Agenda Document Pack - Planning and Regulatory Services Committee - 16/03/2026
Moray Council · 16 March 2026
Back to Planning and Regulatory Services Committee — 16 March 2026 and its agenda
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Planning and Regulatory Services Committee Monday, 16 March 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 Monday, 16 March 2026 at 09:30. BUSINESS 1. Sederunt 2. Declaration of Group Decisions and Members Interests * 3. Hearing: Planning Application 25/00354/MIN Report by Appointed Officer The extraction of sand and gravel by quarrying and the operation of a ready-mix concrete plant on Land to South-east of Dykeside Farm, Birnie, Elgin for Leiths (Scotland) Limited 5 - 122 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. Page 1
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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. Page 2
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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. Page 3
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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 Page 4
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Report to: Special Meeting of the Planning and Regulatory Services Committee Meeting Date: 16 March 2026 Report by: Chief Governance Officer (Monitoring Officer) Author: Lissa Rowan Contact Email: lissa.rowan@moray.gov.uk Subject: Hearing: Planning Application 25/00354/MIN 1. PURPOSE ☐ For Decision ☒ For Information 1.1 The purpose of the Hearing is to afford those submitting representations and the applicant the opportunity to state and explain their cases before the Planning and Regulatory Services Committee prior to the Committee determining the application. 1.2 This report is submitted to Committee in terms of Section III (E) (1) of the Council's Scheme of Administration relating to the functions of the Council as Planning Authority. 3. SUMMARY 3.1 The Committee is invited to hear the applicant and those submitting representations in relation to Planning Application 25/00354/MIN. 2. BACKGROUND AND CONTEXT 2.1 In terms of the Council’s Scheme of Delegation relating to Planning Applications, the above noted application has been referred direct to a Hearing to which the applicant and those submitting representations have been invited to attend and afforded the opportunity of being heard. 2.2 Members of the Committee visited the site of the application on 11 March 2026. 3. APPOINTED OFFICER’S REPORT 3.1 A copy of the Appointed Officer’s report on the application is attached. 4. HEARING PROCEDURE Item 3. Page 5
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4.1 The proposed procedure which the Committee will follow in respect of the Hearing is as follows:- (i) The Applicant will speak first (maximum of 15 minutes) outlining the application and addressing the stated objections. (ii) Members of the Committee will then be given the opportunity to question the Applicant in order to clarify points raised. (iii) Interested Parties will then be given the opportunity to address the meeting (maximum of 10* minutes) to speak to their stated objections/representations. It should be noted that the Committee will not be prepared to consider any new ground(s) of objection/representation. (iv) Members of the Committee will be given the opportunity to question each Interested Party in turn in order to clarify points raised. (v) The Clerk will read out the names of those who have submitted written statements and advise that these have been circulated to the Committee and uploaded on to the Councils Committee Website. (vi) Both Applicant and Interested Parties will then be given the opportunity to summarise their respective cases, in light of the submissions, to the Committee (5 minutes each maximum for Interested Parties and equivalent time for the Applicant). (vii) The Appointed Officer, or their representative, will then be afforded the opportunity to make any additional comments and/or points of clarification in light of the submissions. (viii) The Committee will then determine the application. * This may be extended at the discretion of the Chair in cases where the speaker is speaking on behalf of a number of representatives or is representing other party/parties who are unable to attend a Hearing. Page 6
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WARD 04_17 25/00354/MIN 3rd April 2025 The extraction of sand and gravel by quarrying and the operation of a ready-mix concrete plant on Land to South- east of Dykeside Farm, Birnie, Elgin for Leiths (Scotland) Limited Comments: • A site visit has been undertaken. • This application is a major application. • The proposal has been advertised for neighbour notification purposes and as a Schedule 3 Development. • Representations have been received from 843 individuals/families - 837 of which are objectors, 5 supporting the proposal and 1 neutral. • Heldon Community Council (Local Community Council) and Elgin Community Council have objected. Procedure: • Application to be considered at a meeting of the Planning and Regulatory Services Committee which will include a hearing, as the appointed officer considers, following the consultation process, that the application raises matters of wider community interest. • The hearing will allow for the applicant and those making representations to be given opportunity to speak to the application and the stated representations prior to its determination. Recommendation Refuse for the following reasons: The proposed development is contrary to the National Planning Framework 4 (NPF4) and Moray Local Development Plan 2020 (MLDP). 1. NPF4 Policy 33 Minerals and MLDP Policy DP10 Minerals would only consider such development favourably where it did not result in any significant adverse impacts. Where the proposal would introduce a significant change to the landscape through the extraction of sand and gravel and installation of a concrete ready-mix batching plant into the Countryside Around Towns designation, to the detriment of the rural landscape and its character where the open rural character is specifically to be Page 7
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preserved, results in the departure from Policy 33 and DP10. 2. The proposed development, by virtue of its presence within the Elgin Countryside Around Towns (CAT) designation would sit within a landscape restricted from development and vulnerable to development pressure bringing it into conflict with MLDP Policies DP1 Development Principles and EP3 Special Landscape Areas ii) Landscape Character and NPF4 Policy 4 Countryside Around Towns a) Natural Places. In terms of landscape character, the lack of natural enclosure and impact of the industrial appearance of the quarry and concrete batching plant proposal would have an adverse significant effect and change on the character of the area. Similarly, in terms of visual amenity, the nearby properties to the southeast, east and south in the vicinity would experience significant adverse effects on their visual amenity from the proposed development. The proposed development is therefore a departure from MLDP Policies DP1 and EP3 and NPF Policy 4. 3. The development being proposed within the Elgin (CAT) designation lies within an area where development must generally be prohibited to maintain the distinction between the defined settlement boundary of Elgin and the surrounding open countryside. The proposal is therefore a departure from MLDP Policy EP3 ii), EP4 and the Elgin (CAT) designation where the size and scale of the proposed development (13.59ha), industrial appearance and location in open countryside immediately adjacent to the C2E Elgin to Birnie Road significantly undermines the function, nature and character of the Elgin Countryside Around Town (CAT) area. LIST OF PLANS AND DRAWINGS SHOWING THE DEVELOPMENT Reference No. Version No. Title/Description DFQ3-12 Hedgerow And Woodland Planting Plan DFQ2.1 Site And Location Plan DFQ1.1 Location Plan DFQ3.1 Phase 1 Quarry Development Plan DFQ3.10 Cross Sections DFQ3.11 Waste Management Plan DFQ3.2 Phase 2 Quarry Development Plan DFQ3.3 Phase 3 Quarry Development Plan DFQ3.4 Phase 4 Quarry Development Plan DFQ3.5 Phase 5 Quarry Development Plan DFQ3.6 Phase 6 Quarry Development Plan DFQ3.7 Phase 7 Quarry Development Plan DFQ3.8 Phase 8 Quarry Development Plan DFQ5i Zones Of Theoretical Visibility DFQ5ii Landscape Character DFQ5iii Viewpoint Location Plan Page 8
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DFQ6.2 Proposed Hydrology Plan DFQ6.3 Restored Hydrology Plan DFQ8.1 Potential Noise Sensitive Locations DFQ9.2 Dust Sensitive Locations 01 R0 Ready Mix Concrete Plan BCS1 Bund Cross Section DFQ3.9 rev 1 Restoration Plan Page 9
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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: Land To South-east Of Dykeside Farm Birnie Elgin Planning Application Ref Number: 25/00354/MIN Location Plan Applicant Name: Leiths (Scotland) Limited Page 11
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Location plan Page 12
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Site location plan 16/01664/APP Page 13
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Cross sections 16/01664/APP Page 14
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Ready-m ix concrete plant 16/01664/APP Page 15
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Hedgerow & W oodland planting 16/01664/APP Page 16
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Phase 1 Quarry Developm ent 16/01664/APP Page 17
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Phase 3 Quarry Developm ent 16/01664/APP Page 18
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Phase 6 Quarry Developm ent 16/01664/APP Page 19
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Restoration plan 16/ Page 20
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Photo location plan 16/ Page 21
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Photo 1 16/ Page 22
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Photo 2 16/ Page 23
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Photo 3 16/ Page 24
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Photo 4 16/ Page 25
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Photo 5 16/ Page 26
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PLANNING APPLICATION: 25/00354/MIN 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 • This application seeks planning permission for the extraction of sand and gravel by quarrying, aggregate processing and the operation of a ready-mix concrete plant, on land located to the south-east of Dykeside Farm, Birnie, Elgin. • The quarry would produce washed and graded aggregates suitable for construction uses, e.g. in ready-mix concrete, along with sand suitable for concrete and general-purpose uses. • Planning permission is sought for a period of 18 years 6 months. 850,000 tonnes of sand and gravel would be extracted at a rate of around 50,000 tonnes per annum over 17 years, with an additional 6 months required for set up/initial infrastructure works and a further 1 year for final restoration. • Proposed initial works would involve the formation of the site access onto the C2E Elgin to Birnie Road, the creation of the access haul road and installation of site infrastructure including weighbridge, site office and processing plant. Either prior to or during this initial period tree and shrub planting would be undertaken on the land immediately to the south-east of the development area with hedgerow planting being undertaken along the edge of the C2E road. • The site would be worked in eight phases. • Soils would be stored in peripheral screening mounds on the site boundary and within the storage mound in the north-western corner of the site. As operations proceed, any overburden (i.e. non-sand and gravel, clay materials) encountered within the excavation area will be placed in the storage mound in the north-western corner of the site. Following soils removal in advance of extraction operations, sand and gravel extraction will be undertaken using a wheeled loading shovel and articulated dump truck. The processing and stockpiling of sand and gravel will be undertaken on the quarry floor within the excavation void created by the development of Phases 1, 2 and 3. As operations move into Phase 4 progressive restoration will commence with stripped soils being utilised for progressive restoration. The progressive removal of the overburden storage mound will commence during Phase 5 with these materials being utilised to landscape and restore the southern quarry void. Phases 5 to 8 will involve removal of the overburden storage mound, and final stages of extraction and restoration. • Water for operations, including aggregate washing, concrete production, and dust suppression will be sourced from surface runoff and a proposed Page 27
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on-site borehole. Three settlement ponds will collect and recycle water, with no discharge from the site. • Following cessation of excavation and processing, a further year is proposed for restoration. Equipment and hard surfaces will be removed, and stored soils will be used to reinstate the final excavation and plant areas. • The majority of the site will return to agricultural use, with woodland and shrub planting to be undertaken along the northern boundaries. A low-lying area will form a seasonal ephemeral wetland to manage surface water and support biodiversity. • Site access will be retained for future land management. • The proposed hours of operation and despatch (as requested by the applicant) are 7.00am to 6.00pm Mondays to Fridays and 7.00am to 12.00pm on Saturdays. • The application is supported by an Environmental Review (ER) which includes assessments in relation to landscape and visual impact, hydrogeology and hydrology, ecology, noise, air quality, transportation and the historic environment, restoration and aftercare proposals, a Dust Management Plan, Extractive Waste Management Plan, Stability Risk Assessment, Biodiversity Net Gain Assessment, along with a Planning Statement, Pre Application Consultation Report, Residential Visual Amenity Assessment, Community Wealth Building Plan and a Climate Change Assessment. • The applicant has also submitted responses to comments received from Transportation, Environmental Health and Flood Risk Management Sections, the Council’s Landscape Adviser, the Elgin and Heldon Community Councils and representations received as a result of neighbour notification procedures. 2. THE SITE • The proposed quarry is situated on agricultural land at Dykeside Farm in the parish of Birnie 1.5 km south of Elgin. • The site area is 13.59 ha, with 11.59 ha proposed for excavation. • The proposed quarry site is bordered by the C2E Elgin to Birnie Road to the east, with agricultural land beyond. To the south, the U117E road connects Elgin to Birnie Road to Paddockhaugh, with arable farmland immediately adjacent. The western and northern boundaries comprise hedgerows, with grazing land to the west and former pig farming land to the north. • Scattered residential properties and businesses are located throughout the surrounding area. The following distances relate to the closest point of the proposed excavation. The closest properties are Denarii and Barholm, located on the eastern side of the C2E Elgin to Birnie Road, approximately 100 metres to the south-east of the site. Immediately adjacent to Denarii lies the Moray Archery Club, at a distance of around 150 m from the excavation boundary. Further east, an unclassified road leads from the C2E to a small cluster of six residential properties known as The Level, situated between 280 and 450 m from the site, beyond which lies the Springfield Group timber Page 28
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kit factory. Two properties at Castlehill, including a vehicle repair business, are positioned approximately 320 metres to the south-east. • Thomshill lies approximately 540 m to the south, while the hamlet of Paddockhaugh, comprising a group of residential properties and Birnie Parish Kirk (a Scheduled Monument and listed building), is located between 580 and 700 metres to the west. To the north, Dykeside Farm and Grieves House, owned by the site landowner, are approximately 440 metres away, with Dykeside Cottages a little further north at 460 m. The Kennels, a residential property adjacent to the Elgin to Birnie Road, is situated around 720 m to the north. In addition, several distilleries are present in the wider area, the closest being the Glenlossie and Mannochmore complex, located near Thomshill approximately 600 m to the south-east of the proposed site. • The site is located within the Elgin Countryside Around Towns designation as identified in the Moray Local Development Plan 2020. • The site is generally level, with gentle slopes ranging from 60 metres AOD in the south to around 52 metres in the north-east. Surrounding land varies in elevation, rising to over 100 metres in the south and falling to around 40 metres near the River Lossie to the west. To the north, the terrain dips towards Elgin, with wooded areas reaching up to 55 metres AOD. • Overhead electricity lines cross the site, with one central line requiring relocation during quarry operations. A second line on the south-west side will remain in place. A high-pressure gas main lies 20 metres north of the site boundary and 55 metres from main quarry operations. A mains water pipe runs along the western edge of the Elgin to Birnie road which the proposed site access road will require to cross to access the Elgin to Birnie road. • The site is not within any designated environmentally sensitive areas. • There are known cultural heritage assets located within the proposal site. • The land is not classified as Prime Agricultural Land. It is designated as Class 3.2 under the Land Capability for Agriculture system (indicating that it is capable of supporting mixed agriculture, where a moderate range of crops can be grown). • Based on the SEPA online flood maps, the site is not at risk of fluvial flooding; parts of the site are at risk of pluvial flooding. 3. HISTORY For the Site: 24/00058/PAN - Proposal of Application Notice for proposed formation of quarry extraction and processing of sand and gravel and production of ready-mix concrete at the site. Responses dated 31 January and 20 March 2024 confirmed consultation arrangements and publicity events to be acceptable and provided feedback from the Planning and Regulatory Services Committee to be considered in the preparation of the application. This highlighted concerns regarding the increase of HGV traffic in the area, proximity of the development to neighbouring properties, the use of countryside and agricultural land for the proposal, dust permeating into the wider area from the development, potential flood risk, how Page 29
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the land will be returned to agricultural land once the development is complete and impact to climate change and biodiversity. 23/02159/PEMAJ - Pre-application major enquiry for proposed formation of quarry extraction and processing of sand and gravel and production of ready-mix concrete at the site. 23/02120/SCN & 21/02121/SCO – Screening Opinion adopted 16 December 2021 for proposed formation of quarry extraction and processing of sand and gravel and production of ready-mix concrete; assessment confirmed the proposal to be a Schedule 2 development but not likely to result in significant environmental effects, and therefore not requiring to be subject to EIA procedures. 4. POLICIES National Planning Framework 4 Policy 1 - Tackling the Climate and Nature Crisis Policy 2 - Climate Mitigation and Adaptation Policy 3 - Biodiversity Policy 4 - Natural Places Policy 5 - Soils Policy 7 - Historic Assets and Places Policy 12 - Zero Waste Policy 13 - Sustainable Transport Policy 14 - Design, Quality and Place Policy 18 - Infrastructure First Policy 22 - Flood Risk Policy 23 - Health and Safety Policy 25 - Community Wealth Building Policy 33 - Minerals Moray Local Development Plan 2020 PP2 - Sustainable Economic Growth PP3 - Infrastructure and Services DP1 - Development Principles DP10 - Minerals EP1 - Natural Heritage Designation EP2 - Biodiversity EP3 - Special Landscape Areas EP4 - Countryside Around Towns EP7 - Forestry Woodland and Trees EP8 - Historic Environment EP12 - Management and Enhancement Water EP13 - Foul Drainage EP14 - Pollution Contamination Hazards Page 30
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5. ADVERTISEMENTS • Advertised for neighbour notification purposes. • Advertised as a development specified in Schedule 3 of the Development Management Regulations 2013. 6. CONSULTATIONS Strategic Planning and Development – The proposal departs from National Planning Framework 4 (NPF4) Policies 4 and 33 and the Moray Local Development Plan (MLDP) 2020 Policies DP1, DP10 and EP3. The site is located within the Elgin Countryside Around Town (CAT) designation. Notes that the proposal provides a very specific site locational justification associated with mineral extraction and the development would contribute towards long-term planning for the provision of construction aggregates in Moray. However, the proposal is not one of the exceptions set out in policy and therefore would be considered a departure from MLDP Policy EP4. Despite the locational justification, given the significant adverse landscape and visual effects highlighted below the proposal would not be considered an acceptable departure, unless these are mitigated appropriately to prevent development sprawl. The proposed development is subject to NPF4 Policy 33 and MLDP Policy DP10 which states that proposals for the sustainable extraction of minerals will only be supported where they avoid or satisfactorily mitigate impacts. NPF4 Policy 4 and MLDP Policy DP1 (i) b) requires development to integrate into the surrounding landscape/natural environment. Local Development Plans are required to support a landbank of construction aggregates of at least 10-years at all times in the relevant market areas. The Moray Minerals Audit 2023 identified that the was a sufficient landbank for crushed (hard) rock, however there was only a permitted minerals reserve of sand and gravel to September 2033 with consented supply levels to drop considerably by 2031 i.e. there is an insufficient landbank for sand and gravel. The Council’s appointed Landscape Adviser has undertaken a detailed appraisal of the proposal. This concludes that although the development would have limited wider visibility due largely to containment provided by landform and woodland, significant adverse effects would mainly occur on the character of the site and its immediate surroundings within the Coastal Farmland Landscape Character Type. There would be significant adverse effects on views from minor roads, recreational routes and from some residential properties lying close to the site, namely: • In the short term from the Thomshill to Elgin Road which is aligned on the eastern boundary of the proposed development site and represented by Viewpoints 2, 3, 4 and 8 when the pre-operation works of access construction, soil stripping and screen bunding earth works would be seen Page 31
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in close proximity. Effects on views from this road would reduce to not significant as grass seeding on the screen bunding established and hedgerow and tree planting becomes sufficiently dense and tall to provide screening. It is estimated that this would occur approximately 5 years after the commencement of works. While the bunding and planting would curtail currently open views from the road, the baseline character of the site is of relatively low scenic value. Uniform, evenly graded earth bunding would however appear obviously artificial and further mitigation is recommended to reduce adverse effects on views. • Longer term significant adverse effects would occur from more elevated views where a greater extent of the excavation works would be visible. These are represented by Viewpoints 2, 7 and 9. While a significant adverse effect could also occur from the elevated Viewpoint 10 on the northern edge of Hillhead Wood, this viewpoint is considered to be difficult to access and unlikely to be experienced by many people. Although progressive restoration and planting on the boundaries of the site would alter the nature of views over the operational phases of the quarry, it is considered that effects would remain significant throughout much of the duration of the development. • A significant adverse effect would occur on views from the unclassified road aligned on the southern boundary of the site (represented by Viewpoint 11) where it rises gradually to the west and where the overburden store and other infrastructure would intrude above the top of screen bunding. While this effect would persist in the longer term, views would be brief and there would be likely to be relatively few people affected. Further mitigation in the form of hedgerow and tree planting is recommended on the southern boundary of the site. • Significant adverse effects on views from the upper floor west-facing windows of the properties of Windsong and Denmoor are anticipated however it is considered that the Residential Visual Amenity Threshold (RVAT) would not be reached however given the overall relatively limited effects on views from within these buildings and their gardens due to the screening provided by earth bunding and planting on the eastern edge of the site. • The RVAA description of the property of Windsong indicates that the assessor did not verify likely visibility from inside the house and has assumed that there is a double-height ground floor west-facing room from planning documents. As it is not possible for the Council to make detailed visits of all nearby properties both inside and out and a certain amount of reliance is necessary on the RVAA submitted by Applicant, it is acknowledged that if there are no upper west-facing rooms in the property of Windsong then effects on views would not be significant. An update to their original July 2025 report omitted to mention the nearby property of Denarii which would, in their opinion, also be subject to significant adverse effects from upper west-facing windows. • There would be adverse effects on views from some gardens within Thomshill and it is considered that 26 Mannochmore, which may have elevated views from the rear of the property and garden, could be significantly affected. There is also considered to be significant adverse effects from the garden of the property of Castlehill lying to the east of the Page 32
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proposed development site due to its elevated nature. However, it is not considered that the RVAT would be reached in the case of these properties given the distance of the development, its relatively low-lying nature and the character of existing views. If the application is to be supported, the Council’s Landscape Adviser recommends extensive mitigation measures, such as early hedgerow and woodland planting, naturalistic earth bund design, and a detailed restoration plan that enhances biodiversity and potentially includes open water and public access. An extended aftercare period of 10 years and a robust management plan are also advised. NPF4 Policy 25 requires proposals to contribute to local or regional community wealth building strategies and be consistent with local economic priorities. A Community Wealth Building Plan (CWBP) has been submitted in support of the application setting out how the proposal maximises local employment and skills opportunities and stimulates local supply chain opportunities through construction and operational stages of the development. Subject to a condition to secure an updated CWBP that reflects the difference procurement stages and monitoring statement to be agreed with Strategic Planning & Development and the Planning Authority, the proposal complies with NPF4 Policies 25 and associated Moray Planning Policy Guidance on Community Wealth Building. NPF4 Policy 2 requires developments to be sited and designed to minimise lifecycle greenhouse gas emissions, as far as possible, and adapt to current and future risks from climate change. A Climate Change Assessment Report has been submitted with the application in compliance with NPF4 Policy 2 and associated Moray Planning Policy Guidance on Carbon. NPF4 Policy 3 and MLDP Policy EP2 requires development proposals to contribute to the enhancement of biodiversity, including where relevant, restoring degraded habitats, and building and strengthening nature networks and the connections between them. NPF4 Policy 3 (b) requires ‘national or major’ development to demonstrate how the proposal will conserve, restore and enhance biodiversity, including nature networks so they are in a demonstrably better state than without intervention. Sufficient information has been submitted in support to demonstrate how the proposal conserves, restores and enhanced biodiversity. Subject to a condition requiring an updated Ecological Survey to ensure these are up to date at the time of construction, and the provision of any mitigation measures identified, the proposal complies with NPF4 Policy 3, associated Moray PPG and MLDP Policy EP2. In conclusion, the proposal provides a very specific site locational justification associated with mineral extraction and the development would contribute towards long-term planning for the provision of construction aggregates in Moray. However, the site is located within the Elgin CAT, does not meet any exemptions set out in MLDP Policy EP4 and has the potential to result in significant adverse landscape and visual effects. Page 33
