Fiona Thompson - Aberdeenshire · 7th May 2015 . Dear Sir/Madam . I write in regard to the...
Transcript of Fiona Thompson - Aberdeenshire · 7th May 2015 . Dear Sir/Madam . I write in regard to the...
1
Fiona Thompson
From:Sent: 07 May 2015 21:41To: LDPSubject: Representation for Blackburn
We would like to comment on plans for housing at site OP1 at Blackburn, which is behind our house in Craig Gardens. We would expect to be provided with minimum 6ft fencing for security and privacy. We would also like to ask that the new housing plans are considerate to existing housing in the area, with no houses directly overlooking our property and not too close to our boundary. The houses in this area have been here for many years and we are disappointed that new housing is being planned for the field behind our house. Also, it might be beneficial to have access to our property from the back garden, via the current field. Houses 1‐3 Craig Gardens currently have no access from the back, but his might be useful. We would prefer no through road directly behind our property for privacy and noise reasons. Regards,
Infrastructure Services
Planning and Building Standards
Woodhill House
Westburn Road
Aberdeen
AB16 5GB
7th May 2015
Dear Sir/Madam
I write in regard to the Aberdeenshire Local Development Plan 2016 for the proposal for
development at OP3 Portsoy Bridge Street. I wish to make my view known that I have a concern that
the land outlined is not suitable for the development of homes.
The notification states that up to 125 homes will be built on the site. This is a considerably large
number of houses for a site that has been identified as a flood risk area. As a resident of a property
adjacent to the site, I am concerned that my home and surrounding homes will be at risk of flooding
or other issues associated with poor drainage. Indeed it is unknown what other problems might arise
due to the stress of the addition of so many houses.
Furthermore, I believe that because of the layout of water pipes and such, this concern will not only
be restricted to property surrounding the area but, in fact, other homes in Portsoy, particularly
beside Loch Soy and towards the conservation area.
Yours faithfully
Traffic management such as restrictions on access to Hill of Banchory West to larger vehicles would not only assist in stopping the Raemoir Road/Hill of Banchory West junction from being blocked but would alleviate safety concerns about the risk these vehicles present negotiating this junction. Road markings such as box junctions may also assist in keeping access to nearby residential streets clear when traffic does become backed up. Also, consideration should be made to the speed limit in the area along with traffic calming measures, particularly with the site being designated for an educational facility. Furthermore, traffic directed from Raemoir Road to the site may avoid turning onto Hill of Banchory West so as to avoid having to negotiate leaving this busy junction on return back onto Raemoir Road. Consideration should be made to ensure this traffic does not use residential streets off Raemoir Road as drop off/collection points. Extra traffic on the residential streets would not only hinder residents travel along these streets and access to properties, but also presents an increased risk to the inevitable increase of pedestrians in these areas. It should be noted that residents’ privacy would also be impacted due to the increase in traffic and pedestrians in the area and design proposals should be configured to distribute these increases sparsely. Development that reduces the need to travel by car should be promoted. Infrastructure and facilities should be provided to encourage active travel or travel by public transport. The site is currently in immediate proximity to the Loch of Leys Local Nature Conservation Area. This area is also home to a wide variety of wildlife not least deer, red squirrels, birds and bats. The scale of developments in this area has the potential to impact on local biodiversity and habitats. The site at present is a wonderful facility to encourage and facilitate a healthy lifestyle. There is presently a lack of recreation facilities in close proximity and the proposal will have a significant adverse effect on recreation interests, including uses of core paths and other established access for walking and cycling. Any development should improve and enhance existing strategic walking and cycling networks in a way which creates opportunities for improvements to the natural environment by linking habitats and species in green areas. Accessible green networks create a high quality environment, particularly in built-up areas. Connected areas of green space and habitats such as parks, paths and woodlands within and on the edge of our towns can provide a range of social, ecological and economic benefits. The trees of this woodland are an important feature and contribute to the overall character of the area. Should the site be developed it would be imperative to leave trees encircling the development to maintain the outlook of the area and protect and enhance green infrastructure. This landscape buffer strip would be particularly crucial between the site and the conservation area but would also facilitate retention of popular woodland paths in the area. Preservation of the existing trees surrounding the site would further benefit the conservation area and neighbouring sites by screening them from the inevitable noises that come from an educational facility during and outwith operating hours. If the existing trees are incompatible with the development plan, suitable screening trees should be planted between the proposed and neighbouring sites at the earliest opportunity. This would give time for the trees to mature and provide some degree of screening from the sights and noise during development of the site. Landscaping, means of enclosure, layout of building design with visual appearance and finishing materials will all further affect the impact of development of this site to neighbouring sites. Should the proposed development plan be approved on this site, consultations on these issues with neighbours should be held as a priority.
Control of opening hours to the educational facility and its’ grounds will greatly influence how much the development will impact local residents. Late opening hours could lead to congregations of people in the area which may cause nuisance and be particularly intimidating to vulnerable groups. On the contrary, open access to the development grounds for use by the public could provide a beneficial recreational facility for neighbouring residents. Lighting of the facility should be controlled so as to minimise light pollution onto the neighbouring sites and into neighbouring homes. Again, appropriate screening of the facility and control of operating/lighting hours will manage disturbance of light that may particularly affect residents with homes overlooking the development site and those who study the night sky from neighbouring sites. Thank you for the opportunity to submit our contribution to this planning application and we look forward to continued involvement regarding protection of this site and its neighbouring lands. Kind regards,
Please use this form to make comments on the Proposed Aberdeenshire Local Development 2016. If you are making comments about more than one topic it would be very helpful if you could fill in a separate form for each comment.
