work has taken place. 
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. 
Total FIT Income 20-21 21-22 Difference %
Elgin HS  £1,938 £1,503 -£435 -29% 
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Invoice Processing
5.14 All utility invoices go directly to the Energy Team for verification and validation
prior to centralised authorisation and payment.  The vast majority of utility
invoices are received electronically and uploaded directly 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. 
5.15 During 2022-23 the active management, checking and validation of utility
consumptions and invoices identified over £60,545 of erroneous charges which
were resolved by the Energy Team.
6. POLICY AND STRATEGY 
6.1 The Scottish Government has produced a heat in buildings strategy, outlining the
steps they will take to reduce greenhouse gas emissions from Scotland’s
buildings.  The focus of this strategy is on energy demand for space and water
heating.  APPENDIX I of this report is an update to The Moray Council, Energy
Policy and Strategy for Non-Domestic Operational Properties. This is a high level
strategy that should be reviewed annually by officers and reported to committee
for approval. 
7. ENERGY INITIATIVES 
7.1 In the year 2022-23 energy and water efficiency projects actioned by the energy
team had a total capital cost of £8,707.  Annually these projects generate
revenue savings of £4,546 and a reduction of 2980kg of CO2e. £6,437 of this
was funded from the energy budget.  The remaining £2,269.86 was awarded
after winning a water saving competition from Business Stream. 
7.2
Site / Project Capital cost Savings Unit Annual £ Savings
Annual Kg
CO2e Savings Funding Source
New Elgin Water taps £2,270 994.5 Water M3 £864 18 Business stream
HQ Corridor lights £1,200 3369.6
Electricity
kWh £418 711 Energy
HQ Annexe Car park Lights £4,782 11497.5
Electricity
kWh £2,727 1353 Energy
Larch court LED £455 2239.64
Electricity
kWh £538 898 Energy
Cedarwood Day Centre Boiler Replacement £20,000 30,837 Gas kWh £2,168 399 Maintenance
17106.74
Electricity
kWh
994.5 Water M3
£28,707 30837 Gas kWh £6,714 3379Totals
Energy Efficiency Projects 2022-23
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Future Energy Initiatives
7.3 
7.4 Energy Awareness
Throughout the year the energy team have engaged with stakeholders to
educate them on issues around energy use, increase awareness and promote
good behaviour.  This has been done through climate change week events,
STEM events and visits to schools.  In the year 2022-23 a total 1018 people,
including pupils and employees, attended one of our group events and
workshops. 
7.5 The Non Domestic Energy Efficiency Framework – Project Support Unit (NDEE
PSU) run by Mott MacDonald are consultants working on the council’s behalf that
is grant funded by the Scottish Government (SG).  Working with the PSU, a desk
top analysis of our building stock was done and ten buildings w ere shortlisted for
auditing. These audits have identified measures that will deliver energy
efficiencies in these buildings with a total value just under £11.4m.  These
measures are what is required to bring these buildings to a condition that is
necessary to achieve net zero carbon emissions. 
7.6 The Scottish Government announced £20 million in grant funding which will be
available under Scotland’s Public Sector Heat Decarbonisation Fund, delivered
through Salix. This is match funding of 80% of the cost of projects.   It was
announced on 25 October 2023 that the portal for applications will open on a
date in November, yet to be decided, then closed in a date in December. For
successful applications, grant offer letters will be issued from February 2024
onwards. The application can be up to a maximum £2.5m to be utilised across
both the 23/24 and 24/25 financial years. The applications will undergo a quality-
based assessment and the highest scoring application will be approved for
funding.  The time of submission will have no impact on the assessment outcome
as long as it’s made while the portal is open.  In line with Government policy, the
applications should take a whole building approach. The Energy Consumption
Action Options and Decarbonisation of Corporate Buildings report approved at
this Committee on 7 February 2023 approved a recommendation “to grant
delegated authority to the Head of Housing and Property Services to apply for
funding opportunities if eligible as set out in para 7.2 of that Report” (para18
refers). At the time of that report the Salix funding was via a loan.  However, as
Site Capital cost
Estimated
Annual
Savings Unit
Estimated
Annual £ Savings 
Estimated
Annual Kg
CO2e Savings Funding Source Stage
Cooper Park PC LED Replacment £1,285.00 1534
Electricity
kWh £429.52 324 Energy Complete
Hopeman Harbour PC LED Replacement £893.95 933
Electricity
kWh £261.24 213 Energy Complete
Rothes PC LED Replacement £800.00 900
Electricity
kWh £252.00 206 Energy Scheduled Q3
Moray Resource Centre LED Replacement £13,300.00 12833
Electricity
kWh £3,593.24 1510 Maintenance Scheduled Q3
Newmill Primary LED Replacement £9,939.45 8290
Electricity
kWh £2,321.20 2404 Energy Scheduled Q3
Buckie Library LED Replacment £8,822.00 11666
Electricity
kWh £3,266.48 2217 Energy Planning Q4
Cullen Primary Heating Controls £700.00 1922 Oil L £1,562.11 6979 Energy Complete
Mortlach Primary Heating Controls £600.00 61599 Gas kWh £4,373.66 11223 Energy Complete
Rothiemay PS Heating Controls £600.00 1509 Oil L £1,177.35 27396 Energy Complete
Pinefield Park Boiler Replacment £5,500 20759 Gas kWh £1,565.28 3782 Maintenance Complete
St Thomas Primary School Boiler Replacment £27,800 43242 Gas kWh £3,231.56 7878 Maintenance Scheduled Q3
Anderson Primary Urinal Controls £1,000 854 W M3 £732.82 85 Energy Scheduled Q3
Aberlour Primary Urinal Controls £1,000 854 W M3 £732.82 162 Energy Scheduled Q3
Energy Efficiency Projects 2023-24
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stated above, the funding is now in the form of a grant with 20% match funding
required by the Council. The work that officers have been doing with Mott
Macdonald’s Non Domestic Energy Efficiency Support Unit puts us in a position
to make a strong application.  The support unit will assist with making the
application.  The fund is likely to be oversubscribed, therefore there is no
guarantee of success.  Proposals will be subject to internal governance via the
Asset Management Working Group before the grant funding application is made
when the portal opens and specific committee approval for capital funding
commitment will be made prior to committing to the match funding. 