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If the application is approved, a condition should be applied requiring the provision of an updated Ecological Survey, and any mitigation measures identified, and an updated CWBP and monitoring statement to be agreed with the Planning Authority. Moray Flood Risk Management - Following review of submitted drawings, drainage and flood risk assessment, and additional information, no objection. Transportation – Following review of submitted drawings and Transport Statement, and additional drawings and information - no objection, subject to conditions requiring submission/approval of a detailed road width investigation report covering the section from the site access northwards to the Elgin Golf Club entrance to identify carriageway widths and any required widening works to 6 metres, provision of visibility splays, site access surfaced to adoptable standards with swept paths, 50 metres of hot rolled asphalt laid centred on the access, a Construction Traffic Management Plan and a Management Plan addressing site drainage and vehicle cleaning to prevent discharge onto the public road, provision of drainage and catch ditch drains to the bunds and access, an Operational Traffic Management Plan to show how HGV routing will be managed, and CCTV monitoring system (if required) to ensure effective enforcement of designated traffic routes, restrictions on excavations, slopes and planting adjacent to the public road, car and cycle parking provision and implementation of road sweeper to prevent to prevent accumulation of debris and verge creep. Preamble The following response is provided based on the following documents/drawings submitted on 27.03.2025 as a part of this planning application and subsequent supporting information/drawings provided as a response to Transportation Further information request issued on 20.05.2025. 1. Site and location plan (DFQ2.1) 2. Quarry Development plans (Phase 1-8) Drawing numbers DFQ3.1-Q3.8 3. Restoration plan (DFQ3.9) 4. Appendix 7 Fairhurst transport statement (TS) • Indicative site access layout (159952/sk1003-A) • Swept Path Analysis, Articulated Vehicles (159952/sk1004-A) • HGV Routing (159952/sk8000-A) • Existing Road Widths (159952/sk1001-A) • Proposed Road Widening (159952/sk1002-B) 5. Additional supporting information/drawings submitted on 11.06.2025 • Car and cycle parking plan (DFQ3.11) • Indicative site access layout (159952/sk1003-C) • Swept Path Analysis (159952/sk1004-B) • Areas to be widened (159952/sk1005) Page 34
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Parking Provision Based on the provided details, the quarry facility will operate with four staff members when fully operational and will offer six standard parking spaces, including two designated for visitors. The number of parking spaces is considered sufficient given the staffing level at the facility. Of the six spaces, one has been designated as a disabled parking space. Additionally, a separate location has been allocated for a secure, covered, and enclosed cycle parking facility, which will accommodate four bicycles. Impact on the Local Road Network The Site is bounded to the east by C2E Elgin to Birnie Road and to the south by U117E Paddockhaugh Road. Paddockhaugh Road is a narrow single-track road without adequate passing facilities and is therefore unsuitable for HGV movements. As such, Transportation does not recommend its use as an access route to the site during either the construction or operational phases of the proposed development. It is proposed to get access to the proposed quarry facility from the C2E Elgin to Birnie Road which has varying carriageway widths in the vicinity of the development access. Consequently, there is currently no centre line marked on this section of the road. The Elgin-Birnie Road (C2E), heading south through Thomshill towards Fogwatt on the A941, is a single-track road with limited passing places, making it unsuitable for HGVs passing light vehicles. Therefore, it is recommended that the HGV vehicle movements to/from the south from/to the proposed development are restricted. Any use of the Elgin-Birnie Road (C2E) south of site access and any location between the A941 and B9010 should only be permitted for deliveries to a postcode that takes main access from any of the Elgin-Birnie Road (C2E), Shougle Road (U113E), Paddockhaugh Road (U117E), Glenlatterach Road (U118E), Birkenbaud Road (U119E) and Trochail Road (U124E), subject to existing HGV restrictions. Section 5.2.1 of the TS reaffirms this position. However, to effectively monitor compliance, usually a CCTV camera system would need to be installed at the site entrance, with access provided to the Council’s Traffic Team. This would enable the Council to monitor adherence to designated delivery routes and respond to any public complaints regarding HGV movements. The applicant is of the view that the use of the southern section of Elgin-Birnie Road (C2E) can be prevented by implementing a robust protocol for HGV drivers and any customers accessing the site. Furthermore, the applicant is open to a planning condition requiring approval of this protocol, which would negate the need for CCTV monitoring. Accordingly, a planning condition seeking approval of this protocol is included in this response. Should there be any failures in adhering to the protocol, or if evidence or complaints arise regarding the use of the southern section of Elgin-Birnie Road by Page 35
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HGVs associated with the proposed quarry facility, the installation of a CCTV system will become necessary. A separate clause will be added to the condition to address this scenario. An Automatic Traffic Count (ATC) close to the proposed site access has been carried out between 19.04.2024 and 25.04.2024 to assess total traffic volumes and the number of HGVs on the C2E Elgin to Birnie Road. A summary of the ATC findings is as follows: • Five-day (Weekday, 07:00 -18:00 p) two-way average traffic volume is 736 • Five-day (Weekday, 07:00 -18:00) two-way average HGV traffic volume is 138 • Maximum of 28 HGV trips (two way) recorded during the peak hour Trip Generation It is expected that the proposed quarry will operate 5.5 days per week- Monday to Friday from 07:00 to 18:00, and Saturday from 07:00 to 13:00 - producing approximately 40,000 tonnes of dry aggregates and 10,000 tonnes of ready-mix concrete annually. Trip generation from the proposed development has been estimated based on two scenarios. Each scenario is further divided into two sub- scenarios to reflect variations during normal demand and periods of higher demand (defined as double the average production). A summary of the trip generation calculations is provided below. Scenario 1: all dry aggregates will be removed from the site in 20-tonne loads Scenario 2: 38,000 tonnes will be removed in 20-tonne loads and 2,000 tonnes in 5-tonne loads. • The weight of the concrete mixer vehicle used in the calculation is 20 tonnes (8 m³). • A scenario involving 2,000 tonnes transported in 5-tonne loads has been included to reflect on-site material sales carried out by smaller vehicles. Scenarios considered Average Weekday HGV Vehicle Trips (Two way) Average Weekday HGV Vehicle Trips (Two Way- hourly) Scenario 1 (normal demand) 20 2 Scenario 1 (higher demand) 38 4 Scenario 2 (normal demand) 22 2 Scenario 2 (higher demand) 42 4 Overall, with the additional information and clarifications provided, Transportation is content with the trip generation calculations. Page 36
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Proposed Mitigatory Measures. Should the quarry facility become operational, there will be conflicting movements between additional HGV traffic generating from the proposed quarry and existing HGV traffic serving, such as the Glenlossie/Mannochmore distillery. Although some localised widening has been carried out along the C2E, it does not provide a consistent minimum width along the Elgin–Birnie (C2E) Road. The National guidance recommends a minimum road width of 6.0 metres for occasional HGV use and 6.8 metres for roads where HGVs are expected to pass regularly. On narrower roads, HGVs passing each other are forced to use the outer margins of the carriageway, increasing the need for edge strengthening. Transportation would seek improvements to provide a minimum 6.0-metre width, including curve widening from the site entrance north to the A941, where swept path analysis demonstrates the need. The existing road structure already shows signs of pavement distress over long sections; therefore, additional edge strengthening and drainage works will be required before any increase in HGV traffic is permitted on this section of road. To address these concerns, the submitted Transport Statement (TS) included proposals for road and curve widening at identified locations along the Elgin - Birnie Road. According to the "Existing Road Widths" drawing (159952/sk1001-A), three locations - A, B, and C - have been identified for potential widening. This drawing also provides measured road widths along the 2.5 km stretch from the proposed quarry access to the Elgin Golf Club entrance. The proposed widening sections are: • Location A: From CH: 940m to 967m • Location B: From CH: 1072m to 1200m • Location C: From CH: 1500m to 1643m However, as per the carriageway widths presented in the ‘Existing Road Widths’ (159952/sk1001-A) drawing, there appear to be some other locations where the carriageway width falls below the standard required width of 6m as follows: Chainage (m) Carriageway Width (m) 50 5.99 100 5.87 150 5.86 200 5.93 250 5.97 500 5.86 1450 5.97 2400 5.88 Page 37
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The narrower section of road at CH:2400 has already been identified as a potential problem area where two HGVs cannot pass each other safety due to the limited road width. Therefore, further information was sought regarding proposed improvements at these locations to ensure a consistent minimum carriageway width of 6.0 metres along the Birnie Road. The additional information provided by the applicant on 11.06.2025 includes the proposals to improve these sections of road to minimum road width of 6.0m. The applicant has carried out site investigations at selected locations, which revealed that verge creep has reduced the effective carriageway width to below 6.0 metres. Therefore, the applicant proposes to conduct further investigations on the road sections identified in the table above. If it is found that the actual carriageway width is less than 6.0 metres, widening works will be undertaken, ensuring a minimum compaction width of 800 mm to bring these sections to minimum carriageway width of 6.0 metres. Road Construction Consent (RCC) will be required for these works, and detailed drainage information will be submitted as part of the technical documentation required for the RCC process. Furthermore, during the quarry operational period, the applicant will periodically employ a road sweeper to ensure that verge creep does not significantly reduce the effective width of the Elgin–Birnie (C2E) Road below 6.0m. Access to the development At the pre-application stage, the applicant was informed that a visibility splay of 4.5 x 160m in both directions would be required at the access onto the Elgin– Birnie Road (C2E), maintained clear of any obstruction greater than 0.26m in height. This requirement was based on an assumed 85th percentile speed of 50mph. However, the speed survey report submitted as part of planning application reference 24/01431/APP has recorded 85th percentile speeds of 57.2mph northbound and 54.4mph southbound. These higher speeds necessitate increased visibility splays, and it is therefore recommended that the visibility splays for this development should be provided as follows, • Visibility splay to the south: 185m • Visibility splay to the north: 170m An updated visibility splay drawing was requested to reflect these changes. The updated drawing, reference no. 159952/SK1003 dated 21.05.2025, shows the revised visibility splays as required. Additionally, based on the vertical profile drawings provided, it is understood that the proposed access is located at the highest point of the crest curve of the road, which enhances visibility in both directions. The forward visibility line shown along the road confirms that any vehicle waiting on the Elgin–Birnie Road to turn right into the new access will be visible to approaching vehicles from both directions at the specified distances of 185 metres and 170 metres. Page 38
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Swept Path Analysis (SPA) The submitted swept path analysis (SPA) drawings for turning movements of both HGVs and large tipper lorries entering and exiting the site are acceptable. The drawings demonstrate that during the anticipated turning manoeuvres, the wheels and body of the vehicles remain within the expected carriageway lane and do not encroach onto the opposite lane, thereby avoiding hazardous movements. Additionally, the applicant has provided further details confirming that the larger tipper used in the SPA accurately represents the existing fleet operated by Leiths (Scotland) Limited. The additional information confirms that the larger tipper used in the analysis is 0.8 metres longer than the tipper lorries currently in use by Leiths (Scotland) Limited. Drainage and Flooding Screening earth bunds have been proposed throughout different phases of the development. These bunds should include roadside drainage measures to ensure that no surface water is trapped by these bunds which would result in flooding on the public road. This is especially relevant to the U117E Paddockhaugh Road to the south of the development site, which is entirely reliant in natural flow paths following existing lie of the land either through groundwater or occasional overland flows for drainage. Therefore, Additional drainage details were sought to demonstrate that the proposed bunds and access arrangements will not negatively impact existing drainage or exacerbate flooding issues along Elgin–Birnie Road and Paddockhaugh Road. The applicant has proposed to install a series of catch ditch drains within the site to collect water runoff from the U117E Paddockhaugh Road and direct it into the site's internal drainage system, where it will be managed to maintain the existing free flow of surface water. Further drainage details will be secured through a planning condition attached to this response and as part of the Road Construction Consent (RCC) and technical approval process. Other issues As the proposed quarry is bounded by public roads on two sides, it is essential to maintain adequate lateral support for these public roads. Therefore, no excavation should be undertaken within a minimum distance of 3m from the edge of the public road boundary and slopes should be excavated to a maximum gradient of 1:2. The proposal shows some broadleaf tree planting. However, no tree planting should be permitted within 5m of the edge road carriageway. This buffer will allow trees to develop a near-natural canopy with minimal intervention required by the Roads Authority under Section 91 of the Roads (Scotland) Act. Additionally, any proposed tree planting or earth bunds must not encroach upon the visibility splays at the Paddockhaugh Road / Elgin–Birnie Road junction. Page 39
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The additional details provided by the applicant via a separate email dated 17.06.2025 confirm that, during gravel extraction, the closest excavations will be at least 15 metres from the C2E Elgin–Birnie Road and at least 11 metres from the U117E Paddockhaugh Road. Furthermore, it is confirmed that all tree planting will be carried out with a 5 metre buffer from the road edge and will not obstruct the visibility splays as previously noted. The earth bunds will be designed to maintain forward visibility along Paddockhaugh Road and will not obstruct the visibility splay at the development access. Environmental Health – Following review of the application and additional information - no objection, subject to conditions limiting quarry operations to 08:00–18:00 Monday to Friday and 08:00–12:00 on Saturdays, unless otherwise agreed; noise levels not to exceed 45 dB(A) during normal operations and 70 dB(A) for soil and overburden handling, which is restricted to eight weeks per year; all vehicles to use white noise reversing alarms; submission/approval of a Noise Monitoring Programme and site lighting details, to be maintained throughout the development; implementation of a Site Dust Management Plan in accordance with supporting Environmental Review information, to be maintained throughout the development; and further requirements for the operator to monitor noise following complaints and implement mitigation if limits are breached. Environmental Health (Contaminated Land) - No objections. Environmental Health, Private Water Supplies - No objection, subject to condition requiring submission/approval of a comprehensive Water Management Plan which should include the information submitted on 09.05.25 to the Environmental Health Private Water Supplies Team regarding the proposed new water extraction onsite borehole, the cumulative abstraction volume from the unregistered abstraction well on Dykeside Farm used for farming purposes and the Hillhead Irrigation licence. The plan should detail actions to be taken, including shut down of abstraction operations (if required), during seasonal weather variations and periods of water scarcity. The plan shall also include evidence that the requisite investigations regarding the hydrological and geomorphology of the location can provide and sustain the required abstraction without impacting other private water supplies in the area. Aberdeenshire Council Archaeology Service – No objection, subject to a condition requiring submission/approval of an archaeological written scheme of investigation (WSI), implementation of archaeological works in accordance with the approved WSI and should works reveal need for post excavation analysis the submission/approval of a post-excavation research design (PERD). Planning And Development Obligations - No obligations sought. Moray Access Manager - No objection. Notes that while access rights will not be impeded by the application, increased traffic on the surrounding quiet roads, which are frequently used by walkers, cyclists, and horse riders, could raise safety concerns and affect how these routes are enjoyed by the public. This is Page 40
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highlighted by high Strava use in the area, indicating significant recreational activity by typical users of the platform. Building Standards - Building warrant may be required for the office building depending upon its floor area and facilities. The applicant should contact the building standards service direct to provide further information and discuss the need for building warrant. Scottish Water – No objection, subject to provisos. The applicant is advised that this does not confirm serviceability, and there is no public wastewater infrastructure nearby. Private treatment options should be considered. Capacity cannot be reserved; availability will be assessed following planning approval and a formal connection application. Scottish Water assets are located near the site, and the applicant must check for conflicts, contact the Asset Impact Team via the Customer Portal, and obtain written permission before commencing works. No designated Drinking Water Protected Areas are affected by the proposal. Historic Environment Scotland – Notes that the proposals have the potential to affect Birnie Parish Kirk and associated heritage assets (Scheduled Monument SM2781 and Listed Building LB2294). Confirms that it has no comments to make; however, this should not be interpreted as support. The application should be determined in line with national and local policy on development affecting the historic environment. NatureScot – Confirms no comments to make. Refers local planning authorities and developers to its standing advice in relation to protected species and licensing requirements. Scotland Gas Networks Ltd – Following separate discussions with the applicant, no objection subject to a condition requiring consultation with SGN at each stage of development to ensure that the proposed development does not impact nearby pipeline. Scottish Hydro Electric Power (Scottish and Southern Energy) - No response received. Scottish Environment Protection Agency - The application falls below the thresholds for which site-specific advice is typically provided and provides the following regulatory advice: Following the replacement of Controlled Activities Regulations (CAR) by Environmental Authorisations (Scotland) Regulations (EASR) for regulated activities, two separate authorisations will be required instead of a simple licence. The construction of a borehole less than 200m in depth requires a registration level authorisation and the abstraction will require a separate permit level authorisation. It is recommended that the applicant review the information and guidance available on SEPA's website and contact the Water Permitting team for pre-(authorisation)application discussions if required. Transport Scotland – Does not propose to advise against the granting of permission. The applicants should make themselves aware of the proposed Page 41
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alignment and current status of, and associated alterations to access arrangements that would be brought about by, the A96 Hardmuir to Fochabers Scheme. National Quarries Inspection Team – Provides regulatory advice and confirms: Fugitive dust is considered to be a statutory nuisance and a matter for the Local Authority. Matters of public health from substances are a matter for Public Health Scotland. The mineral planning authority has powers to apply planning conditions including for levels of dust emissions and for monitoring. The control of exposure to dust for workers on the site would be regulated by HSE under the COSHH regulations. Heldon Community Council – Objection. Strongly opposes the proposed sand and gravel quarry and ready-mix concrete plant on the basis that it poses serious risks to health, environment, and local amenity. Considers the development conflicts with multiple policies in NPF4 and the Moray Local Development Plan 2020 and is unjustifiably located within a Countryside Around Town (CAT) zone, which is intended to protect rural character and prevent urban sprawl. The proposal undermines climate and sustainability goals by increasing emissions, discouraging recycling, and promoting virgin aggregates despite an existing surplus of local quarries. It ignores government initiatives for a zero-waste economy and green alternatives to concrete. Environmental concerns include flawed biodiversity assessments, long restoration times creating an 18-year “biodiversity desert,” and potential harm to adjacent habitats and protected species. The loss of productive farmland, degradation of soil structure, and risks to nearby ancient woodlands from dust and groundwater changes are highlighted. Flooding risks are considered significant, with bunds likely to worsen runoff and unclear plans for sourcing large volumes of water for operations, raising fears of groundwater depletion and contamination. Health and safety objections focus on intrusive noise from prolonged quarry operations, flawed noise assessments, and cumulative impacts on vulnerable individuals and farm animals. Air quality risks from dust and silica exposure are deemed underestimated, with inadequate mitigation plans, no baseline monitoring, and reliance on inaccurate wind data. Independent reviews of the noise and air quality assessments have been submitted with the Community Council’s response, identifying methodological flaws and insufficient consideration of vulnerable individuals. The proximity to a high-pressure gas pipeline adds further safety concerns. The proposal is seen as damaging to local amenity and community life, threatening Moray Archery, a nationally recognised sports facility, along with local businesses and jobs. Increased heavy vehicle traffic on narrow rural roads would endanger cyclists, pedestrians, and school buses, while reducing the attractiveness of active travel routes. The development would also harm tourism by degrading scenic routes and the historic setting of Birnie Kirk, a scheduled monument of national importance. Page 42
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Also argues that the justification for the quarry is weak, relying on opaque and potentially biased mineral audit data, failing to consider alternative sites, and disregarding trends toward reduced aggregate use and increased sustainability. The proposal breaches multiple NPF4 and MLDP Policies on climate, biodiversity, natural places, soils, forestry, health, transport, tourism, and rural development, and ignores PAN 50 guidance on quarry proximity to homes. The Community Council concludes that the site is wholly unsuitable for a quarry and urges refusal to protect the community and environment from irreversible harm. Further comments received following re-consultation: Heldon Community Council (HCC) expresses concern over the short timeframe for the re-consultation process, noting that it coincided with the election of new members and limited community awareness. They confirm that original objections remain valid, as the applicant’s response introduced only minor changes and no significant new mitigations. HCC also criticised the applicant’s feedback as dismissive and aggressive, and regretted the lack of meaningful engagement. HCC welcomes Historic Environment Scotland’s observation that the proposal could affect Birnie Kirk, reinforcing community concerns about cumulative noise and impacts on the setting of this scheduled monument. Also supports Moray Council’s decision to request a Residential Visual Amenity Assessment but criticise the applicant’s report as biased and incomplete. Notes that the Council’s Landscape Advisor concluded that the assessment underestimated the sensitivity of receptors and the magnitude of change, predicting significant adverse effects on views from roads, recreational routes, and nearby homes. Bunds were considered visually intrusive, and photomontages misleading. Seasonal screening changes and lighting impacts were ignored, and the refusal to plant trees outside bunds was deemed unreasonable. Traffic and road safety remain major concerns. The applicant’s own analysis predicts 19–42 additional HGV movements daily, representing a 46–102% increase on a road already considered dangerous. HCC disputes assumptions about road widening and highlights existing verge deterioration. They support the Transportation Manager’s view that the C2E is unsuitable for HGVs and endorse the recommendation for a minimum width of 6.8 meters, along with a detailed road width investigation before any decision. Also, back proposals for CCTV to prevent quarry traffic through Thomshill. On economic and social impacts, HCC criticise the submitted Community Wealth Building Plan for ignoring negative effects on local businesses, some of which have already delayed investment due to the quarry. Promised jobs and local spending lack guarantees and appear to benefit the applicant’s own companies rather than the immediate community. Climate change and emissions were another focus. The quarry will operate nine major plant items and up to 42 HGVs daily, with no mitigation for emissions or air quality impacts in Elgin, despite all traffic passing through the town. CO₂ Page 43
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emissions from concrete production are significant, and the justification for locating the quarry in a CAT zone was based on flawed distance analysis. Carbon offset claims were unsubstantiated, and the loss of agricultural carbon capture was ignored. Finally, HCC note new applications for other quarries, which undermine the need for Dykeside, and cite recent Reporter comments on the Longmorn Biomass Plant, which reaffirm the restrictive nature of CAT policy for all development types. HCC urges Moray Council to explore alternative reserves outside CAT zones and maintains their strong opposition to the proposal. Elgin Community Council – Objection. Elgin Community Council (ECC) objects to the proposed sand and gravel quarry and ready-mix concrete plant at Dykeside Farm, citing inadequate public engagement and significant potential impacts on Elgin and surrounding communities. While acknowledging the extensive documentation provided with the application, ECC believes the applicant’s engagement with the public has been minimal compared to the proactive efforts of local residents, who have explained the likely impacts in a clear and credible manner. ECC considers that the proposal represents a departure from the Local Development Plan (LDP 2020) because the site is not listed as a protected mineral reserve. Policy DP10 requires Moray to maintain a 10-year supply of sand and aggregates, and new extraction sites should only be considered when reserves fall below that threshold. The applicant’s claim of a deficit is based on interpolated data from a confidential report, which ECC considers questionable, particularly as it does not account for the impact of the Covid pandemic on reserve drawdown. ECC warns that approving this application could prevent future competing proposals under DP10, reducing competition and creating an unintended monopoly. They suggest rejecting the application and inviting bids from multiple developers to ensure fair assessment and compliance with LDP objectives. Traffic is a major concern, as all quarry-related movements, including cement deliveries, aggregates, and concrete, would route through Elgin, adding congestion at peak times and impacting an active travel route used by schoolchildren. ECC also raises serious doubts about water supply, noting that large volumes will be needed for concrete production, aggregate washing, and dust suppression. Also fear this could compromise Elgin’s mains supply, especially during drought, and point out that Scottish Water’s response does not guarantee connection or confirm availability of sufficient water. The ECC highlights risks to local amenity and recreation. The area is popular for walking, jogging, and cycling, and increased traffic would make it less safe and attractive. Moray Archery, one of only three outdoor ranges in Scotland, could be severely affected by noise, threatening its viability and the tourism benefits it brings. ECC also stresses the potential noise and visual impact on Birnie Kirk, a scheduled monument with historic links to Elgin Cathedral, arguing that its setting should be protected. Page 44
