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Agenda Document Pack - Planning and Regulatory Services Committee - 14/01/2026

Moray Council · 14 January 2026
Back to Planning and Regulatory Services Committee — 14 January 2026 and its agenda

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Planning and Regulatory Services Committee 
Wednesday, 14 January 2026 
NOTICE IS HEREBY GIVEN that a Special Meeting of the Planning and Regulatory
Services Committee is to be held at Council Chambers, Council Office, High Street,
Elgin, IV30 1BX on Wednesday, 14 January 2026 at 09:30. 
BUSINESS 
1. Sederunt 
2. Declaration of Group Decisions and Members Interests * 
Guidance Note 5 - 6
3. Planning Application 2501203APP_Redacted
Report by Appointed Officer  
7 - 106 
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.     
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Watching the Meeting
You can watch the webcast live by going to: 
http://www.moray.gov.uk/moray_standard/page_43661.html    
Webcasts are available to view for 1 year following the meeting.  
You can also attend the meeting in person.  If you wish to attend
in person, please come to the High Street entrance door and a
member of staff will let you into the Chamber. 
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GUIDANCE NOTES 
* Declaration of Group Decisions and Members Interests - The Chair of the
meeting shall seek declarations from any individual or political group at the
beginning of a meeting whether any prior decision has been reached on how the
individual or members of the group will vote on any item(s) of business on the
Agenda, and if so on which item(s).  A prior decision shall be one that the
individual or the group deems to be mandatory on the individual or the group
members such that the individual or the group members will be subject to
sanctions should they not vote in accordance with the prior decision.  Any such
prior decisions will be recorded in the Minute of the meeting. 
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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 
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GUIDANCE NOTE PRODUCED FOR PLANNING AND REGULATORY SERVICES COMMITTEE
MEETING OF 14 JANUARY 2026 
REPORT ON APPLICATION 
“Note for guidance of the Committee where the decision of the Planning and Regulatory Services Committee
is contrary to the recommendations of the Depute Chief Executive (Economy, Environment and Finance) in
respect to a Planning Application.” 
Any Councillor putting forward a motion to refuse an application, contrary to recommendation, shall clearly state the
reasons for refusal.  These reasons should be based on policies contained in the approved National Planning
Framework 4 (NPF4), Local Development Plan or some other material consideration.  Time should be allowed to
ensure that these reasons are carefully noted for minuting purposes. 
Where Councillors put forward a motion to approve an application, contrary to recommendation, an indication should
be given of any specific matters which should be subject of conditions along with reasons which should be based on
policies in the approved Local Development Plan or some other appropriate consideration. 
Note for guidance where the decision of the Planning and Regulatory Services Committee is to depart from
the Development Plan (NFP4 and or Local Development Plan) 
Where a Councillor is convinced that there is reason to depart from Development Plan policy; then the Councillor’s
reasons for making the motion should be clearly stated for minuting purposes.  Any matters which should be subject to
conditions drafted subsequently by the Depute Chief Executive (Economy, Environment and Finance) should be
indicated. If the Committee remains of a mind to approve such an application then the whole matter will be subject to
statutory procedures as apply. In such cases, Councillors should be aware that the application may require to be
advertised as a departure and any objections reported to the next available meeting of the Planning and Regulatory
Services Committee.  It also may be necessary to convene a hearing to consider the views of objectors. 
There are three potential consequences if Committee takes a decision where the proper procedures have not been
followed in whole or in part.  Firstly, the person aggrieved by a decision may apply to the Supreme Courts in Scotland
for an Order either compelling the Council to act according to law, quashing the decision altogether or declaring a
decision to be unlawful coupled with an order to prevent the decision being implemented.  A referral to the Supreme
Courts in these circumstances is known as applying for Judicial Review.   
Secondly, in addition to the application for Judicial Review when questions of alleged failure, negligence or
misconduct by individuals or local authorities in the management of public funds arise and are raised either by or with
the External Auditor of the Council and where an individual can be blamed the sanctions available are:- 
Censure of a Councillor or an Officer
Suspension of a Councillor for up to one year
Disqualification of a Councillor for up to five years 
In the case of the Council being to blame, recommendations may be made to the Scottish Ministers about rectification
of the authority’s accounts. Ministers can make an order giving effect to these recommendations. 
Thirdly, whilst the Ombudsman accepts that Planning authorities have the freedom to determine planning applications
as they wish procedural impropriety may be interpreted as maladministration.  This can also lead to recommendations
by the Ombudsman that compensation be paid. 
Consistent implementation of departure procedures maintains public confidence in the planning system and is
consistent with the time and effort invested in preparing the NPF4 and Local Development Plan. 
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WARD 08_17 
25/01203/APP
14 January 2026
Erect a new three-storey building comprising of 1120 pupil
secondary school and additional support needs teaching
facilities and community facilities with associated hard and
soft landscaping external sport provision and car parking
and bus drop-off to replace existing academy on Site of
Forres Academy/Applegrove/Roysvale Forres Moray 
for Moray Council 
Comments: 
• A site visit has been carried out. 
• This is a major application. 
• Advertised for neighbour notification and Schedule 3 purposes.
• 134 representations have been received - 110 of which are objections, 23 supporting
the proposal and 1 neutral. 
Procedure: 
• If minded to approve, first adopt the conclusions of Habitat Regulation Appropriate
Assessment Appraisal summarised in the Observations section of the report, where
adequate mitigation is proposed. 
Recommendation 
Grant Planning Permission - Subject to the following: 
Conditions/Reasons 
1. Unless otherwise agreed in writing with the Council as Planning Authority, the
development to which this permission relates must be begun not later than the
expiration of 3 years beginning with the date on which the permission is granted. 
Reason: The time limit condition is imposed in order to comply with the
requirements of section 58 of the Town and Country Planning (Scotland) Act 1997 as
amended. 
2. Notwithstanding the submitted details, prior to the commencement of any
development, a detailed Phasing Plan and detailed Construction Programme for the
development shall be submitted to and approved the Council, as Planning Authority
Item 3.
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in consultation with the Roads Authority. The Phasing Plan and detailed Construction
Programme shall include the details of all proposed works to deliver the new school
and re-develop the existing school site, along with the timing of works at both the
new school site and existing school site. 
Thereafter, all works shall be completed in accordance with the approved Phasing
Plan and Construction Programme. 
Reason: In order to ensure that the matters specified can be fully considered prior to
the commencement of development. 
3. No development shall commence until evidence has been submitted in writing to
confirm that the statutory process to promote the Stopping Up of the Sanquhar Road
Cycle Track to enable the provision of the new bus lay-by has commenced. 
Reason: To ensure that the required statutory process for the relocation of the cycle
track has commenced. 
4. No development shall commence until evidence has been submitted in writing to
confirm that the statutory process to promote new and amended waiting restrictions
on Orchard Road, Sanquhar Road and Burdsyard Road has commenced. 
Reason: To ensure that the required statutory process for the relocation of the cycle
track has commenced. 
5. No development shall commence until details have been submitted for the approval
in writing of the Planning Authority, in consultation with the Roads Authority, showing
the proposed alterations and restorations to the existing road markings, and the
provision of new road markings in the vicinity of the development along Orchard
Road, Sanquhar Road, and Burdsyard Road, in accordance with The Traffic Signs
Regulations and General Directions 2016; and thereafter the road markings shall be
altered/reinstate in accordance with the approved details once the required changes
to the Traffic Regulation Order have been made as per the above Condition 2. 
Reason: To ensure that the required statutory process for the relocation of the cycle
track has commenced. 
6. Notwithstanding the details submitted on Drawing 619428-JMA-00-ZZ_ZZ-D-A000005
P01, no development shall commence until details of the following have been
submitted to and approved in writing by the Council, as Planning Authority in
consultation with the Roads Authority: 
a)  Drawings (1:200 minimum) showing: 
i)  the widening of the existing footway along the Orchard Road frontage of the
site starting from the existing build-out at the Zebra Crossing and tying in at
an appropriate location to the west of the proposed development access; 
ii)  access radii and dropped kerb provision at the proposed vehicular 
access onto Orchard Road; 
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iii)  amendments to the proposed vehicular access onto Orchard Road to 
provide a pedestrian visibility splay of 2.4 metres by 5 metres in each 
direction clear of any obstruction above 0.6 metres in height; 
iv)  the realignment of the existing dropped kerbs and tactile paving which 
provide a crossing point on Sanquhar Road to the south of the rear 
pedestrian access to Applegrove Primary School; 
v)   the provision of a raised crossing on Burdsyard Road in lieu of the 
proposed Zebra crossing; 
vi)  improvements to Castle Street to enhance the crossing of the Roysvale 
Terrace remote footpath; 
vii) the proposed bus lay-by and replacement cycle track on Sanquhar Road; 
and 
viii)  the proposed new north-south active travel path connecting Core Path 
CPFR32 to the pupil entrance. 
b)  A drawing (Scale 1:100 minimum) showing: 
i)  Details of design and capacity of the proposed cycle parking facilities across
the Forres Academy campus; and 
ii)  Details of the number, 18 minimum, location, and rating (kW) of the
proposed electric vehicle chargers. Thereafter, the works shall be
implemented in accordance with the approved details and in accordance
with the approved Phasing Plan and Construction Programme. 
Reason: To ensure an acceptable development in road safety and sustainable travel
through the provision of details currently lacking from the submitted particulars to
date. 
7. No development shall commence until a Construction Traffic Management Plan
(CTMP) has been submitted to and agreed in writing by the Planning Authority in
consultation with the Roads Authority. 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:
i.  duration of works;
ii.  construction programme; 
iii.  number of vehicle movements (i.e. materials, plant, staff, components);
iv.  types and sizes of construction vehicles accessing the site during the
construction period (Depending on the size of vehicle accessing the site,
vehicle swept paths may be required to confirm that sufficient manoeuvring
space would be available and to confirm that vehicles would be able to enter
and exit the site in a forward gear); 
v.  schedule for delivery of materials and plant; 
vi.  parking provision, loading, and unloading areas for construction traffic; 
vii.  full details of temporary arrangements to safeguard pedestrian movements in
the vicinity of the development during the construction period; 
viii.  full details of the management of deliveries and traffic movements to avoid
school drop off and pick up times for the adjacent Primary School and the
existing Secondary School; 
ix.  full details of any temporary access;
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x.  measures to be put in place to prevent material being deposited on the public
road; 
xi.  Traffic management measures to be put in place during works including any
specific instructions to drivers; 
xii.  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 and 
xiii.  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. 
8. Prior to the opening of the development to the public, evidence of the development
of a School Travel Plan shall be submitted to and agreed in writing with the Planning
Authority, in consultation with the Roads Authority, detailing how the options for
travel to and from the school have been communicated to staff, pupils and parents. 
Reason: To ensure an acceptable form of development in terms of the arrangements
to manage travel associated with the use of the development for secondary
education purposes. 
9. No development shall commence until a safeguarding scheme (protective fencing
with defined access points) which will protect the existing pitch area at Roysvale
Park during the construction period shall be submitted for the written approval of the
planning authority prior to the commencement of development. The approved
safeguarding scheme shall be implemented for the duration of the construction
period. 
Reason: To ensure protection of the pitch area. 
10. The new synthetic pitch will be designed and constructed by a recognised (e.g.
SAPCA* registered) specialist pitch contractor(s). Details of contractor(s) and pitch
specification shall be submitted for the written approval of the planning authority
prior to the commencement of development. *SAPCA is The Sports and Play
Construction Association (www.sapca.org.uk).  The synthetic pitch shall be
constructed in accordance with the approved details. 
Reason: To ensure a satisfactory pitch is provided. 
11. The new synthetic surfaced pitch as approved shall be fully operational and available
for use no later than eighteen months after the opening of the new school, unless
otherwise agreed in writing the Council, as Planning Authority. 
Reason: To ensure the pitch is provided timeously. 
12. The proposed flood storage area and flood bund (Mitigation Option 4) outlined within
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the Flood Risk Assessment modelling report (Mott MacDonald, 2025) must be
constructed and operational prior to commencement of demolition works at the
existing Forres Academy Site. The storage area and flood bund must be maintained
for the lifetime of the development. 
Reason: To ensure there is no increase in flood risk as a result of the development. 
13. The proposed pedestrian footpath (as shown on the Landscape GA Plan drawing no.
619428-RYD-94-XX-XX-D-L-210000 P8) to the west of Roysvale Park shall be fully
constructed and brought into operational use prior to the closure of the core path
(CP-DA01) located on the east side of Roysvale Park, unless otherwise agreed in
writing with the Council, as Planning Authority. 
Reason: To ensure continuous pedestrian connectivity and maintain public access
in the interest of public safety and convenience. 
14. No development shall commence until a detailed Biodiversity Plan for the site edged
red is submitted to and approved in writing by the Planning Authority, in consultation
with the Climate Change Strategy Officer, unless otherwise agreed in writing with the
Council, as Planning Authority. For the avoidance of doubt The Biodiversity Plan
must include detail of:
•  the methodology and phasing for the plan's delivery; and
•  a comprehensive 30-year monitoring and maintenance plan, including details
regarding funding sources and responsible parties. 
Reason: To ensure suitable enhancement provision within the proposal hereby
approved, in the interests of the environment and character of the surrounding area. 
15. Notwithstanding the submitted details in the Carbon Management Statement a
further Carbon Statement is required to be submitted and approved in writing by the
Planning Authority in conjunction with the Climate Change Strategy Officer prior to
the demolition of the existing Forres Academy. The following detail is required within
the Carbon Statement: - 
•  complete energy modelling; 
•  demolition carbon calculations;
•  operational carbon details; and 
•  developing a carbon reporting plan during detailed design phase. 
Thereafter the development shall be delivered and operated in accordance with the
approved Carbon Statement, unless otherwise agree in writing with the Council, as
Planning Authority. 
Reason: To ensure carbon emissions are minimised during the delivery and lifetime
of the development. 
16. Unless otherwise agreed in writing with the Council, as Planning Authority no
development shall commence until a Community Wealth Building Plan prepared in
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accordance with the "Moray Local Development Plan - Community Wealth Building
Planning Guidance" has been submitted to and approved in writing by the Council,
as Planning Authority. Thereafter the proposal shall be implemented in full
accordance with the approved Community Wealth Building Plan.    
Reason: To ensure the development contributes to community wealth building aims
in accordance with National Planning Framework 4 Policy 25 and the "Moray Local
Development Plan - Community Wealth Building Planning Guidance. 
17. The development hereby approved shall be carried out in accordance with the
submitted particulars of the Preliminary Ecological Appraisal (Forres Academy)
dated 21st July 2025 and the identified measures to mitigate the impact and
disturbance upon European Protected Species and nesting birds in section 4
Discussions and Recommendations, unless otherwise agreed in writing with the
Council, as Planning Authority. 
Reason: To ensure an acceptable form of development which will not adversely
impact upon or disturb European Protected Species and nesting birds. 
18. The development hereby approved shall be carried out in accordance with the
submitted details set out in the Tree Survey (Forres Academy) dated 22 September
2025 and the identified Tree Protection Measures detailed on page 11, unless
otherwise agreed in writing with the Council, as Planning Authority.   
Reason: To ensure the existing trees on the site are protected from the development
in the interests of biodiversity, character and appearance of the area. 
19. No existing trees other than those detailed for removal in the Tree Survey (Forres
Academy) dated 22 September 2025 shall be lopped topped or felled, unless
information from a qualified arboriculturalist is submitted justifying why the tree or
part thereof should be removed, unless otherwise agreed in writing with the Council,
as Planning Authority. 
Reason: To ensure the existing trees on the site are retained in the interests of the
biodiversity, character and appearance of the area. 
20. In relation to the approved landscaping scheme (Landscape GA Plan, drawing no.
619428-RYD-94-XX-XX-D-L-210000 P8) all new planting (where possible) must take
place no later than the end of the planting season following the commencement of
the new school. Any planting that cannot take place following commencement of the
new school must take place as soon as practically possible in the next available
planting season. Any trees shrubs and hedge plantings which within a period of 5
years from planting die, are removed or become seriously damaged or diseased shall
be replaced in the following planting season with others of similar size, number and
spacing unless otherwise agreed in writing with the Council, as Planning Authority. 
Reason: In order to ensure that the approved landscaping works are timeously
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carried out and properly maintained in a manner which will not adversely affect the
development of the amenity, appearance, character and quality of the development
and the surrounding area. 
21. Unless otherwise agreed in writing with the Council, as Planning Authority no
development shall commence until detailed elevations of all the fencing shown on
the Landscape GA Plan (drawing no. 619428-RYD-94-XX-XX-D-L-210000 P8) is
submitted to and agreed in writing with the Council, as Planning Authority. 
Reason: To ensure all fencing harmonises with the surrounding area. 
22. The development hereby approved shall be carried out in accordance with the
Drainage Strategy Report (Forres Academy) dated 22 September 2025, unless
otherwise agreed in writing with Council, as Planning Authority. 
Reason: To ensure that foul drainage and surface water drainage is provided
timeously and complies with the principles of SUDs in order to protect the water
environment. 
23. The development hereby approved shall be carried out in accordance with the Flood
Risk Assessment (Forres Academy) dated 3 November 2025, unless otherwise
agreed in writing with the Council, as Planning Authority. 
Reason: To ensure that the development is constructed in full accordance with the
flood protection and mitigation measures detailed in the approved Flood Risk
Assessment. 
24. No development shall commence until details have been submitted to and approved
by the Council, as Planning Authority regarding samples and/or specifications and
colouration of all external material finishes for all buildings/structures within the
development, unless otherwise agreed in writing with the Council, as Planning
Authority. 
Reason: To ensure an acceptable form of development in the interests of the
appearance and amenity of the development and the surrounding area. 
25. Construction works (including vehicle movements) associated with the development
audible at any point on the boundary of any noise sensitive dwelling shall be
permitted between 0800 - 1900 hours, Monday to Friday and 0800 - 1300 hours on
Saturdays only, and at no other times outwith these permitted hours (including
National Holidays). The above construction hours shall apply, unless otherwise
agreed in writing with the Planning Authority, and where so demonstrated
exceptional operational constraints require limited periods of construction works to
be undertaken outwith the permitted construction hours. 
Reason: To protect local residents from noise nuisance in ensuring the construction
phase is restricted within permitted hours.
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26. No development shall commence until a Construction Environmental Management
Plan (CEMP) has been submitted and agreed in writing by the Planning Authority. The
plan shall detail best practicable measures to reduce the impact of construction
noise (including vibration) at noise sensitive locations.  It should also include
measures to minimise and control, 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. 
27. Unless otherwise agreed in writing with the Planning Authority, the lighting on the
approved 3G pitch shall be of the specification Siteco FL11-3 Blade-PL33T located
on Masts M1 to M6, fitted at the mounting height and at the illuminance levels shows
in the supporting drawing titled ‘Forres Academy Proposed Floodlighting.  Drawing
HLS10571, REV1, Dated 19/08/2025’. The agreed lighting details shall be maintained
throughout the lifetime of the development. 
Reason: To protect local residents from light nuisance at the site. 
28. Unless otherwise agreed in writing by the Planning Authority, the use of the lighting
on the 3G pitch shall only be permitted between 0800 to 2100, Monday to Friday, and
0900 to 1700 hours on Saturdays and Sundays and only operational when the pitch is
in use. 
Reason: To protect local residents from light nuisance at the site. 
29. Unless otherwise agreed in writing with the Planning Authority, the use of the 3G
pitch shall be permitted between 0800 to 2100, Monday to Friday, and 0900 to 1700
hours on Saturdays and Sundays. 
Reason: To protect local residents from noise nuisance by ensuring the
development is restricted to permitted hours.   
30. The use of the 3G pitch shall not commence until details have been submitted and
agreed in writing by the Planning Authority, regarding the design and materials of the
“containment boards” as referred to in Section 4.9 and 7.4 of the Noise Impact
Assessment supporting document by RMP dated 8th December 2025 and titled
‘Noise Impact Assessment, New Forres Academy Forres, BIM No: 619428-RMP-ZZ-
ZZ_ZZ-T-AE-10039A’. The 3G pitch sports noise related activities shall not exceed the
levels stated in Table 4.3 of the aforementioned Noise Impact Assessment. 
Reason: To protect local residents from noise nuisance at the site. 
31. Unless otherwise agreed in writing with the Planning Authority, weldmesh fencing
shall be fixed using resilient fixings as referred to in Section 4.17 of the Noise Impact
Assessment supporting document by RMP dated 8th December 2025 and titled
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‘Noise Impact Assessment, New Forres Academy Forres, BIM No: 619428-RMP-ZZ-
ZZ_ZZ-T-AE-10039A.’ 
Reason: To protect local residents from noise nuisance at the site. 
32. The use of the 3G sports pitch shall not commence until a Noise Management Plan
has been submitted and agreed in writing with the Planning Authority as referred to in
Section 7.7 of the Noise Impact Assessment supporting document by RMP dated 8th
December 2025 and titled ‘Noise Impact Assessment, New Forres Academy Forres,
BIM No: 619428-RMP-ZZ-ZZ_ZZ-T-AE-10039A.’. The agreed Noise Management Plan
shall thereafter be implemented and maintained throughout the lifetime of the
development. 
Reason: To protect local residents from noise nuisance due to the use of the
development. 
33. Unless otherwise agreed in writing with the Planning Authority, the use of the dance
and fitness studio within the approved school building shall be permitted between
0800 to 2200, Monday to Friday, and 0900 to 1700 hours on Saturdays and Sundays. 
Reason: To protect local residents from noise nuisance by ensuring the
development is restricted to permitted hours.   
34. The use of the dance/fitness studio shall not commence until details has been
submitted and agreed in writing by the Planning Authority, regarding its design and
building fabrication to ensure noise emissions arising from the studios do not exceed
Noise Rating Curve (NR) 15 as determined within a living apartment of the nearest
noise sensitive dwelling with the window moderately open as referred to in Section
7.5 of the Noise Impact Assessment supporting document by RMP dated 8th
December 2025 and titled ‘Noise Impact Assessment, New Forres Academy Forres,
BIM No: 619428-RMP-ZZ-ZZ_ZZ-T-AE-10039A.’  This limit would apply and be
determined over a minimum of 5 minutes duration between the hours of 0700 to
2300 hours. 
Reason: To protect local residents from noise nuisance from the development. 
35. Prior to the installation of the building plant, further details of the potential noise
impact and mitigation measures required must be submitted to and agreed in writing
by the Planning Authority as referred to in Section 6.5 of the Noise Impact
Assessment supporting document by RMP dated 8th December 2025 and titled
‘Noise Impact Assessment, New Forres Academy Forres, BIM No: 619428-RMP-ZZ-
ZZ_ZZ-T-AE-10039A.’.  This mitigation should ensure noise emissions arising from the
plant does not exceed Noise Rating Curve (NR) 25, as determined within a living
apartment of the nearest noise sensitive dwelling with the window moderately open.