Please email or send the form to reach us by 8th May 2015 at the following address:
Post: Planning Policy Team Infrastructure ServicesAberdeenshire CouncilWoodhill HouseWestburn RoadABERDEENAB16 5GB
Email: [email protected]
Title
First name
Surname
Date
Postal Address
Postcode
Telephone Number
Are you happy to receive future correspondence only by email - Yes No
Are you responding on behalf of another person? Yes No
If yes who are you representing
YOUR DETAILS
An acknowledgement will be sent to this address soon after the close of consultation.
Please provide us with your comments below. Please feel free to add any extra pages you may require. We will summarise comments and in our analysis will consider every point that is made. Once we have done this we will write back to you with Aberdeenshire Council’s views on the submissions made. We will publish your name as the author of the comment, but will not make your address public.
YOUR COMMENTS
Modification that you wish to see
Reason for change
re. Local Development Plan 2016 Settlement Statements Formartine Pages 47-50 re. Newburgh Area OP2 Knockhall Road These plans require a new "distributor" road above the St Clair estate.
We are unhappy with this development on the grounds that we expect traffic problems to arise which have not been given sufficient attention. There are two areas of concern. One is increased congestion around the church hall where the roads are already narrow and very busy, especially with nursery and primary school children and also a considerable proportion of elderly residents. The other is increased traffic on St Clair Wynd which we expect will be used by residents and delivery drivers of the new development in their frustration at the inevitable traffic problems around the church hall. There are bound to be delays at the junction of Knockhall Road and Main Street; this will encourage drivers to use St Clair Wynd which was not designed for such increased traffic movement, and is not fit for this purpose. St Clair Wynd benefits now from a 20mph zone, speed bumps and narrowed areas; nevertheless drivers can already be seen driving there inconsiderately and at excessive speed. The Formartine Area Committee and numerous other parties are very clear that the present road structure and the proposed minor enhancements by Scotia Homes are completely inadequate; hence the convincing (9 votes to 2) refusal of Full Planning Permission. The only satisfactory means by which this traffic issue can be remedied is the construction of a new "distributor" road above the St Clair estate and it seems that all parties involved agree with this, but are not prepared to build it. The Scottish Reporter has acknowledged this difficulty but seems to override it. Yours faithfully,
Aberdeenshire Local Development Plan: Proposed Plan Consultation Barratt North Scotland: Policy H1 Housing Land
May 2015
Contents
Modifications Sought to the Proposed Plan
1.0 Introduction and Executive Summary
2.0 Policy H1: Housing Land Supply
Scottish Planning Policy (SPP)
Housing Supply / Sites
Site Cap on Unit Numbers
3.0 Summary
Modifications Sought to the Proposed Plan
Aberdeenshire Local Development Plan: Proposed Plan Consultation Barratt North Scotland: Policy H1 Housing Land
May 2015
Modifications Sought to the Proposed Plan
• Increase the housing supply target by 10 to 20% to ensure a generous
supply.
• A robust review to be included on the deliverability of allocated sites to
assess their effectiveness.
• Allocation of additional sites to replace the housing numbers that cannot
be delivered during the plan period.
• Remove the cap on the unit numbers provided in Appendix 5 and
settlement statements clearly being indicated for guidance only.
1.0 Introduction and Executive Summary
1.1 Kirkwood Homes are based in Aberdeenshire and have constructed many houses
within the area and wish to see Aberdeenshire continue to prosper through the
confidence that a Development Plan led system can deliver to the business sector
and all local stakeholders.
1.2 Having reviewed the Proposed Plan we acknowledge that the Settlement Strategy
generally reflects that of the Strategic Development Plan (SDP). However, along
with much of the development industry, Barratt North Scotland continue to have
serious reservations regarding the Housing Land Supply and the failure of the Plan
to conform with the Strategic Development Plan and Scottish Planning Policy.
1.3 The Local Development Plan (LDP) review process suggests that new land
allocations are not required, largely due to the scale of housing allowance proposed
by the Aberdeen City and Shire Strategic Development Plan 2014.
1.4 We promote the position that there will be a requirement to compensate for
ineffective sites and large sites that are being delivered at a considerably slower
rate of progress than anticipated, primarily due to long lead in times and consumer
demand for range and choice.
1.5 We have also assessed the plan in light of recently updated statements of
Government Policy in Scottish Planning Policy (SPP) which of course stresses the
need to deliver rather than just allocate housing land. The SPP also introduces a
10 to 20% margin of flexibility to the overall housing supply target in order to
ensure that a generous supply of land for housing is provided.
Aberdeenshire Local Development Plan: Proposed Plan Consultation Barratt North Scotland: Policy H1 Housing Land
May 2015
2.0 Policy H1: Housing Land Supply
2.1 There has been a clear failure of the extant LDP to deliver the housing land
requirements set by the approved SDP. These issues were highlighted by various
housebuilders in response to the Main Issues Report (MIR) and again in response
to the MIR Addendum.
2.2 These responses explained the need for the Council to undertake a robust exercise
to accompany the LDP to test the effectiveness and deliverability of all land which is
assumed to meet the housing requirement and to allocate further land as
necessary to meet the full 10-year life span of the Plan. No such exercise has been
undertaken.
2.3 This supply is further constrained by the cap imposed on the number of units that
can be developed on allocated sites, regardless of the size of the site. That is
contrary to SPP and SDP Guidance and should be removed. The cap on the
number of units provided in Appendix 5 and the Settlement Statements should be
for guidance only.