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In conclusion, ECC recommends refusal of the application, citing policy non- compliance, environmental risks, and negative impacts on community health, heritage, and recreation. Believes this reflects the popular view in Elgin and urge Moray Council to prioritise the protection of local amenity and sustainable development. Further comments received following re-consultation: ECC objects to the quarry proposal for previously stated reasons and additionally due to the timing of the application, which coincides with Community Council elections. This timing appears to limit input from Community Councils. ECC requests an extension to allow Elgin Community Council to reform post-election and properly review the consultation. Given the complexity of the application, ECC require three months, with an extension until March 2026 if our inaugural meeting occurs in November. If an election is necessary due to oversubscription, further time may be needed, and we will advise accordingly. 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). This application has attracted representations from 843 individuals, 837 of which are objections, 1 neutral and 5 in support. A list of names and addresses of persons/parties that submitted representations is in Appendix 1. 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 COMMENTS Impact on Amenity Noise and Vibration • Noise pollution will rise dramatically from quarry operations, concrete plant, and increased traffic; will disturb residents and reduce quality of life; noise impacts will occur 6 days a week. Excavation noise and heavy truck traffic will disrupt the area. • Quarry noise would significantly harm mental well-being and quality of life. • Construction works and passing lorries cause excessive noise and make houses shake. Page 45
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• Quarry site is too close to existing residential properties; site is only 60m from residential properties, causing noise, vibration, and disruption six days a week. • Application site is very close proximity (21m) to neighbouring housing; continuous quarry noise will affect night shift workers who require to sleep during normal working day; statements and conclusions within NIA regarding no significant noise impact disputed. • Already affected by noise and dust from Cloddach Quarry; adding another quarry and concrete mixing plant will worsen living conditions; combined operations will significantly increase noise. • Concerns about cumulative industrial developments (biomass plant and proposed quarry); increased noise, lighting, dust, chemical pollution, and traffic will harm rural quality of life. • Sand and gravel quarrying generates noise well above background levels; proximity to homes will harm local amenity despite mitigation. • Lack of detail on whether blasting will occur; current experience with Fogwatt quarry shows blasts can be powerful and shocking, especially without prior warning. • Noise assessment lacks credibility - predicts <45db at 60–80m despite multiple 100db sources and unobstructed terrain. No evidence of PAN 50- compliant surveys at sensitive properties; no monitoring plan provided. Construction phase (up to 26 weeks) will exceed mandated noise limits (45db normal, 70db exceptional for 8 weeks). Accuracy of noise impact assessment survey readings questioned; Survey period too short to provide an accurate guide to average background noise levels; readings taken during noisy bird song. Noise impacts cannot be mitigated and breach NPF4 Policy 33 and PAN 50 standards. • Vulnerable residents with health conditions will be adversely affected; proposal ignores this. • Proposed development will not be able to meet requirements of BS 8233:2014 Guidance on sound insulation and noise reduction for buildings. • Noise impact assessment does not mention stone crushing mentioned at publicity event, noise from this is unlikely to be unbearable to contributors’ property 100 metres away from site. • Soil and overburden handling and other works in connection with landscaping not to exceed 70 dB will be unacceptable and unbearable. • Disagrees with applicants’ assertion that only 45dB will be heard at neighbouring properties when quarry activity can be heard 2 km away on a calm day and other statements/findings contained within noise impact assessment. • No independent confirmation that increased HGV traffic will not cause vibrations or structural damage to nearby properties. • No consideration given in the submitted quarry NIA to cumulative noise impact from approved Diageo Biomass distillery hammer shed (24/00742/APP). • Concerns regarding accuracy and completeness of applicant’s NIA with no reliable evidence to show that proposed mitigation measures will eliminate noise nuisance. Page 46
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Comments (PO): • The Environmental Health Section has assessed the application and supporting information and has raised no objection subject to conditions to mitigate impacts, prevent nuisance and protect residential amenity. These relate to controlled operational hours, noise limits during normal operations and soil/overburden handling (max 8 weeks/year), use of white noise reversing alarms to all vehicles, submission / maintenance of a Noise Monitoring Programme and site lighting details throughout development, and for the operator to monitor noise after complaints and apply mitigation if limits are breached. • As part of its assessment of the proposal, the Environmental Health Section has followed national guidance and lower threshold daytime limits in line with PAN 50 Annex A when recommending conditions. • As the proposal involves the introduction of a new quarry within a rural area with existing nearby housing, conditions are recommended requiring an 08:00 start time and Saturday operations restricted to a half day. • On vibration and potential structural damage to property, existing HGV’s currently use the road, and these are not likely to be near any building damage thresholds. • Night-time standards cannot be applied during the day for night-shift workers, as this is not considered practical. • On the concerns that residents already experience noise and dust from Cloddach Quarry and adding another will worsen conditions, the Environmental Health Section has recommended conditions placing responsibility on the operator to manage and monitor impacts in line with national standards. It is also satisfied that a cumulative noise assessment been undertaken considering Cloddach which demonstrates that no significant cumulative noise impacts will occur. • The biomass plant at Thomshill is sufficiently remote from the application site to not give rise to unacceptable cumulative impacts and is subject to its own Noise Impact Assessment and planning conditions which control noise levels in the area at Thomshill. • No blasting is proposed which is confirmed in the application. • The Environmental Health Section is content that a satisfactory PAN 50 Annex A assessment has been undertaken and accepts the noise predictions/findings within the Noise Impact Assessment. It notes that levels are typical of the area and overall low background has been established that promotes the need for a lower noise limit than typically 50 or 55 dB(A). As already outlined, a range of conditions are recommended to control noise to within the lower national limits for quarries and a monitoring and complaint trigger set. • External levels of up to 45 dBA will meet with internal standards in 8233 for living apartments. • All plant has been considered in noise predictions and noise limits applied in conditions. • On the concerns regarding construction works, this will be in phases spread over several years – limited exceedances of up to 8 weeks for bund Page 47
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formation is noise limited, and time limited by condition, as recommended by the Environmental Health Section. • In response to the concerns disputing the applicants’ assertion that only 45dB(A) will be heard at neighbouring properties when quarry activity can be heard 2 km away, the Environmental Health Section has clarified that the issue is not “audibility”, but a deemed acceptable level of noise within national standards. At 45 dB(A) activity may be audible outside but not deemed of nuisance level. • On the concerns regarding accuracy and completeness of the applicant’s NIA with no reliable evidence to show that proposed mitigation measures will eliminate noise nuisance, Vibrock are independent noise and vibration consultants and have carried out several NIAs in this area over the years. As already outlined, noise conditions will be applied and limits etc. to prevent nuisance. Dust • Dust pollution poses serious health risks, including increased asthma cases in children and worsening conditions for existing sufferers. • Quarrying creates persistent airborne dust and sand, unlike short-term agricultural dust events, blown sand from stockpiles pose safety risks. • Dust from the site could travel long distances, regular dust clouds already visible during construction in Elgin South. • Site is only 540m from Thomshill and close to Castlehill and The Level, posing major health and safety risks; quarry is even closer to homes near the entrance. • Air Quality Risks: Quarrying produces dust and respirable crystalline silica, posing health risks to vulnerable groups, especially for children, the elderly and those with asthma and pre-existing conditions; wind could carry dust to Elgin and beyond; outdoor living and gardening will become hazardous. • Significant concerns about silica dust from ready-mix plant and quarry operations. Dust and silica exposure pose serious health risks (lung disease, eye/nasal irritation), especially for vulnerable groups (children, elderly, those with asthma/COPD). • Mitigation measures unlikely to be effective given close proximity to housing. • Current sand drifts already block roads during breezes; quarry will worsen this problem. • Site is highly exposed with no natural shelter, leading to excessive dust spread in windy conditions, 3 m high bunds will not stop wind-driven dust - needs expert analysis on wind flow changes. • School bus stops near site expose children to dust; increased traffic makes waiting areas unsafe; cycling and outdoor play will be impossible. • Residents will face prolonged exposure to dust for many years. • Queries how dust suppression will work at night and weekends when the quarry is not operational, how dust suppression plant will be powered and noise impacts. • No provision for asbestos risk, which can occur during sand and gravel quarrying. Page 48
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• PAN 50 states dust can affect properties up to 1km from source: severe concerns likely within 100m - exactly the case here. • Dust will adversely affect nearby neighbouring property covering solar panels, cars and clogging filters to heat recovery system and soakaway. • Application does not evidence of compliance with Control of Substances Hazardous to Health or Management of Health and Safety Regulations for public protection. • Parliamentary debate (2022) warned of health risks for residents within 1.5 km of sand quarries: supported by peer-reviewed research. • Prevailing Wind Concern; Winds predominantly from SW, W, and NW. More than 50% of affected residential properties within 500m lie downwind of the site. Open landscape increases dust dispersion risk; accuracy of wind assessment questioned. Weather data sourced from RAF Lossiemouth (11 km away) likely skewed by coastal conditions; prevailing winds in the area are typically westerly (NW–SW), not NE as claimed. • Applicant proposes wheel cleaning for site vehicles but no dust prevention measures for third-party vehicles transporting material, which are outside applicant’s control. • Quarry workers require PPE for silicosis risk, but nearby residents and road users will have no protection; applicant cannot guarantee negligible impact on surrounding properties and village. • Mineral removal renders land unsuitable for future farming use; likely to become landfill, creating further health hazards. Comments (PO): • Dust and air quality impacts associated with the proposed development have been fully assessed in the determination of this application. The Environmental Health Section has reviewed the supporting air quality assessment (and additional information) and is content with the findings / recommendations. The Section has raised no objection subject to a condition requiring implementation and maintenance of a Site Dust Management Plan; this requires the developer to prepare and maintain a comprehensive plan, as detailed in the Environmental Statement. • The submitted air quality assessment predicts negligible impacts with mitigation measures such as wet processing, bunding, and dust suppression. Dust control will follow best practice principles, focusing on daily site management and prompt remedial action. The assessment considered working methods, mitigation measures, activity duration, weather, and receptor sensitivity. With the Site Dust Management Plan implemented, dust impacts are expected to be negligible, with no significant reduction in air quality and no residual impacts identified. • On the comment relating to dust suppression and how will work at night and weekends when the quarry is not operational, supporting information confirms that fugitive dust from out of hours is considered to be of low risk, as there is no disturbance from machinery that could create the circumstances for dust emissions. The applicant also proposes the use of a binding agent for stockpiles referenced in a dynamic Dust management plan that can be reviewed and has committed to ongoing monitoring. Page 49
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• On the concerns regarding silica dust and particulate matter (PM10, PM2.5), these are addressed within the submitted Environmental Statement (pages 179-183); these also reference HSE guidance, which confirms no documented cases of silicosis among the general public, making the risk negligible beyond the site boundary. • As noted from the Environmental Statement (at page 180) local air quality is confirmed as good and the site is not in a designated Air Quality Management Area. A review of Defra mapping data shows current levels low for PM 10 and PM 2.5’s, good locally. Requests for further details and clarification on these issues from the Environmental Health Section have been adequately addressed through submission of additional information. • Based on supporting information, the air quality assessment followed Institute of Air Quality Management (IAQM) best practice guidance, using Lossiemouth meteorological data as the nearest reliable long-term source, which is standard for such assessments. The Environmental health Section following review was satisfied with this assessment methodology. • Equipment and site activities will also be subject to SEPA air quality regulation, while Environmental Health enforces nuisance legislation and applies planning conditions to safeguard amenity. • As noted from supporting information occupational dust exposure at the quarry would be regulated under COSHH (Control of Substances Hazardous to Health) Regulations and monitored against HSE limits. These limits only apply to workers operating close to dust-generating activities. Off-site dust levels are expected to be typically far lower due to dispersion over distance, around 100 times below the HSE limits, so if on-site standards are maintained, the risk to nearby residents is negligible. • The applicant has also confirmed that there is no requirement for PPE to be worn by quarry staff. • The submitted restoration plans detail that the majority of the site will return to agricultural use and the applicant has confirmed that the site will not be used for landfill. Road Safety and Access • C2E road is narrow with hazardous bends; increased HGV traffic will heighten risk of collisions and accidents. • No footpaths for pedestrians; road heavily used by walkers, runners and cyclists, making it unsafe for vulnerable users. • Previous fatality involving pedestrian and HGV; proposed road improvements offer no protection for pedestrians or cyclists. • Routing concerns - Transport Statement suggests primary HGV access from the north but also mentions possible southern route through Thomshill and narrower roads without clear restrictions. • Risk of significant and unacceptable HGV traffic through village and unsuitable roads. • Traffic volume underestimated; Analysis excludes third-party “self-collect” traffic; estimates suggest an additional 40 visits per day (80 movements), significantly increasing congestion and risk. Page 50
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• Road between Thomshill and Elgin is a narrow C-class road, unsuitable for increased heavy traffic; roads are narrow, unsafe, and already congested with distillery traffic. • Roads lack footpaths and will require extra maintenance heavy vehicles will accelerate road surface degradation, increasing potholes. • Heavy vehicle traffic poses safety risks to walkers, runners, cyclists, horse riders, school buses and other vulnerable road users; additional heavy goods vehicles will significantly increase danger for all road users; no mitigation proposed to address safety impacts. • Road already carries high HGV volumes due to Diageo operations at Glenlossie Distillery; additional quarry traffic will worsen safety risks. • Existing quarries already generate significant heavy traffic; no capacity for additional industrial development. • Proposed entrance lies on Elgin to Thomshill route already used by large vehicles; narrow sections barely accommodate two cars. Increased HGV traffic will endanger walkers, cyclists, horse riders, and school buses. • Flooding during heavy rain worsens risks; increased traffic will destabilize verges; road prone to flooding near proposed access point; poor condition worsens risk. • Increased traffic makes bus stop waiting areas unsafe. • Increased quarry traffic will pass through heavily populated areas of New Elgin, creating major safety risks and dangers to children walking to school; children need to cross the road to reach school, creating a major safety concern. • Busy roads and removal of crossing patrols make walking to school unsafe; added quarry traffic worsens risks. • Wind-blown sand will reduce visibility and create dangerous road conditions locally and in Elgin. • Queuing at quarry entrance will increase congestion and accident risk. • Fatality in 2022 involving an HGV highlights existing danger; proposal ignores this. • Unsafe bridges remain unrepaired, forcing all traffic - including walkers, cyclists, families, and horses - onto unsuitable roads. • Proposal introduces a large-scale operation in a rural area with access via C2E road, mostly single track. • Increased traffic from Springfield housing development and Elgin South Masterplan (2,500 homes + new school); currently 8 residential street junctions off Birnie Road. • Heavy transport through Elgin’s residential areas will reduce quality of life; increased road danger for schoolchildren crossing the main access road to reach school. • Increased heavy traffic on Birnie Road will endanger walkers, including children accessing golf club, on an already congested route used by housing, distillery, and farming vehicles. Adding quarry traffic will significantly raise accident risk. • Proposed road widening minimal and insufficient; many sections remain below safe width (6m or less). Blind summits and tight junctions not Page 51
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addressed; drawings outdated and do not reflect new pavements and developments. • Heavy vehicles will accelerate road degradation and increase maintenance costs. • Leiths state minimal HGVs on site, but third-party transport (builders, suppliers, ready-mix customers) will add traffic on the local ‘C’ road. • Grass verge damage shows frequent near misses; accident records don’t capture near misses or pedestrian risks; from personal experience over 3 years, twice nearly forced off the road by large vehicles; often had to step onto verges for safety while walking. • Routes include popular cycling paths, increasing danger for cyclists; being overtaken by HGVs while cycling is hazardous and can be fatal if insufficient passing space is given. • No pedestrian verge on long sections; road is popular with walkers and cyclists and designated as an active travel route under Moray Core Paths Plan. • Already heavily used by HGVs for distilleries and timber yard. Proposed widening to 6m only meets minimum for two HGVs; limited to short section near site. • Traffic Volume and Timing; Assessment assumes even distribution of HGVs, but peak movements will coincide with school runs and collection surges. • PAN 50 advises avoiding sensitive areas and narrow roads for large vehicles - proposal fails this guidance. • Despite proposed widening, safety for pedestrians, cyclists, and other road users cannot be guaranteed; risks remain high and cumulative impacts unaddressed. • Information in Transport Assessment in relation traffic movements and accidents is inaccurate. • Road already busy with HGVs; proposal will significantly increase heavy traffic. • No clear estimate of private vehicle trips; surge risk during peak times. • Road is heavily used horse riders in a well-established equestrian area; additional large quarry vehicles will significantly increase danger for riders and other users; proposed site access would cut off a main safe riding route, severing a vital link in the local equestrian network. • Proposal may conflict with future A96 Elgin bypass plans and associated housing development. Comments (PO): • The Transportation Section has assessed the application and accompanying supporting Transport Statement (and addendum) and has raised no objection, subject to conditions. These include a detailed road width investigation from the site access to Elgin Golf Club, with any required widening to 6 metres; provision of visibility splays; adoptable-standard site access surfacing with swept paths; and laying 50 metres of hot rolled asphalt along the public road at the access point. Additional requirements include a Construction Traffic Management Plan, drainage and vehicle cleaning measures to prevent discharge onto public roads, and details of Page 52
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bund and access drainage. An Operational Traffic Management Plan will manage HGV routing, with CCTV monitoring if necessary. Further conditions cover restrictions on excavations and planting near the public road, provision of car and cycle parking, and implementation of a road sweeper to prevent debris accumulation and verge creep. • Detailed comments from the Transportation Section on the various transport matters are included within Consultation Section of the report. • As noted from the submitted Transport Statement and consultation response comments from the Transportation Section, the surrounding road network is considered to be capable of accommodating additional traffic generated by the proposed development without adverse impacts on road safety. • The submitted supporting Transport Statement and addendum, confirms that quarry traffic is predicted to be relatively low, averaging one HGV arrival and departure per hour, rising to two each way on busier days. Private sales will generate negligible additional trips. Existing HGV flows on the C2E road are modest, and the network can accommodate the increase without significant impact. Swept path analysis and extended visibility splays will ensure safe access, with all quarry traffic routed north to Elgin. Minor road widening will be achieved by clearing verge overgrowth, with further widening proposed where necessary. Surface water will be managed within the site using settlement ponds and catch ditches to prevent runoff. Overall, the assessment concludes that the road network and access arrangements meet safety and transportation requirements. • On the issue of the future A96 dualling project, Transport Scotland following consultation has raised no objection to the proposal; it has however recommended that the applicant make themselves aware of the proposed alignment and current status of, and associated alterations to access arrangements that would be brought about by, the A96 Hardmuir to Fochabers Scheme which runs 1km to the north of the proposal. Impact on Natural Environment • The development may significantly impact local wildlife, including protected species such as red squirrels, badgers, foxes and deer. • There is a risk of damage to the surrounding landscape and natural habitats. • Surface runoff and dust will harm local wildlife and watercourses. • Runoff may carry pollutants (sediment, chemicals, heavy metals) into water sources, harming aquatic life and soil quality. • Local wildlife already suffers from road fatalities; added traffic will worsen this impact. • Project will fragment habitats, disrupt migration, and stress wildlife, reducing breeding success and survival rates. • Quarry threatens wildlife habitats and disrupts ecosystems, will destroy 13.59 hectares of valuable natural land. • Increased noise, traffic, and dust will be detrimental to the environment in the area. • Quarries are highly disruptive to local ecosystems, driving away wildlife and damaging habitats. Mitigation measures cannot compensate for habitat Page 53
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loss; habitats for birds, mammals, amphibians, and invertebrates will be destroyed; Wildlife corridors severed; nesting and breeding sites disrupted. • Area is rich in wildlife: deer, red squirrels, geese, seabirds, owls, badgers, foxes, and bats (pipistrelle). • Proposal ignores impact of noise and artificial light on sensitive species, especially bats. • Quarrying will eliminate established ecosystems and natural habitats, causing irreversible damage to local biodiversity. Comments (PO): • An Ecological Impact Assessment (EcIA) has been undertaken for the proposed development, supported by a Phase 1 Habitat Survey and species- specific assessments. This confirms that the site, currently used for pig farming, consists mainly of improved grassland with limited ecological value, with hedgerows along the site boundaries providing habitat, supporting birds, bats, and badgers. • The EcIA sets out that no main badger setts were found and recommends mitigation such as pre-commencement surveys and licensing if required. Further recommendations include hedgerow management to enhance habitat, vegetation clearance timed outside the bird breeding season, and lighting directed away to protect bats. No amphibian or reptile habitat was identified, and other mammals are unlikely to be affected. • In light of the findings of the EcIA, and subject to conditions addressing mitigation the proposal is not considered to adversely affect protected species, in line with NPF4 and MLDP policy. Landscape and Visual Impact • The development will be visually intrusive and harmful to the surrounding landscape. • The quarry site is inappropriate for a wide-open farming area, even with hedging. • Numerous existing quarries nearby - adding another erodes rural character and sets a negative precedent. • Significant impact on the surrounding area and landscape from the proposed development. • Loss of rural character; development will irreversibly alter the landscape and diminish residents’ quality of life. • Located in open countryside, highly visible and not screened like other quarries. • The quarry will be an eyesore on the landscape; will destroy natural scenery, wildlife habitats, and ecological integrity. • The quarry would be an unnecessary blight on Elgin’s surrounding green belt and destroy a significant area of protected greenbelt. • Proposed site lies in protected countryside; large-scale industrial activity would cause irreversible damage to ecosystems and scenery. • Quarry reduces the rural gap between Thomshill and Elgin, harming the area's character. Page 54