This limit would apply and be determined over a minimum of 5 minutes duration
between the hours of 0700 to 2300 hours. 
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Reason: To protect local residents from noise nuisance at the development. 
36. Prior to the installation of the building plant, further details of the potential noise
impact and mitigation measures required must be submitted to and agreed in writing
by the Planning Authority as referred to in Section 6.5 of the Noise Impact
Assessment supporting document by RMP dated 8th December 2025 and titled
‘Noise Impact Assessment, New Forres Academy Forres, BIM No: 619428-RMP-ZZ-
ZZ_ZZ-T-AE-10039A.’. This mitigation should ensure noise emissions arising from the
plant does not exceed Noise Rating Curve (NR) 20, as determined within a bedroom
of the nearest noise sensitive dwelling with the window moderately open. This limit
would apply and be determined over a minimum of 5 minutes duration between the
hours of 2300 to 0700 hours. 
Reason: To protect local residents from noise nuisance from the development. 
37. Prior to the development commencing, confirmed details of the proposed lighting
shall be submitted to and agreed in writing by the Planning Authority, having regard to
the supporting statement ‘Technical note, Light Pollution Planning Statement,
Project Number 324.016.00, Issued by RYBKA, dated 28/08/2025’.  Thereafter, the
agreed lighting details shall be implemented and maintained throughout the lifetime
of the development. 
Reason: To protect local residents from light nuisance from the site. 
38. Prior to development commencing details of the measures/design features utilised
to deter roosting and nesting gulls upon the roofs of all buildings must be submitted
to and approved in writing by the council as Planning Authority. Thereafter the
measures hereby approved must be adhered to and in place prior to any of the
buildings coming into occupation/use and maintained for the lifetime of the
development. 
Reason: In order to ensure the development does not attract seagull activity which
would be to the detrimental amenity of the users and neighbouring properties. 
39. Maintenance of the Sustainable urban Drainage (SuDs) scheme and flood mitigation
measures will be carried in accordance with the maintenance plan provided within
section 9 of the approved Landscape Maintenance Plan. 
Reason: To ensure that SuDs scheme and flood mitigation measures continue to
operate as required. 
Reason(s) for Decision
The Council’s reason(s) for making this decision are:- 
The proposal is to provide a new Forres Academy and additional support needs teaching
facilities and community facilities with associated landscaping, external sport provision
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including a 3G sports pitch, car parking and bus drop-off to replace the existing academy
on land at Applegrove Playing Field, Roysvale Park and the existing Forres Academy site,
Forres. 
The new school is essential community infrastructure required to deliver a key objective of
the Moray Council. The proposed development represents a significant and positive
opportunity to replace the existing school with a modern, fit-for-purpose facility, while
also enhancing sports and community facilities for the benefit of both students and the
wider community. 
The site layout and building design incorporate green infrastructure, biodiversity
enhancements, and sustainable drainage systems, all of which contribute to nature
recovery and ecological resilience. The proposal demonstrates a clear commitment to
climate action and will minimise lifecycle greenhouse gas emissions and contribute to
Scotland’s net zero targets. 
Subject to conditions where recommended, the siting, design and servicing arrangements
for the replacement school are considered acceptable with no unacceptable or significant
adverse impact identified upon the appearance and amenity of the development plan
and/or the surrounding area. The proposal is, in all respects, considered to be acceptable
and accord with the provisions of the National Planning Framework 4 and Moray Local
Development Plan 2020 and there are no material considerations that indicate otherwise. 
List of Informatives: 
THE TRANSPORTATION MANAGER, has commented that: - 
Planning consent does not carry with it the right to construct a new road or any part
of 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  Road Safety Audit of
accesses and bus drop off/pick up zone. 
The detailed design required for the Road Construction Consent shall be informed by
a Stage 2 Road Safety Audit, for the proposed bus lay-by, new vehicular access onto
Orchard Road, widening of the footway along the Orchard Road site frontage,
pedestrian crossing point on Burdsyard Road and the improvements to the Roysvale
Terrace remote footway crossing of Castle Street. A Stage 3 Road Safety Audit shall
be undertaken prior to the opening of the development to the public and a Stage 4
Road Safety Audit within 1 year of first opening of the development. The applicant
shall act on all recommendations set out at each Stage of the Road Safety Audit
process. 
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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 should also note that all costs associated with the preparation and
promotion of a Road Traffic Regulation Order to facilitate the provision of any
required waiting restrictions along with all costs associated with the provision of
appropriate road markings to support the Road Traffic Regulation Order shall be met
by the developer. 
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. 
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.
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 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. 
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In the event of approval, the applicant should consider liaising with the funeral
director on Orchard Road to see if the Construction Traffic Management Plan, could
accommodate HGV movements from and to the site to avoid funeral events. 
THE SERVICE MANAGER – COMMUNITY PROTECTION, has commented that: - 
This development has been identified from Ordnance Survey Map data as having an
Electricity Sub Station located in the southern section of the site. Moray Council
does not have any further information as to whether the ground is contaminated.
[Safe development is the responsibility of the developer.] You should consider
investigating this matter further prior to proceeding with the proposed works.  Should
contamination be encountered, contact the Environmental Health section
immediately (email contaminated.land@moray.gov.uk  Tel 0300 1234561) to agree
an appropriate course of action. 
The proposed development shall be suitably controlled so as not to give rise to a
Statutory Nuisance in terms of the Environmental Protection Act 1990. 
External lighting shall be suitably maintained so as not to give rise to a Statutory
Nuisance in terms of the Environmental Protection Act 1990. 
Should Planning consent be attained, the food business is recommended to contact
the Environmental Health Section to ensure the premises layout, equipment and
facilities complies with the Food Hygiene (Scotland) Regulations 2006. 
The business operator will require to register the premises in terms of the Food
Premises (Registration) Regulation 1991. 
The premises will require to comply with The Health and Safety at Work etc. Act 1974
and associated regulations enforced by this Section. 
Noise from the indicative sounder equipment on the 3G pitch for bird protection
should be suitably controlled so as not to give rise to a Statutory Nuisance in terms
of the Environmental Protection Act 1990. 
THE SERVICE MANAGER, DEVELOPMENT MANAGEMENT AND BUILDING STANDARDS,
has commented that: - 
During construction work the applicant and/or the developer should remain vigilant
for signs of bats, if they come across any bats or any signs of bats, all work in that
area must cease immediately and Scottish Natural Heritage must be contacted for
further advice. 
It should be noted that as bats are a European Protected Species, as listed in the
Conservation (Natural Habitats &c.) Regulations 1994 it is illegal to: 
•  Deliberately kill, injure, disturb or capture/take European Protected Species of    
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animal.  
•  Damage or destroy the breeding sites or resting places of such animals. 
Furthermore, where it is proposed to carry out works that will affect a European
Protected Species or their shelter/breeding places, whether or not they are present,
a licence is required from the appropriate licensing authority. 
A Building Warrant will be required for the proposals. Should you require further
assistance please do not hesitate to contact Building Standards by telephoning 0300
1234561 or emailing buildngstandards@moray.gov.uk 
LIST OF PLANS AND DRAWINGS SHOWING THE DEVELOPMENT
Reference No. Version No. Title/Description
619428-JMA-00-01_ZZ-D-A-000027 P01 Site Sections
619428-JMA-00-01_00-D-A-000002 P01 Floor Level 00
619428-JMA-00-01_00-D-A-000002 P01 Floor Level 01
619428-JMA-00-01_02-D-A-000002 P01 Floor Level 02
619428-JMA-00-01_R2-D-A-000002 P01 Roof Plan
619428-RYD-94-XX_XX-D-L-211000P6 Hardworks
619428-RYD-94-XX_XX-D-L-700000P6 Planting Strategy
HLS10571 REV1 Proposed Floodlighting
619428-JMA-00-ZZ_ZZ-D-A-000005P01 Proposed Site Plan
619428-RYB-96-00_ZZ-D-ME-00011P04 Proposed Site Services Layout - Sheet 1 Of 5
619428-RYB-96-00_ZZ-D-ME-00012P03 Proposed Site Services Layout - Sheet 2 Of 5
619428-RYB-96-00_ZZ-D-ME-00013P03 Proposed Site Services Layout - Sheet 3 Of 5
619428-RYB-96-00_ZZ-D-ME-00014P03 Proposed Site Services Layout - Sheet 4 Of 5
619428-RYB-96-00_ZZ-D-ME-00015P03 Proposed Site Services Layout - Sheet 5 Of 5
619428-RYB-90-02_00-D-A-000001P02 Sprinkler Compound
FAF-2509-TPN  Tree Protection North
FAF-2509-TPS  Tree Protection South
619428-RYD-94-XX_XX-D-L-213000 P06 Trees To Be Removed and Retained
619428-RYD-94-XXXX-D-L-480001P2 Soft Landscape Details
619428-JMA-00-ZZ_ZZ-D-A-000002P3 Location Plan
619428-RYD-94-XX_XX-D-L-212000P6 Fencing Plan
619428-JMA-90-04_00-D-A-000001P02 CDT Covered Yard Elevations and Floor Plan
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619428-JMA-90-03_00-D-A-000001P02 Bin Store and Substation Elevation and Floor
Plan
619428-JMA-90-01_ZZ-D-A-000001P01 Bird Protection Measures - Main Building
619428-JMA-90-00_ZZ-D-A-000001P01 Bird Protection Site Plan
619428-JMA-90-13_00-D-A-000001P02 External Store Elevations and Floor Plans
619428-JMA-90-11_ZZ-D-A-000026P01 Building Sections
619428-JMA-00-01_ZZ-D-A-000013P01 Site Elevations
619428-RYD-94-XX-XX-D-L-210000P8 Landscape Plan 
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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:
Site Of Forres Academy/Applegrove/Roysvale
Forres
Planning Application Ref Number: 
25/01203/APP 
Location Plan
Applicant Name:
Moray Council 
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Location
plan
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Site
plan
16/01664/APP
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Elevations
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Landscaping
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PLANNING APPLICATION: 25/01203/APP 
In the event that a recommendation on this planning application is overturned the
Committee is reminded of the advice contained on the front page of the agenda for Reports
on Applications 
1.   THE PROPOSAL 
• Planning permission is sought for the erection of a replacement secondary
school, additional support needs teaching facilities, community facilities,
associated hard and soft landscaping, sports provision, 3G pitch, car parking
and bus drop-off on the site of Forres Academy, Applegrove and Roysvale Park. 
• The new school will be 3-storey in height with plant equipment on the roof
which includes air source heat pumps and mechanical ventilation heat
recovery systems. 
• The building would have a footprint of 6,500 sqm (total gross floorspace 13,032
sqm) with a roof height of 13.8m in height. The plant on the roof takes the
overall height to 16.3m. 
• The new building can accommodate 1120 pupils (the same capacity as the
existing Forres Academy). 
• External materials for the new school include facing brick in buff and grey,
polyester powder coated (PPC) aluminium cladding and a polyester powder
coated aluminium framed glazing system. 
• The proposal includes the following:-
• Pedestrian footways, including at the front entrance of the school and
footpaths at the west and east edges of Roysvale Park. 
• A cycle path at the east edge of Roysvale Park. 
• A vehicular access point off Orchard Road, with enhanced provision drop
off at front of the school. 
• Abus layby parallel to Sanquhar Road and reconfigured bus layby on
Burdsyard Road.
• Car parking areas (within the southern part of the site for the school: 140
spaces and 14 EV charging spaces) (within the northern end of the site, for
visitors 11 spaces and 8 accessible). 
• Cycle parking (total of 200 cycle spaces across the site).
• External plant (sprinkler compound, substation).
• Ground lowering works in respect of flood basin at the south end of the
site.
• A full-size synthetic grass pitch (3G astroturf) served by six 15m high flood
lighting masts on the site of the existing Forres Academy. 
• External outdoor activity spaces, including playground, dining area,
enhanced garden provision, food technology area and a craft and design
technical covered area.
• Drainage and Sustainable Urban Drainage (SUDs). 
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• Flood mitigation measures.
• Hard and soft landscaping. 
• The existing grass football pitch and athletics track within Roysvale Park will
remain in use during and after construction. 
• The proposed school is for a ‘5-18 community shared campus’, which will be
accessible to the public; it will be able to offer sports classes, recreation
sessions, activity clubs, range of fitness classes, community group meetings
and social activities. Opening times are as follows: -
• School – 8am to 10pm Monday to Friday and 9am to 5pm Saturday and
Sunday. 
• The use of the facilities will be managed by the school during school
hours and outwith school hours it will be managed by the Councils Sports
and Culture Department. 
• 3G pitch – School term time Monday to Friday is school use only until 4pm
and 4pm to 9pm is for public bookings. Outside school term time public
bookings are Monday to Friday between 9am and 9pm. Weekend use for
public bookings is 9am to 5pm. 
• The existing Forres Academy is to be demolished; this will be undertaken
following occupation of the new school building.
• This planning application is accompanied by the following supporting
information: 
• Arboricultural Impact Assessment 
• Carbon Management Statement 
• Construction Phase Plan 
• Construction Project Management Plan 
• Construction Susutainabilty Plan 
• Construction Traffic Management Plan 
• Design and Access Statement 
• Drainage Strategy Report 
• Ecological Appraisal 
• Ecological Summary 
• Geotechnical Design and Environmental Risk Assessment 
• Landscape Maintenance Plan 
• Noise Impact Assessment 
• Pre-Application Consultation Report 
• Sports Facility Note 
• Tree Suvey 
• Biodiversity Net Gain Assessment 
• Flood Risk Assessment 
• Transport Statement 
• Light Pollution Planning Statement 
• Planning Statement 
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2.   THE SITE 
•  The site is located within the settlement boundary of Forres 250m south of
the Town Centre on Applegrove Playing Field, Roysvale Park and the existing
Forres Academy site. It extends to 8.9 (ha). Land to the south west of the
existing Forres Academy, across the Mosset Burn, is also included within the
site. This is used by the existing Forres Academy for sports. 
•  The site is located in a mixed-use area which is largely residential.
Applegrove Primary School is adjacent to the north east of the site, Forres
Tennis Club is located on the north west boundary of the site, the north east
corner of the site is occupied by the existing Forres Academy building which
includes the Forres Swimming Pool and Hydrotherapy pool and fitness
centre (please note only the Forres Academy Building is to be demolished)
and Sanquhar Woods are to the wider south of the site. 
•  The existing Forres Academy site comprises two distinct areas. The main
site, located adjacent to Roysvale Park, is split by the Mosset Burn and
accommodates the school buildings, Forres Swimming and Hydrotherapy
Pool, car parks, and a mix of hard and soft sports pitches. In addition, there
is a satellite site to the south, connected by footpaths from the main
campus, which provides additional grass playing fields.
•  The part of the site where the new school is proposed is covered by an ENV4
designation “Applegrove Primary School” (as defined in the Moray Local
Development Plan 2020 (MLDP settlement Statement for Forres)  South of
this, there are four further ENV4 designations on the site,  “Roysvale”,
“Playing Field (Mosset Burn)”,  “Playing Field (Burn of Mosset)” and
“Lochview” and  are all sports areas. 
Roysvale Park, currently has a grass football pitch and athletics pitch
marked out on it. The bus drop-off lane with pavement and cycle path and a
contractor’s compound (only required temporarily for phase 1 of the
development) are to be located within Roysvale Park. 
3.   HISTORY 
25/00672/PAN - Proposal of Application Notice (PAN) for the Erection of a new
three-storey building comprising of 1120 pupil secondary school and additional
support needs teaching facilities and community facilities with associated hard
and soft landscaping, external sport provision and car parking and bus drop-off to
replace existing academy at Forres Academy, Burdsyard Road, Forres – response
issued 18 June 2025, confirms the requirements for consultation with the local
community i.e. consultation with the local Community Council and other
surrounding Community Councils and at least two public events. 
Following consideration of the PAN by the Planning & Regulatory Services
Committee (on 12 August 2025) there were no provisional views/statements from
any members. 
25/00548/SCN – (Screening Opinion) Erect a new three-storey building
comprising of 1120 pupil secondary school and additional support needs teaching
facilities and community facilities with associated hard and soft landscaping,
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external sport provision and car parking to replace existing academy at Forres
Academy Burdsyard Road, Forres. Decision issued on 27 May 2025 confirmed that
no Environmental Impact Assessment is required. 
25/00159/PEMAJ - Erection of new secondary school with community facilities
and associated infrastructure on land west of Applegrove Primary School
Forres. Following a pre-application meeting, response (24 March 2025) provides
feedback on the proposal, including consultee responses and identification of
information expected to accompany any formal application. 
4.   POLICIES 
National Planning Framework 4 
NPF1 - Tackling the Climate 
NPF2 - Climate Mitigation and Adaptation 
NPF3 - Biodiversity 
NPF6 - Forestry, Woodland and Trees 
NPF7 - Historic Assets and Places 
NPF9 – Brownfield, Vacant, Derelict land 
NPF 12 – Zero Waste
NPF13 - Sustainable Transport 
NPF14 - Design, Quality and Place 
NPF 15 Local Living and 20 Minute Neighbourhoods 
NPF18 - Infrastructure First 
NPF 19 - Heating and Cooling
NPF21 - Play, Recreation and Sport 
NPF22 - Flood Risk 
NPF23 - Health and Safety 
NPF25 - Community Wealth Building 
Moray Local Development Plan 2020 
PP1 - Placemaking 
PP2 - Sustainable Economic Growth 
PP3 - Infrastructure and Services 
DP1 - Development Principles 
EP2 - Biodiversity 
EP5 - Open Space 
EP7 - Forestry Woodland and Trees 
EP8 - Historic Environment 
EP12 - Management and Enhancement Water 
EP13 - Foul Drainage 
EP14 - Pollution Contamination Hazards 
Forres ENV4 – Sports Areas
• ‘Roysvale’
• ‘Playing Field (Burn of Mosset)’
• ‘Academy Playing Fields’
• ‘Applegrove Primary School’
• ‘Lochview’
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5.   ADVERTISEMENTS 
5.1  The application has been advertised for neighbour notification purposes and as
development defined under Schedule 3 of The Town and Country Planning
(Development Management Procedure) (Scotland) Regulations 2013. 
6.   CONSULTATIONS 
Strategic Planning and Development – No objection. Proposal complies with all
relevant Moray Local Development 2020 and National Planning Framework
policies subject to conditions relating to a detailed Biodiversity Plan, an updated
Carbon Statement (once the additional design detail is available) and a
Community Wealth Building Plan. 
Planning and Developer Obligations – No developer obligations sought. 
Moray Access Manager – No objection subject to the replacement cycle/ footpath
adjacent to Sanquhar Road being constructed like for like in terms of a durable,
smooth surface (as shown in the Landscape General Arrangement Plan and this
path being opened as quickly as possible. A condition is attached to the consent
requiring the proposed pedestrian footpath to the west of Roysvale Park being fully
constructed and brought into operational use prior to the closure of the core path
(CP-DA01) located on the east side of Roysvale Park. 
Moray Flood Risk Manager - No objection subject to a condition requiring the
proposed flood storage area and bund being fully operational prior to the
commencement of the demolition of the existing academy. 
SEPA – No objection subject to a condition requiring the proposed flood storage
area and flood bund (Mitigation Option 4) outlined within the Flood Risk
Assessment modelling report (Mott MacDonald, 2025) being constructed and
operational prior to commencement of demolition works at the existing Forres
Academy Site. 
Sportscotland – No objection subject to conditions relating to a safeguarding
scheme which protects the existing pitch area at Roysvale Park during the
construction period, the new synthetic pitch being surfaced with a synthetic pitch
that will be designed and constructed by a recognised (e.g. SAPCA* registered)
specialist pitch contractor(s) and the new synthetic surfaced pitch being fully
operational and available for use not later than eighteen months  after the opening
of the new school, unless otherwise agreed in writing. 
Forres Community Council – Support proposal – for the new school as it is much
needed in the area. Support on the provision that the drainage and flood
alleviation shown in the plan are fully costed and all risks are fully mitigated. 
Moray Council Education – No objection. 
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SSEN Transmissions – No comments. 
Environmental Health – No objection subject to conditions relating to
construction works permitted hours, a Construction Environmental Management
Plan (CEMP), type of lighting on the 3G pitch and its permitted hours of use, the
hours of permitted use of the 3G pitch, the design and materials of the
containment boards for the 3G pitch, the type of fencing for the 3G pitch, a noise
management plan for the 3G pitch, hours of operation of the dance and fitness
studio, design and building fabrication details of the dance and fitness studio,
noise impact and mitigation measures of the building plant and confirmation of
the lighting. Informatives are also provided. 
Contaminated Land – No objection – an informative is recommended regarding
an Electricity Sub Station located in the southern section of the site and that it
should be considered investigating to establish whether the land is contaminated
with mitigation if required. 
Transportation Manager – No objection subject to  conditions relating to a
Phasing and Construction Plan; evidence being submitted to confirm that the
statutory process to promote the Stopping Up of the Sanquhar Road Cycle Track
to enable the provision of the new bus lay-by has commenced; evidence being
submitted to confirm that the statutory process to promote new and amended
waiting restrictions on Orchard Road, Sanquhar Road and Burdsyard Road has
commenced; the proposed alterations and restorations to the existing road
markings; the provision of new road markings in the vicinity of the development
along Orchard Road, Sanquhar Road, and Burdsyard Road, amendments and
improvements to ensure acceptable development in road safety and sustainable
travel; a Construction Traffic Management Plan and evidence of the development
of a School Travel Plan being submitted. All of the conditions are required to be
discharged prior to the commencement of development apart from the final
condition that relates to a school Travel Plan, this is required to be submitted and
agreed in writing prior to the opening of the development of the public.
Informatives are also recommended.   
Scottish Water – No objection – Confirmed capacity for water and waste water
connection and details provided on surface water requirements and asset impact
assessment, drinking water protected areas and next steps for non-domestic /
commercial properties and trade effluent discharge from non-domestic property.   
Aberdeenshire Archaeology – No objection. 
7.   OBJECTIONS-REPRESENTATIONS 
NOTE: Following the determination of this application, name and address details
will be/have been removed (i.e. redacted) in accordance with the General Data
Protection Regulations (paragraph 3 of Minute, Planning & Regulatory Services
Committee 16 September 2014).
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This application has attracted representations from 134 individuals, 110 of which
are objections, 1 neutral and 23 in support. A list of names and addresses of
persons/parties that submitted representations is in Appendix 1. 
