Agenda Document Pack - Planning and Regulatory Services Committee - 16/12/2025
Moray Council · 16 December 2025
Back to Planning and Regulatory Services Committee — 16 December 2025 and its agenda
Text extracted from the council's PDF. Layout and reading order may differ from the original.
Page 1
Planning and Regulatory Services Committee Tuesday, 16 December 2025 NOTICE IS HEREBY GIVEN that a Meeting of the Planning and Regulatory Services Committee is to be held at Council Chambers, Council Office, High Street, Elgin, IV30 1BX on Tuesday, 16 December 2025 at 09:30. BUSINESS 1. Sederunt 2. Declaration of Group Decisions and Members Interests * 3. Minute of meeting of 21 October 2025 5 - 34 4. Written Questions ** 5. 25/01364/S37 Report by Executive Director Economy, Enterprise and Operations Consultation response to Scottish Minsters for a proposed 186km overhead transmission line (400kV) and associated development between Beauly and Peterhead 35 - 102 6. Performance Report (Economic Growth and Development - Planning) - Period to September 2025 Report by Executive Director Economy, Enterprise and Operations 103 - 108 7. Moray Employment Land Audit 2025 Report by Executive Director Economy, Enterprise and Operations 109 - 150 Page 1
Page 2
8. Moray Town Centre Health Check 2025 Report by Executive Director Economy, Enterprise and Operations 151 - 180 9. Housing Land Audit 2025-26 Report by Executive Director Economy, Enterprise and Operations 181 - 332 Summary of Planning and Regulatory Services Committee functions: Town and Country Planning; Building Standards; Environmental Health; Trading Standards; Weights & Measures, Tree Preservation Orders, and Contaminated Land issues. Watching the Meeting You can watch the webcast live by going to: http://www.moray.gov.uk/moray_standard/page_43661.html Webcasts are available to view for 1 year following the meeting. You can also attend the meeting in person. If you wish to attend in person, please come to the High Street entrance door and a member of staff will let you into the Chamber. Page 2
Page 3
GUIDANCE NOTES * Declaration of Group Decisions and Members Interests - The Chair of the meeting shall seek declarations from any individual or political group at the beginning of a meeting whether any prior decision has been reached on how the individual or members of the group will vote on any item(s) of business on the Agenda, and if so on which item(s). A prior decision shall be one that the individual or the group deems to be mandatory on the individual or the group members such that the individual or the group members will be subject to sanctions should they not vote in accordance with the prior decision. Any such prior decisions will be recorded in the Minute of the meeting. ** Written Questions - Any Member can put one written question about any relevant and competent business within the specified remits not already on the agenda, to the Chair provided it is received by the Proper Officer or Committee Services by 5pm three working days prior to the day of the meeting, please see Standing Order 36 for deadlines. A copy of any written answer provided by the Chair will be published on the Council’s committee management system by 12pm the day before the meeting. The Member who has put the question may, after the answer has been published, may ask one supplementary question directly related to the subject matter at the meeting, but no discussion will be allowed. No supplementary question can be put or answered more than 10 minutes after the Council has started on the relevant item of business, except with the consent of the Chair. If a Member does not have the opportunity to put a supplementary question because no time remains, then he or she can submit it in writing to the Proper Officer who will arrange for a written answer to be provided within 7 working days. Page 3
Page 4
MORAY COUNCIL Planning and Regulatory Services Committee SEDERUNT Councillor David Gordon (Chair) Councillor Paul McBain (Depute Chair) Councillor Peter Bloomfield (Member) Councillor Neil Cameron (Member) Councillor Tracy Colyer (Member) Councillor Theresa Coull (Member) Councillor John Cowe (Member) Councillor John Divers (Member) Councillor Amber Dunbar (Member) Councillor Jérémie Fernandes (Member) Councillor Sandy Keith (Member) Councillor Marc Macrae (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 Page 4
Page 5
MORAY COUNCIL Minute of Meeting of the Planning and Regulatory Services Committee Tuesday, 21 October 2025 Council Chambers, Council Office, High Street, Elgin, IV30 1BX PRESENT Councillor Peter Bloomfield, Councillor Neil Cameron, Councillor Tracy Colyer, Councillor Theresa Coull, Councillor John Divers, Councillor Amber Dunbar, Councillor Jérémie Fernandes, Councillor David Gordon, Councillor Sandy Keith, Councillor Marc Macrae, Councillor Paul McBain, Councillor Draeyk van der Horn, Councillor Sonya Warren APOLOGIES Councillor John Cowe IN ATTENDANCE Head of Growth, Planning and Climate (Chief Planning Officer); N MacPherson, Acting Development Management and Building Services Manager; R Smith, Principal Planning Officer; D Anderson, Senior Engineer (Transportation); Service Manager Legal Services; L Rowan, Committee Services Officer. 1 Chair The meeting was chaired by Councillor David Gordon. 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. 3 Minute of meeting of 12 August 2025 The Minute of the meeting of the Planning and Regulatory Services Committee dated 12 August 2025 was submitted and approved. 4 Written Questions The Committee noted that no written questions had been submitted. Item 3. Page 5
Page 6
5 Planning Application 24/00617/EIA Erect four wind turbines three of which are up to 180m to blade tip height and one up to 149.9m blade tip height, associated and ancillary infrastructure, includes hardstanding areas for each turbine location, onsite access tracks, an electrical substation and buried cables, temporary laydown areas and a temporary construction compound on Land at Cairds Wood, Moray for EDPR. The meeting had before it a report by the Appointed Officer recommending that, for reasons detailed in the report, planning permission be granted to erect four wind turbines, three of which are up to 180m to blade tip height and one up to 149.9m blade tip height, associated and ancillary infrastructure, including hardstanding areas for each turbine location, onsite access tracks, an electrical substation and buried cables, temporary laydown areas and a temporary construction compound on Land at Cairds Wood, Moray for EDPR. The Committee noted that the application had been referred to Committee as the Appointed Officer considers the matter raises matters of wider community interest and/or planning significance by virtue of the scale or height of the turbines. Prior to consideration of the planning application, the Legal Adviser advised that Members may have received an email from the objectors the previous afternoon however this had been received out with the time period for late representations in terms of the late representation policy. The Legal Adviser further advised that this had been discussed with the Head of Growth, Planning and Climate who confirmed that the issues raised were already addressed in the report and that Members should disregard this email. This was noted. During discussion, concern was raised in relation to whether the proposal would affect the water supply to properties at Mains of Auchindachy Farmhouse, Keith, AB55 5HT and Coldhome, Keith, AB55 5NX located to the north of the development site and the Committee sought assurance that the water supply to these properties would be protected. In response, Mr Smith, Principal Planning Officer advised that no development would take place until a Private Water Supply Management Plan had been received, as detailed in condition 32, however suggested that these specific properties be named within the condition to provide assurance to home owners that their water supply would not be affected. Mr Smith, Principal Planning Officer further noted reference to the Environmental Health Manager in conditions 32 and 40 and advised that this job title had changed to Service Manager Community Protection and sought the agreement of the Committee to update these conditions. This was agreed. In relation to tree felling, several concerns were raised particularly in relation to the associated compensatory planting measures noting that compensatory planting would not fully mitigate against the loss of habitat. It was also noted that there was no confirmed location for the proposed 18.63 hectares of off-site compensatory planting, uncertainty regarding the type of land to be used and no details provided on the species mix, planting schedule, or whether the new woodland will be publicly accessible. Page 6
Page 7
In response Mr Smith, Principal Planning Officer suggested that condition 33 could be amended to stipulate that the Compensatory Planting Plan (CP) must not include or affect land that is classified as prime agricultural land, must include provision for at least 50% native broadleaf species, and include, where possible, provision for public access to allow recreational use of the woodland and forest resource. This was agreed. The Head of Growth Planning and Climate (Chief Planning Officer) further suggested the addition of an informative in relation to the provision of public access within the compensatory planning site, where possible. This was agreed. Thereafter, the Committee unanimously agreed to grant planning permission in respect of Planning Application 24/00617/EIA subject to the following conditions and reasons with amendments to conditions 32, 33 and 40 to reflect the following: • Condition 32 • Mains of Auchindachy Farmhouse, Keith, AB55 5HT and Coldhome, Keith, AB55 5NX to be named to provide assurance to home owners that their water supply would not be affected; • Update job title of Environmental Health Manager to Service Manager Community Protection; • Condition 33 – to stipulate that the CP area must not include or affect land that is classified as prime agricultural land, must include provision for at least 50% native broadleaf species, and include, where possible, provision for public access to allow recreational use of the woodland and forest resource; • Condition 40 – Update job title of Environmental Health Manager to Service Manager Community Protection; and • Additional informative in relation to the provision of public access within the compensatory planning site, where possible. Conditions/Reasons Length of planning permission 1. Unless otherwise agreed in writing with the planning authority, the permission hereby granted shall endure for a period no longer than 40 years from the date of final commissioning, after which the development shall cease to export electricity to the national grid and shall be decommissioned in accordance with the details otherwise approved elsewhere within this planning permission. The date of final commissioning shall be as informed to the planning authority in writing or 18 months from the date of this planning permission, whichever is the sooner. Reason: To avoid uncertainty and ensure that the permission is implemented within a reasonable period, and to allow the planning authority to monitor compliance with the other conditions imposed. Expiry of planning permission 2. This planning permission will lapse on the expiration of a period of five years from the date of this planning permission, unless the development has been started within that period. Page 7
Page 8
Reason: To apply a reasonable time limit for the implementation of the planning permission. Turbine details 3. No turbines shall be erected on the site until the definitive type/model of all turbines including details of the hub height, blade length and blade tip height, external finishes and colour, together with any further assessments as may be required in order to demonstrate to the reasonable satisfaction of the planning authority that the turbines conform to the impacts of the candidate turbine assessed in the EIA report, have been submitted to and approved in writing by the planning authority. The approved details shall be implemented. Furthermore:- a) all wind turbine blades shall rotate in the same direction; b) no part of the development shall display any name, logo, sign or other advertisement other than as specified in the application, unless approved in advance in writing by the planning authority or if required by law; and c) the wind turbines shall be constructed and operated in accordance with the approved details and shall be maintained in the approved colour, free from external rust, staining or discolouration, until such time as the development is decommissioned. Reason: To ensure that the environmental impacts of the turbines forming part of the development conform to the impacts of the candidate turbine assessed in the EIA report and in the interests of the visual amenity of the area. Substation 4. No construction of the substation shall commence until final details of the external appearance, dimensions, surface materials and boundary treatment of the substation including the means of foul water disposal and water supply have been submitted to and approved in writing by the planning authority. The sub- station (including associated infrastructure) shall thereafter be constructed in accordance with the approved details. Reason: To ensure that the environmental impacts of the sub-station forming part of the development conform to the impacts assessed in the EIA report and in the interests of visual amenity. Transportation Matters 5. Prior to commencement of deliveries to site, the proposed route for any abnormal loads on the trunk road network must be submitted to and approved by the Planning Authority, in consultation with Transport Scotland as the trunk roads authority. Reason: To minimise interference and maintain the safety and free flow of traffic on the Trunk Road as a result of the traffic moving to and from the development. 6. Prior to the movement of any abnormal load, any accommodation measures required on the trunk road network, including the removal of street furniture, junction widening and traffic management must be approved and implemented to the satisfaction of the Planning Authority, in consultation with Transport Scotland. Page 8
Page 9
Reason: To minimise interference and maintain the safety and free flow of traffic on the Trunk Road as a result of the traffic moving to and from the development. 7. Prior to the movement of any components and/or construction materials, any additional signing or temporary traffic control measures deemed necessary on the trunk road network due to the size or length of any loads being transported must be undertaken by a recognised QA traffic management consultant, to be approved by Transport Scotland. Reason: To ensure that the transportation of any components/materials will not have any detrimental effect on the road and structures along the route. 8. Prior to commencement of any abnormal deliveries to site, any Construction Traffic Management Plan shall include swept path analysis to ensure these can be transported along the trunk road network safely. The complete report shall detail any accommodation measures required including the temporary removal of street furniture, junction widening, traffic management etc. and show that the transportation will not have any detrimental effect on structures within the route path. Reason: To minimise interference and maintain the safety and free flow of traffic on the Trunk Road as a result of the traffic moving to and from the development. 9. No development shall commence until: i. a detailed drawing (scale 1:500 or 1:1000 which shall also include details to demonstrate control of the land through evidence of ownership or provision of third party agreement.) showing the visibility splay 4.5 metres by 215 metres at both directions onto the B9115 Drummuir - Turfhillock - Newtack Road (including the 215m forward sightline for the vehicles travelling westbound and assessment of vertical road alignment) with all boundaries set back to a position behind the required visibility splay, and a schedule of maintenance for the splay area has been submitted to and approved in writing by the Council, as Planning Authority in consultation with the Roads Authority; and ii. thereafter the visibility splay shall be provided in accordance with the approved drawing prior to any works commencing (except for those works associated with the provision of the visibility splay); and iii. thereafter the visibility splay shall be maintained at all times free from any obstruction exceeding 0.6 metres above the level of the carriageway in accordance with the agreed schedule of maintenance. Reason: To enable drivers of vehicles leaving/entering the site to have a clear view over a length of road sufficient to allow safe exit/entry, in the interests of road safety for the proposed development and other road users. 10. No development shall commence until: Page 9
Page 10
i. a detailed drawing (scale 1:500 or 1:1000 which shall also include details to demonstrate control of the land through evidence of ownership or provision of third-party agreement.) showing the visibility splay 4.5 metres by 90 metres at both directions onto the Blackhillock Road (U43H) with all boundaries set back to a position behind the required visibility splay, and a schedule of maintenance for the splay area has been submitted to and approved in writing by the Council, as Planning Authority in consultation with the Roads Authority; and ii. thereafter the visibility splay shall be provided in accordance with the approved drawing prior to any works commencing (except for those works associated with the provision of the visibility splay); and iii. thereafter the visibility splay shall be maintained at all times free from any obstruction exceeding 0.6 metres above the level of the carriageway in accordance with the agreed schedule of maintenance. Reason: To enable drivers of vehicles leaving/entering the site to have a clear view over a length of road sufficient to allow safe exit/entry, in the interests of road safety for the proposed development and other road users. 11. No development shall commence until a Construction Traffic Management Plan (CTMP) has been submitted to an agreed in writing by the Planning Authority in consultation with the Council Roads Authority and Transport Scotland. Thereafter the development shall be carried out in accordance with the agreed CTMP at all times. For the avoidance of doubt the CTMP shall include as a minimum the following information: • duration of works; • construction programme; • number of vehicle movements on each construction traffic route by daily/weekly/monthly frequency broken down by vehicle type/size and expected construction traffic generation during the peak construction periods are required as opposed to the average traffic generation over a period of time (i.e. materials, plant, staff, components); • schedule for delivery of materials and plant; • parking provision, loading and unloading areas for construction traffic; • full details of temporary arrangements to safeguard pedestrian movements during the construction period; • full details of any temporary access; • measures to be put in place to prevent material being deposited on the public road; • traffic management measures to be put in place during works including any specific instructions to drivers; • full details of construction traffic routes from/to the site, including any proposals for temporary haul routes and routes to be used for the disposal of any materials from the site; (The section of the section of B9115 from the site to Drummuir and Rosehall Road (U43aH) must not be used by HGV construction traffic associated with the proposed development); and • a programme of monitoring for all routes identified within the CTMP during construction will be required. Reason: To ensure an acceptable form of development in terms of the arrangements to manage traffic during construction works at the site. Page 10
Page 11
12. No development shall commence until evidence of a satisfactory Wear and Tear Agreement has been submitted to and agreed in writing by the Planning Authority in consultation with the Roads Authority. The scope of the Wear and Tear Agreement shall be agreed with the Planning Authority in consultation with the Roads Authority and shall include a condition survey of the network undertaken jointly by the developer and a representative from the Council. The survey shall include the full extent of the agreed construction traffic route(s) (within Moray) between the site and the ‘A’ class road network. In addition, the wear and tear agreement shall also include condition surveys of all roads identified as ‘unsuitable’ which must be agreed with the Planning Authority in consultation with the Roads Authority as a part of condition ‘11’ above. Reason: To mitigate the potential risks from damage to the public road occurring during the construction phase of the development. 13. No development shall commence until evidence of a financial guarantee or bond or suitable equivalent and a Wear and Tear Agreement have been put in place to ensure the repair of the public road serving the site in the event that the road is not maintained in a safe condition during the construction phase of the development and to restore the road to its pre-development condition within 1 year of the development becoming operational has been submitted to and agreed in writing with the Council, as Planning Authority. For the avoidance of doubt the agreement shall cover the length of the B9115 from A96 to site access and Blackhillock Road (U43H) from A96 to site access as a minimum and all roads identified as ‘unsuitable’ as in condition ‘11’ above. Reason: To mitigate the potential risks from damage to the public road occurring during the construction phase of the development. 14. Prior to the commencement of any part of the development, the following must be submitted for approval by the Planning Authority: a) Detailed proposals for undertaking trial runs and also delivery of abnormal indivisible loads, must be submitted for approval by the Planning Authority in consultation with Roads Authority. Details must include, measures proposed to protect the public road and structures, traffic management (including temporary waiting restrictions), vehicle holding areas and non- vehicular management during deliveries, time restrictions for deliveries i.e. out with school arrival and departure times. b) Detailed plans (1:200 min) of all works to accommodate the proposed abnormal indivisible deliveries must be submitted and approved by the Planning Authority in consultation with the Roads Authority. c) Details of an Assessment of the adequacy of the existing passing places along the B9115 Drummuir - Turfhillock - Newtack Road and Blackhillock Road (U43H) Road for the increased HGV construction traffic, including the distances between the existing passing places. The assessment should identify the improvements required for the existing passing places to provide a passing width of 6m over a 20m length with 10 metre tapers at each end. Third party land may be required to meet the required standard. Adjacent Passing places should be intervisible and have a maximum spacing not exceeding 150m. Page 11
Page 12
d) Detailed plans (1:200 min) of all temporary and permanent works proposed to the public road (based on the details of part ‘b’ and ‘c’ above of this condition) must be submitted and approved by the Planning Authority in consultation with the Roads Authority. e) Detailed plans (1:200 min) of all forestry clearance works related to the proposed wind farm development project along with the full details of the routes used for the timber traffic and associated enabling works must be submitted and approved by the Planning Authority in consultation with the Roads Authority. f) Details of an assessment of the structural integrity of the road pavement to demonstrate that the selected roads are capable of sustaining the level of development traffic generated during construction. The assessment should identify any strengthening and/or improvements where required for the existing road pavement to accommodate the anticipated construction traffic. g) Details of the proposals to promote a short-term Road Traffic Regulation Order allowing the introduction of a One - Way system for the triangular area incorporating the B9115 / C75H (Marypark Edintore Road) h) Notwithstanding the details submitted which are not accepted, classified traffic surveys over a 4-week period will be required for a neutral period out- with school/public holidays prior to development commencing. The counts will be required at locations to be agreed with Moray Council Transportation (Traffic) on the B9115 Drummuir - Turfhillock - Newtack Road and Blackhillock Road (U43H). i) Details of proposed CCTV camera system which will be implemented at the site entrance (B9115) to monitor adherence to the designated construction route. Thereafter, the development shall be completed in accordance with the approved details. Reason: To ensure an acceptable development in road safety terms through the provision of details currently lacking from the submission. 15. Prior to the commencement of construction and deliveries; a) The proposed new vehicular access on to the B9115 shall be developed to accommodate vehicle swept paths and have a maximum gradient of 1:20 measured for the first 5.0m from the edge of the public carriageway. The first 15 m of the access track, measured from the edge of the public road, shall be constructed to the Moray Council specification and surfaced with bituminous macadam. The additional temporary widening area should only use during the AILs deliveries and should be protected by an agreed barrier system to avoid entering other vehicles and to protect the edge of the road. b) A 35 metre length of hot rolled asphalt shall be provided on the B9115 (10 metres to the left (west) and 25 metres to the right (east) of the centreline of the new junction) and the B9115 should be widened to at least 6 metres over the length of the hot rolled asphalt section of the road at the new access junction including appropriate tapers, so that the delivery/construction vehicles do not have to overrun the verges when negotiating at the access junction. Page 12
Page 13
c) All suspensive works approved through condition (9 to 14 inclusive), must be completed in accordance with the approved plans. Any works undertaken are to be permanent for the duration of the operation of the development unless otherwise agreed in writing with the Roads Authority. Thereafter, the development shall be completed in accordance with the approved details. Reason: The provision of details currently lacking and in order to ensure that acceptable infrastructure is provided on the route to/from the development in the interests of road safety. 16. Prior to any abnormal indivisible load being delivered to the site: a) All suspensive works approved through conditions (9 to 15 a) and b) inclusive), must be completed in accordance with the approved plans. Any works undertaken are to be permanent for the duration of the operation of the development unless otherwise agreed in writing with the Roads Authority. b) Abnormal load trial run(s) must be undertaken after all mitigation works have been completed to confirm the works are acceptable and to identify any other restrictions not previously addressed and the frequency and location of abnormal load passing places/oncoming vehicle holding areas required. Representatives from Moray Council Transportation (Traffic), and Police Scotland must be invited to the trial run. Thereafter, the development shall be completed in accordance with the approved details. Reason: To ensure that acceptable infrastructure is provided on the route to/from the development in the interests of road safety. 17. No water shall be permitted to drain or loose material be carried onto the public footway/carriageway. Reason: To ensure the safety and free flow of traffic on the public road and access to the site by minimising the road safety impact from extraneous material and surface water in the vicinity of the new access. 18. Any existing ditch, watercourse or drain under the site access shall be piped using a suitable diameter of pipe, agreed with the Roads Maintenance Manager (300mm minimum). The pipe shall be laid to a self-cleansing gradient and connected to an outfall. Reason: To ensure the construction of an acceptable access in the interests of road safety and effective drainage infrastructure. 19. Prior to the commencement of construction and deliveries, a finalised Site- Specific Route Access Report and Construction Traffic Management Plan in respect of construction traffic that would affect the Aberdeenshire Road networks shall be submitted to and agreed by Moray Council, in consultation with the Aberdeenshire Council Structures Section. Page 13
Page 14
Thereafter, the development shall be completed in accordance with the approved details. Reason: To ensure an acceptable development in road safety terms on the Aberdeenshire Road network through the provision of details that are currently lacking from the submission. Archaeology 20. No works in connection with the development hereby approved shall commence unless a site protection plan has been submitted to and approved in writing by the planning authority. Site protection measures shall be shown on a layout plan accompanied by descriptive text and shall include: a) The location of the historic environment features to be protected during construction works; and b) The position and details of the warning signs and protective fencing to be erected. No works in connection with the development hereby approved shall commence unless the site protection measures have been implemented in full in accordance with the approved details. All protective fencing and warning signs shall be retained during the construction period in accordance with the approved details and no works shall take place at any time within the protected areas. Reason: In the interests of protecting known features of the historic environment. 21. No works in connection with the development hereby approved shall commence unless an archaeological written scheme of investigation (WSI) has been submitted to and approved in writing by the planning authority and a programme of archaeological works has been carried out in accordance with the approved WSI. The WSI shall include details of how the recording and recovery of archaeological resources found within the application site shall be undertaken, and how any updates, if required, to the written scheme of investigation will be provided throughout the implementation of the programme of archaeological works. Should the archaeological works reveal the need for post excavation analysis the development hereby approved shall not be brought into use unless a post-excavation research design (PERD) for the analysis, publication and dissemination of results and archive deposition has been submitted to and approved in writing by the planning authority. The PERD shall be carried out in complete accordance with the approved details. Reason: To safeguard and record the archaeological potential of the area. Scottish Gas Network 22. The development shall be implemented in accordance with the notification and mitigation requirements agreed between Scotland Gas Networks and the Developer, as contained within the revised Scotland Gas Network consultation response letter dated 17 December 2024. Reason: To allow for alternating current (AC) interference issues to be investigated if necessary and mitigated to protect SGN infrastructure. Page 14
Page 15
Scottish & Southern Electricity Networks 23. No development shall commence until a finalised Construction Traffic Management Plan (CTMP) has been submitted to and approved in writing by the Council, as Planning Authority in consultation with Scottish & Southern Electricity Networks Transmission. Thereafter, the development shall be implemented in accordance with these approved details. Reason: To ensure that construction traffic associated with the development is effectively managed and will not adversely impact the access road which is required by SSEN Transmission to access the Blackhillock substation at all times. 24. No development shall commence until a Scheme detailing interference mitigation works has been submitted to and approved in writing by the Council, as Planning Authority in consultation with Scottish & Southern Electricity Networks (SSEN). This Scheme shall encompass all the agreements contained within the mitigation agreement letter, signed by both SSEN and the Developer, dated 11 July 2025, submitted to the Council by SSEN. Thereafter, the approved Scheme of Mitigation shall be implemented in accordance with these approved details. Reason: To ensure that the identified mitigation is carried out in accordance with the approved details to protect Scottish & Southern Electricity Networks (SSEN) operational telecoms asset. Aviation Safety 25. No wind turbine shall be erected unless and until an Air Traffic Control Radar Mitigation Scheme to address the impact of the wind turbines upon air safety has been submitted to and approved in writing by Moray Council in conjunction with the Ministry of Defence (MOD). The Air Traffic Control Radar Mitigation Scheme (ATCRMS) is a scheme designed to mitigate the impact of the development upon the operation of the Air Traffic Control Radar System(s) used by RAF Lossiemouth (“the Radar”) and the air traffic control operations of the MOD which are reliant upon the Radar. The ATCRMS shall set out the appropriate measures to be implemented to mitigate the impact of the development on the Radar and shall be in place for the lifetime of the development provided the Radar remains in operation. The development shall be implemented strictly in accordance with the details set out in the approved ATCRMS. Reason: To maintain aviation safety. 26. No wind turbine erected as part of this development shall be permitted to rotate its rotor blades about its horizontal axis, other than for the purpose of testing radar mitigation for this development for specific periods as defined in the approved Air Traffic Control Radar Mitigation Scheme (ATCRMS) or otherwise arranged in accordance with provisions contained in the approved ATCRMS, until: Page 15
Page 16
a) those mitigation measures required to be implemented prior to any wind turbine being permitted to rotate its rotor blades about its horizontal axis as set out in the approved ATCRMS have been implemented; b) any performance criteria specified in the approved ATCRMS and which the approved ATCRMS requires to have been satisfied prior to any wind turbine being permitted to rotate its rotor blades about its horizontal axis have been satisfied and Moray Council, in conjunction with the Ministry of Defence, have confirmed this in writing. Thereafter the development shall be operated strictly in accordance with the details set out in the approved ATCRMS for the lifetime of the development, provided the Radar remains in operation. Reason: To maintain aviation safety. 27. Prior to commencing construction of any wind turbine generators, anemometry masts, or deploying any construction equipment or temporal structure(s) 50 metres or more in height (above ground level) the undertaker must submit an aviation lighting scheme for the approval of Moray Council in conjunction with the Civil Aviation Authority and the Ministry of Defence defining how the development will be lit throughout its life to maintain civil and military aviation safety requirements as required under the Air Navigation Order 2016 and, or, determined necessary for aviation safety by the Ministry of Defence and, or, as directed by the Civil Aviation Authority. This should set out: a) Details of any construction equipment and temporal structures with a total height of 50m or greater (above ground level) that will be deployed during the construction of wind turbine generators and details of any aviation warning lighting that they will be fitted with. b) the locations and heights of all wind turbine generators in the development identifying those that will be fitted with aviation warning lighting identifying the position of the lights on the wind turbine generators; the type(s) of lights that will be fitted and the performance specification(s) of the lighting type(s) to be used. Thereafter, the undertaker must exhibit such lights as detailed in the approved aviation lighting scheme. The lighting installed will remain operational for the lifetime of the development. Reason: To maintain aviation safety. 28. The undertaker must notify the Ministry of Defence, at least 14 days prior to the commencement of the works, in writing of the following information: a) the date of the commencement of the erection of wind turbine generators and anemometer masts; b) the maximum height of any construction equipment to be used in the erection of the wind turbines; c) the date any wind turbine generators are brought into use; d) the latitude and longitude and maximum heights of each wind turbine generator, and any anemometer mast(s). Page 16
Page 17
The Ministry of Defence must be notified of any changes to the information supplied in accordance with these requirements and of the completion of the construction of the development. Reason: To maintain aviation safety. 29. No turbine shall be erected until a Primary Radar Mitigation Scheme (PRMS) agreed with the Operator has been submitted to and approved in writing by the planning authority in order to mitigate the impact of the development on the Primary Radar Installation at Perwinnes and the associated air traffic management operations. Reason: To maintain aviation safety. 30. No turbine shall be erected unless and until the approved Primary Radar Mitigation Scheme has been implemented and the development shall thereafter be operated fully in accordance with such an approved Scheme. Reason: To maintain aviation safety. Reduced lighting scheme 31. Unless otherwise agreed in writing with the planning authority, prior to development commencing, a report detailing investigations into a reduced lighting scheme including an assessment of the potential for installation of an Aircraft Detection Lighting System (“ADLS”), with a statement setting out current and anticipated regulatory environment in relation to ADLS (or evidence of why this cannot be achieved), must be submitted to and approved in writing by the planning authority, in consultation with the Ministry of Defence and the Civil Aviation Authority. Thereafter the lighting scheme must be implemented in accordance with the approved scheme. Reason: To ensure that only the minimum necessary lighting requirement are developed and to allow for further consideration of the lighting proposals. Private Water Supply Management Plan 32. No development shall commence until a Private Water Supply Management Plan prepared by a suitably qualified professional has been submitted to and agreed by the Planning Authority. The plan shall include the mitigation identified in the EIA chapter 9 and the addition of Water Testing records as detailed in correspondence dated 13.09.24 from Greencat Renewables author Ciara Morton. This shall include the protection of supplies to the properties known as Mains of Auchindachy Farmhouse, Keith, AB55 5HT and Coldhome, Keith, AB55 5NX located to the north of the development site, in addition to those already identified in the EIA and additional correspondence. In the event that the wholesomeness or adequacy of any private water supply becomes affected by construction activity, all users of such supplies and Service Manager Community Protection of Moray Council must be contacted to discuss remediation measures as a priority. Thereafter repair of any affected private water supply must be carried be to the satisfaction of the Council as Planning Authority in consultation with the Service Page 17
Page 18
Manager Community Protection. The Council shall be the final arbiter whether any supply has been affected by this development. Reason: In order to safeguard the and maintain the wholesome provision of any private water supply affected by the development. Forestry 33. Prior to the commencement of the development or any tree felling on the site, a Compensatory Planting Plan (CP) detailing the provision of 18.63ha of tree planting shall be submitted to and approved in writing by the Council, as Planning Authority in consultation with Scottish Forestry. The CP must provide full details of the proposed planting, including its maintenance over the entire lifespan of the development and include the following information: a) The CP Plan must be prepared and delivered by qualified and experienced professionals, such as a chartered forester, responsible for both felling and compensatory planting. b) The 18.63 ha CP area must be clearly mapped and described and located in Moray. c) Any necessary statutory consents for implementing the CP must be identified and provided. d) A UKFS v5 compliant silvicultural plan must be submitted with maps, covering site preparation, planting method, species selection with proven site suitability and provenance, stocking density, maintenance, and long- term protection. e) CP must be completed within five years of woodland removal or two years of development completion, whichever is earlier. A maintenance plan and timeline must also be included, with establishment within the enforcement period. f) A qualified professional (e.g. chartered forester) must inspect the CP at Years 1, 5, and 10, report to the Planning Authority, and confirm the woodland is properly established and maintained. g) Restocking must occur within two years of woodland removal or associated development completion. Extensions are only permitted if justified by the Hylobius Decision Support System, but never beyond five years. h) The CP area must not include or affect land that is classified as prime agricultural land. i) The CP must include provision for at least 50% native broadleaf species. j) The CP should include, where possible, provision for public access to allow recreational use of the woodland and forest resource. Reason: To mitigate the effects of the development on woodland and ensure provision of satisfactory compensatory planting 34. Prior to the commencement of the development or any tree felling on the site, a revised felling and restocking strategy shall be submitted to and approved in writing by the Council, as Planning Authority in consultation with Scottish Forestry. The revised strategy must include the following information: a) Improvements shall be made to the design of the forestry on the development site with this focused on external margins which are currently Page 18
Page 19
angular with a poor fit to landform. These shall incorporate the addition of broadleaved planting to soften abrupt edges. b) The proportion of broadleaves within the forest shall be increased to at least match the hectarage in the baseline Forest Plan. c) Details of efforts made by the developer to include additional broadleaved planting on adjoining farmland, if possible and in agreement with appropriate parties, with this connecting to new broadleaved planting within the productive forest to enhance biodiversity in line with the requirements of NPF4 Policy 3 Biodiversity (which aims to deliver positive effects from development) and Policy 11 (particularly ix and xii which relates to mitigation and the quality of restoration plans) and also to improve wider landscape character. Reason: To mitigate the effects of the development on wider landscape character, ensure provision of a revised satisfactory felling and restocking plan and enhance biodiversity. Mitigation 35. No development shall commence until a Schedule of Mitigation has been submitted to and approved in writing by the Planning Authority. This Schedule shall encompass a list of all mitigation measures from the EIA Report, any other commitments made by the applicant and all relevant mitigation secured by conditions attached to this permission with defined timescales for implementation of each mitigation measure. Thereafter, the approved Schedule of Mitigation shall be implemented in full unless otherwise approved in writing by the Planning Authority. Reason: To ensure that the identified mitigation through the EIA Report is carried out in accordance with the approved details. Environmental Clerk of Works 36. No development shall commence until the terms of the appointment of a suitably qualified, experienced, and independent Ecological Clerk of Works (“ECoW”) by the applicant have been submitted to, and approved in writing by, the Planning Authority. The terms of appointment shall: i) impose a duty to monitor compliance with the ecological and hydrological commitments provided in the mitigation identified in the EIA Report and the Schedule of Mitigation approved under condition 35; any micro-siting approved under condition 41, the Construction Environmental Management Plan approved under condition 40; the habitat management plan approved under condition 38; and any species protection plans approved under condition 40; ii) require the ECoW to report to the developer's nominated construction project manager and the planning authority any incidences of noncompliance with the mitigation measures referred to at i) above at the earliest practical opportunity and no later than 5 working days following the incidence of non-compliance; Page 19
Page 20
iii) require the ECoW to direct the micro-siting and placement of the turbines, buildings, tracks, hardstanding, and other ancillary infrastructure in accordance with the micro-siting condition; iii) require the ECoW to submit a quarterly report to the Planning Authority summarising works undertaken on site; and iv) require the ECoW to advise on adequate protection of nature conservation interests on the site and be responsible for checks for protected species before and during construction. The ECoW shall be appointed on the approved terms prior to the commencement of development, throughout any period of construction activity and during any period of post construction restoration works. Reason: To secure effective monitoring of and compliance with the environmental mitigation and management measures associated with the development. Environmental Clerk of Works (Decommissioning) 37. No later than six months prior to decommissioning of the development or the expiration of this permission (whichever is the earlier), details of the terms of appointment of an independent environmental clerk of works throughout the decommissioning, restoration and aftercare phases of the development shall be submitted in writing to the planning authority for approval in writing. The environmental clerk of works shall be appointed on the approved terms throughout the decommissioning, restoration and aftercare phases of the development. Reason: To secure effective compliance with the environmental mitigation and management measures associated with the development during decommissioning. Habitat Management Plan and Biodiversity Enhancement 38. Prior to the commencement of development and further to the mitigation and enhancement contained within the Outline Habitat and Biodiversity Enhancement Management Plan (Appendix 6.4) and associated supplementary information hereby approved, the following must be submitted to the planning authority for approval in writing: - a) An updated Habitats and National Vegetation Classification (NVC) Survey and Outline Biodiversity Enhancement and Management Plan (OBEMP), incorporating additional enhancement out with the development site to strengthen habitat connectivity. b) A detailed Habitat Management and Monitoring Plan (HMMP), as referred to in Chapter 6 of the EIA Report. This shall set out proposed habitat management of the site during the period of construction, operation, and decommissioning, restoration and aftercare, and shall provide for the maintenance, monitoring and reporting of habitat on site. This shall provide provision and details for regular monitoring and review to be undertaken against the HMMP objectives and reasonable measures for securing amendments or additions to the HMP in the event that the HMMP objectives are not being met. Page 20
Page 21
The approved OBEMP and HMMP shall be implemented in full, unless otherwise agreed in advance in writing by the Planning Authority. Reason: In the interests of the protection of the habitats of those species identified in the EIA Report and provision of biodiversity enhancement and to minimise potential impacts on flora and fauna. Drainage 39. Unless otherwise agreed with the planning authority in writing, a finalised drainage impact assessment, showing the following must be submitted to and approved in writing by the planning authority (in consultation with Moray Flood Risk Management Team) prior to completion of all water crossing(s) and turbine foundation pads. The drainage impact assessment should be based upon the designed drainage mitigation contained in Chapters 9 of the EIA report and detail the following: a) plans submitted with the definitive track and turbine pad layout of the drainage system for both the construction phase and the final site layout once micro-siting allowances have been made; b) the drainage system should be designed to a 1:30 year return period (including 37% climate change), without surcharging, if attenuation is used the system must drain completely within 24 hours; c) demonstrate that the post development run-off rate does not exceed the predevelopment run-off rate, or increase the risk of flooding to the surrounding land; and d) confirm that drainage is not redirected to allow surface water draining from one catchment to drain into a different catchment either at construction phase or completion. Reason: To ensure all the necessary flood prevention measures are in place and to ensure that protection of the water environment is maintained throughout the construction, operation and decommissioning of the development. Construction Environmental Management Plan 40. No development shall commence until a Construction and Environmental Management Plan (CEMP), containing site specific details of all on-site construction works, post-construction reinstatement, drainage and mitigation, together with details of their timetabling, has been submitted to, and approved in writing by, the Planning Authority, in consultation with the Service Manager Community Protection. The CEMP shall be informed by the site and ground investigation works and best practice. The CEMP shall provide: a) A site waste management plan (dealing with all aspects of waste produced during the construction period), including details of contingency planning in the event of accidental release of materials which could cause harm to the environment, evidencing all proposals comply with SEPA’s guidance and the requirements of the waste management licensing regime as appropriate; b) Details of the location, layout, formation of the construction compound, welfare facilities, any areas of hardstanding, turning areas, internal access tracks, car parking, material stockpiles, oil, fuel and chemical storage, Page 21
Page 22
lighting columns, and any construction compound boundary fencing required for the construction period; c) A dust management plan detailing all mitigation/dust suppression measures intended to reduce the impacts of dust on site, including measures to reduce dust on roads; d) Site specific details for management and operation of any concrete batching plant (including disposal of pH-rich waste water and substances); e) Details of measures to be taken to prevent loose or deleterious material being deposited on the local road network including wheel cleaning and lorry sheeting facilities, and measures to clean the site entrances and the adjacent local road network; f) A Pollution Prevention and Incident Plan incorporating a Pollution Prevention Plan, Pollution Incident Plan and a Pollution Control Monitoring Plan, this shall provide measures to protect watercourses, groundwater, management of natural surface hydrological flows (flushes, springs, etc.) and protection of soils, arrangements for the storage and management of oil and fuel and other chemicals on the site and sewage disposal and treatment; g) Details of soil storage and management including outline quantities, locations (other than peat and other carbon rich soils) management of long term storage of construction generated to facilitate future site restoration; h) A drainage management strategy, demonstrating how all surface and waste water arising during and after construction is to be managed and prevented from impacting on the water environment and to mitigate flood risk; i) A surface water and groundwater management and treatment plan, including details of the separation of clean and dirty water drains, and location of settlement lagoons for silt laden water; j) Details of temporary site illumination, including measures to ensure light spill/pollution is minimised and avoids habitats within the site and does not extend beyond the immediate working area, and not beyond the site boundary; k) Protected Species Plan. The Plan shall be informed by otter, badger, water vole, red squirrel, wild cat and breeding bird surveys (for construction works within the breeding bird season) carried out by a suitably qualified person. The surveys shall inform the mitigation measures required to protect these protected species during construction of the Development. The Plan shall provide mitigation measures, as required, and a timetable for implementation. l) Site-specific Construction Method Statements for the following: i. crane pads; ii. turbine foundations; iii. working cable trenches; iv. erection of the wind turbines; v. Substation compound formation, erection of associated buildings and ancillary infrastructure; vi. watercourse crossings including full details and plans of the design and specification of all new and upgraded watercourse crossings to be constructed, ensuring continuous flow and fish passage with no hanging culverts, noting all crossings shall be oversized bottomless arched culverts or traditional style bridges; m) Details of post-construction restoration/reinstatement of the working areas not required during the operation of the development; Page 22
Page 23
n) A Construction Noise Management Plan including details of the management of noise and vibration during construction and post- construction restoration, including that caused by construction traffic, to the lowest practicable levels and in accordance with BS 5228:2009 “Code of Practice for noise and vibration control on construction and open sites – Part 1: Noise and Part 2: Vibration” (or any updated version/document which superseded this document) and how any properties likely to be affected by construction noise will be kept informed; o) Construction Method Statements for all roads/tracks to be altered/formed within the development site including their width, likelihood of widening or passing places, means of drainage (which shall have regard to SUDS principles), means of construction, and edge reinstatement including verge width. The specification shall be accompanied by relevant plans at a scale sufficient; p) The cable trenches; q) A phasing plan for the construction works; and r) A written scheme which details the methodology for dealing with any revisions to any of the documents required under this part (3). Any revised documents will require to be submitted to and approved in writing by the Planning Authority prior to the revisions being implemented on site. Thereafter, the development shall be implemented in accordance with the CEMP approved under this condition unless otherwise approved in advance in writing by the Planning Authority. Reason: To ensure that all construction operations are carried out in a manner that minimises their impact on road safety, amenity and the environment, and that the mitigation measures contained in the EIA Report accompanying the application, or as otherwise agreed, are fully implemented. Micro-siting 41. All wind turbines, buildings, areas of hardstanding and tracks shall be constructed in the locations shown in drawing C4221 (P) 101 Rev A - Site Layout. The location of the wind turbines, compounds, areas of hardstanding and tracks may be varied (micro-sited) within the site subject to the following, unless otherwise approved in advance in writing by the planning authority: i) no wind turbine, building, mast, tracks, hardstanding or other ancillary infrastructure shall be moved more than 50 metres from the position shown within the drawing C4221 (P) 101 Rev A - Site Layout. If any micro-siting is sought, it must first be approved in writing by the planning authority (in consultation with the Ministry of Defence – Safeguarding and NATS). ii) all micro-siting permissible under this condition must be approved in advance in writing by the appointed ECoW. iii) for any micro-siting of turbines which results in an increase in altitude of more than 5m from the approved position, a prior request for approval in writing must be made to the planning authority (in consultation with the Ministry of Defence, Safeguarding and NATS). Such a request must be accompanied by an updated and comparative ZTV plan and wireline montages as required by the planning authority. No such micro-siting can take place without the written approval of the planning authority. Page 23
Page 24
No later than two months after the date of final commissioning, an updated site plan shall be submitted to the planning authority showing the final position of all wind turbines, areas of hardstanding, tracks and associated infrastructure forming part of the development. The plan must also specify areas where micro- siting has taken place and, for each instance, be accompanied by the ECoW or the planning authority's written approval, as applicable. Reason: To ensure that micro-siting decisions take account of environmental impacts and local ground conditions, including existing infrastructure. Community Wealth Building Plan 42. Prior to development commencing, an updated Community Wealth Building Plan shall be submitted to and approved in writing by the Council, as Planning Authority. The plan shall be prepared in accordance with the Moray Council’s adopted “Community Wealth Building Planning Guidance” and shall also be accompanied by a monitoring statement, which shall demonstrate how the development will deliver beneficial effects to the local economy from the construction and operation of the approved wind farm. Thereafter the development shall be implemented in accordance with the approved details, unless otherwise agreed in writing with the Council as Planning Authority. Reason: To ensure compliance with National Planning Framework 4 Policies 11 and 25 with regard to community wealth building. Windfarm Noise 43. The rating level of noise immissions from the combined effects of the wind turbines (including the application of any tonal penalty and amplitude modulation (AM) penalty) when determined in accordance with the attached Guidance Notes (to this condition), shall not exceed the values for the relevant integer wind speed set out in, or derived from, the tables attached to these conditions at any dwelling which is lawfully existing or has planning permission at the date of this permission and: a) The wind farm operator shall continuously log power production, wind speed and wind direction, all in accordance with Guidance Note 1(d). These data shall be retained for a period of not less than 24 months. The wind farm operator shall provide this information in the format set out in Guidance Note 1(e) to the Local Planning Authority on its request, within 14 days of receipt in writing of such a request. b) No electricity shall be exported until the wind farm operator has submitted to the Local Planning Authority for written approval a list of proposed independent consultants who may undertake compliance measurements in accordance with this condition. Amendments to the list of approved consultants shall be made only with the prior written approval of the Local Planning Authority. c) Within 21 days from receipt of a written request from the Planning Authority following a complaint to it from an occupant of a dwelling alleging noise disturbance at that dwelling, the wind farm operator shall, at its expense, employ a consultant approved by the Local Planning Authority to assess the level of noise immissions from the wind farm at the complainant’s dwelling in accordance with the procedures described in the attached Guidance Page 24
Page 25
Notes. The written request from the Local Planning Authority shall set out at least the date, time and location that the complaint relates to and any identified atmospheric conditions, including wind direction, and include a statement as to whether, in the opinion of the Local Planning Authority, the noise giving rise to the complaint contains or is likely to contain a tonal component, or is likely to contain an amplitude modulation (AM) component. d) The assessment of the rating level of noise immissions shall be undertaken in accordance with an assessment protocol that shall, prior to the commencement of any measurements, have been submitted to and approved in writing by the Local Planning Authority. The protocol shall include the proposed measurement location identified in accordance with the Guidance Notes where measurements for compliance checking purposes shall be undertaken, whether noise giving rise to the complaint contains or is likely to contain a tonal component and/or amplitude modulation (AM) component and also the range of meteorological and operational conditions (which shall include the range of wind speeds, wind directions, power generation and times of day) to determine the assessment of rating level of noise immissions. The proposed range of conditions shall be those which prevailed during times when the complainant alleges there was disturbance due to noise, having regard to the written request of the Local Planning Authority under paragraph (c), and such others as the independent consultant considers likely to result in a breach of the noise limits. e) Where a dwelling to which a complaint is related is not listed in the tables attached to these conditions, the wind farm operator shall submit to the Local Planning authority for written approval proposed noise limits selected from those listed in the Tables to be adopted at the complainant’s dwelling for compliance checking purposes. The proposed noise limits are to be those limits selected from the Tables specified for a listed location which the independent consultant considers as being likely to experience the most similar background noise environment to that experienced at the complainant’s dwelling. The rating level of noise immissions resulting from the combined effects of the wind turbines when determined in accordance with the attached Guidance Notes shall not exceed the noise limits approved in writing by the Local Planning Authority for the complainant’s dwelling. f) The wind farm operator shall provide to the Local Planning Authority the independent consultant’s assessment of the rating level of noise immissions undertaken in accordance with the Guidance Notes within 2 months of the date of the written request of the Local Planning Authority for compliance measurements to be made under paragraph (c), unless the time limit is extended in writing by the Local Planning Authority. Unless otherwise agreed in writing by the Local Planning Authority, the assessment shall be accompanied by all data collected for the purposes of undertaking the compliance measurements, such data to be provided in the format set out in Guidance Note 1(e) of the Guidance Notes with the exception of audio data which shall be supplied in the format in which it is recorded. The instrumentation used to undertake the measurements shall be calibrated in accordance with Guidance Note 1(a) and certificates of calibration shall be submitted to the Local Planning Authority with the independent consultant’s assessment of the rating level of noise immissions. Page 25