Scottish Planning Policy (SPP)
2.4 SPP clearly focuses on the delivery of sustainable development and in particular,
the delivery of housing in specified Plan periods. Paragraph 115 requires Plans to
set out the housing supply target for each functional housing market area based on
evidence from the Housing Needs & Demand Assessment. It advises that the
housing supply target is a policy view of the number of homes the authority has
agreed will be delivered in each Housing Market Area over the periods of the
Development Plan and Local Housing Strategy.
2.5 The subsequent paragraph 116 requires that within the overall housing supply
target, Plans should indicate the number of new homes to be built over the Plan
period. Paragraph 116 is unequivocal in stating that this figure should be
increased by a margin of 10 to 20% to establish the housing land requirement, in
order to ensure that a generous supply of land for housing is being provided. The
exact extent of the margin will depend on local circumstances but a robust
explanation for it should be provided for in the plan.
2.6 Whilst paragraph 118 states that Strategic Development Plans should set out the
housing supply target and the housing land requirement for the area, page 2 of the
Aberdeenshire Local Development Plan: Proposed Plan Consultation Barratt North Scotland: Policy H1 Housing Land
May 2015
SPP confirms that where development plans and proposals accord with this SPP
their progress through the planning system should be smoother.
2.7 As a statement of Ministers’ priorities, the content of SPP is a material
consideration that carries significant weight and the LDP should therefore reflect
the need for an additional 10 to 20% and not await the next review of the SDP
which will merely confirm this position. Para 2.14 confirms the basis as to how the
percentage figure can be established.
Housing Supply / Sites
2.8 In allocating sites, paragraph 119 of the SPP advises that Planning Authorities
should be confident that land can be brought forward for development within the
Plan period and that the range of sites allocated will enable the housing supply
target to be met.
2.9 Planning Authorities therefore must ensure that those sites can be delivered and
houses built within the Plan period. If that cannot be achieved, as is clearly the case
in the AHMA, additional sites must be allocated. This is essential to ensure there
are no difficulties with delivering housing later in the Plan period.
2.10 The Council’s fallback position is of course the 2014 Housing Land Audit, which
highlights a supply in excess of 5 years in the AHMA. However, that calculation
masks the failure of the Local Development Plan to deliver housing in the 2012 –
2016 period. As an example, that part of the Aberdeen Housing Market Area
falling within Aberdeenshire was allocated 5,000 units by the Strategic
Development Plan for the period 2012-2016. The extant Local Development Plan
identified sites to accommodate 4,751 units, yet only 1,451 units are expected to
be delivered by the end of 2016. This results in the failure to deliver 3,549 units in
the Aberdeenshire part of the Aberdeen Housing Market Area in the period to
2016.
2.11 The extant Local Development Plan advocated a drawdown mechanism to take
sites forward from the 2017-2021 period to address any shortfall. Unfortunately,
the Plan’s reliance on large sites to deliver the housing requirement means that
this approach has not been possible as the majority of potential drawdown sites
are Phase 2 elements of these larger sites. If the first phase is not delivering the
second phase certainly cannot.
Aberdeenshire Local Development Plan: Proposed Plan Consultation Barratt North Scotland: Policy H1 Housing Land
May 2015
2.12 As way of an example, the new settlement at Chapelton of Elsick was expected to
deliver 1,845 units in the period 2012-2016, but in actual fact will have delivered
only 270 units based on the draft 2015 Housing Land Audit figures. As a
consequence, the 2,200 houses allocated on that site for the period 2017-2026
cannot be delivered until the balance of 1,575 units has been built. Similar
scenarios exist throughout the Aberdeen Housing Market Area.
2.13 The only way this can be resolved is through the allocation of additional sites which
are capable of early implementation to ensure that housing is delivered within the
time periods specified by the SDP.
2.14 The failure of the Local Development Plan to deliver the required housing within the
specified Plan periods is compounded by an increased demand for housing.
Revised household projections, published in July 2014, identified a higher
requirement for the period 2017-2026 than set out in Figure 10 of the Strategic
Development Plan. This, in itself, justified a review of the housing allocations to
ensure a generous land supply capable of addressing the increased housing
requirement. As stated in paragraph 2.7 above, this is required by SPP.
2.15 Furthermore, analysis undertaken in responding to the MIR Addendum indicated
that there was a significant imbalance between the City and Shire in terms of the
effective supply with the Shire relying on the City to deliver the bulk of the post-5
year effective supply. To address this, various third party responses to the MIR
Addendum concluded that the housing land supply in the Aberdeenshire part of the
Aberdeen Housing Market Area should be increased by over 2,800 units.
2.16 On the basis of the above, and given the focus on delivery of housing within the SPP,
there is a compelling case for the allocation of additional smaller scale and
deliverable housing sites through the Local Development Plan 2016. It is
disappointing that the Proposed Plan does not take this forward.
Site Cap on Unit Numbers
2.17 A further means to help address the shortfall is to remove the cap placed on the
number of units that can be developed from allocated sites. There is absolutely no
justification for this cap. SPP imposes a presumption in favour of development that
contributes to sustainable development. This requires that policies and decisions
should be guided by giving due weight to economic benefit; making efficient use of
existing capacities of land, buildings and infrastructure; and, supporting the delivery
Aberdeenshire Local Development Plan: Proposed Plan Consultation Barratt North Scotland: Policy H1 Housing Land
May 2015
of accessible housing. The Strategic Development Plan is also perfectly clear that
“…land brought forward for development must be used efficiently”. It also
highlights the need to invest in both existing and new infrastructure to ensure the
area has enough people, homes and jobs to support the level of service and
facilities needed to maintain and improve the quality of life.