Two neighbour notification periods have been run during the consideration of the
application, and all representations have been read and where material given
appropriate consideration prior to the recommendation being finalised. Given the
number of representations, the material grounds for objection/representation are
summarised below. Comments that are not material considerations have also
been summarised. The grounds for objection/representations have been generally
grouped into the topic heading below to aid reference. The main issues raised in
the representations can be summarised as follows: 
Objection 
Loss of Privacy 
Parking 
Reduction of natural light 
Road Access
Road Safety 
Traffic 
View affected 
Affecting natural light 
Drainage 
Litter 
Over-development of site 
Poor design 
Smell 
Inadequate Plans 
Dust
Height of proposed development
Noise 
Affecting natural environment 
Legal issues 
Loss of privacy (being overlooked)
Poor design 
Procedures not followed correctly
Activity at unsociable hours/behaviour 
Community Council / Association Consult 
Out of Time Objection
Inappropriate materials / finishes 
Siting and Design
•  The school is shoehorned into the site and there is no room to expand it. 
•  Lack of facilities due to size of site.
•  The proposed relocation would represent overdevelopment on a site that is
ill-suited to a large institutional use and would significantly alter the
character of the area.
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•  It is being located in a primary school play area because it's the cheapest
option. Extra money should be spent to have the academy at Lochyhill. 
•  Roysvale Park is common good land. 
•  There are better alternative sites such as Lochyhill.
•  The original survey done by Moray Council as to where the new Academy
should be built, more than half suggested Lochyhill was best. 
•  Building on an already built-up area makes no sense.
•  Disruption to residential area. 
•  It is not a safe place for so many children considering there's another two
schools in close proximity.
•  Building on Applegrove playing field is a loss for the community. 
•  Brownfield sites or underutilized land nearby could be viable options.
•  Has there been a study on the pollution and general health conditions such
as asthma in such proximity to a primary school. 
•  With this new plan, in excess of 1000 academy pupils, approx. 300 primary
pupils plus a large community of local residents who often use Roysvale
Park common good land for recreation/dog walking etc will all be sharing
this limited area. A step backwards and a real loss of green space with no
replacement.
•  Regulations state secondary schools of the proposed size should have
playing fields 3.6 hectares (36000 square metres). Roysvale park is
(14600m2) and a new 3G football pitch (7000m2) so therefore it falls
significantly short. 
•  The principle of locating such a large school build on an existing primary
playing field appears contrary to the objective of preserving existing
educational outdoor facilities for younger children.
•  The inclusion of public facilities and library probably means that the
functions of the existing community centre are likely to be transferred to the
new building. The new location for this is much too far from the town centre.
The current community centre should be retained and the new building
reduced in size. 
•  Would feel uncomfortable accessing community facilities within a
secondary school.
•  Building a new school even closer to the centre of the town defies logic and
goes against everything that is being done nationally to making inner city /
town environments more friendly and healthy places to live in.
•  If it was in the Roysvale Park area it would not look as out of place next to the
nearby villas. 
•  The Council is trying to bill the Applegrove site as an ideal place for a 5-18
campus. There is no precedent for 5-18 campuses in Scotland, apart from
enhanced provision schools which tend to be much smaller. The majority of
3-18 campuses in Scotland have been built on greenfield sites on the edge of
town and there is no precedent for shoe-horning such a significant build into
town centres.
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•  A three-storey building of the type proposed would appear incongruous and
overbearing, creating a visual impact that is entirely out of step with the
established pattern of development. The form and scale of the proposal
seem to result from an attempt to shoehorn a large structure into an
unsuitable site rather than from a design that responds sympathetically to
its setting.
•  Forres Academy will have bits and pieces of land making up their campus,
split by busy roads, at a distance from the actual school. The feasibility
study stated that the new school campus should not be a split campus.
•  The proposed site is outwith the Forres Conservation Area although there
were previous proposals to extend the Conservation area boundary to
include properties along Sanquhar Road which overlook Applegrove and
Roysvale Park.
•  The simple 25 degree section is misleading for the pitch of sunlight during
the winter months in Forres. An aerial photograph in the local press of
Applegrove Playing Fields and Roysvale Park with the existing mature trees
between the two green spaces shows a shadow of a great depth into
Applegrove. With the proposed building being of a similar height it is difficult
to see how the Veteran Cottages will not be in shade and how this is
acceptable?
•  The drawing on page 50 of the design and access statement which seems to
suggest there will be no impact to the war veteran cottages daylight but is
entirely misleading in that regard. The 25° rule is a preliminary rule of thumb
and not a substitute for a detailed daylight assessment. A context specific
approach should be used here. The sun is below 25° in Forres from early
October to the end of February. So, for roughly 4.5 months of the year, the
veterans' cottages will be deprived of direct sunlight they once had.
•  The footpath to the west of Roysvale Park is also not required. There is a
recently upgraded cycle / footpath next to Sanquhar Road. Removal of this
would reduce the impact on the common good land.
•  There is little space within the site for the pupils to go at break and lunch.
This will result in overspill into Roysvale Park or the High Street.
•  The building size could be significantly reduced if the community facility
aspects were removed. This would also reduce build costs.
•  Placing a community facility at Applegrove Playing Field will likely result in
the loss of facilities and economic decline on Forres High Street. Any
community facilities moved to the Academy site will not be available to the
community with the same flexibility and open access as they are now. This
will result in loss of available amenities to the community, not gain.
•  The siting of the 3G pitch a good distance away from the main building will
impact the time available for PE classes as pupils will take time to get to the
site back again.
•  Potential for risk to health from the distance walked to the site from the 3G
pitch in terms of weather conditions but also for first aid if a pupil becomes
injured.
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•  Should be built onsite of existing academy. Provision of temporary
classroom facilities would cost more, but it would also solve the RAAC
problems even sooner than the optimistic October 2028 date as proposed.
•  Classroom windows, and circulation zones will directly overlook veterans'
gardens and windows.
•  The plan is an "eye-sore" and the design is unsuitable for the local traditional
vernacular.
•  The use of buff brickwork and sheet metal cladding is considered out of
character with the area's historic buildings. 
•  The proposed 3-to-4 storey height is "out of keeping" with local amenity and
will tower over single-storey homes in Cicely Place, Roysvale Place, Albert
Street, and the Veterans' Cottages.
•  Comparisons to existing structures like Hainings Court are not relatable, the
plant rooms' height is not adequately considered.
•  Concern raised about the negative impact on a well preserved quiet green
area" and the "landscape of the lovely old town of Forres.
•  Concern regarding overshadowing, loss of light, and loss of openness for
nearby properties and gardens, as well as for the adjacent Applegrove
Primary School.
•  Privacy is a concern, with the upper levels of the new building likely to
overlook neighbouring properties and gardens.
•  The reliance on trees for permanent screening is challenged, as trees can be
removed.
•  The artist's impression of the view from Orchard Road is misleading and
inaccurate.
•  The design does not respect local character or scale, contrary to the aims of
the Moray Local Development Plan.
•  There is a lack of clarity, as there is no overall height of the building
elevations shown in the plans.
•  The size of proposed outdoor learning spaces (outdoor classroom, garden) is
considered too small and inadequate for a school of 1200 pupils.
•  The proposed roofs at 4-10 degrees are classified as flat. Adding a pitched
roof would further increase the height however other applications for
buildings with flat roofs are often refused. The flatness also requires
protection from birds nesting.
•  The height and massing are out of keeping with nearby single and two-storey
housing, breaching NPF Policy 14 and MLDP Policy PP1, which require
design to respect existing scale and context.
•  Upper floors will overlook gardens and homes on Orchard Road, Sanquhar
Road, and Albert Street, leading to loss of privacy contrary to MLDP Policy
DP1 and NPF Policy 14(c) which protect residential amenity. The upper
floors will have direct line of site into house.
•  The development's height and bulk will dominate views across Roysvale
Park and the Forres skyline, harming visual amenity and townscape
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character. This is contrary to NPF Policy 14 and MLDP Policy PP1 (high-
quality, context-sensitive design).
•  The proposal fails to comply with both NPF4 Policy 14(c) and Policy
DP1(i)(a). It does not respect the scale, density, or character of the
surrounding area, and its design is detrimental to local amenity. The
development would introduce an overbearing and incongruous form into a
setting of modest dwellings, undermining the qualities of a successful place.
•  Reference to the site elevations (drawing no. 000027) and the visual impact
assessments contained in Part 8 of the Design & Access Statement confirms
that the proposed building would dominate its surroundings, appearing as a
bulky giant in comparison to neighbouring properties.
•  Serious concern for the quality of life for those who live in the War Veteran
cottages. Their entire living space will be dominated by a large 3 storey
building. 
•  Natural light and gardens degraded with loss due to no direct sunlight in the
winter months. 
•  Neighbouring properties will have an increase in noise litter and boisterous
teenagers. 
•  Neighbouring properties will be overlooked, as well as losing light, privacy,
being disturbed by noise. 
•  Locating the new academy in Applegrove Playing Fields will seriously impact
the residents in close proximity to the building in particular the Veterans and
those living in Roysvale cottages. 
Comments (PO): 
The new school building replaces an outdated facility with a modern, purpose-
built design on an adequately sized site. Its co-location with Applegrove Primary
School establishes a central hub that strengthens both educational provision and
community amenities. The development is sensitively integrated into its setting,
featuring landscaped areas and outdoor sports facilities to complement the
surrounding environment. There is not an unacceptable impact on amenity for
neighbouring properties. The proposal complies with all siting and design policies
of NPF and MLDP as detailed in the observation section of this report. 
It is not anticipated that future extensions to the school will be required given the
new school can accommodate 1120 pupils. The current school role is less than
880.   
Three potential sites were jointly and collectively scored by Design Team
members, and the outcome of the appraisal determined that Roysvale Park
achieved the highest overall score and thus would be the preferred site. It is
considered that a central site, still accessible to all neighbourhoods within the
town, would serve the settlement better than one on its outskirts. 
As with any new build or re-development on a site, construction impacts including
disturbance and disruption are somewhat inevitable but likely to be intermittent,
occur over a short-term period and are temporary in duration.  Attention to the on-
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site management of construction activity, including 'best practice' and adherence
to requirements of other legislation can also address and mitigate the impact of
such effects to ensure that any residual impacts, if any, are not significant. Noise,
dust and vibration monitoring stations will be set up prior to commencement of
works and this will be used as a baseline comparison for the regular monitoring
that will take place during construction. 
It is acknowledged that the chosen site results in a reduction of play space for
Applegrove Primary School. While this is regrettable, the broader benefits of
utilising this location are considered to outweigh the loss of the play area. 
Sportscotland have returned their consultation response with no objection
subject to conditions. The required playing areas sizes have been met. 
Balfour Beatty have mandated Considerate Contractor scheme compliance for all
sites and will have regular meetings with both school management teams. There
will be a robust construction and traffic management plan in place: these include
restricted and allocated delivery and access / egress times to the site. 
The Vertical Sky Component method used to assess the daylight impact of a
proposal on a window is sufficiently clear using the 25 degrees assessment. This
method of assessing daylight impact to neighbouring properties is deemed
acceptable. 
The public can still use Roysvale Park as they currently do. 
The facilities being provided in the school for the public are also required for use
by pupils of the new school as well as nearby primary schools. It is unlikely that
the new school offering some community facilities will result in the decline of the
High Street, this is speculative. 
There is ample dining space for pupils internally and externally for the new school. 
There are a number of 5-18 campus schools already operational in Scotland and
further schools are planned. In the case of the Applegrove/Roysvale site, it
provides an opportunity to create a 5-18 community campus school by
incorporating the existing Applegrove into the design consideration. 
Traffic 
•  The area already experiences high traffic volume, illegal parking, road rage,
and congestion during school hours, backing up to the High Street
roundabout. Orchard Road and St Leonard's Road has heavy commercial
traffic (vans, timber lorries, agricultural vehicles) using them. 
•  Existing car parks in the area are frequently full. 
•  Traffic is already an issue in school hours at the traffic lights and backing up
to the roundabout at the bottom of the High Street. 
•  The increased volume of cars, HGV construction vehicles, and buses poses
a significant safety hazard for pupils, pedestrians, and cyclists. Hazards
include blind junctions (bottom of Nelson Road), current Academy pupils
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spilling across roads, and a lack of monitored crossings. It is feared that a
serious injury or fatality is only a matter of time.
•  Adding another 1000 secondary pupils into this area will exacerbate the
existing situation. 
•  There is no mention of road crossings, patrolled or otherwise or where the
Applegrove parents can pick up and drop off when their usual areas are
blocked by construction traffic and the new bus parking lanes. This will
cause issues for all neighbouring residents who will be unable to access
their properties by car.
•  The Victorian Street infrastructure is not designed for the volume or size of
vehicles anticipated during construction. 
•  Concern regarding use of the surrounding roads will be undermined by heavy
construction traffic over three years, they are not fit for this.
•  The construction phase will add significant vehicle movements (up to 300
personnel movements, 500 delivery movements daily) competing with
existing school traffic. 
•  Delivery restrictions do not adequately cover the Applegrove Primary finish
time.
•  The current traffic management plans are viewed as based on questionable
or inadequate data, not accounting for "human nature" (e.g., illegal parking,
speeding). 
•  The Transport Statement focuses on parking occupancy rather than overall
traffic flow.
•  Proposed new bus drop-off points may cause chaos with existing Applegrove
school drop-offs. Buses should use tarred area at rear of school. 
•  Using Roysvale Park for P.E. is considered unsafe due to proximity to the
road. 
•  A potential lack of court consent for using common good land for a bus layby
could derail the entire plan.
•  The proposed development dramatically exacerbates documented existing,
safety hazards and infrastructure deficiencies, which currently range from
daily frustration and illegal parking to serious accident risks. 
•  An in-depth study into the impact of increased traffic in the building phase
and operating phase of the Applegrove/Lochyhill site does not appear to
have taken place.
•  Can delivery restrictions be put in place when funerals are taking place at
the funeral director across the street?
•  Existing roads (Sanquhar, Orchard, Burdsyard, and Albert) are narrow,
already congested, and unsafe for heavy goods vehicles and increased
traffic. The design fails MLDP Policy T2 (safe and suitable access).
•  Proposal is inconsistent with LDP Policy T2 (Provision of Access) and Policy
T3 (Parking Standards), which require that developments ensure adequate
parking and road-safety measures. It also fails NPF4 Policy 13 (Sustainable
Transport), which seeks to improve conditions for active travel and local
amenity.
•  The 20-minute neighbourhood in NPF Policy 15 is noted in the planning
proposal however it is not appropriate to assess this proposal against it
given the rural context and limited transport infrastructure in Forres. The
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proposal underestimates car dependency and risks creating parking
shortfalls and congestion, contrary to NPF Policies 13 and 15 and MLDP
Policies PP1 and T2. A balanced approach that reflects local realities and
ensures adequate parking and safe access is essential. 
Comments (PO): 
The Transportation Service Manager has considered all these issues as part of the
application but does not object to the proposal on road safety, traffic congestion
or parking grounds subject to conditions and informatives being attached to the
planning consent if permitted. The proposal complies with the policies of NPF and
MLDP in terms of Transportation requirements as detailed in the observation
section of this report. 
Policies T1 and T2 are from the MLDP 2015. This local plan has been replaced with
the MLDP 2020. The relevant policies of the MLDP have been complied with, as
detailed in the observation section of this report. 
The start of the school day at Forres Academy is earlier than for Applegrove
Primary school and the end of the school day is later. Observations are that the
timing of activity at both schools is separate and distinct. This means that the use
of the bus lay-by will be before the drop off time for the primary school and after
the pickup time at the end of the school day – except on Fridays when this will
occur at lunchtime. 
The predicted number of additional pupils attending the new school is 15 in 2032.
8.4% percent of pupils are currently dropped off by parents which means there
would only be a small increase in this by 2032. The provision of teacher parking
will be at the same location. Bus movements will not be substantially different as
they already use Castle Street, Burdsyard Road and Sanquhar Road to access the
existing school. 
Traffic routing through the A940/Orchard Road traffic signals will remain unaltered
by the relocation of the senior school. 
Parents choosing to park on existing waiting restrictions is a matter for Police
Scotland. The Council’s Park Smart programme is a joint action between Police
Scotland, Transportation and a school to educate and inform parents/carers
about safe parking. 
If Applegrove is experiencing problems with indiscriminate parking, taking part in
Park Smart can assist with educating parents/carers to address their behaviours.
Transportation will be happy to liaise with Applegrove School to undertake this
programme, should they wish to participate. 
There are existing 20mph speed limits in place around Applegrove, Andersons and
Forres Academy. All roads surrounding the schools are to have a reduced speed
limit of 20mph in the new year as part of the National Strategy for 20mph. 
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A condition attached to the planning consent seeking road markings to be
provided to protect property driveways and discourage parking is recommended. 
The school is a replacement school with access for pupils from the southern side
of the building. This is only some 300m from the pupil access for the existing
Forres Academy building. 
A condition requiring a construction traffic management plan (CTMP) to be agreed
with the Council prior to works commencing on the site is to be attached to the
consent. This will ensure an acceptable form of development in terms of the
arrangements to manage traffic during construction works at the site. 
Deliveries out with school drop off and pick up times is standard practice for
development near schools. 
Travel to and from school (excluding on a school bus/taxi) is the responsibility of
parents/carers. 
A definitive study into the impact of construction traffic is not required at this
stage and the Construction Traffic Management Plan is normally not finalised until
a contractor has been appointed. Effects will be temporary and are dependent on
construction techniques and programme. The CTMP will provide information and
proposals for mitigation. 
Transportation advised that delivery restrictions could be written into the
Construction Traffic Management Plan/Travel Plan for when funerals are taking
place. The funeral director would be responsible for providing timings with an
appropriate amount of notice so deliveries can be amended if need be.  An
informative is recommended to encourage the applicant to investigate this
possible measure. 
Parking 
•  The plan relies on staff and parents using distant car parks (High Street,
other side of Roysvale Park). This ignores "human nature"; people will
choose to park illegally or on nearby residential streets (Albert Street, etc.)
for convenience, especially in bad weather or when carrying supplies. This
displaces existing users of public car parks (library, dance classes, tennis
courts, residents) and exacerbates existing Applegrove parking issues.
•  The split-site parking location (remote from the main building) is impractical
and creates safety hazards with increased on-street parking that could block
emergency vehicle access. The entrance/exit points on narrow roads will
increase congestion at blind spots.
•  Using the existing tarred area/car park at the rear of the current academy site
for bus drop-offs/staff parking or modifying the current bus stop area to be
longer, removing the need to appropriate Common Good land in Roysvale
Park for a new bus layby/parking area.
•  There is no designated parking close to the proposed site, this will cause
chaos on Orchard Road which is already congested with traffic from
Applegrove. 
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•  The proposed vehicle entrance to the new school is close to neighbouring
properties traffic congestion will increase as cars turn into and emerge from
the small car park proposed in the plan. 
•  The Moray Council has stated in consultation that the current bus drop off
cannot be used as children would have to cross the road when they get off
the bus. The Moray Council, however, has canvassed for a town centre (20 
minute neighbourhood) school so children can walk / cycle to school. Will
children who walk or cycle not have to cross a road? The argument put
forward by the Moray Council at consultation for this bus lane does not stack
up.
•  Where will people park to use the community facilities. There are no bus
stops nearby the new school therefore how are people supposed to access
them such as the elderly. 
•  Drawing more traffic into the town centre permanently counters government
recommendations on pollution. Concerns were raised about bus drivers
idling their engines and the impact of traffic fumes on public health (asthma,
COPD).
•  The traffic survey was conducted on a single summer day (June 12th, 2025)
which is likely unrepresentative of peak winter traffic flows. The data for
community centre use figures is also questionable.
•  The local Victorian road infrastructure is already vulnerable (a section of
Orchard Road recently collapsed). The high volume of construction HGV
traffic poses an extreme risk, especially concerning access for emergency
vehicles during an accident.
•  The council planning statement indicates increased demand for car/bus
access, the local network and narrow streets may not be sufficient to cope
without significant detrimental impact on residents.
•  There are not enough parking spaces outside the swimming
pool/hydrotherapy pool/gym, so people are parking out on Burdsyard Road,
and it is difficult to pass the cars when cars are coming from opposite
direction.
•  During construction the number of vehicles anticipated does not match the
size of the compound on Roysvale Park. The compound use requires court
approval. To allow Roysvale Park to remain accessible as a football pitch
and running track during the works the compound cannot increase so the
result could be that these vehicles will fight for spaces in Orchard Road,
Sanquhar Road and beyond.
•  It is not enforceable to make staff park in the main car park.
•  Parking spaces in a bus lane will inevitably lead to cars being parked in the
bus lane at times when the buses want to be there, which will lead directly to
further chaos and traffic dangers in the area. The Transport Statement
indicates that cars stop in the bus lane of the current academy, so this is
already an issue, without including formal parking spaces.
•  It has been suggested that parking issues will be managed via double yellow
lines. Double yellow lines do not stop people parking in those areas at peak
traffic times round the current academy and Applegrove. This is noted in the
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Transport Statement submitted by the Moray Council with this application,
yet it is still mooted as a mitigation, in complete contradiction to the results
of its own survey. It would be a shame to find ourselves with a town where
our own planning is so bad we have to install double yellow lines everywhere
to try and manage this.
•  Parking restrictions are stated to be in place around Sanquhar Road and
Orchard Road for two years. This will prevent people parking outside their
own homes and will lead to further issues for parking in other areas. How will
parents drop their children at either school during this time?
•  If the planned 12 metre bus lane goes ahead, can the bus drivers be forced
to switch off their engines while they're waiting instead of pumping fumes on
to the pavement.
•  Using a 12-meter strip of Roysvale Park (Common Good land) for a bus
lane/parking area would reduce valuable green space used for football
pitches and running tracks. Court approval is required for this action.
•  Sanquhar Road was wrongly dismissed as residents parking in the traffic
survey. There is significant congestion both before 0900 and around 1500 as
the younger primary pupils are collected from Applegrove, either side of the
junction with Nelson Road. This often coincides with the buses arriving for
the Academy and the teachers are already there. 
Comments (PO): 
The Transportation Service Manager has considered all these issues as part of the
application but does not object to the proposal on road safety, traffic congestion
or parking grounds subject to conditions and informatives being attached to the
planning consent if permitted. The provision and availability of on-site parking for
this development is in accordance with current parking standards. 
The proposed bus layby is closer to the new school entrance than the existing bus
layby used for Forres Academy. 
Temporary obstruction during deliveries is a matter for Police Scotland. 
A raised crossing is to be provided for pupils and staff crossing Burdsyard Road,
this will be secured by condition. Safe crossing points are/will be located
throughout the local road network. 
The pupil entrance is to the rear of building and not on Orchard Road. Therefore,
school drop of by parents/carers will be directed to Burdsyard Road, as present. 
The new small car park at the front of the new school is for Enhanced Provision
pupils only. Traffic using this car park will therefore be limited. 
Staff will be asked to park in the main car park. 