Page 26
g) Where a further assessment of the rating level of noise immissions from the wind farm is required pursuant to Guidance Note 4(c), the wind farm operator shall submit a copy of the further assessment within 21 days of submission of the independent consultant’s assessment pursuant to paragraph (d) above unless the time limit has been extended in writing by the Local Planning Authority. Table 1: Between daytime (07:00 to 23:00 hours) – Noise limits expressed in dB LA90,10 minute as a function of the standardised wind speed (m/s) at 10 metre height as determined within the site averaged over 10 minute periods. Location Standardised 10 metre-height Wind Speed (as defined in accordance with the attached Guidance Notes to the noise condition) 4 5 6 7 8 9 10 11 12 Blackhillock Croft 30 35 38 39 39 39 39 39 39 North Whiteley 32 37 40 40 40 40 40 40 40 Marypark 28 33 36 36 36 36 36 36 36 Mains of Pitlurg 22 27 31 31 31 31 31 31 31 Rinnes View 27 32 35 36 36 36 36 36 36 Little Pitlurg 25 30 33 34 34 34 34 34 34 Edintore-Taber Chalich 27 32 35 35 35 35 35 35 35 Edintore Farmhouse 27 32 35 35 35 35 35 35 35 Edintore Cottage 24 29 32 32 32 32 32 32 32 Drumgrain 25 30 33 33 33 33 33 33 33 Davieburn Kennels 26 31 34 34 34 34 34 34 34 Davieburn Lodge 26 31 34 35 35 35 35 35 35 Mossend 26 31 34 34 34 34 34 34 34 Alder Brae 28 33 36 37 37 37 37 37 37 Newton 31 36 39 39 39 39 39 39 39 Quarryhead 30 35 38 38 38 38 38 38 38 Millwood 29 34 37 37 37 37 37 37 37 Auchorties 26 31 34 35 35 35 35 35 35 Table 2: Between night time periods (23:00 to 07:00 hours) – Noise limits expressed in dB LA90,10 minute as a function of the standardised wind speed (m/s) at 10 metre height as determined within the site averaged over 10 minute periods Location Standardised 10 metre-height Wind Speed (as defined in accordance with the attached Guidance Notes to the noise condition) 4 5 6 7 8 9 10 11 12 Blackhillock Croft 30 35 38 39 39 39 39 39 39 North Whiteley 32 37 40 40 40 40 40 40 40 Marypark 28 33 36 36 36 36 36 36 36 Mains of Pitlurg 22 27 31 31 31 31 31 31 31 Rinnes View 27 32 35 36 36 36 36 36 36 Little Pitlurg 25 30 33 34 34 34 34 34 34 Edintore-Taber Chalich 27 32 35 35 35 35 35 35 35 Page 26
Page 27
Edintore Farmhouse 27 32 35 35 35 35 35 35 35 Edintore Cottage 24 29 32 32 32 32 32 32 32 Drumgrain 25 30 33 33 33 33 33 33 33 Davieburn Kennels 26 31 34 34 34 34 34 34 34 Davieburn Lodge 26 31 34 35 35 35 35 35 35 Mossend 26 31 34 34 34 34 34 34 34 Alder Brae 28 33 36 37 37 37 37 37 37 Newton 31 36 39 39 39 39 39 39 39 Quarryhead 30 35 38 38 38 38 38 38 38 Millwood 29 34 37 37 37 37 37 37 37 Auchorties 26 31 34 35 35 35 35 35 35 Table 3: Co-ordinate locations of the dwellings listed in Tables 1 and 2: Receptor Grid Reference Easting Northing Blackhillock Croft 343475 848073 North Whiteley 343632 847116 Marypark 343751 846526 Mains of Pitlurg 343713 845587 Rinnes View 343051 846082 Little Pitlurg 342728 845771 Edintore-Taber Chalich 342796 845996 Edintore Farmhouse 342618 846043 Edintore Cottage 341971 845641 Drumgrain 341388 845790 Davieburn Kennels 341161 846370 Davieburn Lodge 340939 846644 Mossend 340838 846690 Alder Brae 340926 847144 Newton 341082 847486 Quarryhead 341199 848053 Millwood 341735 848498 Auchorties 342987 848930 Note to Table 3: The geographical coordinate references are provided for the purpose of identifying the general location of dwelling to which the noise limits apply. Reason: to protect the amenity of nearby dwellings and to prevent nuisance. Guidance Notes for Noise Condition These notes are to be read with and form part of the noise condition. They further explain the condition and specify the methods to be employed in the assessment of complaints about noise immissions from the wind farm. The rating level at each integer wind speed is the arithmetic sum of the wind farm noise level as determined from the best-fit curve described in Guidance Note 2 of these Guidance Notes and any tonal penalty applied in accordance with Guidance Note 3, and any Amplitude Modulation (AM) penalty applied in Guidance Note 5. Reference to ETSU-R-97 refers to the publication entitled “The Assessment and Rating of Noise from Wind Farms” (1997) Page 27
Page 28
published by the Energy Technology Support Unit (ETSU) for the Department of Trade and Industry (DTI). Guidance Note 1 a) Values of the LA90,10 minute noise statistic should be measured at the complainant’s property, using a sound level meter of EN 60651/BS EN 60804 Type 1, or BS EN 61672 Class 1 quality (or the equivalent UK adopted standard in force at the time of the measurements) set to measure using the fast time weighted response as specified in BS EN 60651/BS EN 60804 or BS EN 61672-1 (or the equivalent UK adopted standard in force at the time of the measurements). This should be calibrated in accordance with the procedure specified in BS 4142: 1997 (or the equivalent UK adopted standard in force at the time of the measurements). Measurements shall be undertaken in such a manner to enable a tonal penalty to be applied in accordance with Guidance Note 3. b) The microphone should be mounted at 1.2 – 1.5 metres above ground level, fitted with a two-layer windshield or suitable equivalent approved in writing by the Local Planning Authority, and placed outside the complainant’s dwelling. Measurements should be made in “free field” conditions. To achieve this, the microphone should be placed at least 3.5 metres away from the building facade or any reflecting surface except the ground at the approved measurement location. In the event that the consent of the complainant for access to his or her dwelling to undertake compliance measurements is withheld, the wind farm operator shall submit for the written approval of the Local Planning Authority details of the proposed alternative representative measurement location prior to the commencement of measurements and the measurements shall be undertaken at the approved alternative representative measurement location. c) The LA90,10-minute measurements should be synchronised with measurements of the 10-minute arithmetic mean wind and operational data logged in accordance with Guidance Note 1(d), including the power generation data from the turbine control systems of the wind farm. d) To enable compliance with the conditions to be evaluated, the wind farm operator shall continuously log arithmetic mean wind speed in metres per second and wind direction in degrees from north at hub height for each turbine, and at any on site meteorological mast(s), if available, together with the arithmetic mean power generated by each turbine, all in successive 10-minute periods. All 10 minute arithmetic average mean wind speed data measured at hub height shall be ‘standardised’ to a reference height of 10 metres as described in ETSU-R-97 at page 120 using a reference roughness length of 0.05 metres . It is this standardised 10 metre height wind speed data, as determined from whichever source is agreed in writing with the Local Planning Authority as being most appropriate to the noise compliance measurements being undertaken, which is correlated with the noise measurements determined as valid in accordance with Guidance Note 2, such correlation to be undertaken in the manner described in Guidance Note 2. All 10-minute periods shall commence on the hour and in 10- minute increments thereafter. e) Data provided to the Local Planning Authority in accordance with the noise condition shall be provided in comma separated values in electronic format. f) A data logging rain gauge shall be installed in the course of the assessment of the levels of noise immissions. The gauge shall record over successive 10-minute periods synchronised with the periods of data recorded in accordance with Note 1(d). Page 28
Page 29
Guidance Note 2 a) The noise measurements shall be made so as to provide not less than 20 valid data points as defined in Guidance Note 2 (b) b) Valid data points are those measured in the conditions specified in the agreed written protocol under paragraph (d) of the noise condition, but excluding any periods of rainfall measured in the vicinity of the sound level meter. Rainfall shall be assessed by use of a rain gauge that shall log the occurrence of rainfall in each 10 minute period concurrent with the measurement periods set out in Guidance Note 1. c) For those data points considered valid in accordance with Guidance Note 2(b), values of the LA90,10 minute noise measurements and corresponding values of the 10- minute standardised ten metre height wind speed, as derived from the site measured wind speed source(s) agreed in writing with the Local Planning Authority in accordance with Guidance Note 1(d), shall be plotted on an XY chart with noise level on the Y-axis and the standardised mean wind speed on the X- axis. A least squares, “best fit” curve of an order deemed appropriate by the independent consultant (but which may not be higher than a fourth order) should be fitted to the data points and define the wind farm noise level at each integer speed. Guidance Note 3 a) Where, in accordance with the approved assessment protocol under paragraph (d) of the noise condition, noise immissions at the location or locations where compliance measurements are being undertaken contain or are likely to contain a tonal component, a tonal penalty is to be calculated and applied using the following rating procedure. b) For each 10 minute interval for which LA90,10 minute data have been determined as valid in accordance with Guidance Note 2 a tonal assessment shall be performed on noise immissions during 2 minutes of each 10 minute period. The 2 minute periods should be spaced at 10 minute intervals provided that uninterrupted uncorrupted data are available (“the standard procedure”). Where uncorrupted data are not available, the first available uninterrupted clean 2 minute period out of the affected overall 10 minute period shall be selected. Any such deviations from the standard procedure, as described in Section 2.1 on pages 104-109 of ETSU-R-97, shall be reported. c) For each of the 2 minute samples the tone level above or below audibility shall be calculated by comparison with the audibility criterion given in Section 2.1 on pages 104109 of ETSU-R-97. d) The average tone level above audibility shall be calculated for each wind speed bin, each bin being 1 metre per second wide and centred on integer wind speeds. Samples for which the tones were below the audibility criterion or no tone was identified, a value of zero audibility shall be substituted. e) The tonal penalty for each wind speed bin is derived from the margin above audibility of the tone according to the figure below. Page 29
Page 30
Guidance Note 4 a) If a tonal penalty is to be applied in accordance with Guidance Note 3 the rating level of the turbine noise at each wind speed is the arithmetic sum of the measured noise level as determined from the best fit curve described in Guidance Note 2 and the penalty for tonal noise as derived in accordance with Guidance Note 3 at each integer wind speed within the range specified by the Local Planning Authority in its written protocol under paragraph (d) of the noise condition. b) If no tonal penalty is to be applied, then the rating level of the turbine noise at each wind speed is equal to the measured noise level as determined from the best fit curve described in Guidance Note 2. c) In the event that the rating level is above the limit(s) set out in the Tables attached to the noise conditions or the noise limits for a complainant’s dwelling approved in accordance with paragraph (e) of the noise condition, the independent consultant shall undertake a further assessment of the rating level to correct for background noise so that the rating level relates to wind turbine noise immission only. d) The wind farm operator shall ensure that all the wind turbines in the development are turned off for such period as the independent consultant requires to undertake the further assessment. The further assessment shall be undertaken in accordance with the following steps e) To this end, the steps in Guidance Note 2 shall be repeated with the required number of turbines shut-down in accordance with Guidance Note 4(d) in order to determine the background noise (L3) at each integer wind speed within the range requested by the Local Planning Authority in its written request under paragraph (c) and the approved protocol under paragraph (d) of the noise condition. f) The wind farm noise (L1) at this speed shall then be calculated as follows where L2 is the measured level with turbines running but without the addition of any tonal penalty: g) The rating level shall be re-calculated by adding arithmetically the tonal penalty (if any is applied in accordance with Note 3) to the derived wind farm noise L1 at that integer wind speed. h) If the rating level after adjustment for background noise contribution and adjustment for amplitude modulation and/or tonal penalties (if required in accordance with Guidance Note 3 and 5 ) at any integer wind speed lies at or below the values set out in the Tables attached to the conditions or at or below the noise limits approved by the Local Planning Authority for a complainant’s Page 30
Page 31
dwelling in accordance with paragraph (e) of the noise condition then no further action is necessary. If the rating level at any integer wind speed exceeds the values set out in the Tables attached to the conditions or the noise limits approved by the Local Planning Authority for a complainant’s dwelling in accordance with paragraph (e) of the noise condition, then the development fails to comply with the conditions. Guidance Note 5 a) Where, in accordance with the assessment protocol agreed under the noise condition, noise immissions at the location or locations where compliance measurements are being undertaken contain or are likely to contain an amplitude modulation component, an amplitude modulation penalty is to be calculated and applied using the following rating procedure. b) The analysis of amplitude modulation shall be undertaken using the Institute of Acoustics (IOA) metric described in “A Method for Rating Amplitude Modulation in Wind Turbine Noise” dated 9th August 2016 or any update of that method. The value of AM obtained with the IOA metric for each ten-minute period shall be converted to a penalty in decibels in accordance with the graph below. At each integer wind speed, a penalty for AM would be based on the arithmetic average of the calculated penalties for all valid periods assessed at this wind speed. Guidance Note 6 a) At each integer wind speed, the tonal penalty determined in accordance with Guidance Note 3 and the amplitude modulation penalties determined in accordance with Guidance Note 5 would be added arithmetically, except where the AM penalty and the tonal penalty relate to the same characteristic (e.g. amplitude modulated tones), only the larger of the AM or tonal penalty should be applied. 44. There shall be no Commencement of Development unless full details of the proposed wind turbines (including the power rating, sound power levels, and tonality assessment carried out on the selected turbine) have been submitted to and approved in writing by the Planning Authority. Page 31
Page 32
Reason: To allow the Planning Authority to monitor compliance with controls on noise imposed by conditions on this consent. 45. The wind farm operator shall employ an independent consultant, approved by the Planning Authority, to measure and where necessary calculate, at the operator’s own expense, the level of noise immissions from the wind turbines within the first year of the operation of the turbines. The measurement procedures, which may include filtering data according to wind direction, shall be agreed with the Planning Authority prior to commencement. The results of any measurement exercise shall be forwarded to the Planning Authority as soon as practicable after the completion of the monitoring exercise. Reason: To check compliance with the immission limits set in the Noise Condition above and thereby to protect the amenity of nearby dwellings and prevent nuisance. 46. a) Construction work shall only take place on the site between the hours of 07.00 to 19.00 on Monday to Friday inclusive and 07.00 to 16.00 on Saturdays, with no construction work taking place on a Sunday or on national public holidays or bank holidays other than concrete pouring if started within those hours, turbine erection and emergency works. The developer shall notify the Planning Authority of such works if carried out outside the permitted hours within two working days of their occurrence. b) Heavy Goods Vehicles (HGV) movements to and from the site (excluding abnormal loads) during construction of the wind farm shall be limited to 07.00 to 19.00 Monday to Friday, and 07.00 to 16.00 on Saturdays, with no HGV movements to or from site taking place on a Sunday or on national public holidays or bank holidays unless otherwise agreed in writing by the Planning Authority. c) Turbine delivery may be made out with these construction hours, where necessary, and as agreed in writing in advance with the Planning Authority. For the avoidance of doubt the public holidays or bank holidays are detailed as follows: • New Year's Day, if it is not a Sunday or, if it is a Sunday, 3rd January; 2nd January, if it is not a Sunday or, if it is a Sunday, 3rd January; • Good Friday; • The first Monday in May; • The first Monday in August; • 30th November, if it is not a Saturday or Sunday or, if it is a Saturday or Sunday, the first Monday following that day; • Christmas Day, if it is not a Sunday or if it is a Sunday, 27th December; and Boxing Day, if it is not a Sunday or, if it is a Sunday, the 27th December. Reason: To protect local residents from noise nuisance in ensuring the construction phase is restricted within permitted hours. Shadow flicker Page 32
Page 33
47. At the reasonable request of the Planning Authority following a complaint the wind farm operator shall investigate and instigate appropriate measures to minimise the effects of shadow flicker. Reason: To protect the amenity of nearby dwellings from shadow flicker and to prevent nuisance. Decommissioning, Restoration and Aftercare 48. a) The development will cease to generate electricity by no later than the date falling 40 years from the date of final commissioning. The total period for decommissioning and restoration of the site in accordance with this condition shall not exceed 42 years from the date of final commissioning without prior written approval of the planning authority. b) Prior to the commencement of development an outline decommissioning, restoration and aftercare method statement shall be submitted to and approved in writing by the planning authority in consultation with the Scottish Environment Protection Agency. The method statement shall include measures for the decommissioning of the development, restoration and aftercare of the site and will include, without limitation, proposals for the removal of the above ground elements of the development, the treatment of ground surfaces, the management and timing of the works and environmental management provisions. c) No later than one year prior to decommissioning of the development or the expiration of the 40 year period of operation (whichever is the earlier) a detailed decommissioning, restoration and aftercare method statement, based upon the principles of the approved outline decommissioning, restoration and aftercare method statement, shall be submitted to the planning authority for written approval in consultation with the Scottish Environment Protection Agency. The detailed decommissioning, restoration and aftercare method statement will provide updated and detailed proposals for the removal of above ground elements of the development, the treatment of ground surfaces, the management and timing of the works and environment management provisions. d) The development shall be decommissioned, site restored, and aftercare thereafter undertaken in accordance with the detailed decommissioning, restoration and aftercare method statement as approved, unless otherwise agreed in writing in advance with the planning authority in consultation with Scottish Environment Protection Agency. Reason: To ensure the decommissioning and removal of the development in an appropriate and environmentally acceptable manner and the restoration and aftercare of the site, in the interests of safety, amenity and environmental protection. Financial Guarantee 49. a) No development shall commence until a bond or other form of financial guarantee in terms which secures the cost of performance of all decommissioning, restoration and aftercare obligations referred to in Page 33
Page 34
condition 48 has been submitted to and approved in writing by the planning authority. b) The value of the financial guarantee shall be agreed between the developer and the planning authority or, failing agreement, determined (on application by either party) by a suitably qualified independent professional as being sufficient to meet the costs of all decommissioning, restoration and aftercare obligations referred to in condition 48 above. c) The financial guarantee shall be maintained in favour of the planning authority until the date of completion of all decommissioning, restoration and aftercare obligations referred to in condition ‘48’ above. d) The value of the financial guarantee shall be reviewed by agreement between the developer and the planning authority or, failing agreement, determined (on application by either party) by a suitably qualified independent professional not less than every five years and at the time of the approval of the detailed decommissioning, restoration and aftercare plan approved under condition 48. The value of the financial guarantee shall be increased or decreased to take account of any variation in costs of compliance with decommissioning, restoration and aftercare obligations referred to in condition 48 and best practice prevailing at the time of each review. Reason: To ensure that there are sufficient funds to secure performance of the decommissioning, restoration and aftercare conditions attached to this deemed planning permission in the event of default by the developer. Page 34
Page 35
Report to: Planning and Regulatory Services Committee Meeting Date: 16 December 2025 Report by: Executive Director Economy, Enterprise and Operations Author: Andrew Miller Contact Email: andrew.miller@moray.gov.uk Subject: 25/01634/S37 - Consultation response to Scottish Minsters for a proposed 186km overhead transmission line (400kV) and associated development between Beauly and Peterhead 1. PURPOSE ☒ For Decision ☐ For Information 1.1 The purpose of this report is to consider the consultation request received from the Energy Consents Unit (ECU) of the Scottish Government in relation to an application under section 37 of the Electricity Act 1989 for a new overheard electricity line running between Beauly and Peterhead. This section of the Act relates to consent for onshore electricity transmission infrastructure. 1.2 This report is submitted to Committee in terms of Section III (E) (1) of the Council’s Scheme of Administration relating to exercising the function of the Council as Planning Authority. 2. SUMMARY 2.1 This report considers a consultation request from the ECU seeking a response from Moray Council on an application made by Scottish Hydro Electric Transmission PLC under section 37 of the Electricity Act 1989 for a new 400kV overhead electricity transmission line running between Beauly and Peterhead. It recommends the Council raise no objection to the consultation response, subject to a suite of conditions to mitigate the impact of the proposal on local infrastructure, the environment and the amenity of the area surrounding the proposed route. 3. RECOMMENDATIONS 3.1 It is recommended that Committee: i) consider and note the contents of the report, as set out in Appendix 1, including the conclusions about the planning and wider merits of the development (see Section 5 below) where taking into account National Planning Framework 4, Moray Local Development Plan 2020 and all other material considerations, it is recommended that Moray Council does not Item 5. Page 35
Page 36
object to the section 37 application; and ii) agree to respond to the consultation from the Energy Consents Unit, raising no objection to the currently proposed development on the basis of the recommendations set out in Appendix 1 and conditions in Appendix 2. 3.2 If the Committee are minded to raise an objection to the section 37 consultation, the Committee should provide reasons for formally objecting to the section 37 application, but officers recommend the approach suggested in 3.1 (ii) above. Andrew Miller Acting Principal Planning Officer 4. BACKGROUND AND CONTEXT 4.1 As the proposal involves obtaining consent to install, operate, and maintain an electric line of 132 kilovolt (kV) or above (in this case a 400kV line), the determination of the proposal rests with the Electricity Consents Unit (ECU) within the Scottish Government. The ECU is responsible for consulting statutory consultees and relevant local authorities, receiving representations, and making the final decision. In this context, the Council acts as a consultee rather than the determining authority. The ECU has requested comments from the Council, as well as Aberdeenshire and Highland Councils, regarding the proposed electric line within a specified timeframe, alongside responses from other consultees. Notably, if a Council objects to a section 37 consultation, this generally triggers a Public Local Inquiry (PLI). 5. PROPOSALS 5.1 The proposal subject to this consultation is described as a new double circuit steel structure 400 kV overhead line (OHL) to connect into new substation sites at Beauly, New Deer and Peterhead with a length of 186 km, 59 km of which would be in Moray. A detailed description of the OHL route and infrastructure proposed is in sections 3 and 4 of Appendix 1. 5.2 A report of handling as detailed in Appendix 1 details the main considerations for the Council in responding to the consultation request. The report finds that the OHL and resultant loss of woodland to accommodate it will have significant adverse landscape and visual impact on Moray, particularly at the River Spey, Glen Rothes, Newmill and Keith. An alternative alignment to accommodate the proposed Kellas Drum Wind Farm would also have effects (including cumulative) on the Kellas area. 5.3 The report of handling also identifies impacts on woodland and forestry loss, impacts on peat and soils, transportation and access routes, flooding, cultural heritage, ecology and biodiversity. Socio-economic benefits of the proposal are also considered. It concludes that, while the proposal will result in significant landscape, visual, and ecological impacts, its role as a nationally important strategic development supporting the electricity grid and Net Zero targets is acknowledged. The principle of development is established under national planning policy (National Planning Framework 4). Balancing these considerations, it is recommended the Council raise no objection to the proposal, but this is subject to conditions as well as a number of caveats/requests of Scottish Ministers as specified in Appendix 1 and Appendix 2. Page 36
Page 37
6. SUMMARY OF IMPLICATIONS 6.1 The table below shows whether risks and implications apply if the recommendations are agreed: SUBJECT YES NO Corporate Plan and 10 Year Plan (Local Outcome Improvement Plan) X Policy and Legal X Financial X Risk X Staffing X Best Value and Transformation X Property X Information Communications Technology/Digital X Equalities. Social Inclusion and Economic Impact X Climate Change and Biodiversity Impact X 6.2 Corporate Plan and 10 Year Plan (Local Outcomes Improvement Plan (LOIP)) Improved Collaborative Leadership, as part of continuous improvement through Best Value, will better enable the Council to fulfil the ambitions set out in its strategic plans. a) Links to Council Corporate Plan – The proposals in this report support and contribute to improved outcomes for communities as outlined in the following Council Plan strategic priorities: ☐ Tackle Poverty and Inequality. ☒ Build Stronger Greener Vibrant Economy. ☐ Build Thriving, resilient, empowered Communities. b) Links to Local Outcomes Improvement Plan – The proposals in this report support and contribute to improved outcomes for communities as outlined in the following Local Outcomes Improvement Plan priorities: ☒ Developing a diverse, inclusive, and sustainable economy ☐ Building a better future for our children and young people in Moray. ☐ Empowering and connecting communities. ☐ Improving wellbeing of our population 6.3 Policy and Legal The application is made for consent under section 37 of the Electricity Act 1989 to the Scottish Ministers, and is processed by the Energy Consents Unit of the Scottish Government. If consented, planning permission is deemed to be granted for the development under section 57 of the Town and Country Planning (Scotland) Act 1997. If granted by the Scottish Ministers, the responsibility for the discharge of (planning) conditions attached to the formal decision to grant consent will pass to the Council (along with Aberdeenshire and Highland Councils). 6.4 Financial If this committee is minded to object to the proposal, a Public Local Inquiry (PLI) may be arranged by Scottish Government. The Council would be expected to attend and Page 37
Page 38
participate in the Inquiry process, including any pre-Inquiry arrangements with resultant costs, including officer, legal representation and consultant costs where required/appropriate. An application fee was received by the Council (£57,049 as its share of the overall application fee of £360,000). The cost of any PLI would likely use up most of the fee the Council received should an objection be raised. Whilst support to Development Management would be provided by Legal Services it is likely in the event of a PLI that additional legal representation, possibly including Counsel, would be needed to assist in the preparation and presentation of the Council’s case. At Inquiry, the applicant may seek an award of costs against the Council if it is considered the Council has acted unreasonably. 6.5 Risk If the Council decides not to respond within the agreed period it would be open to the Scottish Ministers to proceed and determine the application. If deciding to object, the outcome of any Public Local Inquiry held to consider this proposed development is uncertain: it might uphold and support the Council’s decision to object, but equally the objection could be dismissed and consent granted for the development. 6.6 Staffing In the event that a Public Local Inquiry is convened, staff time and resources - including those of Elected Members, planning officers, and legal officers - will be required for the preparation and attendance associated with the Inquiry. As a priority application for the Scottish Ministers, the target timescale for determination is 52 weeks from the date of application, which includes any periods related to the Inquiry. If the Scottish Ministers decide that a public inquiry is necessary for this application, it is likely that the pre-inquiry meeting will take place during the week commencing 9 February 2026, with any subsequent hearing or inquiry session likely to begin in the week commencing 11 May 2026. 6.7 Best Value and Transformation None. 6.8 Property None. 6.9 Information Communications/Technology/Digital None. 6.10 Equalities, Social Inclusion and Economic Impact The development itself will deliver significant socio-economic benefits for the local economy through its construction and operation (subject to a Community Wealth Building approach to be agreed with the Council), as well as wider benefits for the Scottish and UK economies. The proposal will also enable delivery of more renewable energy projects in the north of Scotland, with subsequent economic benefits from these projects. 6.11 Climate Change and Biodiversity Impacts Page 38
Page 39
As detailed in the Appendix 1 report, the proposed development has the potential to make a considerable contribution toward the transmission of low carbon-based electricity generation so significant weight is attached to this element. Switching to renewable sources of energy is acknowledged to make a large contribution toward climate change goals. Biodiversity and other environmental impacts are sought to be mitigated by those measures proposed within the Environmental Impact Assessment Report as well as the suggested mitigation as shown in the recommendation conditions in Appendix 2. 7. CONSULTATION 7.1 This report has been prepared in consultation with the Executive Director Economy, Enterprise and Finance; Head of Growth, Climate & Climate (Chief Planning Officer); Service Manager Legal Services; Acting Service Manager Planning & Building Standards; Equal Opportunities Officer; Service Manager Strategic Planning and Development; and Service Manager Democratic Services and any comments made have been incorporated into the report. 8. BACKGROUND PAPERS 8.1 Appendix 1, 2 and 3 attached. Page 39
Page 40
Page 40
Page 41
MORAY COUNCIL Response to consultation issued by Scottish Ministers THE ELECTRICITY ACT 1989 – SECTION 37 ELECTRICITY (APPLICATIONS FOR CONSENT) REGULATIONS 1990 INSTALL, OPERATE AND KEEP INSTALLED APPROXIMATELY 186 KM OF NEW 400 KILOVOLT (KV) DOUBLE CIRCUIT STEEL STRUCTURE OVERHEAD TRANSMISSION LINE (OHL), INCLUDING DOWNLEADS AND ASSOCIATED INFRASTRUCTURE BETWEEN BEAULY AND PETERHEAD (MORAY COUNCIL REF: 25/01364/S37, ECU REF: ECU00005165) 1. INTRODUCTION 1.1. On 16 October 2025 Scottish Hydro Electric Transmission PLC (trading/operating as Scottish and Southern Electricity Networks Transmission) submitted an application under section 37 of the Electricity Act 1989 requesting Scottish Ministers’ grant consent to install and keep installed approximately 186 km of 400 kilovolt (kV) double circuit steel structure overhead transmission line (OHL), including downleads, to connect into new substation sites at Fanellan (Beauly, Highland); Greens (New Deer, Aberdeenshire); and Netherton (Peterhead, Aberdeenshire). The Proposed Development also includes crossing works, temporary diversions and permanent realignment works to existing 132 kV and 275 kV OHLs, of approximately 14.7 km in total, and ancillary development and associated works. In total, the Proposed Development would comprise approximately 200.7 km of new OHL infrastructure. The proposed development is within the planning authority areas of Highland Council, Moray Council and Aberdeenshire Council. 1.2. This application will be determined by Scottish Ministers via the Scottish Government’s Energy Consents Unit (ECU), and not by Moray Council as the Local Planning Authority (LPA). 1.3. In determining the section 37 application, the views of Moray Council, as LPA are being sought by the ECU, along with those of Aberdeenshire and Highland councils. The Council’s role in the process is therefore as a statutory consultee. In responding with comments, the Council has a right to object or not to the application, as well as commenting on the conditioning of the consent. If the Council objects to the proposed development and the objection is not later withdrawn, or the areas of objection cannot be addressed by conditions then ECU/Scottish Ministers are likely to convene a Public Local Inquiry. For clarity, any public representations are considered directly by the ECU, and not the LPA as consultee. 1.4. Prior to determination, the ECU are responsible for affording publicity of the proposal and taking account of all representations received, whether from the Appendix 1 Page 41
Page 42
public or interested parties, and for consulting with agencies and organisations (consultees). Internal consultation with relevant services/sections within the Council has been undertaken to provide a comprehensive response in responding to the consultation. 1.5. This proposal qualifies as a priority application for consent to install overhead line transmission under the definitions established by the Scottish Government. It falls within the definition of Strategic Transmission Infrastructure which enhances capacity or improves security of supply within Scotland’s electricity network. Scottish Government guidance states such applications are subject to an anticipated 52-week determination period. Consequently, the period for comments from local planning authorities, other statutory consultees, and the public is limited and will not be subject to extension. For this consultation, the Council must respond by 18 December 2025, which is two months after the ECU issued the consultation request on 17 October 2025. 1.6. This report examines how the proposal will affect the Moray Council administrative area and highlights key points for the Council, acting as the LPA, to consider in its response to the consultation request. 2. SITE HISTORY 2.1. The site subject to this application is extensive, taking in a corridor of approximately 59km running east-west through Moray. There is significant planning history on and around the site. 2.2. Of relevance to this proposal, the Council responded to a consultation on an EIA Scoping Opinion request to Scottish Ministers on 22 August 2024 (ref: 24/01085/S36SCO). 2.3. Kellas Drum Wind Farm (our ref: 24/00486/S36) as proposed has an impact on the alignment of the proposed line, as described below. The section 36 application for this wind farm is still pending consideration. The Council’s Planning and Regulatory Services Committee raised no objection to the wind farm as amended (8 turbines at 149.9 metres high) on 28 May 2025. 3. THE SITE 3.1. The proposed OHL would run between Beauly and Peterhead, in the administrative areas of Highland Council, Moray Council and Aberdeenshire Council. The proposal would be located within a predominantly rural area with taking in upland forests, moorland, agricultural land and rivers. It crosses a number of roads and paths, including core paths and rights of way. Settlements in proximity of the proposed OHL include Elgin (4.6 km), Fochabers (1.7 km), Newmill (327 m) and Keith (1 km). Page 42
Page 43
3.2. The following table describes the route from west to east as per the sections identified in the supporting information (EIA Report Vol 3, Chapter 4, Figure 4.8) provided with the application. It also describes any designations the route passes through or is in proximity to in Moray. Section Route Description Designations 1 - 11 Within Highland Council area, the route would begin at a new substation at Beauly, passing east crossing the Caledonian Canal to the south of Inverness. It continues east to Moray passing to the south of Culloden and Cawdor towards Ferness. Not in or affecting Moray so not detailed as part of this report. 12 Passing south of Ferness in Highland, the OHL enters Moray to the north of Cairn Duhie, remaining south of the existing 275 kV OHL. It crosses the A940 and the Dava Way, then turns northeast across the River Divie towards Hill of Tomechole, passing to the south east of Hill of Glaschyle Wind Farm to Johnstripe. Findhorn Valley and the Wooded Estates SLA to north 0.7 km north Modiach More SSSI and SAC 1.8 km south Lower Findhorn Woods SAC 1.9 km north Darnaway and Lethen Forest SPA 5km north west 13 From Johnstripe, the OHL passes through upland forestry north of Loch Dallas, then heads east crossing upper Glen Lossie to Moss of Bednawinny. None 14 The OHL continues northeast from Moss of Bednawinny, crossing the C13E (Dallas to Knockando Road) towards Kellas. East of Meikle Hill, two potential alignments have been put forward taking account of the proposed Kellas Drum Wind Farm: • Preferred alignment: continues northeast, south of Glenlatterach Reservoir. • Kellas Alternative Alignment: goes north then east around the proposed wind farm, passing north of Glenlatterach Reservoir (proposed should Kellas Drum Wind Farm be consented). Kellas Oakwood SSSI (0.8 km north of northern alignment, 2.6 km north of southern alignment) Buinach and Glenlatterach SSSI immediately north of Kellas Alternative Alignment, 1.1 km north of preferred alignment. 15 From Glenlatterach Reservoir, both alignments converge to the north of Pikey Gulls Nest SSSI 1.5 km south of eastern converging point of Page 43
Page 44
Hill, crossing the A941 between Coleburn and Netherglen (south of Fogwatt). both options. 16 The OHL turns north, climbing the relatively steep eastern banks of upper Glen Rothes, it then proceeds north east/east along the northern slopes of Brown Muir, to the south of the route of the existing 275 kV line towards and through Badentinan Wood, north of the Scottish Water water works. Coleburn Pasture SSSI passes over northern edge of this. Loch Spynie Ramsar & SSSI 9.4 km north 17 From Badentinan Wood, the OHL passes east, crossing the B9103 Lossiemouth to Mulben road to Orbliston. In this area the OHL has to cross two existing 275kV OHLs, as well as the Inverness to Aberdeen railway line. To the immediate east of the railway line, the OHL route turns south east, crossing the B9015 Rothes to Kingston road and the unclassified Dipple Road (U19E) to the north of Inchberry to the eastern banks of the River Spey. Teindland Quarry SSSI approx. 550 m south 18 Moving east, the OHL crosses the River Spey to the north of the existing OHLs, and heads east through the Wood of Ordiequish. The route continues southeast, crossing A96 at the top of the Dramlachs, then turning south east passing through agricultural land, crossing the B9016 (Keith to Buckie road) north of Aultmore towards Auchairn. The River Spey Valley SLA (within SLA) Moray and Nairn SPA and Ramsar 3 km north Crosses River Spey SAC and SSSI Lower River Spey – Spey Bay SAC 3 km north and 2.4 km south (sections both upstream and downstream) Lower River Spey SSSI 2 km north Spey Bay SSSI 6.75 km north 19 Heading east, the OHL passes to the north of Newmill, where it then turns south east, passing east of Newmill, crossing the River Isla, A95 and Inverness to Aberdeen railway line at the Banff Turnpike. To the east of Keith, the OHL then proceeds south to the west of Balloch Wood, meeting with the Aberdeenshire Council boundary at Keith Countryside Around Towns – passes through Mill Wood SSSI adjacent to proposal Den of Pitlurg SSSI (straddles Moray-Aberdeenshire Page 44
Page 45
Coachford, north of the A96. boundary) 1.7 km SE from closest point in Moray. 20 & 21 The OHL route to the east of Coachford stays within Aberdeenshire, running to the north of Huntly, though it will have be visible from the Rothiemay area of Moray (OHL would be circa 1.8 km to the south of the Moray boundary at its closest point). Deveron Valley SLA (Moray) 1.8 km to north. 22 - 29 Route continues east to proposed substations at New Deer and Peterhead. Not in or affecting Moray so not detailed as part of this report. 4. THE PROPOSAL • The proposed development is to install, operate and keep installed approximately 186 kilometres (km) of new 400 kV double circuit OHL between new substation sites proposed at Beauly and Peterhead. Within Moray the OHL would have a length of 59 km. Consent is sought under section 37 of the Electricity Act 1989 and deemed planning permission in terms of section 57(2) of the Town and Country Planning (Scotland) Act 1997. • There would be permanent modifications to existing OHLs at four locations in Moray (two at Orbliston and two to the east of Keith) where the proposed OHL crosses these. Temporary modifications to OHLs are also proposed as part of these works. • As noted under the site description, two alignments are proposed to the south of Kellas. The alignment that would be taken forward is dependent on the outcome of a section 36 application for the proposed Kellas Drum Wind Farm (to which Moray Council raised no objection in May 2025). The total length of the Kellas Alternative Alignment is 8.8 km. If the Kellas Alternative Alignment is constructed, the total length of new 400 kV double circuit OHL would be 187.5 km (making Moray’s section 60.5 km in length) – 1.5 km longer than the preferred alignment. • The pylons proposed would be steel lattice towers formed of galvanized steel and grey in colour comprising: o suspension towers: used for straight sections of OHL where there is no need to manage uplift loads on the support structure; o angle / tension towers: these are used either for straight sections, where there is a need to manage uplift loads on the support structure, where there is an operational security requirement, or where there is a need to change the direction of the OHL alignment; and o terminal towers: proposed at the substations, from which the termination of the OHL to the substation is made. The conductors extend from the tower arms horizontally and downwards into the substation. (NOTE - None of these proposed in Moray.) • Pylons would vary in height between 48 m and 72 m (with one at 95 m crossing the Caledonian Canal at Inverness). The majority of pylons in Moray would be 55 Page 45
Page 46
– 63 m in height. The entire length of line would have 549 towers (172 in Moray), though if the Kellas Alternative Alignment is taken forward this would require 554 towers (177 in Moray). The span length between the pylons varies depending on topography and other constraints, with an average span 338 m in length. • Where crossings of existing OHLs are necessary, existing lines would be modified by splitting in two and crossing under the line and rejoining at the other side, either in a diamond formation around a new tower for the proposed OHL or “ducking under” wires of the proposed OHL. • Associated ancillary development for which deemed planning permission is sought includes: o the upgrade of existing, or creation of new, bellmouth junctions at public road access points; o the formation of access tracks (permanent, temporary, and upgrades to existing tracks) and the installation of bridges and culverts to facilitate access; o working areas around infrastructure to facilitate construction; o formation of flat areas from which the conductor will be pulled during construction, which will contain earthed metal working surfaces referred to as Equipotential Zones (EPZs); o vegetation clearance and management; o other temporary measures required during construction, such as measures to protect road and water crossings during construction (scaffolding etc.); and o public road improvements which would be required in some areas to facilitate construction traffic. • To accommodate changes to the OHL route should there be geotechnical or detailed design issues, Limits of Deviation (LoD) have been proposed as follows: o OHL infrastructure: Suspension towers: 100 m radius; Tension towers: 200 m radius Conductors: 100 m either side of centreline All working areas within LoD o Access tracks: New tracks or major upgrades: 100 m either side Minor upgrades: 50 m either side LoDs merge if within OHL LoD o Forestry areas: LoD widened to 145 m either side for flexibility in tower micrositing. • Across its entire route, the proposal would require the removal of 471.05 ha of woodland. In Moray, 189.58 ha of woodland would be removed, made up of the following woodland types: o Commercial forestry – 176.13 ha o Native woodland – 12 ha o Ancient woodland of semi-natural origin – 1.45 ha • The Kellas Alternative Alignment would necessitate removal of 11.84 ha of commercial forestry and 2.41 ha of native woodland over and above the figures specified above. Page 46
Page 47
• The proposal is considered to be an EIA development, and as such is accompanied by an EIA Report. • It is anticipated that (if consented) construction of this proposal would commence in 2026, with an estimated completion date and commissioning/energisation in late 2030. Construction activities across the proposed overhead line (OHL) will be carried out on various sections throughout the construction period, rather than proceeding sequentially in a single direction (for example, from west to east). • Other works associated with the proposed OHL - such as contractors/works compounds and borrow pits - may need separate planning permission or could be permitted development. Notably substations along the route will need planning permission, albeit none are proposed in Moray. 5. ADVERTISEMENTS Advertisements will have been carried out by the ECU who are determining the application. 6. CONSULTATIONS As noted above, consultations are limited to Council services. Consultations with external bodies such as SEPA are undertaken directly by the Energy Consents Unit. Internal consultation responses from Council departments are summarised as follows: Contaminated Land – No objections. Environmental Health – No objections subject to condition requiring Construction Environment Management Plan to minimise and mitigate construction related noise (including vibration), dust and artificial lighting. Private Water Supplies – No objections subject to condition requiring a Private Water Supply Management Plan and Private Water Supply Monitoring Plan, along with suitable mitigation measures. Strategic Planning and Development – This application will be considered against the policies of the Moray Development Plan, which consists of National Planning Framework 4 (NPF4) and the Moray Local Development Plan (MLDP) 2020. The following response provides an overview of key planning polices in respect of this application. There may be other planning policies and material considerations that require to be considered as part of this application. Energy Infrastructure and Development Principles (NPF4 National Spatial Strategy and Policies 1, 2, 4 and 11; MLDP Policies DP1 and EP3) The proposed development is designated under NPF4 as National Development 3 Strategic Renewable Electricity Generation and Transmission Infrastructure. NPF4 emphasises the need for strategic reinforcement of the transmission grid to connect and transmit from renewable energy development and the development would Page 47
Page 48
contribute significantly towards the delivery of the UK and Scottish Government’s Net Zero targets. The principle of the proposal therefore complies with NPF4 National Spatial Strategy and Policies 1 and 2. NPF4 Policy 11 (c) requires proposals to demonstrate that they maximise net economic impact, including local and community socio-economic benefits such as employment, associated business and supply chain opportunities. A Socio-economic Assessment has been submitted, and a number of conditions have been proposed relating to post- consent. These should be agreed with the Planning Authority in consultation with the Strategic Planning and Development section. The proposal crosses through The Spey Valley Special Landscape Area (SLA). NPF4 Policy 4 and MLDP Policy EP3 seeks to protect designated landscapes for development which has significant adverse effects on their integrity or qualities. Given the scale of the proposal, the development will have a significant effect on the integrity, character and special qualities of this designation. The proposal therefore is contrary to NPF4 Policy 4 (d) (i) and MLDP Policy EP3. The undergrounding of the line in this section of the route would reduce the severe significant landscape and visual effects likely to occur in relation to the Spey Valley crossing. The Kellas Alternative Alignment should be avoided as it would result in significant adverse landscape and visual effects, including significant cumulative effects with the Kellas Drum Wind Farm which is assumed to be consented/constructed if the alternative route is selected. The preferred route alignment would have minimal effects on residential properties, roads and recreational routes in the Kellas area. The preferred route would conflict with the proposed Kellas Drum Windfarm location. The Council’s appointed Landscape Adviser has undertaken a detailed review of the proposal. The assessment concludes that: • The proposed route has sought to minimise views from settlements and effects on designated landscapes where possible. • Significant adverse landscape and visual effects will arise particularly close to the route of the line due to the nature and scale of the infrastructure proposed. • The most significant adverse effects are likely to occur on: people using the Dava Way; Glen Lossie; the Kellas area; Glen Rothes and views from the A941; the Spey Valley crossing and the Keith/Newmill area. • The crossing of existing overhead lines in the Spey Valley and Keith area will be particularly intrusive due to the concentration of intersecting towers and lines at these points. • Whilst the proposal is largely aligned through less settled areas of commercial forestry, minimising effects on communities and landscape and visual effects, 189.58ha of woodland would be permanently lost in Moray. The report by the Landscape Adviser on the proposed development provides a fuller assessment on landscape, visual and cumulative effects. Should the Council be minded not to object, the Landscape Adviser has recommended that the following conditions be submitted to the Energy Consents Unit: Page 48
Page 49
• The permanent loss of woodlands with biodiversity and landscape value (not just Irreplaceable Habitats) along the route should be fully considered in the calculation of compensatory planting. A greater area of woodland than that removed should be planted to more adequately compensate for the loss of woodland with greater biodiversity value in accordance with the objectives of the Moray Woodland and Forestry Strategy. Compensatory planting proposals should be agreed with the Planning Authority and Scottish Forestry. • The proposed landscape mitigation set out in Appendix 7.6 and the increase of the Operational Corridor (OC) to 120m in the western part of Ordiequish Wood. • More extensive planting of trees, hedgerows and woodlands should be undertaken outside the OC to help screen the proposed transmission line from roads, footpaths and dispersed residential properties who will be most affected by views of the proposed line. Biodiversity (NPF4 Policy 3; MLDP EP2) NPF4 Policy 3 and MLDP Policy EP2 requires development proposals to contribute to the enhancement of biodiversity, including where relevant, restoring degraded habitats, and building and strengthening nature networks and the connections between them. NPF4 Policy 3 (b) requires ‘national or major’ development to demonstrate how the proposal will conserve, restore and enhance biodiversity, including nature networks so they are in a demonstrably better state than without intervention. Moray published its proposed Moray Nature Network which the proposal will cross/impact. Conclusion Whilst the proposal would result in significant landscape and visual impacts across the region, including on designated landscapes, the development’s role as a nationally important strategic development and its contribution to the electricity grid and Net Zero targets are acknowledged, subject to the conditions set out by the Landscape Adviser. The proposed Kellas Alternative Arrangement should be avoided as this will result in significant adverse landscape and visual effects, including significant cumulative effects. Transportation – The information submitted for the application establishes the principles of access to some 7 sections of cable route in Moray to enable construction of the new overhead cable towers and their associated foundations, access tracks, associated sub-stations and for the eventual stringing of the cables. There will also be forestry extraction associated with the provision of the new overhead cables along with works near ‘Altonside’ Orton, Orbliston, the A95 just to the east of Keith Cemetery, and ‘Drum Farm’ Keith where existing overhead cables will be improved/realigned. The proposed access points presented in the Transport Assessment have been superseded by those included in the EIA. This is due to further development of the project since the Transport Assessment was completed. As the design and construction plans for the proposed overhead cables progresses, there will be further amendments to the access proposals along the corridor – in particular seeking where Page 49
Page 50
possible to avoid the use of unclassified roads where there are constraints, and to avoid larger construction vehicles passing sensitive locations such as schools. Should consent be granted, the applicant has committed to working closely with each Roads Authority to ensure that access points are located in the optimum location and built to the required standard. It is anticipated that some access points with be upgrades of existing accesses, new permanent accesses (which will support the future maintenance of the overhead cables and towers) and temporary accesses. The development would take place in a phased manner, with work on some sections of the route taking place concurrently. Whilst a framework Construction Traffic Management Plan has been submitted as part of the application, a full Construction Traffic Management Plan will be required for each section of the route. A Section 96 Agreement and associated Road Bond will also be required for the proposed development covering the construction period for each Section of the cables (covering wear and tear of public roads). The majority of construction vehicles will be standard HGVs and workers vehicles. However there will be abnormal loads required to access each section – a crane to erect the towers and for the delivery of the (heavy) cable drums. The applicant has undertaken initial assessments of the routes where the abnormal loads are required to use the public road and has identified ‘pinch points’ and locations where improvement to and the upgrading of the public road may be required. Further assessment work will be undertaken as the project progresses, should planning permission be granted. Conditions are therefore recommended to enable the submission of, and agreement to, the detailed information required to ensure that safe and suitable accesses and, where required, improvements to the public road on the routes to be used for construction traffic are provided in advance works taking place on any particular phase of the development. Outdoor Access and Countryside Officer – Note that paths at Meikle Balloch and Newmill were missing from the supporting information, and highlight several key considerations relating to rights of way, core paths and outdoor access, and outline how this project presents a positive opportunity to enhance local routes and support communities: 1. Protection of Rights of Way, Core Paths and Outdoor Access The proposed route intersects areas with established rights of way, designated core paths and important informal access networks used by residents, land managers, and visitors. These paths provide essential links between communities, support local recreation, and form part of wider regional access networks. It is therefore vital that: • Existing rights of way and core paths are safeguarded during construction and operation, with clear commitments to avoid severance or long-term obstruction. • Any temporary closures are minimised, clearly signposted, and accompanied by safe, well-designed alternative routes in cooperation with Moray Council. Page 50
Page 51
• The Scottish Outdoor Access Code is fully adhered to throughout the project lifecycle. 2. Enhancing the Access Network as Part of the Development While the project presents challenges, it also offers a significant opportunity to secure long-term benefits for local access and community connectivity. Infrastructure works of this scale can deliver added value through: • Upgrading existing core paths or rights of way that require resurfacing, drainage improvement or widening. • Creating new off-road links where communities currently rely on narrow or unsafe roadside walking routes. • Supporting multi-use paths that benefit walkers, cyclists, horse riders and mobility-impaired users. • Introducing landscape and access improvements around tower sites, substations, or diversion routes that remain in place post-construction. These enhancements would strengthen local networks, encourage outdoor recreation, improve health and wellbeing outcomes, and contribute to sustainable travel options. 3. Partnership Working with Communities Close dialogue with communities, access groups, landowners and local authorities should continue throughout the planning and delivery phases. By engaging early and meaningfully, the developer can: • Identify priority routes for improvement, • Understand local access pressures or needs, and • Co-design solutions that leave a positive legacy for the host communities. Where appropriate, community benefit funding or partnership initiatives could help maintain or further develop routes over the long term. Moray Flood Risk Management – No objections, informative notes provided advising that towers located within flood plains are susceptible to the accumulation of debris during flood events. It is strongly recommended that any debris be cleared as soon as it is safe to do so following such events. Failure to remove debris promptly may result in increased flood risk due to obstruction of natural water flow across the flood plain. Additionally, large floating debris poses a significant risk of structural damage to towers during flooding. Appropriate maintenance and monitoring procedures should be implemented to mitigate these risks and ensure the resilience of infrastructure within flood-prone areas. Aberdeenshire Council Archaeology – Information submitted in respect of archaeology is acceptable, and mitigation measures proposed are acceptable. Condition recommended in respect of provision of Written Scheme of Investigation and any Post-excavation Research Design. Any compensatory planting should take account of the historic environment and following best practice in terms of avoiding damage to heritage assets. Informative also recommended in respect of delivery of public benefit. Developer Obligations – No obligations sought. Page 51