2.18 The true capacity of sites can only ever be determined through detailed design. At
Plan preparation stage it can be no more than an estimate based on an average
density. Given the fact that roads, drainage and other infrastructure will have been
provided to facilitate the allocated number of units, if a site is capable of delivering
more units, the developers should be allowed to utilise that infrastructure to ensure
that the maximum benefit accrues from that investment. The numbers allocated to
specific development sites through the Plan should be no more than a guide.
3.0 Summary
3.1 We would respectfully request that the following modifications are made to the
Proposed Plan.
Modifications Sought to the Proposed Plan
• Increase the housing supply target by 10 to 20% to ensure a generous
supply.
• A robust review to be included on the deliverability of allocated sites to
assess their effectiveness.
• Allocation of additional sites to replace the housing numbers that cannot
be delivered during the plan period.
• Remove the cap on the unit numbers provided in Appendix 5 and
settlement statements clearly being indicated for guidance only.
Aberdeenshire Local Development Plan: Proposed Plan Consultation Barratt North Scotland: Policy H1 Housing Land
May 2015
Contents
Modifications Sought to the Proposed Plan
1.0 Introduction and Executive Summary
2.0 Policy H1: Housing Land Supply
Scottish Planning Policy (SPP)
Housing Supply / Sites
Site Cap on Unit Numbers
3.0 Summary
Modifications Sought to the Proposed Plan
Aberdeenshire Local Development Plan: Proposed Plan Consultation Barratt North Scotland: Policy H1 Housing Land
May 2015
Modifications Sought to the Proposed Plan
• Increase the housing supply target by 10 to 20% to ensure a generous
supply.
• A robust review to be included on the deliverability of allocated sites to
assess their effectiveness.
• Allocation of additional sites to replace the housing numbers that cannot
be delivered during the plan period.
• Remove the cap on the unit numbers provided in Appendix 5 and
settlement statements clearly being indicated for guidance only.
1.0 Introduction and Executive Summary
1.1 Kirkwood Homes are based in Aberdeenshire and have constructed many houses
within the area and wish to see Aberdeenshire continue to prosper through the
confidence that a Development Plan led system can deliver to the business sector
and all local stakeholders.
1.2 Having reviewed the Proposed Plan we acknowledge that the Settlement Strategy
generally reflects that of the Strategic Development Plan (SDP). However, along
with much of the development industry, Barratt North Scotland continue to have
serious reservations regarding the Housing Land Supply and the failure of the Plan
to conform with the Strategic Development Plan and Scottish Planning Policy.
1.3 The Local Development Plan (LDP) review process suggests that new land
allocations are not required, largely due to the scale of housing allowance proposed
by the Aberdeen City and Shire Strategic Development Plan 2014.
1.4 We promote the position that there will be a requirement to compensate for
ineffective sites and large sites that are being delivered at a considerably slower
rate of progress than anticipated, primarily due to long lead in times and consumer
demand for range and choice.
1.5 We have also assessed the plan in light of recently updated statements of
Government Policy in Scottish Planning Policy (SPP) which of course stresses the
need to deliver rather than just allocate housing land. The SPP also introduces a
10 to 20% margin of flexibility to the overall housing supply target in order to
ensure that a generous supply of land for housing is provided.
Aberdeenshire Local Development Plan: Proposed Plan Consultation Barratt North Scotland: Policy H1 Housing Land
May 2015
2.0 Policy H1: Housing Land Supply
2.1 There has been a clear failure of the extant LDP to deliver the housing land
requirements set by the approved SDP. These issues were highlighted by various
housebuilders in response to the Main Issues Report (MIR) and again in response
to the MIR Addendum.
2.2 These responses explained the need for the Council to undertake a robust exercise
to accompany the LDP to test the effectiveness and deliverability of all land which is
assumed to meet the housing requirement and to allocate further land as
necessary to meet the full 10-year life span of the Plan. No such exercise has been
undertaken.
2.3 This supply is further constrained by the cap imposed on the number of units that
can be developed on allocated sites, regardless of the size of the site. That is
contrary to SPP and SDP Guidance and should be removed. The cap on the
number of units provided in Appendix 5 and the Settlement Statements should be
for guidance only.
Scottish Planning Policy (SPP)
2.4 SPP clearly focuses on the delivery of sustainable development and in particular,
the delivery of housing in specified Plan periods. Paragraph 115 requires Plans to
set out the housing supply target for each functional housing market area based on
evidence from the Housing Needs & Demand Assessment. It advises that the
housing supply target is a policy view of the number of homes the authority has
agreed will be delivered in each Housing Market Area over the periods of the
Development Plan and Local Housing Strategy.
2.5 The subsequent paragraph 116 requires that within the overall housing supply
target, Plans should indicate the number of new homes to be built over the Plan
period. Paragraph 116 is unequivocal in stating that this figure should be
increased by a margin of 10 to 20% to establish the housing land requirement, in
order to ensure that a generous supply of land for housing is being provided. The
exact extent of the margin will depend on local circumstances but a robust
explanation for it should be provided for in the plan.
2.6 Whilst paragraph 118 states that Strategic Development Plans should set out the
housing supply target and the housing land requirement for the area, page 2 of the
Aberdeenshire Local Development Plan: Proposed Plan Consultation Barratt North Scotland: Policy H1 Housing Land
May 2015
SPP confirms that where development plans and proposals accord with this SPP
their progress through the planning system should be smoother.
2.7 As a statement of Ministers’ priorities, the content of SPP is a material
consideration that carries significant weight and the LDP should therefore reflect
the need for an additional 10 to 20% and not await the next review of the SDP
which will merely confirm this position. Para 2.14 confirms the basis as to how the
percentage figure can be established.