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• Plant equipment up to 6m high will remain visible above bunds; view line images are misleading. • Residents will endure visual intrusion for at least 17 years in a flat, open landscape. • Quarry and 3m bund will severely alter flat landscape and harm rural character. • Area is supposed to be a protected countryside zone, yet industrial activity is expanding. • Irreversible damage to natural landscapes, loss of scenic countryside character; area will never return to its original state even after restoration. • Proposed 13.8m silos will dominate landscape despite 3m bunds, creating an unacceptable visual intrusion. • Site is exposed and cannot be effectively screened; proposed planting will not disguise the quarry during its operational life; proposed trees and landscaping will take many years to mature before offering any reduction in visual impact. • Visual and long-term impact, site restoration planned after 17.5 years, leaving an unsightly crater for decades. • Development will harm the scenic character of the area, contrary to Moray Council’s Countryside Around Town (CAT) policy and Local Plan. • Unlike other quarries that are screened by mature trees this quality will be visible over a large area and will be a scar on the landscape. • Fully exposed location with no natural cover will worsen dust spread and visual intrusion. • Trees to the north may be harvested within a few years, making the site clearly visible from large areas of Elgin and beyond (over 6 km). • Transformation of rural character of site into an industrial one within the Elgin CAT would be unacceptable unless such development is absolutely essential; sand and gravel deposits plentiful in Moray. • Screening on the east side would take longer than 5 years to mature given prevailing windy conditions. • Bunds will be blots on landscape; contributor cites another planning case where Reporter stated that ‘bunds themselves would be intrusive features in open attractive countryside’ and ‘would be predominant features from public vantage points because of their siting, length and height’. Comments (PO): • This proposal has been subject to evaluation by the Council’s appointed landscape adviser, who has reviewed the submitted Landscape and Visual Impact Assessment (and further supporting information) that accompanied the application. The appraisal identifies significant adverse landscape and visual impacts on the rural character of the area, which lies within the Elgin Countryside Around Towns designation, as well as on the visual amenity of nearby residential properties and recreational users. • These comments and concerns raised are largely shared by officers and have been taken on board in the assessment of this application. • The introduction of extensive earth bunds and stockpiles would create prominent, artificial landforms that appear incongruous within the Page 55
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established rural setting. Quarry infrastructure and excavation activities will remain visible throughout the operational period, and while additional hedgerow and tree planting is proposed, this is considered insufficient to provide effective screening. • Any softening of views through planting is expected to take at least five years, and likely longer, to achieve, which is highlighted in the representations. Impacts on Water Environment, Flood Risk and Drainage • Quarry runoff may introduce sediment, chemicals, and heavy metals into local watercourses, harming aquatic life and private water supplies. • Risk of fuel oil spillage during on-site refuelling, causing permanent ground contamination. • Quarry floor only 0.5 m above water table; no clear plan to prevent leaching of contaminants into groundwater, chemical flocculants used for dust suppression could leach into water table. • Proposed borehole raises concerns about impacts on existing public and private water supplies and woodland hydrology. • Surface water drainage plan lacks evidence of compliance with Moray Council Flood Risk and Drainage Impact Guidance. • No evidence drainage system can manage high-intensity rainfall or maintain natural flow paths, increasing off-site flood risk. • Quarrying will remove natural soakaways; bunds may channel water onto adjacent fields and roads, worsening flood impacts. • Extraction will lower water table, causing drought stress to tree crops in The Level Woodland. • Large volumes of water required for dust suppression and concrete production; no clear source or disposal plan provided. • Silt ponds may become pollution repositories and may be inadequate during dry summers. • No credible plan for maintaining water supply or managing excess water during quarry operations. Comments (PO): • Following a review of the submitted information and additional details addressing drainage and flood risk queries, the Flood Risk Management team is content with the proposed drainage arrangements and has raised no objection to the application on flood risk grounds. • Chapter 6 of the Environmental Review confirms the quarry will operate above the water table, avoiding direct groundwater interaction; this is based on site investigations and borehole survey data. A small area is prone to surface water flooding, but this is minor and manageable on-site. Sustainable Urban Drainage Systems (SUDS) and settlement ponds will control runoff, with no discharge from the site. Flood risk to people and property is negligible, and water quality will not be adversely affected. No groundwater-dependent ecosystems or peat were identified. • Operational water will be sourced from surface runoff and a borehole, with recycling via settlement ponds. Page 56
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• Hydrological assessments confirm sustainable abstraction without affecting nearby water bodies or private supplies. SEPA requires two authorisations under by Environmental Authorisations (Scotland) Regulations (EASR): registration for borehole construction and a permit for abstraction and has provided regulatory advice following consultation on the application. • On the point that the application lacks sufficient information to show that the drainage system can manage high-intensity rainfall or maintain natural flow paths, the Flood Risk Management (FRM) Section has confirmed that this is typically required only where adjacent properties are at risk, which is not the case here. FRM have further confirmed that the proposal will not result in any significant change. • The Private Water Section following consultation has also raised no objection, subject to a Water Management Plan covering the proposed borehole, cumulative abstraction, and the Hillhead Irrigation licence. The plan must demonstrate sustainable abstraction through hydrological investigations and outline measures for seasonal variation and water scarcity, including potential shutdowns, to safeguard private water supplies. • Subject to recommended conditions, the proposal is considered compliant with planning policy in relation to surface water and flood risk management, and protection of the water environment and water supplies. Location of Proposal and Impacts on Community • Quarry is too close to homes, new housing developments, local businesses, golf course, and recreational areas; should be located in a more suitable area away from homes and small businesses. • Proposal conflicts with Moray Council’s priorities for sustainable, resilient communities and a greener economy. • Severe negative impact on small independent outdoor businesses (e.g., Moray Archery, dog training facilities, equestrian centres) that rely on quiet rural settings. • Moray Archery Club faces potential closure, ending 11 years of development and jeopardising national-level competitions. The proposed quarry’s proximity to Moray Archery Outdoor Range will disrupt the calm environment essential for mental health and focus, compromise health benefits of outdoor shooting, and jeopardise national-level competitions, negatively impacting Scottish and British archery. Noise threatens Moray Archery Club’s viability and safety; quiet environment is essential for the sport. • Dust and disruption will harm nearby auto repair business, risking damage to high-value vehicles and loss of reputation. • Continuous noise, dust, and industrial activity will destroy rural tranquillity, impacting physical and mental health. • Visual, noise, and dust impacts will erode the sense of place valued by residents and visitors. Page 57
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Comments (PO): • The proximity of the proposed quarry to nearby housing and businesses is acknowledged. Assessment has identified potential dust and noise impacts requiring mitigation, which would be secured by planning conditions recommended by Environmental Health. • As already outlined, with the Site Dust Management Plan in place, dust impacts are expected to be negligible, with no significant effect on local air quality and no residual impacts identified. • Similarly, with the control measures set out in the EIAR and compliance with Environmental Health’s recommended conditions (including noise limits and monitoring), the proposal is anticipated to operate within acceptable limits to protect amenity. Historic Environment • Quarry lies within 500m of Birnie Kirk, Scotland’s oldest continually used church; the development will harm its setting and cultural significance. • Combined impact with existing quarries would surround the Kirk, creating cumulative adverse effects on its historic environment. • Noise from Cloddach Quarry is already audible at the Kirk; adding Dykeside Quarry will further erode its peaceful character. • Quarry will degrade the scenic and historic landscape that attracts visitors and supports cultural tourism. • Permanent damage expected to archaeological and historic features on- site, including roundhouse remains and silver hoard. • No clear mitigation strategy for safeguarding nationally important heritage assets. Comments (PO): • This application has been subject to consultation with Historic Environment Scotland, which has confirmed that it has no comments to make, although it has noted that the proposals have the potential to affect Birnie Parish Kirk and associated heritage assets (Scheduled Monument SM2781 and Listed Building LB2294). • As noted from supporting information and on-site observations, the proposed development is not intervisible with Birnie Kirk due to intervening landform and whilst some quarrying activity may be audible from the Kirk, it is considered that the proposal would not adversely impact the setting of this historic asset. • The regional archaeologist has recommended a condition requiring archaeological mitigation via a condition requiring a Written Scheme of Investigation be undertaken. Policy Conflicts • MLDP Policy DP10 Minerals: Insufficient evidence that this site is necessary or the only option; fails to mitigate impacts; proposal is for a new 13.59- hectare greenfield site, not an extension or reopening of an existing quarry. • Policy DP10 states new mineral sites only permitted if existing reserves exhausted or less than 10-year supply remains - this does not apply (Lossie Page 58
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Forest quarry extended in 2022 for 15 years). Council presumes against irreversible development on prime agricultural land (Class 1, 2, 3.1) unless for settlement expansion - proposal is for a quarry, not settlement. • DP10 (mineral extraction) does not override EP4; policies conflict and require interpretation, not automatic approval. • Claim of site-specific necessity is weak - Moray has extensive sand and gravel deposits in less sensitive areas (NatureScot and BGS confirm). • Policy EP4 Countryside Around Town: Proposal fails to meet CAT policy requirements; quarry use is not identified as suitable under Countryside Around Town policy in the Moray Local Development Plan, the CAT zone under EP4 is intended to prevent urban sprawl and protect rural character – this proposed industrial development conflicts with EP4. • Policy DP1 Development Principles: Insufficient mitigation for impacts on road safety, environment, noise, air quality, landscape, flood risk, archaeology, and habitats. • Policy DP4 Rural Housing: Area is a Pressurised and Sensitive Area; if housing is restricted, a quarry should not be permitted. • NPF4 Policy 22: Flood risk and water environment protection not adequately addressed. • Proposal does not meet requirements of NPF4 Policy 23 and 33(d); buffer zone from residential properties is unclear; several homes are closer than Thomshill. • NPF4 Policy 33 supports extraction only if no significant adverse impacts - proposal fails this test. • Minerals Policy requires consistency with DP1, which this proposal fails— development would harm countryside character and sense of place. • Development requires consideration as policy states proposals immediately outwith settlement boundaries will not be supported unless designated as a LONG-term development site. • NPF4 Policy 8 Green belt requires justification for why alternative sites cannot be used; geology does not support exclusivity. Comments (PO): • The majority of policy comments raised are noted and addressed within the observation section below, under the various topic headings. • In term of impact, as outlined below it is considered that the proposal will give rise to unacceptable significant adverse landscape and visual impacts within the Elgin Countryside Around Towns (CAT) Designation, contrary to NPF4 Policy 33 and MLDP Policies EP4, DP10 and DP1. • While it is noted that other impacts in relation to noise, dust, transport and water can be mitigated subject to conditions as recommended by technical consultees this does not override the abovementioned concerns in relation to landscape and visual impacts. • Policy DP10 Minerals does not require the submission of supporting evidence that this site is necessary or the only option for a quarry proposal. • On the claim that site-specific necessity is weak and that are extensive sand and gravel deposits in less sensitive areas, while noted, the application Page 59
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requires to be assessed on its merits, on the basis of the information submitted. • The comments citing a departure to policy EP4 Countryside Around Town on the grounds that the proposal is not identified as a suitable development within the CAT and fails to meet CAT policy requirements which is intended to prevent urban sprawl and protect rural character is acknowledged. • The point that under policy DP4 Rural Housing for Pressurised and Sensitive Areas, if housing is restricted, a quarry should not be permitted, carries little weight as the two development types are not the same and subject to different policy requirements. • The site does not occupy land that is designated prime agricultural land. • NPF4 Policy 8 is not applicable to the current application as there is no designated green belt within Moray. Community Awareness & Transparency • Lack of communication with residents of the new Elgin South estate, despite previous requests. • Developer has not provided evidence that this is the only suitable site; other quarries exist in Moray, no clear investigation of alternative locations with less community impact. • Initial pre-application submitted Nov 2023; consultations held Feb–Mar 2024. • Current application differs significantly (shape, size, duration, noise details) from what was originally discussed; community should have been re- engaged through a new pre-application process. Comments (PO): • The application is accompanied by a Pre-Application Consultation (PAC) report, which outlines the statutory consultation that the applicant undertook with the local community in relation to the application. This satisfies PAC requirements. • There is no requirement in development plan policy for applicants to have to investigate alternative quarry locations, in support of applications for new quarry sites. • The current application is sufficiently similar to the proposal previously subject to formal pre-application consultation and does not require a new process. As outlined in the observations section, the proposal has been amended in response to public feedback. Changes included relocating the processing and concrete batching plants further from nearby homes, redesigning the site access to improve safety and visibility, and reducing the extraction period from 22.5 to 17 years following groundwater monitoring. Restoration plans have also been updated to incorporate an ephemeral wetland and woodland planting to enhance biodiversity. Absence of Environmental Impact Assessment (EIA) • No EIA conducted despite potential major impacts on noise and dust levels, surface and underground water, and local wildlife and habitats. Page 60
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• Request for EIA to fully assess implications beyond current application detail. Comments (PO): • As set out in planning history, the proposed development has been previously screened under the EIA regulations; assessment confirmed that the proposal was not likely to result in significant environmental effects and not requiring to be subject to EIA procedures. The application contains sufficient supporting information to inform assessment of environmental impacts from the development and any required mitigation. Uncertain Need for Additional Aggregates • Application claims Moray has only 8 years of mineral supply vs. 10-year MLDP requirement, but calculations are unpublished despite FOI requests, raising transparency concerns. • Figures contradict Scottish Government’s 2019 survey showing 43 years of reserves in the Central East Region and high export rates. Previous appeal (PPA-110-2436) shows environmental factors can outweigh reserve policy. • Assessment overlooks government commitments to reduce aggregate use through levies and recycling and does not consider exports or recent quarry approval at Craig, Huntly. • Lack of robust evidence for need makes placing a quarry in a protected Countryside Around Town zone unjustifiable. • Existing quarries at Gedloch and Cloddach already serve the area; cumulative impact of multiple sites must be assessed. Comments (PO): • The information referred to is commercially sensitive hence the reason for it not being published. As noted in the observations section below, the Moray Minerals Audit 2023 has identified that there is currently insufficient landbank for sand and gravel reserves in Moray. • On the second point, the ‘Central East Region’ referred to covers several local authority areas in the central belt specifically on the eastern side of Scotland. This does not include Moray which sits wihtin the ‘North Region’. • From supporting information, recycling cannot fully replace virgin aggregates due to limited waste availability and technical constraints in quarrying. • Cumulative impacts associated with other quarries in the area have been assessed in this case in the determination of this application and are discussed further within the observation section below. Impact on Climate Change • Cement production is among the highest carbon-emitting industries globally. • Concrete production contributes heavily to CO emissions. Undermines Scotland's net-zero policies. • Council’s Local Heat & Energy Efficiency Strategy 2024 aims for sustainable, climate-resilient communities - quarrying is environmentally damaging. Page 61
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• Exhaust Emissions: Multiple diesel-powered vehicles and machinery contradict UK Net Zero goals. Comments (PO): • A Climate Change Assessment Report has been submitted with the application which demonstrates compliance with NPF4 Policy 2 and associated Moray Planning Policy Guidance on Carbon. • This sets out that the site’s central location reduces haulage distances of aggregate and ready-mix concrete compared to alternatives and predicts a carbon saving compared to sourcing from other quarries in Elgin. Carbon offsetting through planting and restoration will mitigate temporary loss of agricultural carbon capture, and cement emissions are accounted for at the manufacturing stage. Future mitigation also includes using the most efficient plant and vehicles and exploring alternative energy and fuel sources. Impact on Property Value • Property values will decline due to proximity to industrial activity. • Property values likely to fall; future buyers will avoid homes near a working quarry due to health and noise concerns. Comments (PO): • Impact on property value as a result of development is not a material planning consideration and as such cannot be taken into account in the determination of this application. Long-Term Costs • Short-term economic gain does not justify permanent environmental and cultural loss. Initial economic benefits will be outweighed by health impacts, road maintenance, accidents, and property damage from blown sand. • In return for all this disruption the quarry company are offering just 4 new jobs. • Negative impact on holiday experience for visitors staying locally; loss of tourism revenue as visitors may choose alternative destinations. Comments (PO): • These comments are noted. Economic gain from the development has been weighed against the impacts from the development, which are discussed below within the observation section of this report. • Any perceived impact on holiday experience for visitors to the area as a result of the proposed development would not be of sufficient weight as to warrant refusal. Community Benefits • No clarity on developer contributions or benefits for local residents if the quarry proceeds. Page 62
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Comments (PO): • The development has been the subject of a developer obligations assessment in accordance with MLDP Policy PP3 and NPF4 Policy 18, and in this instance no developer obligations have been identified. Precedent & Planning Principles • Approving this quarry sets a dangerous precedent for industrial development in Moray’s countryside, approval could lead to further quarry applications, eroding Moray’s rural identity. • Weakens planning protections and public trust in safeguarding rural areas. • Concern about future expansion beyond initial proposal. Comments (PO): • Each application is considered on its individual merits, and it does not necessarily follow that a precedent is set for further development. Applications are required to be determined against the provisions of the development plan and any other material planning considerations. • On the point of future expansion, the current planning application can only be considered. Should any further applications be submitted, these would need to be considered against relevant planning policy in force at that time. Restoration Agreement • No financial bond or legal commitment for site restoration; must be secured before approval. Comments (PO): • As outlined in supporting information, the applicant is a member of the Mineral Products Association’s restoration guarantee scheme which provides a financial guarantee mechanism which Councils can draw upon should a member become insolvent and default on their restoration obligations. Had the application been recommended for approval a condition would have been attached requiring submission of evidence of these details along and review arrangements. Lack of neighbour notification • Neighbouring property was not formally notified of application. Comments (PO): • There are no notifiable properties within 20 metres from the redline boundary of the site requiring neighbour notification letters. Anti-Competitive Concern • Approval could reduce competition under Policy DP10, as future applications by other operators may be blocked once reserves exceed the 10-year requirement. Page 63
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Comments (PO): • This issue is not a planning matter and as such cannot be taken into consideration in the determination of this application. Additional comments – revised / additional information • Revised plans do not address previous objections. • The updated proposal increases expected traffic to the site, adding pressure to an already overused and hazardous road. • Recent housing developments by Springfield in south Elgin have led to more pedestrians and cyclists using this road, heightening safety risks. • Additional HGV and small vehicle traffic significantly raises the likelihood of accidents; Volume of HGV traffic on Elgin to Birnie Road could potentially double taking account of HGV traffic from Springfield factory at The Level and others. • Notes that supporting revised transport information states that average daily HGV movements to and from Elgin is 41 per day, and that the quarry could add between 19 and 42 extra HGV movements per day, doubling the number of HGVs on the road at present. No mention of numbers of private vehicles or concrete plant related traffic. • Proposal to scrape verges is inadequate for safety improvements, road is already busy and dangerous for all users. • Applicant’s assurance that no HGV traffic will turn right towards Thomshill is not enforceable; notes that applicant resisted Moray Council Transportation’s request for a CCTV camera to monitor traffic. • Springfield housing developments have significantly increased traffic volumes. • More families in the area mean higher numbers of pedestrians and cyclists at risk. • Developer has not addressed objections from local residents with strongly held views. Developer has paid insufficient attention to since they receptors in relation to dust and noise i.e. those with underlying health issues such as asthma or other breathing issues or we will have difficulty with continuous noise such is autism. • As stated in original objection, although this is a rural location there are approximately 200 residents living within 800 metres of the site, with a number of those having underlying health issues. • Questions nuisance element of dust migration which has had little coverage in supporting information but would be a serious issue for adjacent properties to the SE living directly downwind. • Increased traffic from quarry operations remains unmitigated, concerns about road safety due to higher vehicle movement. • Existing farm-related dust occurs occasionally and is tolerable; quarry operations would cause persistent dust issues (daily, long-term), impacting garden use and outdoor living. Fear of future extension prolonging these impacts. • Disagrees with applicants’ Landscape and Visual Assessment, as quarry will be visible from neighbouring properties, does not consider visualisations to be a true representation, excavated sand will be yellow, notes Moray Page 64
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Council’s Landscape Adviser considers that significant adverse effects could arise when viewed form adjacent housing. • Agrees with Moray Council’s Landscape Adviser’s report that proposal will cause significant adverse effects on the rural character of the site and adjacent open nearby ground. • No confidence in Community Wealth Building Plan that the development will have any meaningful benefit for local communities. • Insufficient information provided regarding lighting. • Still strongly object to this industrial development within the Elgin CAT and on a flat windswept open filed which is not shielded from view, like most quarries in Moray with woodland around them. Comments (PO): • These comments are noted and have been considered as part of the determination of this application. The points raised are addressed within the observation or representations sections of this report, under their related topic headings. SUPPORT COMMENTS • Believes the development will benefit Moray’s economy and should be welcomed. • Opponents overlook modern equipment and safeguards that mitigate dust, noise, flooding, and traffic concerns. • Berms/embankments and tree cover will reduce dust and noise; similar measures worked at Cloddach quarry. • Current farmland already causes dust during ploughing; claims of severe dust impact are exaggerated. • Post-restoration, the site will be landscaped and improved for wildlife. • Flooding concerns are overstated; existing drainage and soak-away manage surface water effectively. • Criticism about pig farming relocation is inconsistent with previous objections to pig farms nearby. • Roads are adequate for quarry traffic; issues arise from poor driving habits, not road width; traffic will likely use main roads, not village routes. • Overall, proposal meets regulations and safeguards; no major issues for residents. • Protective embankments will deflect sound upward, reducing impact on nearby homes. • Modern quarry design and machinery keep noise within regulated limits. • Water spraying (legally required) minimizes airborne dust. • Strict regulations ensure pollution control and worker safety (e.g., PPE for silica dust). • Lower dust levels mean negligible health risk for residents. • Elgin–Thomshill road already accommodates large vehicles without issues. • 18 extra lorries/day = fewer than 2 per hour; minimal impact on traffic and road wear. • Rural roads already handle tractors and heavy vehicles regularly. Page 65