Heat Networks
7.7 The ongoing development of the Local Heat and Energy Efficiency Strategy
(LHEES), and discussions with partners as part of the delivery of Moray Growth
Deal projects, has identified the centre of Elgin as a potential area for a Heat
Network Zone. The creation of a heat network in the centre of Elgin is an
opportunity to use the Growth Deal as a catalyst to deliver additional benefits for
the town centre and act as a learning resource for elsewhere. As the Growth
Deal includes buildings which are in close proximity, it is an opportunity to
explore the potential to install the infrastructure required. This will allow the
buildings to be utilised as anchor loads for a network which could include other
buildings such as the Council HQ, UHI Moray campus, Elgin Library, Grant
Lodge, businesses, and Dr Grays Hospital.  A decarbonised heat network would
be an opportunity for public and private buildings to share the cost of moving
away from fossil fuel heating. The heat network would be a major innovation to
Elgin and the Growth Deal projects would be at the heart of this. 
7.8 The Scottish Government Heat Network Support Unit (HNSU) can offer 100% of
funding for a Feasibility Study. The capital required and financial viability of the
heat network will be addressed by the feasibility study. If the project is viable, the
HNSU can fund up to 50% of capital costs with the intention to source investment
funding for the remaining 50%. In order to attract external investment the project
will have to be a large enough scale to make it financially viable. If there is a
viable project, the intention would be to create a partnership organisation to drive
the project forward and to operate the network. Further update reports will be
provided to this Committee, following agreement to progress with the Feasibility
Study at the February meeting of this Committee. 
8. SUMMARY OF IMPLICATIONS 
(a) Corporate Plan and 10 Year Plan (Local Outcomes Improvement Plan)
(LOIP)
The Energy Policy and Strategy along with actions to minimise the
Council’s energy use support the aim of the Corporate Plan of a financially
stable Council. 
The Council’s Corporate Plan 2019 – 2024 identifies the environment as a
key principle in the delivery of the Council’s priorities. 
“Environment – look after the world we live in to protect it for the future” 
and for Moray Council to be: 
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“A resource efficient, carbon neutral council that works with partners to
mitigate the worst effects of Climate Change, to create a resilient, fair and
more sustainable future for everyone within Moray”. 
On 10 March 2021 (paragraph 13 of minute refers) the council adopted the
Climate Change Strategy, the strategy set a goal of the Council being
carbon neutral by 2030.  On 6 April 2022 (paragraph 18 of minute refers),
the Route Map to Net Zero was approved.  This creates a framework for our
actions aimed at reducing carbon emissions to net zero by 2030. 
(b) Policy and Legal
In October 2021 the Scottish Government published The Heat in Buildings
Strategy. This sets a target of achieving net zero greenhouse gas
emissions by 2045 with interim targets requiring a 75% reduction by 2030,
and 90% by 2040. 
(c) Financial Implications
In 2022/23 the Council’s total utility bill amounted to £5,106,702 an increase
of £1,410,566 (38.2%) compared to 2021/22. 
Unit electricity costs have increased by 40% and gas costs have reduced
by 11.7% from 2022/23 to 2023/24. 
Energy management measures and weather conditions created equivalent
savings of over £220,000 in the year 2022/23. 
During 2022/23 the active management, checking and validation of utility
consumptions and invoices identified over £60,545 of erroneous charges. 
(d) Risk Implications
Budget guidance issued in July 2023 by Scottish Procurement indicates
that in 2024-25 electricity unit costs are forecast to decrease by 7% and gas
unit costs by 22%.  However, energy markets remain volatile, there is a
significant risk that future prices may change dramatically. 
(e) Staffing Implications
The workload associated with transforming the Council’s property portfolio
to net zero carbon is expected to increase year on year. 
(f) Property
The property implications are as set out in this report. 
(g) Equalities
There are no equalities implications. 
(h) Climate Change and Biodiversity Impacts
Updating the EPS to reflect the Councils goals to achieve net zero and the
developing LHEES strategy will assist in setting out strategic cohesion in
achieving reductions in climate emissions.  