Housing Supply / Sites
2.8 In allocating sites, paragraph 119 of the SPP advises that Planning Authorities
should be confident that land can be brought forward for development within the
Plan period and that the range of sites allocated will enable the housing supply
target to be met.
2.9 Planning Authorities therefore must ensure that those sites can be delivered and
houses built within the Plan period. If that cannot be achieved, as is clearly the case
in the AHMA, additional sites must be allocated. This is essential to ensure there
are no difficulties with delivering housing later in the Plan period.
2.10 The Council’s fallback position is of course the 2014 Housing Land Audit, which
highlights a supply in excess of 5 years in the AHMA. However, that calculation
masks the failure of the Local Development Plan to deliver housing in the 2012 –
2016 period. As an example, that part of the Aberdeen Housing Market Area
falling within Aberdeenshire was allocated 5,000 units by the Strategic
Development Plan for the period 2012-2016. The extant Local Development Plan
identified sites to accommodate 4,751 units, yet only 1,451 units are expected to
be delivered by the end of 2016. This results in the failure to deliver 3,549 units in
the Aberdeenshire part of the Aberdeen Housing Market Area in the period to
2016.
2.11 The extant Local Development Plan advocated a drawdown mechanism to take
sites forward from the 2017-2021 period to address any shortfall. Unfortunately,
the Plan’s reliance on large sites to deliver the housing requirement means that
this approach has not been possible as the majority of potential drawdown sites
are Phase 2 elements of these larger sites. If the first phase is not delivering the
second phase certainly cannot.
Aberdeenshire Local Development Plan: Proposed Plan Consultation Barratt North Scotland: Policy H1 Housing Land
May 2015
2.12 As way of an example, the new settlement at Chapelton of Elsick was expected to
deliver 1,845 units in the period 2012-2016, but in actual fact will have delivered
only 270 units based on the draft 2015 Housing Land Audit figures. As a
consequence, the 2,200 houses allocated on that site for the period 2017-2026
cannot be delivered until the balance of 1,575 units has been built. Similar
scenarios exist throughout the Aberdeen Housing Market Area.
2.13 The only way this can be resolved is through the allocation of additional sites which
are capable of early implementation to ensure that housing is delivered within the
time periods specified by the SDP.
2.14 The failure of the Local Development Plan to deliver the required housing within the
specified Plan periods is compounded by an increased demand for housing.
Revised household projections, published in July 2014, identified a higher
requirement for the period 2017-2026 than set out in Figure 10 of the Strategic
Development Plan. This, in itself, justified a review of the housing allocations to
ensure a generous land supply capable of addressing the increased housing
requirement. As stated in paragraph 2.7 above, this is required by SPP.
2.15 Furthermore, analysis undertaken in responding to the MIR Addendum indicated
that there was a significant imbalance between the City and Shire in terms of the
effective supply with the Shire relying on the City to deliver the bulk of the post-5
year effective supply. To address this, various third party responses to the MIR
Addendum concluded that the housing land supply in the Aberdeenshire part of the
Aberdeen Housing Market Area should be increased by over 2,800 units.
2.16 On the basis of the above, and given the focus on delivery of housing within the SPP,
there is a compelling case for the allocation of additional smaller scale and
deliverable housing sites through the Local Development Plan 2016. It is
disappointing that the Proposed Plan does not take this forward.
Site Cap on Unit Numbers
2.17 A further means to help address the shortfall is to remove the cap placed on the
number of units that can be developed from allocated sites. There is absolutely no
justification for this cap. SPP imposes a presumption in favour of development that
contributes to sustainable development. This requires that policies and decisions
should be guided by giving due weight to economic benefit; making efficient use of
existing capacities of land, buildings and infrastructure; and, supporting the delivery
Aberdeenshire Local Development Plan: Proposed Plan Consultation Barratt North Scotland: Policy H1 Housing Land
May 2015
of accessible housing. The Strategic Development Plan is also perfectly clear that
“…land brought forward for development must be used efficiently”. It also
highlights the need to invest in both existing and new infrastructure to ensure the
area has enough people, homes and jobs to support the level of service and
facilities needed to maintain and improve the quality of life.
2.18 The true capacity of sites can only ever be determined through detailed design. At
Plan preparation stage it can be no more than an estimate based on an average
density. Given the fact that roads, drainage and other infrastructure will have been
provided to facilitate the allocated number of units, if a site is capable of delivering
more units, the developers should be allowed to utilise that infrastructure to ensure
that the maximum benefit accrues from that investment. The numbers allocated to
specific development sites through the Plan should be no more than a guide.
3.0 Summary
3.1 We would respectfully request that the following modifications are made to the
Proposed Plan.
Modifications Sought to the Proposed Plan
• Increase the housing supply target by 10 to 20% to ensure a generous
supply.
• A robust review to be included on the deliverability of allocated sites to
assess their effectiveness.
• Allocation of additional sites to replace the housing numbers that cannot
be delivered during the plan period.
• Remove the cap on the unit numbers provided in Appendix 5 and
settlement statements clearly being indicated for guidance only.
Aberdeenshire Local Development Plan: Proposed Plan Consultation Barratt North Scotland: Policy H1 Housing Land
May 2015
Contents
Modifications Sought to the Proposed Plan
1.0 Introduction and Executive Summary
2.0 Policy H1: Housing Land Supply
Scottish Planning Policy (SPP)
Housing Supply / Sites
Site Cap on Unit Numbers
3.0 Summary
Modifications Sought to the Proposed Plan
Aberdeenshire Local Development Plan: Proposed Plan Consultation Barratt North Scotland: Policy H1 Housing Land
May 2015
Modifications Sought to the Proposed Plan
• Increase the housing supply target by 10 to 20% to ensure a generous
supply.