Page 52
7. REPRESENTATIONS Third party representations are submitted to the ECU for the consideration in dealing with section 37 applications. 8. RELEVANT POLICIES AND GUIDANCE National Planning Framework 4 Policy 1 - Tackling the climate and nature crises Policy 2 - Climate mitigation and adaptation Police 3 - Biodiversity Policy 4 - Natural places Policy 5 - Soils Policy 6 - Forestry, woodland and trees Policy 7 - Historic assets and places Policy 11 - Energy Policy 12 - Zero waste Policy 13 - Sustainable transport Policy 14 - Design, quality and place Policy 18 - Infrastructure first Policy 22 - Flood risk and water management Policy 23 - Health and safety Policy 25 - Community wealth building Policy 29 - Rural development National Development 3 – Strategic Renewable Electricity Generation and Transmission Infrastructure Moray Local Development Plan 2020 PP2 Sustainable Economic Growth PP3 Infrastructure and Services DP1 Development Principles EP1 Natural Heritage Designations EP2 Biodiversity EP3 Special Landscape Areas EP4 Countryside Around Towns EP7 Forestry Woodland and Trees EP8 Historic Environment EP10 Listed Buildings EP11 Battlefields, Gardens and Designed EP12 Management and Enhancement Water EP13 Foul Drainage EP14 Pollution Contamination Hazards EP15 MOD Safeguarding Page 52
Page 53
Scottish Climate and Energy Policies and Legislation The Scottish Energy Strategy (2017) The Climate Change (Emissions Reduction Targets) (Scotland) Act 2019 CCC Report to Scottish Parliament – Progress in reducing emissions in Scotland (March 2024) The Climate Change (Emission Reduction Targets) (Scotland) Act 2024 The Draft Energy Strategy & Just Transition Plan The Green Industrial Strategy CCC Report, Scotland’s Carbon Budgets, Advice for the Scottish Government 9. BACKGROUND 9.1. This proposal seeks consent under section 37 of the 1989 Electricity Act and also a direction under section 57(2) of the Town and Country Planning (Scotland) Act 1997 as amended for the development to be deemed to be granted. 9.2. As Moray Council acts as a consultee in the section 37 process, certain matters included in the Observations section may be evaluated differently than if they were part of a planning application for which Moray Council is the determining authority. Areas such as aviation impacts, impacts on ecology and ornithology, and effects on the water environment will be addressed by relevant regulatory bodies and specialist consultees such as SEPA and NatureScot, who are consulted by and report directly to the ECU. Consequently, the Council’s involvement in particular considerations will be limited where the ECU consults directly with organisations best qualified to address specific areas of expertise/interest. 9.3. Environmental Impact Assessment The proposal is a development which requires Environmental Impact Assessment (EIA) under schedule 1 of The Electricity Works (Environmental Impact Assessment) (Scotland) Regulations 2017 (the EIA Regulations). To inform the scope of the assessment, the applicant submitted a scoping opinion request under regulation 12 to Scottish Ministers on 26 June 2024, who consulted Moray Council on this as an interested party. Officers responded on 22 August 2024 under delegated powers, indicating broad agreement on the scope and approach to the EIA as outlined in the request. Scottish Ministers adopted a scoping opinion on 2 October 2024 which has been used to inform the EIA Report that accompanies this proposal. Page 53
Page 54
9.4. The EIA Report comprises the following: • Volume 1 – Non-Technical Summary • Volume 2 – Main Report • Chapter 1 – Introduction and Background • Chapter 2 – Project Need • Chapter 3 – Project Description • Chapter 4 – The Routeing Process and Alternatives • Chapter 5 – EIA Process and Methodology • Chapter 6 – Scope and Consultation • Chapter 7 – Landscape and Visual • Chapter 8 – Ecology • Chapter 9 – Ornithology • Chapter 10 – Water and Geological Environment • Chapter 11 – Cultural Heritage • Chapter 12 – Forestry • Chapter 13 – Transport • Chapter 14 – Recreation and Tourism • Chapter 15 – Noise and Vibration • Chapter 16 – Cumulative Assessment • Chapter 17 – Summary of Effects • Chapter 18 – Schedule of Mitigation • Volume 3 – Figures for chapters • Volume 4 – Visualisations for Chapters 7 (Landscape and Visual) and 11 (Cultural Heritage) • Volume 5 – Appendices Matters not considered within the scope of the EIA have been addressed via separate reports submitted with the application, including: • Aviation Risk Assessment • Electric and Magnetic Field Study Report • Habitat Regulations Appraisal • Planning Statement • Pre-Application Consultation Report • Socio-Economic Report 9.5. Public Consultation Although not a statutory requirement under the Electricity Act 1989, the applicant voluntarily undertook a Pre-Application Consultation (PAC) process in Page 54
Page 55
line with Scottish Government Good Practice Guidance, with an aim of early and meaningful engagement with communities and stakeholders potentially affected by the development. A PAC Report has accompanied this application outlining the consultation undertaken. 9.6. The PAC Report notes the consultation process was multi-staged, beginning with corridor, route, and refined route consultations, followed by two rounds of formal PAC events, and an additional round focused on design changes after the removal of the proposed Blackhillock (Coachford) substation. The process sought to ensure that feedback from stakeholders, statutory consultees, and the public was gathered, considered, and, where possible, incorporated into the project design. Events were held in person and consultation materials were made available online. 9.7. Key themes raised during the consultations included concerns about the visual and environmental impact of the OHL, property values and compensation, the cumulative effect of multiple infrastructure projects, and preferences for underground or subsea cabling. Health concerns, particularly regarding electric and magnetic fields, and the impact on local biodiversity and ancient woodland were also raised. The applicant states they responded by explaining the technical, economic, and regulatory constraints, outlining mitigation measures, and committing to biodiversity net gain and environmental best practice. The project was revised in response to feedback where feasible, balancing stakeholder views with technical and practical considerations. 9.8. Consultation events in Moray were held in Dallas, Fochabers and Keith, with details publicised through local press, social media, direct mail and the project website. Printed materials, information boards, 3D visualisations, and consultation booklets were made available at these events, and feedback was collected in person, online, and in writing. A further event was held in Keith in June 2025 following removal of the Blackhillock (Coachford) substation and subsequent amendments to the OHL route in this area. 9.9. In addition to public events, the applicant engaged directly with the Council (via the major pre-application advice service) and other statutory consultees through meetings and correspondence. The PAC Report states that all feedback was documented, analysed, and used to inform the final alignment and design of the project, with updates and responses provided to the community throughout the process. Page 55
Page 56
9.10. Need for Proposal Whilst the principle of the proposal is considered under planning policy as outlined below under Observations, the EIA Report (Chapter 2) describes the need for the proposal from a technical, economic and legislative perspective. It notes the need for the proposal has been assessed through national system planning exercises and regulatory frameworks. The National Energy System Operator (NESO) and Ofgem have both identified the requirement for significant upgrades to the transmission network to accommodate the forecasted growth in renewable electricity, particularly from offshore wind. Studies such as the Pathway to 2030 Holistic Network Design and subsequent reviews have confirmed that further reinforcement of the electricity transmission network is necessary to connect new, large-scale renewable energy sources in Scotland. 9.11. Regulatory approval has been granted under Ofgem’s Accelerated Strategic Transmission Investment (ASTI) framework, which supports the economic case for delivering qualifying infrastructure projects. Ofgem has emphasised the benefits of timely delivery of new transmission infrastructure for consumers, including improved resilience, security of supply, and decarbonisation of the energy sector. The applicant states delays in providing these upgrades could result in increased constraints and higher costs for consumers. 9.12. As the transmission licence holder for the north of Scotland, the applicant is legally required to develop and maintain an efficient, co-ordinated, and economical system of electricity transmission. The costs of development, construction, and operation are ultimately recovered from end consumers through electricity bills, making economic efficiency a key consideration. The design of the proposed development has therefore been planned to ensure it meets statutory duties and regulatory requirements, while supporting the transition to a net zero energy system. 9.13. Alternatives Under the EIA Regulations (regulation 5(2)(d) and schedule 4(2)), the applicant has to consider reasonable alternatives to a proposal, such as design, technology, location, size and scale. 9.14. Chapter 4 of the EIA Report outlines the routeing process undertaken by the applicant, along with consideration of alternatives to the proposal subject to the section 37 application. The process was guided by statutory duties, technical standards, and environmental regulations, with the aim of balancing the need Page 56
Page 57
for an economical transmission system while minimising impacts on natural beauty, heritage, and local communities. 9.15. The alternatives considered included the ‘do-nothing’ scenario, underground cable options, and subsea cable options. The ‘do-nothing’ scenario was discounted as it would not meet the UK’s and Scotland’s Net Zero targets or support the required growth in renewable energy generation. 9.16. The use of underground cables and subsea cables was also assessed. These were found to be significantly more expensive (up to 4.5 times the cost of OHLs) and presented technical and operational challenges, especially at the required 400 kV voltage. Subsea cables, while beneficial for long-distance transmission, would require multiple converter stations and offer less capacity than OHLs, with higher costs and greater land take. Both alternatives would introduce additional environmental impacts, such as disruption to peatlands, agricultural land, and watercourses, and were therefore not considered reasonable options. 9.17. The routeing process itself was divided into several stages: corridor selection, route selection, and alignment selection. Each stage involved the use of digital mapping, environmental constraints analysis, and public consultation. In the Moray portion of the OHL, Chapter 4 notes that attention was paid to avoiding areas of high landscape value, designated sites, and residential clusters. The preferred corridors and routes were chosen to minimise visual and ecological impacts, with adjustments made following stakeholder and public feedback. For example, routes were refined to avoid ancient woodland, reduce proximity to settlements, and minimise effects on sensitive habitats such as peatlands and water supplies. 9.18. During the alignment selection stage, further refinements were made to address concerns raised by landowners and statutory consultees. The alignment was adjusted to reduce impacts on farming and forestry operations, avoid notable trees/woodland, and maintain separation from sensitive receptors such as Scheduled Monuments and Sites of Special Scientific Interest (SSSIs). The proposal also incorporates technical solutions such as floating tracks over peatland and piled foundations in areas of deep peat, to further mitigate environmental effects. 9.19. Within Moray the Kellas Alternative Alignment is proposed, which would only be constructed if the proposed Kellas Drum Wind Farm is consented. This Page 57
Page 58
alternative has been assessed for its technical, cost, and environmental merits, with the preferred alignment chosen for its shorter, more direct route and reduced landscape and visual impacts. The application as submitted proposes that should the wind farm not be consented, the main proposed alignment would be constructed instead. 9.20. The information within the EIA Report concludes the proposed OHL route has been established by balancing technical feasibility, cost, and need for environmental protection. Alternatives such as underground and subsea cables have been ruled out by the applicant due to cost, technical, and environmental disadvantages. It reflects the consultation undertaken and refinement to minimise impacts on local communities, sensitive habitats, and landscape character, while ensuring the proposal’s objectives are met. 10. OBSERVATIONS 10.1. Officers have considered the proposal against National Planning Policy 4 (NPF4), the Moray Local Development Plan 2020 (MLDP) and material considerations including national legislation on renewable energy and climate policies and legislation as listed above under section 8. It is noted that the Energy Strategy and Just Transition Plan is still at a draft stage. It should also be noted that as the application is being considered under the Electricity Act 1989, rather than the Town and Country Planning (Scotland) Act 1997, the development plan does not have primacy under section 25 of the 1997 Act in the same way a planning application would. 10.2. Schedule 9 (2) of the Electricity Act 1989 requires those determining proposals under the Act, including section 37, to ‘have regard to the desirability of preserving natural beauty, of conserving flora, fauna and geological or physiographical features of special interest and of protecting sites, buildings and objects of architectural, historic or archaeological interest’ and ‘do what he reasonably can to mitigate any effect which the proposals would have on the natural beauty of the countryside or on any such flora, fauna, features, sites, buildings or objects.’ 10.3. Principle of Proposal NPF4 is Scotland’s national spatial strategy and alongside local development plans is a statutory part of the development plan, setting out priorities for Scotland to 2045. It integrates a national spatial strategy with planning policies, aiming to deliver sustainable, liveable and productive places while addressing the climate and nature crises. It places achievement of net zero emissions by Page 58
Page 59
2045 at its core, alongside economic transformation and community wealth building. 10.4. “National Developments” sit at the top of the Hierarchy of Development, comprising developments that are designated in NPF4 and considered to be of national importance. Annexe A of NPF4 states that “their designation means that the principle of the development does not need to be agreed in later consenting processes”. 10.5. All new and/or upgraded on and offshore high voltage electricity transmission lines, cables and interconnectors of 132kV or more fall within the definition of national development in NPF4 (Annexe B, National Development 3 - Strategic Renewable Electricity Generation and Transmission Infrastructure). 10.6. NPF4 also defines ‘all forms of renewable, low-carbon and zero emission technologies for electricity generation and distribution and transmission electricity grid networks and primary sub stations’ as essential infrastructure. 10.7. NPF4 Policy 1 (Tackling the climate and nature crises) states that significant weight must be attached to the global climate and nature crisis. It aims seeks to reduce emissions and supports development that addresses these goals. Transmission infrastructure for renewable energy is one such development and therefore significant weight must be attached to its contribution toward emissions reductions. Similarly, NPF4 Policy 2 (Climate change and adaptation) seeks to encourage, promote and facilitate development that minimises emissions and adapts to the current and future impacts of climate change. This can directly be linked to other wider objectives of NPF4 in creating sustainable places and the production and transmission of clean energy is part of the spatial strategy for the north of Scotland. 10.8. Policy 11 of NPF4 supports all proposals for renewable, low-carbon, and zero- emission technologies—including wind farms and related grid infrastructure— alongside the climate-focused support in Policy 1. Whilst it identifies the principle of National Developments as being established, it also requires them to be assessed at the project level to ensure compliance with statutory requirements outlined in Annex 1 of NPF4. This includes alignment with the Development Plan, which incorporates NPF4 and MLDP. 10.9. In terms of land use designations in the MLDP, the proposal takes in The Spey Valley Special Landscape Area. Under associated MLDP Policy EP3, uses are restricted in rural areas (i.e. outwith settlements) to limited uses, however there is an allowance for nationally significant infrastructure development identified in NPF4. The general principle of this proposal is therefore not at odds with EP3, Page 59
Page 60
though consideration is given to the landscape and visual impact of the proposal on the SLA below. 10.10. The proposal also passes through part of the Keith Countryside Around Towns (CAT) designation of the MLDP. MLDP Policy EP4 restricts development proposals to limited development types in order to prevent sprawl of settlements into the surrounding countryside. In this case, there is no specific allowance for electricity infrastructure, however as NPF4 establishes the principle of national developments, it is considered this outweighs the policy requirements of MLDP Policy EP4. 10.11. Accordingly, the principle of this development is established and acceptable under planning policy, though consideration will be given to various aspects of this proposal as per the following headings. 10.12. Landscape and Visual Impacts NPF4 Policy 11 states that project design and mitigation must demonstrate how the various impacts of renewable energy developments are addressed and these are listed in part (e) of the policy. This includes enabling works including grid transmission and distribution infrastructure. Part (e)(ii) notes that significant landscape and visual impacts, recognising that such impacts are to be expected for some forms of renewable energy. Where impacts are localised and/or appropriate design mitigation has been applied, they will generally be considered to be acceptable. 10.13. NPF4 Policy 4 requires that development proposals should not have unacceptable impacts on the natural environment. For local landscape designations (including Special Landscape Areas (SLAs) significant adverse effects must be clearly outweighed by social, environmental, or economic benefits of at least local importance. 10.14. The applicant has undertaken a comprehensive Landscape and Visual Impact Assessment (LVIA) as part of the EIAR, detailed in Chapter 7. This assessment evaluates the potential effects of the proposed development on landscape character and visual amenity, considering both the construction and operational phases. The LVIA forms a key component of the EIA process, ensuring that the likely landscape and visual impacts are fully identified, assessed, and, where possible, mitigated within the project design. The Moray section of the LVIA has been reviewed by a Landscape Architect appointed by the Council, and has found it to be thorough. Page 60
Page 61
10.15. As noted above, a range of route options were appraised by the applicant with input from consultees prior to the final alignment being selected. While it is evident that the proposed route for the transmission line has sought to minimise views from settlements and effects on designated landscapes where possible (being located adjacent to existing OHLs in some sections of the route and being aligned through commercial forestry in many areas) significant adverse landscape and visual effects will arise particularly close to the route of the OHL due to the nature and scale of the infrastructure proposed. 10.16. Within Moray, the proposed OHL traverses a variety of landscapes, including the broad, well-wooded valley of the River Spey, upland farmland, and several designated areas. The LVIA has scoped in assessment of the proposal on two SLAs in Moray: the Findhorn Valley and the Wooded Estates SLA, and the Spey Valley SLA, the OHL passing through the latter. These areas are designated in the MLDP as a result of their scenic qualities, historic estates, and recreational opportunities. 10.17. The LVIA identified that the most significant effects in Moray would occur where the proposed OHL crosses the Spey Valley SLA and areas of upland moorland and forestry. The introduction of tall steel lattice towers and the associated operational corridor (OC) would result in the permanent loss of woodland and changes to the visual character of the landscape. In the Spey Valley, the presence of multiple OHLs, including the new proposal, would create a cumulative “wirescaping” effect, further detracting from the visual amenity and perceptual qualities of the area. The felling of large areas of coniferous woodland, particularly on Ordiequish Hill, would be highly prominent in views from local roads, the River Spey, and key recreational routes such as the Speyside Way. The most significant adverse landscape and visual effects are likely to occur in the following parts of the proposed OHL: 10.18. Section 12 - Dava Way: Effects on people using the Dava Way would be significant and adverse. The proposed development would contribute to a complex array of infrastructure in this area including an existing OHL, the operational Hill of Glaschyle wind farm and the consented Clash Gour wind farm resulting in significant adverse combined cumulative landscape and visual effects. The larger towers of the proposed development and their proximity to this recreational route increases the magnitude of effect on character and views. It is recommended that off-site native woodland should be established to the south of the proposed development and close to the Dava Way, possibly focussed on the lower slopes of Cairn Eney and between the Dava Way and the water course to the east of this recreational route. Page 61
Page 62
10.19. Section 13 - Glen Lossie: This small-scale complex valley landform is heavily wooded in places and not well frequented but nonetheless significant adverse effects on character will occur with these accentuated by the consented Clash Gour wind farm. The width of the OC should be increased where the line crosses the valley and native riparian planting and open space should be extended in this area. There are opportunities for compensatory native woodland planting to be accommodated in the vicinity of the River Lossie between Dallas and the proposed development and along the minor road between Dallas and Knockando as this would have biodiversity benefits as well as increase screening for visual receptors. 10.20. Section 14 - Kellas area: The Kellas Alternative Alignment would be aligned closer to the smaller existing overhead line and to the settled Lossie valley. It would necessitate additional removal of 11.84ha of commercial woodland and 2.41ha of native woodland. The removal of lines of trees and hedgerows is also noted as being required to accommodate this alternative alignment in Appendix 8.3 and the LVIA concludes increased adverse effects (significant) on residential and recreational receptors (EIA Report paragraphs 7.8.28 and 7.8.29). The preferred route alignment would have minimal effects on residential properties, roads and recreational routes in the Kellas area. The alternative alignment in contrast would result in significant adverse landscape and visual effects (including significant cumulative effects with the Kellas Drum wind farm which is assumed to be constructed if the alternative route is selected). It is strongly recommended that the Kellas Alternative Alignment is avoided. 10.21. Section 15 - Glen Rothes: Views from the A941 where the large towers of the OHL would be prominent seen in the confines of this narrow and deeply incised glen. The proposed wind farms of Teindland and Blackhills, if constructed, would additionally result in significant adverse cumulative effects with the proposed development in this area. Off-site woodland and tree planting along the A941 would help screen views from the A941. 10.22. Sections 16 and 17 - The Spey valley crossing: Where the proposed development would be seen in close proximity to two existing smaller OHLs and with landscape and visual effects further exacerbated by the complexity of diamond crossings where OHLs intersect. The magnitude of effect on landscape character, views and on the special qualities of the Spey Valley SLA in this area would be of the greatest severity along the route of the proposed development in Moray. The only mitigation that would be effective here would be undergrounding the line with terminal towers sited within forestry in Altonside and Ordiequish Forest to minimise landscape and visual impacts. Moray Council requested at the Pre-App meeting 25/7/24 that alternative measures to OHLs should be considered through sensitive landscapes such as SLAs (EIA Report Table 7.1). Page 62
Page 63
10.23. Section 19 - Keith/Newmill area: The proposed development would exacerbate the complexity of converging transmission lines and substation development around the eastern fringes of Keith. The proposed OHL would particularly affect character and views where it is aligned across the narrow valley of the Burn of Drum and steep farmed and wooded slopes east and south-east of Keith with angle towers and diamond crossings contributing to major adverse effects. It is recommended that detailed proposals are drawn up by the Applicant for mitigation and enhancement planting in this area. 10.24. There would be significant adverse landscape and visual effects during the construction phase associated with the setting up of temporary working areas, construction scaffolds, the widening of public roads (including removal of roadside trees and hedgerows), felling of woodlands and removal of other vegetation generally within a 90m wide corridor and the construction of access tracks, bridges and culverts to facilitate access along corridor. There would also be activity and noise during the construction phase which would significantly impact on the perceptual qualities of the landscape, particularly affecting more tranquil and natural landscapes along the route. 10.25. During the operational phase, the permanent loss of woodlands along the route corridor and the introduction of tall transmission line towers and wires would result in permanent significant adverse landscape and visual effects. These effects would generally extend around 1km either side of the proposed transmission line but would increase in some more open areas and/or where the line is seen against the sky, where multiple towers appear close together in long views or where the angle of route changes (necessitating heavy appearing angle towers). The crossing of existing OHLs in the Spey Valley and Keith area will be particularly intrusive due to the concentration of intersecting towers and lines at these points. 10.26. There would be significant adverse effects affecting the visual amenity of many residential properties lying close to the route of the proposed transmission line. Residential Receptor Groups are considered in the LVIA. Major adverse effects are likely to occur on properties with more open views lying within around a kilometre of the line where it is aligned on the northern slopes of Brown Muir to the eastern side of the Spey crossing and where it is aligned south-east of the Wood of Ordiequish to Keith. Significant adverse cumulative effects would occur around Keith where the proposed development would further compromise the natural landscape setting of the town and would be seen in conjunction with a great many converging OHLs and substation development. 10.27. Significant adverse cumulative landscape and visual effects will additionally occur in the western part of the route where the consented Clash Gour wind Page 63
Page 64
farm would be seen from the Dava Way (the principal recreational facility in this area). They would also occur in the Kellas area should the Kellas Drum wind farm be consented and the Kellas Alternative Alignment be adopted. Significant cumulative effects would also occur on Glen Rothes and the Spey valley (including on The Spey Valley SLA) where the proposed development would be sited in close proximity to the proposed Teindland and Blackhills wind farms. 10.28. This proposal is predicted to have significant adverse effects on both the landscape character and visual amenity of the area surrounding the proposed OHL route, particularly in designated and sensitive locations including The Spey Valley SLA. While mitigation measures are proposed, they will not fully address the scale of change introduced by the development. The most pronounced impacts will be experienced during construction and in the early years of operation, with some reduction in effect as woodland re-establishes over time. However, the introduction of new, prominent electricity transmission infrastructure, larger than any pylons currently in Moray, will inevitably result in lasting changes to the landscape and views of the areas surrounding the OHL. 10.29. NPF4 Policy 11 should be given the greatest consideration regarding landscape and visual issues, as it represents the most recently adopted policy on this matter. The primary focus is on part (e)(ii), which stipulates that project design and mitigation measures must clearly demonstrate how significant landscape and visual impacts have been addressed, acknowledging that such impacts may be inherent to certain types of renewable energy development. When these impacts are localised and/or suitable design mitigation has been implemented, they will typically be regarded as acceptable. NPF4 also places substantial weight on the contribution of such proposals to renewable energy targets and climate objectives. 10.30. Due to its span, this proposal will have a notable landscape and visual impact throughout for a 59km span across Moray. While these effects will mainly be localised to areas adjacent to the OHL – as accepted by NPF4 Policy 11 - the project's considerable length means this will be across the region. Nevertheless, such wide-ranging impacts are unavoidable given the scale of the proposal. 10.31. Cultural Heritage NPF4 Policy 7 (Historic Assets and Places) and MLDP Policy EP8 (Historic Environment) seeks to protect historic and archaeological assets. MLDP Policy EP10 (Listed Buildings) states that development proposals will be refused where they would have a detrimental effect on the character, integrity or setting of a Page 64
Page 65
listed building. Structures such as pylon towers have the potential to affect the setting of listed buildings other cultural heritage assets some distance away. 10.32. Chapter 11 of the EIA Report contains evaluation of the impact of the proposed OHL route on cultural heritage assets. The scope of the assessment was carried out in consultation with Aberdeenshire Council Archaeology Service (on behalf of Moray Council), who emphasised the need to consider both designated and non-designated heritage assets, as well as the importance of compensatory planting and targeted walkover surveys, particularly in wooded areas. The chapter confirms that these recommendations were incorporated into the assessment and mitigation strategy. 10.33. Within Moray, the OHL route and its surrounding area contains a number of heritage assets: both designated (such as listed buildings and Gardens and Designed Landscapes) and non-designated (including agricultural features and other archaeological remains). The assessment identified that construction activities, especially those related to tower compounds and access tracks, have the potential to cause direct physical impacts on some non-designated heritage assets. For example, the loss or partial loss of certain farmsteads, trackways, and enclosures is anticipated, with the significance of these effects ranging from slight to moderate adverse prior to mitigation. However, the report outlines a mitigation strategy which includes archaeological walkovers, demarcation and avoidance, earthwork surveys, and historic building recording, all to be agreed with the Council. 10.34. For designated heritage assets in Moray, the assessment concludes that direct physical impacts during construction will be avoided. However, some assets may experience changes within their setting due to the introduction of new overhead line infrastructure. These impacts are assessed as slight adverse and not significant, due to factors such as distance, existing screening, and the presence of other infrastructure. 10.35. The report also considers cumulative effects with other developments in the area and concludes that, for Moray, there are no significant cumulative impacts anticipated. This is due to either the absence of shared receptors or the implementation of effective mitigation strategies. The residual effects, after mitigation, are generally assessed as slight adverse and not significant for the majority of heritage assets in Moray. Page 65
Page 66
10.36. The only exception is the loss of non-designated heritage assets where moderate adverse effects remain due to the inability to avoid certain assets entirely, namely: • Cairn Duhie (ND95) – Boundary Stone (loss of heritage asset) • Fairy Knowe (ND135) – Possible Dun (loss of heritage asset) • Glen Latterach (ND140) – Spring (loss of heritage asset) • Mill Our (ND148) – Trackway (partial loss of heritage asset) • Netherglen (ND178) – Standing Stone (loss of heritage asset) • Comprehensive excavation, recording, and publication are proposed to ensure preservation by record. 10.37. Historic Environment Scotland have responded to the ECU, objecting to the proposal (at the time of writing this report) due to impacts on designated heritage assets in the Highland Council area. However, no issues were identified in Moray in terms of the impact of the proposed OHL on the following: • Designed Gardens and Landscapes – Regulas, Blackhills House, Gordon Castle. • Category A Listed Buildings – Dunphail House, Edinkillie House, Kellas House, Pittensair, Mill of Towie. • Aberdeenshire Council Archaeology Service (on behalf of Moray Council) have not objected to the proposal, but recommend conditions requiring archaeological mitigation to be undertaken. 10.38. The overall implications of the proposal on cultural heritage in Moray are that, while some non-designated heritage assets may be directly affected by construction, the overall approach proposed minimises impacts and provides suitable mitigation. Subject to conditions as recommended by Aberdeenshire Council Archaeology Service, the proposal is therefore considered to comply with NPF4 Policy 7 (Historic Assets and Places) and MLDP Policy EP8 (Historic Environment) as well as MLDP Policy EP10 (Listed Buildings). 10.39. Noise and Amenity NPF4 Policy 11 (e) (i) requires noise impacts of renewable energy development to be mitigated as part of the design of a development. This is also the case for NPF Policy 23 (Health and Safety) and MLDP Policy EP14 (Pollution, Contamination and Hazards), both of which require noise generated from proposed developments to be an acceptable level or suitably mitigated. Where Page 66
Page 67
this is not the case, development will not be supported. In this instance, Chapter 15 of the EIA Report evaluates noise and vibration from construction and operation of the proposed OHL. In summary it finds that construction vibration and operational noise are not significant, whilst construction related noise would be significant without mitigation. In order to mitigate the impacts of the proposal on noise sensitive receptors, a Construction Noise Management Plan is proposed by the applicant. Where these are factored into the assessment, the conclusion is there is no significant residual effect. 10.40. In reviewing the submission, the Environmental Health service have raised no objections, but have requested a condition be placed requiring a Construction Environment Management Plan to be agreed with the Council in respect of noise, vibration, dust and artificial lighting. Subject to this condition, the proposal is considered to comply with the aforementioned policy 10.41. Private Water Supplies A Private Water Supply (PWS) Risk Assessment undertaken in support of Chapter 10 of the EIA Report has considered the impact of the proposal on private water supplies on and surrounding the OHL route. This has identified that the proposal could have a moderate or major significant impact on 22 PWS in Moray. As such, further assessment is necessary to consider these impacts, along with formation of suitable solutions and monitoring/alternative supplies to be provided. In reviewing the proposal, the Council’s Environmental Health service, responsible for PWS, have requested a condition be placed requiring a Private Water Supply Management Plan and Private Water Supply Monitoring Plan to be submitted, along with measures ensuring an adequate and wholesome supply to those served by affected PWS as a result of construction works. SEPA have also requested a condition requiring further information in respect of PWS. The conditions as requested by Environmental Health will be placed with any response raising no objection. 10.42. Natural Environment NPF4 Policies 1 and 2 adopt a broader perspective on the natural environment, identifying carbon reduction as a key priority in addressing climate change. Policy 1 recognises that ongoing environmental challenges are closely linked with climate change and recommends that both issues be addressed concurrently. The policy further emphasises the development of renewable energy as an integral component of this approach. 10.43. NPF4 Policy 3 (Biodiversity) and MLDP Policy EP2 (Biodiversity) however both seek to enhance biodiversity, so not withstanding allowances made for energy generation in upland areas elsewhere in NPF, efforts should still be made to Page 67
Page 68
enhance the local biodiversity as a result of development. Of note, NatureScot and RSPB will respond separately on aspects such as ornithology and Groundwater dependent terrestrial ecosystems. 10.44. NPF4 Policy 4 (Natural Places) and MLDP Policy EP1 (Natural Heritage Designations) seek to ensure proposals do not have an adverse effect on protected species. 10.45. NPF4 Policy 11 (e) (ix) and MLDP Policy DP9 (a) (iii) and (b) (ii) require renewable energy projects to ensure they do not have an adverse impact on ecology and biodiversity. 10.46. The scale of the proposal means it traverses a diverse ecological landscape within Moray, including internationally, nationally, and locally designated sites, a range of priority habitats, and areas supporting protected species. The assessment of ecology impacts (in Chapter 8 of the EIA Report) has been undertaken in accordance with best practice guidance and relevant legislation, with a focus on minimising adverse ecological effects and securing biodiversity net gain. 10.47. The route passes close to or over several designated sites, notably the River Spey Special Area of Conservation (SAC) and Site of Special Scientific Interest (SSSI), as well as other SSSIs such as Mill Wood, Buinach and Glenlatterach, and Coleburn Pasture. Ancient woodland and areas of blanket bog - both considered irreplaceable habitats - are present within the zone of influence. The project will result in the loss of some woodland including ancient woodland (further considered under Woodland below) and areas of blanket bog, though efforts have been made to avoid or minimise impacts where possible. The loss of these habitats is considered significant due to their irreplaceable nature, but mitigation and restoration measures are proposed, including woodland edge planting and peatland restoration. 10.48. Surveys undertaken have identified the presence or potential for a range of protected species, including bats, badger, pine marten, red squirrel, otter, water vole, wildcat, fish (notably Atlantic salmon), and freshwater pearl mussel. The project will result in the loss or disturbance of some resting sites, setts, dreys, and potential roosts, particularly through tree felling and construction activities. The assessment applies a precautionary approach, recognising that undetected features may be present. Mitigation includes pre-construction surveys, sensitive Page 68
Page 69
timing of works, creation of compensatory habitats (such as artificial setts or bat boxes), and strict adherence to species protection plans. 10.49. The development oversails or is adjacent to several watercourses, including the River Spey, which are of high ecological value. Construction activities pose risks of sedimentation, pollution, and habitat fragmentation, potentially affecting aquatic species such as salmon and freshwater pearl mussel. Mitigation measures suggested by the applicant include best practice construction methods, timing restrictions to avoid sensitive periods for fish, and the use of species protection plans. Any impact on freshwater pearl mussel, given its endangered status, is considered significant and must be avoided wherever possible. 10.50. A Biodiversity Net Gain (BNG) assessment has been undertaken, demonstrating that while there will be a net loss of some habitats on-site (notably woodland and hedgerows), there will be creation of scrub and grassland habitats. Off-site habitat enhancement and creation are proposed to offset losses and achieve a minimum 10% net gain in biodiversity, in line with policy requirements. Restoration of temporarily affected habitats, such as peatland and grassland, is also planned. 10.51. The assessment considers cumulative effects with other developments in the area. 10.52. While the loss of irreplaceable habitats and impacts on certain species are significant, the implementation of mitigation, restoration, and compensation measures is expected to reduce residual effects to a level that is not significant for most receptors, except for irreplaceable habitats and certain protected species where effects remain significant at a local or regional scale. 10.53. Considerations in respect of ecology are best considered by consultees such as NatureScot and the RSPB. The proposal will have unavoidable but mitigated impacts on designated sites, priority habitats, and protected species within Moray. The approach prioritises avoidance, minimisation, and compensation, with a strong emphasis on biodiversity net gain and long-term habitat restoration. Ongoing monitoring and adaptive management are recommended in the EIA Report to ensure the effectiveness of mitigation and to address any unforeseen ecological effects during construction and operation. Page 69
Page 70
10.54. Conditions covering this are to recommended to ensure appropriate protection and mitigation for ecology, as well as biodiversity enhancement is delivered as part of this proposal, as well as potential linkages/enhancements to the Moray Nature Network. This will also incorporate recommendations as suggested under the Landscape and Visual Impact section of this report. 10.55. It should be noted that, as the time of writing this report, NatureScot and RSPB have objected to this proposal (as detailed in their consultation responses to the ECU dated 18 November 2025) because of its potential impact on the capercaillie population in the Darnaway and Lethen Special Protection Area, which spans the Moray and Highland boundary north of the proposed OHL route. Ultimately, it is for the ECU/Scottish Ministers to decide whether the proposal complies with relevant planning policies. However, given NatureScot's and RSPB’s objections, it would appear the proposal may conflict with planning policies concerning ecology, protected species, and international designations. Nevertheless, this is not seen as a reason for the Council itself to object, since these parties are the most appropriate to address this issue through their consultation responses. 10.56. Flood Risk Planning policies at a national and local level generally presume against development in areas at risk of flooding, however there are exceptions. Under NPF4 Policy 22 (a)(i), development proposals at risk of flooding or in a flood risk area will only be supported if they are for essential infrastructure where the location is required for operational reasons. MLDP Policy EP12 takes a similar position on development in areas at risk of flooding. There is however criteria set out by SEPA which development accepted in flood risk areas should comply with. This includes a requirement to not reduce the capacity of a floodplain as a result of development. 10.57. All but two of the pylons meet with the SEPA Standing Criteria on development at risk from flooding, however two pylons at Dipple, adjacent to the River Spey (pylon towers CB12-16A and CB14-1B) require building of foundations above ground that will result in a loss of functional floodplain of the River Spey. A Flood Risk Assessment (FRA) within the EIAR (Volume 5, Appendix 10-8) notes the volume of water displaced by the tower foundations (300 m3 ) is minimal compared to the size of the floodplain, and it is therefore considered to have an inconsequential impact on the floodplain's capacity. The width of the floodplain at this location is approximately 1 km, consisting predominantly of flat, open farmland, as evident from the LiDAR imagery that has been undertaken as part of the FRA. To estimate the area of the Spey floodplain in this area, the 200-year fluvial flood extent has been clipped using the Boat o’ Brig as the upstream Page 70
Page 71
extent and A96 Spey Bridge as the downstream extent. This area is approximately 7 km2. SEPA flood map depth layers indicate most of this area has a flood depth band of 0.3 - 1.0 m. This means the maximum capacity of the floodplain is estimated to be 7,000,000 m3 , making the volume displaced by towers CB12-16A and CB14-1B approximately 0.004% of the total floodplain capacity. 10.58. Moray Flood Risk Management has reviewed the proposal and raised no objections, but has recommended informative notes to be included with any consent in respect of flood risk. SEPA, in responding the ECU, have raised no objections either, but this is subject to condition requiring compensatory storage to be provided to mitigate the impact of any displaced flood waters as a result of the land raising necessary to accommodate the two pylons at Dipple. Subject to this condition, and others as recommended by SEPA, the proposal is considered to be in accordance with NPF4 Policy 22 and MLDP Policy EP12. 10.59. Access and Traffic NPF4 Policy 13 (Sustainable Transport) and MLDP policies PP3 (Infrastructure and Services) and DP1 (Development Principles) contain criteria which seek to ensure the transport impact of a proposal is acceptable, with an emphasis of minimising traffic generation and mitigating impacts on the existing transport network. With specific reference to energy developments, NPF4 Policy 11 (e) (vi) requires proposals to consider impacts on road traffic and the road network. 10.60. Chapter 13 of the EIA Report considers the transport impacts associated with the construction phase of the proposal. The supporting information submitted considers baseline conditions, predicted construction traffic including abnormal, and the effectiveness of proposed mitigation measures. 10.61. Impacts on Moray cover a variety of public roads to be used to provide access to construction areas, including the A96 trunk road, and the Council’s local road network, of which many roads are rural, single-track routes with passing places. Baseline traffic flows were established using a combination of automatic traffic counters and Department for Transport (DfT) data, with additional consideration given to accident records and the presence of sensitive receptors such as schools, residential areas, and pedestrian/cycle facilities. 10.62. During the peak construction period, a temporary but significant increase in traffic volumes is predicted, particularly heavy goods vehicles (HGVs), on Page 71
Page 72
several key routes in Moray. For example, on the A940, B9010, and B9103, daily HGV movements are expected to rise substantially, with some links experiencing increases well above 30% - the threshold at which further assessment is required. However, even with these increases, the analysis demonstrates that the existing road network has spare capacity, and the temporary rise in traffic is not expected to result in significant congestion or capacity issues. 10.63. The assessment finds that, while there will be a noticeable increase in HGV and overall vehicle movements, the impact on community severance (the perceived division of communities by traffic) is generally minor and not significant. Most affected roads are rural with low baseline flows and limited pedestrian activity. In urban areas such as Forres and Elgin, where pedestrian facilities and crossings are present, the impact is further mitigated. The effect on pedestrian and cyclist amenity is also considered minor, as the temporary increase in traffic does not double existing flows on most links, and the number of non- motorised users is expected to remain low. 10.64. A review of accident data for the Moray area indicates that the majority of roads have accident rates below the national average, and there are no inherent safety concerns that would be exacerbated by the construction traffic. All reported accidents in recent years have been attributed to driver or pedestrian error rather than road conditions. The temporary increase in HGVs is not expected to materially worsen road safety, especially with the implementation of a Construction Traffic Management Plan (CTMP). 10.65. A range of embedded mitigation measures is proposed, including the preparation and enforcement of a detailed CTMP, physical improvements to access points and junctions, temporary signage, and restrictions on construction traffic during sensitive periods (e.g. school times). No additional mitigation is deemed necessary beyond these embedded measures, as the assessment concludes that the residual effects will remain minor and not significant. 10.66. The assessment also considers the potential for cumulative impacts with other consented or committed developments in the area, such as wind farms and grid connections. Even when accounting for these additional sources of construction traffic, the analysis finds that the road network retains sufficient capacity, and cumulative effects are not expected to be significant. Page 72
Page 73
10.67. In considering the proposal, the Transportation Manager notes the development would take place in a phased manner, with work on some sections of the route taking place concurrently. Whilst a framework CTMP has been submitted as part of the application, a full CTMP will be required for each Section of the route. A Section 96 Agreement and associated Road Bond will also be required for the proposed development covering the construction period for each Section of the cables. The majority of construction vehicles will be standard HGVs and workers vehicles. However there will be abnormal loads required to access each section – a crane to erect the towers and for the delivery of the (heavy) cable drums. The applicant has undertaken initial assessments of the routes where the abnormal loads are required to use the public road and has identified ‘pinch points’ and locations where improvement to and the upgrading of the public road may be required. Further assessment work will be undertaken as the project progresses, should consent be granted and these matters are recommended to be secured by conditions. 10.68. Conditions requiring a detailed phasing plan, access strategy and construction programme to be submitted are recommended, along with further detail of the proposed access routes including upgrades to the road/access points, detail of cable and haul road crossings of public roads, diversion of footpaths are also required (further considered under Public Access and Recreation below). 10.69. Transport Scotland are the roads authority for trunk roads and have raised no objections to the proposal (to the ECU). 10.70. Subject to conditions as recommended, the proposal is considered to comply with the aforementioned policies in respect of transportation matters. 10.71. Soils (Peat, Prime Agricultural Land) NPF4 Policy 5 (Soils) states that while generally carbon rich soils should be avoided by development, part (c) (ii) within the policy states generation of energy from renewable sources that optimises the contribution of the area to greenhouse gas emissions reductions targets may be accepted in peatland. 10.72. MLDP Policy EP16 (Geodiversity and Soil Resources) states large scale (over 20MW) renewable energy proposals, development will only be permitted where it has been demonstrated that unnecessary disturbance of soils, geological interests, peat and any associated vegetation is avoided. Evidence of the Page 73
Page 74
adoption of best practice in the movement, storage, management and reinstatement of soils must be submitted along with any relevant planning application, including, if necessary, measures to prevent the spread of invasive non-native species. 10.73. The proposal crosses several areas within Moray that contain peat and carbon- rich soils. Chapter 10 of the EIA Report (and associated appendices, including a Peat Management Plan) note the route intersects pockets of Class 1 and Class 2 peatland, as identified on the NatureScot Carbon and Peatland Map. These areas are considered nationally important due to their role in carbon storage and their ecological value. 10.74. Peat surveys undertaken along the route have found that, while the majority of the area is underlain by mineral soils, there are localised sections with significant peat deposits in Moray. The average peat depth recorded in the surveyed area is under 1 metre, with some isolated pockets exceeding this. The most notable concentrations of peat are found in upland and wetland areas, particularly to the west of the Moray section. There is virtually no peat on the OHL route east of Elgin to Peterhead. 10.75. To minimise impacts on peat (peat loss, compaction, erosion and landslips/instability), the project design has incorporated mitigation by means of micrositing, use of floating tracks and reuse/reinstatement of peat. 10.76. With these mitigation measures in place, the EIA Report concludes that the residual impact on peat and soils in Moray will be minor and not significant in EIA terms. The volume of peat to be excavated is a small proportion of the total peatland resource in Moray, and the majority of this peat will be reinstated or used for restoration. The risk of long-term degradation or loss of carbon from soils and peat is considered low, provided that best practice is followed throughout the construction and operational phases. Ultimately, SEPA are best placed to give evaluation to impacts on peat. 10.77. SEPA have raised no objections to the proposal overall, but have highlighted shortcomings in the outline Peat Management Plan (PMP) that was prepared in support of the EIA Report (Volume 5, Appendix 10-2). They have requested conditions to be placed requiring a detailed PMP to be submitted and agreed with the planning authorities covering this proposal, subject to agreement with SEPA. Page 74
Page 75
10.78. The OHL through Moray largely avoids Prime Agricultural Land (PAL) other than a small section of grade 2 land at Burnside of Dipple, adjacent to the River Spey on which two pylons are proposed. Whilst there is a general presumption against development that results in the loss of PAL, NPF4 Policy 5 (b) allows for siting of essential infrastructure (which this proposal is considered to be), subject to there being no other appropriate site and the design minimises the extent of PAL necessary to accommodate it. 10.79. In this instance, it is considered the alignment of the route has been through extensive refinement, as demonstrated in the EIA Report. The overall extent of PAL lost as a result of this proposal is minimal, noting the impact will be limited to the bases of two pylons/towers. In order to ensure any further loss of prime agricultural land is minimised, in raising no objection to this proposal it is recommended that any condition requiring compensatory flood water storage (as requested by SEPA). Avoids the loss of PAL. Subject to this condition, the proposal is not considered to be at odds with NPF4 Policy 5 (b) with regards to PAL. 10.80. Woodland and Forestry Impacts The forestry chapter (12) of the EIA Report considers direct and indirect impacts, cumulative effects, and mitigation measures, focusing on a 100-metre corridor on either side of the alignment and areas at risk of windblow due to felling. Woodland Reports were prepared for each affected area of woodland and the information provided in these is extensive. Reports for Moray are covered in the EIA Report under Volume 5 appendices 12-1-53 to 12-1-93. 10.81. NPF4 Policy 6 (Forestry, Woodland and Trees) seeks to protect and expand forests, woodland and trees. Policy EP7 (Forestry, Woodlands and Trees) is relevant to the issue of any felling that may take place. At a national level, the Control of Woodland Removal Policy (CWRP) provides a policy direction for decisions on woodland removal in Scotland, and requires the Scottish Government to apply the policy to decisions within its areas of competence. 10.82. In the Moray Council area, the project will result in the removal of approximately 189.58 ha of woodland. This includes 176.13 ha of commercial forestry, 12 ha of native woodland, and 1.45 ha of ancient woodland. While the loss of commercial forestry is considered minor and not significant in the context of Moray’s overall forest resource, the loss of native woodland is assessed as moderate and significant. The removal of ancient woodland is regarded as major Page 75
Page 76
and significant due to its irreplaceable ecological value, even though it represents only a small proportion of the total resource. 10.83. The Kellas Alternative Arrangement would necessitate the removal of a further 11.84 ha of commercial forestry, and 2.41 ha of native woodland. The overall loss of native woodland over and above that proposed as part of the preferred route remains as a moderate and significant impact. 10.84. Mitigation measures include reducing the operational corridor width where possible, retaining scrub and understorey layers where safety allows, and implementing off-site compensatory planting that exceeds the area of woodland removed. These measures are designed to comply with national policy and deliver a net positive effect on biodiversity and carbon sequestration. Engagement with landowners will ensure that mitigation is integrated into long- term forest plans. 10.85. Despite these efforts, the residual effect on ancient woodland remains major and significant, as its loss cannot be fully mitigated. For native and broadleaved woodland, residual effects after mitigation are considered minor and not significant. Commercial forestry and forest access impacts are also assessed as not significant. Cumulative effects, taking into account other projects in the area, are expected to be negligible due to compensatory planting requirements. 10.86. The most significant impact within the Moray Council area is the loss of ancient woodland. At the time of writing this report, Scottish Forestry had not provided any consultation comments to the ECU. As the Scottish Government’s agency responsible for forestry policy, support and regulations, they are best placed to provide input on the proposal from a forestry perspective. However the Council, as Planning Authority, also have a role in ensuring that local policies in respect of woodland are considered. 10.87. Given the planning policies in place (NPF4 Policy 6 and MLDP Policy EP7) are quite clear that the loss of ancient woodland is not acceptable, the proposal is not in accordance with these. However, recognising the position that the development plan does not have primacy in this instance, the lack of compliance will have to be balanced against other policy aims and schedule 9 of the Electricity Act. Page 76
Page 77