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(i) Consultations
The Head of Housing and Property Services, the Chief Financial Officer, the
Head of Economic Growth and Development Services, the Property Asset
Manager, the Design and Construction Manager, the Principal Climate
Change Officer, the Legal Services Manager, the Equal Opportunities
Officer and Lindsey Robinson, Committee Services Officer have been
consulted and any comments incorporated in this report as appropriate. 
9. CONCLUSION 
9.1 The Council’s utility consumptions fell by 7% and utility costs rose by 38%
in 2022/23.  It should be noted that this decrease can be attributed to
energy management measures and warmer than average weather
conditions. 
9.2 Reductions in energy consumption continue through a programme of
energy projects, Energy Management Systems and staff
awareness/behaviour changes in the short term as outline within this
report. These are necessary to minimise the Council’s carbon emissions
and energy costs. The energy team continue to progress these actions to
reduce consumption and costs. 
9.3  The rationalisation of the council’s corporate building stock and the way in
which we use buildings continues to evolve.  The long term energy
reduction strategy aligns its goals and actions with this rationalisation, the
council’s Route Map to Net Zero, and the Scottish Government’s Heat in
Buildings Strategy. 
Author of Report:  Iain Highet, Energy Officer
Background Papers:  As referred to in this report.
Ref:    SPMAN-1285234812-1415 
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APPENDIX I 
THE MORAY COUNCIL 
ENERGY POLICY AND STRATEGY – NON DOMESTIC OPERATIONAL
PROPERTIES
Energy Policy – Statement of Commitment
The use of energy is vital in our operation and the provision of services to our
community.  The importance of controlling our energy consumption and associated
carbon dioxide emissions has never been so high.
The Scottish Government updated the 2018 Climate Change Plan in December
2020.  This set out a new ambitious target to end Scotland’s contribution to climate
change by 2045.  Making a commitment to reduce emissions by 75% by 2030
(compared with 1990) and to net zero by 2045. On 10 March 2021 (paragraph 13 of
minute refers) the Council adopted a Climate Change Strategy for 2020-2030.  The
strategy set a goal of the Council being carbon neutral by 2030 and that the Council,
its officers and members will work with others across Moray to deliver that goal.
To achieve this the Council will ensure that:-
• Energy management is fully integrated across all relevant decision making to
reduce energy consumption, costs and carbon emissions in all buildings it
occupies or operates.
• Sufficient resources are in place to meet the objectives of the policy.
• The progress against the objectives of this policy and strategy document is
reported to Committee on an annual basis. 
The Policy Aims
I. Manage energy to achieve ongoing improvements through recording,
benchmarking, monitoring and reporting on energy consumption and
renewable generation associated with the council’s non- domestic building
stock. 
II. Minimise energy consumption. Through energy efficiency projects;
improving building fabric, replacing lighting and optimising on site
renewable generation. 
III. Reduce direct carbon emissions associated with space and water heat with
a target of being as close  as practicably possible to net zero by 2030. 
Item 12
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Energy Management 
Key to achieving our policy aims is to develop an Energy Strategy setting out how
the policy objectives will be met. This strategy applies to all energy use within
buildings occupied or operated by the Council.  The specific objectives of the
strategy are:- 
1. To record energy and carbon consumption by using monitoring and targeting
processes.
• Energy consumption in Council buildings is monitored and the information
recorded on a suitable database and reported back to the Site
Responsible Person.
• Consumption in buildings is analysed against benchmarks to identify
those buildings with the best opportunities for savings.
• Energy audits will be targeted at inefficient buildings to determine what
improvements can be made.
• Energy invoices will be checked and approved by the Energy Officer for
accuracy.
• Review procedures for processing and checking energy invoices.  
• Ensure that high quality energy consumption data is collated to comply
with Carbon Reduction Commitment Energy Efficiency Scheme
requirements. 
2. To increase awareness of energy efficiency measures.
• Improve Site Responsible Persons’ and Council staffs’ awareness of
energy issues.
• Provide training via internal and external advisers/experts to staff directly
involved in energy saving activities. 
3. Promote and develop new and innovative ways of saving energy/water.
• Include energy efficiency requirements in design briefs, planning
permissions and building warrants, in line with the Routemap to Net Zero.
• Share information about projects with other organisations in order to
spread best practice.
• Consult an energy specialist when developing new build/refurbishment
projects. 
• Implement energy efficiency projects/measures identified from site
surveys, data analysis and energy audits.
• Improve use of Building Energy Management Systems. 
• Monitor compliance with corporate Heating Policy. 
4. To reduce water consumption and costs and use water efficiently.
• Carry out site surveys to identify projects that will improve water efficiency
and produce cost savings.
• Implement water efficiency projects identified from site surveys. 
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Establishing a Baseline
Previous energy strategy documents have used the year 2011-2012 as a baseline
with a target of an across the board 2% reduction of all energy consumption.  Using
this target will not result in NetZero carbon emissions.  It also does not take into
account the scope of carbon emissions created from the operation of the council’s
building stock.
Greenhouse Gas emissions are categorised into three scopes. Scope 1 are direct
emissions from onsite fuel combustion and company vehicles. In this case the Scope
1 emissions come from Gas, Oil and biomass boilers used to heat our buildings. 