• A robust review to be included on the deliverability of allocated sites to
assess their effectiveness.
• Allocation of additional sites to replace the housing numbers that cannot
be delivered during the plan period.
• Remove the cap on the unit numbers provided in Appendix 5 and
settlement statements clearly being indicated for guidance only.
1.0 Introduction and Executive Summary
1.1 Kirkwood Homes are based in Aberdeenshire and have constructed many houses
within the area and wish to see Aberdeenshire continue to prosper through the
confidence that a Development Plan led system can deliver to the business sector
and all local stakeholders.
1.2 Having reviewed the Proposed Plan we acknowledge that the Settlement Strategy
generally reflects that of the Strategic Development Plan (SDP). However, along
with much of the development industry, Barratt North Scotland continue to have
serious reservations regarding the Housing Land Supply and the failure of the Plan
to conform with the Strategic Development Plan and Scottish Planning Policy.
1.3 The Local Development Plan (LDP) review process suggests that new land
allocations are not required, largely due to the scale of housing allowance proposed
by the Aberdeen City and Shire Strategic Development Plan 2014.
1.4 We promote the position that there will be a requirement to compensate for
ineffective sites and large sites that are being delivered at a considerably slower
rate of progress than anticipated, primarily due to long lead in times and consumer
demand for range and choice.
1.5 We have also assessed the plan in light of recently updated statements of
Government Policy in Scottish Planning Policy (SPP) which of course stresses the
need to deliver rather than just allocate housing land. The SPP also introduces a
10 to 20% margin of flexibility to the overall housing supply target in order to
ensure that a generous supply of land for housing is provided.
Aberdeenshire Local Development Plan: Proposed Plan Consultation Barratt North Scotland: Policy H1 Housing Land
May 2015
2.0 Policy H1: Housing Land Supply
2.1 There has been a clear failure of the extant LDP to deliver the housing land
requirements set by the approved SDP. These issues were highlighted by various
housebuilders in response to the Main Issues Report (MIR) and again in response
to the MIR Addendum.
2.2 These responses explained the need for the Council to undertake a robust exercise
to accompany the LDP to test the effectiveness and deliverability of all land which is
assumed to meet the housing requirement and to allocate further land as
necessary to meet the full 10-year life span of the Plan. No such exercise has been
undertaken.
2.3 This supply is further constrained by the cap imposed on the number of units that
can be developed on allocated sites, regardless of the size of the site. That is
contrary to SPP and SDP Guidance and should be removed. The cap on the
number of units provided in Appendix 5 and the Settlement Statements should be
for guidance only.
Scottish Planning Policy (SPP)
2.4 SPP clearly focuses on the delivery of sustainable development and in particular,
the delivery of housing in specified Plan periods. Paragraph 115 requires Plans to
set out the housing supply target for each functional housing market area based on
evidence from the Housing Needs & Demand Assessment. It advises that the
housing supply target is a policy view of the number of homes the authority has
agreed will be delivered in each Housing Market Area over the periods of the
Development Plan and Local Housing Strategy.
2.5 The subsequent paragraph 116 requires that within the overall housing supply
target, Plans should indicate the number of new homes to be built over the Plan
period. Paragraph 116 is unequivocal in stating that this figure should be
increased by a margin of 10 to 20% to establish the housing land requirement, in
order to ensure that a generous supply of land for housing is being provided. The
exact extent of the margin will depend on local circumstances but a robust
explanation for it should be provided for in the plan.
2.6 Whilst paragraph 118 states that Strategic Development Plans should set out the
housing supply target and the housing land requirement for the area, page 2 of the
Aberdeenshire Local Development Plan: Proposed Plan Consultation Barratt North Scotland: Policy H1 Housing Land
May 2015
SPP confirms that where development plans and proposals accord with this SPP
their progress through the planning system should be smoother.
2.7 As a statement of Ministers’ priorities, the content of SPP is a material
consideration that carries significant weight and the LDP should therefore reflect
the need for an additional 10 to 20% and not await the next review of the SDP
which will merely confirm this position. Para 2.14 confirms the basis as to how the
percentage figure can be established.
Housing Supply / Sites
2.8 In allocating sites, paragraph 119 of the SPP advises that Planning Authorities
should be confident that land can be brought forward for development within the
Plan period and that the range of sites allocated will enable the housing supply
target to be met.
2.9 Planning Authorities therefore must ensure that those sites can be delivered and
houses built within the Plan period. If that cannot be achieved, as is clearly the case
in the AHMA, additional sites must be allocated. This is essential to ensure there
are no difficulties with delivering housing later in the Plan period.
2.10 The Council’s fallback position is of course the 2014 Housing Land Audit, which
highlights a supply in excess of 5 years in the AHMA. However, that calculation
masks the failure of the Local Development Plan to deliver housing in the 2012 –
2016 period. As an example, that part of the Aberdeen Housing Market Area
falling within Aberdeenshire was allocated 5,000 units by the Strategic
Development Plan for the period 2012-2016. The extant Local Development Plan
identified sites to accommodate 4,751 units, yet only 1,451 units are expected to
be delivered by the end of 2016. This results in the failure to deliver 3,549 units in
the Aberdeenshire part of the Aberdeen Housing Market Area in the period to
2016.
2.11 The extant Local Development Plan advocated a drawdown mechanism to take
sites forward from the 2017-2021 period to address any shortfall. Unfortunately,
the Plan’s reliance on large sites to deliver the housing requirement means that
this approach has not been possible as the majority of potential drawdown sites
are Phase 2 elements of these larger sites. If the first phase is not delivering the
second phase certainly cannot.