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• Moray Archery Club - Quarry hours (7 am–6 pm) do not overlap with club sessions (evenings/weekends); club moves indoors during winter, eliminating potential conflicts. • Modern standards minimize noise, dust, and pollution. • No significant adverse effects on residents, roads, or local clubs. • Supports quarry development; objections appear overstated. Comments (PO): These points are noted. APPLICANT RESPONSES The applicant has submitted the following responses to address matters raised by Heldon and Elgin Community Councils, objections from the public and the Moray Archery Club: Response to Heldon Community Council comments • The applicant considers that the development complies with national and local planning policies, noting that Moray Council has confirmed a sand and gravel landbank deficit, making the proposal necessary under Policy DP10. While acknowledging climate concerns, the applicant argues that the quarry will reduce transport emissions by supplying aggregates locally and clarified that the site will host a concrete batching plant, not cement manufacturing, which significantly lowers emissions compared to claims made in objections. They also highlight that recycling cannot fully replace virgin aggregates due to limited waste availability and technical constraints. • Air quality assessments undertaken in support of the application predict negligible impacts with mitigation measures such as wet processing, bunding, and dust suppression. Silica dust risk to the public is considered minimal, supported by Health and Safety Executive guidance. Real-time dust monitoring was deemed disproportionate, but monthly checks and visual inspections will be implemented. Noise predictions meet PAN 50 limits, and cumulative impacts with Cloddach Quarry are negligible. All plant and vehicles will use white noise reversing alarms to minimize disturbance, and the applicant asserts that Moray Archery and nearby properties will not experience significant noise impacts. • Traffic assessments show only a modest increase in HGV movements, with road upgrades and visibility improvements planned according to Moray Council specifications. The applicant considers there will be no significant effect on school routes or active travel safety. • Water supply will come from a borehole and surface runoff, ensuring no impact on mains water or groundwater levels. Flood risk has been assessed, and Moray Flood Risk Management raised no objections. • Biodiversity net gain is calculated using accepted guidance, with hedgerow and woodland planting included. Heritage concerns were addressed by confirming Birnie Kirk is not intervisible with the site and that archaeological mitigation will be secured through a Written Scheme of Investigation. Page 66
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• The proposal also includes commitments to local employment, creating six jobs with a preference for local hires, and supporting community wealth through use of Moray-based resources. • In summary, the applicant maintains that the quarry is policy-compliant, environmentally managed, and essential to meet Moray’s aggregate needs, with mitigation measures in place to minimise impacts on air quality, noise, traffic, biodiversity, and heritage. • In response to the Appendix 1 Technical Note – Air Quality Chapter Review attached to the Heldon Community Council, the applicant also confirms that the air quality assessment followed Institute of Air Quality Management (IAQM) best practice guidance, using Lossiemouth meteorological data as the nearest reliable long-term source, which is standard for such assessments. They advise that site-specific monitoring is rarely feasible and that even under worst-case wind scenarios, predicted dust impacts remain “slight adverse,” which IAQM considers not significant. Baseline conditions were assessed using Defra and Scotland’s Environment background data, as permitted by IAQM. • Concerns about Respirable Crystalline Silica (RCS) are addressed by referencing HSE guidance, which confirms no documented cases of silicosis among the general public, making the risk negligible beyond the site boundary. • The applicant also highlights inconsistencies in the Technical Note by comparing it to similar assessments, such as Temple Quarry, which used the same methodology. For monitoring, the applicant proposes monthly Frisbee gauges and adhesive strips, with results submitted to Moray Council, and argue that real-time monitoring would be disproportionate given the low risk. They emphasise that mitigation measures including wet processing, sealed cement systems, bunding, and dust suppression will ensure negligible impact, and planning conditions can secure ongoing review. To reassure the community, the applicant has offered to establish a liaison group and conduct annual planning audits, reinforcing their commitment to transparency and compliance. Response to Heldon Community Council further comments, following re- advertisement of the proposal • Applicant notes that while HCC cited limited time for re-consultation, they offered a briefing which could not be scheduled before the deadline. The applicant rejected claims that their previous response was aggressive, stating it aimed to clarify issues. • On heritage concerns, the applicant acknowledges Historic Environment Scotland’s observation of potential impact on Birnie Kirk but highlight that HES did not object and that the site is screened by topography, making visual impact unlikely. Noise and dust effects were assessed and considered minimal. • Regarding landscape, the applicant confirms that bunds will be vegetated, shaped with varied heights, and supplemented by additional hedgerow and tree planting to reduce visual intrusion. Lighting will be limited to early mornings and evenings, directed inward and downward. Page 67
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• Traffic analysis was updated: average HGV increase estimated at 37%, rising to 64% on peak days, not 102% as claimed. Overall traffic increase would be 3.3% on average and 5.8% at peak. Road widening can be achieved within existing verges without third-party land, and improvements will follow Moray Council specifications. • On economic impact, the applicant reiterates their preference to employ local staff and explained that using in-house Moray resources for road works and materials supports local employment. They also highlight their role as a major employer in the region. • Finally, the applicant has clarified that other quarry applications, such as Rosarie (hard rock) and Fairyhill (screening stage), do not resolve Moray’s sand and gravel landbank deficit, which remains below the 10-year minimum required by policy. Response to Elgin Community Council • Applicant considers that public engagement had been adequate, with two pre-application consultation events and invitations extended to Elgin Community Council, though no engagement was recorded. The applicant disputes claims that the community provided more credible information, noting that misinformation such as references to a “cement works” has fuelled unnecessary concern. • On planning compliance, the applicant argues that the proposal is not a departure from the Local Development Plan. Policy DP10 supports new mineral sites to maintain a 10-year reserve, and Moray Council has confirmed a landbank deficit. They dismiss suggestions that Covid-19 affected reserve calculations, explaining that the audit baseline was set after the pandemic. The applicant also rejects the idea of inviting multiple bids for alternative sites, citing the impracticality and high cost of environmental assessments and planning applications. • Traffic concerns were addressed by stating that all site traffic will route through Elgin, but transport assessments show no significant impact. Planned road upgrades will meet Moray Council specifications, and existing roads can safely accommodate the limited increase in vehicle movements. • Regarding water supply, the applicant explains that operational water will come from on-site runoff and a borehole, with recycling through washing ponds. This approach ensures no impact on mains water or Elgin’s supply, with potable water drawn only for staff use. Moray Council Environmental Health has reviewed the water plan and raised no objections. • On amenity and recreation, the applicant argues that the slight traffic increase will not affect walkers, joggers, or cyclists, as most activity occurs during evenings and weekends when the quarry is closed. Concerns about Moray Archery are dismissed, with the applicant stating that noise impacts will be negligible and the facility can coexist with quarry operations. Similarly, Birnie Kirk is unlikely to experience visual, or dust impacts due to intervening topography, and any noise would be minimal and not affect visitor experience. • Overall, the applicant maintains that the proposal complies with planning policy, addresses environmental and amenity concerns, and will not significantly impact local recreation, heritage, or water resources. Page 68
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Response to issues raised in letters of objection from the public • The applicant highlights that the site is located more than 1.5 km from the nearest main residential areas of Elgin, with natural topography providing effective screening. • The development will involve sand and gravel extraction alongside a ready- mix concrete batching plant, not cement production, which significantly reduces environmental, and health risks compared to cement works. • Concerns about noise have been addressed by confirming that operations will be limited to daytime hours 07:00 to 18:00 on weekdays and 07:00 to 12:00 on Saturdays, with no night-time activity. Given the distance and screening measures, noise levels are expected to be negligible and will not contribute to cumulative industrial noise in the area. • Dust management is a key issue, with a comprehensive Dust Management Plan in place. The nearest homes, in the Glassgreen development, are 1.5km away, and prevailing winds combined with topography will minimise dust travel. Both nuisance dust and respirable dust impacts have been assessed as negligible, ensuring compliance with health and safety standards. • Health concerns, particularly regarding silica dust, have been addressed by clarifying that workers will not require facemasks during normal operations, indicating low dust levels. The Health and Safety Executive confirms that environmental exposure to silica dust is too low to cause silicosis among the general public, and the risk to residents, including children at school bus stops, is considered negligible. • The possibility of asbestos contamination has been dismissed, as the site’s geology consists of sand and gravel deposits that do not contain asbestos- bearing rock. The land has only ever been used for agriculture, meaning there is no industrial contamination risk. • Water quality concerns have also been resolved. There are no private water supplies within the area of influence, and all properties are on mains water. Standard mitigation measures will prevent groundwater and surface water contamination, and airborne dust will not pose a risk. Importantly, the proposal is for a ready-mix concrete plant, not cement production, further reducing hydrology concerns. • Traffic impacts are expected to be minimal, with an average of four HGV movements per hour. A transport protocol will manage routing and timing to avoid congestion and conflicts with school buses, and road improvements have been proposed to accommodate the limited increase in traffic. Recreational concerns, including safety for walkers, cyclists, and horse riders, have been addressed by demonstrating that the increase in traffic is negligible compared to current volumes. Suggestions for an off-road active travel route were noted but considered impractical due to land ownership and disproportionate to the impact. • School bus safety has been considered, with the bus stop located 160 meters from the site access. Quarry vehicles will rarely pass this point, and conditions will ensure clean access roads and prevent debris hazards. Similarly, concerns about Elgin Golf Course have been addressed: the course is 1.5 km away, and the quarry will have no significant impact on noise, dust, or traffic. Page 69
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• Other issues, such as blasting and vibration, have been clarified. No blasting is required, as extraction will be by excavator only, and vibration impacts are negligible. There will be no night-time vehicle movements. While property value is not a planning consideration, the applicant acknowledges residents’ worries but notes that similar projects have historically had negligible long- term impact on property values once operations commence. • Lighting will be used only during winter mornings and evenings, directed inward and screened by soil mounds, with no overnight lighting. Mental health concerns are recognized, and the applicant stresses that many fears are based on misconceptions; actual impacts have been assessed as negligible. • Environmental concerns regarding wildlife, livestock, and crops have been mitigated through retention of existing hedgerows and biodiversity enhancements. Dust levels will be lower than those from agricultural activities, posing no significant risk to crops or livestock. Restoration plans include returning land to agriculture, woodland, and wetland, ensuring a biodiversity net gain. Landfilling is not proposed. • Issues of smell and litter have been dismissed, as sand and gravel extraction produces no odour, and waste will be managed responsibly. • The need for the quarry is supported by Moray Council’s 2023 survey, which confirms the requirement for new reserves to maintain a 10-year supply, in line with Policy DP10. Older Scottish Government data cited by objectors refers to a different region; Moray-specific data supports the proposal. • Overall, the applicant asserts that the quarry will operate with negligible impact on local communities and the environment, supported by robust mitigation measures and a comprehensive restoration plan. Response to issues raised in letters of objection from the public following re- advertisement. • Applicant states that quarry traffic will not route through Thomshill except for local deliveries and that predicted HGV increases are far lower than claimed - around 37% on average and 64% on peak days, equating to only a 3 - 6% rise in overall traffic. Roads meet national standards, Moray Council raised no objections, and road widening can be achieved within existing verges. CCTV was not refused; protocols will manage traffic, and cameras will be installed if necessary. • On heritage concerns, the applicant asserts that Birnie Kirk is screened by topography and not visible from the site. Noise and dust assessments at a closer property show levels well below PAN 50 limits, and cumulative impacts with Cloddach Quarry are minimal. They note that similar operations have not harmed the Kirk historically. • Water supply will be secured through a borehole and recirculation ponds, ensuring reliable provision for concrete production, aggregate washing, and dust suppression even during drought. There will be no impact on domestic supplies, groundwater, crops, or woodland. Silts returned to the ground are inert, and best practice prevents contamination. • Dust risks are considered negligible because sand will be processed wet, stockpiles kept damp, and cement handled in sealed systems regulated by Page 70
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SEPA. Climate change concerns are addressed through an adaptive Dust Management Plan. Noise levels will remain within the lowest PAN 50 thresholds, with no significant effect on Moray Archery, dog training, or Elgin Golf Club. • Visual impacts will be mitigated by vegetated bunds shaped to reduce intrusion, plus additional hedgerow and tree planting. Soil bunds are standard practice and blend into the landscape over time. Woodland felling nearby is unrelated and does not affect assessments. • Applicant reaffirms that Moray’s sand and gravel reserves remain below the 10-year minimum required by policy, and other quarry applications do not resolve this deficit. They argue that the site’s central location reduces haulage distances compared to alternatives. Carbon offsetting through planting and restoration will mitigate temporary loss of agricultural carbon capture, and cement emissions are accounted for at the manufacturing stage. The concrete plant will use sealed systems and borehole water, with SEPA oversight. • Applicant also states the quarry will create six jobs, with a preference for local hires, and note that recycled aggregates cannot meet demand or quality standards, making virgin materials essential for construction. Response to Moray Archery Club comments • Applicant clarifies that Moray Archery’s concerns were addressed in earlier responses and that omission from later reports was to avoid repetition. They acknowledged objections from archery governing bodies but emphasised their own expertise in quarry operations and environmental assessment. • The applicant confirms in their opinion that the quarry’s location within a Countryside Around Town (CAT) zone complies with policy, noting that several other quarries operate in similar areas. They addressed noise concerns by citing Vibrock’s survey, which shows existing intermittent traffic noise near the archery site. Predicted quarry noise will be low, with a maximum of 45 dB LAeq,1hr under worst-case conditions, below PAN 50 limits, and most operations quieter. Soil handling noise will be short-term and capped at 70 dB for limited periods, with actual peaks predicted at 61 dB for about a week. All plant and HGVs will use white noise reversing alarms to minimize intrusion. • Dust risks are considered negligible due to wet processing, sealed cement systems, and damping measures, all regulated by SEPA. Moray Council Environmental Health has confirmed the dust management plan is acceptable. Quarry traffic will primarily travel north, away from the archery centre, with only occasional local deliveries passing south. • The applicant acknowledges concerns about the impact on competitions and commit to suspending operations during national events to avoid disruption, similar to arrangements at other sites. They conclude that while the quarry may be audible, it will not significantly affect safety, enjoyment, or the viability of Moray Archery, and mitigation measures will minimize any perceived impacts. Page 71
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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. 8.2 The main issues are considered below: 8.3 Pre-application Consultation Report The application is accompanied by a Pre-Application Consultation (PAC) report, as prescribed under section 35C of the 1997 Act. This outlines the statutory consultation that the applicant undertook with the local community in relation to the application. The form and scope of the pre-application consultation was considered to be suitable and agreed by the Council in response to Proposal of Application Notice 24/00058/PAN. 8.4 The PAC Report outlines the feedback received as part of the PAC process and the applicant’s response. The consultation process included presentations to the Heldon Community Council and two public events held at Birnie Hall. These events were well attended, with over 100 participants across both dates. Materials presented included site plans, environmental assessments, and a 3D visualisation of the proposed quarry. Feedback was invited through comment forms, email, and direct discussion. 8.5 Comments raised a wide range of concerns notably, noise, dust, traffic, visual impact, and potential effects on health, local businesses, and wildlife. Specific concerns included the proximity of the quarry to residential properties, the visibility of plant equipment, and the adequacy of mitigation measures for dust and noise. There were also questions about the long-term restoration of the site and its impact on property values. 8.6 In response, the report confirms that the applicant has made several adjustments to the proposal. The location of the processing and concrete batching plants was moved further from nearby homes, and the site access was redesigned to improve safety and visibility. The extraction period was reduced from 22.5 to 17 years following groundwater monitoring, and restoration plans were updated to include an ephemeral wetland and woodland planting, enhancing biodiversity. 8.7 Environmental Impact Assessment Requirements As noted from the planning history, the proposed development has been previously screened under regulations 6 – 9 of Town and Country Planning (Environmental Impact Assessment) (Scotland) Regulations 2017. The Council, as Planning Authority, adopted an opinion where, in taking account the characteristics and location of the development and characteristics of the potential impact associated with the proposed development, with mitigation no significant environmental effects are considered likely to occur and the proposal does not require to be subject to EIA procedures. Page 72
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8.8 Elgin Countryside Around Town (CAT) The proposal is located within the Elgin Countryside Around Town (CAT) Designation. MLDP Policy EP4 Countryside Around Towns sets out that only certain types of development are appropriate within CATs in order to protect their special character and this includes proposals that are specifically allowed under the terms of other Moray Local Development Plan policies. 8.9 The current proposed development provides a specific site locational justification as it involves mineral extraction and would contribute towards long term planning for the provision of construction aggregates in Moray. However, the proposal is not one of the exceptions set out in policy and therefore would be considered a departure from policy EP4. Despite the locational justification, given the significant adverse landscape and visual effects highlighted below, the proposal would not be considered an acceptable departure unless these are mitigated appropriately to protect the special landscape character of the CAT and prevent development sprawl. 8.10 Minerals Policy The proposed development is subject to NPF4 Policy 33 and MLDP Policy DP10 which state that proposals for the sustainable extraction of minerals will only be supported where they avoid or satisfactorily mitigate impacts. NPF4 Policy 4 and MLDP Policy DP1 (i) b) requires development to integrate into the surrounding landscape and natural environment. 8.11 Policy DP10 Minerals provides for new mineral sites which contribute to the maintenance of at least a 10-year supply of permitted reserves of construction aggregates, subject to meeting the terms of policy DP1 and other relevant policies. 8.12 Local Development Plans are required to maintain a minimum 10-year landbank of construction aggregates within relevant market areas. The Moray Minerals Audit (2023) has identified that there is an adequate landbank for crushed hard rock. However, permitted reserves of sand and gravel only extend to September 2033, with consented supply levels projected to decline by 2031. This indicates an insufficient landbank for sand and gravel. 8.13 Notwithstanding this shortfall, the proposal does not avoid or satisfactorily mitigate landscape and visual impacts within the Elgin CAT as discussed below, and as such is contrary to NPF4 Policies 33, 4 and MLDP Policies DP10 and DP1. 8.14 Landscape and Visual Impact A Landscape and Visual Impact Assessment (LVIA) has been submitted in support of the application. The Council’s appointed Landscape Adviser has undertaken a detailed appraisal of this supporting information, with findings summarised below: 8.15 Overview The proposed sand and gravel quarry is located within the Coastal Farmland Landscape Character Type (LCT), which is defined by its low-lying, gently Page 73
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undulating landform and broad pattern of arable farmland interspersed with occasional woodland. At present, the site has limited landscape diversity and a cluttered appearance due to pig-rearing activities. The development would introduce industrial infrastructure, significant ground modification, and associated noise and activity, fundamentally altering the rural character of the site for up to 18 years. Permanent changes to the landform will remain even after restoration, creating a lasting impact on the local landscape. 8.16 Landscape Character Effects The appraisal concludes that the proposed quarry will have significant adverse effects on the character of the site and its immediate surroundings. The rural qualities of the area will be displaced by industrial activity, including screening bunds, stockpiles, and processing plant structures. These changes will persist throughout the operational life of the quarry. Beyond approximately 0.8 km from the site boundaries, the wider Coastal Farmland LCT will experience reduced effects due to the containment provided by landform and woodland in the wider area. The adjacent Rolling Farmland and Forests LCT will not be significantly affected because visibility from this landscape is limited. While the site is not within a designated landscape, its proximity to public roads and scattered residential properties increases the potential for intrusion. 8.17 Visual Effects The proposed quarry at Dykeside Farm will introduce a substantial industrial presence into what is currently a rural setting, and while the site benefits from some containment by surrounding landform and woodland, it will remain clearly visible from several key locations. The most prominent views will occur from the Thomshill to Elgin Road along the eastern boundary, the minor unclassified road to the south, and certain elevated viewpoints. These roads and vantage points are frequently used by local residents and recreational users, meaning the visual changes will be experienced by a range of receptors. 8.18 Short-term impacts will be most pronounced during the pre-operational phase when soil stripping, bund formation, and access construction take place. At this stage, the site will appear stark and industrial, with exposed soils and angular bunds interrupting the flowing landform of the surrounding countryside. The photomontages provided by the applicant underestimate these effects, as they fail to capture the strong contrast between the natural landscape and the exposed sands, soil stockpiles, and the batching plant, which will protrude above the 3m bunds. The uniformity of the bunds will create an obviously artificial appearance unless redesigned to include varied slopes and profiles. 8.19 Long-term impacts will persist throughout the 18-year operational period. Even with progressive restoration and planting, significant adverse effects will remain from elevated viewpoints and certain properties. Excavation works, stockpiles, and infrastructure will continue to be visible, and while hedgerow and tree planting will eventually soften views, this is likely to take five years or more to become effective. Page 74
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8.20 Assessment of Viewpoints • Thomshill–Elgin Road (Viewpoints 2, 3, 4, and 8): These viewpoints represent close-range views along the eastern boundary of the site. Significant adverse effects are expected during early works, as access construction, soil stripping, and bunding will be seen in close proximity. Over time, as grass seeding establishes and hedgerow and tree planting matures, these impacts will reduce, but the artificial appearance of bunds will remain unless further mitigation is implemented. • Elevated Viewpoints (Viewpoints 2, 7, and 9): Longer-term significant adverse effects will occur from elevated positions where a greater extent of excavation works will be visible. Although restoration and boundary planting will alter the nature of views over time, these effects will remain significant for much of the quarry’s operational life. • Hillhead Wood (Viewpoint 10): A significant effect could occur from this elevated viewpoint on the northern edge of Hillhead Wood, but it is considered difficult to access and unlikely to be experienced by many people. • Southern Boundary Road (Viewpoint 11): Significant adverse effects will occur where the road rises gradually to the west, exposing views of overburden storage and infrastructure above the bunding. These views will be brief and affect relatively few people, but mitigation through hedgerow and tree planting is recommended if the application is to be approved. 8.21 The extent of significant adverse visual effects will be limited to approximately 0.8 km from the site boundaries due to screening provided by landform and woodland. While restoration and planting will reduce impacts over time, the quarry will remain a dominant feature in close-range views for much of its operational period. 8.22 Residential and Recreational Views The Residential Visual Amenity Assessment (RVAA) submitted by the applicant provides baseline information on potential impacts to nearby properties and includes photographs illustrating views toward the proposed development site from individual properties, which is helpful for understanding context. However, the RVAA does not explicitly state the significance of visual effects; instead, it focuses on whether the Residential Visual Amenity Threshold (RVAT) would be reached - meaning whether a property would become an unpleasant place to live due to visual intrusion. 8.23 From review of this assessment, significant adverse effects on views from the upper floor west-facing windows of the properties of Denarii and Denmoor are anticipated however it is considered that the Residential Visual Amenity Threshold (RVAT) would not be reached given the overall relatively limited effects on views from within these buildings and their gardens due to the screening provided by earth bunding and planting on the eastern edge of the site. There would be adverse effects on views from some gardens within Thomshill and it is considered that 26 Mannochmore, which may have elevated views from the rear of the property and garden, could be significantly affected. There is also considered to Page 75