Parking for the community facilities will be located in the main car park out of
school hours.  A dial a bus service operates in the Forres area. Dial a bus is a door
to door bookable bus service for those unable to use existing forms of transport or
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do not have a regular scheduled bus service. This service is available for everyone
regardless of age or disability. 
It can be requested that bus engines are turned off whilst waiting in the proposed
bus lay by. 
Overall there is sufficient capacity on the local road network in Forres, with limited
congestion on the A940 during peak travel periods. The school site is remote
enough from the A940 so as not to have any additional impact on the operation of
that road. 
Additional parking is provided as part of the proposal; as it is close to the
gym/swimming pool/hydrotherapy pool it can be utilised by the users of those
facilities. 
A condition requiring a construction traffic management plan (CTMP) to be agreed
with the Council prior to works commencing on the site is to be attached to the
consent. This will ensure an acceptable form of development in terms of the
arrangements to manage traffic during construction works at the site. 
The proposed bus layby will be dedicated for use by buses only during school drop
off and pick up times. The existing bus lay-by on Burdsyard Road will be amended
and made available for general parking. 
Parking restrictions (double yellow lines) can be introduced to deter
indiscriminate parking behaviours e.g. parking too close to junctions and improve
road safety. Park Smart to educate parents/carers on where to safely park. 
The CTMP will impose temporary restrictions on parking limited to locations where
they are necessary for road safety reasons. 
Construction 
•  Building an academy in the grounds of an existing primary school would
cause years of noise, dust, traffic and danger for neighbouring properties
including Applegrove. 
•  Pupils education will suffer if they are forced to learn in the middle of a
building site. It is not safe or healthy environment for children. 
•  The impact on pupils and teaching staff while this work is underway will be
unimaginable and the disruption to education is unquantifiable. Pupils and
staff will be subjected to unprecedented levels of noise pollution, vibration
and increased traffic flow. The retention and recruitment of teaching staff to
the school at a time of such upheaval is likely to be adversely affected.
•  The construction work taking place during school hours will make noise
distracting pupils from their education, the construction site itself will
disrupt the parents dropping their children off (traffic control measures,
construction vehicles and plant using the roads, etc) which has a knock on
negative effect with their respective employers.
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•  Construction sites are dangerous places that should not be that close to
primary aged children.
•  No consideration given to local residents or Applegrove Primary pupils and
teachers who will have to endure the noise and pollution of the build. The
construction work will run from 7am until 7pm at least five days a week,
perhaps six, every week for at least two years and then for longer, how many
years unknown, as the old Academy is knocked down, a car park made and
an all weather sports pitch installed. 
•  Previous construction work at the Academy and swimming pool that work
was allowed to go ahead outwith the time restrictions including the loading
of scaffolding onto a vehicle at 01:30.
•  It is not suitable for there to be construction noise next to funeral home.
•  Noise will disturb those working from home. 
•  Some of the pupils who attend this school already have special needs and
such an environment will be hostile to them.
•  Piling to establish the foundations may well produce shock waves which can
destabilise buildings as far away as the High Street where buildings are
historic. Could also undermine Applegrove primary due to it being so close
and the existing Forres Academy that has RAAC cement issues already
rendering it structurally weak. 
•  Has Moray Council factored in costs to compensate nearby buildings being
made structurally unsound.
•  Many surrounding properties are older properties and are at high risk of
structural damage due to the use of heavy plant machinery and also due to
high and sustained levels of vibration during the construction phase.
•  Recording and monitoring conditions and making necessary repairs was
indicated previously and this should be a condition of any approved build on
this site.
•  Look at the construction site around the new academy in Nairn to see the
space required for a construction site. That space simply isn't available at
Applegrove Playing Field and the surrounding area.
•  Construction dust will have an impact on medical conditions, both children
and local residents.
•  The project will bring years of heavy construction: piling, concrete work,
vehicle movements, vibration and dust-all within metres of the cottages.
•  Do not give permission for my child/children depending on the time the
building would start to be breathing in all the dust and fumes flying around in
their air during play times and lunch times, or are they expected to stay
inside and not have a play field.
•  During construction, neighbouring homes and Applegrove Primary School
will be exposed to dust, debris, and potential contaminants without an
adequate Construction Environmental Management Plan (CEMP), contrary
to MLDP Policy DP1.
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•  The schools proposed operating hours and extended construction hours will
cause unacceptable noise lighting and traffic disruption to neighbouring
residential streets. 
•  Balfour Beatty state that air monitors will be located at the edge of the site.
The report does not, however, go on to say what will happen if these
monitors are triggered. Installation of a monitor is not in itself a mitigation of
the underlying problem.
•  Despite mitigation, the education of all children at Applegrove will be
negatively impacted during construction due to noise, pollution, vibrations,
limitations on play space and construction dangers. 
Comments (PO): 
As with any new build or re-development on a site, construction impacts including
disturbance and disruption are somewhat inevitable but likely to be intermittent,
occur over a short-term period and are temporary in duration.  Attention to the on-
site management of construction activity, including 'best practice' and adherence
to requirements of other legislation can also address and mitigate the impact of
such effects to ensure that any residual impacts, if any, are not significant. 
Environmental Health were consulted on the proposal and have no objections to it
subject to conditions being attached to the consent (if permitted), this includes a
Construction Environment Management Plan (CEMP) to be submitted and
approved by the Council prior to the commencement of works. This is to ensure
that environmental emissions are considered and managed at the construction
phase, in order to protect local residents. This will be reviewed by Environmental
Health. 
Transportation was consulted on the proposal and have no objections to it subject
to conditions being attached to the consent (if permitted), this includes a
Construction Traffic Management Plan (CTMP) to be submitted and approved by
the Council prior to the commencement of works. This is to ensure an acceptable
form of development in terms of the arrangements to manage traffic during
construction works at the site. This will be reviewed by Transportation. 
Piling is not required to take place to construct the new school. 
The proposed construction compound is large enough for the development to
take place. 
Noise 
•  The increase in noise for the veterans who are housed nearby is terrifying for
those that may have PTSD. The quiet, safe, low-traffic nature of this location
is essential to mental health.
•  Noise will be an issue for the bereaved attending the much respected
Funeral Director opposite the construction site.
•  Neighbouring properties already suffer from noise and litter, this will be
exacerbated if the new school is to incorporate the community centre. 
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•  Long-term school activity will add an increase in daily noise from pupils,
bells, PA systems, buses, and sports fields, and public.
•  No clear noise impact assessment or PTSD-specific mitigation measures are
included in the proposal.
•  The Noise Assessment only relates to the proposed sports facilities and
does not appear to address the overall noise impact. It also appears to lack
detail, in that it does not identify specific types and qualities of noise. It does
not take account of the nature of the surrounding topography, which is a
natural valley and amphitheatre, and thus likely to amplify noise to a degree
not currently experienced from the existing schools and facilities.
•  School-related development is likely to result in increased noise levels and
other impacts, local residents cannot be certain that the impacts will, in the
context, be suitably mitigated. Indeed, it is known that some veterans have
already left their homes citing reasons such as noise and loss of privacy, and
that others are considering the same.
•  A barrier comprising of 2.4m tall boards is to be erected during the build to
mitigate noise. This will have minimal effect to erect a building that is 13m
tall.
•  The impact and noise of over 1,000 high school children coming and going in
such a small built-up area will be detrimental to the health and wellbeing of
the close neighbours. 
•  Neighbouring properties will have to put up with disruption that comes with
living next to a school such as predawn deliveries, noise and detritus. 
•  A funeral home provides a professional and dignified service to the
bereaved, requiring a calm and respectful environment at all times. The level
of noise and disruption anticipated during the construction phase-
particularly from heavy machinery, deliveries, and general site activity-poses
a significant risk of interference with funeral services. Such disturbance
would be deeply distressing to grieving families and could cause
reputational and operational harm to our business.
•  Should the development be approved, we strongly request that strict
conditions are imposed to control construction noise and activity, including
a requirement for all intrusive work to cease during funeral services taking
place at our premises.
•  The Noise Assessment appears limited and does not reflect the natural
topography which can amplify noise. The War Veteran Cottages would be
significantly affected. 
Comments (PO):
A noise impact assessment was submitted with the proposal. Environmental
Health have reviewed the proposal and noise impact assessment (as amended)
and have no objections to it subject to conditions (including a CEMP) and
informatives being attached to the consent if the proposal is permitted. 
Attention to the on-site management of construction activity, including 'best
practice' and adherence to requirements of other legislation can also address and
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mitigate the impact of such effects to ensure that any residual impacts, if any, are
not significant. 
Biodiversity
•  The Biodiversity Net Gain (BNG) does not provide a measurable
enhancement of biodiversity, and MLDP 2020 Policy E2 (Biodiversity),
obliges developers to conserve and enhance existing habitats. 
Comments (PO): 
A proactive approach in terms of Biodiversity has been undertaken, it has been
demonstrated that it aligns with NPF’s requirement for developments to leave
biodiversity in a demonstrably better state and meets MLDP Policy EP2’s
emphasis on enhancement and protection, however a condition is required to be
attached to the planning consent requiring a detailed biodiversity plan to be
submitted and approved in writing prior to the commencement of works (if
permitted). This will ensure that all proposed measures are implemented and
monitored effectively throughout the development lifecycle. The Climate Change
Strategy Officer advised that the BNG report and landscape plan contain enough
information to provide initial comment. 
Open Space 
• Short sighted and will destroy existing green space, this is not in the
Communities interest. 
•  Applegrove’s playing field will be consumed by the new school.  It is large
well used school green space, currently used every day by primary pupils for
outdoor playtime, PE, football, field sports, sports days, daily mile, informal
recreation and social development. 
•  The removal of Applegrove’s playing field will diminish opportunities for
physical activity, informal play and most importantly all the mental-
wellbeing benefits that green outdoor space provides for children. It will
have a direct impact on pupils behaviour and mental health.
•  No regard for children of Applegrove primary by building on their playground.
Outdoor learning would be reduced at Applegrove if they lose their
playground. 
•  The new school will take away a much-needed flat area for older people. 
•  Forres children are being denied extensive outside spaces and playing fields,
unlike Nairn. 
•  Depriving primary pupils of their playground is not in line with Government
policy and the legal framework concerning this is set to change. 
•  It is important to have green spaces where children can play. To think the
children from Applegrove will have the use of Grant Park to play is ridiculous.
Comparing Applegrove with Andersons school who have no playing field is
no excuse for stealing Applegrove field to build an Academy. 
•  The proposal will have a detrimental effect on the whole town which prides
itself on open green areas.
•  People live in rural areas so that their children are brought up and able to
enjoy green space especially while attending school.
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•  Applegrove is a hub for special needs pupils and losing part of their
playground will be detrimental to their wellbeing.
•  Roysvale Park lies within designated greenbelt land and is one of the few
remaining open green spaces accessible to the local community. It provides
a vital area for recreation, walking, and outdoor activities, contributing to
both physical and mental wellbeing for the wider community.
•  Roysvale park loses the cycle path and significant width for the bus area.
•  Roysvale park can no longer be used as multifunction pitch due to the
reduction in size of park due to encroachment by bus access.
•  The high school does not need two sports fields when the primary school will
not even have one.
•  All of Applegrove Primary’s outside space is eliminated. This is inconsistent
with NPF4 Policy 14 (Placemaking) and PAN 65 (Open Space), which require
adequate green and recreational provision.
•  The area already faces a shortage of recreational spaces. Removing this
playing field would overburden existing facilities, leading to overcrowding
and reduced opportunities for physical activity.
•  The joint use of Roysvale for Primary and Secondary activities will increase
the competition for resources.
•  Applegrove playing fields and Roysvale Park are ENV4 and the development
will result in a 90% loss of outdoor playing field for the primary school. 
•  Increased school use of Roysvale Park could further restrict public access,
and the timing of the application is premature given forthcoming updates to
national standards on school outdoor space. The loss would also harm
community groups, tourism, and event hosting, leading to a conclusion that
the development is contrary to MLDP and NPF policies.
•  The primary has a large percentage of ASN pupils who constantly make use
of this open area and will struggle without such a green breakout area. 
•  The new secondary will not have much outdoor space. Reducing outdoor
space for is not a positive move with the mental health and obesity problems
already impacting a greater number of pupils. 
•  If the new school uses this Applegrove’s Playing Field it would mean
Applegrove pupils would only have the small concrete playground - too
small and inadequate for outdoor learning activities - like the recent whole
school celebration of the queen’s jubilee which took place on the enclosed
green playing field. Celebrations like this would not be able to happen.
•  Roysvale is unfenced, bordered by roads, and shared by up to 1600 pupils,
creating safeguarding risks. This is not comparable to Grant Park's much
larger publicly shared space.
•  The proposed new academy will not have its own designated playing field.
There is simply no room on the site to accommodate one.
•  The proposal that the Roysvale Park area will be used as a joint playing area /
sports field for the pupils of the new academy and the pupils of Applegrove
Primary School is unrealistic.
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•  How are the needs of the academy pupils, primary school children and the
general pupil going to be managed to avoid conflict of interests?
•  The new school building provides very little outdoor space and overall, many
more school pupils (primary and secondary) will occupy a significantly
reduced outdoor area. When obesity and mental health problems already
affect children and young adults to a significant degree, the lack of outdoor
space could have a very detrimental effect on the health and wellbeing of
our young people.
•  Applegrove Primary will have no access to a grass playing field before
school, at break times, and at lunch time.
•  The 3G is not in "close proximity" for the primary school as required by the
Regulations. It is too far away to be practical for primary children and would
require numerous staff to be able to walk the children to use it. 
•  What use will the primary school ever get of the 3G pitch when competing
with an academy with 1180 pupils?
•  Forres Academy will have fewer sports areas than at present, which
contravenes Sportscotland recommendations that a replacement school
cannot have less sport's area than the old school.
•  Roysvale is not suitable for a school playing field as balls could end up in
people’s gardens, on surrounding roads among traffic, or in a bus/car park
among traffic. It is use will be increased for ball sports. 
•  The new facility is not replacing the loss of the Applegrove playing field and
does not provide a better-quality facility. 
•  The replacement facilities shown would not provide equivalent, accessible
open space for younger children or the wider public, contrary to Policy EP5.
Shared use with a much larger secondary school population is not a genuine
replacement.
•  There are no toilets on Roysvale Park for the primary pupils to use and the
park would need to be fenced off in order for young children to play safely
which cannot happen as it is common good land.
•  The Regulations state that a secondary school designed for 1180 pupils
should have a site of 6.5 acres (26,305m²). Moray Council states that these
requirements have been met to the tune of 30,290m². - In order to reach
30,290m², Moray Council has included the bus drop off lane as part of the
site. The bus lane is 2530m². The south site (less the 3G pitch) is 10,885m².
Those 10,885m² are made up entirely of the car park. Including a bus lane
and car park (particularly given the size of the car park!) within the
calculation of site size available to the school is taking a very wide
interpretation of what the 1967 Regulations would have intended to be
comprised within a school site. Whilst the inclusion of bus lane and car park
may be legal, it would be closer to the truth to state that the site size for the
new academy in this proposal is 16,875m² which is 9,430m² short of the
legal requirement.
•  The Regulations also state that a secondary school shall have playing fields
of not less than, in this case, 9 acres which amounts to 36,422m². In the
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plans, the playing fields for the new academy are made up of Roysvale Park
(14,600m²) and the 3G pitch (7000m²). This totals 21,600m² which seems to
be 14,822m² short of the legal requirement. This is a significant shortage in
the size requirement and this proposal should be rejected for failing to meet
the Regulations by a significant margin.
•  What protections are in place for potential criminal activity relating to
safeguarding children on Roysvale Park?
•  In any event Roysvale Park is now stated to provide playing fields for up to
nearly 1600 pupils, from two different schools. How will this be managed? It
is not appropriate for five year old children to be mixing with 16 year olds,
these age groups have very different use of language and behaviour that will
bring challenges.
•  Neither Applegrove Primary or the proposed academy will have dedicated
playing fields of their own. Both schools currently have their own playing
fields. Removal of dedicated playing fields is not a step forward for either
school.
•  Applegrove pupils are the victims in this project. They will no longer have a
grass playing field that they can access at break times and lunchtimes, and
before school in the morning.
•  Condensing those c.300 children into a space a fraction of the size
previously available will inevitably lead to issues, as frustration amongst the
pupils grows. Applegrove primary is stated within the planning documents to
have capacity for 460 pupils. If the school was to reach capacity, these
issues would only be exacerbated.
•  Loss of green space and reduction of Common Good Land (CGL) at Roysvale
Park which does not align with NPF4 Policy or the School Premises (General
Requirements and Standards) (Scotland) Regulations 1967.
•  The proposed development is likely to result in issues that appear to be in
direct contrast to the principles of Policy 14 of NPF, which recognise the
importance of improving physical and mental health, and allowing people to
live, play, work and stay in their area.
•  The proposed replacement sports facilities do not provide equivalent open
space in terms of function, quality, or accessibility, particularly for
Applegrove Primary pupils and the wider public.
•  It was suggested the loss of Applegrove playing fields could be mitigated by
changing the use of CGL opposite the British Legion to include a fenced area
of 'replacement playing field' for Applegrove. This would partially align with
policy 21 of NPF. This was not taken forward by Learning Estates. 
Comments (PO): 
The project has been carefully designed to ensure that Applegrove pupils continue
to enjoy high-quality outdoor environments both during construction and after
completion. All pupils will benefit from access to the new 3G pitch. 
In addition, the project includes significant improvements to the drainage of
Roysvale Park and surrounding land. These enhancements will increase the
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quality and year-round usability of green space, providing long-term benefits for
both Applegrove Primary, the new school and wider community. 
All required policies of NPF and MLDP relating to open space are adhered to as
detailed in the observation section of this report. 
Roysvale Park is flat and is to remain largely as is. 
The existing cycle path on the east of Roysvale Park is being replaced and
relocated slightly to allow for the proposed bus layby. 
During and after construction of the new school Roysvale Park will remain in use
providing the same facilities as it currently does, a football pitch and athletics
track. 
The primary school will be able to use the new academy’s indoor and outdoor
sports facilities including the sports pitches. 
A booking system for the use of the new sports facilities is to be put in place, this
will be managed by the new academy. It will ensure that the facilities can be used
by all. 
There will still be areas of open/grassed areas available for Applegrove pupils
within its grounds. 
The existing playing field on the west of the Mosset Burn is to remain as is. 
The new 3G pitch is located in close proximity, approx. 300 metres, from both the
new academy and Applegrove Primary School. 
Forres Academy will not have less sports facilities than it currently does. 
Sportscotland were consulted on the proposal and have no objection to it subject
to condition being attached to the planning consent. 
Roysvale Park is currently used for ball sports. 
The new academy has toilets that can be used by the public. 
It is anticipated that children will be supervised by school whilst using Roysvale
Park. 
The design is compliant with the School Premises (General Requirements and
Standards) (Scotland) Regulations 1967. 
The Schools Premises Scotland Regs 1967 recommends a site area based on the
school size and to have available and in close proximity playing fields sized
accordingly. This area requirement is considered on a case-by-case basis and
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now takes account of all-weather surface pitches and multi-use games area
(MUGA) provision. 
Common Good Land 
•  Roysvale Park and the Applegrove Playing Fields were gifted to the Council’s
predecessor for the benefit of the community and for recreational purposes.
Since then, the inhabitants of Forres and visitors to the town have
appreciated the park for its nature and tranquillity, and the many sporting
and arts events it has accommodated over the years. Whilst access to its full
extent was limited by the development of Applegrove Primary School, it
remains an important public space and one that is much cherished and
used by the local community.
•  Moray Council has yet to provide legal evidence to show that the Common
Good Land status of Applegrove’s Playing Field has been lost. Given the way
in which Applegrove Playing Fields are used by the public, everything would
suggest that its Common Good Land status remains. If this is the case,
Moray Council does not have the right to build at Applegrove Playing Field
without appropriate consultation and obtaining court consent.
•  Common good land is not for Council use. 
•  The issue of Common Good Land remains a legal challenge. The assumption
that, because this proposal is for education, the fundamental principles of
land ownership can be bulldozed does not sit well with the community in
general.
•  There is a change of Common Good Land use beyond that of the bus lane
and the temporary construction site. The red line around Roysvale Park in
the school plans that this is the main playing field for the combined school
capacity of circa 1600 pupils, which is way beyond current usage of the park
(occasional use such as the annual sports day). This will reduce access for
dog walkers and people exercising when the two schools will make so much
use of it.
•  The Roysvale park area is common good land and as such the public is
entitled to use it at any time.
•  The promise of the return of Roysvale Park to the public is not clear if this
green area is to be shared with up to 1600 pupils from both the Academy and
Applegrove.
•  The Common Good consultation only sought a temporary change for the
construction space, and permanent change for the bus lane. This was
justified by the Moray Council on the basis that the remainder of Roysvale
Park would be returned 'as is' after completion of the build. Incidentally, 80%
of those who commented were against any change of use of the Common
Good Land. 
•  Moray Council is yet to receive court approval for the use of Roysvale Park,
this could be denied by the court.
•  It is clear from the plans that Roysvale Park will not be returned 'as is.'
Rather, it is consumed within the Academy boundary in order to meet the
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requirements of the School Premises (General Requirements and
Standards) (Scotland) Regulations 1967 (the "Regulations"). The public was
not informed of this at the time of consultation on the Common Good Land.
•  Taking Roysvale Park within the boundary of proposed academy is a change
of use of that Common Good Land. Moray Council claims it is not, stating
that Forres Academy has always used Roysvale Park in some way. That is not
the case, as can be vouched for by many a former Forres Academy pupil and
teachers. The use by Forres Academy of Roysvale Park is a relatively recent
development. 
•  What protections will be in place to ensure the public will still have use of
Roysvale Park during school hours, as is the case now? The reality is that
Roysvale Park is not being returned to the public 'as is' at all.
•  Moray Council should be carrying out a public consultation and seeking
court consent for a change of use of the whole of Roysvale Park. Without
court approval for this change full change of use of Roysvale Park, this build
should not be able to proceed.
•  The design and access statement states that Applegrove Primary requires
1.5 acres of playing fields. This would increase to 3 acres if Applegrove
reached maximum capacity. Moray Council proposes that this requirement
will be met by the primary school using Roysvale Park. The space at Roysvale
Park is therefore to accommodate both the primary and the academy and is
'double counted' in terms of determining available space. 
•  The common good land should not be stripped from the community in order
to push through an unpopular school build. This is unfair but also against the
spirit of common good protections. 
•  Loss of common good land which is consistently being used by local
charities. 
•  How can the planning application go in when the court has not yet ruled on
the common good land. 
Comments (PO): 
Whilst referred to by various objectors, the legitimacy of use of the common good
land for the new school is not a material planning consideration. 
This is because there is a separate consultation and legal process underway in
relation to the proposed used of common good land. It is a separate matter from
the planning application process and therefore not a material planning
consideration or a determining factor. The planning process is to avoid duplication
of other consenting or legal processes such as is currently underway for the use of
the common good land. 