Aberdeenshire Local Development Plan: Proposed Plan Consultation Barratt North Scotland: Policy H1 Housing Land
May 2015
2.12 As way of an example, the new settlement at Chapelton of Elsick was expected to
deliver 1,845 units in the period 2012-2016, but in actual fact will have delivered
only 270 units based on the draft 2015 Housing Land Audit figures. As a
consequence, the 2,200 houses allocated on that site for the period 2017-2026
cannot be delivered until the balance of 1,575 units has been built. Similar
scenarios exist throughout the Aberdeen Housing Market Area.
2.13 The only way this can be resolved is through the allocation of additional sites which
are capable of early implementation to ensure that housing is delivered within the
time periods specified by the SDP.
2.14 The failure of the Local Development Plan to deliver the required housing within the
specified Plan periods is compounded by an increased demand for housing.
Revised household projections, published in July 2014, identified a higher
requirement for the period 2017-2026 than set out in Figure 10 of the Strategic
Development Plan. This, in itself, justified a review of the housing allocations to
ensure a generous land supply capable of addressing the increased housing
requirement. As stated in paragraph 2.7 above, this is required by SPP.
2.15 Furthermore, analysis undertaken in responding to the MIR Addendum indicated
that there was a significant imbalance between the City and Shire in terms of the
effective supply with the Shire relying on the City to deliver the bulk of the post-5
year effective supply. To address this, various third party responses to the MIR
Addendum concluded that the housing land supply in the Aberdeenshire part of the
Aberdeen Housing Market Area should be increased by over 2,800 units.
2.16 On the basis of the above, and given the focus on delivery of housing within the SPP,
there is a compelling case for the allocation of additional smaller scale and
deliverable housing sites through the Local Development Plan 2016. It is
disappointing that the Proposed Plan does not take this forward.
Site Cap on Unit Numbers
2.17 A further means to help address the shortfall is to remove the cap placed on the
number of units that can be developed from allocated sites. There is absolutely no
justification for this cap. SPP imposes a presumption in favour of development that
contributes to sustainable development. This requires that policies and decisions
should be guided by giving due weight to economic benefit; making efficient use of
existing capacities of land, buildings and infrastructure; and, supporting the delivery
Aberdeenshire Local Development Plan: Proposed Plan Consultation Barratt North Scotland: Policy H1 Housing Land
May 2015
of accessible housing. The Strategic Development Plan is also perfectly clear that
“…land brought forward for development must be used efficiently”. It also
highlights the need to invest in both existing and new infrastructure to ensure the
area has enough people, homes and jobs to support the level of service and
facilities needed to maintain and improve the quality of life.
2.18 The true capacity of sites can only ever be determined through detailed design. At
Plan preparation stage it can be no more than an estimate based on an average
density. Given the fact that roads, drainage and other infrastructure will have been
provided to facilitate the allocated number of units, if a site is capable of delivering
more units, the developers should be allowed to utilise that infrastructure to ensure
that the maximum benefit accrues from that investment. The numbers allocated to
specific development sites through the Plan should be no more than a guide.
3.0 Summary
3.1 We would respectfully request that the following modifications are made to the
Proposed Plan.
Modifications Sought to the Proposed Plan
• Increase the housing supply target by 10 to 20% to ensure a generous
supply.
• A robust review to be included on the deliverability of allocated sites to
assess their effectiveness.
• Allocation of additional sites to replace the housing numbers that cannot
be delivered during the plan period.
• Remove the cap on the unit numbers provided in Appendix 5 and
settlement statements clearly being indicated for guidance only.
Please use this form to make comments on the Proposed Aberdeenshire Local Development 2016. If you are making comments about more than one topic it would be very helpful if you could fill in a separate form for each comment.
Please email or send the form to reach us by 8th May 2015 at the following address:
Post: Planning Policy Team Infrastructure ServicesAberdeenshire CouncilWoodhill HouseWestburn RoadABERDEENAB16 5GB
Email: [email protected]
Title
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Date
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Postcode
Telephone Number
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If yes who are you representing
YOUR DETAILS
An acknowledgement will be sent to this address soon after the close of consultation.
Please provide us with your comments below. Please feel free to add any extra pages you may require. We will summarise comments and in our analysis will consider every point that is made. Once we have done this we will write back to you with Aberdeenshire Council’s views on the submissions made. We will publish your name as the author of the comment, but will not make your address public.
YOUR COMMENTS
Modification that you wish to see
Reason for change
Mr
Gordon
Thomson
8 May 2015
Barton Willmore, 68-70 George Street, EDINBURGH
EH2 2LR
0131 220 7777
✔
Stewart Milne Homes
The following submission has had its supporting documents removed due to file size. If you require a copy of the original digital submission please contact Poliy Planning at [email protected]
Please use this form to make comments on the Proposed Aberdeenshire Local Development 2016. If you are making comments about more than one topic it would be very helpful if you could fill in a separate form for each comment.
Please email or send the form to reach us by 8th May 2015 at the following address:
Post: Planning Policy Team Infrastructure ServicesAberdeenshire CouncilWoodhill HouseWestburn RoadABERDEENAB16 5GB
Email: [email protected]
Title
First name
Surname
Date
Postal Address
Postcode
Telephone Number
Are you happy to receive future correspondence only by email - Yes No
Are you responding on behalf of another person? Yes No
If yes who are you representing
YOUR DETAILS
An acknowledgement will be sent to this address soon after the close of consultation.
Please provide us with your comments below. Please feel free to add any extra pages you may require. We will summarise comments and in our analysis will consider every point that is made. Once we have done this we will write back to you with Aberdeenshire Council’s views on the submissions made. We will publish your name as the author of the comment, but will not make your address public.