Scope 2 emissions are indirect emissions from purchased grid supplied electricity. 
Scope 3 emissions are other indirect emissions from the wider supply chain.  In this
case the emissions from Grid bought Electricity transmission and distribution losses,
Water supply and water treatment of the waste water we produce. In order to meet
the council’s Net Zero targets it is the scope 1 direct emissions that need to be
prioritised for reduction.
In order to bring into line with the climate change Route Map to Net Zero it is
important to establish a common baseline.  The baseline year used in the Route Map
to Net Zero is the year 2017/18. Therefore Energy policy and targeting should be
changed to reflect that.  Future reporting should be made against this new baseline. 
Route to Net Zero Buildings
The graph below shows a best case scenario trajectory towards Net Zero emissions
against the 2017/18 baseline.  This involves changing heating systems that produce
direct emissions to low and zero emissions heating systems. It should be noted that
the linear decline in emissions expressed in the graph would not be expected and
that there would be step changes in years where larger building assets are
connected to low carbon heat sources towards the end of the decade. 
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Electrical Energy Efficiency 
From a carbon emissions perspective electrical energy efficiency is less important
than converting heat provision away from gas and oil systems. Ideally all assets
would be made as energy efficient as possible.  However, wherever it is possible
investing in an asset to generate income or spend to save on revenue costs is a
relevant approach.  There may be occasions when investing in solar panels and LED
lighting on buildings where services are old and its fabric below standard is
necessary.  Therefore LED lighting replacement and solar PV projects should be
carried out as a matter of course where feasible on all assets that will remain
operational for a period that will make projects financially beneficial 
Fabric First
Improving the energy performance of buildings is essential to unlock the rollout of
zero emissions heating. Energy efficiency measures alone will not reduce emissions
enough to meet our emission reduction targets, but they are a critical precursor to
deployment of many zero emissions heating systems. A Fabric First approach
should remain at the core of our heat in building policies and programmes, subject to
cost benefit analysis. 
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It should be acknowledged, however, that there may be occasions when the
measures needed to improve a building’s energy performance to the standard
required are not possible. These include, but are not limited to, the method of
construction, the cost of measures required, the measures having an unacceptable
negative impact on the fabric or structure or the need for 3rd party permission (where
this is not forthcoming). 
No and Low Regrets Technologies
These are technological solutions where cost uncertainty is low and there is cost
certainty of the cost of installation and running.  These technologies should also be
employed in buildings where they are unlikely to be superseded by more economical
solutions before the end of their lifecycles, for example ground source heat pumps in
a building that may be able to connect to a heat network in the future. 
Source: Scottish Government Heat in Buildings Strategy
Heat in Buildings
In order to meet the council’s net zero target 2030 our non-domestic building stock
must significantly reduce its energy consumption, and almost all must be using a
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zero emissions heating system.  What is meant by this are heating systems such as,
individual electric heat pumps and connection to heat networks, or electric systems
such as storage heaters, and systems that have very low emissions such as those
that use hydrogen. 
Bioenergy, for example in the form of biomass, bio-heating oil, bio-propane, where
they come from sustainable sources, are included as low emissions systems, but
likely to have a more limited role. 
The vast majority of our buildings use mains gas as their primary heating fuel.
Followed by direct electric and oil. 
One kWh of electricity is currently more expensive than one kWh of gas by a factor
of about 4-5.  The higher efficiency of a heat pump means the amount of energy
needed can be less than a third the amount of energy needed by an oil or gas boiler,
or direct electric heating to produce an equivalent amount of heat. This means that
for some properties, heat pumps can help reduce bills where they are replacing
older, more inefficient heating systems, or where they are combined with upgrades
to the efficiency of the building’s fabric. Increasingly there is also the option to deploy
heat pumps alongside other measures such as solar PV or battery storage to help
further reduce electricity bills. 
However, when a heat pump replaces a modern, efficient gas boiler, the greater
efficiency of the heat pump will be insufficient to offset the higher cost of electricity.
For this reason heat pump projects should be prioritised in the off gas grid
properties. For properties where direct electric heating is used and savings can be
demonstrated. Then properties on gas grid will be considered with a view to moving
towards heat pumps or district heating where it is likely to be available once
identified through the Local Heat and Energy Efficiency Strategy. 
18%
27%53%
2%
Heating Type By Number Of Buildings
Oil Supplies
Direct Electric
Gas
Heat Pump
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Monitoring and Review
This policy and strategy will be reviewed annually by the Energy Officer and
revisions reported to Committee for approval. 
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REPORT TO: ECONOMIC DEVELOPMENT AND INFRASTRUCTURE
SERVICES COMMITTEE ON 14 NOVEMBER 2023 
SUBJECT: PERFORMANCE REPORT (ENVIRONMENTAL AND
COMMERCIAL SERVICES) – PERIOD TO SEPTEMBER 2023 
BY:  DEPUTE CHIEF EXECUTIVE (ECONOMY, ENVIRONMENT AND
FINANCE) 
1. REASON FOR REPORT 
1.1 To inform the Committee of the performance of the service for the period to
30 September 2023. 
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. RECOMMENDATION 
2.1  It is recommended that Committee: 
(i) scrutinises performance in the areas of Service Planning, Service
Performance and other related data to the end of September 2023;  
(ii) notes the actions being taken to improve performance where
required. 