Trees
•  It will be impossible to protect the high value trees in the area as excavation
for installation of tanks appear to run close to the root systems and the
school building structure is also very close to the roots.
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•  The development will result in the loss of mature trees, green corridors, and
sections of Roysvale Park. 
•  Building on this green space would harm local biodiversity and ecosystems.
Trees, wildlife habitats, and natural drainage systems would be disrupted,
contributing to environmental degradation.
•  The trees around the Applegrove site not only enhance the area but provide
effective carbon capture and water uptake. Damage to mature trees or
removal of trees will make the risk of flooding more likely and remove their
beneficial carbon capture. This is important as school traffic will continue to
this site and increase over the years. 
•  Tree protection zones are identified although there will be overlaps with
installation of holding tanks and drainage pipework illustrated on Drainage
Plan Part 7 therefore it is unclear how successful these protection zones to
the retained mature trees will be. The size of the holding tanks on this plan
appear to be the tanks themselves rather than clearly identifying a suitable
excavated area to allow safe and suitable installation. Additionally,
excavations for the foundations in this tight size will also cross into the
zones.
•  36 trees (many of which are mature) are to be lost to this build.
•  Trees 62-64 that are located next to the proposed sprint track are listed as
some of the most important class A and B mature trees. Up to 26% of their
root plate will be damaged, further to the damage already endured by those
trees during construction of the relatively recent footpath. Despite thinning
of their canopies by 20%, these trees will be put under significant stress and
may be lost, yet they are the key trees in the illustrations to attempt to mask
the building from Roysvale Park.
•  Despite a tree replacement scheme, it will take decades to grow to their
current size.
•  It will take many years or decades to restore some of the trees lost or
damaged due to the scale of this development in a relatively confined space. 
Comments (PO): 
A Tree Survey, Arboricultural Impact Assessment and Tree Protection Plans have
been submitted with the proposal. These documents detail and show how the
trees to be retained will be protected during construction of the new school. 
The Tree Survey details that some trees will be affected by construction activities,
particularly along the western and Applegrove boundaries, where sycamores and
cherries will experience significant root disturbance. However, these are
considered capable of retention with appropriate mitigation, including canopy
thinning to reduce stress and careful management during and after construction. 
To offset the trees that are required to be removed to primarily accommodate the
3G sports pitch, flood basin, bus access, turning area and elements of the car
park and entrance plaza, the proposal includes a compensatory planting scheme
on a 2 for 1 basis and a total of 90 trees will be planted using native species, which
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will strengthen biodiversity, enhance ecological connectivity, and contribute to
long-term landscape quality. 
Wildlife 
•  Concern regarding the very real seagull issue which will be exacerbated by
the proposed site being in a central area with litter caused by pupils. This is
already a major problem with the existing Forres Academy which also has a
flat roof. 
•  Seagulls are a real problem in Forres, as is the case in many parts of
Morayshire. They already nest on the roof of Applegrove, which is sloped at
>4°, and which has ineffective acoustic bird deterrence installed.
•  The proposals to use acoustic 'sirens' to scare the seagulls away will not
work, as evidenced by the nests seen on steeper pitches of Applegrove
roofing, next to such bird deterrence.
•  Biodiversity corridors are being lost. 
Comments (PO): 
A bird protection plan is included with the submission. A condition is attached to
the consent requiring this to be updated to include final details of
measures/design details to deter roosting and nesting gulls upon the roofs of all
buildings prior to the commencement of development if the proposal is permitted.
This is to ensure the development does not attract seagull activity which would be
detrimental to the amenity of the users and neighbouring properties. 
The proposed Forres Urban Nature Network runs through the site, linking
outwards in multiple directions using natural features such as the Mosset Burn
and Sanquhar woods, as well as active travel routes. The site (particularly the old
school) is therefore of strategic importance for nature connectivity, allowing
species to safely move. 
The additional information required through the condition (attached to the
planning consent if permitted) will support the development in strengthening
existing nature networks. 
Flooding and Drainage
•  Existing playing fields act as a floodplain for surface water. 
•  The proposed water storage system and a tarred bus stop is only going to
aggravate the flooding issue. 
•  Development will aggravate flooding issues despite the promise from the
contractors. 
•  Flat roof is impractical for flooding and drainage.
•  Neighbouring house has not flooded in 60 years but recently it has been
difficult to get insurance as it is in a flood zone. 
•  The land lying either side of Orchard Road from the British Legion to
Castlehill Road was shaded purple, the highest flood risk zone on a recent
SEPA report that was commissioned for a nearby property. 
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•  How is acceptable to cover a large natural drainage area of the town into
concrete when insurance companies already won’t protect neighbouring
properties and the SEPA has ranked the area as the highest flood risk.
•  Replacing natural drainage areas with more concrete will cause additional
flooding and do not accept that the plans to deal with this are adequately
thought through.
•  There has been a further Flood Risk Assessment from Goodson Associates
and also a submission from Scottish Water. Believe there remains a
significant adverse risk to properties and indeed to the proposed new
academy and to Applegrove Primary School. This area already floods and
Applegrove Playing Fields provide vital soakaway to surface water which
runs down to this the lowest part of the town from the higher ground.
•  The culvert below the A96 has little flood capacity and already backs up and
if blocked with debris will further increase flooding. The concerns about the
A96 culvert and the river embankments are of course outside the scope of
the new School project to resolve but the new School development could
potentially make things worse. 
•  There does appear to be a fundamental mismatch between the flood
modelling, the capacity of the existing Burn of Mosset and the corresponding
potential risk of flooding the whole of lower Forres! The quoted "significant
amount of upfill across the whole site including the common good land" may
also have the effect of surface rainwater runoff being directed to the existing
lower areas and housing all around the site, during the construction period
and afterwards. Water has to continue downstream and there are some
embankments along the Mosset to protect the lower part of the town.
However, if these embankments are overtopped flooding from combined
sewers would back up into the town. 
•  In particular, is there detailed information available on the likely volume of
water to be discharged into the Mosset Burn through the proposed pipe
under Albert Street, Castle Street and Orchard Road?
•  The infrastructure in this area of Victorian combined drains already has
difficulty coping at times of heavy rainfall and overflows sewage into the
surrounding streets, as evidenced by the flooding to the properties across
the road from the school in Bank Lane and the garage.
•  It is likely that further stress on the system, despite the proposed new
conduit, will result in contamination of the surface water with this sewage
and be directed into the Mosset Burn. Why is it deemed acceptable to
pollute our water ways in this manner?
•  Although certain new mitigation measures and new drainage systems can be
successfully designed and constructed all this is based on the fundamental
assumption that the Burn of Mosset is capable of accepting these design
flows without itself breaking its banks and leading to flooding.
•  How much modelling has been done and how much do we know about the
capacity of the Burn of Mosset and the contributions/flows that will be
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coming in from its own catchment areas, now and in the future (and
including the projections for climate change increases of +42%)?
•  One possible worst-case scenario might be that despite all these measures,
flooding still occurs and Moray Council taxpayers might have to fund extra
work to implement improvements to the existing 'poor overall condition
classification' of the Burn of Mosset (such as dredging, widening, raising the
banks, providing concrete or steel linings to the banks etc.) to try to control
the new flows and the risk of flooding ... but this might only push the problem
further down the line of this particular watercourse (further into the town
itself?), beyond the point were any improvements can be practically made.
Any such works could also be very extensive and very expensive.
•  The concept of capturing and storing water in large tanks underground is
fundamentally flawed. 
•  The catchment area is too large and the calculations are questionable.
Would like an independent survey carried out. 
•  The land itself is at the bottom of multiple hills so rainwater collects there
and the proposed area regularly floods and becomes waterlogged.
•  The field is currently flooded (4/10/2025).
•  There must be a risk of raw sewage on our streets with all the attendant
disastrous public health consequences.
•  No consideration for future global warming of increased rainfall predictions.
•  Flooding may appear to be mitigated however the finer details are
questionable especially as to their effectiveness further downstream.
•  Scottish Water are putting floor doors on surrounding houses due to
flooding.
•  Money coming from the school build will have to be proportioned to support
the inadequate drainage system in the area taking away from funds away
from the main project.
•  Land is low lying. It is at the lowest point and covering the area will not
improve it.
•  In heavy rain sewage bubbles up through the branders along Sanquhar road
and on the ground and path to the east of Applegrove. All the construction
traffic will probably damage it further.
•  The Applegrove / Orchard Road / Sanquhar Road area suffers flooding
regularly from flash floods. Covering a large area of green field will increase
the chances of flooding for Roysvale park and potentially of the surrounding
houses.
•  If new Academy cannot be re-built on existing floodplain then why would it
built on the same flood plain 600 yards away. 
•  The site acts as a flood plain, building on it could cause local flooding
especially during construction. 
•  In heavy rains the Mosset Burn is already almost bursting its banks.
•  Scottish Environment Protection Agency (SEPA) has submitted a "holding
objection" due to lack of information on flood-risk.
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•  Concern whole water table will be disturbed, must be a concern for
residents of Orchard Road. 
•  The Applegrove playing field has a high water table and installation of
attenuation tanks in the past to mitigate the flooding issues on the playing
field has failed to fully resolve the flooding issues, probably because the
attenuation tanks do not store a significant volume of water and that they are
very shallow in depth. Building on a site with sandy / peaty soil which is
prone to flooding will not be without risks which in turn could result in using
up valuable funds that were originally ear marked for the school building
project.
•  Neighbouring house already have issues with toilets backing up and houses
being flooded. 
•  Two major schools and a third under construction are feeding into already
overloaded drainage systems and natural water courses. There is significant
impact on surrounding drainage and downstream flooding especially during
the construction phase. 
•  Existing Mosset Flood Alleviation is designed to a 1:100 year event including
climate change. The proposed flood parameters for application are 1:200
year plus climate change (42%) allowance. All flood defences including
culvert below A96 do not meet the proposed flood parameters and SEPA
guidance. The proposed development is at significant risk of creating
substantial flooding between Orchard Road bridge and A96 Mosset Burn
culvert. This is significantly increased during construction phase of
development with a storm of return period greater than 1:100 years. Further
extensive flooding would be generated through surcharging of known and
unknown drainage systems feeding into Mosset Burn.
•  Transport Scotland have not been consulted of potential risk to A96 through
impounding of water against elevated section of A96 where the Mosset Burn
flows a culvert with less than 1:100 year capacity.
•  Surface and below ground water flows from Cluny hill and area known as
Brae back catchments have not been considered within modelling. These
areas have significant run off and flow directly to proposed development
site.
•  There have been documented instances of the combined drains flooding,
leading to sewage escaping where schoolchildren are walking.
•  Flooding will be highly disruptive to education and damaging to
infrastructure, in particular to the proposed new school and undermine the
investment in education.
•  It is welcomed that the Application is supported by a Flood Risk Assessment
and Drainage Strategy Report but notes that SEPA has submitted a holding
objection due to a lack of information in relation to flood risk. Our client
reserves its right to respond further on these matters once SEPA has
submitted its full assessment of the proposals.
•  If the mitigation and drainage proposals prove to be ineffective, extra work
may be needed. 
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•  The proposal to install new drainage along Orchard Road would require the
area to be dewatered.
•  New development should not be located in areas at flood risk or increase
vulnerability to flooding (as per Policy EP12). Exceptions to this would only
be considered in specific circumstances, e.g. extension to an existing
building or change of use to an equal or less vulnerable use.
•  Unless Scottish Water are minded to replace the whole length of pipework
this combined pipe will run at risk of backing up in front of Applegrove
Primary School and the new proposed school.
•  A new 'clean water' sewer is to be installed. That sewer is shown to take a
circuitous route to join the Mosset Burn. Any gradient of fall to take the water
to the Mosset Burn will be reduced by the distance the sewer needs to travel.
•  The drainage reports deals with the drainage until the point it reaches the
Mosset Burn. At the point ground water is at a height the water from the
tanks needs to drain into the new sewer and the Mosset Burn, the Mosset
Burn will also be up. Will this not cause the water to back up in the new
sewer rather than drain into the Mosset?
•  Flooding mitigation costs are likely to be more than thought and therefore
exceed the putative potential saving of £4 million. 
Comments (PO): 
As detailed in the observation section of the report all potential sources of flood
risk, including rivers, surface water, sewers, groundwater, and artificial sources,
have been assessed. The building has been positioned in the most suitable
location on the site, outside any significant flood risk areas. 
The SEPA flood map and Mott MacDonald flood modelling identifies that the
existing academy site is at risk of fluvial flooding from the Mosset Burn. Therefore,
flood mitigation measures are to be implemented in accordance with
recommendations of the flood modelling report. 
In its current undeveloped state, the site is susceptible to low (1-in-1000-year)
and medium (1-in-200-year) likelihood pluvial flooding. SEPA flood mapping
indicates these areas correspond to low points along the Orchard Road boundary,
through the central playing fields, and around the hardstanding and footprint of
the existing Forres Academy. Through site development and upgrades to the local
surface water drainage system, any existing surface water flooding issues are
expected to improve. In accordance with Moray Council flood risk requirements
the development will be designed to ensure that it is not at risk of flooding from a 1
in 200-year plus 42% climate change event. 
Although the new school is a like-for-like replacement, foul flows from the
development are expected to be significantly reduced due to the installation of
modern low-flow fittings and appliances. Importantly, the only flows entering the
combined sewer from the new facility and Applegrove Primary will be foul water,
which will substantially reduce overall discharge and relieve pressure on the
combined sewer network, historically associated with flooding issues.
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Surface water runoff from new external hardstanding areas will incorporate SuDS
measures for treatment and attenuation, designed to meet agreed discharge
limits. Attenuation features have been tested for 1-in-200-year rainfall events with
an additional 42% uplift for climate change resilience. The northern site (main
school) and Applegrove Primary will discharge via a new surface water sewer
network to the Mosset Burn, significantly improving local drainage and providing
future connection opportunities to this new public asset. 
All foul and surface water flows from the northern site will be removed from the
combined sewer network, creating substantial additional capacity. Surface water
will be treated and attenuated at source prior to discharge into the Mosset Burn at
agreed flow rates. Source-control SuDS features will remove coarse solids and
silts in accordance with CIRIA C753, with treatment provided through a
combination of filter trenches, permeable paving in parking areas, and
attenuation tanks before discharge. The proposed treatment strategy has been
verified using SEPA’s Simple Index Tool. 
Moray Flood Risk Management (MFRM), SEPA and Scottish Water were consulted
on the proposal and have no objections to it. MFRM and SEPA require a condition
to be attached to the consent (if permitted) regarding the proposed flood storage
area and flood bund (Mitigation Option 4) outlined within the Flood Risk
Assessment modelling report (Mott MacDonald, 2025) being constructed and
operational prior to commencement of demolition works at the existing Forres
Academy Site. The storage area and flood bund must be maintained in perpetuity.
This is to ensure there is no increase in flood risk as a result of the development. A
further condition is to be attached to the consent (if permitted) requiring
adherence with the submitted drainage arrangements. 
It is speculative to assume that the development will aggravate flooding issues
given the level of detail the accompanying documents with submission provide
regarding flood mitigation. 
Moray Flood Risk Management confirmed that the culvert at the A96 will not need
upgraded or work done on it as a result of the flood and drainage mitigation
proposed for the development. Transport Scotland are not required to be
consulted on the proposal. 
View
•  Outlook from neighbouring properties will be affected by this proposal as the
open views across trees and stone and slate properties to surrounding
countryside will be replaced by the sports hall roofline and higher main
school building; neither of which are in-keeping with the surroundings. 
•  The bins and plant buildings are to be constructed to the rear of the Veteran
Cottages gardens. These veterans who have served our country are to lose
their view across Roysvale Park to be replaced by service buildings and live
with the noise of those bins being used and emptied on a daily basis. 
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Comment (PO): 
A view is not a material planning consideration. 
Consultation 
•  At a public meeting, those attending were told they were not allowed to
speak from the audience but had to submit written questions which were
then filtered by the panel. 
•  A petition against the proposed site, signed by over 600 people has been
submitted to the council. See Face Book site " Forres New Academy Forum"
for extensive objection to the site are raised. Officer Note – no petition has
been submitted in relation to this planning application.
•  Shame in the council for so arrogantly forcing this site with such little regard
or consultation to the people it affects the most.
•  The citizens of Forres have not been listened to by the Moray Council by
councillors who were elected to represent them. Listen to the people and
their grievances which are all too well known.
•  Residents of the War Veterans' Cottages and other immediately affected
properties were not adequately consulted.
•  Noise, flood risk, traffic, and health studies are either missing, incomplete or
unpublished.
•  Many of the appendix document referred to in the technical supporting
documents are unavailable in the planning documents therefore correct
scrutiny and informed comment is not possible either for or against these
specific areas. Is this acceptable procedure. Until these are appended the
window for comment should be extended. 
•  It would seem that many of the younger population who are greatly going to
be affected by this proposal may not have been properly consulted. Many
will not be able to access online surveys. 
•  Under article 12 of the United Nations Convention on the Rights of the Child
and under the Planning (Scotland) Act, recently taken into Scots law, any
planning application must honour this in detail and provide evidence that the
process has been fulfilled. If not, Scottish Government would be entitled to
withdraw funding. 
•  Council has disregarded its own surveys that show the preference of those
who answered these surveys in good faith was the Lochyhill site. 
•  The Moray Council Learning Estates Department have not taken on board
any of the ideas or technical suggestions that have been presented to them
by experienced and informed members of the public during the consultation
process.
•  The location survey released to the public seemed to show a persuasive
argument in favour of one site over the other. The document introduced an
intentional argument to favour one site. Do not know where this figure came
from or if it was accurate. 
•  It appears that some of the documents referred to in the Application form,
such as the Planning Statement, have not been made available online and in
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hard copy, thereby potentially impacting on the ability of the public to fully
understand, consider and comment on the proposals.
•  It has been a challenge to read and understand all the documents and
absolutely necessary for the expiry date to be extended for comments and
the Council to provide paper copies at Forres Library for those who are
unable and/or struggle with online submissions.
•  One of the groups most affected are the Veterans who live in the
neighbouring cottages. It would have been best practice for the engagement
to have been carried out at a much earlier date and offer and discuss
mitigation measures. This could have helped to ease stress levels to a
certain degree.
•  The Mitigation document claims that additional information has been
provided, this has largely been used to justify continuing with the original
plans instead of making meaningful adjustments or implementing true
mitigations. The process seems focused on defending predetermined
outcomes rather than considering alternative approaches based on
community input. This approach undermines the principles of participatory
planning and democratic engagement, reducing consultation to a
procedural exercise rather than a genuine dialogue. 
Comments (PO): 
All proposals falling within the categories of development defined as 'National
development' and 'Major development' require pre-application consultation (PAC)
to be carried out between developers and communities. The proposal is a major
development, and PAC has been carried out complying with statutory
requirements. 
Notification procedures were carried out in accordance with the requirements set
out by the Scottish Government in the Development Management Regulations.
Two neighbour notification periods have been run. The required documents have
been available to the public to access. 
The pre-application consultation document details how views of the participants
of the consultation events have been incorporated into the development.   
Inadequate Plans
•  Visualisations and massing diagrams understate the building's dominance
and site constraints. 
•  Missing information includes accurate cross-sections, verified viewpoints,
and a complete drainage/FRA report, making assessment incomplete and
inconsistent with LDP Policy DP1 requirements.
•  There is very poor information relating to shape, size of structure above
ground. 
Comments (PO): 
Adequate plans and detailed information relating to drainage and the FRA were
submitted and available to view by the public. 
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Elevations and various artists impressions of the new school were included as
part of the submission. 
Other 
•  The most cost-effective site should not be the only consideration and
majority of Forres do not think this is a good site. 
•  Impact of local businesses. 
•  Forres will become like a concrete jungle which impacts everyone’s
wellbeing. 
•  Relocate to a bigger site with the option to expand in the future if necessary.
Building out with the town would be more beneficial for children and
residents of Forres. Find a location that will give secondary pupils an area of
space and outdoor learning opportunities. 
•  The secondary school aged children should also not be that close to the
primary school children. They have vulgar language and litter often as seen
from the burn behind the current school.
•  Concern over proposed proximity of primary and secondary schools and
resulting social impact. P1 & S6 age groups essentially occupying the same
site.
•  Negative aspects of the proposal far outweigh the positives. 
•  Potential devaluation of property value due to overdevelopment and
construction traffic/noise. 
•  Disagree with veterans losing their homes. 
•  Disregard for certain key elements in particular in relation to the United
Nations Convention of the Rights of the Child.
•  The electorate's faith in local democracy this whole procedure has seriously
undermined what remaining goodwill and confidence we had in our elected
representatives.
•  Project will go over budget. 
•  The current Forres Academy car park site would represent a much more
appropriate and practical location for the new school. This alternative site
would minimise disruption to surrounding businesses and maintain the
quiet and respectful environment essential to neighbouring businesses. 
•  The addition of a walkway across Roysvale Park from the staff car park to the
new site is not required. It will effectively remove a further chunk of usable
field running between this proposed path and the parallel Roysvale Place
hedge.
•  When we are suffering an obesity pandemic the council should be
encouraging the use of green playing areas rather than trying to save a few
pounds.
•  The argument that the other site is too remote is not sensible when it would
still be well within the allowed walking distance for the vast majority of
pupils and definitely good for cycling where there is already excellent
infrastructure in place (enterprise park).
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•  There are already statistics showing that where the council have
amalgamated libraries with schools there is a huge drop off in usage
especially in older members of the community. So, yet another loss of an
amenity.
•  The best school for pupils but the benefits that could have been seen by
siting elsewhere is what is wanted: - clean slate for development without
loss of green space - room for expansion, including a new primary school or
6-18 campus - less issues for parking/traffic - less issues for drainage - less
need to disrupt another school and local residents. 
•  Wish to keep our library and community centre on existing site with footfall
on our high street.
•  Any savings accrued by choosing this site will be inadequate to cover the
extra costs which will inevitably be required to mitigate the flooding which
will be created in the surrounding area.
•  The application is being pushed through purely on financial priorities, not the
will of the Forres community nor consideration of the impact on learners at
both Applegrove and the potential new academy.
•  Lack of respect and safeguarding and protection for the primary school
children and their learning not being thought of is absolutely disgusting. 
•  Is there any conflict of interest in Moray Councillors determining a planning
application on a site which they have already selected as their preferred
option. 
•  Legal advice has been sought which indicates that the Application is
contrary to Moray Council's own Local Development Plan 2020 (LDP)and
therefore should be refused.
•  The community will be so much poorer losing the existing Community
Centre. 
•  Aware of the difficulties facing teaching staff with the rise in violence, mental
health issues, obesity, and school refusers. It is well recognised that pupil
behaviour and mental health improve with access to outdoor spaces. This is
clearly stated in the Scottish Schools' Curriculum for Excellence.