10.88. Conditions are to be recommended in respect of the need for compensatory planting of an appropriate mix, taking account of input provided by the Council’s appointed Landscape Adviser, as outlined under Landscape and Visual Impact. 10.89. Aviation and Military Installations When considering impacts on aviation and military/defence sites, the ECU have consulted with relevant consultees. At the time of writing this report, NATS have raised no objection to the proposal, whilst no responses have been received from Aberdeen Airport and Highlands and Islands Airports at the time of writing this report. 10.90. Highland Gliding Club at Birnie could also be impacted – it is noted from the Aviation Risk Assessment provided with the application that discussions are ongoing with them in respect of impacts of the proposed OHL on their operations. 10.91. Under MLDP Policy EP15 there is a requirement for development proposals to not adversely affect MOD safeguarding operations at RAF Lossiemouth and Kinloss Barracks. At the time of writing this report, the MOD have objected to this application due to concerns about impacts on protected airspace for RAF Lossiemouth. 21 pylon towers are within this area, and 19 of these infringe on the protected airspace. These pylons (CB11-1 to CB 12-6) run from Coleburn/Netherglen to Badentinan, on the northern slopes of Brown Muir. Whilst this is not a reason for the Council to object (noting it is within the remit of the MOD), this response will highlight incompatibility with the aforementioned MLDP Policy EP15 should the MOD objection not be resolved. 10.92. Public Access and Recreation The impacts of the OHL on recreation including outdoor access were assessed as part of the Socio-Economic Assessment and the EIA Report (Chapter 14). Within the Moray Council area, the OHL would cross several watercourses including the River Lossie, River Spey, and River Isla. However, access to recreational activities on these waterways - including kayaking, canoeing, and fishing - will not be restricted during construction, as priority will be given to recreational users. The OHL route also contains woodlands used for recreation, notably Wood of Ordiequish. These woodlands are expected to experience tree removal and the presence of construction activities, particularly where the project bisects them. Visitors to these sites may notice reduced tranquillity and Page 77
Page 78
visual changes, resulting in a moderate adverse (significant) effect during construction. 10.93. The proposal intersects with a number of public access routes including core paths, hill tracks and public rights of way. Notably, the proposal passes over the Dava and Speyside Ways. A Draft Outdoor Access Management Plan appended to chapter 14 identifies the routes potentially affected by the proposal, and outlines the approach to managing access on these routes during construction. In reviewing the details, the Councils Outdoor Access Officer has drawn attention to two core paths that were not considered in the draft plan, an identified opportunities for management and enhancement of core paths as a result of this proposal. 10.94. The EIA Report notes that the overall impact on public access routes is expected to be minor adverse to negligible, resulting in a minor adverse (not significant) to neutral effect. Even for the more sensitive long-distance routes, the effect is not anticipated to be significant when considering the full length of the routes. Non-designated public access routes and publicly accessible land will also experience minor or neutral effects. 10.95. Subject to condition requiring a detailed Outdoor Access Management Plan to be agreed with the Council to ensure management of existing recreation and access routes during construction and enhancement of routes as a result of the proposed OHL development, the proposal is considered to comply with relevant policies (NPF4 Policy 13 (b)(viii) and MLDP Policy PP3 (b)(ii). 10.96. Socio-economics The proposal is expected to deliver substantial economic benefits, both regionally and nationally, while facilitating the transmission of renewable energy from the north of Scotland to areas of demand across the UK. 10.97. The supporting Socio-Economic Assessment that accompanies the application considers the predicted benefits of the proposal under two scenarios: • the “Core Scenario” whereby the minimum level of supply chain content that could be achieved locally is calculated in a worst case scenario; and • the “Ambition Scenario” which is the potential local economic benefit of the proposal from a full implementation of a local supply chain development plan. This scenario would have a greater proportion of spending at a regional (Moray, Aberdeenshire and Highland) and Scottish level. Page 78
Page 79
10.98. Under the Core Scenario, the proposal is forecast to generate £41.8 million in Gross Value Added (GVA) and support 385 years of employment across the regional area. Across Scotland, the figures rise to £413.2 million GVA and 4,010 years of employment. At the UK level, the impact is even greater, with £1,068.1 million GVA and 10,334 years of employment anticipated. 10.99. These benefits could be further enhanced under an ambition scenario, which assumes greater local supply chain involvement, potentially increasing the regional impact to £91.2 million GVA and 846 years of employment, and the Scottish impact to £495.5 million GVA and 4,931 years of employment. 10.100. The Socio-Economic Assessment notes the applicant has adopted a Community Wealth Building (CWB) approach to ensure that economic benefits are retained and reinvested locally. This strategy focuses on inclusive ownership, local procurement, workforce development, land and property, and finance. 10.101. The applicant has also created a housing strategy which aims to deliver at least 200 new homes and unlocking 1,000 additional homes by 2030, helping address rural depopulation and supporting the workforce required for the project. The “unlocking” strategy includes initiatives to refurbish disused properties and unlock additional housing through long-term leases. This is however a generic policy approach of the applicant, and does not specify how housing will be developed in Moray specifically, with a general target covering the entire “north of Scotland” which presumably covers the applicant’s transmission area. However it is noted that the applicant has been in touch with the Council to discuss delivery of housing in Moray. 10.102. To ensure socio-economic benefits are maximised in Moray in accordance with NPF4 Policies 11 (c) and 25 and the Council’s Community Wealth Building Guidance, a condition is recommended requiring a detailed Community Wealth Building Plan to be submitted an agreed with the Council. 10.103. Electric and Magnetic Field Assessment An Electric & Magnetic Field Study Report has been submitted in support of the proposal which considers the electric and magnetic fields of the proposal. The assessment concludes ‘(t)he assessed EMF levels comply fully with the exposure limits set out in the UK’s Code of Practice. These guidelines are based on internationally recognised limits and form the basis of the framework for EMF Page 79
Page 80
safety in the UK. The results confirm that EMF levels remain within the permissible thresholds, demonstrating the Proposed Development’s compliance with the Code of Practice.’ 10.104. The Council does not have the expertise to consider these matters, though would expect this is considered and addressed by the ECU when considering the proposed OHL. 10.105. Cumulative Impacts/Assessment Chapter 16 of the EIA Report evaluates the combined impacts of the proposed development and other associated projects, focusing on both construction and operational phases. It considers how multiple effects - including noise, traffic, changes to visual amenity, private water supply, and flood risk - might interact and potentially magnify impacts on local receptors, particularly residents and transport users. 10.106. During construction, residential receptors in Moray along the route may experience a combination of effects. These include temporary increases in noise and vibration, heightened construction traffic, minor changes to hydrological conditions, and alterations to visual amenity. While some individual effects are classified as major or moderate adverse, the cumulative interactions are predicted to be minor adverse and not significant overall. These impacts are expected to be localised, intermittent, and short-term, with only slight magnification due to the overlap of effects. 10.107. Transport users in Moray, such as those on routes which the OHL crosses including the A940, Knockando to Dallas Road, A941, A96, and the Aberdeen to Inverness railway may also be affected. The combined effects of construction noise, increased traffic, and changes to the landscape are anticipated to result in minor adverse impacts, again considered not significant. The assessment notes that these effects are short-lived and unlikely to result in substantial long- term consequences for transport users. 10.108. The EIA Report concludes the cumulative effects from construction and operation of the OHL are predicted to be minor adverse and not significant. While magnification of effects may occur due to the interaction of multiple impacts, these are temporary and short-term in nature. The findings suggest that the proposed development, in combination with other foreseeable Page 80
Page 81
projects, will not result in significant cumulative harm to residential communities or transport users in Moray. 11. Conclusions and Recommendation 11.1. When balancing the considerations of relevant policies of National Planning Framework 4 and the Moray Local Development Plan 2020, there is a clear recognition that climate change must become a primary guiding principle for all plans and decisions. Significant weight is to be given to the climate emergency and the contribution of individual developments to tackling climate change. Whilst the proposal is considered to be contrary to several policies (due to the proposals significant landscape and visual impact and the loss of ancient woodland), the impact of the proposal on these matters is not considered to outweigh the need for infrastructure to transmit renewable energy. 11.2. In light of this, it is recommended that Council raise no objection, subject to the following: • The schedule of recommended conditions and informative notes as outlined in Appendix 2. • Note that the Council has a strong preference for the preferred alignment to be taken forward, regardless of the determination of the Kellas Drum Wind Farm. This is on the basis the Kellas Drum Alternative Alignment has greater landscape and visual impacts on the Kellas area and would result in additional environmental impacts including woodland removal. • Request that the applicant to work with the Council to maximise the socio- economic benefits of the proposal in the Moray area, particularly in recognition that the Council is raising no objection to enable the timeous delivery of nationally critical electricity infrastructure. • Inform Scottish Ministers that, due to this proposal being classified as a ‘Priority Application for Transmission Infrastructure’ by the Scottish Government, the Council has had very limited time to review this large scale infrastructure project in order to meet the consultation deadline, whilst also having to meet deadlines to consider the proposal within the democratic framework of the Council. Although we have worked to provide a comprehensive and detailed assessment, we expect the Scottish Ministers/ECU, as the decision-makers, to consider all relevant issues and ensure these are properly addressed. • Note that as the enforcing authority for conditions as part of any deemed planning permission, Moray Council would wish to be involved in the formulation of conditions should this proposal be consented, recognising that additional conditions may be required because of consultation responses from other key stakeholders. Page 81
Page 82
Page 82
Page 83
APPENDIX 2 MORAY COUNCIL RECOMMENDED CONDITIONS AND INFORMATIVE NOTES FOR BEAULY TO PETERHEAD 400kV OVERHEAD LINE The conditions suggested below are recommended by Moray Council, and it is expected that all conditions from statutory consultees (e.g. SEPA, NatureScot etc.) are to be placed with any grant of consent in addition to these, as well as standard conditions placed by the ECU in respect of commencement of works, commissioning, assignation etc. We would also request that the condition from SEPA be updated to include a requirement to provide compensatory storage for flood water at Dipple to avoid the loss of Prime Agricultural Land (final condition in Appendix to SEPA’s consultation response dated 18 November 2025. Informative notes are also included. Approved Details and Limits of Deviation 1. The development shall be constructed and operated in accordance with the approved provisions of the application and the Environmental Impact Assessment (EIA) Report. The development maybe amended within the Limits of Deviation as specified in Chapter 3 (section 3.6) of the EIA Report and its associated figures. No later than one month after the date of final commissioning of the development, an updated drawing must be submitted showing the final position of the overhead line, including the positioning and height of all supporting towers and associated infrastructure forming part of the development must be submitted for the written approval of the Planning Authority. The updated drawing requires to specify areas where micro-siting has taken place and, for each instance, be accompanied by copies of the ECoW approval or other technical justification. Reason: To control environmental impacts while considering local conditions. Mitigation Measures 2. No development (including the Site Enabling Works) shall commence until a Schedule of Mitigation has been submitted to and approved in writing by the Planning Authority. This Schedule shall encompass a list of all mitigation measures from the EIA Report, any other commitments made by the applicant and all relevant mitigation secured by conditions attached to this permission with defined timescales for implementation of each mitigation measure. Thereafter, the approved Schedule of Mitigation shall be implemented in full unless otherwise approved in writing by the Planning Authority. Reason: To ensure that the identified mitigation through the EIA Report is carried out in accordance with the approved details. Planning Monitoring Officer 3. There shall be no Commencement of Development until the terms of appointment by the Company of an independent and suitably qualified Page 83
Page 84
consultant as Planning Monitoring Officer (“PMO”) have been submitted to, and approved in writing by, the Planning Authority. The terms of appointment shall: (a) impose a duty to monitor compliance with the terms of the deemed planning permission and the conditions attached to it; (b) require the PMO to submit a quarterly report to the Planning Authority summarising works undertaken on site, matters of compliance or otherwise with the terms of the deemed planning permission and conditions attached to it, alongside a summary of the incidents recorded and reported by the Environmental Clerk of Works and Ecological Clerk of Works; and (c) require the PMO to report to the Planning Authority any incidences of non- compliance with the terms of the deemed planning permission and conditions attached to it at the earliest practical opportunity, and no later than 10 working days following the incidence of non-compliance. The PMO shall be appointed on the approved terms throughout the period from Commencement of Development to completion of construction works and post- construction site reinstatement works. Reason: To ensure compliance with the planning permission and the conditions attached to it. Ecological Clerk of Works 4. (1) There shall be no Commencement of Development until the terms of appointment of a suitably qualified, experienced, and independent Ecological Clerk of Works (“ECoW”) by the Company have been submitted to, and approved in writing by, the Planning Authority. The terms of appointment shall: (a) impose a duty to monitor compliance with the ecological and hydrological commitments provided in the approved Schedule of Mitigation, any micro-siting within the Limits of Deviation as approved under condition 1, the Construction and Environmental Management Plan approved under condition 6, the Habitat Management Plan approved under condition 9, and consider and approve any micro-siting requests in accordance with the provisions of condition 1 (“the ECoW works”); (b) require the ECoW to report to the nominated construction project manager any incidences of non-compliance with the ECoW works at the earliest practical opportunity; (c) require the ECoW to submit a quarterly report to the Planning Authority summarising works undertaken on site; and (d) require the ECoW to report to the Planning Authority any incidences of non-compliance with the ECoW works at the earliest practical opportunity, and no later than 5 working days following the incidence of non-compliance. (2) The ECoW shall be appointed on the terms approved under part (1) throughout the period from pre-construction works, commencement of Page 84
Page 85
development, to completion of construction works and post-construction site reinstatement works. Reason: To secure effective monitoring of and compliance with the environmental mitigation and management measures associated with the Development during the construction, post-construction restoration, decommissioning, restoration and aftercare phases. Environmental Clerk of Works 5. (1) There shall be no Commencement of Development until the terms of appointment of an independent Environmental Clerk of Works (“EnvCoW”) by the Company have been submitted to, and approved in writing by, the Planning Authority. The terms of appointment shall: (a) impose a duty to monitor compliance with the environmental commitments provided in the EIA Report, any micrositing under condition 1, the Construction and Environmental Management Plan approved under condition 6, the Habitat Management Plan approved under condition 9, and all species or habitat management plans identified in the EIA Report; (b) require the EnvCoW to report to the nominated construction project manager, developer and Planning Authority any incidences of non- compliance with the EnvCoW works at the earliest practical opportunity; (c) require the EnvCoW to submit a monthly report to the construction project manager, developer and Planning Authority summarising works undertaken on site. (2) Prior to the decommissioning, restoration and aftercare phases of the Development or the expiration of the operational period of the consent (whichever is the earlier), details of the terms of appointment of a suitably qualified, experienced, and independent EnvCoW by the Company throughout the decommissioning, restoration and aftercare phases of the Development shall be submitted to, and approved in writing by the Planning Authority. (3) The EnvCoW shall be appointed on the terms approved under part (2) throughout the decommissioning, restoration and aftercare phases of the Development. Reason: To secure effective and transparent monitoring of and compliance with the environmental mitigation and management measures associated with the Development during the construction, decommissioning, restoration and aftercare phases Construction Environment Management Plan 6. No development shall commence until a Construction Environmental Management Plan (CEMP) has been submitted and agreed in writing by the Planning Authority in consultation with the Service Manager, Environmental Health. The plan shall include measures to minimise construction related noise Page 85
Page 86
(including vibration), dust and artificial lighting. Thereafter the development will be carried out in accordance with the agreed plan. Reason: In order that environmental emissions are considered and managed at the construction phase, in order to protect local residents. Compensatory Planting 7. No development shall commence unless and until a woodland compensatory planting plan (CPP) in accordance with the Scottish Government Control of Woodland Removal Policy 2025 (or such replacement as may be in place at the time that the CPP is submitted for approval) and the Moray Woodland and Forestry Strategy 2025 has been submitted to and approved in writing by the Planning Authority in consultation with Forestry Scotland (FS). The CPP shall provide details of the planting of woodland and include:- (a) The location and details of the proposed planting, timescales for implementation and its maintenance for the operational period of the Development; (b) Planting at a greater level than that to be felled as part of the proposal in the Moray Council area; and (c) A silvicultural proposal for compensatory planting and a protection plan for the life of the development. Reason: To enable appropriate woodland removal to take place in accordance with the current Scottish Government Control of Woodland Removal Policy. Forestry Felling Plan 8. No felling shall take place until a Forestry Felling Plan (FFP) has been submitted to and approved in writing by the Planning Authority in consultation with Scottish Forestry. The FFP shall cover the Development site and shall provide: (a) details of felling and restocking proposals; (b) details of the management measures to reduce the amount of felling required to accommodate the Development; (c) measures to deal with forest waste including brash in line with the UK Forestry Standard; (d) timelines for implementing the plan; (e) details setting out annual monitoring of the felled area and reporting procedures to be carried out by a qualified expert; (f) details of forestry management practices; and (g) details demonstrating compliance with The UK Forestry Standard and the Scottish Government’s Policy on Control of Woodland Removal (as amended or replaced from time to time) and the Moray Woodland and Forestry Strategy 2025. The approved FFP shall be implemented in full upon Commencement of Felling. Reason: To minimise and manage the effects of forestry felling required to accommodate the Development. Page 86
Page 87
Habitat Management Plan 9. There shall be no Commencement of Development until a Habitat Management Plan (HMP) taking account of the Outline Habitat Management Plan (Vol 5, Appendix 8-3, Annex F of the EIA Report), has been submitted to, and approved in writing by the Planning Authority. The HMP shall set out proposed habitat management of the site during the period of construction, operation, and decommissioning, restoration and aftercare, and shall provide for the maintenance, monitoring and reporting of those habitats identified in the Outline Habitat Management Plan, as well as any protected species that may be identified on site. The HMP shall provide provision and details for regular monitoring and review to be undertaken against the HMP objectives and reasonable measures for securing amendments or additions to the HMP in the event that the HMP objectives are not being met. Until otherwise approved in advance in writing by the Planning Authority, the approved HMP (as amended from time to time with written approval of the Planning Authority) shall be implemented in full in line with the timescales set out in the approved plan. Reason: In the interests of good land management and the protection of habitats. Biodiversity Enhancement 10. No development shall commence until an updated Biodiversity Enhancement Plan (BEP) has been submitted to and approved in writing by the Planning Authority in consultation with NatureScot, SEPA and RSPB. This shall be prepared in accordance with and follow on from the approved details within the approved EIA Report, which has been formulated as a result of the finalised route (including micrositing). Unless otherwise approved in advance in writing with the Planning Authority, the approved BEP shall be implemented in full. Reason: In the interests of the protection of the habitats of those species identified in the EIA Report and provision of biodiversity enhancement. Landscape Mitigation 11. As per the approved EIA Report Appendix 7.6, the mitigation measures as proposed should be undertaken in respect of landscape mitigation planting, in line with timescales for planting to be agreed in writing with the Council, as Planning Authority along with the provision of the following additional mitigation: • the increase of the Operational Corridor to 120m in the western part of Ordiequish Wood and other sections of the OHL route; Page 87
Page 88
• the whole Operational Corridor within Ordiequish Wood should be subject to similar treatment as the western part (shown in Plate 2 of Appendix 7.6) due to the recreational use of this woodland; and • additional landscape mitigation planting to be undertaken at the most severely affected Residential Receptor Groups identified in the approved EIA Report, per those specified in Chapter 7 and its figures and appendices. Reason: To ensure appropriate landscape mitigation planting is undertaken, in the interests of the character and amenity of the area surrounding the development. Outdoor Access Management Plan 12. No development shall commence until an Outdoor Access Management Plan (OAMP) which is based on the Draft OAMP contained in the approved EIA Report (Volume 5, Appendix 14) has been submitted to and approved in writing by the Planning Authority in consultation with the Outdoor Access and Countryside Officer. The Access Plan will include the consideration of the upgrade of the existing tracks, the formation of new tracks and other improvements to provide enhanced access opportunities and improvements to track surfaces across the proposed development area, in consultation with local communities. Reason: To improve public access in and around the development area. Community Wealth Building Plan 13. Prior to development commencing, a Community Wealth Building Plan shall be submitted to and approved in writing by the Council, as Planning Authority. The plan shall be prepared in accordance with the Moray Council’s adopted “Community Wealth Building Planning Guidance” and shall also be accompanied by a monitoring statement, which shall demonstrate how the development will deliver beneficial effects to the local economy from the construction and operation of the approved wind farm. Thereafter the development shall be implemented in accordance with the approved details, unless otherwise agreed in writing with the Council as Planning Authority. Reason: To ensure compliance with National Planning Framework 4 policies 11 and 25 with regard to community wealth building. Working Hours 14. Unless otherwise agreed in writing with the Council, as Planning Authority, all working hours shall be in accordance with those specified in the approved EIA Report Chapter 3 Section 3.11. Reason: In the interests of the amenity of residents in the area surrounding the development. Private Water Supplies Page 88
Page 89
15. No development shall commence until a Private Water Supply Management Plan and Private Water Supply Monitoring Plan regarding the impact of the development on private water supplies is prepared by a suitably qualified professional has been submitted to and agreed in writing by the Council as Planning Authority. The plan must include the mitigation and resolutions for affected sources identified in document titled Water and Geological Environment, dated September 2025, during all three stages of development (construction, operation and decommissioning). The Private Water Supply Management Plan and Private Water Supply Monitoring Plan should include mitigations and a water quality testing regime. The plans shall include the testing regime in compliance with the Water Intended for Human Consumption (Private Supplies)(Scotland) Regulations 2017 parameters and mitigations including the provision of emergency potable water to affected supply users in the event of contamination and provision of a new water supply in the event that the contamination is long term and the supply is no longer fit for human consumption. The water testing should also include monitoring levels for site specific building materials, hydrocarbons and or other site specific leaching or spill risk materials or chemicals which may affect the wholesomeness of potable water. Although the overall assessment of the impact on low, medium and high risk private water supplies has been calculated at 10.5.114, to be Negligible Adverse (not significant), the human impact of losing a private water supply in a remote isolated location and the inability to flush toilets, wash and have access to basic domestic facilities is an immediate deterioration in tolerable living standards. As such there must be effective mitigations in place to communicate with users of affected private water supplies and provide potable and other usable water for sanitary and domestic use within a reasonable time period from the issues being identified. In the event that the wholesomeness or adequacy of any private water supply becomes affected by construction activity, all users of such supplies and the Environmental Health Manager of Moray Council must be contacted by the applicant/developer to agree longer term remediation measures within 14 calendar days from the date the wholesomeness or adequacy of the supply has been affected. Thereafter repair of any affected private water supply must be carried be to the satisfaction of the Council as Planning Authority in consultation with the Environment Health Manager. The Council shall be the final arbiter whether any supply has been affected by this development. Reason: In order to safeguard and maintain the wholesome provision of any private water supply affected by the development and monitor the cumulative effect of the development, if any, on the water security of the area. Archaeology Page 89
Page 90
16. No works in connection with the development hereby approved shall commence unless an archaeological written scheme of investigation (WSI) has been submitted to and approved in writing by the planning authority and a programme of archaeological works has been carried out in accordance with the approved WSI. The WSI shall include details of how the recording and recovery of archaeological resources found within the application site shall be undertaken, and how any updates, if required, to the written scheme of investigation will be provided throughout the implementation of the programme of archaeological works. Should the archaeological works reveal the need for post excavation analysis the development hereby approved shall not be occupied or brought into use unless a post-excavation research design (PERD) for the analysis, publication and dissemination of results and archive deposition has been submitted to and approved in writing by the planning authority. The PERD shall be carried out in complete accordance with the approved details. Reason: To safeguard and record the archaeological potential of the area. Any proposed compensatory planting should take account of the historic environment and should follow industry best practice in terms of avoiding damage to heritage assets. Transportation 17. Notwithstanding the submitted details, prior to the commencement of any development, a detailed Phasing Plan, Access Strategy, and detailed Construction Programme for the development shall be submitted to and approved the Council, as Planning Authority in consultation with the Roads Authority. The Phasing Plan, Access Strategy, and detailed Construction Programme shall include the details of all proposed routes for construction traffic and abnormal load deliveries and the locations of all proposed access points on the public road network, along with the timing of works at each location on the cable route. Thereafter, all works shall be completed in accordance with the approved Phasing Plan, Access Strategy and Construction Programme. Reason: In order to ensure that the matters specified can be fully considered prior to the commencement of development. 18. The planning permission hereby granted for the proposed development shall be carried out only in accordance with the approved phasing plan permitted by Condition 16 and the details including detailed drawings (and other supporting information), which shall previously have been submitted to and approved by the Council, as Planning Authority in consultation with the Roads Authority in line with the matters specified for that phase of the development. These drawings and details shall show the matters specified in Condition 19 and 20 below. Page 90
Page 91
Reason: In order that detailed consideration can be given to the matters specified prior to the works commencing on each phase of the development. 19. In pursuance of Condition 17 above, for each phase of the development for which details are to be submitted for approval the required details shall be: (a) Detailed drawings of the proposed access routes for the phase and details of the number and size of construction vehicles using the access routes for that phase of development, including all traffic associated with the extraction of timber to enable the proposed development. (b) Detailed drawings of the improvements required to the public roads utilised by construction traffic and any abnormal load deliveries for the phase, which shall include but not be limited to the provision of new passing places, junction improvements, road widening and edge strengthening, all on ground over which the applicant has or can obtain control at location(s) and constructed in accordance with Moray Council specification. (c) Detailed drawings of the proposed access locations onto the public road for construction vehicles for the phase, including the required visibility splays (including evidence of control of land), access specification and construction details, details of all earthworks and drainage provision and/or drainage diversion, details of proposed fencing/gates, signage and any required temporary traffic management, along with details of reinstatement works for any temporary access. (d) Details of the locations of all overhead cable and haul road crossings within that phase of the development and the proposed works associated with the crossings, including but not limited to, the means of cable crossing, means of access to works areas, details of the haul road crossings and any required temporary traffic management, and details of required reinstatement works. (e) Details of diversion routes for local footpaths during the construction period and associated signage (to be agreed with the Access Manager). (f) A Construction Traffic Management Plan (CMTP), the details of which must include, full details of construction traffic routes from/to the site, parking provision for staff and the loading/unloading, provision for the prevention of material being deposited onto the public road including wheel cleaning and for road sweeping at construction access(es) to the public road, full details of temporary arrangements to safeguard pedestrian/cyclist movements during the construction period, a programme for monitoring and provisions for interim maintenance to be undertaken to ensure safe and suitable access is maintained for the construction access routes for the duration of the works will be required. (g) A ‘Before’ road condition video and joint Contractor/Council road surveys. Thereafter, all works shall be completed in accordance with the approved details and with the Construction Traffic Management Plan. Reason: In order to ensure that the matters specified can be fully considered prior to the commencement and to ensure acceptable infrastructure to enable Page 91
Page 92
access to the development and development that does not create any hazard to road users in the interests of road safety. 20. In pursuance of Condition 18 above for each phase of the development where there is a requirement for Abnormal Load deliveries for which details are to be submitted for approval the required details shall be: (a) A detailed survey of the Abnormal Load delivery route shall be carried out to determine the locations of structures (e.g. bridges) and street furniture affected by any construction and/or abnormal indivisible load vehicle movements. (b) Road improvements/strengthening (either temporary or permanent) required as a result of the survey prior to any movements of any construction and abnormal load traffic shall be completed. (c) Abnormal Load Traffic Management Plan, details of which must include the methods of dealing with large and/or abnormal delivery vehicles, vehicle swept path analysis and the methods of marshalling and manoeuvring at junctions on the public road network. (d) Evidence of the completion of an Abnormal load trial run(s) undertaken for the delivery route. Representatives from the Moray Council Transportation (Traffic), the Trunk Road Authority, Police Scotland, and any other roads authorities where roads will form part of the route of the delivery must be invited to the trial run. Thereafter, all works associated with the Abnormal Load Deliveries shall be completed in accordance with the approved details and the Abnormal Loads delivered in accordance with the Traffic Management Plan. Reason: In order to ensure that the matters specified can be fully considered prior to the commencement and to ensure acceptable infrastructure to enable access to the development and development that does not create any hazard to road users in the interests of road safety. 21. Prior to commencement development on any phase of the development, the following shall be submitted to and approved by the Council, as Planning Authority in consultation with the Roads Authority: (a) Evidence to confirm that a Section 96 ‘Wear and Tear’ Agreement has been completed and agreed by the developer or their representative and the local Roads Authority, including a commitment to the undertaking of joint ‘before’ and ‘after’ road condition surveys, to ensure that the costs or works to repair damage to the public road as a result of construction traffic on the roads identified in Condition 17 will be met. (b) Evidence to confirm that a Road Bond to accompany each Section 96 ‘Wear and Tear’ Agreement has been provided and will be held for the duration of the construction period. Page 92
Page 93
Reason: To ensure that any adverse impact on the condition of the public road, including roadside verges, attributable to the development traffic is identified and ameliorated. 22. At the start and end of each phase (as per Condition 17) ‘before’ and ‘after’ condition video surveys of the proposed delivery and construction traffic routes shall be undertaken jointly with the Roads Authority and a copy of the survey provided to the Planning and Roads Authority. Reason: To ensure that any adverse impact on the condition of the public road, including roadside verges, attributable to the development traffic is identified and ameliorated. Informative Notes Aberdeenshire Council Archaeology Service (on behalf of Moray Council) Delivery of Public Benefit Archaeological mitigation provides an opportunity for the delivery of public benefit. Community engagement can enhance public understanding of, and support for, the historic environment, adding value to both the conditioned archaeological work being undertaken as well as to the development itself. Identifying appropriate community stakeholders (e.g. local schools, heritage groups, community hubs, employability schemes), and undertaking consultation and engagement with them to inform the approach to engagement, should be undertaken early and in advance of the commencement of the programme of archaeological works to ensure that appropriate engagement activities and deliverables can be incorporated effectively. Potential public benefit opportunities should be outlined in the Written Scheme of Investigation (WSI) and be based on ALGAO Scotland’s Delivery of Public Benefit and Social Value Guidance for Archaeology in the Planning Process (2023). The WSI should include how these benefits might be achieved by means of engagement, participation and/or dissemination of the results both during and after the project, as appropriate to the scale, nature, and circumstances of the work. This may vary from a brief social media post for a smaller project to a full-scale community project for larger scale, more complex sites. Delivery of these public benefits, with further expansion or reduction of engagement activities to be undertaken depending on the results of the mitigation, will be further explored at both the Data Structure Report (DSR) stage (within its ‘Recommendations’), and, if required, at the Post-Excavation Research Design (PERD) stage of the archaeological mitigation process. Moray Council – Transportation Manager Prior to the commencement of deliveries or construction activity, a Section 96 Agreement under the Roads (Scotland) Act 1984 will be required to be approved between the developer and the Roads Authority. This is to ensure that the costs to repair Page 93
Page 94
any damage to the public roads as a result of the construction work traffic are met by the applicant. A Road Bond will be required to accompany the Section 96 Agreement. Planning consent does not carry with it the right to construct a new road or any part of a road. In accordance with Section 21 of the Roads (Scotland) Act 1984 Construction Consent for new roads (includes passing places, modified junctions and footpaths) that will form part of the public road will be required. Advice on this matter can be obtained by emailing transport.develop@moray.gov.uk and reference to the following pages on the Council website. Checklist: http://www.moray.gov.uk/downloads/file68812.pdf RCC and Specification: http://www.moray.gov.uk/moray_standard/page_65638.html Before commencing development, the applicant is obliged to apply for permission to modify the existing public road, in accordance with Section 56 of the Roads (Scotland) Act. The applicant will be required to provide technical information, including drawings and drainage calculations, a programme for the proposed works. Advice on the application process can be obtained by emailing transport.develop@moray.gov.uk The applicant is obliged to apply for road opening permit(s) in accordance with Section 85 of the Roads (Scotland) Act 1984. Advice on this matter can be obtained by emailing roads.permits@moray.gov.uk and reference to the following page on the Council website Road Opening: http://www.moray.gov.uk/moray_standard/page_79860.html Public utility apparatus may be affected by this proposal. Contact the appropriate utility service in respect of any necessary utility service alterations, which have to be carried out at the expense of the developer. Based on the Swept Path Analysis, all public road widening to accommodate vehicle overrun areas up to 6m, curve widening areas (more than 6m), widening to provide better two-lane approaches and required improvements to junction turning facilities should be permanent full road construction and only additional widening to be considered as temporary. The submitted AiLs assessments have been prepared using Ordnance Survey (OS) mapping, which is generally not sufficiently accurate in rural areas. Therefore, the SPA drawings must be updated using detailed topographical survey data when discharging the relevant planning conditions to ensure accuracy and reliability. All marginally widening of carriageway should not be less than 1m wide to allow for proper compaction and construction with the formation of a stepped linear joint into carriageway. Page 94
Page 95
As a winter maintenance provider, Moray Council cannot offer special winter maintenance services for public roads that form part of construction traffic routes on behalf of the developer. It can only be assumed that Moray Council have 1 metre of road verge in the rural area. Confirmation of third-party agreement in writing is required for any area of over run, vegetation trimming or fence relocation out with the public road. Local load bearing widening’s which would encourage overrun by others must be made permanent with full road construction and utilised as formal passing places where appropriate. There should be a minimum of 1 metre verge behind any new construction. Road Construction Consent will be required. It is important to clarify how temporary road widenings will be managed both between Abnormal Indivisible Load (AiL) deliveries and throughout the lifetime of the development. This is particularly significant, as other vehicles may begin to use these temporary widening areas, which could lead to rapid deterioration of the surfaces and result in loose material accumulating on the carriageway, posing safety risks. Vegetation should be cleared from the road verge and overhanging bushes to a point one metre back on the road verge and around passing place signs for the duration of the construction period. This is to ensure maximum forward visibility of oncoming vehicles and passing places is maintained in the interest of road safety. At any locations where kerbing is provided as an edge of the existing carriageway, this must be replicated at the edge of any permanent widening. Any permanent widening must consider the impact on road drainage especially additional run off areas. All alterations either permanent or temporary must not be to the detriment of any existing road drainage, which must be retained, relocated or reinstated to the satisfaction of Roads Maintenance on completion of all abnormal traffic movements. Where substantial earthworks are required to accommodate over sail areas, these areas should be considered as permanent earthworks and a minimum verge upstand of 300mm would be required to discourage vehicle overrun. If the carriageway is widened to 6m or wider than 6m in these areas, a 100mm upstand would be sufficient. Signs which are in place for road safety reasons must be socketed, removed as AiL’s approach and reinstated immediately after the vehicles pass. It is not acceptable to overrun central refuge / splitter islands, they are not constructed to take vehicle loadings. Proposals submitted must show how this will be managed during deliveries. It is also not appropriate to remove signing for the duration of the abnormal loads therefore confirmation of how signs will be managed during the delivery phase needs to be agreed. Page 95
Page 96
Some of the side tracks which join the public road may appear to be part of the public road as they have a thin layer of tar on them. It is unlikely that there is suitable road construction under any of them and where they are being utilised each location should be assessed and reconstructed if necessary. Prior to completion of the development, all areas of temporary over-run must be reinstated to an appropriate standard. Example 300mm thick dressed topsoil and reseeded appropriate for the surroundings. Additional details for all areas of road widening and new passing places must also include drainage details to accommodate the additional road surface area. Any street furniture, which will need to be repositioned to enable the development, including deliveries to the development, shall be at the expense of the developer. Furthermore, any existing roadside ditch, which requires relocating, a pipe or culvert shall be agreed in advance of any works commencing at that location. Advice on these matters can be obtained by emailing road.maint@moray.gov.uk The developer shall be responsible for any necessary diversion of any utilities or drainage present at the locations where works are to be undertaken. The developer shall meet all costs of improvements to the road infrastructure, which are required as a result of the development, including any measures to enable the use of structures on the public road for construction traffic and abnormal load deliveries. The developer shall meet all costs of removal and re-erection of road signage, which are required as a result of the delivery of the abnormal loads. The developer shall meet all costs of diverting any footpath or cycleway during the construction period, including signage. The developer shall be responsible for ensuring that surface/ground water does not run from the public road into the site. The developer shall free and relieve the Roads Authority from any claims arising out of his operations on the road or extension to the road. No retaining structures or embankments shall be constructed along the edge of the road, whether retaining the public road or ground adjoining the public road without prior consultation and agreement of the Roads Authority. Advice on the retaining structures/embankments can be obtained by emailing structures@moray.gov.uk The Transportation Manager must always be contacted before any works commence. This includes any temporary access, which should be agreed with the Roads Authority prior to work commencing on it. Page 96
Page 97
Transport Scotland must be consulted regarding all deliveries proposed via the Trunk Road and any proposed access points onto the Trunk Road network. In addition, neighbouring Local Authorities through which the delivery routes may pass should also be consulted as appropriate. Moray Council – Flood Risk Management Towers located within flood plains are susceptible to the accumulation of debris during flood events. It is strongly recommended that any debris be cleared as soon as it is safe to do so following such events. Failure to remove debris promptly may result in increased flood risk due to obstruction of natural water flow across the flood plain. Additionally, large floating debris poses a significant risk of structural damage to towers during flooding. Appropriate maintenance and monitoring procedures should be implemented to mitigate these risks and ensure the resilience of infrastructure within flood-prone areas. Moray Council – Outdoor Access and Countryside Officer When submitting the detailed Outdoor Access Plan, paths at Meikle Balloch and Newmill should be also included (noted these are excluded from the outline plan). Page 97
Page 98
Page 98
Page 99
Plans, drawings and other material submitted to the local authority are protected by the Copyright, Designs and Patents Act 1988 (section 47). You may only use material which is downloaded and/ or printed for consultation purposes, to compare current applications with previous schemes and to check whether developments have been completed in accordance with approved plans. Further copies must not be made without the prior permission of the copyright owner. Maps shown in the Planning Committee Report can only be used for the purposes of the Planning Committee. Any other use risks infringing Crown Copyright and may lead to prosecution or civil proceedings. Maps produced within this Planning Committee Report can only be reproduced with the express permission of the Moray Council and other Copyright holders. This permission must be granted in advance. PLANNING APPLICATION COMMITTEE SITE PLAN Site Address: Beauly To Peterhead Planning Application Ref Number: 25/01364/S37 Applicant Name: Scottish Hydro Electric Transmission PLC APPENDIX 3 Page 99
Page 100
OHL Route - M oray 16/01664/APP Page 100
Page 101
Page 101
Page 102
Page 102
Page 103
Report to: Planning and Regulatory Services Committee Meeting Date: 16 December 2025 Report by: Executive Director Economy, Enterprise and Operations Author: Suzanne Wilson Contact Email: performance@moray.gov.uk Subject: Performance Report (Economic Growth and Development - Planning) – Period to September 2025 1. PURPOSE ☒ For Decision ☐ For Information 1.1 The purpose of this report is to scrutinise performance in areas of Service Planning, Service Performance and other related data to the end of September 2025 and note actions being taken to improve performance where required. 1.2 This report is submitted to Committee in terms of Section III (A) (4) of the Council’s Scheme of Administration to monitor performance in accordance with the Council’s Performance Management Framework. 2. SUMMARY 2.1 At the end of September 2025, the Economic Growth & Development (Planning) 2025-28 Service Plan actions that are reported to this committee were 39% complete. Progress against Service Plan Priorities and Indicators and operational Service Performance Indicators is presented in the table and charts below. Item 6. Page 103
Page 104
3. RECOMMENDATIONS 3.1 It is recommended that Committee scrutinises and notes performance in areas of Service Planning, Service Performance and other related data to the end of September 2025 and note actions being taken to improve performance where required. Suzanne Wilson Research & Information Officer 4. BACKGROUND AND CONTEXT 4.1 Each service plan sets out the planned strategic and service level priorities and outcomes it intends to deliver in the coming year aligning closely with financial planning, corporate and community planning partnership strategic priorities. 4.2 Service Plan actions are weighted to reflect priority ratings. Actions with higher priorities receive greater weightings which contribute more to the overall delivery of the Plan. Progress on Service Plan priorities and outcomes and key areas of operational performance is reported by exception, highlighting successes and giving assurances around the challenges and actions to support. Links to Service Plan Actions, priority ratings and weightings and Performance Indicators can be accessed within the background papers section of this report. 4.3 Complaints are reported in terms of time taken to respond, outcomes and learning points. Links to Complaints tables can be accessed within the background papers section of this report. 4.4 Latest Local Government Benchmarking Framework (LGBF) results for 2024/25 are published throughout the year with final refresh of data around June 2026. The full suite can be viewed via the LGBF Dashboard. Published indicators for Page 104
Page 105
this service have been incorporated with the relevant section of this report depending on whether used to evidence progress against strategic, service level or service performance priorities. LGBF indicator targets and RAG status in the backing tables is now based on ranking thresholds aligning with exception reporting. 4.5 The Sustainable Development Statement was approved by the Corporate Committee on 5 November 2024 (para 16 of the Minute refers). The Statement draws out the way in which sustainable development is embedded in the Corporate Plan 2024-29 and wider corporate policies, strategies, and plans with progress being reported through several updates and reports, one of which is quarter 4 performance reporting. Service Plan actions and indicators that underpin the delivery of Sustainable Development Goals are highlighted in the backing table documents and comment where relevant is incorporated in this report. An overview of progress will be presented in the annual Corporate Plan progress update. 5. PROPOSALS Successes – Service Plan Strategic & Service Level Outcomes and operational Service Performance 5.1 Work to review Developer Obligations Supplementary Guidance is almost complete. Following a peer review with Aberdeenshire Council, a final version of the Guidance is due to be included as an agenda item to this meeting of Committee. (Service Level Action EGD25-28 Serv 5.2.4) 5.2 Latest available data shows continued improvement for building warrants and amendments with 98.84% issued within 20 working days. Those issued within 10 days of receipt of satisfactory information remained at 100%. (Service Performance Indicators ENVDV-BS-KP01(B) and ENVDV-BS-KPO1(C)) 5.3 Good performance is also evident with the increased number of plans responded to rising to 288. At the same time, the average response time decreased to 4.01 days, reflecting improved efficiency. (Service Performance Indicators ENVDV046a and ENVDV046b) Challenges and actions to support – Service Plan Strategic & Service Level Outcomes and operational Service Performance 5.4 Development of an Environmental Health Team Plan is reported at 20% complete against a due date of December 2025. Key performance indicators have been reviewed and relevant plans collated, with work to continue during quarter 3. (Service Level Action EGD25-28 Serv 5.2.5) Complaints and MP/MSP Enquiries 5.5 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. Overall complaint analysis for Page 105
Page 106
Economic Growth and Development is incorporated in half yearly performance reports to the Economic Development and Infrastructure Committee. Detailed complaint tables can be accessed within the Background Papers section of those reports. Other Performance (not included in the Service Plan) 5.6 The Building Standards team were presented with a National Performance Award from the Scottish Government for the first time. Presented at the Building Standards Leaders Forum in Glasgow on the 26 November 2025, this award recognises the Team’s strong performance across all seven national Key Performance Outcomes during the reporting period 2024-25. Case Studies 5.7 Nothing to report. Consultation and Engagement 5.8 Nothing to report. 6. SUMMARY OF IMPLICATIONS 6.1 The table below shows whether risks and implications apply if the recommendations are agreed: SUBJECT YES NO Corporate Plan and 10 Year Plan (Local Outcome Improvement Plan) X Policy and Legal X Financial X Risk X Staffing X Best Value and Transformation X Property X Information Communications Technology/Digital X Equalities. Social Inclusion and Economic Impact X Climate Change and Biodiversity Impact X 6.2 Corporate Plan and 10 Year Plan (Local Outcomes Improvement Plan (LOIP)) Improved Collaborative Leadership, as part of continuous improvement through Best Value, will better enable the Council to fulfil the ambitions set out in its strategic plans. a) Links to Council Corporate Plan – The proposals in this report support and contribute to improved outcomes for communities as outlined in the following Council Plan strategic priorities: ☐ Tackle Poverty and Inequality. ☒ Build Stronger Greener Vibrant Economy. Page 106
Page 107
☐ Build Thriving, resilient, empowered Communities. b) Links to Local Outcomes Improvement Plan – The proposals in this report support and contribute to improved outcomes for communities as outlined in the following local Outcomes Improvement Plan priorities: ☒ Developing a diverse, inclusive, and sustainable economy ☐ Building a better future for our children and young people in Moray. ☐ Empowering and connecting communities. ☐ Improving wellbeing of our population 6.3 Policy and Legal The Council has a statutory requirement to publish a range of information that will demonstrate that it is securing best value and assist in comparing performance both over time and between authorities where appropriate. 6.4 Financial None arising from this report. 6.5 Risk None arising from this report. 6.6 Staffing None arising from this report. 6.7 Best Value and Transformation How councils plan for, manage and report on performance is a key area of focus in external audit work, particularly on best value. 6.8 Property None arising from this report. 6.9 Information Communications/Technology/Digital None arising from this report. 6.10 Equalities, Social Inclusion and Economic Impact None arising from this report. 6.11 Climate Change and Biodiversity Impacts None arising from this report. 7. CONSULTATION 7.1 This report has been prepared in consultation with the Head of Growth, Planning and Climate (Chief Planning Officer) and relevant Service Managers and any comments made have been incorporated. Page 107
Page 108
8. BACKGROUND PAPERS 8.1 Service Plan Actions Service Performance Indicators Page 108
Page 109
Report to: Planning and Regulatory Services Committee Meeting Date: 16 December 2025 Report by: Executive Director Economy, Enterprise and Operations Author: Arooba Muzma Contact Email: Arooba.muzma@gov.moray.uk Subject: Moray Employment Land Audit 2025 1. PURPOSE ☒ For Decision ☐ For Information 1.1 The purpose of this report is to note the employment land supply in Moray and ask the Committee to agree the final version of the Moray Employment Land Audit 2025. 1.2 This report is submitted to Committee in terms of Section III (E) (2) of the Council's Scheme of Administration relating to the review and preparation of Local Development Plans. 2. SUMMARY 2.1 The report provides an overview of the current employment land supply level in Moray and highlights a lack of choice of sites and a shortage of land within Speyside. The Employment Land Audit 2025 is a key tool informing the new Moray Local Development Plan 2027 providing up to date evidence on the availability, quality and take up of employment land. 3. RECOMMENDATIONS 3.1 It is recommended that Committee: i) note the employment land supply in Moray. ii) approve the finalised Moray Employment Land Audit 2025, as set out in Appendix 1 of the report. Author Name: Arooba Muzma Job Title: Planning Officer 4. BACKGROUND AND CONTEXT 4.1 National Planning Framework 4 (NPF4) requires Local Development Plans (LDPs) to allocate sufficient land for business and industry to ensure that there is a suitable range of Item 7. Page 109
Page 110
sites that meet current market demand, location, size, and quality in terms of accessibility and services and that it is reviewed regularly to ensure that there is a sufficient supply to meet national and regional targets. 4.2 The spatial principles within NPF4 seek to support delivery of productive places that have a greener, fairer, and more inclusive wellbeing economy. The intent of Policy 26 Business and Industry is to encourage, promote and facilitate business and industry uses and enable alternative ways of working. NPF4 states LDPs should allocate sufficient land for business and industry, taking into account business and industry land audits, in particular ensuring that there is a suitable range of sites that meet current market demand, location, size and quality in terms of accessibility and services. The Evidence Report for the Moray Local Development Plan 2027 (MLDP2027) identified the land requirements within each market area as well as highlighting the issues around delivery of serviced land and pressure on land for other uses. The Employment Land Audit (ELA) is a key tool in informing the proposed MLDP2027 by providing up-to-date evidence on the availability, quality and take-up of employment land, ensuring that allocations respond to market demand, address delivery challenges, and support a balanced distribution of sites across Moray. 4.3 The Moray Employment Land Audit has three key functions:- • demonstrate the availability of a range and choice of marketable employment sites; • provide an overview of the supply and availability of employment land across the Local Development Plan area; and • provide an evidence base for the monitoring and review of policies and proposals within the LDP. The Employment Land Audit (ELA) is provided in Appendix 1. 4.4 The audit includes four categories of land supply:- Established – This includes all undeveloped land allocated for industrial/business/employment use in the adopted LDP or land that has a valid planning approval for these uses. Marketable/Effective – Land that as well as meeting business requirements, has a secure planning status, can be serviced within 5 years and is accessible by walking, cycling and public transport. Constrained – Land that is not considered developable within 5 years due to issues such as planning difficulties, ownership issues, infrastructure provision and physical constraints. Immediately Available – Land that has planning permission, is serviced and has no major constraints to immediate development. 4.5 As part of the preparation of the audit, discussions were held with Highlands and Islands Enterprise (HIE), Moray Council Estates and agents working within the sector. The draft audit was also made available for consultation on the Council’s website and sent to internal and external consultees however, no comments were received during the consultation period. 5. AUDIT FINDINGS 5.1 The 2025 Audit is provided in full as APPENDIX 1 to the report. The audit identifies that there is 326.55 hectares (ha) of Gross Established Employment Land Supply. This is a Page 110