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be significant adverse effects from the garden of the property of Castlehill lying to the east of the proposed development site due to its elevated nature. However, it is not considered that the RVAT would be reached in the case of these properties given the distance of the development, its relatively low-lying nature and the character of existing views. 8.24 Cumulative Effects The quarry will add to existing industrial elements in the landscape, including distilleries and Cloddach Quarry, contributing to a gradual erosion of rural character. While cumulative effects will be adverse, they are unlikely to be significant due to the visual containment provided by woodland and landform. However, the perception of industrialisation in the area will increase, particularly when viewed sequentially from minor roads and recreational routes. 8.25 Mitigation and Restoration Post-restoration, the return to agriculture and establishment of woodland and wetland features would gradually reduce visual impacts. However, the uniformity of proposed bunds and restored slopes risks leaving an artificial appearance, unless significant design improvements are implemented. If the Council is minded to approve the application, the Council’s Landscape Adviser stresses that mitigation measures, such as early planting, naturalistic bund design, and biodiversity enhancements are essential to offset these impacts. Additional recommendations include extending aftercare from five to ten years, improving restoration plans to include permanent water bodies and public access, and ensuring irregular landform design to blend with the surrounding landscape. 8.26 In conclusion, the proposed development would introduce industrial concrete batching plant infrastructure, significant ground modification, and quarrying activity, altering the rural character for up to 18 years, with permanent landform changes even after restoration. Significant adverse effects are expected on the site and its immediate surroundings which is located within the Elgin CAT designation, though impacts diminish beyond 0.8 km due to screening. The quarry and associated ground/earthworks and concrete batching plant will remain highly visible from nearby roads, residential properties, recreational routes, and some elevated viewpoints, resulting in significant visual effects. The proposal is therefore considered unacceptable and contrary to NPF4 Policy 33, 4 and MLDP Policy DP1, DP10 and EP3, as it would result in significant adverse landscape and visual impacts on the local area. 8.27 Applicant’s Response In response to Council Landscape Advisor appraisal, the applicant submitted a further statement. They note that the Council’s advisor noted the site is contained by landform and woodland, but flagged significant visual impacts within 0.8 km. The applicant disputes this, citing limited, transient views and faster mitigation benefits. They confirmed existing measures such as bunding and early planting, accepted some extra planting, and initially rejected other suggestions (large trees, southern boundary planting, 10-year aftercare) due to space and safety concerns. The revised restoration plan now includes open water and expanded woodland for biodiversity, though public access was not accepted. Overall, the applicant Page 76
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argues the proposal remains acceptable, with enhanced mitigation and long-term landscape and biodiversity gains. To address further comments from the Landscape Adviser the applicant submitted a further updated landscape plan showing tree planting along the north boundary and cross section drawings of bunding of less uniform appearance. 8.28 The revised mitigation proposals are acknowledged; however, they are considered insufficient to address the significant adverse landscape and visual impacts identified. The introduction of extensive earth bunding around the site perimeter, together with stockpiles, would result in prominent, artificial landforms that would appear incongruous within the established rural character of the area. Excavation activities and associated quarry infrastructure will remain visible throughout the operational period, and while additional hedgerow and tree planting is proposed, this is regarded as inadequate to provide effective screening of the development. Furthermore, although the proposed planting may eventually soften some views, it is anticipated that a minimum period of five years, and most likely longer, will be required before this occurs. 8.29 Drawing from the above considerations, the proposal is contrary to NPF4 Policy 33 and MLDP Policies DP1 and DP10, as it would fail to integrate sensitively into the surrounding landscape and would result in significant adverse landscape and visual effects on the local area. 8.30 Transport and Access NPF4 Policy 13 Sustainable Transport and MLDP Policy PP3 Infrastructure and Services and DP1 Development Principles set out requirements to ensure that transport impacts from development are acceptable, with mitigation where required. NPF4 Policy 33 Minerals states that proposals for the extraction of minerals will only be supported where they minimise transport impacts. 8.31 The quarry layout comprises internal roadways, access ramps, a vehicular access onto the adjacent CE2 road, designated accessible parking space, electric vehicle charging and secure cycle storage. 8.32 A Transport Assessment and addendum (to address initial Transportation Section consultation comments) has been submitted in support of the planning application. These confirm that traffic generated by the quarry is expected to be relatively low, with HGV movements on an average day predicted to be around one arrival and one departure per hour, increasing to two each way on busier days. Private sales of smaller loads are estimated to generate only six two-way trips per day, typically using vans or trailers, and are considered negligible in terms of road impact. 8.33 Updated traffic data shows that existing HGV traffic on the C2E road averages 41 two-way movements per weekday between 07:00 and 18:00. During peak hours, the number of HGVs is sufficiently low that vehicles are unlikely to meet in opposing directions along the 2.6 km stretch between the site and Elgin. The road network is considered capable of accommodating the additional quarry traffic without significant impact. Page 77
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8.34 Swept path analysis confirms safe access for large vehicles, and visibility splays have been extended to meet Council standards, ensuring safe turning movements and adequate sightlines. All quarry traffic will be routed north to Elgin, with signage in place to manage vehicle movements. Road widening will be achieved by scraping back verge overgrowth, with additional widening of the road where necessary. 8.35 The site design will ensure all surface water is contained and managed within the quarry, using settlement ponds and infiltration. Catch ditches will prevent runoff from affecting nearby roads. 8.36 Overall, the assessment confirms that the local road network can accommodate the proposed quarry traffic without adverse road safety impacts, and that the access arrangements comply with transportation requirements. 8.37 The Transportation Section following assessment is content with this supporting information and has raised no objection to the proposal subject to conditions. These require the submission and approval of a detailed road width investigation report covering the section from the site access northwards to the Elgin Golf Club entrance to identify carriageway widths and any required widening works to 6 metres, provision of visibility splays, site access surfacing to adoptable standards with swept paths, 50 metres of hot rolled asphalt to be laid along the public road fronting the site centred on the access, a Construction Traffic Management Plan and a Management Plan addressing site drainage and vehicle cleaning to prevent discharge onto the public road. Further conditions require submission/approval of details of drainage and catch ditch drains to the bunds and access, an Operational Traffic Management Plan to show how HGV routing will be managed, and CCTV monitoring system (if required) to ensure effective enforcement of designated traffic routes, restrictions on excavations, slopes and planting adjacent to the public road, car and cycle parking provision and implementation of road sweeper to prevent to prevent accumulation of debris and verge creep. 8.38 Subject to these conditions, drawing from the above, the proposal is considered to comply with NPF4 Policy 13 and MLDP Policy PP3. 8.39 Hydrology and Hydrogeology NPF4 Policy 33 requires proposals for the extraction of minerals to demonstrate no significant adverse impacts on the environment, including water, air, soil, biodiversity, and local communities. NPF4 22 Flood Risk & Water Management seeks use of SUDs to ensure surface water does not increase flood risk to itself and others. Drainage and flood risk requirements are set out in MLDP Policies PP3 Infrastructure and Services, DP1 Development Principles, EP12 Management and Enhancement of the Water Environment. Policy EP14 Pollution Contamination Hazards outlines requirements for managing pollution and contamination within development proposals. NPF4 Policy 5 Soils and EP16 Geodiversity and Soil Resources state that developments should minimise disturbance to peat and other carbon rich soils. Page 78
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8.40 Chapter 6 of the submitted Environmental Review assesses the potential impacts of the proposed sand and gravel quarry on surface water, groundwater, and nearby water features, based on a hydrological and hydrogeological assessment undertaken for the proposal. This confirms that the proposed quarry will operate above the water table, avoiding direct interaction with groundwater. SEPA’s flood maps indicate that a small part of the site is subject to surface water flooding due to its lower ground position, but this is not considered significant and can be managed on-site. Any water accumulating in the quarry void will be controlled, and the development is assessed as having negligible potential to increase flood risk elsewhere. The proposal incorporates Sustainable Urban Drainage Systems (SUDS) for surface water management and will not adversely affect surface or groundwater quality. No groundwater dependent ecosystems were identified, and no peat is present. Overall, the flood risk to structures, properties, and people is considered negligible. 8.41 Water for operations, including aggregate washing, concrete production, and dust suppression will be sourced from surface runoff and an on-site borehole. Three settlement ponds will collect and recycle water, with no discharge from the site. The only potential contaminant is suspended solids, which pose no risk to groundwater. Fuel and oils will be stored in bunded containers to prevent pollution. 8.42 There are also no private water supplies within close proximity (2km) to the site, and all known abstractions and water features have been documented, with details provided by the Private Water Section, Environmental Health. The proposed borehole abstraction will be regulated by SEPA, within licensing thresholds ensuring no impact on nearby water features. The River Lossie, Foths Burn, and Burn of Linkwood are all located 850 -1,000 metres from the borehole, and the abstraction rate is not expected to affect these water bodies. 8.43 SEPA has been consulted on the proposal and has confirmed that, under the new Environmental Authorisations (Scotland) Regulations (EASR), two separate authorisations will be required for the proposed borehole and water abstraction. A registration-level authorisation is needed for constructing a borehole less than 200 m deep, and a permit-level authorisation is required for the abstraction itself. SEPA has advised that the applicant review its guidance on water activities and contact the Water Permitting team for pre-(authorisation)application discussions if required. 8.44 Scottish Water has raised no objection to the proposal, subject to standard serviceability checks. It confirms that there is no public wastewater infrastructure nearby, and that private treatment options should be considered. Capacity cannot be reserved and will be confirmed after planning approval and a formal connection application is submitted. Scottish Water assets are also located near the site and therefore the applicant must check for conflicts, contact the Asset Impact Team via the Customer Portal, and obtain written consent before works commence. It also confirms that no designated Drinking Water Protected Areas will be affected. Page 79
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8.45 The Private Water Section following assessment of the submitted information (and supplementary information) has raised no objection, subject to condition requiring submission/approval of a Water Management Plan covering the proposed borehole, cumulative abstraction from existing sources, and the Hillhead Irrigation licence. The plan must set out measures to manage abstraction during seasonal variations and water scarcity, including potential shutdowns, and provide evidence that hydrological and geomorphological investigations confirm sustainable abstraction without impacting other private water supplies. This is to safeguard private water supplies and maintain water security in the area. 8.46 Following a review of supporting information and additional details addressing drainage and flood risk queries, the Flood Risk Management team is also content with the proposed drainage arrangements and has raised no objection to the application on flood risk grounds. 8.47 Drawing from the above and subject to the recommended conditions, the proposal is considered to comply with NPF4 Policies 22 and 33, and MLDP Policy EP12 and DP1 in relation to surface water and flood risk management, and protection of the water environment and water supplies. 8.48 Noise, Air Quality/Dust and Lighting NPF4 Policy 33 Minerals and equivalent MLDP Policy DP10 seek to ensure that mineral developments do not cause unacceptable harm to people or the environment and requires proposal to demonstrate how they will manage and minimise noise, dust, and other forms of pollution. NPF4 Policy 23 Health and Safety and Policy EP14 Pollution, Contamination and Hazards, seek to ensure that new development does not create pollution which may adversely affect the environment or local amenity. 8.49 Noise A Noise Impact Assessment was undertaken for the proposed quarry and ready- mix concrete plant, to evaluate potential effects on nearby residential properties and ensure compliance with national planning guidance. 8.50 The assessment, based on Planning Advice Note (PAN) 50 Annex A, confirms that routine operations will remain within the recommended daytime noise limit of 45 dB LAeq,1h. Temporary activities, such as soil stripping and bund construction, may reach up to 70 dB LAeq,1h, but only for short durations (up to 8 weeks per year), which is considered acceptable under planning policy. 8.51 Noise predictions were modelled using worst-case scenarios and show that even during peak activity, levels at nearby receptors will not exceed the relevant thresholds. Mitigation measures including acoustic bunds as shown in phasing plans, controlled working hours, fitting of broad-spectrum white noise reversing alarms to all plant, noise levels of new/replacement plant to be assessed and maintenance of all plant to ensure integrity of silencers, lubrication of bearings etc. are proposed to minimise impacts. The report also confirms that cumulative noise from the nearby Cloddach Quarry will not result in exceedances. Page 80
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8.52 The assessment concludes that the proposed development can operate within acceptable noise limits, with appropriate controls in place to protect residential amenity. 8.53 Air Quality/Dust An assessment of air quality impacts has been submitted to evaluate the potential impacts of dust and particulate emissions from the proposed quarry operations on nearby receptors, public health, and the environment, and to ensure that appropriate mitigation measures are in place to prevent significant adverse effects. Supplementary information was submitted to address queries from the Environmental Health Section. 8.54 The assessment concludes that dust emissions from excavation, processing, and transport will be low, with the greatest risk confined to receptors within 100 and 200 metres of the site. Predicted particulate levels remain below national air quality standards, and ecological receptors are not considered sensitive to dust generated. The assessment draws on local climate and wind data, receptor proximity and sensitivity, and Moray Council’s 2024 air quality baseline. 8.55 The assessment also considered nuisance thresholds, occupational exposure limits, and ecological designations. A Site Dust Management Plan has been prepared which aims to minimise emissions by preventing dust generation and applying effective suppression measures. Key actions would include dampening soil stripping areas, haul roads, and stockpiles during dry or windy conditions, early grass seeding of soil mounds, and controlling vehicle movements through speed limits, water bowser spraying, and regular road maintenance. All loads leaving the site will be sheeted, and vehicles cleaned to avoid dust on public roads. Processing will use wet screening, and stockpiles will be kept below ground level where possible, with temporary sand treated using binding agents. 8.56 Water supply for dust suppression will be maintained throughout operations. Monitoring will involve visual checks and periodic quantitative assessments at sensitive locations, with trigger levels for corrective action. A formal complaints procedure is in place, and the plan will be reviewed regularly to ensure compliance and effectiveness. 8.57 Overall, with the Dust Management Plan implemented, the air quality impact is assessed as negligible to slight, with no significant risk to public health, amenity, or ecology. 8.58 Lighting Consideration has been given to potential light pollution in line with Scottish Government guidance and best practice. As noted from the Environmental Review lighting will be limited to essential health and safety purposes during early mornings and late afternoons in winter, with no overnight use. All lighting will be directed downwards and inwards to operational areas, avoiding over-lighting, with its use periodically reviewed. Peripheral soil screening mounds and the below- ground design of the plant area will assist to screen lighting from external views, and quarry plant lighting will generally be located below ground. As a result, Page 81
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potential impact on residential amenity and the surrounding area is considered to be slight to negligible. 8.59 The Environmental Health Section has reviewed the findings and recommendations of these assessments and additional supporting information and has raised no objection to the proposal, subject to a suite of conditions. These seek to restrict quarry operations to 08:00–18:00 Monday to Friday and 08:00–12:00 on Saturdays, unless otherwise agreed; noise levels must not to exceed 45 dB(A) during normal operations and 70 dB(A) for soil and overburden handling, which is restricted to eight weeks per year; all quarry vehicles must use white noise reversing alarms. Before work begins, a Noise Monitoring Programme and site lighting details must be submitted and approved, and both maintained throughout the development. The operator must also implement a Dust Management Plan as set out in the supporting environmental review. If noise complaints arise, the developer must carry out monitoring in line with PAN 50 Annex A and apply mitigation if limits are breached. 8.60 From the above and subject to the recommended conditions with appropriate mitigation, it is considered that the proposal would not result in unacceptable significant adverse effects on noise and dust/air quality, or the amenity of any nearby sensitive receptors and would accord with the requirements of Policies 33, 23, DP10 and EP14. 8.61 Ecology and Protected Species NPF4 Policy 33 states that development proposals for the extraction of minerals will only be supported where they do not result in significant adverse impacts on the natural environment. NPF4 Policy 4 Natural Places states that development proposals that are likely to have an adverse effect on species protected by legislation will only be supported where the proposal meets the relevant statutory tests, with MLDP Policy EP1 Natural Heritage Designations having similar requirements. These also seek to protect international, national, or local environmental designations from inappropriate development. 8.62 An Ecological Impact Assessment (EcIA) has been undertaken for the proposed development, supported by a Phase 1 Habitat Survey and species-specific assessments. This confirms that the site, currently used for pig farming, consists mainly of improved grassland with limited ecological value, with hedgerows along the site boundaries providing habitat, supporting birds, bats, and badgers. It notes that badgers are active in the area, using hedge bases and nearby scrub for foraging and sett creation. While no main setts were found within the site, mitigation including pre-commencement surveys and licensing (if needed) will ensure protection. The quarry will reduce foraging habitat, but this is not considered significant at a wider scale. 8.63 Birds use the hedgerows for nesting and feeding. Vegetation clearance will be timed to avoid the breeding season, and hedgerow management will be adjusted to enhance habitat value. Bats forage along hedgerows, and lighting will be directed away from these areas to minimise disturbance. No amphibian or reptile Page 82
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habitat was identified, and other mammals such as red squirrel and pine marten are unlikely to be affected due to habitat separation. 8.64 The EcIA also confirms that the proposed quarry will not significantly impact nearby designated sites, namely the Scaat Craig (designated for its geological features) and Buinach & Glenlatterach SSSIs, (for its woodland / dry heath vegetation features), due to their distances of 2.8km to the south-east and 2.9km to south respectively and lack of ecological connectivity. 8.65 In light of the findings of the EcIA, and subject to conditions addressing mitigation the proposal is not considered to adversely affect protected species, in line with NPF4 Policy 4, 33 and MLDP Policy EP1. 8.66 Biodiversity NPF4 Policy 3 and MLDP Policy EP2 both require development proposals to enhance biodiversity. NPF Policy 3 requires major development proposals to enhance biodiversity, including nature networks, ensuring they are in a demonstrably better state than without intervention. 8.67 The Ecological Impact Assessment (EcIA) sets out that while the site currently supports limited ecological value, primarily improved agricultural grassland, there are opportunities to enhance biodiversity through the proposed restoration and mitigation measures. 8.68 At the outset of development, 0.84 hectares of mixed native woodland and scrub is proposed to be planted to the south-east of the site, together with a new native species hedgerow along the eastern boundary that extends northward for 580 metres and tree planting along the northern boundary. Existing hedges will be retained and managed less intensively to enhance their ecological value. The surrounding bunds will be seeded with species-rich meadow mixes to compensate for temporary habitat loss during excavation. 8.69 Following quarrying, restoration include proposed broad-leaved woodland planting around the northern site edges using native species such as ash, sessile oak, wild cherry, rowan, and Scots pine. A wetland area with ponds and scrapes will be created in the lowered northern section to support wading birds and pollinators. In total, the scheme (once restored) would provide 2.5 hectares of woodland, 2.2 hectares of wetland, 9.6 hectares of modified grassland, and approximately 750 metres of new native hedgerow, including a significant offsite section. 8.70 A five-year aftercare period is also proposed to aid habitat establishment and long-term ecological resilience. Had the application been recommended for approval an extended aftercare period of 10 years and robust management plan would have been secured by condition. 8.71 Taken together, it is considered these measures subject to conditions addressing the mitigation measures demonstrate that the development will result in a net Page 83
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gain in biodiversity and contribute to nature networks, in line with requirements of NPF4 Policy 3. 8.72 Cultural Heritage NPF4 Policy 33 states that development proposals for the extraction of minerals will only be supported where they do not result in significant adverse impacts on the historic environment. NPF4 Policy 7 Historic Assets and Places states development proposals with a potentially significant impact on historic assets or places must include an assessment based on an understanding of the cultural significance of the historic asset or place. At a local level, MLDP Policy EP8 Historic Environment takes a similar position. 8.73 The Historic Environment Impact Assessment sets out that the proposed development will not result in any significant adverse impacts on the historic environment. No designated heritage assets lie within the development area, and nearby nationally significant sites - Birnie Parish Kirk and its symbol stone (a category A listed building and Scheduled Monument 500m northwest of the proposal) - are visually screened by natural topography, avoiding setting impacts. 8.74 One undesignated site, a possible Iron Age roundhouse identified through geophysical survey, lies within the development footprint and will be directly affected. This site is of local significance, and its loss is considered a minor effect. To mitigate for this, a programme of archaeological evaluation and recording will be undertaken prior to construction, ensuring any archaeological information is recovered and made publicly accessible. 8.75 The Aberdeenshire Archaeology Service is content with this initial information and has recommended that a suspensive condition be attached requiring submission/approval of an archaeological Written Scheme of Investigation (WSI), implementation of archaeological works in accordance with the approved WSI and should works reveal need for post excavation analysis the submission/ approval of a Post-Excavation Research Design (PERD). 8.76 Historic Environment Scotland’s (HES) remit includes considering the impact of developments on the setting of category A-listed buildings and scheduled monuments. Following consultation, it notes although the proposals have the potential to affect Birnie Parish Kirk and associated heritage assets (Scheduled Monument SM2781 and Listed Building LB2294) to the west, it confirms that it has no comments to make and advises that the application should be determined in line with national and local policy on development affecting the historic environment. As noted from the supporting Historic Environment Impact Assessment and on-site observations, the proposed development is not intervisible with Birnie Kirk due to intervening topography with a steep in rise in ground level (to the southeast of Dykeside Farm) and it is not considered that the proposal would adversely impact the setting of this historic asset. 8.77 From the above considerations, subject to the recommended condition, it is considered that the proposal would not adversely impact the historic environment interests and would accord with NPF4 Policy 7 and MLDP Policy EP8. Page 84