•  The public stop using libraries when they move to schools. 
•  Moray Council has golden opportunity to build a new school, but they are
repeating their mistakes of the last school they built in the 1960s, location
prone to flooding and not able to expand. 
•  The MLDP identifies that Lochyhill is the preferred site for future
development of a school. It is considered that the Lochyhill site is not bound
by many of the issues identified. The reasons given by the Applicant for not
selecting this site are somewhat opaque and lacking in detail. These include,
for example, complex land ownership and higher overall costs. In any event,
it is considered that such issues should not trump the interests of local
residents and the sustainability of the development for schoolchildren and
young adults in future.  
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•  If the Council decides the proposals accord with the Development Plan,
there are clear material considerations which indicate that the Application
should be refused.
•  The response from the council that schools have been built in school playing
fields successfully before is naive and disingenuous, as Moray Council are
building on a different primary school's playing field.
•  Dogs will have to be banned on Roysvale Park for health and safety reasons
as they are in Grant Park for Anderson's school playing field.
•  Foresee the provision of a school library and sports centre as a 'green light'
to close Forres House community centre at a later date. 
•  Have serious doubts about the practicalities of sharing such facilities with a
school, whilst preserving access to the public during school hours, and
safeguarding of pupils. 
•  The last school role forecast shows it peaking in 2028 at 941 before
decreasing to 925 by 2031, within the planning criteria, however according to
the Moray Development Plan 2020 future substantial residential housing is
still planned for Lochyhill, Mannachie, Dallas Dhu and Pilmuir Road West
which must put the school role under future pressure. 
Comments (PO):
With respect, many of the comments above in this section of objections are based
on inaccurate assumptions or speculate about what may arise as a result of the
development. Some are commented upon below. 
Veterans will not lose their homes as a result of the development. 
There are a number of 5-18 campus schools already operational in Scotland and
further schools are planned. In the case of the Applegrove/ Roysvale site, it
provides an opportunity to create a 5-18 community campus school by
incorporating the existing Applegrove into the design consideration. The benefit of
5-18 campuses is well evidenced in Scotland and elsewhere. 
Thers is no current plan to relocate the Community Centre or library to the new
school.
The figures given for the projected school roll are now out of date. Up to date
figures are given in the observation section of this report. The Council is aware of
designated housing sites within the local development plan. 
The site selection process involving Elected Members and the subsequent
planning application being considered before committee are two separate
processes, and no conflict for Elected Members arises who were involved in both. 
Support 
•  The new school will be an amazing asset for the town and young people who
attend. 
•  Sooner it gets built the better for all the children within Forres. 
•  Will be nice to have a safe, purpose built building. 
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•  Ideal location in the centre of town and close to the existing school. 
•  No site is prefect. Forres needs a new school. 
•  The chosen site is the only practical solution. 
•  Money spent acquiring and developing an alternative site will almost
certainly be money taken from the capital build monies available. As much
money as possible needs to go into the school build to provide first class
modern facilities and a build that will not need replacing in 50 year’s time.
•  Long overdue. 
•  Central location means accessible for the majority. 
•  Hate for there to be unnecessary delays. 
•  In the event of a robust legal challenge from neighbouring residents I hope
that there is a suitable "Plan B" waiting in the wings.
•  School location while not ideal is the best option for the majority of pupils.
This will allow for sustainable transport to the school and reducing traffic,
particularly at the Orchard Road /Grantown junction.
•  Schools sit at the heart of communities and Forres Academy has enjoyed a
central location for centuries. This is clearly the most suitable available site,
providing many safe routes for active travel to and from school.
•  The design of the building is sympathetic to the adjacent surroundings. The
building is not a glass box, which I welcome. The design clearly seeks to limit
the impact on the overall visual amenity in the area.
•  A number of comments about adjacent properties being overlooked, an
examination of the plans, especially the north and west elevations, show
that this has been considered within the design of the building and this
concern has been mitigated.
•  The situation of the pupil entrance minimises disruption to neighbouring
properties.
•  Long overdue. 
•  The proposed site would be best for all of the community.
•  Central location near to the existing site. 
•  As a parent fully agree with the new sit of the school. 
•  Just get it built, it's the best location, don't let the unhappy neighbours stop
you, it doesn't matter where you build it someone will still complain.
•  Should go ahead asap.
•  As a young person having gone through the 6 years at Forres Academy, it's
not fair to push back the building any longer. 
•  It is not fair to ask pupils to walk any further, and if not walk, relying on
parents to drive (which has its own economical drawbacks like pollution and
even more traffic than where already is on a school morning) or busses
which will cost the council even more money due to the high intake of pupils
who would need it.
•  Applegrove does not need that much field, and surely it's better for all of
those children to want to come to a better school, nearby to them, when
they eventually leave primary school, which they all will at some point. 
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•  Keeping it central to the town is key, and on that field is ideal, logical and
practical.
•  As a member of Forres Area Forum I would like to add my support to the
Forres and Moray Councillors who have advocated for building the new
Forres Academy on the proposed site on the Applegrove Primary School
Playing Fields. I feel that the position of the new Academy in the centre of
Forres will continue to support the local economy and provide additional
footfall to the High Street which would be lost if the new school was built
further out of town.
•  From the plans it is clear that flooding in the area will be addressed by
building additional drainage for surface water from the new as well as the
existing Applegrove Primary School which will help to alleviate some of the
issues when there is heavy rainfall and storms.
•  The playing field at Applegrove is not use for the majority of the time because
it is water logged or not enough staff to supervise. The concrete playground
could be changed to have some grass. 
•  Support the building of a new Forres Academy on the site of the Applegrove
Primary School Playing Field as it will improve the educational provision and
the infrastructure in the Forres Area. 
Comments (PO): 
These comments are noted. 
8.   OBSERVATIONS 
8.1  Section 25 of the 1997 Act as amended requires applications to be determined in
accordance with the Development Plan i.e., the adopted National Planning
Framework 4 (NPF4) and adopted Moray Local Development Plan 2020 (MLDP)
unless material considerations indicate otherwise. The main issues are
considered below: - 
8.2  Environmental Impact Assessment
As noted above under history, development of this site has been screened against
the relevant 2017 EIA Regulations, and Moray Council adopted a screening
opinion (25/00548/SCN) on 27 May 2025 stating that an Environment Impact
Assessment was not required for this development. 
8.3  Appropriate Assessment - Habitats Regulation Appraisal 
In this instance, Moray Council will adopt the appraisal as modelled by
NatureScot and this appropriate assessment is detailed below. The Mosset Burn,
which flows past the southern part of the site, flows into the Moray and Nairn
Coast RAMSAR Site and Culbin Sands, Culbin Forest and Findhorn Bay SSSI. A
Habitats Regulation Assessment (HRA) is required to be carried out for the
RAMSAR site. The site's status means that the requirements of the Conservation
(Natural Habitats, &c.) Regulations 1994 as amended (the "Habitats Regulations")
apply. Consequently, Moray Council is required to consider the effect of the
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proposal on the designations and their qualifying interests before it can be
consented. 
8.4  These measures are required because the Mosset Burn flows through the site. The
Mosset Burn feeds into the Moray and Nairn Coast RAMSAR site. Therefore, the
proposal has the potential to result in the release of sediment and other
pollutants into the Mosset Burn and affect qualifying interests of the Moray and
Nairn Coast RAMSAR site. 
8.5  The proposal is not directly connected with or necessary for the conservation
management of the Moray and Nairn Coast RAMSAR site, hence further
consideration is required. The proposal has the potential to result in the release of
sediment and other pollutants during construction activities and subsequent
discharge of surface/foul water which may adversely affect the water
environment. 
8.6  Suitable mitigation measures have been proposed to ensure the development
does not adversely affect the interests of the Moray and Nairn Coast RAMSAR site: 
•  A Construction Sustainability Management Plan which detailed measures to
be put in place to ensure no release of sediment and other pollutants into
the Mosset Burn. 
•  Suitable drainage arrangements for surface and foul water from the
development, including good practices during construction as
recommended by SEPA standing advice, previously forwarded to the
developer. 
8.7  These matters have been sufficiently addressed as part of this submission,
offering suitable mitigation/pollution control measures with relevant consultees
raising no objections to the proposal. In light of the foregoing assessment, the
proposal will not adversely affect the integrity of the RAMSAR designation;
including the conservation objectives of its qualifying interests. 
8.8  Pre- Application consultation (PAC)
The application is accompanied by a Pre-Application Consultation (PAC) Report,
as required under section 35C of the 1997 Act. This outlines the statutory
consultation that the applicant undertook with the local community in relation to
this proposal. The form and scope of the pre-application consultation was
considered suitable and agreed by the Council in response to Proposal of
Application Notice 25/00672/PAN.   
8.9  The PAC Report outlines the feedback received as part of the PAC process. The
report details the format for consultation, this includes, two public events, an
unstaffed public exhibition (at Forres Library) and online public exhibition (on
Moray Council website), advertisements promoting the public events in local
press, social media posts promoting the PAN and electronic communications
sent to Forres Academy and feeder primary school families. 
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8.10  A total of 183 people attended the two public events and a total of 121 comments
were received. The PAC report details the feedback received as part of the PAC
process. In summary, feedback received related to concerns about the design of
the proposal, minimising disruption during construction, flood mitigation and
surface water drainage, roads and transport, environmentally sustainability and
ecology, the projects impact on property values, loss of Common Good Land,
preference for the project to be located elsewhere in the town, the correct
statutory process not being complied with, opening hours for the existing
swimming pool, the school and wider community co-existing in the same building,
internal layout and programme of accommodation and a request for a statue
recognising local WW2 efforts. 
8.11  The PAC Report reflects efforts to balance community input with project goals,
with comments received incorporated into the scheme where feasible and
relevant. As such the PAC undertaken is considered suitable. 
8.12  Background
Need for a new Forres Academy
Moray Council agreed the Developing a Strategic Approach to the Learning Estate
paper in March 2020, it details what is necessary to develop a long-term strategy
for the Moray Learning Estate. Key priorities of this included addressing
occupancy, suitability, and condition issues in schools, particularly in areas with
growing school rolls like Buckie, Elgin, and Forres, or those with significant
maintenance problems. 
8.13  In October 2021 in line with the Scottish Government’s Condition Core Facts
Survey criteria, Forres Academy was rated as Condition D – life-expired and/or at
significant risk of imminent failure. The building shows a pattern of increasing
reactive maintenance costs and a growing need for substantial investment to
address essential fabric improvements. Despite considerable expenditure in
recent years, these efforts have only sustained the low condition rating and have
not prevented further deterioration. 
8.14  Following updated UK Government guidance on reinforced autoclaved aerated
concrete (RAAC) issued in late 2022, Moray Council undertook desktop reviews of
its entire building estate, including 54 schools. This was followed by physical
inspections during summer 2023, which confirmed the presence of RAAC within
the flat roof structure at Forres Academy. 
8.15  Subsequently, Moray Council announced that Forres Academy had been
identified as its top priority school for Scottish Government Learning Estate
Improvement Programme (LEIP) Phase 3 funding. 
8.16  In September 2023, Moray Council’s Education, Children’s and Leisure Services
Committee agreed to accelerate progress on Forres Academy by fast-tracking
Outline Business Case approval. The Scottish Government confirmed in October
2023 that the funding bid for a replacement Forres Academy had been successful.
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8.17  Site Location (NPF 15 / MLDP DP1) 
The 8.9 (ha) site is located approx. 250m south of Forres town centre on a site
covering Applegrove Playing Field, Roysvale Park and the existing Forres Academy
site. Land to the south west of existing Forres Academy, across the Mosset Burn,
is also included within the site. This is used by the existing Forres Academy for
sports and will continue to do so. 
8.18  The proposed development of the new Forres Academy demonstrates compliance
with Policy DP1 of the MLDP, which sets out the core development principles for
all development. The development of the new school building replaces an old
facility and delivers a modern, purpose-built school. Its co-location with
Applegrove Primary School creates a central hub, enhancing educational and
community facilities. The development integrates well with its surroundings,
incorporating landscaped areas and outdoor sports facilities. 
8.19  Accessibility and connectivity are key strengths of the proposal. The site layout
includes safe pedestrian and cycle routes, a dedicated bus drop-off area, and car
parking, ensuring inclusive access for all users. 
8.20  In addition, the proposal complies with Policy 15 of NPF, which promotes local
living and the development of 20-minute neighbourhoods. By providing a new
educational facility centrally within Forres, the new academy strengthens local
infrastructure and reduces the need for travel to access education. The
development supports active travel through the provision of safe and accessible
walking and cycling routes, encouraging healthier lifestyles and reducing reliance
on private vehicles. The co-location with Applegrove Primary School and proposed
community use of facilities further enhance the school’s role as a local hub. The
efficient use of land and integration with existing services support compact urban
form and contribute to the creation of a vibrant, accessible, and sustainable
facility. 
8.21  The proposal is considered to meet the development principles set out in DP1 and
its location and design support local living as required by Policy 15. 
8.22  Design (NPF 14 / MLDP PP1 & DP1)
Policy PP1 of the MLDP sets out the overarching placemaking principles that all
development in Moray must adhere to. It emphasises the creation of successful,
healthy, and sustainable places that reflect local character and meet the needs of
communities. Policy DP1 of the MLDP sets out detailed criteria to ensure that
proposals meet siting and design requirements, this includes developments
scale, density and character being appropriate to the surrounding area and
proposals not adversely impacting on neighbouring properties in terms of privacy,
daylight or overbearing loss of amenity. Policy 14 of NPF requires all development
to be designed to a high standard, contributing to the creation of successful,
sustainable, and inclusive places. 
8.23  The new school building is 3 storeys in height with plant equipment and bird
protection measures on the roof. The ground floor comprises a sports hall,
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gymnasium, dance studio, fitness suite, drama studio, community parent room,
learning resource centre, library, kitchen, dining area, pupil support facilities,
classrooms for food technology, technical studies, stores, cupboards changing
rooms, a first aid room, offices, WCs and a changing places facility. Access to the
building for the community is on the north elevation facing Orchard Road and
access for pupils is on the south elevation accessed primarily via Sanquhar Road.
The second floor includes classrooms for music, art, science, IT and business
education and as well as guidance, staff rooms and toilets. The third floor
contains classrooms for maths, social subjects and language and literature. 
8.24  The Design & Access Statement (DAS) explains the design of the new school
building is future proofed to allow for flexibility of use by the community over the
lifespan of the building. The spaces to be used by the community are all located
on the ground floor and carefully positioned. 
8.25  Around the new school building there is landscaping, an ecology garden, a dining
area, enhanced garden provision, food technology area and a craft and design
technical covered area as well as parking provision and cycle storage. 
8.26  The new building has been well designed to fit in with its surroundings in terms of
massing and external materials. 
8.27  The proposed building will predominantly rise to three storeys, aligning in height
with several existing trees along the boundary with Forres Tennis Club. Its eastern
and southern wings are designed to step down to two and one storeys. At roof
level, clerestory glazing has been incorporated to bring natural light into the
building’s central areas. This feature, together with the plant enclosure, is
positioned away from the building’s perimeter to help minimize the visual impact
of its overall height. 
8.28  The choice and colour of materials are designed to complement and give visual
coherence to the context of the building in its surroundings. External materials
include facing brick in buff and polyester powder coated aluminium cladding and
aluminium framed glazing systems. The (DAS) details the importance of selecting
a material palette which compliments and responds to the wider town and
immediate context of the new school, whilst also signifying a modern landmark to
the townscape. The materials chosen reflect the building's status within the
locality. Although the material finishes as described are acceptable, full
specification of materials including their colouration will be addressed by
planning condition.   
8.29  The western elevation of the proposed building will not exceed the height of many
existing trees along the boundary between the playing fields and Forres Tennis
Club. To minimise overlooking to neighbouring properties to the north of the site
(Veteran Cottages), the new school has been positioned 42m away. In addition, a
hedge is proposed between the site and the cottages which will provide a buffer
once established (with sizes and details to be conditioned). Typically, a boundary
hedge would take it the region of a 5-10 years to fully establish, dependent upon
the species. The DAS sets out that a Vertical Sky Component (25° method)
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assessment was undertaken, which shows and concludes that there is a tolerable
impact on daylight to the Veteran Cottages. It should be noted that this does not
exclude some shadows being cast to the north west, particularly when the sun in
lower to the horizon in the winter, but while it is reasonable to expect access to
acceptable levels of daylight, there should be no expectation of direct sunlight
within the built environment. 
8.30  The 3G sports pitch and main car park are to be located on the site of the existing
Forres Academy. The majority of the new tree planting is to be located to the south
end of the 3G sports pitch. A bund and flood basin are proposed to the far south of
the site. The existing outdoor gym in the south section of the site is to remain and
so is the sports pitches to the west of the 3G sports pitch. 
8.31  Although elevations of all fencing has not been provided at this stage details of
heights have been provided and a condition is recommended requiring elevations
of the fencing to be agreed to ensure that this harmonises with the surroundings. 
8.32  The proposal promotes health and wellbeing by providing access to green spaces,
high-quality sports facilities, and a layout that supports both physical and mental
health. The environment is pleasant and welcoming, with thoughtful landscaping
and architectural design that enhance the visual quality of the site and its
surroundings. Connectivity is a key strength of the proposal due to its central
location. Furthermore, the site is well-integrated with the surrounding community,
offering safe and convenient routes for walking, cycling, and public transport. This
supports sustainable travel choices and strengthens the school’s role as a local
hub. The design is distinctive, reflecting the character of Forres while introducing
a contemporary community building that enhances the town’s identity. It is also
sustainable, with the building expected to meet modern energy efficiency
standards and contribute to Scotland’s net zero ambitions. Adaptability is built
into the design through a shared campus model, which allows for future changes
in educational delivery and community use. This ensures that the building
remains relevant and functional over time. 
8.33  The new school will be readily visible from the surrounding area particularly when
viewed from Orchard Road and Roysvale Park. Despite this prominence, the
intervening distances, building heights, and finished ground levels ensure that the
proposed design is not out of scale with its surroundings. The new school will be
set against existing buildings including Applegrove Primary School, this will assist
to mitigate its visual impact and provide a sense of integration within the local
context. 
8.34  The proposal clearly demonstrates a place-based approach, responding to the
specific needs and context of Forres. It aligns with NPF Policy 14 and MLDP PP1
and DP1. 
8.35  Open Space, Play and Recreation (NPF 21 / MLDP EP5)
Policy EP5 of the MLDP emphasises the importance of protecting and enhancing
open space provision in all new developments. The current greenspace within this
site is covered by an ENV4 designation in the MLDP. This reflects its current use as
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a sports area and a playground. Any proposal within an ENV must comply with
Policy EP5 Open Space which seeks to protect open spaces from inappropriate
development. 
8.36  Policy EP5 states that “proposals that would result in a change of use of an ENV4
Sports Area to any other use (including other ENV categories) will be refused. The
only exceptions are where the proposal is for essential community infrastructure
required to deliver the key objectives of the Council and its Community Planning
Partners, excluding housing, or for a site-specific opportunity identified within the
settlement statement.” 
8.37  Furthermore, in line with Policy EP5 the proposal also requires to meet the
following: -
•  Be sited and designed to minimise adverse impacts on the principal function
of the space and the key qualities and features identified in the Moray Open
Space Strategy Supplementary Guidance.
•  Demonstrate that there is a clear excess of the type of ENV and the loss of
the open space will not negatively impact upon the quality, accessibility and
quantity of open space provision and does not fragment green networks
(with reference to the Moray Open Space Strategy Supplementary Guidance,
green network mapping and for ENV4 Sports Area in consultation with
Sportscotland) or replacement open space provision of equivalent function,
quality and accessibility is made.” 
8.38  The part of the site where the new school is proposed is covered by an ENV4
designation (as defined in the MLDP) “Applegrove Primary School”. This reflects
its current use as a playground and kick about area. The part of the site to the
south of this also has an ENV4 designation on it, “Roysvale” given it is a sports
area. “Roysvale Park”, currently has a grass football pitch and athletics pitch
marked out on it. The bus drop off lane with pavement and cycle path and a
contractor’s compound (only required temporarily for phase 1 of the
development) is to be located within Roysvale Park. 
8.39  The south parts of the site are also covered by ENV4 Designations (Playing Field
(Burn of Mosset) and Lochview). Both will remain as functioning open space.  The
Playfield (Burn of Mosset) will remain as a sports pitch and Lochview with an
outdoor gym. 
8.40  The project to deliver a new high school is essential community infrastructure
required to deliver a key objective of the Council. The proposal is therefore one of
the acceptable exceptions to the policy subject to meeting the additional
requirements in relation to minimising adverse impacts through siting and
consideration of impacts on open space provision.   
8.41  The proposal has been carefully sited and designed to minimise adverse impacts
on the principal function of the existing open space and to respect the key
qualities and features identified in the Moray Open Space Strategy Supplementary
Guidance. The layout ensures that essential recreational and green network
functions are retained, while enhancements such as improved landscaping and
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upgraded sports facilities strengthen the overall value of the site. 
8.42  Policy EP5(b) sets standards that new open space is required to meet. The
proposed new Forres Academy responds positively to this policy by delivering a
well-considered and inclusive approach to open space. The development
incorporates a variety of outdoor environments, including formal sports pitches,
landscaped recreational areas, and informal gathering spaces. These areas are
designed not only to support the physical and mental wellbeing of pupils but also
to enhance the visual and environmental quality of the site. The open spaces are
designed to be multi-functional and adaptable, supporting a range of activities
from structured physical education to informal play and social interaction.
Furthermore, the integration of these spaces within the wider campus and their
connection to the surrounding community contribute to a cohesive and
connected green infrastructure network. 
8.43  Policy 21 of NPF promotes the creation of high-quality, accessible, and inclusive
spaces for play, recreation, and sport, particularly in developments that will be
used by children and young people. Therefore, the proposal also has to
demonstrate compliance with Policy 21 as an area identified as a play area will be
lost adjoining the primary school. In particular, Policy 21 a) iii) states that where
proposals result in the loss of a facility, they will only be supported where a facility
is being replaced or upgraded to provide a better-quality one. Under Policy 21, any
development involving the loss, reduction, or reconfiguration of outdoor sports
pitches must be subject to formal consultation with Sportscotland. This
requirement ensures that, the loss or replacement of playing fields is assessed by
the national governing body for sport provision; replacement facilities meet
current Sportscotland standards (pitch size, surface specification, lighting, etc.);
impacts on community clubs, school use, and informal recreation are fully
understood; and, any deficiencies or shortfalls in the proposed replacement
facilities are identified early and addressed. 