Page 111
decrease of 3.55ha compared to 2024 due to development at I7 Barmuckity/Elgin Business Park, I2 Chanonry Industrial Estate, I2 Westerton Road South Keith for the Cooperage and use of land for barrel storage at I7 Isla Bank Mills. The main supply of employment land continues to be within the Elgin, Forres and Buckie Market Areas, with a more limited supply in Keith and in Speyside. A summary for each Market Area can be found on page 13 of the Audit. 5.2 108.85 ha (net) of land, across 20 sites, is classed as Marketable/Effective. This is an increase of 10.17 ha compared to 2024. The increase in Marketable/Effective supply is due to land at Easter New Forres I4 being taken out of the constrained supply due to a better understanding of the site conditions and developable area. It should be noted that whilst sites are identified as marketable/effective as set out within the Moray Business Property Needs Study undertaken in 2023 servicing of sites will likely be reliant on externally leveraged public sector intervention. 5.3 The Marketable/Effective supply is split with 72.26ha suitable for general industrial and 36.59 ha suitable for proposals that require a higher amenity setting usually within the class 4 Business category. The Elgin and Buckie market areas have relatively healthy supplies of general industrial land providing at least the equivalent of 15 years supply. In Forres there is limited choice of sites for general industrial land and delivery at I4 Easter New Forres is important to maintain supply. Only a small portion of the BP1 Forres Enterprise Park can accommodate general industrial uses. In Keith the general industrial supply is more limited, however there is a LONG allocation that could be drawn down if there is shortage. There is, and has historically been, a significant shortage of general industrial land in Speyside. This means there is a reliance on windfall proposals to accommodate demand. 5.4 The amount of land Immediately Available is 32.15 ha (net), across 5 sites. The immediately available supply increased by 0.21 ha compared to 2024. This is due to a review of the available supply at Elgin Business Park/Barmuckity. Take up at I7 Elgin Business Park/Barmuckity has been very good as reflected in previous audits. There is now limited availability with many of these plots now developed, sold or under offer. It is therefore anticipated that the level of immediately available land in the Elgin Market Area will reduce over the next few years. 5.5 There continues to be a restricted choice of sites in the Immediately Available Land Supply. This is a particular issue in Forres and Speyside. The availability of Immediately Available land is a Key Measure in the Moray Economic Strategy. To maintain a supply of serviced sites it is necessary to work together with partners towards bringing other sites forward through the LDP process as a failure to do so could inhibit economic growth. 5.6 92.4ha (net) across 16 sites is classed as constrained. This has decreased by 12.27 hectares since the 2024 audit due to the review of I4 Easter New Forres and the use of land within I7 Isla Bank Mills. 48.06ha of land across 5 sites is classed as a LONG designation and would be capable of being bought forward should the need arise as set out within Policy DP3 Long Term Land Reserves within the MLDP 2020. 5.7 3.47ha across 3 sites was completed in the year to 1st January 2025. This includes completion or occupation of sites at I7 Barmuckity, at I2 Chanonry and occupation of land at I7 Isla Bank Mills. This is an increase in construction compared to 2024 where 0.52ha was completed but still lower than 2022 and 2021 (4.68 in 2021 and 4.74ha in 2022). A number of planning applications have been approved over the audit year and it is Page 111
Page 112
anticipated that take up of these will form part of the next audit. 5.8 4.51ha across 4 sites is under construction on the base date of 1st January 2025. This is a similar level of construction activity compared to 2024 (4.3ha) and on the higher end of levels recorded in audits completed since 2015 which ranged from 2.31ha to 5.25ha. It is noted that this does not represent all building activity, and only that on designated sites or windfall sites that are not restricted to a single user. 6. OTHER DEVELOPMENT 6.1 The employment land audit focusses on development within designated LDP sites and any windfall sites unless they are constrained to a single user. Although not highlighted in the audit it is worth noting that several large developments are currently under construction or are proposed on undesignated sites in rural locations which are significant contributors to the economy in Moray. These include a new distillery at Miltonduff and whisky storage at land west of Glenrothes Distillery. There is also significant development pressure around Portgordon in relation to the maltings and the requirement for storage facilities. There is increasingly significant pressure from the energy sector including battery energy storage systems, anaerobic digesters, and development to support the National Grid. This has impacted on some industrial designations and rural areas. This pressure is particularly prevalent in the Keith and Speyside areas but there has been more interest in other towns such as Elgin and Buckie. 6.2 These trends will be monitored through the LDP2020 Monitoring Report with the implications for policy and designations considered in the preparation of the new LDP. 7. SUMMARY OF IMPLICATIONS 7.1 The table below shows whether risks and implications apply if the recommendations are agreed: SUBJECT YES NO Corporate Plan and 10 Year Plan (Local Outcome Improvement Plan) x Policy and Legal x Financial x Risk x Staffing x Best Value and Transformation x Property x Information Communications Technology/Digital x Equalities. Social Inclusion and Economic Impact x Climate Change and Biodiversity Impact x 7.2 Corporate Plan and 10 Year Plan (Local Outcomes Improvement Plan (LOIP)) Improved Collaborative Leadership, as part of continuous improvement through Best Value, will better enable the Council to fulfil the ambitions set out in its strategic plans. a) Links to Council Corporate Plan – The proposals in this report support and contribute to improved outcomes for communities as outlined in the following Council Plan strategic priorities: ☒ Tackle Poverty and Inequality. Page 112
Page 113
☒ Build Stronger Greener Vibrant Economy. ☒ Build Thriving, resilient, empowered Communities. b) Links to Local Outcomes Improvement Plan – The proposals in this report support and contribute to improved outcomes for communities as outlined in the following Local Outcomes Improvement Plan priorities: ☒ Developing a diverse, inclusive, and sustainable economy ☒ Building a better future for our children and young people in Moray. ☐ Empowering and connecting communities. ☐ Improving wellbeing of our population 7.3 Policy and Legal The preparation of the annual Employment Land Audit is a requirement of NPF4 to monitor the effectiveness of the LDP and ensure an effective supply of employment land is maintained. 7.4 Financial None identified at present. One off Costs: Service Area Budget Budget Years Proposed Spend this Year Virement From Other Comments Annually Recurring Costs: Service Area Budget With Effect From Annual Net Impact Virement From (if applicable) Other Comments 7.5 Risk Risk that insufficient provision of effective employment land limits inward investment and expansion opportunities and risks an unplanned approach being taken to development. 7.6 Staffing Preparation of the annual Employment Land Audit is part of the workload of the Strategic Planning and Development section. 7.7 Best Value and Transformation None arising from this report. 7.8 Property The Employment Land Audit includes industrial estates and sites owned by the Council. The Council’s Estates section were consulted on the draft audit. 7.9 Information Communications/Technology/Digital None Page 113
Page 114
7.10 Equalities, Social Inclusion and Economic Impact There are no equalities issues arising from this report as it is to inform the Committee on monitoring of land supply. 7.11 Climate Change and Biodiversity Impacts Moray Development Plan policies seek to ensure that biodiversity is enhanced and all new buildings reduce carbon emissions. Development proposals are required to maximise connections and routes for pedestrians/cyclists including connections to active travel routes thereby reducing carbon emissions associated with vehicles, create green and blue infrastructure and incorporate and enhance biodiversity through planting and other mechanisms. National Planning Framework 4 (NPF4) has introduced national policies to bring significant changes to the planning system including reducing carbon emissions in new development, enhancing biodiversity and a much greater focus on brownfield redevelopment. 8. CONSULTATION 8.1 This report has been prepared in consultation with Executive Director Economy, Enterprise and Operations, the Head of Growth, Planning and Climate (Chief Planning Officer), Service Manager Legal Services, L Rowan, Committee Services Officer, and the Chief Financial Officer and are in agreement with the contents of the report/comments received have been incorporated into the report. 9. BACKGROUND PAPERS 9.1 Page 114
Page 115
Moray Employment Land Audit DRAFT OCTOBER 2025 Page 115
Page 116
For further information, please contact: keith.henderson@moray.gov.uk Page 116
Page 117
Employment Land Audit 2025 1 1. Introduction 1.1 Purpose of Audit The Moray Employment Land Audit provides an overview of the supply and availability of employment land across the Moray Local Development Plan area. The audit is an annual document and includes figures for take up and sites under construction. The audit provides an evidence base for the monitoring and review of policies and proposals included within the Local Development Plan. In addition, it can help to identify areas where further analysis and investigation is required. The baseline against which information is analysed is 1st January 2025. The information contained in the Employment Land Audit will also be of use to businesses, developers, and other organisations with an interest in employment land in Moray. 1.2 Methodology The audit is prepared from information gathered by Council planning officers through monitoring of the development plan, planning approvals and individual inspections. All employment sites in the existing local development plan have been recorded in a data base, unless the site has been built out in its entirety. In addition to sites allocated in the Moray Local Development Plan 2020 any windfall sites with planning consent for employment uses have been added to the database unless these are constrained to a single user (e.g. a distillery). It is noted that land with buildings that are vacant are not included in the audit nor are redeveloped sites. Once sites have been identified officers undertake a review of planning applications and collect information such as ownership, proposed use etc. for each site. Officers also undertake site visits to monitor development activity. This information is then updated in the data base. The data is then analysed to produce the audit report. Page 117
Page 118
2 Employment Land Audit 2025 2. Background 2.1 National Planning Framework 4 (NPF4) NPF4 was adopted on 13 February 2023 and now forms part of local development plans and sets out the Scottish Government’s policies in relation to supporting economic development in Scotland. NPF4 requires LDP’s to allocate sufficient land for business and industry, taking into account business and industry land audits, to ensure that there is a suitable range of sites that meet current market demand, location, size, and quality in terms of accessibility and services. This allocation should take account of local economic strategies and broader objectives of delivering a low carbon and net zero economic recovery, and a fairer and more inclusive economy. NPF4 requires LDP’s to identify suitable sites for business, general industrial and storage and distribution uses and to enable alternative ways of working such as home working, live-work units and micro businesses. The ELA is undertaken annually to monitor the location, size, planning status, existing use, neighbouring land uses and any significant land use issues of sites within the existing business land supply which is fed into the review of the LDP. 2.2 Moray Local Development Plan NPF4 and the Moray Local Development Plan 2020 form the statutory Development Plan for Moray. LDP’s already adopted will continue to be part of the development plan and existing LDP land allocations will be maintained. The Moray Local Development Plan 2020 was adopted on 27 July 2020 and designates land for employment uses within towns. Sites from the 2020 plan were first included in the 2020 audit. The adoption of NPF4 introduces a change to the requirements for Local Development Plans given that there is now a suite of national policies forming part of the Local Development Plan for which planning applications will be determined against. The Moray Local Development Plan 2020 already sets out the employment land policies for the Planning Authority (excluding the Cairngorms National Park area) related to economic development. These seek to safeguard employment land and support development of employment uses on designated sites. The policies also look at the types of uses that will be supported on designated sites. A more flexible approach to rural business proposals is provided for, with policy criteria used to ensure the most appropriate locations are supported in rural areas. Page 118
Page 119
Employment Land Audit 2025 3 2.3 Moray Economic Strategy and Moray Economic Partnership The Moray Economic Strategy was published in November 2022. The strategy takes account of changes in the economic landscape since 2012. The strategy is for the period 2022-2032 and maintains the overall objective to grow and diversify the economy and focuses on achieving four outcomes, one of which is supporting the economy through the provision of employment land for businesses of all sizes to locate. The Moray Economic Partnership aim to support and diversify the economy by delivering early economic activity that is aligned to the aims of the Moray Economic Strategy. 2.4 Moray 10 Year Plan - Local Outcome Improvement Plan (LOIP) One of four priorities within the Moray Community Planning Partnership Local Outcomes Improvement Plan is “Developing a diverse, inclusive and sustainable economy.” Whilst employment land supply is not a performance indicator within the Local Outcomes Improvements Plan land supply is important for achieving outcomes. 2.5 Demand for Employment Land Discussions with Moray Council Estates, Highlands and Islands Enterprise (HIE) and local agents indicate that, while overall market activity is steady, demand is most evident for smaller sites and units, with enquiries “ticking over” at a consistent rate. This reflects the needs of small local businesses such as trades, plant hire, and service firms, as well as contractors seeking temporary yard, compound and laydown space linked to major infrastructure works, including ongoing powerline upgrades. High construction costs combined with limited rental growth continue to suppress speculative development and private sector investment. There is a general view that assistance will be required across Moray to open up serviced land and create viable development opportunities, particularly in locations where immediate supply is constrained. In sectoral terms, demand from the whisky industry, which has driven significant expansion in recent years appears to have slowed in the short term, although further growth is possible over the medium term given the sector’s long-term importance to Moray’s economy. Other key sectors expected to influence future demand include engineering, technology, and advanced manufacturing. Potential future influences on the market include the impacts of the emerging Green Freeport designation. While there is a perception that adequate land exists within the designated area itself, any “downstream” demand for supply chain sites in Moray, particularly the west of the region, may take time to materialise. The eventual route of the A96 dualling will also be a significant consideration when identifying and safeguarding future employment sites. Overall, while enquiries for large-scale sites remain limited, there is an ongoing need for a range of site sizes and building types to ensure that both local growth and inward investment opportunities can be accommodated. Unlocking strategic and serviced land across the region will be key to meeting identified demand and supporting the ambitions of the Moray Economic Strategy. Page 119
Page 120
4 Employment Land Audit 2025 3. Employment Land Supply Several categories of land supply are identified in the audit. Definitions for these are provided in section 5. Detailed information of the established, constrained, effective and immediately available sites is provided in Appendix 2. 3.1 Established Employment Land Supply The established employment land supply for Moray is shown in figure 1. There has been a decrease in the gross established supply by 3.55 ha since 2024. This decrease is due to development at I7 Barmuckity/Elgin Business Park, I2 Chanonry Industrial Estate, I2 Westerton Road South Keith for the Cooperage and use of land for barrel storage at I7 Isla Bank Mills. Figure 1 Established Employment Land Supply (2025) (Figures in hectares) Gross Established Net Established Number of Sites 326.55 249.86 36 Page 120
Page 121
Employment Land Audit 2025 5 The established employment land supply is broken down in figure 2 by market area. Figure 2 Established Employment Land Supply by town (2025) (Figures in hectares) Town Gross Established Net Established Number of Sites Elgin Market Area 201.37 154.78 19 Elgin 123.52 93.49 11 Lossiemouth 12.8 10.24 1 Mosstodloch 63.44 49.95 6 Troves 1.61 1.1 1 Forres 55.48 36.34 4 Buckie Market Area 43.96 37.46 6 Buckie 43.15 36.81 5 Cullen 0.81 0.65 1 Keith 7.69 6.64 4 Speyside Market Area 18.05 14.64 3 Aberlour 1 1 1 Rothes 17.05 13.64 2 ELGIN MARKET AREA -There has been a small decrease in the established supply within the Elgin Market area compared to 2024 (0.66ha to the gross supply and 0.66ha to the net supply). This is as a result of development at I7 Barmuckity/Elgin Business Park and at Chanonry Industrial Estate. FORRES MARKET AREA - There has been no change to the gross established supply in Forres Market Areas compared to 2024, but there has been a small increase in the net established area by 1.57 ha following review of the I4 Easter New Forres site. BUCKIE MARKET AREA - There has been no change to the established supply in the Buckie Market Areas compared to 2024. KEITH MARKET AREA - There has been a decrease of 2.89ha of the gross and 2.48ha of the net supply due to construction of the new Cooperage and use of land at Isla Bank Mills. SPEYSIDE MARKET AREA - There has been no change to the established supply in the Speyside Market Areas compared to 2024. Page 121
Page 122
6 Employment Land Audit 2025 \ The established employment land supply has also been broken down by size of site to provide an indication of the range of size of sites available. Figure 3: Established Employment Land Supply by site size (2025) (Figures in hectares) Site area Net Established Number of Sites 0 - 1ha 5.23 7 1 - 5 ha 23.72 12 >5 ha 220.91 17 The land supply is broken down by the type of employment uses that are considered suitable on the site. The greatest proportion of land is suitable for Class 5 General Industrial uses and also Class 4 Business and Class 6 Storage and Distribution. On some designations the whole area may be capable of accommodating higher amenity or a greater mix of uses but on some designations distinct areas within a site are identified. These tend to be uses within Class 4 that require a higher amenity setting or due to the location close to residential development general industrial uses would not be suitable. On some larger sites a greater mix of uses (for example Class 1 Shops where ancillary to main use, Class 4 Business, Class 5 General Industrial, Class 6 Storage or Distribution, Class 7 Hotel and Hostels and Use Class 11 Assembly and Leisure) are identified on part of the site to help support delivery of the site as a whole. A breakdown of the type of sites is shown in figures 4 and 5 below. It is noted that some sites will be counted in both the General Industrial and High Amenity figures as on larger sites part of the site may be identified for a greater mix of uses. Figure 4: Net supply by type (2025). Figures in hectares Net Area Number of Sites General Industrial 194.55 30 High Amenity 55.16 11 Page 122
Page 123
Employment Land Audit 2025 7 Figure 5: Net supply by Market Area and type (2025). Figures in hectares Market Area General Industrial Number of Sites High Amenity Number of Sites Elgin 119.51 17 35.12 6 Elgin 63.34 9 30 5 Lossiemouth 5.12 1 5.12 1 Mosstodloch 49.95 6 Troves 1.1 1 Forres 26.07 4 10.27 1 Buckie 30.44 4 7.02 2 Buckie 30.44 4 6.37 1 Cullen 0.65 1 Keith 4.89 3 1.75 2 Speyside 13.64 2 1 1 Aberlour 1 1 Rothes 13.64 2 3.2 Marketable/Effective Employment Land Supply The marketable and effective employment land supply in 2025 is shown in figure 6. Overall the marketable/effective area has increased by 10.17 hectares compared to 2024. The increase in effective supply is due to land at Easter New Forres I4 being taken out of the constrained supply due to a better understanding of the site conditions and developable area. Figure 6: Marketable/Effective Employment Land Supply (2025) Marketable/Effective (Net figure in hectares) Number of Sites 108.85 20 Page 123
Page 124
8 Employment Land Audit 2025 The marketable/effective employment land supply has been broken down by market area in figure 7. Annual requirements established through historic demand studies, build out rates recorded in previous audits, and from discussions with HIE and Moray Council Estates have been used to provide the estimated number of years supply available. It is noted that previously it was desirable to have a five year effective land supply at all times and therefore previous Local Development Plans sought to designate a minimum of 10 year land supply. However, to ensure a generous supply, increase choice and the prospect of a 10 year replacement period for future Local Development Plans, the Moray Local Development Plan 2020 sought to designate a minimum of 15 years supply. Figure 7 Marketable/Effective Employment Land Supply by market area (2025) Market Area Marketable/ Number Estimated Available Supply Effective (Net of Sites Annual in years figure in hectares) Requirements Elgin 56.75 10 2.8 20 years Forres 25.02 2 0.8 31 years Buckie 22.34 4 0.8 28 years Keith 3.14 2 0.4 8 years Speyside 1.6 2 0.4 4 years The level of effective supply in Elgin, Buckie and Forres is currently good. However, the choice of sites is limited across all market areas. It is noted that within in Elgin there are only small areas now available within I6 Linkwood East and I2 Chanonry. The level of interest and recent planning applications at I7 Barmuckity also suggests availability will be limited in the future as these applications build out. In Forres whilst there is a good supply of land this is either at BP1 Forres Enterprise Park or I4 Easter New Forres. Whilst Keith has less than 8 years supply there is a LONG allocation that could be brought forward, however there is a limited choice of sites in Keith with these primarily being in the Westerton Road area. There is a shortage of sites in Speyside and finding suitable sites has been an ongoing issue. Removal of a site in the Examination of the 2020 Local Development Plan means there will be a reliance on windfall proposals within this area. The effective land supply is broken down by the type of employment uses that are considered suitable on the site. The greatest proportion of land is suitable for Class 5 General Industrial uses (and also Class 4 Business and Class 6 Storage or Distribution). As set out above some sites are wholly or have areas that would be capable of accommodating higher amenity uses or a greater mix of uses. These tend to be uses within Class 4 that require a higher amenity setting or due to the location of the site close to residential development general industrial uses would not be suitable. On some larger sites areas that could accommodate a greater mix of uses (for example Class 1 Shops where ancillary to main use, Class 4 Business, Class 5 General Industrial, Class 6 Storage or Distribution, Class 7 Hotel and Hostels Page 124
Page 125
Employment Land Audit 2025 9 and Use Class 11 Assembly and Leisure) are identified to help support delivery of the site as a whole. A breakdown of the type of sites is shown in figures 8 and 9 below. It is noted that some sites will be counted in both the General Industrial and High Amenity figures as on larger sites part of the site may be identified for a greater mix of uses. Figure 8: Effective area by type (2025) Figures in hectares. Effective Area Number of Sites General Industrial 72.26 15 High Amenity 36.59 8 Figure 9: Effective area by Market Area and type (2025). Figures in hectares. Market Area General Industrial Number of Sites High Amenity Number of Sites Elgin 40.2 9 16.55 3 Elgin 26.3 7 16.55 3 Mosstodloch 12.8 1 Troves 1.1 1 Forres 14.75 2 10.27 1 Buckie 15.32 2 7.02 2 Buckie 15.32 2 6.37 1 Cullen 0.65 1 Keith 1.39 1 1.75 1 Speyside 0.6 1 1 1 Aberlour 1 1 Rothes 0.6 1 The Elgin and Buckie market areas have relatively healthy supplies of general industrial land providing the equivalent of around 15 years supply. In Forres there is limited choice of site for general industrial land and delivery at I4 Easter New Forres is important to maintain supply. Only a small portion of the BP1 Forres Enterprise Park can accommodate general industrial uses. In Keith the general industrial supply is more limited however there is a LONG allocation that could be drawn down if there is shortage. There is, and has historically been, a significant shortage of general industrial land in Speyside. This means there is a reliance on windfall proposals to accommodate demand. Page 125
Page 126
10 Employment Land Audit 2025 3.3 Immediately Available The immediately available employment land supply in 2025 is shown in figure 10. The immediately available supply increased by 0.21 ha compared to 2024. This is due to a review of the available supply at Elgin Business Park/Barmuckity. Figure 10: Immediately available Employment Land Supply (2025) Immediately Available (Net figure in hectares) Number of Sites 32.15 5 3.4 LONG The Moray Local Development Plan 2020 included LONG employment sites for the first time. The LONG supply is set out in figure 11 below. These sites set out the direction of growth and assist in forward planning. LONG sites are designated at LONG3 Burnside of Birnie Elgin, LONG MU1 South of the A96, LONG 2 West of Mosstodloch, LONG 2 Westerton Road Keith and LONG2 March Road. Figure 11: LONG sites 2025 LONG (Net figure in hectares) Number of Sites 48.06 5 3.5 Constrained The established land supply that is subject to constraints is shown in figure 12. This has decreased by 12.27 hectares since the 2024 audit this is due to the review of I4 Easter New Forres and the use of land within I7 Isla Bank Mills. Page 126
Page 127
Employment Land Audit 2025 11 Figure 12: Constrained Employment Land Supply (2025) Constrained Supply (Net figure in hectares) Number of Sites 92.4 16 The constrained supply can be broken down into the type of constraints identified. Figure 13: Constrained Employment Land Supply by constraint (2025) (Net figures in hectares) Note some land may fall under more than one constraint. Constraint Type Constrained Supply Number of Sites Infrastructure 35.32 8 Ownership 40.79 6 Physical 49.71 10 3.6 Take up and Construction The number and area of proposals completed in the year to 1st January 2025 is shown in figure 14 below. This includes completion or occupation of sites at I7 Barmuckity, at I2 Chanonry and occupation of land at I7 Isla Bank Mills. This is an increase in construction compared to 2024 where 0.52ha was completed but still lower than 2022 and 2021 (4.68 in 2021 and 4.74ha in 2022). A number of planning applications have been approved over the audit year and it is anticipated that take up of these will form part of the next audit. Figure 14 Employment land completed/taken up in year to 1st January 2025 Take up area (Gross figure in hectares) Number of Sites 3.47 3 The number and area of proposals under construction on the base date of 1st January 2025 is shown in figure 15 below. This is a similar level of construction activity compared to 2024 (4.3ha) and on the higher end of levels recorded in audits completed since 2015 which ranged from 2.31ha to 5.25ha. Page 127
Page 128
12 Employment Land Audit 2025 Figure 15: Employment land under construction at 1st January 2025 Under Construction (Gross figure in hectares) Number of Sites 4.51 4 It is noted that this does not represent all building activity, and only that on designated sites or windfall sites that are not restricted to a single user. Other notable areas of activity primarily relate to expansion proposals of existing businesses, sites in the countryside and expansion of distilleries. 4. Conclusion The Employment Land Audit has been carried out in this format for several years allowing comparison to be made to previous audits. It is clear that the emphasis on employment land continues to be within the main settlements of Elgin, Forres, Buckie and Keith. However, Mosstodloch is also the focus of a large proportion of the supply in the Elgin Market Area. The delivery of sites for general industrial use in Forres is necessary. There is a significant shortage of land and sites within the Speyside Market Areas which means there is a reliance on windfall sites to accommodate demand. Around 37% (92 ha) of the Established Supply has some form of constraint that is likely to prevent the land being brought forward in the next five years and this is a slight increase from 2024. There continues to be a limited choice of serviced sites/immediately available sites across all settlements with only 5 sites being classed in this category. A number of consents were approved on identified sites in 2023 and 2024 along with a number of sites which are now deemed to be under construction. It is anticipated that several of these will be implemented and brought forward which will be reflected in next year’s ELA. The availability of Immediately Available employment land is a Key Measure in the Moray Economic Strategy and will be a focus for the next Moray Local Development Plan. In figure 16 below is a summary by market area. Page 128
Page 129
Employment Land Audit 2025 13 Elgin (including Lossiemouth and Mosstodloch) Forres Development at Barmuckity/Elgin Business Park (I7) is progressing with several plots now completed and others currently under construction. There continues to be significant interest in the remaining plots, including some of the larger plots. The high levels of take up at Elgin Business Park/Barmuckity (I7) suggest the level of Immediately Available land will reduce significantly over the next few years and therefore bringing new sites forward and servicing these is critical to maintaining a supply of serviced sites. At Chanonry (I2) and Linkwood East (I6) there are small areas of immediately available land but this has reduced to only a couple of small plots on each site available. Land at Chanonry is understood to be under offer. At Chanonry there is a private development of 18 starter units that have been built and is now largely occupied. At OPP4 Ashgrove three general industrial and storage and distribution buildings (including ancillary trade counters) have been built and occupied. Bringing forward other sites within Elgin will be critical to maintaining a choice of immediately available sites. To the north of Elgin Newfield (I8) is being actively marketed increasing choice of sites across Elgin. Land has been identified at Burnside of Birnie (I16/LONG3) to meet future demand. Choice of sites is severely restricted in Lossiemouth, only Sunbank OPP1 or windfall opportunities are available. The topography and ground conditions at Sunbank OPP1 are considered to constrain the site. In Mosstodloch additional land is identified at I3 West of Mosstodloch and there are discussions ongoing with the landowner regarding the site. There are issues with delivery of higher quality business land. Strong demand continues for industrial buildings. Very small choice of marketable/effective sites given settlement size and population, but reasonable areas available at the BP1 Enterprise Park. I4 Easter Newforres is understood to have high infrastructure costs that will likely require public sector funding support to make this site effective. There is continued interest in sites at BP1 Enterprise Park. HIE are looking to implement the consent they have for two small business units in the northwest of BP1. Figure 16 Market Area Summary Page 129
Page 130
14 Employment Land Audit 2025 The remaining land at Waterford (I2) is constrained due to restricted access. Strong demand, particularly for smaller units and need for serviced employment land to allow businesses to develop and relocate from smaller units. Small choice of marketable sites but reasonable areas available. Significant area immediately available at I3 Rathven Industrial Estate. Redevelopment opportunities at harbour, as identified in the Buckie Harbour Masterplan. Small site available at Cullen. The Moray Local Development Plan identifies a reserve of industrial land at March Road (LONG2) that could be brought forward if need arose. Very small choice of marketable sites focussed around the Westerton Road area. Issues with providing readily accessible employment sites. Demand for smaller units but greatest demand is currently for battery storage and development linked to Blackhillock, where the Keith Green Energy and Infrastructure Framework has now been completed. A cooperage including office staff facilities storage yard and associated works was approved on the I4 Bridge Street designation. The development has commenced. Opportunities for higher amenity employment uses promoted within a mixed use site to the south of Banff Road (MU). Severely limited choice of designated sites. There is a need for sites for small local businesses in Speyside. The Moray Local Development Plan 2020 identifies a site at Speyview (R2) where 1ha of the housing site is identified for employment uses. The removal of a site during the Examination of the Moray Local Development Plan 2020 means there is a reliance on windfall proposals supported through policy. Growth in the whisky sector has resulted in demand for significant storage facilities which given the lack of designated land has resulted in significant unplanned development on windfall sites. Identification of larger sites to meet future demand of this type would allow for a planned approach to be taken. Forres Buckie Keith Speyside Page 130
Page 131
Employment Land Audit 2025 15 5. Glossary Constrained Employment Land Supply This includes land for example, that has planning difficulties, land subject to ownership difficulties (e.g. multiple ownership/unwilling sellers), land with insufficient infrastructure provision, etc. This category therefore includes much of the land in the Established Employment Land Supply that is not Marketable (see below). Employment Land This includes land for general industrial and business/office use, storage and distribution uses, business parks and specialist technology parks including research and development uses. This comprises Classes 4 (Business), 5 (General Industrial) and 6 (Storage or Distribution) of the 1997 Town and Country Planning (Use Classes) (Scotland) Order, but is not exclusive to these uses. Established Employment Land Supply This includes all undeveloped land that is allocated for industrial/business/ employment use in the adopted Local Plan or has a valid planning approval for these uses. Gross This refers to the total area in (hectares) within the boundary of the site. Immediately Available Land Supply This is marketable/effective land that currently has planning permission, is serviced and has no other major constraints to immediate development. This definition is useful in the assessment of whether demand for land is being adequately met. Marketable/Effective Land Supply This is land that as well as meeting business requirements, has a secure planning status, can be serviced within 5 years, is accessible by walking, cycling and public transport as defined by SPP. Land that is subject to user restrictions or that is held as ‘option land’ for existing companies’ own expansion cannot be considered to be marketable. Such land is not constrained. Net The total area of land excluding roads, landscaping etc. As the physical attributes of a site and surrounding land uses will determine the area suitable for development and the level of landscaping required the net area will vary. For sites that are partially complete, the net area given is the area that is actually available to be developed. For sites that are undeveloped the net area is estimated. This estimate is based on an assumption that on average, 20% of available land will be taken up with roads, landscaping etc. If relevant site information is available, this is taken into account in the estimate. Take-Up The take up figure includes all proposals where development has been completed within the particular year. Under Construction This is the area of land under construction at the base date. These sites are not yet complete. The area under construction area is not included within the land supply or built totals. Page 131
Page 132
The Moray Council Employment Land Audit2025 Reference: M/AB/E/005 Location: Speyview Grid Ref: 325631 841602 Supply Type: Effective Constrained Owner Infrastructure Physical Town: ABERLOUR Effective Supply (Ha): Effective: 1 Immediately Available: 0 LPR: 20/R2 LONG Supply (Ha): Constrained Total (Ha): 0 Established Supply (Ha): Gross Established: 1 Net Established: 1 Development (Ha): Built: 0 Under Construction: 0 LONG: 0 General Industrial: 0 High Amenity: 1 Reference: M/BC/E/001 Location: High Street (W) Grid Ref: 342942 864437 Supply Type: Effective Constrained Owner Infrastructure Physical Town: BUCKIE Effective Supply (Ha): Effective: 6.37 Immediately Available: 0 LPR: 20/MU LONG Supply (Ha): Constrained Total (Ha): 0 Established Supply (Ha): Gross Established: 6.37 Net Established: 6.37 Development (Ha): Built: 0 Under Construction: 0 LONG: 0 General Industrial: 0 High Amenity: 6.37 Page 132
Page 133
The Moray Council Employment Land Audit2025 Reference: M/BC/E/004 Location: March Road (SE) Grid Ref: 343984 865510 Supply Type: Effective Constrained Owner Infrastructure Physical Town: BUCKIE Effective Supply (Ha): Effective: 14.55 Immediately Available: 7.95 LPR: 20/I3 LONG Supply (Ha): Constrained Total (Ha): 0 Established Supply (Ha): Gross Established: 17.69 Net Established: 14.55 Development (Ha): Built: 3.14 Under Construction: 0 LONG: 0 General Industrial: 14.55 High Amenity: 0 Reference: M/BC/E/005 Location: Maltings Grid Ref: 343676 865357 Supply Type: Constrained Constrained Owner Infrastructure Physical Town: BUCKIE Effective Supply (Ha): Effective: 0 Immediately Available: 0 LPR: 20/I4 LONG Supply (Ha): Constrained Total (Ha): 8.5 Established Supply (Ha): Gross Established: 10.3 Net Established: 8.5 Development (Ha): Built: 5.96 Under Construction: 0 LONG: 0 General Industrial: 0 High Amenity: 0 Page 133
Page 134
The Moray Council Employment Land Audit2025 Reference: M/BC/E/006 Location: The Harbour Area Grid Ref: 343086 865957 Supply Type: Part Constrained Constrained Owner Infrastructure Physical Town: BUCKIE Effective Supply (Ha): Effective: 0.77 Immediately Available: 0 LPR: 20/I5 LONG Supply (Ha): Constrained Total (Ha): 1 Established Supply (Ha): Gross Established: 1.77 Net Established: 1.77 Development (Ha): Built: 20.97 Under Construction: 0 LONG: 0 General Industrial: 0.77 High Amenity: 0 Reference: M/BC/E/007 Location: March Road (LONG) Grid Ref: 344222 865018 Supply Type: Effective 5years+ Constrained Owner Infrastructure Physical Town: BUCKIE Effective Supply (Ha): Effective: 0 Immediately Available: 0 LPR: 20/LNG2 LONG Supply (Ha): Constrained Total (Ha): 0 Established Supply (Ha): Gross Established: 7.02 Net Established: 5.62 Development (Ha): Built: 0 Under Construction: 0 LONG: 5.62 General Industrial: 0 High Amenity: 0 Page 134
Page 135
The Moray Council Employment Land Audit2025 Reference: M/CL/E/002 Location: South of Cemetery Grid Ref: 351482 866184 Supply Type: Effective Constrained Owner Infrastructure Physical Town: CULLEN Effective Supply (Ha): Effective: 0.65 Immediately Available: 0 LPR: 20/I1 LONG Supply (Ha): Constrained Total (Ha): 0 Established Supply (Ha): Gross Established: 0.81 Net Established: 0.65 Development (Ha): Built: 0 Under Construction: 0 LONG: 0 General Industrial: 0 High Amenity: 0.65 Reference: M/EL/E/001 Location: Elgin Business Park, Barmuckity Grid Ref: 324719 861725 Supply Type: Part Constrained Constrained Owner Infrastructure Physical Town: ELGIN Effective Supply (Ha): Effective: 15.63 Immediately Available: 9.34 LPR: 20/I7 LONG Supply (Ha): Constrained Total (Ha): 5.86 Established Supply (Ha): Gross Established: 32.57 Net Established: 21.02 Development (Ha): Built: 2.9 Under Construction: 1.56 LONG: 0 General Industrial: 9.68 High Amenity: 5.95 Page 135
Page 136
The Moray Council Employment Land Audit2025 Reference: M/EL/E/002 Location: Riverview Grid Ref: 319633 862782 Supply Type: Constrained Constrained Owner Infrastructure Physical Town: ELGIN Effective Supply (Ha): Effective: 0 Immediately Available: 0 LPR: 20/MU1 LONG Supply (Ha): Constrained Total (Ha): 3.3 Established Supply (Ha): Gross Established: 4.12 Net Established: 3.3 Development (Ha): Built: 0 Under Construction: 0 LONG: 0 General Industrial: 0 High Amenity: 0 Reference: M/EL/E/004 Location: Glen Moray Distillery Grid Ref: 319932 862424 Supply Type: Constrained Constrained Owner Infrastructure Physical Town: ELGIN Effective Supply (Ha): Effective: 0 Immediately Available: 0 LPR: 20/I12 LONG Supply (Ha): Constrained Total (Ha): 1.3 Established Supply (Ha): Gross Established: 1.3 Net Established: 1.3 Development (Ha): Built: 6.5 Under Construction: 0 LONG: 0 General Industrial: 0 High Amenity: 0 Page 136
Page 137
The Moray Council Employment Land Audit2025 Reference: M/EL/E/008 Location: Chanonry Industrial Estate Grid Ref: 323161 862960 Supply Type: Part Constrained Constrained Owner Infrastructure Physical Town: ELGIN Effective Supply (Ha): Effective: 0.44 Immediately Available: 0.44 LPR: 20/I2 LONG Supply (Ha): Constrained Total (Ha): 1.22 Established Supply (Ha): Gross Established: 2.94 Net Established: 1.66 Development (Ha): Built: 10.36 Under Construction: 0 LONG: 0 General Industrial: 0.44 High Amenity: 0 Reference: M/EL/E/011 Location: Pinefield Industrial Estate Grid Ref: 322991 862330 Supply Type: Effective Constrained Owner Infrastructure Physical Town: ELGIN Effective Supply (Ha): Effective: 0.18 Immediately Available: 0 LPR: 20/I5 LONG Supply (Ha): Constrained Total (Ha): 0 Established Supply (Ha): Gross Established: 0.18 Net Established: 0.18 Development (Ha): Built: 12.23 Under Construction: 0 LONG: 0 General Industrial: 0.18 High Amenity: 0 Page 137
Page 138
The Moray Council Employment Land Audit2025 Reference: M/EL/E/012 Location: Linkwood East Grid Ref: 323707 862498 Supply Type: Effective Constrained Owner Infrastructure Physical Town: ELGIN Effective Supply (Ha): Effective: 1.4 Immediately Available: 1.4 LPR: 20/I6 LONG Supply (Ha): Constrained Total (Ha): 0 Established Supply (Ha): Gross Established: 1.71 Net Established: 1.4 Development (Ha): Built: 2.01 Under Construction: 0 LONG: 0 General Industrial: 1.4 High Amenity: 0 Reference: M/EL/E/016 Location: Newfield Grid Ref: 321907 864903 Supply Type: Effective Constrained Owner Infrastructure Physical Town: ELGIN Effective Supply (Ha): Effective: 9.6 Immediately Available: 0 LPR: 20/I8 LONG Supply (Ha): Constrained Total (Ha): 0 Established Supply (Ha): Gross Established: 12 Net Established: 9.6 Development (Ha): Built: 0 Under Construction: 0 LONG: 0 General Industrial: 9.6 High Amenity: 0 Page 138
Page 139
The Moray Council Employment Land Audit2025 Reference: M/EL/E/017 Location: Burnside of Birnie Grid Ref: 322206 859613 Supply Type: Part Constrained Constrained Owner Infrastructure Physical Town: ELGIN Effective Supply (Ha): Effective: 9 Immediately Available: 0 LPR: 20/I16 LONG Supply (Ha): Constrained Total (Ha): 8.87 Established Supply (Ha): Gross Established: 22.3 Net Established: 17.87 Development (Ha): Built: 0 Under Construction: 0 LONG: 0 General Industrial: 4 High Amenity: 5 Reference: M/EL/E/018 Location: Burnside of Birnie (LONG) Grid Ref: 322279 859158 Supply Type: Part Constrained Constrained Owner Infrastructure Physical Town: ELGIN Effective Supply (Ha): Effective: 0 Immediately Available: 0 LPR: 20/LNG3 LONG Supply (Ha): Constrained Total (Ha): 9.8 Established Supply (Ha): Gross Established: 38.2 Net Established: 30.56 Development (Ha): Built: 0 Under Construction: 0 LONG: 20.74 General Industrial: 0 High Amenity: 0 Page 139
Page 140
The Moray Council Employment Land Audit2025 Reference: M/EL/E/019 Location: Lossiemouth Road (NE) Grid Ref: 321871 865361 Supply Type: Effective Constrained Owner Infrastructure Physical Town: ELGIN Effective Supply (Ha): Effective: 5.6 Immediately Available: 0 LPR: 20/MU2 LONG Supply (Ha): Constrained Total (Ha): 0 Established Supply (Ha): Gross Established: 7 Net Established: 5.6 Development (Ha): Built: 0 Under Construction: 0 LONG: 0 General Industrial: 0 High Amenity: 5.6 Reference: M/EL/E/020 Location: Ashgrove Road (Yard) Grid Ref: 322589 862554 Supply Type: Effective Constrained Owner Infrastructure Physical Town: ELGIN Effective Supply (Ha): Effective: 1 Immediately Available: 0 LPR: 20/OPP4 LONG Supply (Ha): Constrained Total (Ha): 0 Established Supply (Ha): Gross Established: 1.2 Net Established: 1 Development (Ha): Built: 0 Under Construction: 0 LONG: 0 General Industrial: 1 High Amenity: 0 Page 140
Page 141
The Moray Council Employment Land Audit2025 Reference: M/FR/E/001 Location: Forres Enterprise Park Grid Ref: 306378 859307 Supply Type: Effective Constrained Owner Infrastructure Physical Town: FORRES Effective Supply (Ha): Effective: 13.02 Immediately Available: 13.02 LPR: 20/BP1 LONG Supply (Ha): Constrained Total (Ha): 0 Established Supply (Ha): Gross Established: 22.88 Net Established: 13.02 Development (Ha): Built: 17.92 Under Construction: 0.16 LONG: 0 General Industrial: 2.75 High Amenity: 10.27 Reference: M/FR/E/006 Location: Benromach Distillery Grid Ref: 303187 859423 Supply Type: Constrained Constrained Owner Infrastructure Physical Town: FORRES Effective Supply (Ha): Effective: 0 Immediately Available: 0 LPR: 20/I3 LONG Supply (Ha): Constrained Total (Ha): 3.2 Established Supply (Ha): Gross Established: 4 Net Established: 3.2 Development (Ha): Built: 4 Under Construction: 1.3 LONG: 0 General Industrial: 0 High Amenity: 0 Page 141
Page 142
The Moray Council Employment Land Audit2025 Reference: M/FR/E/013 Location: Waterford Grid Ref: 303151 859195 Supply Type: Constrained Constrained Owner Infrastructure Physical Town: FORRES Effective Supply (Ha): Effective: 0 Immediately Available: 0 LPR: 20/I2 LONG Supply (Ha): Constrained Total (Ha): 0.8 Established Supply (Ha): Gross Established: 1 Net Established: 0.8 Development (Ha): Built: 6.2 Under Construction: 0 LONG: 0 General Industrial: 0 High Amenity: 0 Reference: M/FR/E/014 Location: Easter Newforres Grid Ref: 306670 859033 Supply Type: Effective Constrained Owner Infrastructure Physical Town: FORRES Effective Supply (Ha): Effective: 12 Immediately Available: 0 LPR: 20/I4 LONG Supply (Ha): Constrained Total (Ha): 7.32 Established Supply (Ha): Gross Established: 27.6 Net Established: 19.32 Development (Ha): Built: 0 Under Construction: 0 LONG: 0 General Industrial: 12 High Amenity: 0 Page 142
Page 143
The Moray Council Employment Land Audit2025 Reference: M/KH/E/004 Location: Bridge Street Grid Ref: 343609 850228 Supply Type: Effective Constrained Owner Infrastructure Physical Town: KEITH Effective Supply (Ha): Effective: 0 Immediately Available: 0 LPR: 20/I4 LONG Supply (Ha): Constrained Total (Ha): 1 Established Supply (Ha): Gross Established: 1 Net Established: 1 Development (Ha): Built: 1.72 Under Construction: 0.97 LONG: 0 General Industrial: 0 High Amenity: 0 Reference: M/KH/E/011 Location: Westerton Road East Expansion Grid Ref: 343761 850329 Supply Type: Effective Constrained Owner Infrastructure Physical Town: KEITH Effective Supply (Ha): Effective: 1.39 Immediately Available: 0 LPR: 20/I11 LONG Supply (Ha): Constrained Total (Ha): 0 Established Supply (Ha): Gross Established: 1.74 Net Established: 1.39 Development (Ha): Built: 0 Under Construction: 0 LONG: 0 General Industrial: 1.39 High Amenity: 0 Page 143
Page 144
The Moray Council Employment Land Audit2025 Reference: M/KH/E/012 Location: Westerton Road (LONG) Grid Ref: 343822 850218 Supply Type: Effective 5years+ Constrained Owner Infrastructure Physical Town: KEITH Effective Supply (Ha): Effective: 0 Immediately Available: 0 LPR: 20/LNG2 LONG Supply (Ha): Constrained Total (Ha): 0 Established Supply (Ha): Gross Established: 3.2 Net Established: 2.5 Development (Ha): Built: 0 Under Construction: 0 LONG: 2.5 General Industrial: 0 High Amenity: 0 Reference: M/KH/E/013 Location: Banff Road South Grid Ref: 343847 850958 Supply Type: Effective Constrained Owner Infrastructure Physical Town: KEITH Effective Supply (Ha): Effective: 1.75 Immediately Available: 0 LPR: 20/MU LONG Supply (Ha): Constrained Total (Ha): 0 Established Supply (Ha): Gross Established: 1.75 Net Established: 1.75 Development (Ha): Built: 0 Under Construction: 0 LONG: 0 General Industrial: 0 High Amenity: 1.75 Page 144
Page 145
The Moray Council Employment Land Audit2025 Reference: M/LS/E/007 Location: Sunbank Grid Ref: 323075 869644 Supply Type: Constrained Constrained Owner Infrastructure Physical Town: LOSSIEMOUTH Effective Supply (Ha): Effective: 0 Immediately Available: 0 LPR: 20/OPP1 LONG Supply (Ha): Constrained Total (Ha): 10.24 Established Supply (Ha): Gross Established: 12.8 Net Established: 10.24 Development (Ha): Built: 0 Under Construction: 0 LONG: 0 General Industrial: 0 High Amenity: 0 Reference: M/MS/E/003 Location: Baxters Grid Ref: 333948 859705 Supply Type: Constrained Constrained Owner Infrastructure Physical Town: MOSSTODLOCH Effective Supply (Ha): Effective: 0 Immediately Available: 0 LPR: 20/I5 LONG Supply (Ha): Constrained Total (Ha): 1.78 Established Supply (Ha): Gross Established: 2.22 Net Established: 1.78 Development (Ha): Built: 12.05 Under Construction: 0 LONG: 0 General Industrial: 0 High Amenity: 0 Page 145
Page 146
The Moray Council Employment Land Audit2025 Reference: M/MS/E/005 Location: North of Baxter's Grid Ref: 333613 860016 Supply Type: Constrained Constrained Owner Infrastructure Physical Town: MOSSTODLOCH Effective Supply (Ha): Effective: 0 Immediately Available: 0 LPR: 20/I2 LONG Supply (Ha): Constrained Total (Ha): 2.57 Established Supply (Ha): Gross Established: 3.22 Net Established: 2.57 Development (Ha): Built: 0 Under Construction: 0 LONG: 0 General Industrial: 0 High Amenity: 0 Reference: M/MS/E/006 Location: South of A96 Grid Ref: 333268 859627 Supply Type: Effective 5years+ Constrained Owner Infrastructure Physical Town: MOSSTODLOCH Effective Supply (Ha): Effective: 0 Immediately Available: 0 LPR: 20/MUL1 LONG Supply (Ha): Constrained Total (Ha): 0 Established Supply (Ha): Gross Established: 11 Net Established: 8 Development (Ha): Built: 0 Under Construction: 0 LONG: 8 General Industrial: 0 High Amenity: 0 Page 146
Page 147
The Moray Council Employment Land Audit2025 Reference: M/MS/E/007 Location: West of Mosstodloch Grid Ref: 331976 860333 Supply Type: Effective Constrained Owner Infrastructure Physical Town: MOSSTODLOCH Effective Supply (Ha): Effective: 12.8 Immediately Available: 0 LPR: 20/I3 LONG Supply (Ha): Constrained Total (Ha): 0 Established Supply (Ha): Gross Established: 16 Net Established: 12.8 Development (Ha): Built: 0 Under Construction: 0 LONG: 0 General Industrial: 12.8 High Amenity: 0 Reference: M/MS/E/008 Location: West of Mosstodloch (LONG) Grid Ref: 331976 860549 Supply Type: Effective 5years+ Constrained Owner Infrastructure Physical Town: MOSSTODLOCH Effective Supply (Ha): Effective: 0 Immediately Available: 0 LPR: 20/LNG2 LONG Supply (Ha): Constrained Total (Ha): 0 Established Supply (Ha): Gross Established: 14 Net Established: 11.2 Development (Ha): Built: 0 Under Construction: 0 LONG: 11.2 General Industrial: 0 High Amenity: 0 Page 147
Page 148
The Moray Council Employment Land Audit2025 Reference: M/MS/E/009 Location: James Jones Expansion Grid Ref: 333256 860661 Supply Type: Constrained Constrained Owner Infrastructure Physical Town: MOSSTODLOCH Effective Supply (Ha): Effective: 0 Immediately Available: 0 LPR: LONG Supply (Ha): Constrained Total (Ha): 13.6 Established Supply (Ha): Gross Established: 17 Net Established: 13.6 Development (Ha): Built: 0 Under Construction: 0 LONG: General Industrial: High Amenity: Reference: M/RS/E/001 Location: Back Burn Grid Ref: 327876 849746 Supply Type: Effective Constrained Owner Infrastructure Physical Town: ROTHES Effective Supply (Ha): Effective: 0.6 Immediately Available: 0 LPR: 20/I1 LONG Supply (Ha): Constrained Total (Ha): 0 Established Supply (Ha): Gross Established: 0.75 Net Established: 0.6 Development (Ha): Built: 0 Under Construction: 0 LONG: 0 General Industrial: 0.6 High Amenity: 0 Page 148
Page 149
The Moray Council Employment Land Audit2025 Reference: M/RS/E/007 Location: Greens of Rothes Grid Ref: 328029 850205 Supply Type: Constrained Constrained Owner Infrastructure Physical Town: ROTHES Effective Supply (Ha): Effective: 0 Immediately Available: 0 LPR: LONG Supply (Ha): Constrained Total (Ha): 13.04 Established Supply (Ha): Gross Established: 16.3 Net Established: 13.04 Development (Ha): Built: 0 Under Construction: 0 LONG: 0 General Industrial: High Amenity: Reference: M/TV/E/001 Location: Troves Industrial Estate Grid Ref: 324974 324974 Supply Type: Effective Constrained Owner Infrastructure Physical Town: TROVES Effective Supply (Ha): Effective: 1.1 Immediately Available: 0 LPR: 20/I1 LONG Supply (Ha): Constrained Total (Ha): 0 Established Supply (Ha): Gross Established: 1.61 Net Established: 1.1 Development (Ha): Built: 0 Under Construction: LONG: 0 General Industrial: 1.1 High Amenity: 0 Page 149
Page 150
October 2025 Page 150
Page 151
Report to: Planning and Regulatory Services Committee Meeting Date: 16 December 2025 Report by: Executive Director Economy, Enterprise and Operations Author: Rowena MacDougall Contact Email: localdevelopmentplan@moray.gov.uk Subject: Moray Town Centre Health Check 2025 1. PURPOSE ☒ For Decision ☐ For Information 1.1 The purpose of this report is to highlight the key findings of the Moray Town Centre Health Check 2025 and recommend that the Moray Town Centre Health Check 2025 is adopted as a material consideration in future retail planning policy and planning application decision making. 1.2 This report is submitted to Committee in terms of Section III (E) (2) of the Council’s Scheme of Administration relating to the review or preparation of the Local Development Plan. 2. SUMMARY 2.1 Town Centre Health Checks have been undertaken every two years since 2010 (with the exception of a delay in 2020 due to covid-19 restrictions). This has allowed indicators to be monitored over time and data to be used as an evidence base for developing policy and strategies to support town centres. Vacant retail units have increased in Elgin and Keith. There was notable decrease in vacancies in Forres, with smaller reductions in vacancies in Buckie and at Edgar Road, Elgin. Vacancies in Lossiemouth have remained the same. The national trend of national multiple retailers moving out of town centres and a shift towards increased leisure use has continued. 3. RECOMMENDATIONS 3.1 It is recommended that Committee: i) note the findings of the Moray Town Centre Health Check 2025; ii) adopt the Moray Town Centre Health Check 2025, as set out in Appendix 1, as a material consideration in future retail planning policy and planning application decision making; and Item 8. Page 151
Page 152
iii) agree the publication of the Town Centre Health Check 2025 on the Planning and Development website pages. Author Name Rowena MacDougall Job Title Senior Planning Officer 4. BACKGROUND AND CONTEXT 4.1 Town centre audits or health checks are important to provide an evidence base of the strengths, vitality and viability, weaknesses and resilience of our town centres. This evidence base can be used to inform development plans and decisions on planning applications. A Town Centre Health Check Framework was developed in 2010 in conjunction with Hargest Planning Ltd and has been used to prepare biennial health checks since 2010. Assessments are undertaken in the town centres of Elgin, Forres, Keith, Buckie, and Lossiemouth. The Edgar Road area of Elgin is also assessed. Audits were also undertaken in Aberlour, Dufftown, Fochabers, and Rothes. 4.2 The Town Centre Health Check data: • Provides an evidence base for use in other studies and strategies; • Supports the preparation and implementation of the Local Development Plan and economic development policies; and • Provides a baseline for assessing the impacts of proposed regeneration projects. 4.3 The principal sources of information used for gathering data are field surveys undertaken during summer 2025 to record the occupier of units and the type of use (Space In Use Survey). This allows assessment against three key vitality and viability indicators: diversity of uses, vacancy rates, and retail representation. Retailer intentions, rate and yield data, consumer surveys and turnover indicators have not been monitored due to the scale and cost of undertaking the survey, the need for specialist consultants and the lack of response in previous studies. 4.4 Previous health checks have included an assessment of pedestrian flow. It has not been possible to assess pedestrian flow since 2023 due to resource issues however it is intended to resume this in 2026 when officers will have access to data from automatic footfall counters in Elgin. 4.5 Work has been ongoing on actions within the Town Centre Improvement Plans for Aberlour, Buckie, Dufftown, Forres, Keith and Lossiemouth. This has included completion of improvements to Aberlour public toilets led by the community association funded by the Council, and installation of bespoke seating in Cluny Square Buckie supported by Buckie High School and Forsyths. Design work for public realm improvements at Museum Square Forres and Dufftown Square has also been completed. In consultation with Ward Members funds have been reallocated to improve St Rufus park pavilion and toilets. Supporting improvements to the appearance of town centres and bringing properties back into use has been supported through the Town Centre Capital Grant Fund. An update on progress with the Levelling Up Fund work within Elgin City Centre was reported to Council on the 27 August 2025. (para 15 of the minute refers) 5. MORAY TOWN CENTRE HEALTH CHECK 2025 5.1 The summary below provides an overview of the key finding of the 2025 health check. A Page 152
Page 153
copy of the full health check is included at Appendix 1. 5.2 ELGIN For the first time the number of units occupied by leisure uses (i.e. restaurants, cafes, pubs, cinemas etc) is higher than comparison retailing (i.e. clothes, gifts, furniture, chemists etc). This change is a result of the St Giles Centre closure and reflects national trends which show high vacancy rates in shopping centres particularly in middle sized centres like Elgin. Comparison retailing and convenience retail (i.e. supermarkets, butchers, newsagents etc) continue to make up a significant proportion of units and occupy significant floor areas due to occupation of larger units by Tesco, Aldi and Marks and Spencer. The city centre has a strong mix of independent retailers but is following national trends with a fall in the number of national multiple retailers (e.g. Argos, WH Smith, Waterstones and The Works have left the city centre). 5.3 The number of vacant units recorded has increased from 40 in 2023 to 51 in 2025. This gives a vacancy rate of 20%. Historically 10% vacancy has been used as being indicative of a healthy centre. The St Giles Centre accounts for 26 of the vacant units and its closure has seen 11 retailers not return to the town centre. Other vacancies since 2023 include TUI travel agent, Shopmobility Moray, Sirology and Lloyds Pharmacy. 5.4 EDGAR ROAD At Edgar Road national multiples continue to be dominant within the two retail parks. Vacancies have decreased by one to four units. All the vacancies are within Elgin Retail Park. 5.5 FORRES Forres has seen a significant positive shift since the last health check in 2023, with the number of vacant units down from 18 to 7 in 2025. This is a vacancy rate of 7%. Comparison retailing and retail services are the dominant use within Forres town centre but leisure uses also make a significant contribution. 5.6 KEITH Vitality and viability indicators in Keith have been relatively steady with the mix of uses remaining largely the same but an increase in vacant units from seven in 2023 to 10 in 2025 is identified. The Barbers at 169 Mid Street and relocation of Kelpie Games from 109 to 119 Mid Street has resulted in new vacancies. The vacancy rate is 12%. 5.7 BUCKIE Comparison retailing still occupies the greatest number of units in Buckie. It is notable that retail services have increased from 11 in 2021 to 20 in 2025 but leisure services have decreased from 23 identified in 2021 to 18 in 2025. Seven vacant units were identified within Buckie town centre, this is a decrease from 11 in 2023. This is a vacancy rate of 8.8% 5.8 LOSSIEMOUTH Leisure continues to be the dominant use in Lossiemouth with reasonable levels of comparison and retail services identified. Five vacant units were identified, which is a vacancy rate of 9.4% and comparable to vacancies in 2023. Notable changes include Moray Driftwood Designs occupying 33 King Street, The Pier coffee shop occupying the former Ladbrokes near the harbour and Moray Coastal Flooring moving to larger premises to the former Bank of Scotland on Queen Street. Page 153