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8.78 Climate Change NPF4 Policies 1 and 2 require significant weight to be given to the climate and nature crises in the assessment of all development proposals and seeks to encourage development that minimises emissions and adapts to the impacts of climate change. 8.79 The supporting Carbon Assessment sets out that the development is consistent with national and local climate policy and demonstrates good practice in minimising greenhouse gas emissions. It concludes that while the quarry will produce emissions typical of mineral extraction, its location close to Elgin reduces transport-related emissions - by around 42% compared to other regional sources. Mitigation measures, including efficient plant, renewable energy use, and carbon offsetting through planting, are expected to offset up to 53% of total emissions over 40 years. Climate resilience measures are embedded into the proposal (to address temperature increase, extreme weather, flood risk and positive adaptation) and considered sufficient to manage future risks. The proposal has been reviewed and is considered to comply with NPF4 Policies 1 and 2. 8.80 Community Wealth Building NPF4 Policy 25 states that proposals will only be supported where they maximise net economic impact, contribute towards local and regional community wealth building strategies and are consistent with local economic priorities. 8.81 The supporting Community Wealth Building Plan (CWBP) sets out that the proposed quarry and ready-mix plant would support local economic growth in line with NPF4 Policy 25 through provision of local employment, training, and supply chain use. Operationally, six jobs are anticipated, with recruitment focused locally through Job Centre Plus and supported by apprenticeships, vocational training, and links to Moray College UHI and Moray Developing the Young Workforce Initiative. The applicant commits to maximising local procurement wherever possible, with estimated local spend of up to 90% during construction and 75 - 90% during operation, supporting local businesses and contractors. 8.82 Subject to a planning condition to secure an updated CWBP that reflects the different procurement stages and a monitoring statement, the proposal complies with NPF4 Policy 25 and associated Council guidance. 8.83 Waste Management All extractive waste operators are required to comply with the Extractive Waste Management (Scotland) Regulations 2010 and Mine Waste Directive. As required under policy DP10, an Extractive Waste Management Plan accompanies this application. 8.84 This plan outlines measures for managing soils, overburden, and processing silts during extraction and restoration. Soils will be stored in screening mounds for later reinstatement. Overburden will be treated as a non-waste by-product and used for restoration, while silts from washing will be settled in ponds, periodically Page 85
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dried, and placed in the excavation void. All materials are inert. Environmental controls include dust suppression, water management under CAR, and compliance with the Quarries Regulations. Restoration will be monitored throughout operations, with five years of aftercare post-closure; no long-term monitoring is anticipated due to the inert nature of the material. The plan is considered to accord with the regulations as well as the requirements of MLDP Policy DP10. 8.85 Restoration and aftercare NPF4 Policy 33 and Moray Local Plan Policy DP10(c) require mineral proposals to include comprehensive restoration and aftercare plans. These policies ensure that sites are progressively restored during operations and fully reinstated after extraction, with measures for soil replacement, landscaping, biodiversity enhancement, and long-term stability. They also require financial guarantees and defined aftercare periods to secure delivery, preventing environmental harm and leaving land in a safe, beneficial condition for future use. 8.86 The proposed restoration and aftercare strategy for the proposed quarry would provide for progressive reinstatement during operations and full restoration on completion, returning the site mainly to agriculture with areas of woodland, hedgerow, and an ephemeral wetland to enhance biodiversity. All plant and hardstanding would be removed, soils respread, and access retained for farm use. A five-year aftercare programme will ensure soil treatment, grass establishment, and maintenance of planting. Biodiversity Net Gain would also exceed targets, with provision of increased habitat and hedgerow units delivered alongside agricultural reinstatement. As noted from supporting information, the applicant is a member of the Mineral Products Association’s restoration guarantee scheme which provides a financial guarantee mechanism which Councils can draw upon should a member become insolvent and default on their restoration obligations. Had the application been recommended for approval conditions would have been attached addressing these matters. Conclusion and Recommendation The proposed development is contrary to the National Planning Framework 4 (NPF4) and Moray Local Development Plan 2020 (MLDP) for the following reasons: 1. NPF4 Policy 33 Minerals and MLDP Policy DP10 Minerals would only consider such development favourably where it did not result in any significant adverse impacts. Where the proposal would introduce a significant change to the landscape through the extraction of sand and gravel and installation of a concrete ready-mix batching plant into the Countryside Around Towns designation, to the detriment of the rural landscape and its character where the open rural character is specifically to be preserved, results in the departure from Policy 33 and DP10. 2. The proposed development, by virtue of its presence within the Elgin Countryside Around Towns (CAT) designation would sit within a landscape restricted from development and vulnerable to development pressure Page 86
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bringing it into conflict with MLDP Policies DP1 Development Principles and EP3 Special Landscape Areas ii) Landscape Character and NPF4 Policy 4 Countryside Around Towns a) Natural Places. In terms of landscape character, the lack of natural enclosure and impact of the industrial appearance of the quarry and concrete batching plant proposal would have an adverse significant effect and change on the character of the area. Similarly, in terms of visual amenity, the nearby properties to the southeast, east and south in the vicinity would experience significant adverse effects on their visual amenity from the proposed development. The proposed development is therefore a departure from MLDP Policies DP1 and EP3 and NPF Policy 4. 3. The development being proposed within the Elgin (CAT) designation lies within an area where development must generally be prohibited to maintain the distinction between the defined settlement boundary of Elgin and the surrounding open countryside. The proposal is therefore contrary to MLDP Policy EP3 ii), EP4 and the Elgin (CAT) designation where the size and scale of the proposed development (13.59ha), industrial appearance and location in open countryside immediately adjacent to the C2E Elgin to Birnie Road significantly undermines the function, nature and character of the Elgin Countryside Around Town (CAT) area. Author/Contact Officer: Richard Smith Principal Planning Officer Ext: 01343 563256 Neal MacPherson Acting Service Manager Development Management & Building Standards Page 87
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APPENDIX 1 - LIST OF OBJECTIONS/REPRESENTATIONS Cameron McCarthy Barholm Birnie Elgin Moray IV30 8SR O Mrs Brenda Carnegie 12 Findlater Lane Elgin Moray IV30 8AX O Mrs Norma Watson 3 Smith Drive Elgin Moray IV30 4NE O Mrs Lisa Campbell 20 Dunvegan Crescent Elgin Moray IV30 8AL O Mr Michael Horsfield 111 Wargrave Road Newton-le-Willows WA12 8JN O Mr Matthew Buckley 10 The Maltings Elgin Moray IV30 8AE O Mr Ross Arthur Bracken Brae Glenlatterach Birnie Elgin Moray IV30 8RR O Mr Marc Roberts Bracany Bracany Park Longmorn Elgin Moray IV30 8SL O Miss Charlene Hamilton Brackenbrae Wardend Birnie Elgin Moray IV30 8RW O Mr Paul Gerrie 35 Thornhill Drive Elgin Moray IV30 6GS O Miss Linda Cameron 66 Queen Street Lossiemouth Moray IV31 6PT O Mr David Brunton 65 Lammermuir Crescent Dunbar EH42 1DW O Mr James Turnbull Glenluce Wardend Birnie Elgin Moray IV30 8RW O Mrs Claire Towers 46 Thornhill Drive Elgin Moray IV30 6GT O C R Duncan Woodside House Birnie Elgin Moray IV30 8RW O Mrs Jennifer Thomson Glebe Cottage Birnie Elgin Moray IV30 8SU O Mrs Claire Mcmanus 47 Greenfield Circle Elgin Moray IV30 5NF O Mr Mark Reilly Craigmhor 21 Mannochmore Thomshill Elgin IV30 8GZ O Mrs S Mccallum 8 Glassgreen Place Elgin Moray IV30 6JE O Mrs Anne Cameron 64 McIntosh Drive Elgin Moray IV30 6AW O Mrs Michela Roberts Bracany Bracany Park Longmorn Elgin IV30 8SL O Mrs Aissa Sadler 1 Broomhill Road Keith Moray AB55 5EX O Christine Poole Tregarne King Street Elgin Moray IV30 1HU O Page 89
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Mr George Fearnley 4 Mannochmore Thomshill Elgin Moray IV30 8GZ O Ms Leigh Robertson 5 Mannoch Court Elgin Moray IV30 6YT O Mrs Susan Brewer 15 Meadow Gardens Hopeman Elgin Moray IV30 5PN O Mr Daniel McManus 47 Greenfield Circle Elgin Moray IV30 5NF O Mr Brian Graham Kirkview Birnie Elgin Moray IV30 8SU O Mrs Dawn Graham Kirkview Birnie Elgin Moray IV30 8SU O Miss Sarah-Jane Paterson 3 Covesea Grove Elgin Moray IV30 4PP O Mrs Ruth McKell Backhill Of Hatton Farmhouse Auchterless Turriff AB53 8AQ O Mr Robert Wickens Northview Birnie Elgin Moray IV30 8RR O Mrs Laura Devlin 41 Townhead Inverbervie DD10 0PN O Mr Christian B 22 Butler Road West Harrow London HA1 4DR O Mrs Kathryn Weir 2 Glenlossie Farm Cottages Birnie Elgin Moray IV30 8ST O Mrs Megan Ross 4 Buchan Green East Kilbride Glasgow G74 3BJ O Ms Arlene Youngson 9 Land Street Keith Moray AB55 5AU O Miss Conny Wylie 35 Glebe Road Kinloss Forres Moray IV36 3TU O Mr Kenneth Roberts Bracany Bracany Park Longmorn Elgin IV30 8SL O Mr Marcus Morran 24 Mannochmore Thomshill Elgin Moray IV30 8GZ O Mr Giles Coutts Ardmhor 18 Mannochmore Thomshill Elgin Moray IV30 8GZ O Mrs Kerrie Kirkwood 1D Fyvie Green Elgin Moray IV30 8AW O Miss Laura Elliott 2 Duart Way Elgin Moray IV30 8AY O Mr Paul Deeming 21 Ogston Lane Lossiemouth Moray IV31 6DX O Mrs Amy Forsyth 15 Gleneagles Drive Elgin Moray IV30 6LP O Michael Mansfield 20 Duart Way Elgin Moray IV30 8AY O Mrs Gillian Campbell Bracitee Longmorn Elgin Moray IV30 8RJ O Mr Allan Grigor Birchbank Glenlatterach Birnie Elgin IV30 8RR O Mrs Karen Grant 1 Birnie Circle Elgin Moray IV30 6JD O Page 90
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Mrs Natasha Grigor Birchbank Glenlatterach Birnie Elgin IV30 8RR O Miss Lisa Mcwilliam 12 Teindland Place Elgin IV30 6LW O Mr Stuart Thompson Chalamain Cottage 11 Mannochmore Thomshill Elgin IV30 8GZ O Mr Colin Allan 80 Moray Street Lossiemouth Moray IV31 6JE O Mr Liam Morran 24 Mannochmore Thomshill Elgin Moray IV30 8GZ O Mr Angus Lawson 3 Jasmine Drive Elgin Moray IV30 8BS O Mrs Fiona Acamovic 14 Fulton Place Dalrymple KA6 6QB O Mr Christopher Ballard 12 Duart Way Elgin Moray IV30 8AY O Ms Sonia Palmer 94 Ashgrove Park Ashgrove Road Elgin Moray IV30 1UT O Mr Greg Murray Shougle Farmhouse Birnie Elgin Moray IV30 8RP O Miss Liz Woodall 25 Coulardhill Terrace Lossiemouth Moray IV31 6LE O Mr Graham Wood 16 Gullane Crescent Elgin Moray IV30 8BZ O Mrs Lynn Sutherland 133 Scone Road Elgin Moray IV30 8BX O Mrs H Stephen Dundara Birnie Elgin Moray IV30 8ST O Mr Peter Stephen Dundara Birnie Elgin Moray IV30 8ST O Mr Joshua Phillips The Manse Inverkeilor Arbroath DD11 5SA O Mr Kenzie Stephen Dundara Birnie Elgin Moray IV30 8ST O Mrs Alison Paterson Jadeil Wester Whitewreath Longmorn Elgin IV30 8SL O Mr Chris Leil Craigmicheal Maggieknockater Craigellachie Aberlour AB38 9RA O Mr Scott Bremner 13 Fyvie Green Elgin Moray IV30 8AW O Mrs Riana Oeschger Wardend Birnie Elgin Moray IV30 8RW O Mrs Carol Spencer Jones 139 Scone Road Elgin Moray IV30 8BX O Mr Iain Wilson 3 Lyonside Street Rigside Lanark ML11 9NJ O Mr Carl Bailey 25 Barhill Road Buckie Moray AB56 1DS O Mrs Janey Cameron Leinster Mhor Kildary Invergordon Ross-shire IV18 0PB O Mrs Sally Smith Cotts Of Innes Farmhouse Cottage Elgin Moray IV30 8LX O Page 91
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Mrs Brianna Wignall 22 Bain Avenue Elgin Moray IV30 6GB O Mrs Joan Garven Willowbank Cottage Dunbar Street Lossiemouth IV31 6RB O Miss Casey Graham Kirkview Birnie Elgin Moray IV30 8SU O Andrew Owen B/1 44 Brisbane Street Greenock PA1 68NP O Mr Joshua McMillan 26 Peter D Stirling Road Kirkintilloch G66 1PF O Miss Brett Robertson 16 Royal Troon Drive Elgin Moray IV30 8BA O Mrs Tracey Reilly Craigmhor 21 Mannochmore Thomshill Elgin IV30 8GZ O Mrs Fiona Morran 24 Mannochmore Thomshill Elgin Moray IV30 8GZ O Mr Kenneth Morran 24 Mannochmore Thomshill Elgin Moray IV30 8GZ O Mr Chris Clements Kirkview Birnie Elgin Moray IV30 8SU O Mrs Margaret Smith 13 Dornoch Links Elgin Moray IV30 6LZ O Mrs Petronella Kaalberg- Schellekens Glendalloch Glenlivet Ballindalloch Moray AB37 9EB O Dayanna Romero 16 Duart Way Elgin Moray IV30 8AY O Mrs Andrea Morrell Twynning Pillowell Road Whitecroft GL15 4QW O Mr Neil Hickman 2 Kearsley Street Leigh WN7 4EP O Mr Bob Rapley 29 Royal Troon Drive Elgin Moray IV30 8BA O Mr John Haefner 27 Scone Road Elgin Moray IV30 8AT O Mr Christopher Hearn 11 Corgarff Road Elgin Moray IV30 8BH O Dr Amy Farrell 8 Dunvegan Crescent Elgin Moray IV30 8AL O Ms A T Clifton Road Lossiemouth IV31 6DP O Mrs Carole Hogan 8 Braco Place Elgin IV30 1PQ O Mrs Nina Lucas 8 Inchbroom Avenue Lossiemouth Moray IV31 6HJ O Ms Jean Main 11 Gleneagles Drive Elgin Moray IV30 6LP O Amy Storey Wester Whitewreath Farmhouse Longmorn Elgin Moray IV30 8SL O Mr Brody McKenzie The Grange 25 Nicol Street Elgin Moray IV30 6BU O Page 92
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Miss Caroline Wilson Tavwil 1 County Houses Birnie Elgin IV30 8SW O Miss Abigail O'Grady 49 Glenlossie Road Thomshill Elgin Moray IV30 8GY O Mrs Hazel Jamieson 5 Kintrae Rise Elgin Moray IV30 5ND O Ms Carol O'Shea 2 Rimsdale Crescent Glenrothes Fife KY7 6FZ O Fiona Davidson 22 Fairfield Avenue Elgin Moray IV30 6BB O Mrs Anne Proctor 34 Birnie Circle Elgin Moray IV30 6JD O Mrs Sam Buchanan 30 Fairfield Avenue Elgin Moray IV30 6BB O Mrs Louise Morris 7 Leslie Place Elgin Moray IV30 4GY O Miss Kerry Black 4 Brora Way Elgin Moray IV30 8DB O Miss Carla Laing 6 Eilean Donan Way Elgin Moray IV30 8TD O David Mckenzie 1 Sellar Street Burghead Elgin Moray IV30 5UL O Mr David Howes 22 Blairfindy Drive Elgin Moray IV30 8BU O Mr John Gibb 18 Macduff Street Lossiemouth Moray IV31 6EX S Mrs Moyra Younie 45 Glenlossie Drive Elgin Moray IV30 6YJ O Mrs Errin Ray 1 Birnie Road Elgin Moray IV30 6JA O Mr Steve Livingstone 10 Provost Fraser Drive Aberdeen AB16 5LP O Mr John Young 8 Wellbrae Court Elgin Moray IV30 6EP O Mr Gary Abel 6 Glen Elgin Drive Elgin Moray IV30 6JH O Mr David Wilson 36 Glamis Place Elgin Moray IV30 8UJ O Mrs L Johnston Carsewell Steading Main Road Alves Elgin IV30 8UE O Mr Kenneth Munro 9 Royal Troon Drive Elgin Moray IV30 8BA O Kelly Findlay 47 Cawdor Avenue Elgin Moray IV30 8AH O Mr Paul Buchanan 30 Fairfield Avenue Elgin Moray IV30 6BB O Miss Jodie Johnston 1 Ardfin Walk Elgin Moray IV30 8BD O Clare And Richard Penny No Address Provided O Agata Wolanska 40 Dunvegan Crescent Elgin Moray IV30 8AL O Page 93
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Brenda Munro 9 Royal Troon Drive Elgin Moray IV30 8BA O Pamela Dewhurst No Address Provided O Derek McLennan 2 Schoolhill Terrace Lossiemouth Moray IV31 6JZ O Mr Malcolm Harper 31 Harald Drive Thurso KW14 8JH O Mr Pete Devlin 59 East High Street Elgin Moray IV30 4EJ O Mrs Leanne Irons 17 Ben Riach View Elgin Moray IV30 6GZ O Mrs Emma Gillings 17 Cardhu Distillery Cottages Cardhu Aberlour Moray AB38 7RZ O Miss Sally Henderson 14 Cawdor Avenue Elgin Moray IV30 8AH O Mrs Claire George 26 Royal Troon Drive Elgin Moray IV30 8BA O Mr Ben Clinch Hollylea Kintessack Forres Moray IV36 2TG O Mrs Hannah Fearnley 4 Mannochmore Thomshill Elgin Moray IV30 8GZ O Mrs Elsa Paterson Kildonan 26 Reidhaven Street Elgin Moray IV30 1QH O Ms Sheila Scott Muckle Hoose Birnie Elgin Moray IV30 8SW O Mr John McMahon 8 Urquhart Grove Elgin Moray IV30 8TB O Mr Jake Innes 13 Birnie Road Elgin Moray IV30 6JA O Carol Lillie 19 Waulkmill Road Elgin Moray IV30 6HJ O Mrs Sharon Thomson 36 Bailies Drive Elgin Moray IV30 6JJ O Ms Carin Bergdahl 19 Whinpark Circle Portlethen AB12 4SS O Mr Paul McMillan 2 Westerfolds Cottages Elgin Moray IV30 5RH O Ms Julie Clark 65 Golf View Crescent Elgin Moray IV30 6JP O Mr Peter Greenslade 5 Craiganroan Corner West High Street Portgordon Buckie Moray AB56 5TL O Miss Samantha Gauld 7 Beaufort Gate Elgin Moray IV30 8BL O Mrs Connie Torry Caberfeidh 32 Glenlossie Road Thomshill Elgin IV30 8GY O Miss Zoé Hood 144 South Victoria Dock Road Dundee DD1 3BF O Miss Kaitlyn Brown 41 Seafield Circle Buckie Moray AB56 5AD O Mr Ross Watson 41 Seafield Circle Buckie Moray AB56 5AD O Page 94
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Mrs Elizabeth Innes 57 Lairds Drive Clackmannan FK10 4EQ O Mrs Moira Green Easterton Farm Birnie Elgin Moray IV30 8SP O Mrs Rachel Watson 20 Linkwood Avenue Elgin Moray IV30 6LE O Mr Daniel Pegg 28 Royal Troon Drive Elgin Moray IV30 8BA O Miss Mel-lisa Robertson 27 Blackburn Road Mosstodloch Fochabers Moray IV32 7AG O Miss Catalina Thornton 27A High Street Grantown PH26 3EG O Miss Staci Taylor 28 Gordon Street New Elgin Elgin Moray IV30 6DA O Mr Jack Glass 26 Pinegrove Elgin Moray IV30 6HP O Mr John Thomson 22 Murray Road Inverness IV2 7LU O Mr Kevin Grimshaw 26 South Covesea Terrace Lossiemouth Moray IV31 6NA O Mrs Adrienne Black 11 Urquhart Grove Elgin Moray IV30 8TB O Ms Jennifer Penlington Woodside Cottage Elgin Moray IV30 8SE O Dawn Campbell 8 Carnoustie Way Elgin Moray IV30 6LQ O Ms Lucy Dolan Highland House Knockando Aberlour Moray AB38 7RP O Miss Ashley Aitken 52 Bailies Drive Elgin Moray IV30 6JJ O Mr Chris Low 14 Dove Avenue Elgin Moray IV30 6LG O Mr William Friend 74 Coulardhill Lossiemouth Moray IV31 6LD O Mrs Melanie Smith 40 Pinefield Crescent Elgin Moray IV30 6HZ O Mrs Kerry Anderson Dunmovin Rothes Aberlour Moray AB38 7AW O Mr James Higgins 4 Kingsbarns Lane Elgin Moray IV30 8BG O Mr Michael Calder 10 Birnie Drive Elgin Moray IV30 6JB O Mrs Carolyn Donlin 12 East Street Fochabers Moray IV32 7DS O Mr Craig Robertson 4 Rose Place Elgin Moray IV30 1NP O Mrs Val Fowles Birken Heights Wardend Birnie Elgin IV30 8RW O Mr Artur Pawlak 16 Dunnottar Road Elgin Moray IV30 8AG O Miss Anna H Waulkmill Road Elgin Moray IV30 6HJ O Page 95
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Mr Conner Petrie 12 Elmfield Road Elgin Moray IV30 6HQ O Mr John Thomson Glebe Cottage Birnie Elgin Moray IV30 8SU O Ms Marlyn Strachan 9 Turnberry Crescent Elgin Moray IV30 8BE O Mr George Jamieson 9 Turnberry Crescent Elgin Moray IV30 8BE O Mrs Helen Mansfield Glenmore Lochiepots Road Miltonduff Elgin IV30 8WL O Mr Darren Campbell 51 Glenlossie Drive Elgin Moray IV30 6YJ O Mr Bob Dumbell Rashcrook Cottage Birnie Elgin Moray IV30 8SW O Mrs Jen Gray Paddockhaugh Birnie Elgin Moray IV30 8SU O Leigh Moreton Caberfeidh 32 Glenlossie Road Thomshill Elgin Moray IV30 8GY O Mr Joe Sammons 8 Carnegie Court Elgin Moray IV30 8BF O Mrs Nikk Wood 16 Gullane Crescent Elgin Moray IV30 8BZ O Mrs Joanna Mcknockiter Balconie 6 Birnie Road Elgin Moray IV30 6DZ O Mr Craig Johnstone 9 Birnie Circle Elgin Moray IV30 6JD O Miss Rosemary Shand 27A High Street Grantown PH26 3EG O Mrs Edna Cameron 7 Forteath Avenue Elgin Moray IV30 1TQ O Miss Gill Garrow Ashgrove Birnie Elgin Moray IV30 8SW O Mr Angus MacDonald Margus Birnie Elgin Moray IV30 8SW O Mrs Julie Robertson 13 Leonach Place Elgin Moray IV30 6JT O Mr Philip Robertson 13 Leonach Place Elgin Moray IV30 6JT O Mr Grant Anderson 13 Leonach Place Elgin Moray IV30 6JT O Mr Aidan Roger 3 Leonach Crescent Elgin Moray IV30 6JS O Mr Innes Green Easterton Farm Birnie Elgin Moray IV30 8SP O Mr Simon Wakefield 5 Dover Street Portknockie Buckie Moray AB56 4LE O Mr Allan Sim 7 Glen Elgin Drive Elgin Moray IV30 6JH O Alan Archibald Birnie Elgin IV30 S Miss Gemma Scott 3 Tresillian Gardens Exeter EX4 7AJ O Page 96
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Anne Scudder No Address Provided O David Scott No Address Provided O Mrs Amelia Quilliam 22 Thornhill Drive Elgin Moray IV30 6GT O Miss Catherine Allan 19 Friar Street Perth PH2 0EG O Miss Jude Handley Sutherland Hall Lilleshall National Sports Centre Telford TF10 9AT O Mr Jason Gallon 10 Cawdor Avenue Elgin Moray IV30 8AH O Mr Ross Adam 9 Cawdor Avenue Elgin Moray IV30 8AH O Adele Park 40 Deanshaugh Terrace Elgin Moray IV30 4ET O Mr Michael Mylchreest 28 Bain Road Elgin Moray IV30 6GD O Mrs Mora Rothnie 43 Thornhill Drive Elgin Moray IV30 6GS O Mr David Ivory 26 Yellowhammer Drive Forres Moray IV36 2NX O Mr Callum Rae 73 Corrennie Circle Dyce Aberdeen AB21 7LD O Ms Lynn Morrison Greenspot Stables Oldmeldrum Inverurie AB51 0AG O Mr Kelvin Moreton 37 Tannachy Terrace Portgordon Buckie Moray AB56 5PF O Mr Richard Hutchison 8 Lochy Park View Longmorn Elgin Moray IV30 8UH O Mrs Claire Lumsden Lismore Lodge Muirton Road Lossiemouth Moray IV31 6TU O Mrs Anne Rodda Failte 23 Morriston Road Elgin Moray IV30 4EB O Miss Sophie Rowberry 21 Meadow Lane Nottingham NG9 5AA O Mr James Talbot 16 South Guildry Street Elgin Moray IV30 1QN O Mr Steven Connolly Hillview Deskford Buckie Moray AB56 5YB O Mrs Anushka Persad 6 Merryton Gardens Nairn IV12 5AG O Mr Daniel Scott 24 Hatherall Road Maidstone ME14 5HE O Mrs Pauline Laing 9 Carnegie Court Elgin Moray IV30 8BF O Mr Steve Christie 45 Mossend Place Elgin Moray IV30 6YB O Mr Chee Hew 20 Brucelands Elgin Moray IV30 1TS O Mrs Marie McCulloch 23 Cawdor Avenue Elgin Moray IV30 8AH O Page 97
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Mr Scott Coull 1C Fyvie Green Elgin Moray IV30 8AW O Mr James Wiseman 153 Edgar Road Elgin Moray IV30 6UQ O Mr Alan Smailes Woodlea Longmorn Elgin Moray IV30 8SL O Mr James Branson 129 Thornhill Road Elgin Moray IV30 6DX O Mrs Jennifer Curry 1 Lews Place Elgin Moray IV30 8AN O Mrs Kailie Walsh 3 Croft Place Craigellachie Aberlour Moray AB38 9TE O Mrs Elizabeth Gibson 2 Garliebank Crescent Cupar KY15 5JL O Mr David Mcmanus 47 Greenfield Circle Elgin Moray IV30 5NF O Mrs Helen Sheridan 9 Victoria Street Lossiemouth Moray IV31 6PU O Mr Matthew Carre 33 Bishops Court Lossiemouth Moray IV31 6TL O Miss Lauren Holmes 48 Fulmar Road Lossiemouth Moray IV31 6SY O Mrs Shirley McBride 15 Murieston Walk Livingston EH54 9EW O Miss Elizabeth Buck Little Withybush Farm Knowle Lane Cranleigh GU6 8JP O Imke Henderson 8 East Back Street Elgin Moray IV30 4EQ O Ms Donna Morrison 22 Mid Street Hopeman Elgin Moray IV30 5TF O Mr Tam Burns-Greenock 18 Conon Crescent Elgin Moray IV30 1SZ O Catherine Quinn Green Fields St Catherines Place Elgin Moray IV30 1TN O Mr Ross Macpherson 8 Dunnottar Road Elgin Moray IV30 8AG O Mrs Nanette Ogilvie 84 Thornhill Drive Elgin Moray IV30 6GT O Miss Kirsty Macgillivray 21 Mossend Place Elgin Moray IV30 6YB O Mr Greg Lister 8 Newfield Road Elgin Moray IV30 4DA O Miss Rhian Cameron 22 Fairway Avenue Elgin Moray IV30 6XF O Debbie Donaldson 6 Cawdor Avenue Elgin Moray IV30 8AH O Miss Rebecca Ray 3 Robertson Place Forres Moray IV36 1EU O Mr Innes McPherson 12 Balvenie Park Elgin Moray IV30 8AJ O Mr Lukasz Mezyk 6 Culzean Road Elgin Moray IV30 8TA O Page 98
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Mrs Yvonne Donaldson Ben Ryvoand Birnie Elgin Moray IV30 8RW O Mrs Christine Morrison Newfield Road Elgin IV30 4DA O Karen Thomson 4 Rashcrook Farm Birnie Elgin Moray IV30 8SW O Mr James Scott 10 Royal Troon Drive Elgin Moray IV30 8BA O Mrs Jennifer Simpson 10 Beechfield Road Elgin Moray IV30 6RT O Mrs Tracie France East Pittendreich Farm Cottages Elgin Moray IV30 8TE O Ms Andrea Fraser 9 Birch Avenue Elgin Moray IV30 5NE O Mr Angus Dixon Red Briars Elgin Moray IV30 8UD O Anne Davidson 8 Land Street Elgin Moray IV30 6BL O Mr Jamie Banks 8A Robertson Place Forres Moray IV36 1EU O Mr David Strachan 21 Cawdor Avenue Elgin Moray IV30 8AH O Miss Jenny Grant 5 Slains Drive Elgin Moray IV30 8AP O Mr Ethan Beaumont 3 Glassgreen Brae Elgin Moray IV30 6JF O Mr Edward Polese 3 Holyrood Drive Elgin Moray IV30 8TP O Dr Sarah-Anne Munoz 48 Holyrood Drive Elgin Moray IV30 8TP O Mr Russell Kessack 27 Nicol Street Elgin Moray IV30 6BU O Mr Russell Taylor Octril 8 The Muir Bogmoor Fochabers IV32 7PN O Mrs Kristen Mayne 30 Academy Street Elgin Moray IV30 1LP O Mrs Ella Adam 9 Cawdor Avenue Elgin Moray IV30 8AH O Mrs Rebecca Scott 15 Glamis Place Elgin Moray IV30 8UJ O Ms Kirsty Bowcutt 58 Brodie Drive Elgin Moray IV30 4LW O Mrs Wendy Taylor 1 Carnegie Court Elgin Moray IV30 8BF O Miss Mic MacDonald 2 Kingsbarns Lane Elgin Moray IV30 8BG O Mrs Lianne Foster 2 Jamieson Place Elgin Moray IV30 6FJ O Mr Mark Forsyth 15 Gleneagles Drive Elgin Moray IV30 6LP O Mrs Jacqueline O'Neill Braemar Cooper Street Hopeman Elgin IV30 5SD O Page 99
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Mr Stewart McIntyre 11 Scone Road Elgin Moray IV30 8AT O Mr Sean Sparey 22 West Queen Street Dundee DD5 1AR O Miss Kayleigh McCartney Doocot Court Elgin IV30 6LF O Mrs Heather Moir 9 Dove Avenue Elgin Moray IV30 6LG O Mr Mark Friend 12 Glassgreen Place Elgin Moray IV30 6JE O Miss Jackie Wiseman 105 Muirfield Road Elgin Moray IV30 6DD O Mr Darren Stewart 2 Cawdor Avenue Elgin Moray IV30 8AH O Zoe Fletcher 63 Fogwatt Lane Elgin Moray IV30 6GG O Mrs Brenda Watson Ardachaidh Glenlatterach Birnie Elgin IV30 8RR O Jackie Sawney 80 Chandlers Rise Elgin Moray IV30 4JE O Ms Lise Olsen 2 Glebe Park Dyke Forres Moray IV36 2WT O Mr Christopher O'Donnell Redwood Cottage Bridge Street Elgin Moray IV30 4DE O Mr J Smith 42 Batchen Street Elgin Moray IV30 1BH O Mr Paul Cater 9 Thornhill Court Elgin Moray IV30 6LY O Mr George Whitecross Deanscrook Lesmurdie Road Elgin Moray IV30 4BN O Mr Steve Elliott Heywoods Ridge Creamery House Audlem CW3 0EF O Mrs Karen Cole 4 Woodridge Newbury RG14 6NP O Mrs Claire Housden 4 Murcar Lane Elgin Moray IV30 8BY O Mr James Crombie The Mews Burnside House Duffus Elgin IV30 5QS O Mrs Beth Graham 11 Buckingham Road Newbury RG14 6DH O Mr William Grant Grangemeadow 2 Moray Place Elgin Moray IV30 1NR O Mr Robert McCallum 54 Holyrood Drive Elgin Moray IV30 8TP O Mrs Chris Tasker 21 Brodie Drive Elgin Moray IV30 4LS O Mrs Kaye Laing Brennach Birnie Elgin Moray IV30 8SW O Mr Paul Stephen 37 Haugh Road Elgin Moray IV30 1AR O Ms Samantha Langford 141 Balnageith Rise Forres Moray IV36 2HF O Page 100
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Mrs Lynley Beckett 79 Marleon Field Elgin Moray IV30 4GE O Mr Luke Foss 9F Shore Street Lossiemouth Moray IV31 6PB O Ms Angela Innes 9 Parkview Elgin Moray IV30 6NU O Mrs Caroline Watson Bracken Brae Glenlatterach Birnie Elgin Moray IV30 8RR O Mr Leslie Thomson Alta Monza Duffus Road Elgin Moray IV30 4NP O Mrs N Wade 34 Holyrood Drive Elgin Moray IV30 8TP O Mr David Easton 4 Seafield Crescent Elgin Moray IV30 1RE O Mrs Ulrike Walker 2 Fogwatt Crescent Elgin Moray IV30 6GX O Mr Kelvin Williams 5 Bisset Beat Elgin Moray IV30 8UG O Mrs Kathryn Larkworthy 44 Holyrood Drive Elgin Moray IV30 8TP O Michael Russell 49 Glenlossie Road Thomshill Elgin Moray IV30 8GY O Mrs Lisa Marshall 8 Eilean Donan Way Elgin Moray IV30 8TD O Mr Ronald Alexander Gillespie Betron Castlehill Birnie Elgin IV30 8SR O Mrs Lydia Koch The Lodge Wardend Fishery Birnie Elgin IV30 8RW O Kevin Koch The Lodge Wardend Fishery Birnie Elgin IV30 8RW O Mrs Margaret Wakefield 5 Dover Street Portknockie Buckie Moray AB56 4LE O Miss Katie Bromham 95 Macdonald Drive Lossiemouth IV31 6LU O Mrs Eleanor Gauld Mains Of Shougle Birnie Elgin Moray IV30 8RP O Mr Pete Deeming 59 Beils Brae Urquhart Elgin Moray IV30 8XQ O Mrs Alison Read Moravia Dunbar Street Lossiemouth Moray IV31 6RB O Mr Joseph Snitch 45 Ashfield Drive Elgin Moray IV30 6HF O Mr Ian Simpson Capercaillie South Lane Archiestown Aberlour AB38 7QQ O Mrs Laura Stuart 2 Dove Avenue Elgin Moray IV30 6LG O Mrs Toni Ferrier 11 Thornhill Road Elgin Moray IV30 6DY O Dr Robyn Geddes 33 Corse Wynd Corse Wynd Aberdeen AB15 8TP O Miss Piper Stewart 16 Birnie Circle Elgin Moray IV30 6JD O Page 101
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Ms Helen Roberts Hillview Deskford Buckie Moray AB56 5YB O Mrs Shirley Miller Darnley Miltonduff Elgin Moray IV30 8TL O Mr Brian Marden 83e Roxburgh Street Kelso TD5 7DS O Miss Claire McCarthy 15 Robertson Drive Elgin Moray IV30 6ET O Mr Paul Willis Silverbirch Birnie Elgin Moray IV30 8RW O Mrs Luci Milne 11 Leonach Place Elgin Moray IV30 6JT O Mrs Heather Stuart Twin Oaks 3 Lochview Grove Forres Moray IV36 2GR O Mr Fraser Moore 40 Fyvie Green Elgin Moray IV30 8AW O Mr Harrison Taylor Royal Air Force Lossiemouth Lossiemouth Moray IV31 6SD O Ms Brigid Aitken Thornhall Dyke Forres Moray IV36 2TL O Mr Sam Fraser Clinton House 68 South Guildry Street Elgin Moray IV30 1QN O Mr M Gillespie Henton Overend House Stinchcombe Dursley GL11 6AR O Mr Chris Macpherson 17 Linkwood Avenue Elgin Moray IV30 6LE O Mr William Grant 26 Lossiemouth Road Elgin Moray IV30 4JP O Mrs Adele Findlay 1 Gleneagles Drive Elgin Moray IV30 6LP O Mr Calum Wilson 16 Birnie Circle Elgin Moray IV30 6JD O Mrs Rebecca Dalkin Reynolds Crescent Elgin IV30 6TP O Mrs Elizabeth Ballantine 149 Scone Road Elgin Moray IV30 8BX O Mr John Churchill 5 Birnie Drive Elgin Moray IV30 6JB O Mrs Shelley Morrison 6 Duffus Place Elgin Moray IV30 5PB O Mrs Jessica Langford 30 Royal Troon Drive Elgin Moray IV30 8BA O Mrs Margarethe Elsegood 3 Dornoch Links Elgin Moray IV30 6LZ O Mrs Claire Scullion 10 Buick Drive, Arbroath DD11 5LF O Mrs Janice Hyndman 53 Springfield Road Elgin Moray IV30 6BZ O Mrs Aileen Stuart 17 Birnie Road Elgin Moray IV30 6JA O Mrs Susan Gillespie Castlehill Birnie Elgin Moray IV30 8SR O Page 102