8.44  The supporting information provided shows that the proposal would seek to make
enhancements to Roysvale Park and would retain space for a football pitch and a
running track. In addition, a 3G pitch is proposed on the existing academy site. For
a project of this scale and nature a Sportscotland consultation is essential to
ensure compliance with NPF4 Policy 21 and MLDP EP5. 
8.45  Sportscotland have been consulted on the proposal and have raised no objection
subject to conditions being attached to the planning consent. The conditions
relate to a safeguarding scheme which protects the existing pitch area at Roysvale
Park during the construction period, the new synthetic pitch being designed and
constructed by a recognised (e.g. SAPCA* registered) specialist pitch
contractor(s) and being fully operational and available for use not later than
eighteen months after the opening of the new school. 
8.46  In summary, the school proposal meets the criteria set out under Policy EP5, with
the applicant demonstrating that the siting minimises impacts and appropriate
mitigation measures have been incorporated. The proposal also meets the quality
standards required by the policy and, given Sportscotland’s consultation
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response, is considered compliant with Policy 21. 
8.47  Access, Parking and Sustainable Transport (NPF 13 /MLDP DP1 and PP3) 
NPF Policy 13 seeks to encourage, promote and facilitate development that
prioritises sustainable travel. MLDP Policies PP3 and DP1 require the provision of
a safe entry/exit from new development, with appropriate infrastructure, parking,
cycle parking and Electric Vehicle (EV) charging facilities. 
8.48  The Transport Statement (TS) details that the site lies within Forres Town Centre
and is therefore well located to take advantage of being within a short walking /
cycling distance of a number of local facilities and attractions which fall within the
recommend catchments for walking and cycling defined in the NPF. The existing
Forres Academy site has been on the Burdsyard Road Campus for over 50 years
and in that time a well-developed local active travel plan network has evolved. The
TS explains this network operates well, offering a number of active travel routes to
the campus. Several core paths pass nearby. Sanquhar Road, Burdsyard Road
and Castle Street are all classified as roadside core paths (CP-DA01 and CP-FR32
respectively). Core Path CPFR33 is off road, cutting across Roysvale Park and
through Roysvale Terrace. 
8.49  A survey of baseline travel conditions in the vicinity of the campus was undertaken
by Goodson Associates on the 12th of June 2025. The findings included that the
nearby Orchard Road car park only reached around 50% capacity at the busiest
time, parking on the streets surrounding the school (with the exception Orchard
Road and Burdsyard Road) was generally observed to be low and largely attributed
to long term residents’ parking - there was little evidence of additional parking
activity associated with school drop off and pick up. On Orchard Road, parking
remained stable, with short peaks in the 15 minutes before and after school
times, and some vehicles were observed waiting on double yellow lines outside
Applegrove Primary School, particularly between 15:00 and 15:30. Burdsyard
Road showed occasional parking in bus laybys, most notably during the afternoon
peak. At Applegrove Primary, drop-off and pick-up patterns were similar, though
pick-up involved slightly longer waits and some parking on Sanquhar Road. Forres
Academy displayed more variation, with very short drop-offs (under one minute),
longer pick-up waits, and fewer pickups overall, suggesting many pupils travel
home independently. 
8.50  The new Forres Academy will replace the existing school with a facility designed
for 1,120 pupils and 123 full-time equivalent (FTE) staff. However, the current roll
is approximately 873 pupils with 100 FTE staff, and this reduced level is expected
to continue when the new school opens. Moray Council forecasts indicate pupil
numbers will remain broadly stable, with a slight increase to around 888 pupils by
2032. A number of surveys took place to determine how and when pupils and staff
travel to the existing academy. Based on the results (and other collected data)
from this and NPF and MLDP policy requirements a number of measures are
proposed to support the proposed development in the TS: - 
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8.51  Walking and Cycling 
•  The pupil entrance will be on the south side of the proposed building
accessed via Roysvale Park.
•  A network of new and upgraded footpaths is being provided to improve the
connectivity of the campus for active travel users, including: -
▪   Core path CP-FR33 is being retained along the southern frontage of
new building, as well as the existing north-south footpath linking to
Albert Street along the western frontage. 
▪    A new cycleway/footway is being provided alongside Sanquhar Road,
adjacent to the new bus drop-off layby. This provides a direct
connection between Burdsyard Road and the pupil entrance, replacing
and upgrading Core Path CP-DA01. This core path will be shut off to
allow for it be upgraded and for the construction compound. 
▪   A new north-south pedestrian link is also being provided along the
western edge of Roysvale Park, linking Core Path CP-FR32 to the new
school building. This link will also serve the main school car park, and a
new pedestrian crossing will be installed on Burdsyard Road. A
condition is attached to the consent requiring this new path to be
constructed and brought into operation use prior to the closure of core
of CP-DA01. This is to ensure continuous pedestrian connectivity and
maintain public access in the interest of public safety and
convenience.
▪   The existing crossing on Sanquhar Road to the south of Nelson Street
will be moved approximately 15m northwards away from the egress of
the bus drop-off layby.
•   200 cycle parking spaces in 5 locations around the new building will be
provided for pupils and staff inline Moray Councils standards. (60-space
compound in the NE corner close to the main entrance and another 40-
space compound in the SW corner adjacent to Roysvale Park. Parking
shelters for a further 100 cycles are provided at a further 3 locations, as
shown on the site plan. These shelters will have lockable sliding gates. 
•   Parking for a further 30 cycles is being provided adjacent to the all-
weather pitch, for use by players and spectators). 
8.52  Car Parking 
•  Car parking is in two locations:-  
•  The main car park (for staff and also visitors) is located to the south of
Burdsyard Road and will reuse the existing access off Sanquhar Road. 
•  A smaller car park will be at the front of the new school building, accessed
from Orchard Road. This is for visitor and accessible parking, enhanced
provision drop-off and general servicing. 
•  157 standard spaces being provided in total (140 in main car park and 17 in
front car park (6 spaces are allocated for enhanced provision parent drop-
off); 11 accessible spaces (8 in front car park and 3 on Burdsyard Road); 8
power two wheeled spaces (2 in front car park and 6 in main car park); and
18 EV charging points (4 in front car park and 14 in main car park). 
8.53  Bus Drop-Off and Pick-Up
•  There are two proposed bus drop-off and pick-up zones:-
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•  One is to be provided at the front of the new school building next to the main
entrance, this will provide 3 spaces for enhanced provision buses. 
•  The main bus drop-off and pick-up layby is being provided on the west side
of Sanquhar Road with capacity for 10 buses in total. It will be one way south
to north, with buses entering at the southern end of the layby and exiting at
the north.
•  Two bus spaces are also being retained within the existing bus layby on
Burdsyard Road for the use of visiting teams. 
8.54  General Pupil Drop-Off and Pick-Up
•  The main pupil entrance is on the south side of the building, closest to
Sanquhar Road and Burdsyard Road. Therefore, it is likely that these roads
will be attractive as pick up and drop off areas for the relocated campus.
•  On street parking is available on Burdsyard Road and Sanquhar Road. 
•  Once the campus relocates existing waiting restrictions on Burdsyard Road
are no longer required and it is proposed that these are lifted to allow drop-
off and pick up to take place.
•  Introduction of the bus layby will restrict the opportunity for drop-off on the
west side of Sanquhar Road, but this is largely compensated for by the
increase in parking on Burdsyard Road.
•  During the initial inventory of parking restrictions, it was noted that the
driveways at the north end of Sanquhar Road have access protection
markings (single white line across the driveway) whereas the driveways at
the southern end do not. Given the ample reserve capacity on Sanquhar
Road, it is unlikely that vehicles picking up/dropping off will block the
unmarked driveways. However, as a precaution access protection markings
will be installed at these driveways to give an additional degree of protection.
•  Suitable waiting restrictions (double yellow lines and/or ‘School Keep Clear’
markings) will be placed on Orchard Road along the new school frontage to
discourage vehicles stopping.
•  The parking surveys suggest that there is plenty of capacity in the Orchard
Road car park at both the start and end of the school day. This offers a
convenient alternative for drop-off and pick up close to the new school. 
8.55  Servicing 
•  Servicing of the school will take place from the front car park. A turning circle
has been provided to allow vehicles to enter and exit in forward gear. 
8.56  Travel Plan 
•  The existing school handbook has very little information for pupils or staff
wishing to access the campus by active travel modes. The opportunity
should be taken to develop a travel plan for the new school, to encourage
sustainable travel. 
8.57  Transportation were consulted on the proposal and have raised no objections 
subject to conditions relating to a Phasing and Construction Plan; evidence being
submitted to confirm that the statutory process to promote the Stopping Up of the
Sanquhar Road Cycle Track to enable the provision of the new bus lay-by has
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commenced; evidence being submitted to confirm that the statutory process to
promote new and amended waiting restrictions on Orchard Road, Sanquhar Road
and Burdsyard Road has commenced; the proposed alterations and restorations
to the existing road markings; the provision of new road markings in the vicinity of
the development along Orchard Road, Sanquhar Road, and Burdsyard Road,
amendments and improvements to ensure acceptable development in road
safety and sustainable travel; a Construction Traffic Management Plan and
evidence of the development of a School Travel Plan being submitted. 
8.58  Overall, and subject to conditions where recommended, the proposed transport
arrangements are acceptable and considered to satisfy relevant transport-related
planning policy with no adverse impact on the surrounding environment. 
8.59  Water Supply and Drainage (NPF 22 / MLDP DP1, EP12 & EP13) 
Policies 22, DP1 EP12 and EP13 together seek to ensure that acceptable water
and drainage provision is made, including the use of sustainable urban drainage
(SUDS). 
8.60  Water Supply
The new school will be provided with a public water supply. Following
consultation, Scottish Water confirm that sufficient water capacity is available
however, a connection is not guaranteed. Further discussion will be required with
this consultee direct about both available capacity and connection arrangements. 
8.61  Drainage 
Foul Drainage
8.62  The foul drainage from the re-developed site and the newly developed school area
will be conveyed to the Scottish Water network via a new gravity fed foul drainage
network within the site boundary, connecting to the existing combined sewer to
the north of the site. 
8.63  Throughout the development, all surface water (rainfall) will be diverted away
from the combined sewer network. This approach applies to both the new
Academy site and the adjacent Applegrove Primary, significantly reducing
pressure and increasing capacity within the combined sewer system. Within the
existing academy site and the proposed new car park and 3G pitch, all foul
drainage connections will be removed, with the exception of the swimming pool.
The removal of the existing building will release substantial capacity within the
adopted drainage network, improving overall system efficiency in this area. 
8.64  Surface Water
Northern Site – New Academy Site 
8.65  The northern site will incorporate a dedicated private surface water sewer
network. This network will route west along Albert Street, then north via Castle
Street, before continuing west along Orchard Road to discharge into the Mosset
Burn, upstream of the vehicular road bridge. The sewer is currently undergoing
technical approval with Scottish Water and once adopted, will form part of the
Scottish Water infrastructure, providing capacity for future development. 
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8.66  It will be served by a new gravity-fed surface water sewer system. Surface water
will undergo treatment at source through sustainable urban drainage measures,
including porous parking areas, filter trenches, and other SuDS features, before
being stored within 692m³ of underground cellular storage crates. Discharge from
this storage will occur at a controlled rate agreed with Scottish Water and SEPA
via the new sewer. This provision will replace and enhance the existing storage
serving Applegrove Primary, while connecting to the new surface water sewer and
removing flows from the combined sewer network. Additionally, the existing drain
line capturing rainwater from greenfield areas will be replaced with dedicated
filter trenches to address historic water management issues. The maximum
discharge rates, incorporating climate change allowances, are 10.7 l/s for the 1-
in-30-year event and 20.6 l/s for the 1-in-200-year event. 
8.67  Southern Site – New Car Park and 3G pitch
The southern site will be served by a dedicated private surface water sewer
network. Stormwater from the car park will be treated and attenuated through
porous paving, while surface water from the sports pitch will be stored within the
granular sub-base beneath the pitch, with discharge limited to 5 l/s. All surface
water will be conveyed by gravity to a new dedicated headwall discharging into the
Mosset Burn. Existing drainage infrastructure will be removed, except for that
serving the retained swimming and hydrotherapy pool building. Importantly, all
foul sewer connections within this section of the site will be removed. 
8.68  The extent of hardstanding in this part of the site will be significantly reduced
through the removal of the existing impermeable car park surface, which will be
replaced with accessible green space. 
8.69  Surface Water Treatment 
It is proposed that external parking areas will receive treatment through a
permeable road system designed in accordance with CIRIA C753. Porous paving,
filter trenches and attenuation tank storage for collection of rainwater prior to
discharge to watercourses will be used. This includes areas for roofing, parking,
and roads, which are to be treated prior to discharge. 
8.70  Surface Water Attenuation 
Upon redevelopment, it is proposed that surface water run-off from the proposed
site will be captured in a new urban drainage network. 
8.71  The proposed drainage strategy incorporates Sustainable Drainage Systems
(SuDS) guidance and includes on-site water attenuation to manage surface water
runoff. A cellular storage solution is proposed, utilising tanks buried beneath the
new car parking areas and external hardstanding. 
8.72  The required storage volume has been accurately modelled
using ‘InfoDrainage’ software. The system is engineered to manage up to a 1 in
200-year storm event, incorporating a 42% allowance for climate change
resilience. The post-development discharge is strictly controlled: flows up to the 1
in 30-year plus climate change event are limited to the 1 in 2-year pre-
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development runoff rate, while all storms up to the 1 in 200-year plus climate
change event are limited to the 1 in 30-year pre-development runoff rate. 
8.73  Summary 
Although the new school is a replacement, foul flows from the development are
expected to be significantly reduced due to the installation of modern low-flow
fittings and appliances. Importantly, the only flows entering the combined sewer
from the new facility and Applegrove Primary will be foul water, which will
substantially reduce overall discharge and relieve pressure on the combined
sewer network, historically associated with flooding issues. 
8.74  Surface water runoff from new external hardstanding areas will incorporate SuDS
measures for treatment and attenuation, designed to meet agreed discharge
limits. Attenuation features have been tested for 1-in-200-year rainfall events with
an additional 42% uplift for climate change resilience. The northern site (main
school) and Applegrove Primary will discharge via a new surface water sewer
network to the Mosset Burn, significantly improving local drainage and providing
future connection opportunities to this new public asset. 
8.75  All foul and surface water flows from the northern site will be removed from the
combined sewer network, creating substantial additional capacity. Surface water
will be treated and attenuated at source prior to discharge into the Mosset Burn at
agreed flow rates. Source-control SuDS features will remove coarse solids and
silts in accordance with CIRIA C753, with treatment provided through a
combination of filter trenches, permeable paving in parking areas, and
attenuation tanks before discharge. The proposed treatment strategy has been
verified using SEPA’s Simple Index Tool. 
8.76  Moray Flood Risk Management, SEPA and Scottish Water were consulted on the
proposal and have no objections to it. The criteria in NPF Policy 22 and MLDP
Policies DP1, EP12 and EP13 has been met. Conditions will be attached to ensure
that proposals for surface water drainage treatment are delivered and maintained. 
8.77  Flooding (NPF 22 / MLDP DP1 & EP12)
These policies seek together to ensure development would not be at significant
risk of flooding from any source or would materially increase the possibility of
flooding elsewhere. Policy 22's intention is to strengthen resilience to flood risk by
promoting avoidance as a first principle and reducing the vulnerability of existing
and future development to flooding. 
8.78  A full stage 2 Flood Risk Assessment (FRA) was submitted with the proposal
providing details of flood risk from all sources, results of hydrological and
hydraulic studies and proposed mitigation. The aim of the Level 2 Flood Risk
Assessment is to assess any potential flooding to the development site from all
potential sources: coastal, fluvial (watercourse), pluvial (surface water) or
groundwater. 
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8.79  Historical Flooding in Forres
Flooding has historically been a concern in Forres, evidenced by past events and
the implementation of the Forres (Mosset Burn) Flood Alleviation Scheme.
Introduced in 2007, the scheme, comprising a major storage reservoir at
Chapelton Dam and two smaller upstream dams, has successfully reduced peak
flows through Forres, with only two notable flood events recorded since its
inception. Historic issues also include sewer flooding east of the site during
extreme rainfall and surface ponding on Roysvale Park due to poor drainage. The
FRA acknowledges these concerns and aligns with wider initiatives to reduce
flood risk across Forres and Moray 
8.80  Fluvial Flooding 
SEPA flood mapping indicates a low likelihood (1-in-1000-year) of fluvial flooding
across part of the proposed site near Applegrove Primary. In comparison, the
existing Forres Academy site is at greater risk, with this flood extent covering the
entire school footprint. Additionally, there is a high likelihood (1-in-10-year) of river
flooding south of the current school around the Mosset Burn, encroaching near
the existing car park. Relocating the school to the proposed site therefore
represents a positive step in reducing overall flood risk. 
8.81  Mott MacDonald were commissioned by Moray Council to undertake a review of
post-development impacts of the development in terms of fluvial flood risk using
an existing model and based on the known risk/likelihood of flooding due to
remaining fluvial flooding concerns. 
8.82  The methodology for reviewing flood risk involved the comparison of the baseline
model (existing conditions) versus the proposed development states, identifying
potential concerns with respect to fluvial flooding which may impact the
proposals. 
8.83  On removal of the existing academy building there is a risk of increased flooding
downstream as this structure essentially acts as a barrier, naturally conveying out
of bank flow back to the watercourse. To alleviate any concerns, flood mitigation
measures are proposed for the development. 
8.84  Mott Macdonald recommended 5 options for mitigation and option 4 was deemed
to be the most advantageous at eliminating the predicted increase of flood risk
and reducing the general peak flood water levels. It is noted that detailed
consideration was given regarding which option from the Mott MacDonald report
was best for the development but also the town as a whole. Option 4 includes the
reduction of existing levels in an area to the south of the existing school site,
adjacent to the ‘outdoor gym’ along the Mosset Burn. The recommendations
suggest a lowering to +16.3m AOD are 10 P15762 – Forres Academy required,
requiring approximately 2500m3 of earthworks cut out of the existing area, and
roughly 300 - 500m3 of earthworks fill for the bund. These flood protection
measures including the lowered ground and earthworks bund will be protected
from future development and will be maintained by Moray Council to ensure
continual, effective operation. 
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8.85  Based on the modelling of this option, it is anticipated that there are a number of
locations where previous flooding is expected to be eradicated. This includes
areas along Orchard Road and the residential properties to the north-west of the
site, to the west of Burdsyard Road above the existing academy, and in a larger
area immediately below the existing academy which are considered as ‘was wet
now dry’ and negative changes in flood height. This is also indicated with
reductions in flood height across various large locations in Forres when
accounting for the proposed mitigation measures. 
8.86  Sewer Flooding 
Scottish Water asset plans indicate the presence of adopted surface water
drainage infrastructure within the site boundary. These assets are located in
landscaped areas, and adequate space must be maintained for access and
maintenance. Any flooding resulting from blockage or surcharge of this
infrastructure is expected to be contained within low-lying landscaped areas,
posing very low risk to proposed residential dwellings. 
8.87  The town of Forres is served by a Scottish Water combined sewer network located
north of the site along Orchard Road, west along Albert Street, and east along
Sanquhar Road. In the event of a combined sewer surcharge, the site’s elevation
and distance, along with kerb and wall separation, provide protection, resulting in
a low risk of flooding. 
8.88  Furthermore, the construction of a dedicated adopted Scottish Water surface
water sewer as part of the development will significantly reduce historic sewer
flooding in this area by returning capacity to the combined sewer network. 
8.89  Ground Water Flooding 
The floodwater levels were monitored over the wettest period of the year and were
found to be stable. All new features and structures have been designed to sit
about this water table. As a result, the risk of ground water flooding can be
considered low. 
8.90  Pluvial Flooding (Surface Water)
The site is susceptible to low (1-in-1000-year) and medium (1-in-200-year)
likelihood surface water flooding, primarily in areas that correspond with fluvial
flood zones previously identified. SEPA pluvial flood mapping indicates these
areas occur within low points of the central playing fields, along the Orchard Road
boundary, and around the hardstanding and footprint of the existing Forres
Academy in the southern section. 
8.91  The proposed surface water drainage network will be designed to accommodate
flood flows up to and including the 1-in-200-year storm event plus climate change
allowance, ensuring no damage to buildings, essential services, or adjacent
properties. Through site development and upgrades to the local drainage system,
combined with the installation of filter trenches, existing surface water flooding
issues are expected to improve. On-site attenuation will be provided using
Scottish Water-adoptable SuDS measures, with appropriate falls formed away
from the proposed development.
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8.92  Climate Change 
The development will be designed to ensure it remains safe from flooding during a
1-in-200-year event, including a 42% climate change allowance in line with SEPA’s
Climate Change Allowances for Flood Risk Assessment (Version 6, Feb 2025). For
the North Highland River Basin Region, this equates to a 42% increase in peak
rainfall intensity to 2080 and will be incorporated into the drainage design. The
proposed surface water drainage network will contain flood flows for these design
events within the site, preventing damage to buildings, essential services, or
neighbouring properties. 
8.93  Summary 
All potential sources of flood risk, including rivers, surface water, sewers,
groundwater, and artificial sources, have been assessed. The building has been
positioned in the most suitable location on the site, outside any significant flood
risk areas. 
8.94  The SEPA flood map and Mott MacDonald flood modelling identifies that the
existing academy site is at risk of fluvial flooding from the Mosset Burn. Therefore,
flood mitigation measures are to be implemented in accordance with
recommendations of the flood modelling report. 
8.95  In its current undeveloped state, the site is susceptible to low (1-in-1000-year)
and medium (1-in-200-year) likelihood pluvial flooding. SEPA flood mapping
indicates these areas correspond to low points along the Orchard Road boundary,
through the central playing fields, and around the hardstanding and footprint of
the existing Forres Academy. Through site development and upgrades to the local
surface water drainage system, any existing surface water flooding issues are
expected to improve. 
8.96  In accordance with Moray Council flood risk requirements the development will
be designed to ensure that it is not at risk of flooding from a 1 in 200-year plus 42%
climate change event. 
8.97  Moray Flood Risk Management, SEPA and Scottish Water were consulted on the
proposal and have no objections to it. MFRM and SEPA require a condition to be
attached to the consent regarding the proposed flood storage area and flood bund
(Mitigation Option 4) outlined within the Flood Risk Assessment modelling report
(Mott MacDonald, 2025) being constructed and operational prior to
commencement of demolition works at the existing Forres Academy Site. The
storage area and flood bund must be maintained in perpetuity this is to ensure
there is no increase in flood risk as a result of the development. The criteria in NPF
Policy 22 and MLDP Policies DP1 EP12 and EP13 has been met. 
8.98  Contaminated Land (NPF 9 & 23 / MLDP EP14)
These policies seek to ensure that where land is known or suspected to be
unstable or contaminated, development proposals will demonstrate that the land
is, or can be made, safe and suitable for the proposed new use. 