3. BACKGROUND 
3.1 On 7 August 2019, the Moray Council approved a revised Performance
Management Framework for services (para 5 of the minute refers). 
4. SERVICE PLANNING 
4.1 Each service plan sets out the 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. 
This report provides an interim update on progress on the service plan, key
outcomes and performance indicators.  Committee is invited to review
progress to secure assurance that is satisfactory and to provide scrutiny and
further direction where performance requires attention.  
Item 13
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4.2 The narrative included is by exception, links to Service Plan Actions and
Performance Indicators can be accessed within the Background Papers
section of this report.   
Strategic Outcomes – successes 
4.3 Installation of charging facilities is ongoing at prioritised locations with 58
charging infrastructure points and 88 plug in sockets now available for council
vehicles. (Action ECS23-24 Section 4a i) 
Strategic Outcomes – challenges and actions to support 
4.4 To aid delivery of the Charging Infrastructure Strategy, this committee at its
meeting on 20 June (item 8 of the Minute refers) approved joining the
Pathfinder Project alongside Highland, Aberdeen City and Aberdeenshire
Councils.  The procurement exercise will identify private operators available to
provide public charging points.  Although progressing out with original target
timescales, tender documents are currently being prepared for issue in the
next quarter.  (Action ECS23-24 Section 4b) 
Service Level Outcomes – successes 
4.5  Good progress has been made with partners to develop a draft Road Safety
Plan that is also on today’s agenda.  Covering the period to 2030, this plan will
be used to support applications to the Scottish Government’s Road Safety
Improvement Fund.  (Action ECS23-24 Section 5a) 
4.6 The migration to a web-based Asset Management System for Roads
Maintenance is complete, removing the need for approx. 9,000 printed orders
per year.  Customer satisfaction levels will be monitored through the APSE
performance network surveys available in 2024.  (Action ECS23-24 Section
5c) 
4.7 The Participatory Budgeting project to deliver cycle parking facilities in Buckie
and Keith has progressed well with locations selected by the community in
each area.  Installation will take place in Buckie in October with the tendering
process ongoing in Keith.  (Action ECS23-24 Section 5gii) 
4.8 The Public Service Improvement Framework (PSIF) for Roads Maintenance is
complete with an action plan in place and progressing.  The long-term impact
RAG
STRATEGIC
LEVEL Developing a diverse & sustainable economy 54%
Improving the Transportation Network 80%
Improving our operations 30%
Improved Service Delivery 90%
Harbour Development/Climate Change 55%
Environment/Climate Change 77%
Our Future Environment 82%
Improving our operations 45%
Delivering Capital Projects 45%
Workforce development 55%
58%
SERVICE PLAN OUTCOMES
OVERALL PLAN PROGRESS
Comment:   At the end of quarter 2, most actions are progressing well.  Implementing
public use charging infrastruture, delivery of a harbour masterplan for Buckie and
completion of the Joint Energy from Waste Project are out with original target
timescales however work on all continues with updates expected during quarter 3.
SERVICE
LEVEL
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of the improvements made will be gauged via APSE surveys in 2024.  With
the process complete earlier than anticipated, assessments are now planned
this year for Waste and Open Spaces.  (Action ECS23-24 Section 5l ii) 
Service Level Outcomes – challenges and actions to support 
4.9 Work to deliver a Buckie Harbour Master Plan is ongoing out with the original
due date.  A successful application to the Scottish Government’s Just
Transition Fund, helped secure consultancy support to develop both the plan
and a business case for future inward investment.  An update is included as a
separate report on today’s agenda.  (Action ECS23-24 Section 5d ii) 
4.10 Completion of the Joint Energy from Waste project is expected in November
with the final Acceptance Certificate.  All non-recyclable waste from Moray is
now transported to the East Tullos site however contingency plans were
needed on 21 August when, following a shut down and inspection, delays led
to insufficient capacity.  During this time, waste from Moray was diverted to
the Dallachy landfill site.  All issues have since been resolved with the site
operating well.  (Action ECS23-24 Section 5e) 
4.11 Both performance indicators shown as performing out with target relate to 
annual results, being the latest available data, from a previous period that has 
already been reported to this Committee.  (PIs ECSCON01, ENV6) 
4.12 Uptake of school meals (both free and paid) has fallen during quarter 2. 
Although P6/7 uptake at 34.8% remains above target (30%), several issues
are thought to have contributed to the decline including recent strike action,
increasing popularity for packed lunch offer and a low uptake with P6 pupils
moving from universal free meals to paid meals.  Menu choices have been
refined and unpopular dishes removed and management have continued to
promote the service through attendance at inductions and parents’ evenings. 
(Action ECS23-24 Section 5j, PIs ECSEPBCC02 and ECSEPBCC02a) 
5 SERVICE PERFORMANCE 
5.1 In line with Performance Management Framework, operational performance is
monitored quarterly by departmental management.  Areas performing well
and/or areas subject to a decreasing trend or where benchmarking results
show performance below comparators will be reported to this Committee for
member scrutiny. 