Page 154
5.9 SMALLER SETTLEMENTS (ABERLOUR, DUFFTOWN, FOCHABERS AND ROTHES) A significant proportion of the uses in the centre of Moray’s smaller towns are Leisure Services, with Comparison and Retail Services also contributing to the mix. Convenience shopping needs are provided for by a number of smaller stores, such as the Co-operative stores in Aberlour, Dufftown and Fochabers. Rothes is serviced by a Keystore and Morrisons. One vacancy was identified in Aberlour and Fochabers, ten in Dufftown (an increase from 5 in 2023) and seven in Rothes (an increase from 5 in 2023). 6. SUMMARY OF IMPLICATIONS 6.1 The table below shows whether risks and implications apply if the recommendations are agreed: SUBJECT YES NO Corporate Plan and 10 Year Plan (Local Outcome Improvement Plan) x Policy and Legal x Financial x Risk x Staffing x Best Value and Transformation x Property x Information Communications Technology/Digital x Equalities. Social Inclusion and Economic Impact x Climate Change and Biodiversity Impact x 6.2 Corporate Plan and 10 Year Plan (Local Outcomes Improvement Plan (LOIP)) Improved Collaborative Leadership, as part of continuous improvement through Best Value, will better enable the Council to fulfil the ambitions set out in its strategic plans. a) Links to Council Corporate Plan – The proposals in this report support and contribute to improved outcomes for communities as outlined in the following Council Plan strategic priorities: ☐ Tackle Poverty and Inequality. ☐ Build Stronger Greener Vibrant Economy. ☒ Build Thriving, resilient, empowered Communities. b) Links to Local Outcomes Improvement Plan – The proposals in this report support and contribute to improved outcomes for communities as outlined in the following Local Outcomes Improvement Plan priorities: ☒ Developing a diverse, inclusive, and sustainable economy ☐ Building a better future for our children and young people in Moray. ☐ Empowering and connecting communities. ☐ Improving wellbeing of our population 6.3 Policy and Legal If approved the Moray Town Centre Health Check Report 2025 would be a material consideration in any relevant future planning applications. Page 154
Page 155
6.4 Financial There are no direct financial implications from this report. One off Costs: Service Area Budget Budget Years Proposed Spend this Year Virement From Other Comments Annually Recurring Costs: Service Area Budget With Effect From Annual Net Impact Virement From (if applicable) Other Comments 6.5 Risk The risk of not monitoring the health of town centres would be an out of date evidence base being used for preparing strategies. 6.6 Staffing The field study and analysis of space in use was completed by officers within Strategic Planning and Development. 6.7 Best Value and Transformation None arising from this report. 6.8 Property None 6.9 Information Communications/Technology/Digital None 6.10 Equalities, Social Inclusion and Economic Impact There are no direct implications arising from this report. Any changes to policy through the review of the Local Development will be subject to assessment. 6.11 Climate Change and Biodiversity Impacts Town centres are often the most accessible by public and active travel options. Successful and thriving town centres that provide a range of services and social opportunities can help to reduce the need to travel by car and support walkable neighbourhoods. Making best use of existing town centre infrastructure including reuse and regeneration of existing buildings is preferable to demolition from an embodied carbon perspective. 7. CONSULTATION 7.1 This report has been prepared in consultation with Executive Director Economy, Enterprise and Operations, Head of Growth, Planning and Climate (Chief Planning Officer), , Service Manager Legal Services, L Rowan Committee Services Officer, and the Chief Financial Page 155
Page 156
Officer and any comments made have been incorporated into the report 8. BACKGROUND PAPERS 8.1 Page 156
Page 157
Moray Town Centre TOWN CENTREHEALTHCHECK Health Check Assessment 2025 © Crown copyright [and database rights] 2025 OS AC0000806936 Moray Council Page 157
Page 158
1 1. Executive Summary In 2025, Moray Council undertook several Town Centre Health Check Assessments in the town centres of Elgin, Forres, Buckie, Keith and Lossiemouth. Limited assessment of Dufftown, Rothes, Aberlour and Fochabers was also undertaken. This report does not aim to interpret the data collected; it is simply presenting information for others to analyse. 1.1 Summary Table of Key Findings A summary table of key findings is set out below: Town Comparison Convenience Retail Service Leisure Service Vacancy Vacancy Rate 2025 2023 2025 2023 2025 2023 2025 2023 2025 2023 2025 2023 Elgin 66 73 17 18 43 46 70 70 50 40 20% 16% Edgar Road 22 20 3 3 7 4 4 3 4 5 10% 14.3% Forres 33 31 12 15 25 24 24 23 7 18 7% 16.2% Keith 26 27 12 12 17 18 18 18 10 7 12% 7% Buckie 25 24 9 7 20 17 18 20 7 11 8.9% 13.7% Lossiemouth 10 11 6 8 14 11 18 21 5 5 9.4% 9% Aberlour 4 5 5 4 6 5 9 13 1 0 4% 0% Dufftown 7 10 2 3 8 8 14 17 10 5 24.3% 11.6% Fochabers 6 8 3 4 5 2 10 9 1 3 3% 11.5% Rothes 2 3 3 3 4 3 9 9 7 5 28% 22% Page 158
Page 159
2 1.2 Vitality & Viability Indicators Vitality and viability indicators are used to assess the performance of town centres featured in this report. ‘Vitality’ is a measure of how lively and busy a town centre is. ‘Viability’ is a measure of the capacity to attract ongoing investment for maintenance, improvement, and adaptation to changing needs. Together these measures give an indication of the health of a town centre and, when used consistently over a period of time they can demonstrate changes in performance. A brief description of key Vitality and Viability Indicators assessed in this report are provided below: • Diversity of uses surveys analyse the mix of uses within each centre and the quantum floor space they occupy. A table showing GOAD categories is included in Appendix II. • Retailer representation involves recording the identity and type of retailers within the town centre. This form of analysis focuses on the number of independent and national retailers within a centre. • Vacancy rates can be defined as either the number of units or amount of vacant floor space not in occupation, expressed as a percentage of the total number of retail units or floor space in a centre. Vacancies are measured for vacant Comparison, Convenience, Retail Services and Leisure Services only. A vacancy rate below 10% indicates a healthy and viable town centre • Pedestrian flow – it was not possible to assess pedestrian flow in 2025, new automatic counters are due to be installed. 1.3 Previous Assessments Figures for 2021 were obtained by Hargest Planning Ltd. as part of the wider Moray Retail Study 2021. Whilst a similar methodology was used, data was presented differently which accounts for differences between datasets. Additionally, there have been some changes to the categorisation of certain uses to improve consistency between towns. These adjustments, as the study progresses account for some of the differences between categories. 1.4 GOAD Designations GOAD designations are used to categorise the type of retailer/organisation within an occupied unit. Definitions of the key designations feature below: • Convenience units are predominantly food-related, some examples of this designation are supermarkets, butchers, bakers, off licenses, and newsagents. Page 159
Page 160
3 • Comparison retailers sell a wide range of non-food items including clothing, books, office supplies, toys, furniture and flowers. This designation also includes chemists and charity shops. • Leisure Services provide opportunities for socialising and relaxation such as bars, cinemas, night clubs, takeaways/restaurants, hotels and sports facilities. • Retail Services provide an in-person service. This designation covers hairdressers/barbers, health & beauty treatment, post offices, travel agents and dry cleaners. Other designations include financial & business services, health & medical services, public service, religious service and offices. The number of vacancies only considers vacant convenience, comparison, leisure service and retail service units; this is VAC1. All other designations are classed as VAC2 and are not included in the vacancy figures through this assessment. 2. Elgin Town Centre Health Check Since the last town centre health check was undertaken in 2023, Elgin has seen significant changes. The most notable of these being the closure of the entire St Giles shopping centre, accounting for over half of Elgin’s current vacant units. The closure has resulted in Ashers Bakery and Ramsdens occupying new premises within the town centre. The Moray School Clothing Bank has also occupied a unit on the High Street. However, several national retailers including Argos, Waterstones, Subway, The Works, Vodaphone and, O2 have not returned to Elgin since St Giles closed in January 2025. Leisure services within Elgin town centre have also experienced changes. Restaurants including The Northern Chip Shop, The Pancake Place and, 156 Bar and Grill have all closed. However, several new eateries like Norah’s Café and Wine Bar which occupies the unit vacated by Starbucks, You You Tea and Krua Thai Restaurant have opened in recent years. The South Street regeneration plan is now underway bringing new residential, leisure and employment use to the town centre. Additionally, Poundland has moved from its temporary unit back to its original location on the high street after over 6 years of restoration. The number of vacant units within Elgin town centre is the highest since the biennial Town Centre Health Checks commenced in 2010. 2.1 Diversity of Uses The dominant use within Elgin is now leisure services, this has changed from comparison retailing which has been the most common use for almost 10 years. Comparison retail still makes up a significant number of units, but the number of units has been steadily declining. Retail services within Elgin town centre are predominantly comprised of hairdressers/barbers. There is a smaller proportion of convenience shops but some units within this designation, like Tesco have large floor spaces. Almost 30 units are designated as Financial and Business Services, these include solicitors, accountants, and property agents. Page 160
Page 161
4 The overall mix of uses and the quantum floor space they occupy is summarised below: Summary of Elgin Diversity of Uses Survey 2025 2023 2021 (Completed by Hargest Planning Ltd) Type of Use No. of Outlets Floor space (sqm) No. of Outlets Floor space (sqm) No. Of Outlets Floor space (sqm) Comparison 66 16337.4 73 18847.4 82 28338 Convenience 17 14909.9 18 15440.1 16 10293 Retail Service 43 3530.3 46 4503.4 55 17460 Leisure Service 70 15891.9 70 17392.9 61 Financial & Business Service 26 5710.2 38 7760.4 26 Health & Medical 9 9 Public Service 21 26 Religious Service 6 6 General Office Use 17 24 Vacancy 50 10664.5 40 8986.6 32 6546 Total 325 67044.2 350 72930.8 272 62637 2.2 Retailer Representation Elgin town centre is home to a number of national retailers including TK Maxx, Marks and Spencer, Boots, Costa Coffee, Starbucks, Tesco and Aldi. The total number of national (Scottish/UK) retailers within Elgin is 40. This is a decrease from 46 in 2023, this can be attributed to the closure of the St Giles centre in which many national retailers had units. Elgin town centre has a good range of independent stores. Batchen Street, Commerce Street and South Street are hubs for independent retail within the town centre. These shops tend Page 161
Page 162
5 to offer a more specific, bespoke service. Elgin also has several independent retail and leisure service providers, these include restaurants, hairdressers, beauticians and, takeaways. Within the defined town centre boundary there are a number of food stores, the largest of which are Tesco on Blackfriars Road, Marks & Spencer’s store on High Street and an Aldi store. Both Tesco and M&S have a substantial portion of floor space for Comparison goods as well as Convenience. This has all been classed as ‘Convenience’ floor space above. There are seven charity shops within the town centre boundary, this is the same level as 2023 and 2018. There are 20 hairdressers or barbers within Elgin town centre, these occupy almost half of all retail service outlets. Elgin town centre has 2 betting offices and Ramsdens is the only retailer resembling a high interest money lender. There are 15 takeaways within the town centre, this is a slight decrease from 16 in 2023. This figure does not include restaurants or cafes which offer a takeaway service in addition to the “sit in” offer. 2.3 Vacancy Rate A site survey by Moray Council planning staff during summer 2025 confirmed the number of vacant units within Elgin town centre stood at 50. This is an increase from 2023 when 40 vacant units were recorded. Vacancies account for 20% of the total number of Comparison, Convenience, Retail and Leisure Service units within the centre. The St Giles Centre accounts for 26 of the vacant units within Elgin and its closure has seen 11 retailers not return to the town centre. It is noted that previous town centre health checks in 2018 and 2023 highlighted high vacancy rates within the St Giles Centre. Other vacancies since 2023 include TUI travel agent, Shopmobility Moray, Sirology and Lloyds Pharmacy. A number of units have remained vacant since the last assessment including 239, 134, 35 and 7 High Street. Available floor space data indicates that approximately 10,664.5² of floor space within Elgin town centre is vacant, this is an increase from the 8,986.6m² recorded in 2023. There is approximately 100.2m of vacant retail frontage within the town centre. This equates to 7.7% of the retail frontage of the traditional shopping streets within Elgin town centre, these include the core retail area of High Street, Commerce Street, Batchen Street, South Street and Thunderton Place. Page 162
Page 163
6 3. Edgar Road Health Check Edgar Road is not included within Elgin’s town centre boundary; however, it is a key commercial centre with substantial retail space. Edgar Road encompasses Springfield Retail Park, Elgin Retail Park, and shops along Edgar Road. Since 2023, there has been limited change. Carpet Right and the NHS Covid Vaccine Centre have closed, and Bensons for Beds is now a charity shop. 3.1 Diversity of Uses The dominant use within Edgar Road is Comparison retailing. These are predominantly national retailers such as Home Bargains, B&M, Pets at Home and Boots. Convenience retailing accounts for a small number of units but a large proportion of floor space use; ASDA Superstore, The Food Warehouse and, Allaburn Farm Shop have significant floor space. Retail services are predominantly comprised of car related services. The overall mix of uses and the quantum floor space they occupy is summarised below: Summary of Edgar Road Diversity of Uses Survey 2025 2023 2018 Type of Use No. of Outlets Floor space (sqm) No. of Outlets Floor space (sqm) No. of Outlets Floor space (sqm) Comparison 22 21536.16 20 21699.8 21 21171.76 Convenience 3 13325.86 3 13325.86 2 12386.8 Retail Service 7 1508.3 4 1481.3 2 547.2 Leisure Service 4 1352.63 3 665.7 4 1182.06 Financial & Business Service 3 1232.5 3 1232.5 3 1232.5 Health & Medical 1 2 1 Public Service 1 1 1 Religious Service 0 0 General Office Use 0 0 Vacancy 4 2526.9 5 3050.21 7 4247.44 Total 45 41482.35 42 41455 41 40767.76 Page 163
Page 164
7 3.2 Retailer Representation There are 22 national (Scottish/UK) retailers along Edgar Road, these take up the majority of units along Edgar Road. Some local independent retailers have units outside of the main retail parks like Elgin Autos, Wards Veterinary, Elgin Marble Company, Hawco Car Sales and Allaburn Farm Shop. 3.3 Vacancy Rate The number of vacant units identified was 4, an decrease of 1 from 2023. Floorspace figures indicate the amount of vacant floorspace was approx 2,526.9m². All vacant units are located within Elgin Retail Park. 4. Forres Town Centre Health Check Forres has seen a significant positive shift since the last health check in 2023, with the number of vacant units down from 18 in 2023 to 7 in 2025. Independent retailers like The Old Market Gift Shop and MacKenzie of Forres Kilt Shop have occupied previously vacant units. Additionally, 2 vacant banks, which had been empty for a number of years, at the centre of Forres High Street have been converted into a whiskey shop and banking hub. 4.1 Diversity of Uses Comparison retailing remains as the dominant use within Forres Town Centre. Leisure and Retail services also make up a significant proportion of retailers. Forres has a decent number of convenience retailers, comprised of convenience stores, butchers, and specialist food shops. Larger convenience retailers such as Tesco and Lidl exist just out of the town centre. The overall mix of uses and the quantum of floor space they occupy is summarised in the table below. Summary of Forres Diversity of Uses Survey 2025 2023 2021 (Completed by Hargest Planning Ltd) Type of Use No. of Outlets Floor space (sqm) No. of Outlets Floor space (sqm) No. of Outlets Floor space (sqm) Comparison 33 5918.9 31 5067.9 29 4455 Convenience 12 1955.9 15 1933 11 1840 Retail Service 25 2454.61 24 1683 18 4591 Page 164
Page 165
8 Leisure Service 24 1525.3 23 1232.6 21 Financial & Business Service 11 3747.9 9 3410.7 8 Health & Medical 4 4 5 Public Service 9 10 14 Religious Service 3 3 3 General Office Use 3 4 6 Vacancy 7 906.4 18 1758.1 12 1084 Total 131 16509.01 141 150853 138 16091.4 4.2 Retailer Representation 14 national (Scottish/UK) retailers occupy units within Forres town centre including, Boots, The Co-op and Savers. This is the same level as the previous health check in 2023. 5 charity shops were identified within the town centre, this is the same level as the previous health check. No betting offices or high interest money lending were identified during the assessment. There are 7 takeaways within Forres town centre, this is consistent with the previous health check. This figure does not include restaurants or cafes which offer a takeaway service in addition to the “sit in” offer. 4.3 Vacancy Rates 7 vacant units were identified within Forres town centre, this is a decrease of over 60% from 2023. The majority of units along Forres High Street that were vacant in 2023 are now occupied, the only exceptions are 154, 85 and 97C. Vacancies along Forres High Street are relatively spread out, this helps to reduce the visual impact of vacant units within the town centre. Floor space data suggests approximately 906.4m² of floor space is currently vacant. This is a significant reduction from the 1,758.1m² recorded in 2023. There is approximately 9.1m of vacant frontage in Forres town centre, this accounts of 1.2% of the 748m total frontage. Page 165
Page 166
9 5. Keith Town Centre Health Check Keith and Fife Keith have their own individual town centres, for the purpose of this report the findings have been combined. Keith has seen some new businesses within its town centre including Reform by Ryan Fitness and Tyred and Cranky Bike Shop. Since the last health check in 2023, new vacant units have emerged in Keith, predominantly along Mid Street. 5.1 Diversity of Uses Comparison retailing is the most common use within Keith, followed by leisure and retail services. The overall mix of uses and the quantum of floor space they occupy is summarised in the table below. Summary of Keith Diversity of Uses Survey 2025 2023 2021 (Completed by Hargest Planning Ltd) Type of Use No. of Outlets Floor space (sqm) No. of Outlets Floor space (sqm) No. of Outlets Floor space (sqm) Comparison 26 5060.9 27 5373.7 23 4051 Convenience 12 1400.7 12 1393.5 11 1497 Retail Service 17 1447.9 18 1305.9 14 3951 Leisure Service 18 1282.2 18 1028.8 15 Financial & Business Service 9 925 9 1220 8 Health & Medical 1 1 Public Service 1 Religious Service 1 1 General Office Use 2 3 Vacancy 10 880.5 7 706 12 1925 Total 97 10997.2 96 11027.9 83 11424 Page 166
Page 167
10 5.2 Retailer Representation There are 6 national (Scottish/UK) retailers within Keith town centre including, Spar and Harry Gows Bakery. The closure of Blythswood Care at 100-102 Mid Street has reduced the number of charity shops in Keith to 1. No betting offices or high interest money lenders were identified during the assessment. 6 takeaways were identified within the town centre; this has increased from 5 in 2023. This figure does not include restaurants or cafes which offer a takeaway service in addition to the “sit in” offer. 5.3 Vacancy Rate 10 vacant units were identified in Keith, this is an increase from 7 in the last health check. The Barbers at 169 Mid Street and relocation of Kelpie Games from 109 to 119 Mid Street has resulted in new vacancies. The former Keystore at 78-82 Mid Street and The Cozy Neuk at 105 Mid Street are both still vacant from 2023. Floor space data indicates approximately 931.5m² of floor space is vacant within Keith’s town centre. This is an increase of 225.5m². There is approximately 71.4m of vacant retail frontage along Mid Street, the traditional shopping street in Keith. 6. Buckie Town Centre Health Check Buckie town centre has seen some changes since the last health check in 2023. A handful of new independent businesses, predominantly retail services like Glow 365 Tanning, USA Nails and Spa, and Sign/Etch have open along East Church Street. The town centre has also seen a number of new retail and non-retail vacancies including WM. R Mair Funeral Directors, Bengal Brasserie Indian Restaurant and Hardware and Tech Centre. 6.1 Diversity of Uses Within Buckie, comparison retail is the most common use. The number of retail services has increased from 17 in 2023 to 20 in 2025, over half of retail service units are occupied by a hair or beauty service. Buckie town centre has an adequate selection of convenience retailers, with corner shops, bakeries and a Lidl supermarket. The overall mix of uses and the quantum of floor space they occupy is summarised in the table below. Page 167
Page 168
11 Summary of Buckie Diversity of Uses Survey 2025 2023 2021 (Completed by Hargest Planning Ltd) Type of Use No. of Outlets Floor space (sqm) No. of Outlets Floor space (sqm) No. of Outlets Floor space (sqm) Comparison 25 5234.8 24 4413 27 6161 Convenience 9 2352.2 7 2243.9 12 3413 Retail Service 20 1508.3 17 1584.1 11 4693 Leisure Service 18 2248 20 2437.9 23 Financial & Business Service 6 1056 8 1391.9 7 Health & Medical 3 5 Public Service 6 9 Religious Service 4 4 General Office Use 1 Vacancy 7 755.8 11 1928 6 724 Total 99 13155.1 105 13871.8 86 14991 6.2 Retailer Representation Buckie has 13 national retailers (Scottish/UK) within its town centre including The Co-op, Savers, Subway and Lidl. This is an increase of 2 from 2023. Buckie has a large number of independent shops and retail service units. 3 charity shops were identified with the town centre, this has remained consistent since the last health check. 1 betting office and no high interest money lending units were identified in the assessment. There are 6 takeaways within Buckie’s town centre, this has decreased from 7 following the closure of Sugar and Slice at 7 West Church Street. This figure does not include restaurants or cafes which offer a takeaway service in addition to the “sit in” offer. Page 168
Page 169
12 6.3 Vacancy rate 7 vacant units were identified within Buckie town centre, this is a decrease from 11 in 2023. Floor space data indicates approximately 755.8m² of floor space within Buckie is vacant. This significant decrease from 1928m² in 2023 can be attributed to 5 East Church Street, which is now occupied by Taylors Home Furnishings. This unit has just over 1000m² of floor space spread over three floors. Approximately 57.7m of retail frontage is vacant, this equates to 6% of total retail frontage along the traditional shopping streets (East Church Street, West Church Street and High Street) within Buckie town centre. 7. Lossiemouth Town Centre Health Check Lossiemouth does not have a defined ‘town centre’ within the Moray Local Development Plan 2020. A map of the study area for this assessment has been included below. Lossiemouth has experienced some changes since the last town centre health check in 2023. Moray Driftwood Designs now occupies 33 King Street and The Pier coffee shop has taken over an old Ladbrokes unit beside the harbour. Moray Coastal Flooring has moved to a larger premises at the former Bank of Scotland unit along Queen Street. The closure of Buckley’s Newsagents and Fred’s Threads have resulted in new vacancies. Page 169
Page 170
13 7.1 Diversity of Uses The most common use within Lossiemouth is leisure services, likely to be attributed to the area’s popularity with tourists. Lossiemouth also has a decent number of retail services and comparison units. The diversity of convenience retailers is limited within the town centre, The Co-op is the only supermarket for residents and tourists. The overall mix of uses and the quantum of floor space they occupy is summarised in the table below. Summary of Lossiemouth Diversity of Uses Survey 2025 2023 2021 (Completed by Hargest Planning Ltd) Type of Use No. of Outlets Floor space (sqm) No. of Outlets Floor space (sqm) No. of Outlets Floor space (sqm) Comparison 10 1064.4 11 907.9 11 882 Convenience 6 1742.6 8 1841.3 8 989 Retail Service 14 979.5 11 775.4 12 3404 Leisure Service 18 1680.8 21 2531.7 21 Financial & Business Service 3 665.2 3 611.7 2 Health & Medical 3 2 Public Service 5 3 Religious Service 1 1 General Office Use 1 Vacancy 5 592.3 5 600.5 1 81 Total 65 6724.8 61 7154.3 55 5356 Page 170
Page 171
14 7.2 Retailer Representation There are only 2 national goods/services retailers (Scottish/UK), these are The Co-op and Right Medicine Pharmacy. Lossiemouth has a diverse range of independent retailers that offer a more unique experience when compared to high street chains. No charity shops, betting shops, or high interest lenders were identified during the assessment. There are 6 takeaways in Lossiemouth, this is down from 7 in 2023. This figure does not include restaurants or cafes that offer a takeaway service in addition to ‘sit in’ offer. 7.3 Vacancy Rate The number of vacant units identified in Lossiemouth is 5, this is consistent with the 2023 assessment. There is approximately 592.3m² of vacant floor space in Lossiemouth, a slight decrease from 2023. 8. Smaller Settlement Health Check Health check assessments were carried out for Aberlour, Dufftown, Fochabers and Rothes. Leisure service is the predominant use across all smaller settlements in Moray. Aberlour and Dufftown are popular with tourists and have a high percentage of leisure usage. Smaller settlements also tend to have a significant proportion of retail services. Comparison retailing tends to be provided by independent retailers offering specific products. Convenience retail is provided by one or two convenience shops like Co-op stores in Aberlour, Dufftown and Fochabers; Rothes is serviced by a Keystore and Morrisons. 8.1 Aberlour Aberlour has experienced minimal change since the 2023 health check. 79 High Street is now home to 3 Bags Wool Craft Shop and most notably, the petrol station and wooden toy shop along the High Street has closed. Aberlour is heavily reliant on independent retailers, the Co- Operative is the only national retailer in the town. Page 171
Page 172
15 Summary of Aberlour Diversity of Uses Survey 2025 2023 2018 Type of Use No. of Outlets Floor space (sqm) No. of Outlets Floor space (sqm) No. of Outlets Floor space (sqm) Comparison 4 311.5 5 327 7 613 Convenience 5 814.9 4 666.7 4 666.7 Retail Service 6 1804.1 5 1719.9 5 1665.2 Leisure Service 9 551.7 13 806.3 10 572.9 Financial & Business Service 3 484.7 3 286.1 2 191.1 Health & Medical 2 2 2 Public Service 3 4 4 Religious Service 1 1 1 General Office Use 0 Vacancy 1 15.5 0 1 70.1 Total 34 3982.4 37 3806 36 3779 Page 172
Page 173
16 8.2 Dufftown Vacancy rates in Dufftown have doubled since 2023. A number of local businesses including The Chippy Café, Fourmet Guesthouse, McIntosh Butchers and, the Fireplace Shop have closed in recent years. The Chippy Café and Fourmet Guesthouse are comprised of multiple units and occupied a large floorspace that is now vacant. Two new businesses have occupied previously vacant units along Fife Street; The Salon and The Cozy Coo Café. Summary of Dufftown Diversity of Uses Survey 2025 2023 2018 Type of Use No. of Outlets Floor space (sqm) No. of Outlets Floor space (sqm) No. of Outlets Floor space (sqm) Comparison 7 380.4 10 399.3 7 291.8 Convenience 2 528.9 3 607.5 7 825.7 Retail Service 8 691.2 8 603.5 4 599.2 Leisure Service 14 869.9 17 1174 19 1403.5 Financial & Business Service 3 797.7 4 912.2 4 881.5 Health & Medical Public Service 2 3 3 Religious Service General Office Use 1 Vacancy 10 805.7 5 346.1 2 93.8 Total 46 4073.8 51 4042.6 46 4095.5 Page 173
Page 174
17 8.3 Fochabers Fochabers has experienced a positive change since the last health check in 2023, with only one vacant unit and four previous vacancies now filled. Mother Goose Catering and Speyside Angling Centre have taken over vacant units along Fochabers High Street. Summary of Fochabers Diversity of Uses Survey 2025 2023 2018 Type of Use No. of Outlets Floor space (sqm) No. of Outlets Floor space (sqm) No. of Outlets Floor space (sqm) Comparison 6 646.6 8 737.1 9 810.5 Convenience 3 600.9 4 663.7 4 287.5 Retail Service 5 262.3 2 76.5 2 78.5 Leisure Service 10 404.5 9 341.7 9 439.5 Financial & Business Service 1 343.6 1 1 197.8 Health & Medical 1 1 2 Public Service 3 2 2 Religious Service 1 1 1 General Office Use 1 2 2 Vacancy 1 74.8 3 212 1 343.6 Total 32 2332.7 33 2031 33 2157.4 Page 174
Page 175
18 8.4 Rothes Rothes currently has 7 vacancies. No vacant units have been occupied recently within Rothes town centre. Rothes also has a high number of financial and building service usage including Forsyths and Hendersons. Rothes Primary School, Fire Station and Police Station are all located within its town centre, this accounts for the high number of public service units for a town of this size. Summary of Rothes Diversity of Uses Survey 2025 2023 2018 Type of Use No. of Outlets Floor space (sqm) No. of Outlets Floor space (sqm) No. Of Outlets Floor space (sqm) Comparison 2 251.5 3 337 6 276 Convenience 3 424.6 3 474.9 3 474.9 Retail Service 4 493.3 3 403.6 2 362.5 Leisure Service 9 104.8 9 104.8 9 153 Financial & Business Service 6 838.1 4 838.1 4 203.6 Health & Medical 1 1 1 Public Service 5 6 6 Religious Service 1 1 1 General Office Use Vacancy 7 709.8 5 433.8 3 275.6 Total 38 2822.1 35 2592.2 35 1745.6 Page 175
Page 176
19 Appendix I: Location of Key Centres Page 176
Page 177
20 GOAD Class GOAD Sub-Class Primary Activity Code Retail Comparison Antiques shops COM 1 Retail Comparison Art & Art dealers COM 2 Retail Comparison Booksellers COM 3 Retail Comparison Carpets and Flooring COM 4 Retail Comparison Charity Shops COM 5 Retail Comparison Chemists & Drugstores COM 6 Retail Comparison Children’s & Infants wear COM 7 Retail Comparison Crafts, Gifts, China & Glass COM 8 Retail Comparison Cycles & Accessories COM 9 Retail Comparison Department and Variety Stores COM 10 Retail Comparison DIY & Home Improvement COM 11 Retail Comparison Electrical & Other Durable Goods COM 12 Retail Comparison Florists COM 13 Retail Comparison Footwear COM 14 Retail Comparison Furniture COM 15 Retail Comparison Gardens & Equipment COM 16 Retail Comparison Greeting Cards COM 17 Retail Comparison Hardware & Household Goods COM 18 Retail Comparison Jewellery, Watches & Silver COM 19 Retail Comparison Mixed Clothing COM 20 Retail Comparison Ladies Wear & Accessories COM 21 Retail Comparison Leather & Travel Goods COM 22 Retail Comparison Men's Wear & Accessories COM 23 Retail Comparison Music & Musical Instruments COM 24 Retail Comparison Stationers COM 25 Retail Comparison Office Supplies COM 26 Retail Comparison Other Comparison Goods COM 27 Retail Comparison Photographic COM 28 Retail Comparison Second Hand Goods & Books COM 29 Retail Comparison Sports, Camping & Leisure Goods COM 30 Retail Comparison Telephones & Accessories COM 31 Retail Comparison Textiles & Soft Furnishings COM 32 Retail Comparison Toys, Games & Hobbies COM 33 Retail Comparison Vehicle & Motorcycle Sales COM 34 Retail Comparison Vehicle Accessories COM 35 Retail Comparison Opticians COM 36 Retail Convenience Bakers & Confectioners CNV 1 Retail Convenience Butchers CNV 2 Appendix II: GOAD Categories and Classifications Page 177
Page 178
21 GOAD Class GOAD Sub-Class Primary Activity Code Retail Convenience Convenience Store, Groceries & Frozen Food CNV 3 Retail Convenience Delicatessen CNV 4 Retail Convenience Fishmonger CNV 5 Retail Convenience Health Foods CNV 6 Retail Convenience Markets CNV 7 Retail Convenience Off licence CNV 8 Retail Convenience Shoe repairs etc CNV 9 Retail Convenience Supermarkets CNV 10 Retail Convenience Confectionery, Tobacconist, Newsagent CNV 11 Retail Retail Service Clothing & Fancy-Dress Hire RS 1 Retail Retail Service Dry Cleaner & Laundrette RS 2 Retail Retail Service Filling Stations & Garages RS 3 Retail Retail Service Health & Beauty (e.g. beauticians, nail bars) RS 4 Retail Retail Service Hairdressers/Barbers RS 5 Retail Retail Service Other Retail Outlets RS 7 Retail Retail Service Photo Processing RS 8 Retail Retail Service Photo Studio RS 9 Retail Retail Service Post Offices RS 10 Retail Retail Service Repair, Alterations & Restoration RS 11 Retail Retail Service Travel Agents RS 12 Retail Retail Service Vehicle Rental RS 13 Retail Retail Service Vehicle Repair & Services RS 14 Retail Other Retail Shops OR 1 Service Leisure Services Bars, Wine Bars & Public House LS 1 Service Leisure Services Bingo & Amusement LS 2 Service Leisure Services Cafes LS 3 Service Leisure Services Casino & Betting Offices LS 4 Service Leisure Services Cinemas, Theatres & Concert Halls LS 5 Service Leisure Services Clubs LS 6 Service Leisure Services Disco, Dance & Nightclub LS 7 Service Leisure Services Fast Food & Takeaways LS 8 Service Leisure Services Hotels & Guest Houses LS 9 Service Leisure Services Restaurants LS 10 Service Leisure Services Sports & Leisure Facilities LS 11 Service Financial & Business Services Building Society FBS 1 Service Financial & Business Building Supplies & Services FBS 2 Service Financial & Business Services Business Goods & Services FBS 3 Page 178
Page 179
22 GOAD Class GOAD Sub-Class Primary Activity Code Service Financial & Business Services Employment & Careers FBS 4 Service Financial & Business Services Financial Services FBS 5 Service Financial & Business Services Legal Services FBS 6 Service Financial & Business Services Other Business Services FBS 7 Service Financial & Business Services Printing & Copying FBS 8 Service Financial & Business Services Property Services FBS 9 Service Financial & Business Services Retail Banks FBS 10 Service Health & Medical Services Chiropodist HMS 1 Service Health & Medical Services Dental Surgery HMS 2 Service Health & Medical Services Doctors Surgery HMS 3 Service Health & Medical Services Health Centre HMS 4 Service Health & Medical Services Nursing Home HMS 5 Service Health & Medical Services Osteopath HMS 6 Service Health & Medical Services Other Health & Medical Service HMS 7 Service Health & Medical Services Rest home HMS 8 Service Health & Medical Services Veterinary surgery HMS 9 Service Public Service Advice Centre PS 1 Service Public Service Community Centre PS 2 Service Public Service Council Offices PS 3 Service Public Service Educational Establishment PS 4 Service Public Service Emergency Services PS 5 Service Public Service Information Centre PS 6 Service Public Service Kindergarten PS 7 Service Public Service Library PS 8 Service Public Service Museum & Art Gallery PS 9 Service Public Service TA/Cadet Centre PS 10 Service Public Service Tourist Information PS 11 Service Religious Service Place of Worship REL Vacant Vacant Retail Vacant Shop VAC 1 Page 179
Page 180
© The Moray Council 2025 © Crown copyright [and database rights] 2025 OS AC0000806936 Moray CouncilPage 180
Page 181
Report to: Planning and Regulatory Services Committee Meeting Date: 16 December 2025 Report by: Executive Director Economy, Enterprise and Operations Author: Darren Westmacott Contact Email: Darren.Westmacott@moray.gov.uk Subject: Housing Land Audit 2025/26 1. PURPOSE ☒ For Decision ☐ For Information 1.1 The purpose of this report is to consider the housing land supply situation in Moray and agree the final version of the Moray Housing Land Audit (HLA) 2025/26. 1.2 This report is submitted to Committee in terms of Section III (E) (2) of the Council’s Scheme of Administration relating to the review and preparation of Local Development Plans (LDP). 2. SUMMARY 2.1 The report provides the Committee with an update on the current housing land supply in Moray as at 31 March 2025, summarises responses to the consultation and seeks approval of the Moray HLA 2025/26 3. RECOMMENDATIONS 3.1 It is recommended that Committee: i) note the housing land supply in Moray; ii) agree the Council’s responses to the consultation on the draft Moray Housing Land Audit 2025/26, as set out in Appendix 1 of the report; and iii) approve the finalised Moray Housing Land Audit 2025/26, as set out in Appendix 2 of the report. Darren Westmacott Planning Officer (Strategic Planning and Development) 4. BACKGROUND AND CONTEXT Item 9. Page 181
Page 182
4.1 National Planning Framework 4 (NPF4) was published in February 2023 and introduced significant changes to the development planning system across Scotland. NPF4 Policy 16: Quality Homes sets out that a local development plan (LDP) should identify a housing target for the area it covers, in the form of a Local Housing Land Requirement (LHLR). The LHLR represents how much land is required and is expected to exceed the 10-year Minimum All-Tenure Housing Land Requirement (MATHLR). NPF4 sets the MATHLR as 3,450 units for Moray. 4.2 The Housing Land Audit (HLA), as set out in Appendix 2, provides an overview of Moray’s housing land supply as at 31 March 2025. It is used to monitor and support housing delivery and provides a comparison of supply with the LHLR of 5,732 units. 4.3 The HLA identifies and provides a programme of expected housing delivery over an initial 10-year period and the years thereafter. The audit also examines past and future predicted trends in housing land supply and identifies any action required to address issues arising. 4.4 Guidance on HLAs was issued by the Scottish Government on 20 January 2025 to support a consistent approach to the method and presentation of HLA. The HLA 2024/25 implemented a number of these changes based on the Scottish Government HLA Feedback Paper from August 2023. Moray Council moved to a financial year audit in 2024, therefore completions for 2023/24 also include calendar months January to March 2023 (identified in the audit by an asterisk). The key change made this year has been modifications to the definitions for the land supply (now referred to as site capacity) categories. 4.5 The audit includes three categories of site capacity (land supply): • Deliverable - Sites which are free from constraints and can be realistically programmed in the short/medium/long term. These sites contribute towards meeting the LHLR. • Deliverable with Constraints - Sites with one or more constraints that may be considered deliverable if action to overcome the constraint can be identified or if they are constrained only by a lack of market demand. These sites contribute towards meeting the LHLR. • Constrained - Sites with constraints which, at the base date of the audit, have no known prospect of being resolved. These sites do not contribute towards meeting the LHLR. 4.6 Deliverability factors (constraints) that could constrain the deliverability of the site include: • Land use status. • Ownership (includes programming/LONGs). • Physical conditions (e.g. slope, aspect, flood risk, contamination and pipelines). • Infrastructure (as defined under ‘Infrastructure first’ in NPF4). • Financial (e.g. construction costs, deficit funding and marketability). 4.7 Housebuilders and landowners were consulted during the preparation of the draft audit to provide the most up to date build-out projections. The figures within the draft audit are based upon housebuilders’ returns, where received, with adjustments made by Planning Officers. Page 182
Page 183
5. HOUSING LAND AUDIT 2025/26 5.1 The draft HLA 2025/26 was made available for consultation on the Council’s website and notification was sent to Homes for Scotland (HfS), Cairngorms National Park Authority (CNPA), statutory consultees as well as developers, agents and landowners. Comments were received from Altyre Estate, CNPA, HfS, Scottish and Southern Electricity Networks (SSEN), Scottish Water and Tulloch of Cummingston which are summarised, with the proposed Council responses, in Appendix 1 of the report. 5.2 The final HLA is included as Appendix 2 and identifies that there is a 24.4-year total housing site capacity (12,209 units), made up of ‘Deliverable’ and ‘Deliverable with Constraints’ site capacities, based on an annual total deliverable site capacity target of 500 units as identified in the Housing Needs and Demand Assessment (HNDA) 2023. This consists of an 11.7-year total deliverable site capacity (5,844 units) and 12.7-year constrained site capacity (6,365 units), of which 7.7-years capacity is designated as LONG (3,825 units). 5.3 This approach to LONG term housing land has been recognised as good practice and allows for longer term infrastructure planning through strategic level masterplanned expansion areas. This also means that the MLDP 2027 will likely only require minimum additional housing land to be identified, with officers exploring policy approaches to incentivise brownfield site redevelopment. 5.4 Actual housing completions in 2024/25 were 305 units compared to the programmed 358 units, a difference of 14.8%, primarily due to projected completions in Buckie not materialising, with one of the housebuilders having liquidated. This is compared to 459 in 2023/24*, which was a drop of 1.08% compared to the programmed rate. 5.5 While the overall total site capacity of housing is particularly good, the projected house completions reflect the low supply of new housing in Keith and Speyside. However, work at Banff Road (Keith R4) is progressing and construction has recently begun at Speyview (Aberlour R2). In addition, a masterplan is being finalised for Hillside Farm (Dufftown R1) in partnership with Dufftown and District Community Association. The Moray Growth Deal Housing Mix Delivery project will bring further investment to help unlock previously constrained housing sites. 6. BROWNFIELD SITES 6.1 NPF4 Policy 9 ‘Brownfield, vacant and derelict land and empty buildings’ aims to encourage, promote and facilitate the reuse of brownfield, vacant and derelict land and empty buildings and to help reduce the need for greenfield development. 6.2 Completions on brownfield sites in 2024/25 was 4 units, compared with 18 units in 2023/24*, 55 in 2021 and 15 in 2020. This equates to 5.6% of total completions between 2020 and 2024/25. 6.3 As set out in the MLDP 2027 Evidence Report, Moray Council have proposed a target of 10% of housing completions on brownfield sites by the end of the plan period. Whilst the target is considered to be ambitious, it is recognised that this will be dependent upon availability of staff and financial resources to tackle the complexity of brownfield site redevelopment. Page 183
Page 184
7. SUMMARY OF IMPLICATIONS 7.1 The table below shows whether risks and implications apply if the recommendations are agreed: SUBJECT YES NO Corporate Plan and 10 Year Plan (Local Outcome Improvement Plan) X Policy and Legal X Financial X Risk X Staffing X Best Value and Transformation X Property X Information Communications Technology/Digital X Equalities. Social Inclusion and Economic Impact X Climate Change and Biodiversity Impact X 7.2 Corporate Plan and 10 Year Plan (Local Outcomes Improvement Plan (LOIP)) Improved Collaborative Leadership, as part of continuous improvement through Best Value, will better enable the Council to fulfil the ambitions set out in its strategic plans. a) Links to Council Corporate Plan – The proposals in this report support and contribute to improved outcomes for communities as outlined in the following Council Plan strategic priorities: ☒ Tackle Poverty and Inequality. ☒ Build Stronger Greener Vibrant Economy. ☒ Build Thriving, resilient, empowered Communities. b) Links to Local Outcomes Improvement Plan – The proposals in this report support and contribute to improved outcomes for communities as outlined in the following Local Outcomes Improvement Plan priorities: ☒ Developing a diverse, inclusive, and sustainable economy ☒ Building a better future for our children and young people in Moray. ☒ Empowering and connecting communities. ☒ Improving wellbeing of our population 7.3 Policy and Legal The proposals support the delivery of the statutory MLDP 2020 and NPF4. 7.4 Financial None arising from this report. 7.5 Risk None arising from this report. 7.6 Staffing None arising from this report. Preparation of an annual HLA is part of the workload of the Strategic Planning and Development section. 7.7 Best Value and Transformation Page 184
Page 185
None arising from this report. 7.8 Property None arising from this report. 7.9 Information Communications/Technology/Digital None arising from this report. 7.10 Equalities, Social Inclusion and Economic Impact None arising from this report. Positive impact in terms of equalities through enhanced and improved communities through a range of interventions. 7.11 Climate Change and Biodiversity Impacts None arising from this report. NPF4 and MLDP policies seek to ensure that development proposals reduce carbon emissions and enhance biodiversity. NPF4 also places a much greater focus on brownfield redevelopment. 8. CONSULTATION 8.1 This report has been prepared in consultation with the Executive Director Economy, Enterprise and Operations, Head of Growth, Planning and Climate (Chief Planning Officer), Chief Financial Officer, Service Manager Housing Strategy, Service Manager Legal Services, Equal Opportunities Officer and Lissa Rowan, Committee Services Officer and any comments made have been incorporated into the report. Page 185
Page 186
Appendix 1 – Summary of Consultation Representations and Officers’ Response Organisation Comment(s) Council Response Changes Proposed to HLA Altyre Estate Agreement with status of sites relating to Altyre Estate. Noted. No change. Cairngorms National Park Authority (CNPA) Agreement with status of sites relating to CNPA. Noted. No change. Homes for Scotland (HfS) Queries relating to planning consents, developers and landowners. Positions relating to these matters at the time of the cut- off date are provided in the Schedules of the HLA. No change. Queries relating to gaps in programming/ delivery. Clarification has been provided directly to HfS. No changes are proposed to projections. No change. Various comments relating to Tulloch of Cummingston sites. See Tulloch of Cummingston response below. No change. Note that Findrassie (D Parcel) is coming forward earlier than programmed. Developer had not engaged directly in the process and no information has provided to support earlier delivery. No change. Scottish and Southern Electricity Networks (SSEN) No specific comments. Notes how the audit can be incorporated into planning of network. Noted. No change. Scottish Water Updates on infrastructure status relating to each site. Noted. No change. Tulloch of Cummingston Pending application for Balnageith (Forres) so site should be considered deliverable. Position occurred after the cut-off date and planning application is yet to be determined. The recent planning permission and the determination of such will be reflected in the No change. Page 186
Page 187
2026/27 HLA. Boundary incorrect in respect of Chapleton Farm (Forres). Seek additional land to be designated. Accepted in part. Matter to be considered as part of the Local Development Plan process. Further development will be reflected in future HLAs as appropriate. Map updated to reflect ownership. Update on ownership at Sunbank/Kinneddar and seek land to be designated. Matter to be considered as part of the Local Development Plan process. No change. Revised projections for Manse Road (Hopeman) and Inchbroom (Lossiemouth) The Manse Road projections are noted. The projections for Inchbroom however would exceed the number of units consented for the site. Projections for Manse Road (Hopeman) updated. Recent consent given at Commerce House (Elgin) Planning consent was issues after the cut-off date. The recent consent will be reflected in the 2026/27 HLA. No change. Page 187
Page 188
Moray Housing Land Audit 2025/26 October 2025 Page 188
Page 189
Contents 1 Introduction and Overview 1 2 Completions 3 3 Housing Land Supply 4 4 Small Sites 6 5 Brownfield Sites 6 6 Windfall Sites 7 7 Long-term Housing Designations 8 8 Housing Land Requirement & 10 Total Deliverable Site Capacity 9 Glossary 13 Page 189
Page 190
Moray Housing Land Audit 2025/26 1 1. Introduction and Overview Purpose 1.1. The Housing Land Audit (HLA) provides an overview of Moray’s housing land supply as at 31 March 2025. It is used to monitor and support housing delivery and provides a comparison of supply with the Local Housing Land Requirement (LHLR) of 5,732 units1. 1.2. National Planning Framework 4 (NPF4) was published in February 2023 and introduces significant changes to the development planning system across Scotland. NPF4 Policy 16: Quality Homes sets out that a local development plan (LDP) should identify a housing target for the area it covers, in the form of a LHLR. The LHLR represents how much land is required and is expected to exceed the 10-year Minimum All-Tenure Housing Land Requirement (MATHLR). NPF4 sets the MATHLR as 3,450 units for Moray. 1.3. The HLA identifies and provides a programme of expected housing delivery over an initial 10-year period and the years thereafter. The audit also examines past and future predicted trends in housing land supply and identifies any action required to address issues arising. This should be read in conjunction with the Moray Housing Delivery Pipeline. 1.4. HLA Guidance was published by the Scottish Government on 20 January 2025 to support a consistent approach to the method and presentation of HLA. The HLA 2024/25 implemented a number of these changes based on the Scottish Government HLA Feedback Paper from August 2023. Moray Council moved to a financial year audit in 2024, therefore completions for 2023/24 also include calendar months January to March 2023 (identified by an asterisk). The key change made this year has been modifications to the definitions for the land supply categories (see Paragraph 1.10). 1.5. The HLA is made up of two parts: the HLA Report, which provides an analysis of the housing land supply and the HLA Schedule, which collates detailed information for each site. A spreadsheet of the HLA Schedule is available on request. Methodology and Consultation 1.6. The audit has been prepared by Moray Council using details of all relevant development sites within the Moray Local Development Plan (MLDP) 2020 and other (windfall) sites with planning consent for residential use. 1.7. Completions have been recorded through contact with developers, agents and landowners, site visits and analysis of building warrant completion certificates. Constraints have been identified through the LDP process and discussions with statutory consultees. 1.8. Details of sites with a capacity of 4 or more houses are recorded and an assessment made of potential future development rates, informed by developers, agents and landowners. This takes account of planning status, infrastructure constraints, building capacity, market demand and financial plans. 1 Moray Local Development Plan 2027: Evidence Report (April 2024) Page 190
Page 191
1.9. A draft HLA was made available on the Moray Council website for consultation and notification was sent to Homes for Scotland (HfS), Cairngorms National Park Authority (CNPA), Scottish Water, BT, Scottish and Southern Electricity Networks (SSEN) as well as developers, agents and landowners. Responses to the draft HLA were considered by Moray Council in December 2025. Land Supply Definitions 1.10. There are three categories of land supply identified within the audit: Sites which are free from constraints and can be realistically programmed in the short/medium/long term. These sites contribute towards meeting the LHLR. Sites with one or more constraints that may be considered deliverable if action to overcome the constraint can be identified or if they are constrained only by a lack of market demand. These sites contribute towards meeting the LHLR. Sites with constraints which, at the base date of the audit, have no known prospect of being resolved. These sites do not contribute towards meeting the LHLR. 1.11 Deliverability factors (constraints) that could constrain the deliverability of the site include: l Land use status. l Ownership (includes programming/LONGs). l Physical conditions (e.g. slope, aspect, flood risk, contamination and pipelines). l Infrastructure (as defined under ‘Infrastructure first’ in NPF42). l Financial (e.g. construction costs, deficit funding and marketability). 2 Moray Housing Land Audit 2025/26 Deliverable Deliverable with Constraints Constrained 2 NPF4 Annex F – Glossary of definitions Page 191
Page 192
2. Completions 2.1. Table 1 identifies previous completion rates and compares actual completions to the previous year’s projected programming. 2015 2016 2017 2018 2019 2020 2021 2022 23/24* 24/25 Programmed 348 365 412 337 304 303 416 500 464 358 Actual 337 335 350 358 414 231 398 418 459 305 Difference (%) -3.2 -8.2 -15 +6.2 +36.1 -23.4 -4.3 -16.4 -1.08 -14.8 Table 1: Programmed and Actual Housing Completions 2.2 In 2024/25, there were 305 actual completions compared to the projected 358 units. This is a difference of 14.8%. This was primarily due to projected completions in Buckie not materialising, with one of the housebuilders having liquidated. 2.3 Table 2 identifies projected completion rates for the initial ten-year deliverable housing land period. These are largely based upon returns from housebuilders and landowners. As part of School Roll Forecasting, information is also provided to Education Services which includes a reduced ratio applied to projections within the Housing Land Audit for Elgin and Forres. This is due to historical accuracies demonstrating that projections can be unrealistic, particularly after Year 3, compared to actual completions (as demonstrated in Table 1 above). 25/26 26/27 27/28 28/29 29/30 30/31 31/32 32/33 33/34 34/35 403 447 387 546 492 555 509 511 486 471 Table 2: Projected completion rates Moray Housing Land Audit 2025/26 3Page 192
Page 193
3. Housing Land Supply (as at 31 March 2025) Total Site Capacity 3.1. Previously referred to as ‘Established Land Supply’, the total site capacity is the overall number of units still to be built on each site as at the audit base date of 31 March 2025. The number of units within each of the land supply categories is summarised in Table 3a and a comparison of the total site capacity with previous years is shown in Table 3b. Site Capacity Status Units Deliverable 4,935 Deliverable with Constraints 909 Total Deliverable 5,844 Constrained 6,365 Total 12,209 Table 3a: Total Site Capacity as at 31 March 2025 2021 2022 2023 2024/25 2025/26 12,346 12,192 11,770 12,461 12,209 Table 3b: Comparison of Total Site Capacity 3.2 The Total Site Capacity in 2025/26 is 12,209 units. This includes extensive areas of LONG-term land which function as a reserve and can be released should a shortfall be projected. Total Deliverable Site Capacity 3.3 Previously referred to as ‘Effective Land Supply’, the Total Deliverable Site Capacity is the total capacity of ‘Deliverable’ and ‘Deliverable with Constraints’ sites. In 2025/26, the total deliverable site capacity is 5,844 units and is shown in Table 4. 2021 2022 2023 2024/25 2025/26 5,508 5,365 5,022 5,303 5,844 Table 4: Comparison of Total Deliverable Site Capacity (previously Effective Land Supply) Deliverable Site Capacity 3.4 The Deliverable Site Capacity in 2025/26 is 4,935 units and the 10-year programming of delivery for the MLDP area is shown in Table 5. 4 Moray Housing Land Audit 2025/26 Page 193
Page 194
25/26 26/27 27/28 28/29 29/30 30/31 31/32 32/33 33/34 34/35 403 447 352 402 366 450 362 343 326 286 Table 5: Deliverable Site Capacity programmed rates Deliverable with Constraints Site Capacity 3.5 The Deliverable with Constraints Site Capacity at 2025/26 is 909 units. The 10-year programming of delivery for the MLDP area is showing Table 6. 25/26 26/27 27/28 28/29 29/30 30/31 31/32 32/33 33/34 34/35 0 0 17 67 80 102 137 106 46 69 Table 6: Deliverable with Constraints Site Capacity programmed rates Constrained Site Capacity 3.6 The Constrained Site Capacity is shown in Table 7a. 2021 2022 2023 2024/25 2025/26 6,838 6,827 6,748 7,158 6,365 Table 7a: Comparison of Constrained Site Capacity 3.7 A total of 6,365 units is constrained in 2025/26 - a reduction from 7,158 in 2024/25 which reflects the continued more proactive approach being taken to overcome constraints and explore ways of unlocking sites. Table 7b below summarises the constrained sites and the nature of the constraint. The table shows that the majority of these sites are constrained through ownership. LONG sites can only be considered deliverable when the required triggers for release of LONG sites have been met and the site is free of, or there is a commitment to overcoming, the constraints listed in paragraph 1.11. Constraint No. of Units No. of Sites Financial 240 4 Infrastructure 193 8 Ownership 1,905 17 Ownership (Programming (LONG)) 3,825 8 Physical Conditions 202 6 Total 6,365 43 Table 7b: Analysis of Constraints 3.8 Land supply (site capacity) which is only constrained by marketability are now categorised as Deliverable with Constraints and are no longer included in the Constrained Site Capacity. Moray Housing Land Audit 2025/26 5Page 194
Page 195
6 Moray Housing Land Audit 2025/26 4. Small Sites 4.1. In addition to sites with consents for a capacity of 4 units and over outwith settlements (Rest of Moray (ROM)), there are a number of consents granted for sites (both urban and rural) with a capacity of 1 to 3 units which cumulatively make a significant contribution to the housing land supply. Table 8 identifies previous completion rates. 2020 2021 2022 2023/24* 2024/25 N/A 50 70 73 60 Table 8: Small Sites completion rates 4.2 A programmed supply for small housing sites is provided in this audit based on the average of the last 5 years of small site completions and rural communities’ contribution agreed with Homes for Scotland. This will be monitored and reviewed on an annual basis. 5. Brownfield Sites 5.1. NPF4 Policy 9: Brownfield, vacant and derelict land and empty buildings aims to encourage, promote and facilitate the reuse of brownfield, vacant and derelict land and empty buildings and to help reduce the need for greenfield development. Tables 9a and b identifies previous and projected completion rates on brownfield sites. 2020 2021 2022 2023/24* 2024/25 15 55 10 18 4 5.6% Table 9a: Brownfield sites completion rates 2025/26 2026/27 2027/28 2028/29 2029/30 26 57 22 28 37 7.5% Table 9b: Brownfield sites projected completion rates 5.2 As set out in the MLDP 2027 Evidence Report, Moray Council have proposed targets of 10% and 5% of housing completions over the next 10 years for brownfield sites and within town centres, respectively. Whilst these targets are considered to be ambitious, it is recognised that this will be dependent upon availability of staff and financial resources to tackle the complexity of brownfield site redevelopment. Brownfield sites completions Percentage of total completions 2020 - 2024/25 Brownfield sites projected completions Percentage of total projected completions 2025-2030 Page 195
Page 196
6. Windfall Sites 6.1. A windfall site is a site not specifically allocated for development in the LDP but which becomes available for development or is granted planning permission during the lifetime of the Plan. Windfall completions can make a significant contribution to the land supply. 6.2. Tables 10a and b set out the previous and projected completion rates on windfall sites. 2020 2021 2022 2023/24* 2024/25 22 47 14 14 13 Table 10a: Windfall site completion rates 2025/26 2026/27 2027/28 2028/29 2029/30 39 59 15 20 23 Table 10b: Windfall site projected completion rates 6.3 Windfall sites continue to demonstrate the historical trend of varied annual completions and projections. Moray Housing Land Audit 2025/26 7Page 196
Page 197