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8.99  Following consultation and in relation to potential pollution risks, the Council's
Environmental Health Contaminated Land Service has no objections however an
informative is required to be attached to the consent detailing that an Electricity
Sub Station is located in the southern section of the site and that it should be
considered investigating whether the land is contaminated prior to proceeding
with the proposed works and the need for any resulting mitigation works. 
8.100  Pollution (NPF 23 / MLDP EP14) 
Policies 23 and EP14 aim to ensure that new developments do not create
pollution which could adversely affect the environment or local amenity. Pollution
can take various forms including run off into watercourses, noise pollution, air
pollution and light pollution. 
8.101  Construction 
The Environmental Health Section following consultation and review of the
application and construction information documents (Construction Phase Plan,
Construction Project Management Plan and Construction Susutainabilty Plan),
has raised no objection subject to conditions to ensure that the proposal does not
adversely affect the environment or local amenity. These include controlling hours
of construction works including vehicle movements, submission/approval of a
Construction Environmental Management Plan (CEMP) to minimise construction
related noise, dust and artificial lighting, controlling operational noise levels and
submission/approval of details of all artificial lighting during operations to avoid
light pollution. 
8.102  External Lighting and Flood Lighting 
External lighting is to be located throughout the site. The Lighting Pollution
Statement states that the current proposal for external lighting is for information
only however, the standards and principles outlined in the report will be followed
throughout the design. On review of the Light Pollution Planning Statement,
Environmental Health have no objection to the external lighting subject to a
condition requiring the final details to be approved in writing prior to
commencement of the development. 
8.103  Details of the floodlighting for the 3G Sports Pitch is provided in drawing –
Proposed Forres Academy Floodlighting. Environmental Health have no objection
to this subject to a condition that ensures the floodlighting is as proposed unless
otherwise agreed in writing. 
8.104  Noise 
A Noise Impact Assessment was undertaken for the 3G sports pitch, dance and
fitness studios and building plant and specific mitigation is set out below: 
8.105  3G Sports Pitch 
Th 3G Sports Pitch, to be located on the existing academy site once it is
demolished is proposed to be open during school term time Monday to Friday
8am to 9pm (8am to 4pm for school use and beyond this for public bookings) and
Saturday and Sunday 9am to 5pm. Outwith school term time it is proposed to be
open Monday to Friday 9am to 9pm and Saturday and Sunday 9am to 5pm. The 3G
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Sports Pitch will be managed during school hours by the school and out of school
hours by the Sports and Culture department. Noise mitigation measures for the
pitch are detailed in the Noise Impact Assessment (NIA); these include
containment boards, goal backboards for hockey and weldmesh fencing be fixed
using resilient fixings. Subject to conditions Environmental Health have raised no
objections to the proposed 3G Sports Pitch.  The conditions relate to the hours of
permitted use, the design and materials of the containment boards, the type of
fencing and a noise management plan. 
8.106  Fitness/Dance Studio 
A fitness suite and dance studio is proposed within the ground floor of the new
school. The proposed opening times of the fitness suite and dance studio are 8am
to 10pm Monday to Friday and 9am to 5pm Saturday and Sunday.  The fitness
suite and dance studio will be managed during school hours by the school and out
of school hours by the Sports and Culture department. Environmental Health have
no objection to it subject to conditions stating the hours of used (as above, unless
otherwise agreed in writing) and details regarding its design and building
fabrication to ensure noise emissions arising from the studios do not exceed
Noise Rating Curve (NR) 15 as determined within a living apartment of the nearest
noise sensitive dwelling with the window moderately open as referred to in the
NIA. 
8.107  Building Plant 
The plant associated with the school will predominantly be roof-mounted,
comprising five larger mechanical ventilation with heat recovery (MVHR) units
serving internal spaces and ten air source heat pumps (ASHP). Additionally, most
external-facing classrooms will be equipped with individual MVHR units. The NIA
notes the specific plant selection has not yet been finalised, and it therefore
assesses the maximum permissible noise levels required to meet the relevant
criteria. Environmental Health have no objection to it subject to a condition
requiring further details of the potential noise impact and mitigation measures
required for the plant equipment. The mitigation should ensure noise emissions
arising from the plant does not exceed Noise Rating Curve (NR) 25 (between 0700
and 2300) and Noise Rating Curve (NR) 20 (between 2300 and 0700), as
determined within a living apartment of the nearest noise sensitive dwelling with
the window moderately open. Thie limit would apply and be determined over a
minimum of 5 minutes duration between the hours of 0700 to 2300 hours. 
8.108  Bird Control 
Measures to deter roosting and nesting gulls upon the roofs of buildings is
proposed. This includes bird netting and sounder equipment. The number and
positions of the sounder equipment shown on the Bird Protection Site Plan and
Bird Protection Measures – Main Building Measures is indicative only therefore a
condition is attached to the consent requiring the details of the measures/design
features utilised to deter roosting and nesting gulls upon the roofs of all buildings
to be submitted to and approved in writing by the Council as Planning Authority
prior to the commencement of development. Thereafter the measures hereby
approved must be adhered to and in place prior to any of the buildings coming into
occupation/use. This is to ensure the development does not attract seagull
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activity which would be to the detrimental amenity of the users and neighbouring
properties. 
8.109  Subject to the conditions the proposal complies with the criteria in NPF Policy 23
and MLDP Policy EP14. 
8.110  Biodiversity (NPF 3 / MLDP EP2)
The proposed development of the new Forres Academy demonstrates compliance
with NPF Policy 3 and MLDP Policy EP2, both of which require developments to
deliver positive effects for biodiversity and contribute to nature recovery. These
policies emphasise the application of the mitigation hierarchy, enhancement of
habitats, and integration of nature-based solutions. 
8.111  The design approach for the new academy prioritises biodiversity through the
retention of existing green infrastructure and the introduction of new landscaping
that incorporates native species planting. These measures will create habitats for
pollinators and local wildlife, strengthen ecological connectivity, and improve the
overall biodiversity value of the site. In addition, the development includes
sustainable drainage features and outdoor learning spaces, which further support
biodiversity. 
8.112  To ensure compliance, the applicant has submitted a Biodiversity Net Gain (BNG)
statement and a landscape plan. These documents set out the baseline of how
the development will achieve measurable improvements in biodiversity, including
habitat creation, species-rich planting, and long-term management
commitments. 
8.113  The following habitats are proposed to be created: 
•  Ninety native individual trees will be planted across the Site, predominantly
within the northern and southern areas of the Site. 
•  Modified grassland will be created predominantly in the northern areas of
the Site. This will be seeded with a suitable amenity grassland mix; 
•  Additional lowland meadow, ‘other neutral grassland’ will be planted
utilising a mix of amenity grasses and lowland wild flowers (of a similar type
to Scotia Seeds ‘Urban Pollinator Mix’1 ) 
•  A rain garden will be created within the northern area of the Site; 
•  As stated on the Landscaping GA Plan (see appendix B), mixed scrub
planting will be scattered throughout the Site; 
•  Block paving, vehicle asphalt, cycle path colour tarmac, tactile pathing, 3G
pitch, footpath, benches, sheds with canopies, hungry hut, free standing
canopies, cycle shelters, cycle path, amphitheatre and greenhouses will be
developed throughout the Site.  
8.114  Further biodiversity enhancement will be provided through the addition of bird and
bat boxes (providing nesting and roosting opportunities) installed on mature trees
throughout the site. 
8.115  The proposed development will deliver a net gain of +10.10% for habitats and
+128.06% for hedgerows. Due to the nature of the scheme, it was not possible to
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completely avoid habitat impacts through re-siting. Every effort has been made to
achieve the local policy target for biodiversity net gain on-site; however, the
functional requirements of the development limit the scope for enhancements
beyond the +10% target. The inclusion of fruit- and nut-bearing trees and shrub
species within the planting scheme will provide additional biodiversity benefits by
offering foraging opportunities for birds and small mammals, these benefits are
not captured within the metric, which is based solely on habitat area.
Furthermore, the creation of wildflower areas will support pollinators and other
invertebrates, which in turn provide a food source for birds and bats. In addition,
habitat piles of logs and brash will be retained within planted areas to create
refugia for local wildlife. 
8.116  While this proactive approach aligns with NPF’s requirement for developments to
leave biodiversity in a demonstrably better state and meets MLDP Policy EP2’s
emphasis on enhancement and protection, a condition is required to be attached
to the planning consent requiring a detailed biodiversity plan to be submitted and
approved in writing prior to the commencement of works. This will ensure that all
proposed measures are implemented and monitored effectively throughout the
development lifecycle. The Climate Change Strategy Officer advised that the BNG
report and landscape plan contains sufficient information to provide comment,
however the documents do not refer to NPF and biodiversity principles. The
following suggestions were made to the applicant to be included within the
Biodiversity Plan, swift bricks, bird boxes within the ecology garden, amphibian
hibernacula, hedgehog holes in fences, showing habitat types, prioritising locally
native trees, details of plants in ecology garden. This is in addition to the proposed
enhancements. 
8.117  The proposed Forres Urban Nature Network runs through the site, linking
outwards in multiple directions using natural features such as the Mosset Burn
and Sanquhar woods, as well as active travel routes. The site (particularly the old
school site) is therefore of strategic importance for nature connectivity, allowing
species to safely move. The inclusion of education and recreation spaces within
this part of the network also increase the value of communicating that importance
through interpretation (Policy 3 (b)(v.) The additional information required through
the condition will support the development in meeting the Policy 3 outcome to
strengthen nature networks. 
8.118  Overall, subject to a condition requiring submission of a detailed biodiversity plan,
the proposal is considered to meet the requirements of NPF4 Policy 3 and MLDP
Policy EP2. These conditions include proposed condition 18 regarding protection
of trees to be retained. 
8.119  European Protected Species (NPF 3 / MLDP EP1)
Nationally protected species are defined in the Wildlife and Countryside Act 1981.
Under NPF Policy 3 and MLDP EP1 any development proposals that would have an
adverse effect on a European Protected Species will not be approved.    
8.120  A Preliminary Ecological Appraisal (PEA) and Preliminary Ecological Assessment
Summary were submitted with the proposal. The PEA details that there are no
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designated sites identified which overlap with or were adjacent to the proposed
site boundary. Six statutory designated sites were identified within 5km of the site
boundary. 
8.121  None of the habitats recorded in the site are considered to be ‘priority habitat’ and
presently offer limited significant biodiversity value. No evidence of protected
species was recorded within the site. 
8.122  The PEA makes various recommendations, including:- 
•  The Mosset Burn, which flows through the site, flows into the Moray and
Nairn Coast RAMSAR Site and Culbin Sands, Culbin Forest and Findhorn Bay
SSSI. Without mitigation, it is considered likely that there is a risk of
significant adverse effect to these sites from pollution during construction. A
Habitats Regulation Assessment (HRA) should be carried out for the
RAMSAR site (this has been undertaken).
•  The habitats on site are mainly urban and of low ecological value. The
woodland habitats, while potentially being of greater ecological value,
mainly consist of rows of trees, or the edges of larger woodland areas. It is
recommended that trees are retained wherever possible or replaced if felling
is required.
8.123  In terms of Protected Species various recommendations are made:-
•  Badgers - safe site mitigation measures should be followed for the duration
of the works as follows, all efforts should be made to ensure a safe work
site, which must include capping all exposed pipes / containers and
covering all open excavations (if required for the works) or providing an
adequate means of escape should any animals fall in (i.e., earth ramps or
wooden planks). 
•  Bats - further surveys are recommended to determine the presence or
absence of roosting bats in any buildings to be demolished given the
buildings on the site may be suitable for roosting bats – one potential entry
point was recorded. Trees bordering the northern playing fields had potential
for roosting bats. Should any work be required to take place within 30m of
these trees, it is recommended that further bat surveys are carried out to
determine the presence or absence of roosting bats on these trees. The
habitats within the site may provide opportunity for foraging and commuting
bats within the wider landscape. A lighting plan for the works is
recommended to ensure that site lighting is restricted to the works area only
with minimal light spill to the wider corridor and embankments. The works
area should not be lit when site staff are not in attendance.
•  Birds – The woodland habitat, academy buildings and vegetation within the
survey area provide suitable nesting habitat for birds. If
works/demolition/any vegetation removal are to commence within the
nesting bird season (March-August in Scotland, inclusive), it is
recommended that a nesting bird check of all works areas is undertaken
prior to the start of works, no more than 48 hours ahead of works, by a
suitably qualified ecologist. If nesting birds are confirmed to be present, then
all works in the vicinity of any nest must be delayed until the young have
fledged, and an ecologist has confirmed the nest is no longer in use. An
appropriate exclusion area will also be put in place.
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•  Otters - The Mosset Burn which flows between the two southern parts of the
site was identified as being suitable habitat for otter, although no otter signs
were recorded. If any works are to disturb this area, or come within 50 m of
the watercourse, it is recommended that a full otter survey is carried out.
•  Pine martens – although no pine marten signs were identified in the survey
area given the woodland habitat bordering the Mosset Burn and the two
southern parts of the site may provide suitable foraging habitat. As pine
marten may utilise the Survey Area for commuting, the following general
mitigation measures are recommended for the duration of the works an
emergency stop works procedure should be implemented by site workers if
pine martens or potential pine marten dens are unexpectedly encountered.
All work within 50m will cease until a suitably qualified ecologist has
inspected the site and determined the appropriate course of action.
•  Red squirrels - No squirrel signs were identified within the Survey Area. The
presence of red squirrel cannot be ruled out by this PEA alone, as such the
following precautionary mitigation measures are recommended for the
duration of the works an emergency stop works procedure should be
implemented by site workers if red squirrels or potential red squirrel dreys
are unexpectedly encountered. All work within 50m will cease until a
suitably qualified ecologist has inspected the site and determined the
appropriate course of action.
•  Reptiles - may use rock piles and wood piles as refugia. Should it be
necessary to remove these features, care should be taken to allow reptiles
to disperse. This should not be undertaken from October – March when
reptiles may be using the features as hibernacula and are sensitive to
disturbance. 
8.124  NatureScot confirmed that they did not require to be consulted on the proposal. A
condition is attached to the consent to ensure adherence with the
recommendations within the PEA. The criteria in NPF Policy 3 and MLDP Policy
EP1 have been met. 
8.125  Trees (NPF 6 / MLDP EP7)
The proposed development of the new Forres Academy demonstrates a
commitment to the principles set out in NPF Policy 6: Forestry, Woodland and
Trees and MLDP Policy 7. Both policies emphasise the importance of protecting
existing woodland, enhancing tree cover, and integrating green infrastructure into
development to support biodiversity, climate resilience, and community
wellbeing. 
8.126  The design for the new academy respects the existing landscape by retaining
mature and important trees wherever possible, ensuring that the character and
ecological value of the site are preserved. This approach reflects the national and
local policy requirement to safeguard established woodland and avoid
unnecessary loss of tree cover. While some trees will inevitably be removed to
accommodate the new building and associated infrastructure, this has been
minimised through careful site planning and design. In total the felling of 44 trees
(including Birch (Silver and Downy), Rowan, Elm, Cherry, Alder, Sycamore, Lime
and Holly) across the site is required, primarily to accommodate the new football
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pitch, flood basin, bus access, turning area and elements of the car park and
entrance plaza.  Additional trees will be affected by construction activities,
particularly along the western and Applegrove boundaries, where sycamores and
cherries will experience significant root disturbance. These are considered
capable of retention with appropriate mitigation, including canopy thinning to
reduce stress and careful management during and after construction. 
8.127  To offset this loss, the proposal includes a compensatory planting scheme on a 2
for 1 basis and a total of 90 trees will be planted using native species, which will
strengthen biodiversity, enhance ecological connectivity, and contribute to long-
term landscape quality. These measures not only enhance the visual quality of the
development but also deliver significant environmental benefits, including carbon
sequestration and improved habitat diversity. 
8.128  A condition is attached to the consent to ensure adherence with the submitted
Tree Protection measures.    
8.129  Overall, the Forres Academy project demonstrates good practice in embedding
forestry and woodland considerations into development. By retaining existing
trees, introducing new native planting, and creating spaces that support
biodiversity, the proposal meets the requirements of NPF4 Policy 6 and MLDP
Policy 7, while contributing positively to Moray’s vision for a greener future. 
8.130  Climate and Nature Crisis, Mitigation and Adaptation (NPF 1 & 2)
Policy 1 of National Planning Framework 4 (NPF4) places significant weight on the
global climate and nature crises in the assessment of all development proposals.
It requires that planning decisions actively contribute to addressing these twin
emergencies by promoting development that is nature-positive and supports the
transition to net zero. 
8.131  The proposed new Forres Academy complies with this policy. The development
replaces an outdated building with a modern, energy-efficient facility that is
designed to minimise environmental impact. The site layout and building design
incorporate green infrastructure, biodiversity enhancements, and sustainable
drainage systems, all of which contribute to nature recovery and ecological
resilience. Landscaping proposals are expected to support habitat connectivity
and improve the ecological value of the site, in line with the policy’s emphasis on
restoring and enhancing nature networks. 
8.132  Furthermore, the proposal demonstrates a clear commitment to climate action
through the submission of a positive carbon statement. This document outlines
how the development will reduce lifecycle greenhouse gas emissions and
contribute to Scotland’s net zero targets. The inclusion of this statement reflects a
proactive approach to climate responsibility and provides a transparent
framework for assessing the development’s environmental performance. 
8.133  Policy 2 of NPF4 requires that all development proposals are sited and designed
to minimise lifecycle greenhouse gas emissions and adapt to current and future
risks from climate change. The new Forres Academy meets these requirements
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through a combination of design, construction, and operational strategies. 
8.134  The carbon statement confirms that the development provides a comprehensive
overview of whole-life carbon considerations, future climate adaptability, and net-
zero operation plans. However, demolition carbon emissions and detailed
operational carbon breakdown remain incomplete and will be addressed during
the detailed design phase. While renewable energy and heat decarbonisation
strategies are fully detailed, including capacity and integration, there is no carbon
management and reporting plan or timeline for energy modelling completion.
Sequestration opportunities are limited but integrated where possible, and
barriers to net zero are primarily financial, with LEIP funding critical to delivery. 
8.135  Next steps include completing energy modelling, demolition carbon calculations,
operational carbon details, and developing a carbon reporting plan during detailed
design. A planning condition would be attached to the consent to ensure these
details are considered, when available. 
8.136  In terms of adaptation, the development responds to the increasing risks
associated with climate change, such as more intense rainfall and higher
temperatures. The site includes sustainable drainage systems (SuDS) to manage
surface water and reduce flood risk. 
8.137  The positive carbon statement submitted with the planning application provides a
clear and measurable account of how the development addresses both mitigation
and adaptation. It demonstrates that the project has been designed with a full
understanding of its environmental responsibilities and aligns with national
climate policy objectives. 
8.138  The proposed new Forres Academy is an environmentally positive, sustainable
development that fully supports the aims of NPF Policy 1 and Policy 2. Through its
energy-efficient design, biodiversity enhancements, and climate resilience
measures underpinned by a submitted positive carbon statement the project
exemplifies best practice in tackling the climate and nature crises. 
8.139  Heat Network (NPF 19) 
The proposed development of the new Forres Academy has been assessed
against National Planning Framework 4 (NPF4) Policy 19, which seeks to ensure
that all new developments contribute to the decarbonisation of heat and cooling
systems and support Scotland’s transition to net zero. 
8.140  The submitted information confirms that the building design incorporates modern
energy efficiency measures, including renewable energy integration and low-
carbon heating solutions. These measures demonstrate compliance with Policy
19 by reducing lifecycle greenhouse gas emissions and supporting sustainable
energy use. 
8.141  It is noted that there is no need for the development to connect to a Local Heat
and Energy Efficiency Strategy (LHEES) network, as the building will be net zero on
its own. 
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8.142  In summary, the proposal meets the intent of NPF4 Policy 19 by prioritising heat
decarbonisation and energy efficiency without reliance on LHEES connectivity. 
8.143  Socio-economic (NPF 25)
Policy 25 of NPF4 introduces a strategic shift in how development contributes to
local economies, placing community wealth building (CWB) at the heart of
planning decisions. This policy seeks to ensure that development proposals
deliver tangible economic, social, and environmental benefits to local
communities by supporting local employment, supply chains, and community
ownership. 
8.144  In line with emerging best practice and local planning guidance, the applicant has
committed to the submission of a Community Wealth Building Plan (CWBP)
through a planning condition. The supporting information provided confirms that
the CWBP will set out clear measures to maximise community benefits, including
the use of local labour, apprenticeships, and training opportunities, as well as
prioritising local supply chains and support for small and medium-sized
enterprises (SMEs) in Moray. The applicant has indicated that the plan will also
detail mechanisms for community access to facilities and explore partnerships
with local organisations, ensuring that the new Forres Academy becomes a focal
point for social and economic development. These commitments align with the
principles of Policy 25 by embedding community wealth building into the delivery
of the project and creating tangible benefits for the local economy and residents.
The CWBP will therefore provide a structured framework to monitor and secure
these outcomes throughout the construction and operational phases of the
development. 
8.145  Overall, subject to a condition requiring submission of a detailed Community
Wealth Building Plan (CWBP), the proposal is considered to meet the
requirements of NPF4 Policy 25. 
REASON(S) FOR DECISION
The Council’s reason(s) for making this decision are: - 
The proposal is to provide a new Forres Academy and additional support needs
teaching facilities and community facilities with associated landscaping, external
sport provision including a 3G sports pitch, car parking and bus drop-off to
replace the existing academy on land at Applegrove Playing Field, Roysvale Park
and the existing Forres Academy site, Forres. 
The new school is essential community infrastructure required to deliver a key
objective of the Moray Council. The proposed development represents a
significant and positive opportunity to replace the existing school with a modern,
fit-for-purpose facility, while also enhancing sports and community facilities for
the benefit of both students and the wider community. 
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The site layout and building design incorporate green infrastructure, biodiversity
enhancements, and sustainable drainage systems, all of which contribute to
nature recovery and ecological resilience. The proposal demonstrates a clear
commitment to climate action and will minimise lifecycle greenhouse gas
emissions and contribute to Scotland’s net zero targets. 
Subject to conditions where recommended, the siting, design and servicing
arrangements for the replacement school are considered acceptable with no
unacceptable or significant adverse impact identified upon the appearance and
amenity of the development plan and/or the surrounding area. The proposal is, in
all respects, considered to be acceptable and accord with the provisions of the
National Planning Framework 4 and Moray Local Development Plan 2020 and
there are no material considerations that indicate otherwise. 
Author/Contact
Officer:
Emma Mitchell            
Senior Planning Officer
Ext: 01343 563326 
Neal MacPherson
Acting Service Manager, Planning and Building Standards Manager 
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Appendix 1 – List of Persons/Parties Submitting Representations 
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