5.2 Following approval of the Service Plan by Committee, a review of
performance indicators has been undertaken and amendments made to align
indicators with service outcomes. 
5.3 The narrative included is by exception, links to Service Performance
Indicators can be accessed within the Background Papers section of this
report.   
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Operational Indicators – successes 
5.4 Average occupancy of paid car parks in Elgin improved during quarter 2 with
57% of all available spaces occupied during the latest survey against a target
of 50%.  (PIs ECSTCP01) 
Operational Indicators – challenges and actions to support 
5.5 The latest data for the quarter ended June showed the unit cost per vehicle
and planned maintenance at £235 had fallen but remained above target
(£205).  As vacancies within the team are filled, there will be less
subcontracting required and the unit cost should continue to decrease.  (PI
ECSRMF02) 
5.6 The enhanced m.connect service was launched as planned in early May. 
This significant expansion has, as expected, affected costs however
improvement is noted between quarters 1 and 2 with net unit cost per
passenger falling from £9.12 to £8.33 against a target of £5.20.  Costs will
continue to be monitored as the new service is established.  (PI ECSTPT01) 
6 OTHER PERFORMANCE RELATED DATA 
Complaints & MP/MSP Enquiries 
6.1 In line with the Performance Management Framework, complaints are
reviewed quarterly by departmental management in terms of time taken to
respond, outcome and learning points.  Detailed tables can be accessed
within the Background Papers section of this report.   
6.2 During the reporting period, Environmental and Commercial Services received
a total of 133 complaints.  In the same period, 129 complaints were closed,
122 (95%) as Frontline and 7 (5%) as Investigative.  113 Frontline complaints
(93%) and 6 Investigative complaints (90%) met target timescales of 5 and 20
working days respectively.   
6.3 Overall, 56 complaints were upheld and 4 partially upheld.  28 (47%) involved
Household Collections with the most common concern around delays
experienced for new and replacement bins.  To help address this, timeframes
provided to members of the public have been revised and the Waste Team
are working to improve the communication methods used for when stock is
overdue.  
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6.4 In addition to complaints, 102 MP/MSP enquiries were received during the
first half of 2023/24 with 22 relating to Road Safety/Speeding concerns in
various areas of Moray. 
Other Performance (not included in the Service Plan) 
6.5 Nothing to report. 
Case Studies 
6.6 As part of the Cycling UK Bothy programme, the Moray Bothy, now in its
second year, aims to bring communities together and help get people active. 
Staff in Moray have led rides for Elgin Youth Café, locally based Asylum
Seekers and individuals through Spinal Injuries Scotland, helping those
involved familiarise themselves with local routes and gain skills and
confidence.  Families have also been able to try different cycles to see what
best fits their needs, with one family purchasing a Tern bike through the
Energy Savings Trust loan scheme that they now use for everyday journeys
instead of their car. 
6.7 In September, the m.connect service was shortlisted for the Scottish Council
for Development and Industry (SCDI) Highlands & Islands annual awards and
celebrated as a runner up in the category ‘Excellence in Innovation’.  This was
a welcome achievement considering the early stages of project
implementation. 
Consultation and Engagement 
6.8 To help shape the next phase of the m.connect service and ensure the aims
of the project are met, an online survey was shared with the public in
September.  Responses are now being analysed with outcomes and
recommendations expected by the end of the year.   
7  SUMMARY OF IMPLICATIONS 
(a) Corporate Plan and 10 Year Plan (Local Outcomes Improvement
Plan (LOIP))
Performance measurement is used to ensure the efficient and
sustainable delivery of services to meet the Council’s priorities in both
the Corporate Plan and the LOIP. 
(b) 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. 
(c) Financial implications
None. 
(d) Risk Implications
None. 
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(e) Staffing Implications
None. 
(f) Property
None. 
(g) Equalities/Socio Economic Impact
An Integrated Impact Assessment is not needed because the report is to
inform the Committee on performance. 
(h) Climate Change and Biodiversity Impacts
None 
(i) Consultations
Depute Chief Executive (Economy, Environment and Finance), The
Head of Environmental and Commercial Services, Service Managers,
Legal Services Manager, the Equal Opportunities Officer and Lissa
Rowan, Committee Services Officer have been consulted, with any
comments received incorporated into this report. 
8. CONCLUSIONS 
8.1 At the end of September 2023, the Environmental and Commercial
Services Service Plan is 58% complete.  Three actions are progressing
out with original target timescales. 
Author of Report: Suzanne Wilson, Research and Information Officer
Background Papers: Service Plan Actions 
Service Plan Performance Indicators
Service Performance Indicators
Complaints Monitoring Report
Ref: SPMAN-524642768-983 
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REPORT TO: ECONOMIC DEVELOPMENT AND INFRASTRUCTURE
SERVICES COMMITTEE ON 14 NOVEMBER 2023 
SUBJECT: PERFORMANCE REPORT (ECONOMIC GROWTH AND
DEVELOPMENT SERVICES) – PERIOD TO SEPTEMBER 2023 
BY:  DEPUTE CHIEF EXECUTIVE (ECONOMY, ENVIRONMENT AND
FINANCE) 
1. REASON FOR REPORT 
1.1 To inform the Committee of the performance of the service for the period to 30
September 2023. 