7. Long-Term Housing Designation 7.1. Long-term (LONG) designations have been identified to set out the direction of growth and to assist in the forward planning of infrastructure and landscape enhancement/mitigation. The Council will evaluate the need for early release of long-term housing land through the annual Housing Land Audit process and monitoring report. 7.2. The release of LONG-term designations is controlled through the Policy DP3 LONG Term Land Reserves of the MLDP 2020. The triggers are a shortfall in the 10-year total deliverable site capacity (housing land supply) or shortfall in projected delivery of housing land is identified in the annual Housing Land Audits, which cannot be met by:- 1. Windfall provision assuming previous trends; 2. sites which are likely to become available for development to meet the shortfall in the relevant timeframe; or 3. Where the release of LONG-term land is required to deliver key objectives of the Council or its Community Planning Partners set out in the Local Outcome Improvement Plan, or to meet significant increased demand for housing arising from personnel deployment at RAF Lossiemouth or Kinloss Barracks. In these circumstances, an appropriate release of LONG-term land may be recommended where:- l This can be achieved without compromising delivery of a master-planned approach and where appropriate access, infrastructure and landscaping setting can be secured. l The site is demonstrated to be effective within the next five years. l Any site specific triggers are fully complied with. 7.3. The amount of land to be released will be dependent upon an assessment of what other sites will become effective to ensure a continuous 5-year deliverable site capacity. A shortfall of deliverable housing land in one of the 8 main towns should be met through a LONG-term release in the same town. 7.4. Where a decision is made to release LONG term land and there is more than one LONG term site is that settlement, an assessment will be made as to which site is considered the most suitable based on considerations such as infrastructure, landscaping, settlement pattern and effectiveness. 7.5. Outwith the eight main towns, LONG term sites will only be considered for early release where the residential land designations are clearly demonstrated to be constrained for the entire plan period and that constraint cannot be overcome. 8 Moray Housing Land Audit 2025/26 Page 197
Page 198
Table 11: LONG Term Sites Moray Housing Land Audit 2025/26 9 Settlement Alves Buckie Burghead Elgin Elgin Fochabers Forres Keith Urquhart Site North South West Clarkly Hill North East South Ordiquish Road East Lochyhill Nursery Field Meft Road Comment/Triggers No deliverable site capacity. Total deliverable site capacity of 761 units in LHMA, projected 10- year completions of 650 units. Total deliverable site capacity of 2,766 units in LHMA, projected 10-year completions of 84 units. Total deliverable site capacity of 2,766units in LHMA, projected 10- year completions of 1,691 units. Total deliverable site capacity of 2,766 units in LHMA, projected 10-year completions of 1,691 units. Total deliverable site capacity of 2,205 units in LHMA, projected 10-year completions of 78 units. Total deliverable site capacity of 1,135 units in LHMA, projected 10-year completions of 563 units . Total deliverable site capacity of 210 units in LHMA, projected 10- year completions of 166 units. Total deliverable site capacity of 2,205 units in LHMA, projected 10-year completions of 24 units. Recommendation No requirement to release. Part of the site received planning permission in 2024/25. No requirement to release remainder of site (see para 8.3). No requirement to release. No requirement to release. Amendment to Elgin South phasing approved in 2021. No requirement to release. No requirement to release. No requirement to release. Site released in 2023. No requirement to release. Page 198
Page 199
8. Housing Land Requirement & Total Deliverable Site Capacity 8.1. The Council’s HNDA 2017 has informed the housing land supply and housing completions targets set out in the MLDP2020. These have been updated in the Evidence Report submitted to the Scottish Government as part of the preparation of the MLDP 2027 and are based upon the HNDA 2023, which has been signed off as robust and credible by the Scottish Government's Centre for Housing Market Analysis. The key targets reflect the MATHLR set out in NPF4 and are: l Annual housing completion target (HNDA Growth scenario) - 440 units l Annual total deliverable site capacity target - 500 units 8.2. Using these figures gives a 10-year completion target of 4,400 units and a 10-year total deliverable site capacity target of 5,000 units. Site Capacity No. of years supply Total 12,209 24.4 Total Deliverable 5,844 11.6 Constrained 6,365 12.7 Table 12a: Site Capacity and Supply 10 Moray Housing Land Audit 2025/26 Page 199
Page 200
Table12b: Deliverable Site Capacity and completion targets by LHMA. 8.3 Whilst it appears there is a deficit of deliverable site capacity in the Buckie HMA, projections include sites which are currently constrained. The increase in projected completions reflects the focus of projects such as the Growth Deal Housing Mix in overcoming constrained development in the coastal settlements. 8.4 The totals of the total deliverable, constrained and total site capacities are set out in Table 12c below. 2020 2021 2022 2023 2024/25 2025/26 Total Deliverable 5,638 5,508 5,365 5,022 5,303 5,844 Constrained 6,890 6,838 6,827 6,748 7,158 6,365 Total Site Capacity 12,528 12,346 12,192 11,770 12,461 12,209 Table 12c: Moray Total Site Capacity 2025/26 Moray Housing Land Audit 2025/26 11 Comments Deficit of deliverable site capacity. Surplus of deliverable site capacity. Surplus of deliverable site capacity. Surplus of deliverable site capacity. Surplus of deliverable site capacity. Surplus of deliverable site capacity. 10 year completion target (10 x 440) 4,400 10 year projected completions 1,005 2,325 757 286 434 4,807 10 year total deliverable site capacity 2025-2034 893 2,898 1,267 342 444 5,844 10 year total deliverable site capacity target (10 x 500) 727 2,728 741 427 377 5,000 LHMA Buckie Elgin Forres Keith Speyside Total Page 200
Page 201
12 Moray Housing Land Audit 2025/26 TOW N ABERLOUR ALVES ARCHIESTOW N BUCKIE BURGHEAD CRAIGELLACHIE CULLEN CUM M INGSTON DALLAS DUFFTOW N DYKE ELGIN FINDHORN FINDOCHTY FOCHABERS FORRES GARM OUTH / KINGSTON HOPEM AN KEITH KINLOSS LHANBRYDE LOSSIEM OUTH M OSSTODLOCH NEW M ILL PORTGORDON PORTKNOCKIE RAFFORD REM AINDER OF M ORAY ROTHES ROTHIEM AY TOM INTOUL URQUHART Total 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 0 0 138 9 2 75 6 0 18 60 308 41 26 0 162 9 5 41 10 30 1 18 60 403 33 35 1 1 188 11 8 58 16 2 12 18 60 4 447 2 1 67 8 0 0 109 2 8 34 8 6 3 20 17 10 12 12 60 4 4 387 2 73 8 12 20 1 1 180 1 8 64 8 6 5 42 12 10 12 60 15 4 2 546 1 4 44 14 12 0 0 171 12 8 63 8 16 3 27 12 10 12 60 15 492 3 72 8 12 1 20 1 205 16 3 63 8 36 5 12 10 12 60 4 4 555 4 76 12 11 2 25 132 16 8 82 2 8 26 3 12 10 12 60 4 4 509 30 3 77 14 2 20 171 16 10 52 2 3 26 3 12 10 60 511 4 105 10 2 20 188 10 42 2 10 3 17 60 10 3 486 3 75 10 20 185 10 64 2 10 2 17 60 10 3 471 250 18 451 130 10 4 5 4625 97 1070 2 115 76 420 10 60 20 35 4 7,402 Page 201
Page 202
9. Glossary Moray Housing Land Audit 2025/26 13 Constrained site Sites with constraints which, at the base date of the audit, have no known prospect of being resolved. These sites do not contribute towards meeting the LHLR. Deliverable site Sites which are free from constraints and can be realistically programmed in the short/medium/long term. These sites contribute towards meeting the LHLR. Deliverable with constraints site Sites with one or more constraints that may be considered deliverable if action to overcome the constraint can be identified or if they are constrained only by a lack of market demand. These sites contribute towards meeting the LHLR. Deliverable housing pipeline The expected sequencing of the Local Housing Land Requirement over the short (1-3 years), medium (4-6 years) and long-term (7-10 years), as set out in the Local Development Plan Delivery Programme. Delivery Programme A document which sets out how the Local Development Plan will be delivered. Evidence Report Supporting document to the Local Development Plan which summarises the evidence base for proposals and policies set out in the development plan. Housing Land Audit (HLA) Annual audit which monitors the delivery of housing land, including past completions and future programming. Housing Needs and Demand Assessment (HNDA) A tool used to estimate housing need and demand across various housing tenures to inform the development of the Local Housing Strategy and Local Development Plan. Local Housing Market Area (LHMA) A geographical area defined by household demand and preferences for all types of housing, reflecting the key functional linkages between places where people live and work. Local Housing Strategy (LHS) Strategy that sets out the outcomes that the Council and its partners want to achieve, and the action they will take, to address housing need and demand in their areas. Local Development Plan (LDP) A plan in which it is sets out, for land in the part of the district to which it relates: l a spatial strategy, being a detailed statement of the planning authority's policies and proposals as to the development and use of the land; l such other matters as may be prescribed; and l any other matter which the planning authority consider it appropriate to include. Local Housing Land Requirement (LHLR) The amount of land required for housing, as identified by the LDP. The LHLR is expected to exceed the 10-year Minimum All-Tenure Housing Land Requirement (MATHLR) set out in the National Planning Framework. Page 202
Page 203
Minimum All-Tenure Housing Land Requirement (MATHLR) The minimum amount of land, by reference to the number of housing units, that is to be provided by each planning authority in Scotland for a 10-year period, as set out in NPF4 Annex E. The MATHLR is expected to be exceeded in the LDP’s LHLR. National Planning Framework (NPF) 4 A long-term plan looking to 2045 that guides spatial development, sets out national planning policies, designates national developments and highlights regional spatial priorities. The following definitions and classification in the schedules apply: 14 Moray Housing Land Audit 2025/26 Site Ref Area/Settlement or Parish/Residential/Sequential Reference Number. Location Address of Site. Owner Current owner of the site. Developer Agency responsible for the development and management of the site and not necessarily to the actual construction company. Tenure Five tenure types are specified:- HA - Housing Association for rent LA - Local Authority PRIV - Private MOD - Ministry of Defence Other - Other tenure, i.e. housing association shared ownership or low cost home ownership and joint venture between a local authority and a private developer. Area Site areas are quoted in hectares and represent the gross area of the site. Units The capacity of sites is expressed as a number of house units. For sites where no detailed housing layout has yet been prepared and no density has been specified, then an estimate has been made. Serviced Indicates the number of housing units which are serviced. Not built Total number of house units on the site which have not yet been built at the date of the update. Effective Currently effective (EFF) or constrained (CON) LPR Local Plan Site Reference Page 203
Page 204
Moray Housing Land Audit 2025/26 15 Land Use Categorises the main existing or former use of a site before it is re-zoned or developed. The land use categories used are:- AGR 1-7 Agricultural Land by Class (1, 2 & 3. 1 = prime) AG BLDG Agricultural Building WOOD Woodlands (may also be grazed) HORT Allotments and nurseries PRIV/PUB OS Privately or publicly owned open space (e.g. Grounds of a large house or hospital) RESID Residential COMM Commercial EDUC Educational RAIL Railway MOD Ministry of Defence PUB BLD Public Building UNUSED Derelict, Vacant, Backland etc. COMMTY Community IND Industry Greenfield/ Describes whether the site is within an urban area or previously developed Brownfield (brownfield) or outwith the urban area and not previously developed (green field). APPLICATION DETAILS Applic Ref Reference number of planning applications relating to the development of the site. Note where applications are made for individual plots within a site, these have been grouped together under the Application Reference ‘Individs’ with no decision date given. Units Number of units relating to each planning application. Type Describes the type of permission application:- OUT Application for Outline Planning Permission DET Application for Full Permission or Permission of Reserved Matters Decision Details of decision on the application. Apart from self explanatory terms – Approved, Refused, Withdrawn, Expired, Pending, it has been necessary to indicate the latest classified either as ‘Superseded’ or ‘Duplicate’. Dec. Date Date of final decision on the application. COMPLETION DETAILS Built Take up rates (in house units) for the previous 5 years are listed on an annual basis and assessments of subsequent completions are also listed annually for the next 5 years. Page 204
Page 205
The Moray Council Housing Land Audit 2025DELIVERABLE HOUSING LAND SUPPLY Reference Location Developer Undeveloped (Units)OwnerLocal Plan ABERLOUR 9TOMBAIN FARMM/AB/R/010 Mr Simon Gibbs20/R1 100SPEYVIEW Springfield Properties PlcM/AB/R/15/04 Springfield Properties & Moray Coun20/R2 Total Town Units 109 Total Town Site 2 ARCHIESTOWN 20EAST ENDM/AR/R/07/01 Mr Edward Aldridge20/R1 4SOUTH LANEM/AR/R/15/02 Mr Robert Gordon & Mr Alan Williams20/R2 6WEST ENDM/AR/R/15/03 Mrs Anne Ogg20/R3 10SOUTH OF VIEWMOUNTM/AR/R/15/04 Mr Robert Gordon20/R4 Total Town Units 40 Total Town Site 4 BUCKIE 5PARKLANDS MPD HomesM/BC/R/035 MPD Homes15/R2 20MILLBANK GARAGE MPD HomesM/BC/R/041 MPD Homes20/OPP7 140LAND AT MUIRTONM/BC/R/20/07 Mr Alan Durno20/R7 250LAND AT BARHILL ROAD Springfield Properties PlcM/BC/R/20/08 Mr Michael Watt20/R8 100HIGH STREET (W)M/BC/R/20/MU 20/MU 11MILL OF BUCKIEM/BC/R/20/W1 Mr Fredrick Parkes20/R10 Total Town Units 526 Total Town Site 6 BURGHEAD 14NORTH QUAYM/BH/R/006 Unknown (A) and Margery Bray (B)20/R1 80CLARKLY HILL Tulloch of CummingstonM/BH/R/04 Tulloch of Cummingston20/R2 Total Town Units 94 Total Town Site 2 Page 205
Page 206
The Moray Council Housing Land Audit 2025DELIVERABLE HOUSING LAND SUPPLY Reference Location Developer Undeveloped (Units)OwnerLocal Plan CRAIGELLACHIE 12BRICKFIELDM/CR/R/003 Strathdee Properties20/R3 Total Town Units 12 Total Town Site 1 CULLEN 55SEAFIELD ROADM/CL/R/15/02 Seafield Estate20/R1 Total Town Units 55 Total Town Site 1 CUMMINGSTON 3SEAVIEW ROAD Tulloch of CummingstonM/CM/R/02 Tulloch of Cummingston20/R1 Total Town Units 3 Total Town Site 1 DUFFTOWN 5OLD MART ROADM/DF/R/012 Moray Council20/OPP1 100HILLSIDE FARMM/DF/R/15/03 Mr James Wiseman20/R1 Total Town Units 105 Total Town Site 2 DYKE 3FIR PARK ROADM/DY/R/20/03 Ms Ros Davidson20/R3 Total Town Units 3 Total Town Site 1 Page 206
Page 207
The Moray Council Housing Land Audit 2025DELIVERABLE HOUSING LAND SUPPLY Reference Location Developer Undeveloped (Units)OwnerLocal Plan ELGIN 102BILBOHALL SOUTH Grampian Housing A.M/EL/R/07/05 Grampian Housing A.20/R3 8THE FIRS, BILBOHALL Moray CouncilM/EL/R/093 Moray Council20/R7 85KNOCKMASTING WOOD Scotia HomesM/EL/R/15/12 Scotia Homes20/R6 10HAMILTON DRIVE MPD HomesM/EL/R/15/13 20/R9 70LESMURDIE FIELDS Robertson Residential GroupM/EL/R/15/14 Robertson Residential Group20/R13 106EDGAR ROADM/EL/R/20/02 Moray Council20/R2 609EASTER LINKWOOD AND LINKWOOD Springfield Properties PlcM/EL/R/20/19 Mr Ian Robertson20/R19 6GLASSGREEN, ELGIN SOUTH Springfield Properties PlcM/EL/R/20/20 Springfield Properties Plc20/R20 584ELGIN SOUTH (GRASSGREEN, BURNSIDE & CEMETERY) Springfield Properties PlcM/EL/R/21/L2 Springfield Properties Plc20/LONG2 24BAIN AVENUE Springfield Properties PlcM/EL/R/23/01 20/ENV2+3 173FINDRASSIE (E PARCEL) Barratt Homes/David Wilson HomesM/EL/R/23/02 Barratt Homes20/R11 266FINDRASSIE (D PARCEL) Robertson Residential GroupM/EL/R/23/03 Pitgaveny Estate20/R11 12OLDMILLS ROAD Tulloch of CummingstonM/EL/R/23/W1 Tulloch of Cummingston20/ENV6 38SOUTH STREET Moray Council/Robertson GroupM/EL/R/25/01 Moray Council/Robertson Group 21161-163 HIGH STREET (POUNDLAND) M/EL/R/TC/01 Poundland Elgin Ltd20/TC 442 BATCHEN STREETM/EL/R/TC/04 Mr Richard Ham20/TC Total Town Units 2118 Total Town Site 16 FINDHORN 2HEATHNEUKM/FH/R/009 Mr Tim Clark20/R1 20NORTH WHINS Duneland LtdM/FH/R/11 1RESIDENTIAL CARAVANSM/FH/R/20/RC 20/RC Total Town Units 23 Total Town Site 3 Page 207
Page 208
The Moray Council Housing Land Audit 2025DELIVERABLE HOUSING LAND SUPPLY Reference Location Developer Undeveloped (Units)OwnerLocal Plan FINDOCHTY 60MORVEN CRESCENTM/FN/R/009 Seafield Estate20/R1 Total Town Units 60 Total Town Site 1 FOCHABERS 40ORDIQUISH ROAD Bob Milton PropertiesM/FO/R/07/01 Bob Milton Properties20/R1 50ORDIQUISH ROAD WEST Bob Milton PropertiesM/FO/R/07/02 Bob Milton Properties20/R2 50ORDIQUISH ROAD EASTM/FO/R/20/04 Crown Estate Scotland20/R4 Total Town Units 140 Total Town Site 3 FORRES 48CAROLINE STREETM/FR/R/060 AES Solar20/OPP1 79FERRYLEA Springfield Properties PlcM/FR/R/07/03 Springfield Properties Plc20/R2 40MANNACHIE Tulloch of CummingstonM/FR/R/07/08 Tulloch of Cummingston20/R4 136DALLAS DHUM/FR/R/15/10 Altyre Estate20/R6 260LOCHYHILL (AREA A) Robertson Residential GroupM/FR/R/23/01 White Family20/R3 500LOCHYHILL (AREA B) Robertson Residential GroupM/FR/R/23/02 White Family20/R3 4CHAPELTON FARM Tulloch of CummingstonM/FR/R/24/W1 Tulloch of Cummingston Total Town Units 1067 Total Town Site 7 HOPEMAN 69MANSE ROAD Tulloch of CummingstonM/HP/R/15/R1 Tulloch of Cummingston20/R1 Total Town Units 69 Total Town Site 1 Page 208
Page 209
The Moray Council Housing Land Audit 2025DELIVERABLE HOUSING LAND SUPPLY Reference Location Developer Undeveloped (Units)OwnerLocal Plan KEITH 6BALLOCH ROADM/KH/R/030 Mr and Mrs N. Howie20/R3 58BANFF ROAD NORTH Springfield Properties PlcM/KH/R/07/08 Moray Council20/R4 12NEWMILL SOUTH ROADM/KH/R/15/036 ACE Roofing (Keith)20/OPP3 70NURSERY FIELD LONG1M/KH/R/20/LG1 Moray Council20/LONG1 50BANFF ROAD SOUTHM/KH/R/20/MU 20/MU 4138-140 MID STREETM/KH/R/TC/02 Mr Barry Fettes Total Town Units 200 Total Town Site 6 KINLOSS 6WEST OF SEAPARK HOUSEM/KN/R/003 Seapark Estate Ltd20/R1 1FINDHORN ROAD WEST MPD HomesM/KN/R/009 MPD Homes20/R2 23DAMHEADM/KN/R/07/04 The Rhind 2008 Discretionary Trust20/R3 Total Town Units 30 Total Town Site 3 LHANBRYDE 77WEST OF ST ANDREWS ROAD Springfield Properties PlcM/LH/R/07/01 Springfield Properties Plc20/R1 24GARMOUTH ROAD Grampian Housing AssociationM/LH/R/20/02 Moray Council20/R2 Total Town Units 101 Total Town Site 2 LOSSIEMOUTH 17INCHBROOM Tulloch of CummingstonM/LS/R/023 Tulloch of Cummingston20/R3 21WEST BASIN, LOSSIEMOUTH MARINA Oakbank HomesM/LS/R/039 185SUNBANK/KINNEDDAR Tulloch of CummingstonM/LS/R/07/01 Tulloch of Cummingston20/R1 Total Town Units 223 Total Town Site 3 Page 209
Page 210
The Moray Council Housing Land Audit 2025DELIVERABLE HOUSING LAND SUPPLY Reference Location Developer Undeveloped (Units)OwnerLocal Plan PORTGORDON 60WEST OF REID TERRACEM/PG/R/07/04 Colin Murray Developments20/R1 Total Town Units 60 Total Town Site 1 PORTKNOCKIE 60SEABRAESM/PK/R/004 Seafield Estate20/R1 Total Town Units 60 Total Town Site 1 RAFFORD 12BROCHLOCHM/RF/R/07/01 Finderne Development Trust20/R1 Total Town Units 12 Total Town Site 1 REMAINDER OF MORAY 660SITES BELOW 5 HOUSES PRIVATEM/RM/R/999B PRIVATELDP Total Town Units 660 Total Town Site 1 ROTHES 30SPEY STREETM/RS/R/07/01 Mr & Mrs Scott20/R1 Total Town Units 30 Total Town Site 1 ROTHIEMAY 10CASTLE TERRACEM/RT/R/001 Mr Robert Thain20/R1 Total Town Units 10 Total Town Site 1 Page 210
Page 211
The Moray Council Housing Land Audit 2025DELIVERABLE HOUSING LAND SUPPLY Reference Location Developer Undeveloped (Units)OwnerLocal Plan TOMINTOUL 8CONGLASS LANEM/TO/R/21/01 Crown Estate ScotlandCNPA21/H1 8LECHT DRIVEM/TO/R/21/02 Crown Estate ScotlandCNPA21/H2 Total Town Units 16 Total Town Site 2 URQUHART 10MEFT ROAD Findrassie Developments LtdM/UR/R/20/01 Findrassie Developments Ltd20/R1 8STATION ROADM/UR/R/20/02 Mr Ian Dean20/R2 Total Town Units 18 Total Town Site 2 5844Total Deliverable Housing Land Supply 75Total Sites Page 211
Page 212
The Moray Council Housing Land Audit 2025CONSTRAINED HOUSING LAND SUPPLY Reference Location Developer Undeveloped (Units)OwnerLocal Plan Constraint Details ALVES 250 OwnershipConstrainedALVES NORTHM/AL/R/15/LON The Moray Council20/LONG Total Town Units 250 Total Town Sites 1 BUCKIE 60 InfrastuctureConstrainedRATHBURN (N)M/BC/R/015 Reidhaven Estate20/R3 60 OwnershipConstrainedRATHBURN (S)M/BC/R/07/07 Reidhaven Estate20/R4 200 FinancialConstrainedHIGH STREET (E)M/BC/R/07/10 J.M. Watt20/R5 5 OwnershipConstrainedSITE AT ARDACH HEALTH CENTREM/BC/R/20/09 Moray Council20/R9 250 OwnershipConstrainedLAND TO SOUTH WEST OF BUCKIE Springfield Properties PlcM/BC/R/20/LG1 Mr Michael Watt20/LONG1 Total Town Units 575 Total Town Sites 5 BURGHEAD 40 Physical ConditionsConstrainedWEST FORESHORE Tulloch of CummingstonM/BH/R/012 Moray Council/ToC/John Gordon20/OPP1 80 OwnershipConstrainedLONG1 CLARKLY HILL Tulloch of CummingstonM/BH/R/20/LNG Tulloch of Cummingston20/LONG1 Total Town Units 120 Total Town Sites 2 CRAIGELLACHIE 5 Physical ConditionsConstrainedEDWARD AVENUEM/CR/R/001 Bacardi20/R1 5 OwnershipConstrainedFORMER BREWERY, SPEY ROADM/CR/R/004 Bacardi20/R2 Total Town Units 10 Total Town Sites 2 DALLAS 6 InfrastuctureConstrainedDALLAS SCHOOL WESTM/DA/R/001 Dallas Estate20/R1 4 FinancialConstrainedFORMER FILLING STATIONM/DA/R/002 Mr Ian Thomson20/R3 Total Town Units 10 Total Town Sites 2 Page 212
Page 213
The Moray Council Housing Land Audit 2025CONSTRAINED HOUSING LAND SUPPLY Reference Location Developer Undeveloped (Units)OwnerLocal Plan Constraint Details DYKE 5 InfrastuctureConstrainedSOUTH DARKLASS ROADM/DY/R/15/02 Mr Grant Davidson20/R2 Total Town Units 5 Total Town Sites 1 ELGIN 40 InfrastuctureConstrainedBILBOHALL NORTH Robertson Residential GroupM/EL/R/048 Robertson Residential Group20/R1 107 Physical ConditionsConstrainedSOUTH WEST OF ELGIN HIGH SCHOOL M/EL/R/07/06 Mr Dean Andersson20/R4 12 InfrastuctureConstrainedNEWFIELD HOUSE, LOSSIEMOUTH ROAD M/EL/R/081 Mr Ian Aitkenhead 20 OwnershipConstrainedPALMERS CROSSM/EL/R/082 Edgar Road Properties Ltd20/R21 190 OwnershipConstrainedBARMUCKITY Springfield Properties PlcM/EL/R/088 Mr Ian Robertson20/R16 50 OwnershipConstrainedSPYNIE HOSPITALM/EL/R/094 NHS Grampian20/R14 1800 OwnershipConstrainedLONG1 A/B NORTH EASTM/EL/R/15/LNE Pitgaveny Estate20/LONG1 50 OwnershipConstrainedBILBOHALL WESTM/EL/R/20/05 Mr Dean Anderson20/R5 150 OwnershipConstrainedFINDRASSIE (R12 PARCEL)M/EL/R/20/12 Pitgaveny Estate20/R12 1000 OwnershipConstrainedELGIN SOUTH LONG2 Springfield Properties PlcM/EL/R/20/L2 20/LNG2 260 OwnershipConstrainedFINDRASSIE (W PARCEL)M/EL/R/23/04 Pitgaveny Estate20/R11 519 OwnershipConstrainedFINDRASSIE (N PARCEL)M/EL/R/23/05 Pitgaveny Estate20/R11 Total Town Units 4198 Total Town Sites 12 FOCHABERS 35 OwnershipConstrainedORDIQUISH ROAD EAST LONGM/FO/R/15/LG Crown Estate Scotland20/LONG Total Town Units 35 Total Town Sites 1 Page 213
Page 214
The Moray Council Housing Land Audit 2025CONSTRAINED HOUSING LAND SUPPLY Reference Location Developer Undeveloped (Units)OwnerLocal Plan Constraint Details FORRES 24 FinancialConstrainedAUCTION MART, TYTLER STREET Cairn Housing AssociaionM/FR/R/057 20/OPP4 400 OwnershipConstrainedLOCHYHILL LONG1M/FR/R/07/11 White Family20/LONG1 12 FinancialConstrainedBALNAGEITH Tulloch of CummingstonM/FR/R/15/08 Tulloch of Cummingston20/R5 40 Physical ConditionsConstrainedPILMUIR ROAD WESTM/FR/R/15/11 G & AG Proctor20/R7 90 OwnershipConstrainedLOCHYHILL (AREA C) Robertson Residential GroupM/FR/R/23/03 White Family20/R3 Total Town Units 566 Total Town Sites 5 GARMOUTH/KINGSTON 10 InfrastuctureConstrainedSOUTH OF INNES ROADM/GM/R/15/01 20/R1 Total Town Units 10 Total Town Sites 1 KEITH 36 OwnershipConstrainedDUNNYDUFF ROADM/KH/R/015 Various20/R2 40 InfrastuctureConstrainedEDINDIACH ROAD (EAST)M/KH/R/07/15 20/R8 5 Physical ConditionsConstrainedDENWELL ROADM/KH/R/20/08 20/R7 Total Town Units 81 Total Town Sites 3 MOSSTODLOCH 60 OwnershipConstrainedGARMOUTH ROADM/MS/R/15/02 Crown Estate Scotland20/R2 10 OwnershipConstrainedBALNACOULM/MS/R/20/03 Forestry and Land Scotland20/OPP1 350 OwnershipConstrainedSOUTH OF A96M/MS/R/20/MU Crown Estate Scotland20/MUL1 Total Town Units 420 Total Town Sites 3 Page 214
Page 215
The Moray Council Housing Land Audit 2025CONSTRAINED HOUSING LAND SUPPLY Reference Location Developer Undeveloped (Units)OwnerLocal Plan Constraint Details NEWMILL 10 OwnershipConstrainedISLA ROADM/NM/R/001 Newmill Estate20/R1 Total Town Units 10 Total Town Sites 1 ROTHES 40 OwnershipConstrainedGREEN STREETM/RS/R/15/02 Mr Stewart Meldrum20/R2 Total Town Units 40 Total Town Sites 1 ROTHIEMAY 5 Physical ConditionsConstrainedANDERSON DRIVEM/RT/R/07/02 Mrs H. Mackenzie20/R2 20 InfrastuctureConstrainedDEVERONSIDE ROADM/RT/R/15/03 The Church of Scotland20/R3 Total Town Units 25 Total Town Sites 2 URQUHART 10 OwnershipConstrainedMEFT ROAD LONG1M/UR/R/20/L1 Rattray Family20/LNG1 Total Town Units 10 Total Town Sites 1 6365Total Constrained Housing Land Supply 43Total Sites Page 215
Page 216
SITE REF: M/AB/R/010 LOCATION: TOMBAIN FARM Units Not Built Total Units 10Capacity: Planning Applications: ABERLOUR The Moray Council Housing Land Audit 2025 Easting: 326135 Northing: 842322 Area (Ha): 2.18 Primary School: Aberlour Primary School Secondary School: Speyside High School Ward: Speyside Glenlivet Effective Land 9 Supply Type: Deliverable LPR: 20/R1 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: Detail House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Agricultural Land Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2003 Effective Land: 2003 Owner: Mr Simon Gibbs Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 24/00376 Full Approved 30/05/2025 Plot 5 20/00317 5 Full Approved 29/03/2022 Phase 1 18/01457 Full Approved 13/02/2019 Plot 12 16/01350 Full Approved 20/10/2016 Plot 12 13/01619 Full Approved 11/11/2013 Extend planning consent (07/01651) 13/01618 Full Approved 31/10/2013 Extend planning consent (07/01634) 07/01651 7 Full Appeal 05/09/2008 Approved on appeal 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 0 2 2 2 2 1 9 10Market 0Affordable 9 4Flat 6House Page 216
Page 217
SITE REF: M/AB/R/15/04 LOCATION: SPEYVIEW Units Not Built Total Units 100Capacity: Planning Applications: ABERLOUR The Moray Council Housing Land Audit 2025 Easting: 325786 Northing: 841867 Area (Ha): 14.02 Primary School: Aberlour Primary School Secondary School: Speyside High School Ward: Speyside Glenlivet Effective Land 100 Supply Type: Deliverable LPR: 20/R2 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: Detail/Under Construction House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Agricultural Land Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2015 Effective Land: 2018 Owner: Springfield Properties & Moray Developer: Springfield Properties Plc Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 24/00043 31 Full Approved 17/06/2024 Phase 2 23/00494 39 Full Approved 21/12/2023 Phase 1 21/00348 Full Expired 19/04/2022 Plot substitution (private to affordable) 18/01373 39 Full Expired 12/11/2019 Phase 1 18/01132 PAN for residential development 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 39 31 30 100 22Market 78Affordable 100 20Flat 50House 30Unknown Page 217
Page 218
SITE REF: M/AL/R/15/LON LOCATION: ALVES NORTH Units Not Built Total Units 250Capacity: Planning Applications: ALVES The Moray Council Housing Land Audit 2025 Easting: 313538 Northing: 862518 Area (Ha): 23.11 Primary School: Alves Primary School Secondary School: Forres Academy Ward: Heldon And Laich Effective Land 0 Supply Type: Constrained LPR: 20/LONG Tenure: Projected Completions: Constrained Land 250 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Ownership Land Use Type: Agricultural Land Constraint Notes: Programming (LONG) and ownership Dispute: Agreed Windfall: No Established Land: 2015 Effective Land: Owner: The Moray Council Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 250 250 187Market 63Affordable 250Unknown Page 218
Page 219
SITE REF: M/AR/R/07/01 LOCATION: EAST END Units Not Built Total Units 20Capacity: Planning Applications: ARCHIESTOWN The Moray Council Housing Land Audit 2025 Easting: 323338 Northing: 844111 Area (Ha): 1.28 Primary School: Knockando Primary School Secondary School: Speyside High School Ward: Speyside Glenlivet Effective Land 20 Supply Type: Deliverable LPR: 20/R1 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Agricultural Land Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2007 Effective Land: 2007 Owner: Mr Edward Aldridge Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 3 3 3 3 3 3 2 20 15Market 5Affordable 18 20Unknown Page 219
Page 220
SITE REF: M/AR/R/15/02 LOCATION: SOUTH LANE Units Not Built Total Units 4Capacity: Planning Applications: ARCHIESTOWN The Moray Council Housing Land Audit 2025 Easting: 323201 Northing: 844079 Area (Ha): 0.58 Primary School: Knockando Primary School Secondary School: Speyside High School Ward: Speyside Glenlivet Effective Land 4 Supply Type: Deliverable with Constraints LPR: 20/R2 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Financial Land Use Type: Agricultural Land Constraint Notes: Marketability Dispute: Agreed Windfall: No Established Land: 2015 Effective Land: Owner: Mr Robert Gordon & Mr Alan W Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 06/02500 1 Outline Refused 18/12/2006 05/01395 1 Full Refused 18/11/2005 05/01605 1 Outline Refused 28/10/2005 05/00780 1 Outline Refused 21/07/2005 06/00933 1 Full Withdrawn 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 1 1 1 1 4 3Market 1Affordable 4 4Unknown Page 220
Page 221
SITE REF: M/AR/R/15/03 LOCATION: WEST END Units Not Built Total Units 6Capacity: Planning Applications: ARCHIESTOWN The Moray Council Housing Land Audit 2025 Easting: 322922 Northing: 843982 Area (Ha): 0.77 Primary School: Knockando Primary School Secondary School: Speyside High School Ward: Speyside Glenlivet Effective Land 6 Supply Type: Deliverable with Constraints LPR: 20/R3 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Financial Land Use Type: Agricultural Land Constraint Notes: Marketability Dispute: Agreed Windfall: No Established Land: 2015 Effective Land: Owner: Mrs Anne Ogg Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 6 6 4Market 2Affordable 6Unknown Page 221
Page 222
SITE REF: M/AR/R/15/04 LOCATION: SOUTH OF VIEWMOUNT Units Not Built Total Units 10Capacity: Planning Applications: ARCHIESTOWN The Moray Council Housing Land Audit 2025 Easting: 323022 Northing: 843927 Area (Ha): 1.32 Primary School: Knockando Primary School Secondary School: Speyside High School Ward: Speyside Glenlivet Effective Land 10 Supply Type: Deliverable with Constraints LPR: 20/R4 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Financial Land Use Type: Agricultural Land Constraint Notes: Marketability Dispute: Agreed Windfall: No Established Land: 2015 Effective Land: Owner: Mr Robert Gordon Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 10 10 7Market 3Affordable 10Unknown Page 222
Page 223
SITE REF: M/BC/R/015 LOCATION: RATHBURN (N) Units Not Built Total Units 60Capacity: Planning Applications: BUCKIE The Moray Council Housing Land Audit 2025 Easting: 343833 Northing: 866135 Area (Ha): 2.44 Primary School: Portessie Primary School Secondary School: Buckie High School Ward: Buckie Effective Land 0 Supply Type: Constrained LPR: 20/R3 Tenure: Projected Completions: Constrained Land 60 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Infrastucture Land Use Type: Agricultural Land Constraint Notes: Road access Dispute: Agreed Windfall: No Established Land: Effective Land: Owner: Reidhaven Estate Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 60 60 45Market 15Affordable 60Unknown Page 223
Page 224
SITE REF: M/BC/R/035 LOCATION: PARKLANDS Units Not Built Total Units 54Capacity: Planning Applications: BUCKIE The Moray Council Housing Land Audit 2025 Easting: 342831 Northing: 864624 Area (Ha): 3.21 Primary School: Cluny Primary School Secondary School: Buckie High School Ward: Buckie Effective Land 5 Supply Type: Deliverable LPR: 15/R2 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: Detail House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Agricultural Land Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2003 Effective Land: 2003 Owner: MPD Homes Developer: MPD Homes Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 19/00819 Full Approved 02/09/2019 Plot 33 19/00657 Full Approved 01/08/2019 Plot 30 11/01818 54 Full Approved 10/01/2012 08/00951 54 Full Approved 10/05/2010 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 1 2 2 5 54Market 5 49House 5Unknown Page 224
Page 225
SITE REF: M/BC/R/041 LOCATION: MILLBANK GARAGE Units Not Built Total Units 20Capacity: Planning Applications: BUCKIE The Moray Council Housing Land Audit 2025 Easting: 342573 Northing: 865455 Area (Ha): 0.18 Primary School: Cluny Primary School Secondary School: Buckie High School Ward: Buckie Effective Land 20 Supply Type: Deliverable LPR: 20/OPP7 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: Detail/Under Construction House Programme:Adopted Local Plan: Green/Brown: Brown Constraint Type: Land Use Type: Commercial Constraint Notes: Dispute: Agreed Windfall: Yes Established Land: 2010 Effective Land: 2024 Owner: MPD Homes Developer: MPD Homes Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 08/01098 20 Full Approved 22/01/2009 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 6 5 5 4 20 20Market 20 20Flat Page 225
Page 226
SITE REF: M/BC/R/07/07 LOCATION: RATHBURN (S) Units Not Built Total Units 60Capacity: Planning Applications: BUCKIE The Moray Council Housing Land Audit 2025 Easting: 344006 Northing: 866047 Area (Ha): 5.88 Primary School: Portessie Primary School Secondary School: Buckie High School Ward: Buckie Effective Land 0 Supply Type: Constrained LPR: 20/R4 Tenure: Projected Completions: Constrained Land 60 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Ownership Land Use Type: Agricultural Land Constraint Notes: Prrogramming (R5 to be substantially complete) Dispute: Agreed Windfall: No Established Land: 2007 Effective Land: Owner: Reidhaven Estate Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 60 60 45Market 15Affordable 60Unknown Page 226
Page 227
SITE REF: M/BC/R/07/10 LOCATION: HIGH STREET (E) Units Not Built Total Units 170Capacity: Planning Applications: BUCKIE The Moray Council Housing Land Audit 2025 Easting: 343235 Northing: 864455 Area (Ha): 11.13 Primary School: Millbank Primary School Secondary School: Buckie High School Ward: Buckie Effective Land 0 Supply Type: Constrained LPR: 20/R5 Tenure: Projected Completions: Constrained Land 200 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Financial Land Use Type: Agricultural Land Constraint Notes: Marketability Dispute: Agreed Windfall: No Established Land: 2007 Effective Land: Owner: J.M. Watt Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 08/00753 162 Withdrawn 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 10 190 200 150Market 50Affordable 10 200Unknown Page 227
Page 228
SITE REF: M/BC/R/20/07 LOCATION: LAND AT MUIRTON Units Not Built Total Units 140Capacity: Planning Applications: BUCKIE The Moray Council Housing Land Audit 2025 Easting: 341370 Northing: 864453 Area (Ha): 8.02 Primary School: Cluny Primary School Secondary School: Buckie High School Ward: Buckie Effective Land 140 Supply Type: Deliverable LPR: 20/R7 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: Detail House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Agricultural Land Constraint Notes: Dispute: Windfall: No Established Land: 2020 Effective Land: 2020 Owner: Mr Alan Durno Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 21/01963 65 Full Approved 23/06/2023 Phase 1 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 20 20 20 20 20 20 20 140 102Market 38Affordable 140 4Flat 61House 75Unknown Page 228
Page 229
SITE REF: M/BC/R/20/08 LOCATION: LAND AT BARHILL ROAD Units Not Built Total Units 250Capacity: Planning Applications: BUCKIE The Moray Council Housing Land Audit 2025 Easting: 341931 Northing: 864204 Area (Ha): 18.47 Primary School: Cluny Primary School Secondary School: Buckie High School Ward: Buckie Effective Land 250 Supply Type: Deliverable LPR: 20/R8 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Agricultural Land Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2020 Effective Land: 2020 Owner: Mr Michael Watt Developer: Springfield Properties Plc Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 21/01224 101 Full Appeal 29/09/2023 Appeal [PPA-300- 2069] upheld (Phase 1) 23/02231 95 Full Pending Phase 1 (174 units total) 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 20 35 30 16 35 35 35 44 250 187Market 63Affordable 250 33Flat 68House 149Unknown Page 229
Page 230
SITE REF: M/BC/R/20/09 LOCATION: SITE AT ARDACH HEALTH CENTRE Units Not Built Total Units 5Capacity: Planning Applications: BUCKIE The Moray Council Housing Land Audit 2025 Easting: 342444 Northing: 864944 Area (Ha): 0.38 Primary School: Cluny Primary School Secondary School: Buckie High School Ward: Buckie Effective Land 0 Supply Type: Constrained LPR: 20/R9 Tenure: Projected Completions: Constrained Land 5 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Ownership Land Use Type: Constraint Notes: Programming Dispute: Agreed Windfall: No Established Land: 2020 Effective Land: 2020 Owner: Moray Council Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 5 5 3Market 2Affordable 5Unknown Page 230
Page 231
SITE REF: M/BC/R/20/LG1 LOCATION: LAND TO SOUTH WEST OF BUCKIE Units Not Built Total Units 250Capacity: Planning Applications: BUCKIE The Moray Council Housing Land Audit 2025 Easting: 342171 Northing: 863966 Area (Ha): 13.1 Primary School: Cluny Primary School Secondary School: Buckie High School Ward: Buckie Effective Land 0 Supply Type: Constrained LPR: 20/LONG1 Tenure: Projected Completions: Constrained Land 250 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Ownership Land Use Type: Agricultural Land Constraint Notes: Programming (LONG) Dispute: Agreed Windfall: No Established Land: 2020 Effective Land: Owner: Mr Michael Watt Developer: Springfield Properties Plc Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 23/02231 79 Full Pending Phase 1 [174 units total] 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 15 45 19 45 126 250 187Market 63Affordable 124 250Unknown Page 231
Page 232
SITE REF: M/BC/R/20/MU LOCATION: HIGH STREET (W) Units Not Built Total Units 100Capacity: Planning Applications: BUCKIE The Moray Council Housing Land Audit 2025 Easting: 342970 Northing: 864255 Area (Ha): 12.4 Primary School: Cluny Primary School Secondary School: Buckie High School Ward: Buckie Effective Land 100 Supply Type: Deliverable LPR: 20/MU Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Agricultural Land Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2020 Effective Land: 2020 Owner: Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 10 20 20 20 20 10 100 75Market 25Affordable 90 100Unknown Page 232
Page 233
SITE REF: M/BC/R/20/W1 LOCATION: MILL OF BUCKIE Units Not Built Total Units 11Capacity: Planning Applications: BUCKIE The Moray Council Housing Land Audit 2025 Easting: 342151 Northing: 864638 Area (Ha): 1.14 Primary School: Cluny Primary School Secondary School: Buckie High School Ward: Buckie Effective Land 11 Supply Type: Deliverable LPR: 20/R10 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: Detail House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Agricultural Land Constraint Notes: Dispute: Agreed Windfall: Yes Established Land: 2020 Effective Land: 2020 Owner: Mr Fredrick Parkes Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 19/01127 11 Full Approved 11/02/2021 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 2 3 3 3 11 8Market 3Affordable 11 11House Page 233
Page 234
SITE REF: M/BH/R/006 LOCATION: NORTH QUAY Units Not Built Total Units 14Capacity: Planning Applications: BURGHEAD The Moray Council Housing Land Audit 2025 Easting: 310871 Northing: 869062 Area (Ha): 0.08 Primary School: Burghead Primary School Secondary School: Lossiemouth High School Ward: Heldon And Laich Effective Land 14 Supply Type: Deliverable LPR: 20/R1 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: Detail House Programme:Adopted Local Plan: Green/Brown: Brown Constraint Type: Land Use Type: Derelict, vacant, backland etc. Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2001 Effective Land: 2001 Owner: Unknown (A) and Margery Bray Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 18/00359 Full Expired 05/09/2019 Renewal of 15/00221 15/00221 Full Expired 21/04/2015 Renewal of 11/00065 11/00065 6 Full Expired 29/03/2012 Site B 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 6 4 4 14 10Market 4Affordable 14 14Flat Page 234
Page 235
SITE REF: M/BH/R/012 LOCATION: WEST FORESHORE Units Not Built Total Units 40Capacity: Planning Applications: BURGHEAD The Moray Council Housing Land Audit 2025 Easting: 311355 Northing: 868688 Area (Ha): 0.91 Primary School: Burghead Primary School Secondary School: Lossiemouth High School Ward: Heldon And Laich Effective Land 0 Supply Type: Constrained LPR: 20/OPP1 Tenure: Projected Completions: Constrained Land 40 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Brown Constraint Type: Physical Conditions Land Use Type: Industry Constraint Notes: Contamination and ownership Dispute: Agreed Windfall: No Established Land: 1998 Effective Land: Owner: Moray Council/ToC/John Gordo Developer: Tulloch of Cummingston Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 98/00681 40 Outline Expired 13/08/1998 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 40 40 30Market 10Affordable 40Unknown Page 235
Page 236
SITE REF: M/BH/R/04 LOCATION: CLARKLY HILL Units Not Built Total Units 80Capacity: Planning Applications: BURGHEAD The Moray Council Housing Land Audit 2025 Easting: 312292 Northing: 868516 Area (Ha): 3.75 Primary School: Burghead Primary School Secondary School: Lossiemouth High School Ward: Heldon And Laich Effective Land 80 Supply Type: Deliverable LPR: 20/R2 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Agricultural Land Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2015 Effective Land: 2015 Owner: Tulloch of Cummingston Developer: Tulloch of Cummingston Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 8 8 8 8 8 10 10 10 10 80 60Market 20Affordable 70 80Unknown Page 236
Page 237
SITE REF: M/BH/R/20/LNG LOCATION: LONG1 CLARKLY HILL Units Not Built Total Units 80Capacity: Planning Applications: BURGHEAD The Moray Council Housing Land Audit 2025 Easting: 312458 Northing: 868376 Area (Ha): 5.69 Primary School: Burghead Primary School Secondary School: Lossiemouth High School Ward: Heldon And Laich Effective Land 0 Supply Type: Constrained LPR: 20/LONG1 Tenure: Projected Completions: Constrained Land 80 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Ownership Land Use Type: Agricultural Land Constraint Notes: Programming (LONG) Dispute: Agreed Windfall: No Established Land: 2020 Effective Land: Owner: Tulloch of Cummingston Developer: Tulloch of Cummingston Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 80 80 60Market 20Affordable 80Unknown Page 237
Page 238
SITE REF: M/CR/R/001 LOCATION: EDWARD AVENUE Units Not Built Total Units 5Capacity: Planning Applications: CRAIGELLACHIE The Moray Council Housing Land Audit 2025 Easting: 329039 Northing: 844746 Area (Ha): 0.55 Primary School: Craigellachie Primary School Secondary School: Speyside High School Ward: Speyside Glenlivet Effective Land 0 Supply Type: Constrained LPR: 20/R1 Tenure: Projected Completions: Constrained Land 5 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Physical Conditions Land Use Type: Agricultural Land Constraint Notes: Protected water supply Dispute: Agreed Windfall: No Established Land: Effective Land: Owner: Bacardi Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 5 5 3Market 2Affordable 5Unknown Page 238
Page 239
SITE REF: M/CR/R/003 LOCATION: BRICKFIELD Units Not Built Total Units 12Capacity: Planning Applications: CRAIGELLACHIE The Moray Council Housing Land Audit 2025 Easting: 329232 Northing: 844453 Area (Ha): 1 Primary School: Craigellachie Primary School Secondary School: Speyside High School Ward: Speyside Glenlivet Effective Land 12 Supply Type: Deliverable LPR: 20/R3 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: Detail House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Agricultural Land Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2010 Effective Land: 2017 Owner: Strathdee Properties Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 16/01558 3 Full Approved 02/03/2017 16/01559 4 Full Approved 02/03/2017 08/01974 8 Full Expired 16/01/2010 08/01973 4 Full Expired 16/01/2010 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 12 12 12Market 12 7House 5Unknown Page 239
Page 240
SITE REF: M/CR/R/004 LOCATION: FORMER BREWERY, SPEY ROAD Units Not Built Total Units 5Capacity: Planning Applications: CRAIGELLACHIE The Moray Council Housing Land Audit 2025 Easting: 329173 Northing: 844819 Area (Ha): 0.63 Primary School: Craigellachie Primary School Secondary School: Speyside High School Ward: Speyside Glenlivet Effective Land 0 Supply Type: Constrained LPR: 20/R2 Tenure: Projected Completions: Constrained Land 5 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Brown Constraint Type: Ownership Land Use Type: Industry Constraint Notes: Operational requirements Dispute: Agreed Windfall: No Established Land: Effective Land: Owner: Bacardi Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 5 5 3Market 2Affordable 5Unknown Page 240
Page 241
SITE REF: M/CL/R/15/02 LOCATION: SEAFIELD ROAD Units Not Built Total Units 55Capacity: Planning Applications: CULLEN The Moray Council Housing Land Audit 2025 Easting: 351585 Northing: 866720 Area (Ha): 3.39 Primary School: Cullen Primary School Secondary School: Buckie High School Ward: Keith And Cullen Effective Land 55 Supply Type: Deliverable LPR: 20/R1 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Agricultural Land Constraint Notes: Dispute: Agreed Windfall: No Established Land: Effective Land: Owner: Seafield Estate Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 20 12 12 11 55 41Market 14Affordable 55 55Unknown Page 241
Page 242
SITE REF: M/CM/R/02 LOCATION: SEAVIEW ROAD Units Not Built Total Units 4Capacity: Planning Applications: CUMMINGSTON The Moray Council Housing Land Audit 2025 Easting: 313561 Northing: 869105 Area (Ha): 0.63 Primary School: Hopeman Primary School Secondary School: Lossiemouth High School Ward: Heldon And Laich Effective Land 3 Supply Type: Deliverable LPR: 20/R1 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: Detail/Under Construction House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Agricultural Land Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2009 Effective Land: 2009 Owner: Tulloch of Cummingston Developer: Tulloch of Cummingston Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 21/00808 Full Approved 09/07/2021 Amended house design (Plot 15) 20/01573 Full Approved 02/03/2021 Amended house desing (Plots 15 and 16) 17/00627 Full Approved 07/06/2017 Amended house design (Plot 15) 10/00573 3 Full Approved 16/07/2013 10/02077 1 Full Approved 17/03/2011 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 0 0 1 0 1 0 1 3 4Market 3 4House Page 242
Page 243
SITE REF: M/DA/R/001 LOCATION: DALLAS SCHOOL WEST Units Not Built Total Units 6Capacity: Planning Applications: DALLAS The Moray Council Housing Land Audit 2025 Easting: 312117 Northing: 852138 Area (Ha): 1.06 Primary School: Dallas Primary School Secondary School: Forres Academy Ward: Speyside Glenlivet Effective Land 0 Supply Type: Constrained LPR: 20/R1 Tenure: Projected Completions: Constrained Land 6 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Infrastucture Land Use Type: Derelict, vacant, backland etc. Constraint Notes: Waste water Dispute: Agreed Windfall: No Established Land: 2003 Effective Land: Owner: Dallas Estate Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 2 2 2 6 4Market 2Affordable 6 6Unknown Page 243
Page 244
SITE REF: M/DA/R/002 LOCATION: FORMER FILLING STATION Units Not Built Total Units 4Capacity: Planning Applications: DALLAS The Moray Council Housing Land Audit 2025 Easting: 312216 Northing: 852275 Area (Ha): 0.25 Primary School: Dallas Primary School Secondary School: Forres Academy Ward: Speyside Glenlivet Effective Land 0 Supply Type: Constrained LPR: 20/R3 Tenure: Projected Completions: Constrained Land 4 Extra Information: Planning Consent: Detail House Programme:Adopted Local Plan: Green/Brown: Brown Constraint Type: Financial Land Use Type: Derelict, vacant, backland etc. Constraint Notes: Marketability Dispute: Agreed Windfall: No Established Land: 2007 Effective Land: Owner: Mr Ian Thomson Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 10/00323 4 Full Approved 10/05/2010 05/00354 5 Outline Approved 06/03/2007 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 4 4 4Market 4House Page 244
Page 245
SITE REF: M/DF/R/012 LOCATION: OLD MART ROAD Units Not Built Total Units 5Capacity: Planning Applications: DUFFTOWN The Moray Council Housing Land Audit 2025 Easting: 332193 Northing: 840371 Area (Ha): 0.24 Primary School: Mortlach Primary School Secondary School: Speyside High School Ward: Speyside Glenlivet Effective Land 5 Supply Type: Deliverable LPR: 20/OPP1 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: Detail House Programme:Adopted Local Plan: Green/Brown: Brown Constraint Type: Land Use Type: Commercial Constraint Notes: Dispute: Agreed Windfall: Established Land: 2014 Effective Land: 2019 Owner: Moray Council Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 14/00320 24 Full Approved 23/06/2014 5 units approved for this area of site 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 5 5 5 Page 245
Page 246
SITE REF: M/DF/R/15/03 LOCATION: HILLSIDE FARM Units Not Built Total Units 100Capacity: Planning Applications: DUFFTOWN The Moray Council Housing Land Audit 2025 Easting: 331836 Northing: 840087 Area (Ha): 5.57 Primary School: Mortlach Primary School Secondary School: Speyside High School Ward: Speyside Glenlivet Effective Land 100 Supply Type: Deliverable LPR: 20/R1 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Agricultural Land Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2015 Effective Land: 2020 Owner: Mr James Wiseman Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 20 20 20 20 20 100 75Market 25Affordable 100 100Unknown Page 246
Page 247
SITE REF: M/DY/R/15/02 LOCATION: SOUTH DARKLASS ROAD Units Not Built Total Units 5Capacity: Planning Applications: DYKE The Moray Council Housing Land Audit 2025 Easting: 298708 Northing: 858312 Area (Ha): 0.44 Primary School: Dyke Primary School Secondary School: Forres Academy Ward: Forres Effective Land 0 Supply Type: Constrained LPR: 20/R2 Tenure: Projected Completions: Constrained Land 5 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Infrastucture Land Use Type: Agricultural Land Constraint Notes: Road infrastructure Dispute: Agreed Windfall: No Established Land: 2015 Effective Land: Owner: Mr Grant Davidson Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 5 5 3Market 2Affordable 5Unknown Page 247
Page 248
SITE REF: M/DY/R/20/03 LOCATION: FIR PARK ROAD Units Not Built Total Units 3Capacity: Planning Applications: DYKE The Moray Council Housing Land Audit 2025 Easting: 299035 Northing: 858718 Area (Ha): 0.18 Primary School: Dyke Primary School Secondary School: Forres Academy Ward: Forres Effective Land 3 Supply Type: Deliverable LPR: 20/R3 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Agricultural Land Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2020 Effective Land: 2020 Owner: Ms Ros Davidson Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 22/01315 3 Full Approved 05/05/2023 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 1 0 1 0 1 3 3Market 3 3House Page 248
Page 249
SITE REF: M/EL/R/048 LOCATION: BILBOHALL NORTH Units Not Built Total Units 80Capacity: Planning Applications: ELGIN The Moray Council Housing Land Audit 2025 Easting: 320844 Northing: 862045 Area (Ha): 3.38 Primary School: Greenwards Primary School Secondary School: Elgin High School Ward: Elgin City South Effective Land 0 Supply Type: Constrained LPR: 20/R1 Tenure: Projected Completions: Constrained Land 40 Extra Information: Planning Consent: Detail House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Infrastucture Land Use Type: Agricultural Land Constraint Notes: Road infrastructure Dispute: Agreed Windfall: No Established Land: 2003 Effective Land: 2005 Owner: Robertson Residential Group Developer: Robertson Residential Group Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 06/00232 Full Refused 10/08/2006 Appeal dismissed 04/00476 60 Full Approved 22/09/2005 09/01476 44 Full Withdrawn Amend condition to increase number 19/00930 380 PAN for Bilbohall Masterplan 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 25 15 40 75Market 5Affordable 40 60House 20Unknown Page 249
Page 250
SITE REF: M/EL/R/07/05 LOCATION: BILBOHALL SOUTH Units Not Built Total Units 102Capacity: Planning Applications: ELGIN The Moray Council Housing Land Audit 2025 Easting: 320800 Northing: 861785 Area (Ha): 10.25 Primary School: Greenwards Primary School Secondary School: Elgin High School Ward: Elgin City South Effective Land 102 Supply Type: Deliverable LPR: 20/R3 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: Detail House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Agricultural Land Constraint Notes: Dispute: Agreed Windfall: No Established Land: Effective Land: Owner: Grampian Housing A. Developer: Grampian Housing A. Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 20/00905 102 Full Approved 21/04/2022 Bilbohall Maspterplan (Phase 2 - 194 units total) 19/00930 380 PAN for Bilbohall Masterplan 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 22 40 40 102 102Affordable 102 40Flat 62House Page 250
Page 251
SITE REF: M/EL/R/07/06 LOCATION: SOUTH WEST OF ELGIN HIGH SCHOOL Units Not Built Total Units 107Capacity: Planning Applications: ELGIN The Moray Council Housing Land Audit 2025 Easting: 320916 Northing: 861311 Area (Ha): 14.17 Primary School: Greenwards Primary School Secondary School: Elgin High School Ward: Elgin City South Effective Land 0 Supply Type: Constrained LPR: 20/R4 Tenure: Projected Completions: Constrained Land 107 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Physical Conditions Land Use Type: Agricultural Land Constraint Notes: Topography Dispute: Agreed Windfall: No Established Land: 2007 Effective Land: Owner: Mr Dean Andersson Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 19/00930 380 PAN for Bilbohall Masterplan 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 107 107 80Market 27Affordable 107Unknown Page 251
Page 252
SITE REF: M/EL/R/081 LOCATION: NEWFIELD HOUSE, LOSSIEMOUTH ROAD Units Not Built Total Units 8Capacity: Planning Applications: ELGIN The Moray Council Housing Land Audit 2025 Easting: 321853 Northing: 864506 Area (Ha): 0.22 Primary School: Seafield Primary School Secondary School: Elgin Academy Ward: Elgin City North Effective Land 0 Supply Type: Constrained LPR: Tenure: Projected Completions: Constrained Land 12 Extra Information: Planning Consent: Detail House Programme:Adopted Local Plan: Green/Brown: Brown Constraint Type: Infrastucture Land Use Type: Commercial Constraint Notes: Active travel Dispute: Agreed Windfall: Yes Established Land: 2011 Effective Land: Owner: Mr Ian Aitkenhead Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 12/00652 Full Refused 20/12/2012 Vary conditions (provision of cycleway) 12/00071 Full Refused 01/03/2012 Delete conditions (provision of cycleway) 11/00233 4 Full Approved 26/08/2011 Permission commenced 09/02161 8 Full Approved 11/08/2010 Permission commenced 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 4 8 12 12Market 12 12Flat Page 252
Page 253
SITE REF: M/EL/R/082 LOCATION: PALMERS CROSS Units Not Built Total Units 29Capacity: Planning Applications: ELGIN The Moray Council Housing Land Audit 2025 Easting: 320396 Northing: 862046 Area (Ha): 2.52 Primary School: West End Primary School Secondary School: Elgin Academy Ward: Elgin City South Effective Land 0 Supply Type: Constrained LPR: 20/R21 Tenure: Projected Completions: Constrained Land 20 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Brown Constraint Type: Ownership Land Use Type: Residential Constraint Notes: Ownership and marketability Dispute: Windfall: No Established Land: 2013 Effective Land: Owner: Edgar Road Properties Ltd Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 14/02172 Full Expired 22/12/2014 Extend 11/01882 11/01882 Full Expired 17/01/2012 Extend 06/02897 06/02897 29 Outline Approved 18/03/2009 17/01933 28 Outline Withdrawn 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 20 20 15Market 5Affordable 20Unknown Page 253
Page 254
SITE REF: M/EL/R/088 LOCATION: BARMUCKITY Units Not Built Total Units 190Capacity: Planning Applications: ELGIN The Moray Council Housing Land Audit 2025 Easting: 324098 Northing: 861856 Area (Ha): 13.18 Primary School: Split Secondary School: Split Ward: Fochabers Lhanbryde Effective Land 0 Supply Type: Constrained LPR: 20/R16 Tenure: Projected Completions: Constrained Land 190 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Ownership Land Use Type: Agricultural Land Constraint Notes: Programming Dispute: Agreed Windfall: No Established Land: 2017 Effective Land: Owner: Mr Ian Robertson Developer: Springfield Properties Plc Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 190 190 142Market 48Affordable 180Unknown Page 254
Page 255
SITE REF: M/EL/R/093 LOCATION: THE FIRS, BILBOHALL Units Not Built Total Units 8Capacity: Planning Applications: ELGIN The Moray Council Housing Land Audit 2025 Easting: 320694 Northing: 862025 Area (Ha): 0.41 Primary School: Greenwards Primary School Secondary School: Elgin High School Ward: Elgin City South Effective Land 8 Supply Type: Deliverable LPR: 20/R7 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: Detail House Programme:Adopted Local Plan: Green/Brown: Brown Constraint Type: Effective 5yr+ Land Use Type: Commercial Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2019 Effective Land: 2019 Owner: Moray Council Developer: Moray Council Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 20/00905 8 Full Approved 21/04/2022 Blibohall Masterplan (Phase 1 - 194 units total) 19/00930 380 PAN for Bilbohall Masterplan 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 8 8 8Affordable 8 8House Page 255
Page 256
SITE REF: M/EL/R/094 LOCATION: SPYNIE HOSPITAL Units Not Built Total Units 50Capacity: Planning Applications: ELGIN The Moray Council Housing Land Audit 2025 Easting: 320704 Northing: 863952 Area (Ha): 3.8 Primary School: Bishopmill Primary School Secondary School: Elgin Academy Ward: Elgin City North Effective Land 0 Supply Type: Constrained LPR: 20/R14 Tenure: Projected Completions: Constrained Land 50 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Brown Constraint Type: Ownership Land Use Type: Derelict, vacant, backland etc. Constraint Notes: Operational requirements Dispute: Agreed Windfall: No Established Land: 2019 Effective Land: Owner: NHS Grampian Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 20/00781 62 Full Withdrawn 08/12/2022 Affordable housing 19/01025 PAN 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 10 20 20 50 37Market 13Affordable 50 50Unknown Page 256
Page 257
SITE REF: M/EL/R/15/12 LOCATION: KNOCKMASTING WOOD Units Not Built Total Units 85Capacity: Planning Applications: ELGIN The Moray Council Housing Land Audit 2025 Easting: 320541 Northing: 861909 Area (Ha): 4.28 Primary School: Greenwards Primary School Secondary School: Elgin High School Ward: Elgin City South Effective Land 85 Supply Type: Deliverable LPR: 20/R6 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Agricultural Land Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2015 Effective Land: 2015 Owner: Scotia Homes Developer: Scotia Homes Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 15/01330 1 Full Refused 29/09/2015 Refused by LRB in 2016 05/00758 80 Full Withdrawn 19/00930 380 Full PAN for Bilbohall Masterplan 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 5 30 50 85 63Market 22Affordable 35 85Unknown Page 257
Page 258
SITE REF: M/EL/R/15/13 LOCATION: HAMILTON DRIVE Units Not Built Total Units 18Capacity: Planning Applications: ELGIN The Moray Council Housing Land Audit 2025 Easting: 320812 Northing: 863708 Area (Ha): 1.18 Primary School: Bishopmill Primary School Secondary School: Elgin Academy Ward: Elgin City North Effective Land 10 Supply Type: Deliverable LPR: 20/R9 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: Detail/Under Construction House Programme:Adopted Local Plan: Green/Brown: Brown Constraint Type: Land Use Type: Derelict, vacant, backland etc. Constraint Notes: Dispute: Windfall: No Established Land: 2015 Effective Land: 2015 Owner: Developer: MPD Homes Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 23/00649 1 Full Approved 24/08/2023 22/01221 Full Approved 23/11/2022 Vary house type (Plot 6) 19/01614 17 Full Approved 30/09/2021 19/00386 17 Full Withdrawn 09/10/2019 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 0 2 2 2 2 2 10 14Market 4Affordable 10 4Flat 14House Page 258
Page 259
SITE REF: M/EL/R/15/14 LOCATION: LESMURDIE FIELDS Units Not Built Total Units 70Capacity: Planning Applications: ELGIN The Moray Council Housing Land Audit 2025 Easting: 322746 Northing: 863777 Area (Ha): 6.07 Primary School: Seafield Primary School Secondary School: Elgin Academy Ward: Split Effective Land 70 Supply Type: Deliverable LPR: 20/R13 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: Detail House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Agricultural Land Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2015 Effective Land: 2015 Owner: Robertson Residential Group Developer: Robertson Residential Group Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 19/01510 70 Full Approved 16/11/2022 18/00978 90 PAN 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 10 25 25 10 70 48Market 22Affordable 70 8Flat 62House Page 259
Page 260
SITE REF: M/EL/R/15/LNE LOCATION: LONG1 A/B NORTH EAST Units Not Built Total Units 1800Capacity: Planning Applications: ELGIN The Moray Council Housing Land Audit 2025 Easting: 322626 Northing: 864410 Area (Ha): 88.71 Primary School: Seafield Primary School Secondary School: Elgin Academy Ward: Split Effective Land 0 Supply Type: Constrained LPR: 20/LONG1 Tenure: Projected Completions: Constrained Land 1800 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Ownership Land Use Type: Agricultural Land Constraint Notes: Programming (LONG) Dispute: Agreed Windfall: No Established Land: 2015 Effective Land: Owner: Pitgaveny Estate Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 1800 1800 1350Market 450Affordable 1800Unknown Page 260
Page 261