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Mr Ronald Gordon Gillespie Castlehill Birnie Elgin Moray IV30 8SR O Ms Fiona Richardson 2 Milton of Straloch Newmachar AB21 0QE O Mr Matthew Spencer-Jones 139 Scone Road Elgin Moray IV30 8BX O Dorothy Jack 68 Hebenton Road Elgin Moray IV30 4ER O Mrs Rhoma Pirie Cruachan 2 Beils Brae Urquhart Elgin IV30 8XQ O Mr Patrick Crookes 17 Linkwood Court Elgin Moray IV30 6LD O Mr Reece Dalling 17 Sandstone Drive Elgin Moray IV30 6GW O Mrs Linda McMahon 8 Urquhart Grove Elgin Moray IV30 8TB O Mr Andrew Wallis The Grange Birnie Elgin Moray IV30 8SU O Mr Clifford Miller 38 Glenlossie Road Thomshill Elgin Moray IV30 8GY O Mr Ian Thomson Bracken Fell Birnie Elgin Moray IV30 8SP S Mrs Jackie Lister 8 Newfield Road Elgin Moray IV30 4DA O Mr Luke Groves 8 Ethel Fenwick Grove Elgin Moray IV30 4FS O Mr Anthony Brown Outfit Moray Shore Street Lossiemouth Moray IV31 6PB O Ms Nicola Hire Beechwood Elgin Moray IV30 8SE O Mrs Rachel J McClure Burnside Of Birnie Elgin Moray IV30 8SB O Mr Ian Duncan 5 Fairway Avenue Elgin Moray IV30 6XF S Mrs Debbie Reid The Cottage Birnie Elgin Moray IV30 8SW O Mr Daniel Simpson 2 Traynor Way Buckie Moray AB56 1FT O Mrs Jillian Johnston 1 Dunvegan Crescent Elgin Moray IV30 8AL O Miss Paige Jeffs Hangingfolds Birnie Elgin Moray IV30 8RP O Mr Duncan Strachan 15 Cawdor Avenue Elgin Moray IV30 8AH O Mr Martin Gillespie Castlehill Birnie Elgin Moray IV30 8SR O Mr David Stuart 17 Birnie Road Elgin Moray IV30 6JA O Mrs India Georgeson Craigievar 6 Petrie Crescent Elgin Moray IV30 1PE O Mr John Elkin 15 Dunbar Street Hopeman Elgin Moray IV30 5TD O Page 103
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Miss Gemma Norgate 40 Royal Troon Drive Elgin Moray IV30 8BA O Mr Kyle Juliao-Rumbles 34 Dunvegan Crescent Elgin Moray IV30 8AL O Mrs Lesley Russell Leddach Fogwatt Elgin Moray IV30 8SL O Ms Isla Cameron 18 Lussielaw Road Edinburgh EH9 3BX O Mrs Leigh Ritchie 33 Woodlands Crescent Elgin Moray IV30 4LY O Mr Max Fraser Brown 236 Califer Road Forres Moray IV36 1JE O Mrs Angela McCarthy Barholm Birnie Elgin Moray IV30 8SR O Mrs Valerie Regan 35 Brucelands Elgin Moray IV30 1TS O Mrs Carol Archibald 10 Fairway Avenue Elgin Moray IV30 6XF O Mrs Sandra Grant 18 Sandstone Drive Elgin Moray IV30 6GW O Mrs Karen Gerrie 35 Thornhill Drive Elgin Moray IV30 6GS O Cameron Coutts Ardmhor 18 Mannochmore Thomshill Elgin IV30 8GZ O Ian Richards No Address Provided O Miss Cara Weir 7 Ben Rinnes Walk Elgin Moray IV30 6YX O Ms Lindsay Belton 12 Forbes Court Shaw Place Elgin Moray IV30 1ZE O Mr Jan Oeschger Wardend Birnie Elgin Moray IV30 8RW O Mr Douglas Paul 12 Glen Elgin Drive Elgin Moray IV30 6JH O Ms Donna Sutherland 7 Eilean Donan Way Elgin Moray IV30 8TD O Mr Christopher Goulding 17 Cawdor Avenue Elgin Moray IV30 8AH O Mrs Erin Beaumont 3 Glassgreen Brae Elgin Moray IV30 6JF O Mrs Nicola Cochrane 8 Quarry Road Lossiemouth Moray IV31 6ND O Ms Shonagh MacDonald 207 Kingsmills Elgin Moray IV30 4BT O Miss Shena Blain 16 Sunbank Place Lossiemouth Moray IV31 6LS O Mr Mark Kullas 2 Level Farm Cottages Birnie Elgin Moray IV30 8SR O Mr Joel Charles 26 Cromarty Place Lossiemouth Moray IV31 6ST O Mr Lewis Walsh 58 Nairn Drive Bishopton PA7 5GE O Page 104
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Ms Karen McLean Riana Shore Street Lossiemouth Moray IV31 6PB O Mrs June Gray 12 Hillocks Way Lossiemouth Moray IV31 6HN O Miss Eve Thomson Coldbrook Cottage Birnie Elgin Moray IV30 8SR O Mr Tom Williams 8 Warrender Court North Berwick EH39 4RR O Cynthia Munro Denmoor Birnie Elgin Moray IV30 8SR O Barbara Allan Craigroy 22 Mannochmore Thomshill Elgin IV30 8GZ O Iain Allan Craigroy 22 Mannochmore Thomshill Elgin IV30 8GZ O Gordon Nicol Muckle Hoose Birnie Elgin Moray IV30 8SW O Emily Thomson Coldbrook Cottage Birnie Elgin Moray IV30 8SR O Mark Thomson Coldbrook Cottage Birnie Elgin Moray IV30 8SR O Colin McCarthy Barholm Birnie Elgin Moray IV30 8SR O Claire Thomson Coldbrook Cottage Birnie Elgin Moray IV30 8SR O Jill Geach 38 Glenlossie Road Thomshill Elgin Moray IV30 8GY O Mrs Natasha Sherwin 13 Findlater Lane Elgin Moray IV30 8AX O Mr Darren McConnachie 19 Cawdor Avenue Elgin Moray IV30 8AH O Helen Mutch Omega 13 Waterside Street Elgin Moray IV30 4LU O Mr Peter Goodwin 15 Sea Park Hopeman Elgin Moray IV30 5RY O Mr Alan Weston No Address Provided O Yvonne Milton 10 Leonach Crescent Elgin Moray IV30 6JS O Alan & Fiona Masson 18 Glen Elgin Drive Elgin Moray IV30 6JH O Mr David Swart Eastdale Longmorn Elgin Moray IV30 8SH O Mr Simon Phillips Westview 33 Sandy Road Elgin Moray IV30 6EG O Ms Jane Newsome Carding House Longmorn Elgin Moray IV30 8SN O Mr James Wilson Wardend Side Birnie Elgin Moray IV30 8SW O Mrs Irena Wilson Wardend Side Birnie Elgin Moray IV30 8SW O Mr Venkata Donkena 13 Grant Place Forres Moray IV36 1NJ O Page 105
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Linda Hinshelwood Triskele Birnie Elgin Moray IV30 8SW O Mrs Denise Turner 26 Holyrood Drive Elgin Moray IV30 8TP O Mrs Louise Brown 28 Russell Place Elgin Moray IV30 4PJ O Mrs Alexis Robinson 16 Mannachie Rise Forres Moray IV36 2US O Mrs Lesley Williamson 26A North Street Bishopmill Elgin Moray IV30 4EF O Mrs Fiona Dey The Schoolhouse Knockando Road Dallas Forres IV36 2RZ O Mr Graeme Duffus 14 Fairway Avenue Elgin Moray IV30 6XF O Mrs Debbie Thomson 4 Gleneagles Drive Elgin Moray IV30 6LP O Mrs Shannon Munro 26 Glenesk Road Lhanbryde Elgin Moray IV30 8PW O Mrs Tracy Stirling Clear View Inverugie Road Hopeman Elgin IV30 5SX O Miss Claire Macleay 37 Muirfield Road Elgin Moray IV30 6DB O Mrs Shelley Oneill 32 Holyrood Drive Elgin Moray IV30 8TP O Miss Louise Milne 13 Birnie Road Elgin Moray IV30 6JA O Ms Nicola Donald 3 Murray Street Elgin Moray IV30 6DT O Mrs Alison Clark Main Street Elgin IV30 6BH O Mr Ronald Rae Flat 0/2 10 Sutcliffe Court Glasgow G13 1AP O Miss Charlie Welsh Rashcrook Farmhouse Birnie Elgin Moray IV30 8SW O Mr Steve Cockburn 9 Eilean Donan Way Elgin Moray IV30 8TD O Mrs Jessica Owen 4 Park Road Faringdon SN7 7BT O Mrs Mandy Doherty 14 Burnbank Fochabers Moray IV32 7EQ O Mrs Louise Sutherland The Brae Dunbar Street Lossiemouth Moray IV31 6AL O Mrs Rachel Grant Blackfriars Cottage 1 Blackfriars Road Elgin Moray IV30 1TY O Mrs Laura Peden 29 Holyrood Drive Elgin Moray IV30 8TP O Mrs Susan Watson Still View Birnie Elgin Moray IV30 8SR O Mr Brian Robertson Leanochmor Elgin Moray IV30 8TS O Amy Wiggins Easterton Wood Cottage Birnie Elgin Moray IV30 8SP O Page 106
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Mr Craig McConnachie McCallan House Birnie Elgin Moray IV30 8ST O Miss Heather Moreton 73 Corrennie Circle Dyce Aberdeen AB21 7LD O Mrs Margaret Kinsman The Birches Culbokie IV7 8JP O Mrs Fiona Steele Braeview 17 Mannochmore Thomshill Elgin IV30 8GZ O Miss R M 78 Knockomie Gardens Forres Moray IV36 2TN O Mr Ruairidh Steele 96 Bailies Drive Elgin Moray IV30 6JJ O Ms Rachel Robertson 42 Pinefield Crescent Elgin Moray IV30 6HZ O Mrs Freda Chalmers 40 Gordon Street New Elgin Elgin Moray IV30 6EF O Miss Hayley Campbell Hangingfolds Birnie Elgin Moray IV30 8RP O Miss Michelle Russell 49 Glenlossie Road Thomshill Elgin Moray IV30 8GY O Mrs Amanda Kingham 16 Spey Avenue Fochabers Moray IV32 7QR O James Purdew Struan Cottage Moss Street Aberlour Moray AB38 7QN O Mrs Sam Inch 43 Chandlers Rise Elgin Moray IV30 4JB O Mr Andrew Bentley Arduthie 33 St Andrews Road Lhanbryde Elgin IV30 8PU O Mr Sean Thomson 32 Dunvegan Crescent Elgin Moray IV30 8AL O Mr Anthony Tanner Sonas Birnie Elgin Moray IV30 8SU O Mrs Kay McBride 13 Fraser Drive Aberdeen AB32 6FA O Mrs Morag Reid The Neuk North Darkland Elgin Moray IV30 8LB O Mrs Jacqui Mitchell 133 Scone Road Elgin Moray IV30 8BX O Mr Adrian Bonnington 137 Scone Road Elgin Moray IV30 8BX O Mrs Sharon Hatch Elgin View Birnie Elgin Moray IV30 8SW O Mr Rickie Rogers Wardend View Birnie Elgin Moray IV30 8RW O Mr Maciej Holowiecki 19 Carnoustie Drive Corby NN17 5GP O Mrs Caroline Holland 70 Braxted Park London SW16 3AU O Mrs Pat Milligan 3 Bankton Cottage Tranent EH33 1NG O Miss Jodie Wilson 31 Bain Avenue Elgin Moray IV30 6GB O Page 107
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Miss Rhianne Sutherland 9 Smithfield Place Lossiemouth Moray IV31 6DG O Kelly Gammack 1 Longmorn Crescent Elgin Moray IV30 6GP O Mrs Laura McKenzie 22 Inchbroom Avenue Lossiemouth Moray IV31 6HJ O Mrs June Angus 85 Wards Road Elgin Moray IV30 1TE O Mrs Jacqueline Russell 49 Glenlossie Road Thomshill Elgin Moray IV30 8GY O Miss Jackie Macleod 32 Croft Road Elgin Moray IV30 6DR O Mr Martin Touzel Braefiddich Craigellachie Aberlour Moray AB38 9RR O Mrs Caroline Stickings 31 Lakeway Retreat DAWESVILLE 6211 O Mr Sam Wiggins Easterton Wood Cottage Birnie Elgin Moray IV30 8SP O Mrs Claire Farthing 27 Packer Road Kettering NN15 7RP O Mrs Harriet Walker 8 Rose Place Elgin Moray IV30 1NP O Dr Marek Wolanski Bethel Birnie Elgin Moray IV30 8RW O Mr Scott Mathieson 14 Turnberry Crescent Elgin Moray IV30 8BE O Mrs Sara Marsh 2 Findrassie Crescent Elgin Moray IV30 6AR O Mrs Fiona Dunbar 5 Troon Place Elgin Moray IV30 6LR O Mrs Morva Leslie 18 Birnie Drive Elgin Moray IV30 6JB O Miss Kiera Green 32 Dunvegan Crescent Elgin Moray IV30 8AL O Mr Robert Stewart 27 Royal Troon Drive Elgin Moray IV30 8BA O June Fearnley No Address Provided O Kathleen Hobson No Address Provided O Miss Naomi Fraser 6 Glassgreen Brae Elgin Moray IV30 6JF O Mrs Lauren Stewart 56 Holyrood Drive Elgin Moray IV30 8TP O Mr Michael McDonald 10 Eilean Donan Way Elgin Moray IV30 8TD O Mrs Anne Wibberly Cheznous 14 Mannochmore Thomshill Elgin Moray IV30 8GZ O Lorna J Coutts 1 St Catherines Place Elgin Moray IV30 1TN O Ruth Anderson 38 Bailies Drive Elgin Moray IV30 6JJ O Page 108
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Patricia Harper Windsong Birnie Elgin Moray IV30 8SR O Mr Alistair Harper Windsong Birnie Elgin Moray IV30 8SR O J L Athol Munro Denmoor Birnie Elgin Moray IV30 8SR O Mr Andrew Kelly Denarii Birnie Elgin Moray IV30 8SR O Janice Johnson Paddockhaugh Cottage Birnie Elgin Moray IV30 8SU O Lorraine Kelly Denarii Birnie Elgin Moray IV30 8SR O Moray Archery Archery Centre Level Farm Birnie Elgin Moray IV30 8SR O Mrs Andrea Fyvie 15 Glassgreen Brae Elgin Moray IV30 6JF O Dr Ruth McCullough 2 Dunvegan Crescent Elgin Moray IV30 8AL O Mr Scott Anderson 4 King Street Lossiemouth Moray IV31 6QA O Diane Stuart Parkview Elgin Moray IV30 8ND O Mr Jordan Little 105 Muirfield Road Elgin Moray IV30 6DD O Mr Dan Rae 73 Corrennie Circle Dyce Aberdeen AB21 7LD O Mrs Renee Milne 40 Spynie Street Elgin Moray IV30 4JS O Dr Andrej Andrasovsky 3 Birch Avenue Elgin Moray IV30 5NE O Stephanie Burgess 6 Urquhart Grove Elgin Moray IV30 8TB O Mr William Thomson Bracken Fell Birnie Elgin Moray IV30 8SP S Mr Wayne Chisholm 65 Golf View Crescent Elgin Moray IV30 6JP O Mr Anthony Falkingham Finlarig Rafford Forres Moray IV36 2RU O Mrs Lisa Allan 12 Fogwatt Crescent Elgin Moray IV30 6GX O Mr Paul Stephenson 3 Urquhart Grove Elgin Moray IV30 8TB O Mr Graham Rodgers 5 Woodburn Court Darvel KA17 0DJ O Ms Stephanie Waddell 2 Cloddymoss Kintessack Forres Moray IV36 2TG O Mr Stephen Hull 14 Mannachie Rise Forres Moray IV36 2US O Mrs Victoria Cranna 16 Glen Elgin Drive Elgin Moray IV30 6JH O Mrs Susan Glass The Meadows Roseisle Elgin Moray IV30 8XN O Page 109
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Mr Robert Pera 4 Balvenie Park Elgin Moray IV30 8AJ O Mrs Rachel Moultonn 17 Sandy Road Elgin Moray IV30 6EQ O Mr Campbell McNeill 30 Bain Avenue Elgin Moray IV30 6GB O Miss Louise Marshall 18 Royal Troon Drive Elgin Moray IV30 8BA O Mrs Fiona Cunningham 10 Fogwatt Crescent Elgin Moray IV30 6GX O Mrs Hannah May 12 Covesea Grove Elgin Moray IV30 4PP O Mrs Margaret Mubro 23 South Covesea Terrace Lossiemouth Moray IV31 6NA O Mrs Christine Elliott Heywoods Ridge Creamery House Audlem CW3 0EF O Mr Sam Jarockyj 41 Glenlossie Road Thomshill Elgin Moray IV30 8GY O Mr Roy Taylor 1 Carnegie Court Elgin Moray IV30 8BF O Mr Jan Wolanski Bethel Birnie Elgin Moray IV30 8RW O Mrs Carol Daglish 9 Springfield Gardens Elgin Moray IV30 6XX O Geraldine Bohler No Address Provided O Krystle Bentley No Address Provided O Miss Courtney Scott The Beeches Enzie Buckie Moray AB56 5BJ O Mrs Anne MacMillan 21 Orchy Gardens Oban PA34 4JR O Mr John MacMillan 21 Orchy Gardens Oban PA34 4JR O Mrs Shelley Cater 9 Thornhill Court Elgin Moray IV30 6LY O Mr David Cairns 3 Benriach Cottages Elgin Moray IV30 8SF O Mrs Mary Baker Bramble Corner The Firs Inkpen Hungerford RG17 9PT O Mrs Julie Brander 10 Balvenie Park Elgin Moray IV30 8AJ O Mrs Rosamund Johnson-Borg Aitendow 12 Mannochmore Thomshill Elgin IV30 8GZ O Mrs Maureen Macpherson 17 Linkwood Avenue Elgin Moray IV30 6LE O Mr Andrew Edgar Belgrave Mansions 12 Belgrave Terrace Aberdeen AB25 2NS O Ms Kayleigh Gordon 82 Hardhillock Avenue Elgin Moray IV30 6UG O Miss Kirsty McCulloch 2 Level Farm Cottages Birnie Elgin Moray IV30 8SR O Page 110
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Mrs Linda McCulloch 46 Eemins Place Elgin Moray IV30 4PA O Mr Eric Borg Aitendow 12 Mannochmore Thomshill Elgin IV30 8GZ O Mr Angus Macdonald 20 Red Craig Drive Burghead Elgin Moray IV30 5ZF O Mrs Julia Moreton Caberfeidh 32 Glenlossie Road Thomshill Elgin IV30 8GY O Mrs Sarah Stewart 10 Bisset Beat Elgin Moray IV30 8UG O Shirley Jackson Mingulay Birkenhill Elgin Moray IV30 8SB O Mrs Isla Whyte 2 Holyrood Drive Elgin Moray IV30 8TP O Mr Michael Duncan 26 Mannochmore Thomshill Elgin Moray IV30 8GZ O Mr Andrew Fyvie 15 Glassgreen Brae Elgin Moray IV30 6JF O Mr Christopher Watson Still View Birnie Elgin Moray IV30 8SR O Mr Innes Manson 32 Scone Road Elgin Moray IV30 8AT O Mrs Fiona Howie 64 Spynie Street Elgin Moray IV30 4JS O Mrs Clare Fraser 5 Glassgreen Place Elgin Moray IV30 6JE O Mrs Julie Ralph 20 Fairway Avenue Elgin Moray IV30 6XF O Mrs Caryn Tadeusz 9 Marina Quay Pitgaveny Street Lossiemouth Moray IV31 6TJ O Miss Stephanie Turner 21 Clayknowes Drive Musselburgh EH21 6UW O Mrs Emma-Louise Thomas 25 Moray Street Lossiemouth Moray IV31 6JD O Ms Robyn Mitchell The Cairn Birnie Elgin IV30 8SW O Heather Main 26 Lossiemouth Road Elgin Moray IV30 4JP O Mrs Sandra Wilson 2 The Mews Springfield Gardens Elgin Moray IV30 6UX O Mr Corvin Kelly Denarii Birnie Elgin Moray IV30 8SR O Mrs Amy Greenwood 12 Leonach Crescent Elgin Moray IV30 6JS O Mrs Allyson Conacher Firbank Meikle Wartle Inverurie AB51 5AA O Miss Kirsten Steele Flat 10 2 North Street New Elgin Elgin IV30 6BS O Mr S Thomson Scone Road Elgin Moray IV30 8BX O Mrs Mary Findlay 4 Cawdor Avenue Elgin Moray IV30 8AH O Page 111
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Mr Duncan Fyvie 1 Ardfin Walk Elgin Moray IV30 8BD O Mr Andrew Whyte 2 Holyrood Drive Elgin Moray IV30 8TP O Mrs Ellie Fraser 4 Sandstone Drive Elgin Moray IV30 6GW O Mr Brandon Ironside 2A Morriston Road Elgin Moray IV30 4EB O Mrs Tracey Bavidge 12 Turnberry Crescent Elgin Moray IV30 8BE O Mrs Nicola Duncan 26 Mannochmore Thomshill Elgin Moray IV30 8GZ O Ms Clare Crocker 83e Roxburgh Street Kelso TD5 7DS O Mrs Shirley Smith c/o 39 Robertson Drive New Elgin Elgin IV30 6ET O Mr Derek McGaw Rivendell Alves Elgin Moray IV30 8XF O Mr Sean Buckle 9 Camperdown Road Nairn IV12 5AR O Mr David Black 11 Golf View Crescent Elgin Moray IV30 6JP O Mr Calum Cass 29 Pinefield Crescent Elgin Moray IV30 6HZ O Miss Hollie McBride 2 Cawdor Avenue Elgin Moray IV30 8AH O Mrs Kersey Whyte 147 Scone Road Elgin Moray IV30 8BX O Mr Gary Wright 43 Robertson Drive Elgin Moray IV30 6ET O Ms Dianne Fraser Bridgeale House Craigievar Alford AB33 8JR O Miss Rosemary Pook 42 Fyvie Green Elgin Moray IV30 8AW O Mr John Stuart Parkview Elgin Moray IV30 8ND O Mrs Leonie Trehearne 130 Craven Road Newbury RG14 5NR O Mr Stevie Milne 20 Glen Elgin Drive Elgin Moray IV30 6JH O Mrs Agnes Martin 21 Bailielands Linlithgow EH49 7ST O Mr Cameron Waters 37 Balmoral Terrace Elgin Moray IV30 4JH O Mrs Andrea Szabo 13 Bain Avenue Elgin Moray IV30 6GB O Mr Cieran Geddes 1 Kingsbarns Lane Elgin Moray IV30 8BG O Miss Emily McAuslan 1 Kingsbarns Lane Elgin Moray IV30 8BG O Mrs Melissa Smith 15 Leonach Crescent Elgin Moray IV30 6JS O Page 112
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Mrs Clare Hogan 21 St Aethans Road Burghead Elgin Moray IV30 5YR O Mrs Helen Scott 10 Royal Troon Drive Elgin Moray IV30 8BA O Miss Aimee Stephen 1C Fyvie Green Elgin Moray IV30 8AW O Mrs Jo Little Kirkside Birnie Elgin Moray IV30 8SU O Mr Ian Howland 15 Urquhart Grove Elgin Moray IV30 8TB O Graham Gillespie 20 Birnie Circle Elgin Moray IV30 6JD O Ms Gail Williams West Rescobie 29 West Road Elgin Moray IV30 1SA O Mr Leslie Thompson 8 Dornoch Links Elgin Moray IV30 6LZ O Kian Coutts Ardmhor 18 Mannochmore Thomshill Elgin IV30 8GZ O Miss Lily Duncan 26 Mannochmore Thomshill Elgin Moray IV30 8GZ O Mr Richard Ralph 6 Fairway Avenue Elgin Moray IV30 6XF O Mrs Jodi Davidson 6 Blairfindy Drive Elgin Moray IV30 8BU O Mrs Alannah Higgins 6 Royal Troon Drive Elgin Moray IV30 8BA O Mr Andrew McDonald 36 Anderson Drive Elgin Moray IV30 6EN O Mrs Elsie Galt 1 Lodge Park Fort William Road Newtonmore PH20 1AB O Mr Matthew O'Neill 32 Holyrood Drive Elgin Moray IV30 8TP O Mrs Sandra Logan Sgor Dearg 47 Glenlossie Road Thomshill Elgin IV30 8GY O Elizabeth Duncan Briar Cottage 13 Hawthorn Road Elgin Moray IV30 1PG O Mr Reece Mellis 143 Scone Road Elgin Moray IV30 8BX O Mr Ian Leslie 32 Golf View Crescent Elgin Moray IV30 6JP O Mr Josh Davidson Leamington 3 Seafield Crescent Elgin Moray IV30 1RE O Mrs Karen Thomson Rashcrook Equestrian Rashcrook Farm Birnie Elgin IV30 8SW O Miss Blair Johnston 28 Birnie Place Elgin Moray IV30 6EB O Thomas And Jane Bryson 14 Gullane Crescent Elgin Moray IV30 8BZ O Kathleen And Alan Hobson Hobson No Address Provided O Page 113
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Mr Mike Alexander 9 Deanshaugh Road Elgin Moray IV30 4JA O Mrs Maureen Low 14 Dove Avenue Elgin Moray IV30 6LG O David Ireland 86 Chandlers Rise Elgin Moray IV30 4JE O Mrs Sarah Bulloch 46 Clifton Road Lossiemouth Moray IV31 6DP O Mr Jamie Alsamarraie 7 Crathes Court Elgin Moray IV30 8TR O Carol Wallis The Grange Elgin Moray IV30 8SU O Mr William Logan Sgor Dearg 47 Glenlossie Road Thomshill Elgin IV30 8GY O Mrs Elizabeth Morran 20 Alford Drive Glenrothes Fife O Ms Tracy Moeller 17 Glassgreen Brae Elgin Moray IV30 6JF O Ms Sarah Riley-Evans 36 Holyrood Drive Elgin Moray IV30 8TP O Ms Lisa Brook 40 Deanshaugh Terrace Elgin Moray IV30 4ET O Mrs Margaret Rollo 1 Glen Elgin Drive Elgin Moray IV30 6JH O Mrs Diane Maciver 11 Chandlers Rise Elgin Moray IV30 4JB O Mr Steven Morrice 2 Dornoch Links Elgin Moray IV30 6LZ O Mrs Paula Baker 18 Main Street Buckie Moray AB56 1XQ O Mr Owen Buckley 30 Doocot Court Elgin Moray IV30 6LF O Mrs Donna Watson 46 Glenlossie Road Thomshill Elgin Moray IV30 8GY O Chris Hall 20 Birnie Road Elgin Moray IV30 6EA O Miss Caitlyn McGilly 26 King Street New Elgin Elgin Moray IV30 6BX O Mrs Lynn Scott 24 Hatherall Road Maidstone ME14 5HE O Miss Samantha Ryder 44 Glenlossie Road Thomshill Elgin Moray IV30 8GY O Miss Ashlie McBride 2 Cawdor Avenue Elgin Moray IV30 8AH O Joan Hall 20 Birnie Road Elgin Moray IV30 6EA O Mrs D Kerr 31 Birnie Crescent Elgin Moray IV30 6JG O Mrs Victoria Mullings 69 High Street Buckie Moray AB56 1AX O Mrs Nadia Blatt Newlands Of Easterton Farmhouse Newlands Of Birnie Birnie Elgin IV30 8SW O Page 114
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Miss Catherine Mccready 5 Anderson Drive Elgin Moray IV30 6EW O Mrs Alison Mclean 13 Birnie Circle Elgin Moray IV30 6JD O Mr Logan Young 17 Glassgreen Brae Elgin Moray IV30 6JF O Ms Gail Mcy 12 Stonecrosshill Elgin Moray IV30 6HS O Mr Alistair Watson 46 Glenlossie Road Thomshill Elgin Moray IV30 8GY O Mr Russell Findlay 47 Cawdor Avenue Elgin Moray IV30 8AH O Mrs Lyndsay Noon Scottish Archery Ingliston Showground Newbridge EH28 8NB O Kathryn Seabrook 1 Fogwatt Crescent Elgin Moray IV30 6GX O Mr Jim Talbot 16 South Guildry Street Elgin Moray IV30 1QN O Mrs Wendy King 6 Brinuth Place Elgin Moray IV30 6YW O Miss Frances Campbell 65 Kingsmills Elgin Moray IV30 4BX O Mrs Morag Ralph 6 Fairway Avenue Elgin Moray IV30 6XF O Mr Steven Milne Elgin Golf Club Elgin Moray IV30 8SX O Mrs Nicola McIntosh 1 Ewing Howe Elgin Moray IV30 6FN O Mrs Jacquelyn Grant 23 Dove Court Elgin Moray IV30 6LH O Mr Craig Johnston 2 Sandstone Place Elgin Moray IV30 6LL O Mrs Amelia Stewart 27 Royal Troon Drive Elgin Moray IV30 8BA O Mrs Jean Lee Cedarwood 42 Glenlossie Road Thomshill Elgin IV30 8GY O Mrs Julie Stuart 23 Birnie Place Mosstodloch Fochabers Moray IV32 7JW O Mrs Doris Anderson Newlands Of Easterton Farmhouse Newlands Of Birnie Birnie Elgin IV30 8SW O Iain Bruce No Address Provided O Katherine Allsop No Address Provided O Mr Ayub Makda 8 Ennerdale Road Dewsbury WF12 7NE O Bruce Park Glen-darren Birnie Elgin Moray IV30 8SW O Miss Lou Gaines 12 Thornhill Drive Elgin Moray IV30 6GT O Miriam Haywood 5 Carnegie Court Elgin Moray IV30 8BF O Page 115
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Eilidh Coutts Ardmhor 18 Mannochmore Thomshill Elgin IV30 8GZ O Mr Danny Stuart 5 Corgarff Road Elgin Moray IV30 8BH O Ms Morven Ferguson 8 Doocot Court Elgin Moray IV30 6LF O Ms Isla Gray 49 Glenlossie Drive Elgin Moray IV30 6YJ O Mrs Kaley Stevenson 25 Esmonde Gardens Elgin Moray IV30 4LB O Mrs Ashley Russell 13 Glamis Place Elgin Moray IV30 8UJ O Dr Jennifer Mcclay Westlye 16A Mid Street Hopeman Elgin IV30 5TF O Ms Judy Light 18 Findhorn Forres Moray IV36 3YE O Jenni Milligan 22 Kintrae Rise Elgin Moray IV30 5ND O Miss Karen Johnston 151 Scone Road Elgin Moray IV30 8BX O Mrs Karen Yeats Culdeen Longmorn Elgin Moray IV30 8SH O Dr Alex McClure Burnside Of Birnie Elgin Moray IV30 8SB O Miss Georgia Morrison 84 Woodlands Drive Lhanbryde Elgin Moray IV30 8JU O Mr Stuart Mackenzie 5 Leonach Place Elgin Moray IV30 6JT O Mrs Pauline Wickens Northview Birnie Elgin Moray IV30 8RR O Mr Christopher Forbes 14 Royal Troon Drive Elgin Moray IV30 8BA O Ian MacDonald 102 Maes Ty Gwyn Llangennech SA14 8XW O Dawn Lockey Loch View Birnie Elgin Moray IV30 8RW O Mr Michael Sinclair 14 Burnside Way Balmedie AB23 8XW O Mrs Laura McLean-Begg 6 Murcar Lane Elgin Moray IV30 8BY O Mr Graham Morrison 79 Springfield Drive Elgin Moray IV30 6XZ O Mrs Averil Cockburn 9 Eilean Donan Way Elgin Moray IV30 8TD O Mr Steven Valentine Foths Farmhouse Birnie Elgin Moray IV30 8ST O Mrs Jacqueline Stewart Cabrach Cottage Cummingston Elgin Moray IV30 5XY O Mrs Sharon Wooller Pitchaidlie Place Fordyce AB45 2SY O Mrs Jeanette Green 18 Linkwood Avenue Elgin Moray IV30 6LE O Page 116
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Mr William Waddell 21 St Gerardines Road Lossiemouth Moray IV31 6JX O Mr Gareth Yea 82 Farquhar Street Hopeman Elgin Moray IV30 5SL O Mrs Nikki Lees 3 Abbotsford Gardens Pluscarden Road Elgin Moray IV30 1YF O Mrs Amy Tough 3 Glassgreen Place Elgin Moray IV30 6JE O Mrs Andrea Grierson Ivybank Bridge Street Elgin Moray IV30 4DE O Ms Suzanne Auld 54 Bailies Drive Elgin Moray IV30 6JJ O Mrs Kara Lobban 57 Hossack Drive Elgin Moray IV30 6JY O Mrs Evelyn Harper 31 Harald Drive Thurso KW14 8JH O Mrs Anna Wolanska Bethel Birnie Elgin Moray IV30 8RW O Mrs Kerry Turkington-Glass 80 Spynie Street Elgin Moray IV30 4LX O Mrs Diane Mitchell 1 Carnoustie Way Elgin Moray IV30 6LQ O Mr Callum Reid 35 Glenlossie Road Thomshill Elgin Moray IV30 8GY O Mrs Melanie Munro-Newlands 8 Kirkton Place Elgin Moray IV30 6JR O Mr Ian Moore 4A Gordon Street Elgin Moray IV30 1JQ O Mr Magnus Green Easterton Farm Birnie Elgin Moray IV30 8SP O Mr Christopher Tack 22 Duart Way Elgin Moray IV30 8AY O Mrs Sarah Anderson 13 Leonach Place Elgin Moray IV30 6JT O Rebecca Hutchison 8 Lochy Park View Longmorn Elgin Moray IV30 8UH O Mrs Hannah Cradock Birchwood Birnie Elgin Moray IV30 8SW O Mrs Andrea Robinson Swansree Mosstowie Elgin Moray IV30 8XE O Brian Yeats Culdeen Longmorn Elgin Moray IV30 8SH O Mr David Mansfield Glenmore Lochiepots Road Miltonduff Elgin IV30 8WL O Mrs Karen Touzel Braefiddich Craigellachie Aberlour Moray AB38 9RR O Miss Katrina Macneill 7 Waulkmill Grove Elgin Moray IV30 6HR O Mr George Watson Ardachaidh Glenlatterach Birnie Elgin IV30 8RR O Miss Amy Wakefield 27 Ladysbridge Cottages Banff AB45 2JR O Page 117
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Ms ML4RVV9T Gill 30 Birnie Road Elgin Moray IV30 6EA O Joyce Hawley Blawearie 20 Mannochmore Thomshill Elgin IV30 8GZ O Michael Hawley Blawearie 20 Mannochmore Thomshill Elgin IV30 8GZ O Mrs Lynn Fyvie 10 Leonach Place Elgin Moray IV30 6JT O Mrs Amanda Willox 28 Linkwood Court Elgin Moray IV30 6LD O Mrs Hart-Alison 40 Glenlossie Road Thomshill Elgin Moray IV30 8GY O Lesley Miller Pendennis 21 Forteath Avenue Elgin Moray IV30 1TF O Stephen Marsh 2 Findrassie Crescent Elgin Moray IV30 6AR O Mrs Gillian Boag Rose Cottage 11 Greyfriars Street Elgin Moray IV30 1LF O Miss Charlotte Turner 2/1 King Street Edinburgh EH6 6TN O Mr Darren Munro 6 Dunvegan Crescent Elgin Moray IV30 8AL O Mr George Stewart 56 Holyrood Drive Elgin Moray IV30 8TP O Mr Callum Watson 20 Linkwood Avenue Elgin Moray IV30 6LE O Mr Ed Fennell 42 Newlands Drive Portlethen AB12 4LX O Mrs Sheila Bennett Bonniview Birnie Elgin Moray IV30 8RP O Mrs Jacqui Alexander 9 Deanshaugh Road Elgin Moray IV30 4JA O Miss Ellah Reader Roburn 43 Glenlossie Road Thomshill Elgin IV30 8GY O Ms Amanda Strang 5 Birnie Circle Elgin Moray IV30 6JD O Mrs Claire O'Shane 8 Bisset Beat Elgin Moray IV30 8UG O Moira Nuttall 1 Bridge Street Portknockie Buckie Moray AB56 4LG O Miss Martyna Wolanska 35 Jasmine Drive Elgin Moray IV30 8BS O Mrs Susan Hull Clachmadadh Craigellachie Aberlour Moray AB38 9SQ O Miss Louise Vanzetta 2 Cowfords Cottages Mosstodloch Fochabers Moray IV32 7LJ O Mrs Lucy Scott 109 Macdonald Drive Lossiemouth Moray IV31 6LU O Mr Christopher O'Neill Braemar Cooper Street Hopeman Elgin IV30 5SD O Clare Harwood 19 Braemorriston Road Elgin Moray IV30 4DT O Page 118
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Mrs Stephanie Shirt-Gould Thornwell Roseisle Elgin Moray IV30 5YF O Miss Emily Michie 6 Forbes Court Shaw Place Elgin Moray IV30 1ZE O Mrs Patricia Brown 236 Califer Road Forres Moray IV36 1JE O Mrs Nicola Henry 2 Tower Street Selkirk TD7 4LR O Grace Taylor 14 Bisset Beat Elgin Moray IV30 8UG O Miss Aleisha Kelman 16 Moravia Apartments Elgin Moray IV30 6LN O Mr Richard Turner 16 Sandstone Place Elgin Moray IV30 6LL O Mr Alan Turner 13 High School Drive Elgin Moray IV30 6UE O Mr Leo McPherson 80 Bailies Drive Elgin Moray IV30 6JJ O Mr Gary Groves Greenwards Nr Brinie Elgin IV30 8SW O Mr Andy Beck 44 Glenlossie Road Thomshill Elgin Moray IV30 8GY O Maisie-Cate Kerr 63 Thornhill Road Elgin Moray IV30 6DX O Mr Paul Lloyd Brewer 15 Meadow Gardens Hopeman Elgin Moray IV30 5PN O Mrs Fiona Pellegrom 4 Duffus Place Elgin Moray IV30 5PB O Patricia Grant 10 Blairfindy Drive Elgin Moray IV30 8BU O Mr Alexander Yeats Roburn 43 Glenlossie Road Thomshill Elgin IV30 8GY O Jordan Legge Stynie Orchard Mosstodloch IV32 7LE O John Kelly 43 Birnie Place Elgin Moray IV30 6EB O Mr Kenny Martin 12 Macroberts Reply Lossiemouth Moray IV31 6TR O Miss Stephanie Collie 58 Rosebank Terrace Aberdeen AB11 6LP O Roy Ballantine No Address Provided O Albert Bohler No Address Provided O Rachel Swinglehurst-Hewkin 17 Glenlossie Road Thomshill Elgin Moray IV30 8GY O Mrs Kirsti Sinikka Paterson Covesea House Wester Covesea Duffus Elgin IV30 5QS O Mr Les Thomson 4 Rashcrook Farm Birnie Elgin Moray IV30 8SW O Mr Christopher Wallis 1 Chapel Walk Adderley Street Uppingham LE15 9NE O Page 119
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Mr Andrew Thomas 16 Dunvegan Crescent Elgin Moray IV30 8AL O Diane Hampton 77 High Street Rothes Aberlour Moray AB38 7AY O Mr George Innes Lower Falls Mosstowie Elgin Moray IV30 8TU O Mr Michael Ray 1 Birnie Road Elgin Moray IV30 6JA O Mr Michael Ogg 2 Slains Drive Elgin Moray IV30 8AP O Mr Mark Kinsman The Birches Culbokie IV7 8JP O Mr Ian MacKay 68 Duncan Drive Elgin Moray IV30 4NH O Mrs Laura Macpherson 8 Dunnottar Road Elgin Moray IV30 8AG O Mr Matthew Peden 8 Culzean Road Elgin Moray IV30 8TA O Miss Ashleigh Ralph 3 Auchindoun Way Elgin Moray IV30 8BJ O Caroline Maddams Stonewells Farm Elgin Moray IV30 8NF O Mrs Sandra Downing Kathadie Glen Elgin Road Longmorn Elgin IV30 8SZ O Mrs Michelle Cumming 25 Linkwood Court Elgin Moray IV30 6LD O Mr Ross Urquhart 36 Cathedral Road Elgin Moray IV30 1HQ O Mrs Linda Craig 14 Clarendon Court Elgin Moray IV30 6TA O Miss Oona Borg Aitendow 12 Mannochmore Thomshill Elgin IV30 8GZ O David Swart 21 Brechan Rig Elgin Moray IV30 6FL O Mrs Alice Mount Upper Atcombe Farm Stroud GL5 5HR O Mr Trevor Collery 9 Leonach Crescent Elgin Moray IV30 6JS O Mr Sean Thomson 41 Ashgrove Place Elgin Moray IV30 1UJ O Mr Andrew Kelly Denarii Glenlossie road, Birnie Elgin IV30 8SR O Mr Tony Mitchell Barn Owl Cottage Moss Side Nairn IV12 5NZ O JL Athol Munro Denmoor Birnie Elgin Moray IV30 8SR O Mr Michael Scott 15 Glamis Place Elgin Moray IV30 8UJ O Mrs Veronica Watson 20 Pelstream Avenue Stirling FK7 0BE O Mr Howard Johnson Dunure 10 Duff Avenue Elgin Moray IV30 1QS O Page 120
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Mr Terence Lee Cedarwood 42 Glenlossie Road Thomshill Elgin IV30 8GY O Mr Christopher Walis 28 the Orchard Market Deeping PE6 8JS O Mrs Carol Maclennan 86 Thornhill Drive Elgin Moray IV30 6GT O Mrs Debbie MacMillan 7 Caroline Street Elgin Moray IV30 4DP O Mr David Fraser 3 Brora Way Elgin Moray IV30 8DB O Paul Duke Cairnduna St Aethans Road Burghead Elgin IV30 5US O Mrs Fiona Ridley Caberfeidh 32 Glenlossie Road Thomshill Elgin Moray IV30 8GY O Mrs Patricia Brown 4 Riddock Gardens Forres Moray IV36 2QE O Mr Ron Cameron 64 McIntosh Drive Elgin Moray IV30 6AW R Krystle Ross Spring Tyne Birnie Elgin Moray IV30 8SW O Mrs Anne Scudder 6 Mannochmore Thomshill Elgin Moray IV30 8GZ O Miss Rachel Foster 20 Linkwood Avenue Elgin Moray IV30 6LE O Mrs Heather Crawford 13 Stillmans Wynd Elgin Moray IV30 8AD O Mrs Donna Kerr 31 Birnie Crescent Elgin IV30 6JG O Ms Audrey West 15 Fountain Park Banff AB45 1JS O Mr James Craig 14 Clarendon Court Elgin Moray IV30 6TA O Page 121
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