1.2 This report is submitted to Council in terms of Section III (A) (4) of the
Council's Scheme of Administration to monitor performance of the services
within the Committee’s remit in accordance with the Council’s performance
management framework.   
2. RECOMMENDATION 
2.1 It is recommended that Committee: 
(i) scrutinises performance in the areas of Service Planning, Service
Performance and other related data to the end of September 2023; 
(ii) notes the actions being taken to improve performance where
required. 
3. BACKGROUND 
3.1 On 7 August 2019, the Moray Council, approved a revised Performance
Management Framework for services (para 5 of the minute refers).   
4. SERVICE PLANNING 
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. This report provides an interim update on progress on the service
plan, key outcomes and performance indicators. The Committee is invited to
Item 14
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review progress to secure assurance that it is satisfactory and to provide
scrutiny and further direction where performance requires attention. 
4.2 The narrative included is by exception, links to Service Plan Actions and
Performance Indicators can be accessed within the Backing Papers of this
report. 
4.3 Local Government Benchmarking Framework indicators are used to measure
Service Plan performance, latest results are due for publication in November
and will therefore be incorporated within quarter 4 reporting.   
Strategic Outcomes - successes 
4.4 The Full Business Case for the Housing Delivery Mix was approved by Moray
Growth Deal Board and is now progressing through Scottish Government
policy teams. This will enable further affordable homes to be built across
Moray. Phase 1 of the Dallas Dhu Masterplan is progressing and a planning
application is expected to be submitted early 2024 for 24 affordable homes
and 10 self build innovation plots. Design work and land assembly at South
Street, Elgin is progressing and legal agreements signed between partners. A
draft Masterplan is progressing for a site in Dufftown. This will provide
residents and people looking to move to the area an assurity in transition to
net zero with the associated positive impacts on health and wellbeing.
Members briefings have been arranged for MGD projects and the full
business cases will be coming to Council for approval. (ACTION: EGD23-24-
4.1a) 
4.5 Walking tours of the Cultural Quarter in Elgin, part of the Moray Open Doors
weekend in September, were all fully booked. Visitors were able to find out
about the proposed regeneration of Grant Lodge in Elgin and the upgrade and
refurbishment of the Town Hall over the next 8 years. Procurement is
RAG
Moray Growth Deal: Development and
delivery of Housing Mix Delivery Project 90%
Moray Growth Deal: Cultural Quarter
Project 25%
Climate Change and Biodiversity Route
Map 56%
Identify route for training local
Environmental Health Officers and
associated budget needs
13%
Maximise external funding for Council
priorities including Town Centre
Improvement works and employability.
60%
Town Centre Improvement Delivery Plan
and LDP 2027. 25%
External funding achieved for delivery of
strategic plans associated with Town
Centres and LDP
50%
Service identifies and secures future
needs for succession planning 50%
Service improves the ERDP experience
and holds accurate records, including
CPD.
50%
50%
SERVICE PLAN PRIORITIES
SERVICE LEVEL
OVERALL PLAN PROGRESS
STRATEGIC
LEVEL
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underway for an innovative architect-led design team and they are expected
to be appointed by the end of November, paving the way for a connected,
vibrant cultural centre. (ACTION: EGD23-4.1b)   
4.6 Each action in Moray Council’s Route Map to Net Zero has three measures -
schedule, budget and objectives and 87% of these RAG indicators are on
target. All three measures are on track against the roll-out of the Climate
Change and Home Energy eLearning modules on the “learnPro” system and
completion of the LHEES strategy beyond Phase 1, (tems 4.9 and 7.1 of the
Climate Change Strategy Actions refers). (ACTION EGD23-4.2, INDICATOR:
RMNZ-EGD1) 
4.7 Some 28 staff and six elected members have undertaken training and are
certified as Carbon Literate with excellent feedback received. There are
challenges to recruit participants and no capacity to run a course for all staff at
present, but focus is now is on delivering training to a further 31 staff and four
elected members (ACTION: EGD24-4.2j). 
Strategic Outcomes – challenges and actions to support 
4.8 Energy usage has increased over the past three years starting with additional
ventilation measures in schools during Covid and continuing in the present
with staff returning to offices. The energy team is creating an action plan and
revised energy strategy although smarter working and co-location of partner
services will offset this carbon footprint to some degree (ACTION:  EGD24-
4.2b) 
Service Level Outcomes – successes 
4.9 Work is almost complete on Moray’s Coast to Country project. This initiative,
made possible by the £360k Rural Tourism Infrastructure Fund, includes
upgrade of motorhome facilities, toilet blocks and EV chargers across Moray.