SITE REF: M/EL/R/20/02 LOCATION: EDGAR ROAD Units Not Built Total Units 106Capacity: Planning Applications: ELGIN The Moray Council Housing Land Audit 2025 Easting: 320936 Northing: 861606 Area (Ha): 5.42 Primary School: Greenwards Primary School Secondary School: Elgin High School Ward: Elgin City South Effective Land 106 Supply Type: Deliverable LPR: 20/R2 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: Detail House Programme:Adopted Local Plan: Green/Brown: Brown Constraint Type: Land Use Type: Derelict, vacant, backland etc. Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2020 Effective Land: 2020 Owner: Moray Council Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 20/00905 84 Full Approved 21/04/2022 Bilbohall Masterplan (Phase 1 - 194 units total) 15/00607 Full Approved 24/06/2015 Deposit of excated material 19/00930 380 PAN for Bilbohall Masterplan 24/00705 106 Full Approved Phase 1 revised layout (increase of 22 units) - approved subject to S75 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 28 47 31 106 106Affordable 106 46Flat 60House Page 261
Page 262
SITE REF: M/EL/R/20/05 LOCATION: BILBOHALL WEST Units Not Built Total Units 50Capacity: Planning Applications: ELGIN The Moray Council Housing Land Audit 2025 Easting: 320688 Northing: 861340 Area (Ha): 4.39 Primary School: Greenwards Primary School Secondary School: Elgin High School Ward: Elgin City South Effective Land 0 Supply Type: Constrained LPR: 20/R5 Tenure: Projected Completions: Constrained Land 50 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Ownership Land Use Type: Agricultural Land Constraint Notes: Programming Dispute: Agreed Windfall: No Established Land: 2020 Effective Land: Owner: Mr Dean Anderson Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 50 50 37Market 13Affordable 50Unknown Page 262
Page 263
SITE REF: M/EL/R/20/12 LOCATION: FINDRASSIE (R12 PARCEL) Units Not Built Total Units 150Capacity: Planning Applications: ELGIN The Moray Council Housing Land Audit 2025 Easting: 321674 Northing: 865510 Area (Ha): 16.95 Primary School: Seafield Primary School Secondary School: Elgin Academy Ward: Heldon And Laich Effective Land 0 Supply Type: Constrained LPR: 20/R12 Tenure: Projected Completions: Constrained Land 150 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Ownership Land Use Type: Agricultural Land Constraint Notes: Programming Dispute: Agreed Windfall: No Established Land: 2020 Effective Land: Owner: Pitgaveny Estate Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 150 150 112Market 38Affordable 150Unknown Page 263
Page 264
SITE REF: M/EL/R/20/19 LOCATION: EASTER LINKWOOD AND LINKWOOD Units Not Built Total Units 675Capacity: Planning Applications: ELGIN The Moray Council Housing Land Audit 2025 Easting: 323677 Northing: 861106 Area (Ha): 48.38 Primary School: Linkwood Primary School Secondary School: Split Ward: Fochabers Lhanbryde Effective Land 609 Supply Type: Deliverable with Constraints LPR: 20/R19 Tenure: Projected Completions: Constrained Land Extra Information: Planning Consent: Detail House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Ownership Land Use Type: Agricultural Land Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2018 Effective Land: Owner: Mr Ian Robertson Developer: Springfield Properties Plc Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 20/00316 Full Approved 16/09/2020 Variation of house types 18/01209 645 Full Approved 16/05/2019 Variation of phasing [Phases 1A, B + C] 16/01244 Full Approved 10/05/2018 Elgin South Masterplan [Phase 1 - 870 units total] 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 45 45 70 70 70 45 45 219 609 497Market 178Affordable 390 29Flat 37House 609Unknown Page 264
Page 265
SITE REF: M/EL/R/20/20 LOCATION: GLASSGREEN, ELGIN SOUTH Units Not Built Total Units 197Capacity: Planning Applications: ELGIN The Moray Council Housing Land Audit 2025 Easting: 321896 Northing: 860463 Area (Ha): 17.59 Primary School: Greenwards Primary School Secondary School: Elgin High School Ward: Elgin City South Effective Land 6 Supply Type: Deliverable LPR: 20/R20 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: Detail/Under Construction House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Agricultural Land Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2018 Effective Land: 2019 Owner: Springfield Properties Plc Developer: Springfield Properties Plc Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 21/01163 10 Full Approved 21/07/2023 Phase 2 (10 units) 21/00206 Full Approved 13/01/2023 Variation to phasing and layout (increase in units [5]) 21/00304 Full Approved 13/01/2023 Variation to layout (reduction in units [1]) 21/00396 187 Full Approved 13/01/2023 Plot substitution (reduction in units [12]) 19/01641 Full Approved 08/04/2020 Variation to house types 18/01209 195 Full Approved 16/05/2019 Variation to phasing 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 10 6 6 132Market 65Affordable 6 58Flat 139House Page 265
Page 266
SITE REF: M/EL/R/20/L2 LOCATION: ELGIN SOUTH LONG2 Units Not Built Total Units 1000Capacity: Planning Applications: ELGIN The Moray Council Housing Land Audit 2025 Easting: 322892 Northing: 860523 Area (Ha): 69.3 Primary School: Split Secondary School: Split Ward: Fochabers Lhanbryde Effective Land 0 Supply Type: Constrained LPR: 20/LNG2 Tenure: Projected Completions: Constrained Land 1000 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Ownership Land Use Type: Agricultural Land Constraint Notes: Programming (LONG) Dispute: Agreed Windfall: No Established Land: 2015 Effective Land: Owner: Developer: Springfield Properties Plc Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 1000 1000 750Market 250Affordable 1000Unknown Page 266
Page 267
SITE REF: M/EL/R/21/L2 LOCATION: ELGIN SOUTH (GRASSGREEN, BURNSIDE & CEMETERY) Units Not Built Total Units 627Capacity: Planning Applications: ELGIN The Moray Council Housing Land Audit 2025 Easting: 323286 Northing: 860599 Area (Ha): 41.8 Primary School: Split Secondary School: Elgin High School Ward: Split Effective Land 584 Supply Type: Deliverable LPR: 20/LONG2 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: Detail/Under Construction House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Agricultural Land Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2015 Effective Land: 2021 Owner: Springfield Properties Plc Developer: Springfield Properties Plc Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 24/00866 176 Full Approved 31/03/2025 Variation of house types (Phase 2 - private to care (reduction of 10 units] 21/01163 186 Full Approved 21/07/2023 Glassgreen Village (Phase 2) 20/01731 Full Withdrawn North Burnside 23/01440 Full Pending Variation of house types (Phase 2 - reduction in units [14]) 24/01437 204 Full Pending Phase 3 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 43 68 54 40 68 54 41 259 584 470Market 157Affordable 325 45Flat 117House 465Unknown Page 267
Page 268
SITE REF: M/EL/R/23/01 LOCATION: BAIN AVENUE Units Not Built Total Units 24Capacity: Planning Applications: ELGIN The Moray Council Housing Land Audit 2025 Easting: 323505 Northing: 861804 Area (Ha): 2.11 Primary School: Linkwood Primary School Secondary School: Elgin High School Ward: Elgin City South Effective Land 24 Supply Type: Deliverable LPR: 20/ENV2+3 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: Detail House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Constraint Notes: Dispute: Agreed Windfall: Yes Established Land: 2020 Effective Land: 2022 Owner: Developer: Springfield Properties Plc Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 21/01863 24 Full Approved 23/05/2022 Variation to house types (reduction in units (2)) 19/00547 26 Full Appeal 23/03/2020 Appeal (PPA-300- 2056) upheld 19/00547 26 Full Refused 09/10/2019 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 24 24 24Affordable 24 8Flat 16House Page 268
Page 269
SITE REF: M/EL/R/23/02 LOCATION: FINDRASSIE (E PARCEL) Units Not Built Total Units 419Capacity: Planning Applications: ELGIN The Moray Council Housing Land Audit 2025 Easting: 321601 Northing: 864744 Area (Ha): 15.54 Primary School: Seafield Primary School Secondary School: Elgin Academy Ward: Heldon And Laich Effective Land 173 Supply Type: Deliverable LPR: 20/R11 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: Detail/Under Construction House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Agricultural Land Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2007 Effective Land: 2019 Owner: Barratt Homes Developer: Barratt Homes/David Wilson Hom Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 23/02239 148 Full Approved 23/10/2024 AMC (17/00834 and 19/01085) [Phases E3/4] 23/01167 Full Approved 30/11/2023 Variation of house types 22/01385 158 Full Approved 08/02/2023 Variation of house type (increase in units (2)) [Phase E2] 21/00961 156 Full Approved 13/04/2022 AMC (17/00834 and 19/01085) [Phase E2] 20/00753 113 Full Approved 27/01/2021 AMC (17/00834 and 19/01085) [Phase E1] 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 81 67 55 47 4 173 313Market 106Affordable 173 36Flat 383House Page 269
Page 270
SITE REF: M/EL/R/23/03 LOCATION: FINDRASSIE (D PARCEL) Units Not Built Total Units 266Capacity: Planning Applications: ELGIN The Moray Council Housing Land Audit 2025 Easting: 320451 Northing: 864268 Area (Ha): 11.32 Primary School: Bishopmill Primary School Secondary School: Elgin Academy Ward: Elgin City North Effective Land 266 Supply Type: Deliverable LPR: 20/R11 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Agricultural Land Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2007 Effective Land: 2015 Owner: Pitgaveny Estate Developer: Robertson Residential Group Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 23/01071 268 Full Pending 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 15 30 30 30 30 30 101 266 199Market 67Affordable 165 266Unknown Page 270
Page 271
SITE REF: M/EL/R/23/04 LOCATION: FINDRASSIE (W PARCEL) Units Not Built Total Units 260Capacity: Planning Applications: ELGIN The Moray Council Housing Land Audit 2025 Easting: 320890 Northing: 864851 Area (Ha): 12.12 Primary School: Bishopmill Primary School Secondary School: Elgin Academy Ward: Split Effective Land 0 Supply Type: Constrained LPR: 20/R11 Tenure: Projected Completions: Constrained Land 260 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Ownership Land Use Type: Agricultural Land Constraint Notes: Programming Dispute: Agreed Windfall: No Established Land: 2007 Effective Land: Owner: Pitgaveny Estate Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 20 40 40 160 260 195Market 65Affordable 100 260Unknown Page 271
Page 272
SITE REF: M/EL/R/23/05 LOCATION: FINDRASSIE (N PARCEL) Units Not Built Total Units 519Capacity: Planning Applications: ELGIN The Moray Council Housing Land Audit 2025 Easting: 321225 Northing: 865218 Area (Ha): 31.91 Primary School: Seafield Primary School Secondary School: Elgin Academy Ward: Heldon And Laich Effective Land 0 Supply Type: Constrained LPR: 20/R11 Tenure: Projected Completions: Constrained Land 519 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Ownership Land Use Type: Agricultural Land Constraint Notes: Programming Dispute: Agreed Windfall: No Established Land: 2007 Effective Land: Owner: Pitgaveny Estate Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 519 519 389Market 130Affordable 519Unknown Page 272
Page 273
SITE REF: M/EL/R/23/W1 LOCATION: OLDMILLS ROAD Units Not Built Total Units 12Capacity: Planning Applications: ELGIN The Moray Council Housing Land Audit 2025 Easting: 320761 Northing: 862735 Area (Ha): 0.42 Primary School: West End Primary School Secondary School: Elgin Academy Ward: Elgin City South Effective Land 12 Supply Type: Deliverable LPR: 20/ENV6 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: Detail House Programme:Adopted Local Plan: Green/Brown: Brown Constraint Type: Land Use Type: Derelict, vacant, backland etc. Constraint Notes: Dispute: Agreed Windfall: Yes Established Land: 2023 Effective Land: 2023 Owner: Tulloch of Cummingston Developer: Tulloch of Cummingston Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 20/00795 12 Full Approved 28/04/2023 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 6 6 12 12Market 12 12Flat Page 273
Page 274
SITE REF: M/EL/R/25/01 LOCATION: SOUTH STREET Units Not Built Total Units 38Capacity: Planning Applications: ELGIN The Moray Council Housing Land Audit 2025 Easting: 321559 Northing: 862760 Area (Ha): 0.3 Primary School: West End Primary School Secondary School: Elgin Academy Ward: Elgin City South Effective Land 38 Supply Type: Deliverable LPR: Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: Detail/Under Construction House Programme:Adopted Local Plan: Green/Brown: Brown Constraint Type: Land Use Type: Commercial Constraint Notes: Dispute: Agreed Windfall: Yes Established Land: 2018 Effective Land: 2018 Owner: Moray Council/Robertson Grou Developer: Moray Council/Robertson Group Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 24/00300 38 Full Approved 30/05/2024 17/00963 Full Approved 01/03/2018 CoU nightclub to 14 serviced apartments 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 19 19 38 38Affordable 38 38Flat Page 274
Page 275
SITE REF: M/EL/R/TC/01 LOCATION: 161-163 HIGH STREET (POUNDLAND) Units Not Built Total Units 21Capacity: Planning Applications: ELGIN The Moray Council Housing Land Audit 2025 Easting: 321480 Northing: 862875 Area (Ha): 0.14 Primary School: West End Primary School Secondary School: Elgin Academy Ward: Elgin City South Effective Land 21 Supply Type: Deliverable LPR: 20/TC Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: Detail/Under Construction House Programme:Adopted Local Plan: Green/Brown: Brown Constraint Type: Land Use Type: Commercial Constraint Notes: Dispute: Agreed Windfall: Yes Established Land: 2020 Effective Land: 2020 Owner: Poundland Elgin Ltd Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 20/00891 21 Full Approved 15/10/2020 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 4 7 7 7 21 6Market 15Affordable 21 21Flat Page 275
Page 276
SITE REF: M/EL/R/TC/04 LOCATION: 42 BATCHEN STREET Units Not Built Total Units 4Capacity: Planning Applications: ELGIN The Moray Council Housing Land Audit 2025 Easting: 321535 Northing: 862727 Area (Ha): 0.02 Primary School: West End Primary School Secondary School: Elgin Academy Ward: Elgin City South Effective Land 4 Supply Type: Deliverable LPR: 20/TC Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: Detail House Programme:Adopted Local Plan: Green/Brown: Brown Constraint Type: Land Use Type: Commercial Constraint Notes: Dispute: Agreed Windfall: Yes Established Land: 2021 Effective Land: 2021 Owner: Mr Richard Ham Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 20/00282 4 Full Approved 11/09/2020 Coversion of shop storage to 4 x flats 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 4 4 4Market 4 4Flat Page 276
Page 277
SITE REF: M/FH/R/009 LOCATION: HEATHNEUK Units Not Built Total Units 6Capacity: Planning Applications: FINDHORN The Moray Council Housing Land Audit 2025 Easting: 304580 Northing: 863950 Area (Ha): 0.9 Primary School: Kinloss Primary School Secondary School: Forres Academy Ward: Forres Effective Land 2 Supply Type: Deliverable LPR: 20/R1 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: Detail/Under Construction House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2015 Effective Land: 2015 Owner: Mr Tim Clark Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 18/01518 Full Approved 29/01/2019 Plot 2a 18/00429 Full Approved 04/05/2018 Plot 2a - Change of use (garage) to self-catering rental unit 17/00333 1 Full Approved 10/05/2017 Sub division of Plot 1 14/00869 5 Full Approved 07/07/2014 Sites marketed and sold 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 0 0 1 0 1 2 6Market 2 6House Page 277
Page 278
SITE REF: M/FH/R/11 LOCATION: NORTH WHINS Units Not Built Total Units 38Capacity: Planning Applications: FINDHORN The Moray Council Housing Land Audit 2025 Easting: 304945 Northing: 863894 Area (Ha): 2.68 Primary School: Kinloss Primary School Secondary School: Forres Academy Ward: Forres Effective Land 20 Supply Type: Deliverable LPR: Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: Detail/Under Construction House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Constraint Notes: Dispute: Agreed Windfall: Yes Established Land: 2019 Effective Land: 2020 Owner: Developer: Duneland Ltd Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 20/01222 9 Approved 12/08/2021 AMC of 19/00320/PPP [Plot 14] 20/00135 8 Approved 24/09/2020 AMC of 19/00320/PPP [Plot 13.2] 19/01649 8 Approved 23/09/2020 AMC of 19/00320/PPP 20/00016 Full Approved 13/08/2020 Amend condition re max. ridge height 19/01436 Full Withdrawn 14/01/2020 Amend condition re max. ridge height 19/00320 38 Outline Approved 04/11/2019 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 9 9 9 2 20 28Market 10Affordable 20 38House Page 278
Page 279
SITE REF: M/FH/R/20/RC LOCATION: RESIDENTIAL CARAVANS Units Not Built Total Units 9Capacity: Planning Applications: FINDHORN The Moray Council Housing Land Audit 2025 Easting: 305094 Northing: 863641 Area (Ha): 7.85 Primary School: Kinloss Primary School Secondary School: Forres Academy Ward: Forres Effective Land 1 Supply Type: Deliverable LPR: 20/RC Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: Detail House Programme:Adopted Local Plan: Green/Brown: Brown Constraint Type: Land Use Type: Residential Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2019 Effective Land: 2019 Owner: Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 19/00043 8 Full Approved 23/07/2020 19/00042 1 Full Approved 19/03/2019 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 0 0 1 1 1Market 8Affordable 1 8Flat 1House Page 279
Page 280
SITE REF: M/FN/R/009 LOCATION: MORVEN CRESCENT Units Not Built Total Units 60Capacity: Planning Applications: FINDOCHTY The Moray Council Housing Land Audit 2025 Easting: 346362 Northing: 867677 Area (Ha): 2.82 Primary School: Findochty Primary School Secondary School: Buckie High School Ward: Buckie Effective Land 60 Supply Type: Deliverable with Constraints LPR: 20/R1 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Financial Land Use Type: Agricultural Land Constraint Notes: Marketability Dispute: Agreed Windfall: No Established Land: 2003 Effective Land: Owner: Seafield Estate Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 10/00419 19/03/2010 SCN for residential development 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 12 16 16 16 60 45Market 15Affordable 60 60Unknown Page 280
Page 281
SITE REF: M/FO/R/07/01 LOCATION: ORDIQUISH ROAD Units Not Built Total Units 49Capacity: Planning Applications: FOCHABERS The Moray Council Housing Land Audit 2025 Easting: 334366 Northing: 858016 Area (Ha): 2.62 Primary School: Milne's Primary School Secondary School: Milne's High School Ward: Fochabers Lhanbryde Effective Land 40 Supply Type: Deliverable LPR: 20/R1 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: Detail/Under Construction House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Agricultural Land Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2007 Effective Land: 2015 Owner: Bob Milton Properties Developer: Bob Milton Properties Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 23/01866 Full Approved 26/03/2024 Variation of house types [Plots 13-19] 22/00385 Full Approved 05/07/2022 Variation of house types [Plots 4-7] 21/01487 Full Approved 09/12/2021 Amend house design [Plot 8] 21/00933 Full Approved 19/08/2021 Variation of house type [Plot 3] 15/00244 49 Full Approved 26/11/2015 12/01577 50 Outline Approved 10/02/2014 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 2 5 8 8 8 8 3 40 37Market 12Affordable 40 49House Page 281
Page 282
SITE REF: M/FO/R/07/02 LOCATION: ORDIQUISH ROAD WEST Units Not Built Total Units 50Capacity: Planning Applications: FOCHABERS The Moray Council Housing Land Audit 2025 Easting: 334242 Northing: 858100 Area (Ha): 2.32 Primary School: Milne's Primary School Secondary School: Milne's High School Ward: Fochabers Lhanbryde Effective Land 50 Supply Type: Deliverable LPR: 20/R2 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Agricultural Land Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2008 Effective Land: 2015 Owner: Bob Milton Properties Developer: Bob Milton Properties Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 8 10 10 10 12 50 37Market 13Affordable 38 50Unknown Page 282
Page 283
SITE REF: M/FO/R/15/LG LOCATION: ORDIQUISH ROAD EAST LONG Units Not Built Total Units 35Capacity: Planning Applications: FOCHABERS The Moray Council Housing Land Audit 2025 Easting: 334612 Northing: 857859 Area (Ha): 1.85 Primary School: Milne's Primary School Secondary School: Milne's High School Ward: Fochabers Lhanbryde Effective Land 0 Supply Type: Constrained LPR: 20/LONG Tenure: Projected Completions: Constrained Land 35 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Ownership Land Use Type: Agricultural Land Constraint Notes: Programming (LONG) Dispute: Agreed Windfall: No Established Land: 2015 Effective Land: Owner: Crown Estate Scotland Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 35 35 26Market 9Affordable 35Unknown Page 283
Page 284
SITE REF: M/FO/R/20/04 LOCATION: ORDIQUISH ROAD EAST Units Not Built Total Units 50Capacity: Planning Applications: FOCHABERS The Moray Council Housing Land Audit 2025 Easting: 334498 Northing: 857930 Area (Ha): 2.5 Primary School: Milne's Primary School Secondary School: Milne's High School Ward: Fochabers Lhanbryde Effective Land 50 Supply Type: Deliverable with Constraints LPR: 20/R4 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Financial Land Use Type: Agricultural Land Constraint Notes: Marketability Dispute: Agreed Windfall: No Established Land: 2020 Effective Land: 2020 Owner: Crown Estate Scotland Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 50 50 37Market 13Affordable 50Unknown Page 284
Page 285
SITE REF: M/FR/R/057 LOCATION: AUCTION MART, TYTLER STREET Units Not Built Total Units 24Capacity: Planning Applications: FORRES The Moray Council Housing Land Audit 2025 Easting: 303070 Northing: 858830 Area (Ha): 0.2 Primary School: Pilmuir Primary School Secondary School: Forres Academy Ward: Forres Effective Land 0 Supply Type: Constrained LPR: 20/OPP4 Tenure: Projected Completions: Constrained Land 24 Extra Information: Planning Consent: Detail House Programme:Adopted Local Plan: Green/Brown: Brown Constraint Type: Financial Land Use Type: Commercial Constraint Notes: Dispute: Agreed Windfall: Yes Established Land: 2011 Effective Land: 2011 Owner: Developer: Cairn Housing Associaion Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 13/00347 24 Full Approved 25/09/2013 Extend 08/01954 08/01954 24 Full Approved 21/05/2010 15/00371 Full Listed Building Consent 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 12 12 24 24Affordable 24 24Flat Page 285
Page 286
SITE REF: M/FR/R/060 LOCATION: CAROLINE STREET Units Not Built Total Units 48Capacity: Planning Applications: FORRES The Moray Council Housing Land Audit 2025 Easting: 303505 Northing: 859113 Area (Ha): 1.51 Primary School: Anderson's Primary School Secondary School: Forres Academy Ward: Forres Effective Land 48 Supply Type: Deliverable with Constraints LPR: 20/OPP1 Tenure: Projected Completions: Constrained Land Extra Information: Planning Consent: Detail House Programme:Adopted Local Plan: Green/Brown: Brown Constraint Type: Physical Conditions Land Use Type: Commercial Constraint Notes: Contamination Dispute: Agreed Windfall: No Established Land: 2019 Effective Land: Owner: AES Solar Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 20/01455 48 Full Appeal 18/10/2022 Appeal (PPA-300- 2065) upheld 20/01455 48 Full Refused 25/08/2021 16/00740 80 PAN for affordable units development 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 24 24 48 48Affordable 48 19Flat 29House Page 286
Page 287
SITE REF: M/FR/R/07/03 LOCATION: FERRYLEA Units Not Built Total Units 572Capacity: Planning Applications: FORRES The Moray Council Housing Land Audit 2025 Easting: 303116 Northing: 857233 Area (Ha): 33.53 Primary School: Split Secondary School: Forres Academy Ward: Forres Effective Land 79 Supply Type: Deliverable LPR: 20/R2 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: Detail/Under Construction House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Agricultural Land Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2007 Effective Land: 2012 Owner: Springfield Properties Plc Developer: Springfield Properties Plc Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 23/00583 318 Full Approved 05/06/2023 Remix of house typres/plots (reduction in units [3]) 22/01332 Full Approved 30/05/2023 Variation of house types 21/00941 Full Approved 05/04/2023 Variation of house types 21/01217 325 Full Approved 04/04/2023 Remix of house types/plots (increase in units [3]) 21/01350 332 Full Approved 04/04/2023 Remix of house types/plots (increase in units [7]) 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 75 40 39 79 405Market 167Affordable 79 124Flat 448House Page 287
Page 288
SITE REF: M/FR/R/07/08 LOCATION: MANNACHIE Units Not Built Total Units 40Capacity: Planning Applications: FORRES The Moray Council Housing Land Audit 2025 Easting: 303514 Northing: 857451 Area (Ha): 2.85 Primary School: Applegrove Primary School Secondary School: Forres Academy Ward: Forres Effective Land 40 Supply Type: Deliverable with Constraints LPR: 20/R4 Tenure: Projected Completions: Constrained Land Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Physical Conditions Land Use Type: Woodlands Constraint Notes: Dispute: Agreed Windfall: No Established Land: Effective Land: Owner: Tulloch of Cummingston Developer: Tulloch of Cummingston Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 20/00927 32 Full Refused 06/02/2023 Phase 1 20/01028 8 Outline Refused 06/02/2023 Phase 2 (Apartment Block) 23/02096 32 Full Pending Phase 1 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 6 6 6 6 6 10 40 30Market 10Affordable 40 40Unknown Page 288
Page 289
SITE REF: M/FR/R/07/11 LOCATION: LOCHYHILL LONG1 Units Not Built Total Units 400Capacity: Planning Applications: FORRES The Moray Council Housing Land Audit 2025 Easting: 305989 Northing: 858888 Area (Ha): 16.73 Primary School: Anderson's Primary School Secondary School: Forres Academy Ward: Forres Effective Land 0 Supply Type: Constrained LPR: 20/LONG1 Tenure: Projected Completions: Constrained Land 400 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Ownership Land Use Type: Agricultural Land Constraint Notes: Programming (LONG) Dispute: Agreed Windfall: No Established Land: 2007 Effective Land: Owner: White Family Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 400 400 300Market 100Affordable 400Unknown Page 289
Page 290
SITE REF: M/FR/R/15/08 LOCATION: BALNAGEITH Units Not Built Total Units 12Capacity: Planning Applications: FORRES The Moray Council Housing Land Audit 2025 Easting: 302147 Northing: 857332 Area (Ha): 1.17 Primary School: Pilmuir Primary School Secondary School: Forres Academy Ward: Forres Effective Land 0 Supply Type: Constrained LPR: 20/R5 Tenure: Projected Completions: Constrained Land 12 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Brown Constraint Type: Financial Land Use Type: Agricultural Land Constraint Notes: Marketability Dispute: Agreed Windfall: No Established Land: 2015 Effective Land: Owner: Tulloch of Cummingston Developer: Tulloch of Cummingston Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 3 3 3 3 12 9Market 3Affordable 12 12Unknown Page 290
Page 291
SITE REF: M/FR/R/15/10 LOCATION: DALLAS DHU Units Not Built Total Units 136Capacity: Planning Applications: FORRES The Moray Council Housing Land Audit 2025 Easting: 303562 Northing: 857092 Area (Ha): 11.8 Primary School: Applegrove Primary School Secondary School: Forres Academy Ward: Forres Effective Land 136 Supply Type: Deliverable LPR: 20/R6 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Agricultural Land Constraint Notes: Dispute: Windfall: No Established Land: 2015 Effective Land: 2015 Owner: Altyre Estate Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units Dallas Dhu Masterplan 24/01087 34 Full Pending Phase 1 25/00279 5 Full Pending 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 18 24 24 24 24 22 136 102Market 34Affordable 136 8Flat 31House 97Unknown Page 291
Page 292
SITE REF: M/FR/R/15/11 LOCATION: PILMUIR ROAD WEST Units Not Built Total Units 40Capacity: Planning Applications: FORRES The Moray Council Housing Land Audit 2025 Easting: 302493 Northing: 857809 Area (Ha): 2.28 Primary School: Pilmuir Primary School Secondary School: Forres Academy Ward: Forres Effective Land 0 Supply Type: Constrained LPR: 20/R7 Tenure: Projected Completions: Constrained Land 40 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Brown Constraint Type: Physical Conditions Land Use Type: Derelict, vacant, backland etc. Constraint Notes: Contamination and ownership Dispute: Agreed Windfall: No Established Land: 2015 Effective Land: Owner: G & AG Proctor Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 40 40 30Market 10Affordable 40Unknown Page 292
Page 293
SITE REF: M/FR/R/23/01 LOCATION: LOCHYHILL (AREA A) Units Not Built Total Units 260Capacity: Planning Applications: FORRES The Moray Council Housing Land Audit 2025 Easting: 305445 Northing: 859534 Area (Ha): 11.94 Primary School: Anderson's Primary School Secondary School: Forres Academy Ward: Forres Effective Land 260 Supply Type: Deliverable LPR: 20/R3 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Agricultural Land Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2007 Effective Land: 2015 Owner: White Family Developer: Robertson Residential Group Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 09/02364 229 Full Expired 02/07/2015 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 30 30 30 30 30 30 30 50 260 195Market 65Affordable 210 260Unknown Page 293
Page 294
SITE REF: M/FR/R/23/02 LOCATION: LOCHYHILL (AREA B) Units Not Built Total Units 500Capacity: Planning Applications: FORRES The Moray Council Housing Land Audit 2025 Easting: 305701 Northing: 859268 Area (Ha): 33.53 Primary School: Anderson's Primary School Secondary School: Forres Academy Ward: Forres Effective Land 500 Supply Type: Deliverable LPR: 20/R3 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Agricultural Land Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2007 Effective Land: 2015 Owner: White Family Developer: Robertson Residential Group Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 10 490 500 375Market 125Affordable 10 500Unknown Page 294
Page 295
SITE REF: M/FR/R/23/03 LOCATION: LOCHYHILL (AREA C) Units Not Built Total Units 90Capacity: Planning Applications: FORRES The Moray Council Housing Land Audit 2025 Easting: 306028 Northing: 859667 Area (Ha): 15.64 Primary School: Anderson's Primary School Secondary School: Forres Academy Ward: Forres Effective Land 0 Supply Type: Constrained LPR: 20/R3 Tenure: Projected Completions: Constrained Land 90 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Ownership Land Use Type: Agricultural Land Constraint Notes: Programming Dispute: Agreed Windfall: No Established Land: 2007 Effective Land: Owner: White Family Developer: Robertson Residential Group Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 90 90 67Market 23Affordable 90Unknown Page 295
Page 296
SITE REF: M/FR/R/24/W1 LOCATION: CHAPELTON FARM Units Not Built Total Units 4Capacity: Planning Applications: FORRES The Moray Council Housing Land Audit 2025 Easting: 304795 Northing: 858006 Area (Ha): 0.92 Primary School: Applegrove Primary School Secondary School: Forres Academy Ward: Forres Effective Land 4 Supply Type: Deliverable LPR: Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: Detail House Programme:Adopted Local Plan: Green/Brown: Brown Constraint Type: Land Use Type: Agricultural Building Constraint Notes: Dispute: Agreed Windfall: Yes Established Land: 2013 Effective Land: 2024 Owner: Tulloch of Cummingston Developer: Tulloch of Cummingston Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 12/01867 Outline Approved 08/11/2013 Plot 3 12/01868 Outline Approved 02/08/2013 Plot 4 09/01010 1 Full Approved 19/04/2010 Plot 2 09/00980 1 Full Approved 11/03/2010 Plot 1 25/00303 2 Full Pending Plots 3 & 4 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 1 1 1 1 4 4Market 4 4House Page 296
Page 297
SITE REF: M/GM/R/15/01 LOCATION: SOUTH OF INNES ROAD Units Not Built Total Units 10Capacity: Planning Applications: GARMOUTH/KINGSTON The Moray Council Housing Land Audit 2025 Easting: 333732 Northing: 864503 Area (Ha): 0.67 Primary School: Mosstodloch Primary School Secondary School: Milne's High School Ward: Fochabers Lhanbryde Effective Land 0 Supply Type: Constrained LPR: 20/R1 Tenure: Projected Completions: Constrained Land 10 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Infrastucture Land Use Type: Agricultural Land Constraint Notes: Infrastrucutre and ownership Dispute: Agreed Windfall: No Established Land: 2015 Effective Land: Owner: Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 2 2 2 2 2 10 7Market 3Affordable 8 10Unknown Page 297
Page 298
SITE REF: M/HP/R/15/R1 LOCATION: MANSE ROAD Units Not Built Total Units 75Capacity: Planning Applications: HOPEMAN The Moray Council Housing Land Audit 2025 Easting: 314186 Northing: 869354 Area (Ha): 4.67 Primary School: Hopeman Primary School Secondary School: Lossiemouth High School Ward: Heldon And Laich Effective Land 69 Supply Type: Deliverable LPR: 20/R1 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: Detail/Under Construction House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Agricultural Land Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2015 Effective Land: 2015 Owner: Tulloch of Cummingston Developer: Tulloch of Cummingston Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 24/01356 1 Full Approved 24/12/2024 Variation of house type (increase of 1 unit) [Phase 1] 20/00278 48 Full Approved 31/03/2022 Phase 1 19/00783 75 PAN for residential development and nursing/retirement home 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 6 10 16 8 8 8 8 8 3 69 56Market 19Affordable 69 14Flat 34House 27Unknown Page 298
Page 299
SITE REF: M/KH/R/015 LOCATION: DUNNYDUFF ROAD Units Not Built Total Units 40Capacity: Planning Applications: KEITH The Moray Council Housing Land Audit 2025 Easting: 343505 Northing: 850034 Area (Ha): 3.22 Primary School: Keith Primary School Secondary School: Keith Grammar School Ward: Keith And Cullen Effective Land 0 Supply Type: Constrained LPR: 20/R2 Tenure: Projected Completions: Constrained Land 36 Extra Information: Planning Consent: Detail House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Ownership Land Use Type: Agricultural Land Constraint Notes: Ownership and marketability Dispute: Agreed Windfall: No Established Land: 2003 Effective Land: 2003 Owner: Various Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 15/00841 1 Outline Refused 01/07/2015 07/01549 21 Full Approved 22/02/2008 1 x Full, 20 x Outline 05/01000 6 Outline Refused 26/05/2006 03/00298 6 Outline Refused 13/11/2003 INDIVIDS 3 Full Approved 97/02052 1 Full Approved 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 6 6 6 6 12 36 30Market 10Affordable 24 4House 36Unknown Page 299
Page 300
SITE REF: M/KH/R/030 LOCATION: BALLOCH ROAD Units Not Built Total Units 6Capacity: Planning Applications: KEITH The Moray Council Housing Land Audit 2025 Easting: 343375 Northing: 850030 Area (Ha): 0.26 Primary School: Keith Primary School Secondary School: Keith Grammar School Ward: Keith And Cullen Effective Land 6 Supply Type: Deliverable LPR: 20/R3 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Brown Constraint Type: Land Use Type: Residential Constraint Notes: Dispute: Agreed Windfall: No Established Land: Effective Land: Owner: Mr and Mrs N. Howie Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 04/02978 7 Full Withdrawn 22/00939 3 Full Withdrawn 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 6 6 4Market 2Affordable 6 6Unknown Page 300
Page 301
SITE REF: M/KH/R/07/08 LOCATION: BANFF ROAD NORTH Units Not Built Total Units 122Capacity: Planning Applications: KEITH The Moray Council Housing Land Audit 2025 Easting: 343562 Northing: 851304 Area (Ha): 8.52 Primary School: Keith Primary School Secondary School: Keith Grammar School Ward: Keith And Cullen Effective Land 58 Supply Type: Deliverable LPR: 20/R4 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: Detail/Under Construction House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Agricultural Land Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2007 Effective Land: 2013 Owner: Moray Council Developer: Springfield Properties Plc Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 18/01497 122 Full Approved 15/07/2019 17/00009 90 Full Approved 15/09/2017 Amend 10/01492 10/01492 76 Full Approved 19/09/2013 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 26 16 16 58 122Affordable 58 40Flat 82House Page 301
Page 302
SITE REF: M/KH/R/07/15 LOCATION: EDINDIACH ROAD (EAST) Units Not Built Total Units 40Capacity: Planning Applications: KEITH The Moray Council Housing Land Audit 2025 Easting: 343940 Northing: 849868 Area (Ha): 5.13 Primary School: Keith Primary School Secondary School: Keith Grammar School Ward: Keith And Cullen Effective Land 0 Supply Type: Constrained LPR: 20/R8 Tenure: Projected Completions: Constrained Land 40 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Infrastucture Land Use Type: Agricultural Land Constraint Notes: Utilities and marketability Dispute: Agreed Windfall: No Established Land: 2007 Effective Land: Owner: Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 40 40 30Market 10Affordable 40Unknown Page 302
Page 303
SITE REF: M/KH/R/15/036 LOCATION: NEWMILL SOUTH ROAD Units Not Built Total Units 7Capacity: Planning Applications: KEITH The Moray Council Housing Land Audit 2025 Easting: 343047 Northing: 851430 Area (Ha): 0.85 Primary School: Keith Primary School Secondary School: Keith Grammar School Ward: Keith And Cullen Effective Land 12 Supply Type: Deliverable with Constraints LPR: 20/OPP3 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: Outline House Programme:Adopted Local Plan: Green/Brown: Brown Constraint Type: Financial Land Use Type: Commercial Constraint Notes: Marketability Dispute: Agreed Windfall: No Established Land: 2016 Effective Land: Owner: ACE Roofing (Keith) Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 15/00998 7 Outline Approved 31/07/2015 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 6 6 12 9Market 3Affordable 12 12Unknown Page 303
Page 304
SITE REF: M/KH/R/20/08 LOCATION: DENWELL ROAD Units Not Built Total Units 5Capacity: Planning Applications: KEITH The Moray Council Housing Land Audit 2025 Easting: 343477 Northing: 849731 Area (Ha): 1.67 Primary School: Keith Primary School Secondary School: Keith Grammar School Ward: Keith And Cullen Effective Land 0 Supply Type: Constrained LPR: 20/R7 Tenure: Projected Completions: Constrained Land 5 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Physical Conditions Land Use Type: Agricultural Land Constraint Notes: Flood risk Dispute: Agreed Windfall: No Established Land: 2020 Effective Land: Owner: Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 5 5 3Market 2Affordable 5Unknown Page 304
Page 305
SITE REF: M/KH/R/20/LG1 LOCATION: NURSERY FIELD LONG1 Units Not Built Total Units 70Capacity: Planning Applications: KEITH The Moray Council Housing Land Audit 2025 Easting: 343114 Northing: 849706 Area (Ha): 2.55 Primary School: Keith Primary School Secondary School: Keith Grammar School Ward: Keith And Cullen Effective Land 70 Supply Type: Deliverable LPR: 20/LONG1 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Agricultural Land Constraint Notes: LONG released in 2023 Dispute: Agreed Windfall: No Established Land: 2020 Effective Land: 2023 Owner: Moray Council Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 4 4 4 58 70 52Market 18Affordable 12 70Unknown Page 305
Page 306
SITE REF: M/KH/R/20/MU LOCATION: BANFF ROAD SOUTH Units Not Built Total Units 50Capacity: Planning Applications: KEITH The Moray Council Housing Land Audit 2025 Easting: 343860 Northing: 850947 Area (Ha): 16.7 Primary School: Keith Primary School Secondary School: Keith Grammar School Ward: Keith And Cullen Effective Land 50 Supply Type: Deliverable LPR: 20/MU Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Agricultural Land Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2020 Effective Land: 2020 Owner: Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 10 20 20 50 37Market 13Affordable 50 50Unknown Page 306
Page 307
SITE REF: M/KH/R/TC/02 LOCATION: 138-140 MID STREET Units Not Built Total Units 4Capacity: Planning Applications: KEITH The Moray Council Housing Land Audit 2025 Easting: 343198 Northing: 850508 Area (Ha): 0.07 Primary School: Keith Primary School Secondary School: Keith Grammar School Ward: Keith And Cullen Effective Land 4 Supply Type: Deliverable LPR: Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: Detail House Programme:Adopted Local Plan: Green/Brown: Brown Constraint Type: Land Use Type: Commercial Constraint Notes: Dispute: Agreed Windfall: Yes Established Land: 2019 Effective Land: 2019 Owner: Mr Barry Fettes Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 20/00161 4 Full Approved 14/10/2020 19/00750 Full Approved 06/08/2019 Inc. retail 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 4 4 4Market 4 4Flat Page 307
Page 308
SITE REF: M/KN/R/003 LOCATION: WEST OF SEAPARK HOUSE Units Not Built Total Units 6Capacity: Planning Applications: KINLOSS The Moray Council Housing Land Audit 2025 Easting: 306068 Northing: 861557 Area (Ha): 1.61 Primary School: Kinloss Primary School Secondary School: Forres Academy Ward: Forres Effective Land 6 Supply Type: Deliverable LPR: 20/R1 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: Detail/Under Construction House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Woodlands Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2007 Effective Land: 2017 Owner: Seapark Estate Ltd Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 21/01836 Full Approved 18/08/2023 Residential and storage caravans during construction [Plot 1] 23/00463 Full Approved 18/08/2023 Plot 5 22/00158 Full Approved 17/08/2023 Plots 3+6 22/00421 Full Approved 16/08/2023 Plot 2 23/00462 Full Approved 16/08/2023 Plot 4 17/00780 Full Approved 05/12/2017 Plot 1 15/01605 6 Outline Approved 03/08/2007 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 2 0 2 0 2 6 6Market 6 6House Page 308
Page 309
SITE REF: M/KN/R/009 LOCATION: FINDHORN ROAD WEST Units Not Built Total Units 6Capacity: Planning Applications: KINLOSS The Moray Council Housing Land Audit 2025 Easting: 306150 Northing: 861832 Area (Ha): 0.6 Primary School: Kinloss Primary School Secondary School: Forres Academy Ward: Forres Effective Land 1 Supply Type: Deliverable LPR: 20/R2 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: Detail/Under Construction House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2013 Effective Land: 2019 Owner: MPD Homes Developer: MPD Homes Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 22/00389 Full Approved 22/07/2022 Rotation of house position (Plot 1) 20/01335 Full Approved 30/03/2021 Rotation of house position (Plot 6) 17/01906 6 Full Approved 07/06/2019 10/01588 6 Full Approved 01/03/2013 07/02082 Full Refused 16/00286 6 Full Withdrawn 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 0 1 1 6Market 1 6House Page 309
Page 310
SITE REF: M/KN/R/07/04 LOCATION: DAMHEAD Units Not Built Total Units 23Capacity: Planning Applications: KINLOSS The Moray Council Housing Land Audit 2025 Easting: 308098 Northing: 862481 Area (Ha): 3.38 Primary School: Kinloss Primary School Secondary School: Forres Academy Ward: Forres Effective Land 23 Supply Type: Deliverable LPR: 20/R3 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: Outline House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Woodlands Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2007 Effective Land: 2020 Owner: The Rhind 2008 Discretionary T Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 23/01408 Full Approved 26/02/2025 Deletion of condition (17 - RCC) 19/00260 23 Outline Approved 15/12/2020 18/00346 19 Outline Withdrawn 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 3 3 3 3 3 3 3 2 23 23Market 23 23House Page 310
Page 311
SITE REF: M/LH/R/07/01 LOCATION: WEST OF ST ANDREWS ROAD Units Not Built Total Units 77Capacity: Planning Applications: LHANBRYDE The Moray Council Housing Land Audit 2025 Easting: 326794 Northing: 861219 Area (Ha): 6.92 Primary School: Lhanbryde Primary School Secondary School: Milne's High School Ward: Fochabers Lhanbryde Effective Land 77 Supply Type: Deliverable LPR: 20/R1 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: Detail House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Agricultural Land Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2007 Effective Land: 2021 Owner: Springfield Properties Plc Developer: Springfield Properties Plc Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 23/02157 Full Approved 26/07/2024 Variation of codition [19 - footpath] 19/01080 77 Full Approved 14/04/2021 18/01190 PAN 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 20 30 27 77 58Market 19Affordable 77 8Flat 69House Page 311
Page 312
SITE REF: M/LH/R/20/02 LOCATION: GARMOUTH ROAD Units Not Built Total Units 24Capacity: Planning Applications: LHANBRYDE The Moray Council Housing Land Audit 2025 Easting: 327858 Northing: 861687 Area (Ha): 1.69 Primary School: Lhanbryde Primary School Secondary School: Milne's High School Ward: Fochabers Lhanbryde Effective Land 24 Supply Type: Deliverable LPR: 20/R2 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: Detail House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Agricultural Land Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2020 Effective Land: 2020 Owner: Moray Council Developer: Grampian Housing Association Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 22/00863 Full Approved 26/08/2022 Variation of roof forms and windows 20/01615 24 Full Approved 04/04/2022 Dev includes 8 specialist care units and staff block 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 12 0 12 24 24Affordable 24 8Flat 16House Page 312
Page 313
SITE REF: M/LS/R/023 LOCATION: INCHBROOM Units Not Built Total Units 83Capacity: Planning Applications: LOSSIEMOUTH The Moray Council Housing Land Audit 2025 Easting: 323497 Northing: 869622 Area (Ha): 7.31 Primary School: St. Gerardine Primary School Secondary School: Lossiemouth High School Ward: Heldon And Laich Effective Land 17 Supply Type: Deliverable LPR: 20/R3 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: Detail/Under Construction House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Woodlands Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2003 Effective Land: 2003 Owner: Tulloch of Cummingston Developer: Tulloch of Cummingston Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 24/01596 Full Approved 19/12/2024 Variation to house type (Plot 42) 23/00983 83 Full Approved 21/06/2024 Variation to layout (Phase 2B - increase in units [8]) 19/01178 75 Full Approved 06/11/2020 Variation to layout and house types (increase in units (4)) 20/00265 Full Approved 04/11/2020 Variation of conditions (Upgrade of junction) 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 4 6 6 5 17 63Market 20Affordable 17 24Flat 59House Page 313
Page 314
SITE REF: M/LS/R/039 LOCATION: WEST BASIN, LOSSIEMOUTH MARINA Units Not Built Total Units 30Capacity: Planning Applications: LOSSIEMOUTH The Moray Council Housing Land Audit 2025 Easting: 323711 Northing: 871205 Area (Ha): 0.35 Primary School: St. Gerardine Primary School Secondary School: Lossiemouth High School Ward: Heldon And Laich Effective Land 21 Supply Type: Deliverable LPR: Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: Detail/Under Construction House Programme:Adopted Local Plan: Green/Brown: Brown Constraint Type: Land Use Type: Commercial Constraint Notes: Dispute: Agreed Windfall: Yes Established Land: 2005 Effective Land: 2008 Owner: Developer: Oakbank Homes Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 17/01802 Full Approved 15/02/2018 Amendment to remove concrete bollards 13/01640 30 Full Approved 05/08/2014 07/02022 21 Full Approved 28/07/2008 04/00974 20 Outline Approved 24/10/2005 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 5 5 11 21 30Market 10 30Flat Page 314
Page 315
SITE REF: M/LS/R/07/01 LOCATION: SUNBANK/KINNEDDAR Units Not Built Total Units 278Capacity: Planning Applications: LOSSIEMOUTH The Moray Council Housing Land Audit 2025 Easting: 322631 Northing: 869449 Area (Ha): 14.49 Primary School: Hythehill Primary School Secondary School: Lossiemouth High School Ward: Heldon And Laich Effective Land 185 Supply Type: Deliverable LPR: 20/R1 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: Detail/Under Construction House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Agricultural Land Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2007 Effective Land: 2017 Owner: Tulloch of Cummingston Developer: Tulloch of Cummingston Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 22/00161 275 Full Approved 07/02/2023 Variation to layout (increase in units (10)) 19/00100 265 Full Approved 12/06/2020 Variation to phasing and layout (increase in units [4]) 17/01076 Full Withdrawn 12/12/2018 Variation to phasing 14/01486 261 Full Approved 11/04/2017 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 14 12 12 12 12 12 12 12 12 12 12 65 185 208Market 70Affordable 120 95Flat 183House Page 315
Page 316
SITE REF: M/MS/R/15/02 LOCATION: GARMOUTH ROAD Units Not Built Total Units 60Capacity: Planning Applications: MOSSTODLOCH The Moray Council Housing Land Audit 2025 Easting: 332766 Northing: 860237 Area (Ha): 3.41 Primary School: Mosstodloch Primary School Secondary School: Milne's High School Ward: Fochabers Lhanbryde Effective Land 0 Supply Type: Constrained LPR: 20/R2 Tenure: Projected Completions: Constrained Land 60 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Ownership Land Use Type: Agricultural Land Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2015 Effective Land: Owner: Crown Estate Scotland Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 60 60 45Market 15Affordable 60Unknown Page 316
Page 317
SITE REF: M/MS/R/20/03 LOCATION: BALNACOUL Units Not Built Total Units 10Capacity: Planning Applications: MOSSTODLOCH The Moray Council Housing Land Audit 2025 Easting: 332551 Northing: 859535 Area (Ha): 2.6 Primary School: Mosstodloch Primary School Secondary School: Milne's High School Ward: Fochabers Lhanbryde Effective Land 0 Supply Type: Constrained LPR: 20/OPP1 Tenure: Projected Completions: Constrained Land 10 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Brown Constraint Type: Ownership Land Use Type: Commercial Constraint Notes: Operational requirements Dispute: Agreed Windfall: No Established Land: 2020 Effective Land: Owner: Forestry and Land Scotland Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 10 10 7Market 3Affordable 10Unknown Page 317
Page 318
SITE REF: M/MS/R/20/MU LOCATION: SOUTH OF A96 Units Not Built Total Units 350Capacity: Planning Applications: MOSSTODLOCH The Moray Council Housing Land Audit 2025 Easting: 333026 Northing: 859605 Area (Ha): 22.3 Primary School: Mosstodloch Primary School Secondary School: Milne's High School Ward: Fochabers Lhanbryde Effective Land 0 Supply Type: Constrained LPR: 20/MUL1 Tenure: Projected Completions: Constrained Land 350 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Ownership Land Use Type: Agricultural Land Constraint Notes: Programming Dispute: Agreed Windfall: No Established Land: 2020 Effective Land: Owner: Crown Estate Scotland Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 350 350 262Market 88Affordable 350Unknown Page 318
Page 319
SITE REF: M/NM/R/001 LOCATION: ISLA ROAD Units Not Built Total Units 10Capacity: Planning Applications: NEWMILL The Moray Council Housing Land Audit 2025 Easting: 343411 Northing: 852366 Area (Ha): 0.36 Primary School: Newmill Primary School Secondary School: Keith Grammar School Ward: Keith And Cullen Effective Land 0 Supply Type: Constrained LPR: 20/R1 Tenure: Projected Completions: Constrained Land 10 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Ownership Land Use Type: Agricultural Land Constraint Notes: Leased on long-term tenancy agreement(s) Dispute: Agreed Windfall: No Established Land: 2003 Effective Land: Owner: Newmill Estate Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 10 10 7Market 3Affordable 10Unknown Page 319
Page 320
SITE REF: M/PG/R/07/04 LOCATION: WEST OF REID TERRACE Units Not Built Total Units 60Capacity: Planning Applications: PORTGORDON The Moray Council Housing Land Audit 2025 Easting: 339143 Northing: 863968 Area (Ha): 3.69 Primary School: Portgordon Primary School Secondary School: Buckie High School Ward: Fochabers Lhanbryde Effective Land 60 Supply Type: Deliverable with Constraints LPR: 20/R1 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Financial Land Use Type: Agricultural Land Constraint Notes: Marketability Dispute: Agreed Windfall: No Established Land: 2007 Effective Land: Owner: Colin Murray Developments Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 10 10 10 10 10 10 60 45Market 15Affordable 60 60Unknown Page 320
Page 321
SITE REF: M/PK/R/004 LOCATION: SEABRAES Units Not Built Total Units 60Capacity: Planning Applications: PORTKNOCKIE The Moray Council Housing Land Audit 2025 Easting: 349342 Northing: 868487 Area (Ha): 3.01 Primary School: Portknockie Primary School Secondary School: Buckie High School Ward: Keith And Cullen Effective Land 60 Supply Type: Deliverable LPR: 20/R1 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Agricultural Land Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2003 Effective Land: 2003 Owner: Seafield Estate Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 04/00799 Outline Refused 10/00418 Screening opinion 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 12 12 12 12 12 60 45Market 15Affordable 60 60Unknown Page 321
Page 322
SITE REF: M/RF/R/07/01 LOCATION: BROCHLOCH Units Not Built Total Units 12Capacity: Planning Applications: RAFFORD The Moray Council Housing Land Audit 2025 Easting: 306752 Northing: 855598 Area (Ha): 1.69 Primary School: Anderson's Primary School Secondary School: Forres Academy Ward: Forres Effective Land 12 Supply Type: Deliverable LPR: 20/R1 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Agricultural Land Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2007 Effective Land: 2011 Owner: Finderne Development Trust Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 24/00528 12 Full Pending 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 12 12 12Affordable 12 12House Page 322
Page 323
SITE REF: M/RS/R/07/01 LOCATION: SPEY STREET Units Not Built Total Units 30Capacity: Planning Applications: ROTHES The Moray Council Housing Land Audit 2025 Easting: 328011 Northing: 849105 Area (Ha): 1.67 Primary School: Rothes Primary School Secondary School: Speyside High School Ward: Speyside Glenlivet Effective Land 30 Supply Type: Deliverable LPR: 20/R1 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Agricultural Land Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2007 Effective Land: 2007 Owner: Mr & Mrs Scott Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 15 15 30 22Market 8Affordable 30 30Unknown Page 323
Page 324
SITE REF: M/RS/R/15/02 LOCATION: GREEN STREET Units Not Built Total Units 40Capacity: Planning Applications: ROTHES The Moray Council Housing Land Audit 2025 Easting: 328284 Northing: 849451 Area (Ha): 1.74 Primary School: Rothes Primary School Secondary School: Speyside High School Ward: Speyside Glenlivet Effective Land 0 Supply Type: Constrained LPR: 20/R2 Tenure: Projected Completions: Constrained Land 40 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Brown Constraint Type: Ownership Land Use Type: Agricultural Building Constraint Notes: Operational farm buildings Dispute: Agreed Windfall: No Established Land: 2015 Effective Land: Owner: Mr Stewart Meldrum Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 10 10 20 40 30Market 10Affordable 20 40Unknown Page 324
Page 325
SITE REF: M/RT/R/001 LOCATION: CASTLE TERRACE Units Not Built Total Units 11Capacity: Planning Applications: ROTHIEMAY The Moray Council Housing Land Audit 2025 Easting: 354854 Northing: 848405 Area (Ha): 1 Primary School: Rothiemay Primary School Secondary School: Keith Grammar School Ward: Keith And Cullen Effective Land 10 Supply Type: Deliverable with Constraints LPR: 20/R1 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: Detail House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Financial Land Use Type: Agricultural Land Constraint Notes: Marketability Dispute: Agreed Windfall: No Established Land: 2003 Effective Land: Owner: Mr Robert Thain Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 15/01013 Full Approved 29/07/2015 Plot 1 14/01431 12 Full Approved 12/11/2014 AMC (07/02477) 11/00991 12 Outline Approved 19/08/2011 Renewal of 07/02477 07/02477 12 Outline Approved 17/07/2008 14/00626 Full Withdrawn 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 10 10 12Market 12House Page 325
Page 326
SITE REF: M/RT/R/07/02 LOCATION: ANDERSON DRIVE Units Not Built Total Units 5Capacity: Planning Applications: ROTHIEMAY The Moray Council Housing Land Audit 2025 Easting: 354630 Northing: 848690 Area (Ha): 0.61 Primary School: Rothiemay Primary School Secondary School: Keith Grammar School Ward: Keith And Cullen Effective Land 0 Supply Type: Constrained LPR: 20/R2 Tenure: Projected Completions: Constrained Land 5 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Physical Conditions Land Use Type: Agricultural Land Constraint Notes: Flood risk and marketability Dispute: Agreed Windfall: No Established Land: 2007 Effective Land: Owner: Mrs H. Mackenzie Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 5 5 5Market 5Unknown Page 326
Page 327
SITE REF: M/RT/R/15/03 LOCATION: DEVERONSIDE ROAD Units Not Built Total Units 20Capacity: Planning Applications: ROTHIEMAY The Moray Council Housing Land Audit 2025 Easting: 354666 Northing: 848375 Area (Ha): 0.92 Primary School: Rothiemay Primary School Secondary School: Keith Grammar School Ward: Keith And Cullen Effective Land 0 Supply Type: Constrained LPR: 20/R3 Tenure: Projected Completions: Constrained Land 20 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Infrastucture Land Use Type: Agricultural Land Constraint Notes: Road access and marketability Dispute: Agreed Windfall: No Established Land: 2015 Effective Land: 2015 Owner: The Church of Scotland Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 20 20 15Market 5Affordable 20Unknown Page 327
Page 328
SITE REF: M/TO/R/21/01 LOCATION: CONGLASS LANE Units Not Built Total Units 8Capacity: Planning Applications: TOMINTOUL The Moray Council Housing Land Audit 2025 Easting: 316655 Northing: 819218 Area (Ha): 0.5 Primary School: Tomintoul Primary School Secondary School: Speyside High School Ward: Speyside Glenlivet Effective Land 8 Supply Type: Deliverable LPR: CNPA21/H1 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Agricultural Land Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2021 Effective Land: 2021 Owner: Crown Estate Scotland Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 4 4 8 6Market 2Affordable 8 8Unknown Page 328
Page 329
SITE REF: M/TO/R/21/02 LOCATION: LECHT DRIVE Units Not Built Total Units 8Capacity: Planning Applications: TOMINTOUL The Moray Council Housing Land Audit 2025 Easting: 317144 Northing: 818525 Area (Ha): 1.1 Primary School: Tomintoul Primary School Secondary School: Speyside High School Ward: Speyside Glenlivet Effective Land 8 Supply Type: Deliverable LPR: CNPA21/H2 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Agricultural Land Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2021 Effective Land: 2021 Owner: Crown Estate Scotland Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 4 4 8 6Market 2Affordable 8 8Unknown Page 329
Page 330
SITE REF: M/UR/R/20/01 LOCATION: MEFT ROAD Units Not Built Total Units 10Capacity: Planning Applications: URQUHART The Moray Council Housing Land Audit 2025 Easting: 328504 Northing: 862749 Area (Ha): 0.8 Primary School: Lhanbryde Primary School Secondary School: Milne's High School Ward: Fochabers Lhanbryde Effective Land 10 Supply Type: Deliverable LPR: 20/R1 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: Detail House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Agricultural Land Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2008 Effective Land: 2015 Owner: Findrassie Developments Ltd Developer: Findrassie Developments Ltd Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 20/00120 10 Full Approved 17/02/2022 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 4 4 2 10 10Market 10 10House Page 330
Page 331
SITE REF: M/UR/R/20/02 LOCATION: STATION ROAD Units Not Built Total Units 8Capacity: Planning Applications: URQUHART The Moray Council Housing Land Audit 2025 Easting: 328866 Northing: 862942 Area (Ha): 0.65 Primary School: Lhanbryde Primary School Secondary School: Milne's High School Ward: Fochabers Lhanbryde Effective Land 8 Supply Type: Deliverable LPR: 20/R2 Tenure: Projected Completions: Constrained Land 0 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Land Use Type: Agricultural Land Constraint Notes: Dispute: Agreed Windfall: No Established Land: 2020 Effective Land: 2020 Owner: Mr Ian Dean Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 4 4 8 6Market 2Affordable 8 8Unknown Page 331
Page 332
SITE REF: M/UR/R/20/L1 LOCATION: MEFT ROAD LONG1 Units Not Built Total Units 10Capacity: Planning Applications: URQUHART The Moray Council Housing Land Audit 2025 Easting: 328425 Northing: 862735 Area (Ha): 0.81 Primary School: Lhanbryde Primary School Secondary School: Milne's High School Ward: Fochabers Lhanbryde Effective Land 0 Supply Type: Constrained LPR: 20/LNG1 Tenure: Projected Completions: Constrained Land 10 Extra Information: Planning Consent: None House Programme:Adopted Local Plan: Green/Brown: Green Constraint Type: Ownership Land Use Type: Agricultural Land Constraint Notes: Programming (LONG) Dispute: Agreed Windfall: No Established Land: 2008 Effective Land: Owner: Rattray Family Developer: Planning: Application Units Type Decision Decision Date NotesAff Type Tenure Type Units Projected 10yr Completions Unit Type: Unit Type Units 20/00120 Full Approved 17/02/2022 Small release of LONG to accommodate development on R1 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035+ 3 3 4 10 7Market 3Affordable 6 10Unknown Page 332