This will make Moray a more attractive location for ‘staycations’ and retain
wealth generated by tourists. (ACTION: EGD24-5.2) 
4.10 After the success in 2022/23 of securing £270k Regeneration Capital Grant
Fund (RCGF) for the Lossie 2-3 Group, planning for renovation of the old
Warehouse Theatre has been approved.  This will provide a one-stop
community shop with affordable childcare, addiction counselling, debt advice,
employability advice, IT training and literacy training. Outcome of the 2023/24
application which has been delayed by the large number of applications made
to the RCGF. (ACTION: EGD24-5.2) 
4.11 The £668k Place Based Investment Fund has been drawn down and
contributing to Stage 1 works  at Lossiemouth Community Hub and
development work at Buckie Harbour with the nearby brownfield site having
been identified for potential solar PVs supplying low-carbon energy to the
harbour.  (ACTION: EGD24-5.2)   
Service Level Outcomes – challenges and actions to support 
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4.12 With no funding available for two Environmental Health Officer posts, the
service was able to convert one vacant EHO post to a trainee EHO, who has
now been appointed. It takes four years to train an EHO, therefore there is a
risk to delivery of  Environmental Health and Trading Standards services
within  the next five years due to insufficient staffing levels and shortages
nationally that can only be mitigated by training our own Environmental Health
and Trading Standards Officer. The situation is subject to continued
monitoring and is replicated nationally. (ACTION: EGD24-5.1, INDICATOR:
ENVDV518.)   
5. SERVICE PERFORMANCE 
5.1  In line with the Performance Management Framework, operational
performance is reviewed quarterly by departmental management.  Areas
performing well and/or areas subject to a decreasing trend or where
benchmarking results show performance significantly below comparators will
be reported to this committee for member scrutiny.   
5.2 The narrative included in this report is by exception, links to Service
Performance Indicators can be accessed within the Background Papers at the
end of this report. 
Operational Indicators - successes 
5.3 The percentage of building warrants issued within timescales continues to
exceed target year on year, as does the number of days taken to respond to
amended plans. (INDICATORS: ENVDV-BS-KPO1(B), ENVDV-BS-KPO1(C) 
5.4 There are currently 1,133 registered food premises in Moray.  In the quarter
ended September, over 80% of the planned food safety inspections were
carried out. (INDICATORS: ENVDV259ab, ENVDV259c, ENVDV259d,
ENVDV259e) 
Operational Indicators - challenges and actions to support
5.5 The number of new businesses start-ups through the Business Gateway is
down when compared to the first half of last year, from 75 to 47. National
challenges of rising costs, inflation and supply issues coupled with the cost of
living crisis are all contributory factors. However the types of business start-
ups are similar, from services such as cleaning and heating engineers to
those dealing in holiday lets and beauty products, all helping to create more
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opportunities in a vibrant economy in Moray. Enquiries to the Business
Gateway have remained fairly constant with advice mainly given face-to-face
now that the walk-in office in Elgin High Street is fully operational. Six firms
registered for the 10-week free Moray Business Growth Programme
introduced in September, which is designed for micro and small businesses
needing advice and support from local experienced mentors, and two more
programmes are planned for the next financial year.(INDICATOR:
ENVDV266) 
5.6 Planning data has to be verified by the Scottish Government meaning it is
generally six months arrears and information for quarters 1 and 2 is expected
to be available early in 2024. (INDICATORS: ENVDVD262-3, SDS2ai-iii,
SDS2b 
6. OTHER PERFORMANCE RELATED DATA 
6.1 Complaints & MP/MSP Enquiries  
6.2  In line with the Performance Management Framework, complaints are
reviewed quarterly by departmental management in terms of time taken to
respond, outcome and learning points. Links to complaints tables can be
accessed within the Backing Papers of this report. 
6.3 A total of 19 complaints were closed in the half year to September 2023 of
which 9 (47%) were frontline stage and 10 (57%) were investigative stage.
Two complaints were upheld. As a comparison, in the same period last year,
13 complaints were closed. 
6.4 In addition to complaints, a total of 44 MSP/MP enquiries were received in the
last two quarters out of 291 to the Council as a whole, 39 of which were
resolved. Common issues were planning disputes, gulls and anti-social
behaviour. 
Other Performance (not included within Service Plan) 
6.5 Nothing to report. 
Case Studies 
6.6 Nothing to report 
Consultation and Engagement 
6.7 Nothing to report 
7. SUMMARY OF IMPLICATIONS 
(a) Corporate Plan and 10 Year Plan (Local Outcomes Improvement
Plan (LOIP)) 
Performance measurement is used to ensure the efficient and
sustainable delivery of services to meet the Council’s priorities in both
the Corporate Plan and the LOIP. 
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(b) 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. 
(c) Financial implications 
None. 
(d) Risk Implications 
The lack of budget availability to provide Trainee posts in Environmental
Health and Trading Standards combined with the anticipated
replacement demand over the next five years and the national shortage
of officers in these proffessions means there is a risk that the Council will
be unable to meet statutory duties in future years. 
(e) Staffing Implications 
None. 
(f) Property 
None. 
(g) Equalities/Socio Economic Impact 
An Equality Impact Assessment is not required as this report is to inform
the Committee on performance. 
(h) Consultations 
The Head of Economic Growth & Development Services, Depute Chief
Executive (Economy, Environment & Finance) and Service Managers,
have been consulted with any comments received incorporated into this
report. 
8. CONCLUSION 
8.1 As at 30 September 2023 the plan overall is 50% complete, three actions or
subactions having been completed. 
Author of Report: Christopher Dewhurst, Research & Information Officer
Background Papers: Service Plan Actions 
Service Plan Performance Indicators 
Service Performance Indicators 
Service Complaints
Ref: 
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