YOUR COMMENTS
Modification that you wish to see
Reason for change
Please see attached pages.
Please see attached pages.
Mains of Cowie, Stonehaven Objection: Objection is made to the failure to allocate Mains of Cowie, Stonehaven for residential-led mixed use development in accordance with proposals contained in the accompanying submission. Modification Sought: Inclusion of the site at Mains of Cowie for residential-led mixed use development comprising up to 400 dwellings, retail foodstore (up to 4,000m2), land for a primary school and open space in the Stonehaven Settlement Statement tables and maps (Appendix 8 Settlement Statements) and to the Table (Page 10) in Appendix 5 New Housing Land Allocations. Justification: Limited to 2000 words Stewart Milne Homes (SMH) have identified the site at Mains of Cowie as more sustainable, more deliverable and more in keeping with the historical growth and development of the town than other residential sites being progressed through the Local Development Plan preparation process. It could make a valuable contribution to the delivery of housing in the area and assist in addressing the emerging shortfall which has arisen as a result of a failing housing land supply carried over from the adopted LDP. This matter is addressed in separate representations on Policy H1 by SMH. The site could also deliver ancillary uses including land for a new primary school, community uses and food retail, the latter of which is considered in a separate objection to the PLDP. Stonehaven is already a very popular place to live. The construction of the Aberdeen Western Peripheral Route (AWPR) will mean quicker and easier access to jobs within Aberdeen City, its western business parks and job markets further north. The catchment for workers looking for places to live will extend and Stonehaven will see even greater demand for housing. SPP requires (Paragraph 30) that development planning should set out a spatial strategy which is both sustainable and deliverable and (Paragraph 29) that planning policies and decisions should support the delivery of accessible housing and retailing development. Over and above the concerns listed below on housing delivery across the Strategic Growth Area, Aberdeenshire Council is not properly planning for sustainable growth in Stonehaven. The Council has not allocated any significant housing land within the A90 boundary. The only significant housing allocations lie at the Ury Estate and sit disconnected from the town. Delivering a new Northern Gateway In a physical sense, the enhanced grade separated junction, with new southbound sliproads on Stonehaven’s northern approach provides the opportunity for a new gateway to the town. The ‘fastlink’ that connects this junction to the southern and northern legs of the AWPR will provide fast and efficient access to Aberdeen City as well as Aberdeen Airport. These connections will further enhance Stonehaven as a highly accessible place to provide housing and commercial opportunities such as leisure and tourism and business accommodation. Development on the Mains of Cowie site will play an important part in maximising the impact of this key entrance to the Town.
Sustainable Development at Stonehaven and within the A90 As well as the quantitative debate about housing, there is also a qualitative aspect that is equally as important. While Aberdeenshire Council have identified significant housing land to meet ambitious growth targets across the Shire, it could be argued that a significant proportion of these allocations are not (at least currently) in the places that people want to live. This has implications for delivery and maintaining an effective land supply. Despite identifying the Mains of Cowie site as a preferred option in the 2009 MIR, off the back of the ‘Imagine Stonehaven’ Capacity Study finding the site to be a suitable location for housing with retail development), Aberdeenshire Council took the decision to allocate a significant proportion of its future housing land away from established settlements like Stonehaven and towards Chapelton of Elsick. In other words, to allocate growth away from mature, popular and sustainable existing places to a new town. We concur that Elsick has the potential to become an attractive new settlement in time. However, New Towns will take time to establish themselves. Facilities take time to come on stream (especially when they are entirely market driven) and perhaps more importantly people take time to decide to live there. Until a new town becomes established, there will inevitably be a precarious balance between the idea and its delivery. This is evidenced by the current rate of delivery sitting far behind that originally projected. By 2015 Elsick was projected to deliver 1845 by 2016 – if the projections in the 2014 HLA are accurate it will have delivered 200, a fact compounded by a general lack of delivery across the strategic growth area. While it is appropriate to focus energies upon committed sites, there must also be a balance. Delays impact upon the delivery of housing across the Strategic Development Plan area as a whole and only increase pressure elsewhere. Moreover, the Plan should be providing people with the opportunity to live in places that allow them to walk to local retail, the town centre, primary and secondary schools and open space, all via attractive routes and paths. Delivering a mixed use development that will form part of Stonehaven From the outset, SMH has been committed to delivering an attractive development that respects and reflects the best of Stonehaven. The current application for planning permission in principle which remains undetermined has emerged from a significant design exercise and has been shaped by considerable community engagement. The indicative density of the proposal reflects the principle of historical townscape proportions and character. This is evident in its block structure, street orientation and design. The proposed grid can accommodate a flexible housing mix which can still ensure the streets and spaces are retained whilst increasing or decreasing density. SPP and NPF3 place great emphasis on the objective that planning should direct development to the right place. SPP confirms (Paragraph 40) that to achieve this, development plans should be guided by policy principles, including:
• co-ordinating housing with infrastructure investment including transport and education facilities;
• using land within or adjacent to settlements for a mix of uses; • considering whether the permanent greening of some of a site could make a valuable
contribution to green and open space networks; and • locating development where investment in growth or improvement would have most
benefit for the amenity of local people and the vitality of the local economy.
Mains of Cowie is an attractive, accessible and sustainable housing site within easy reach of the town centre and its facilities. Indeed, Mains of Cowie is the only project proposed for Stonehaven that offers significant, sustainable growth within the town bypass (A90) and in proximity to the town centre. The site can accommodate up to 400 homes with a suitable range of types and tenures. Up to 25% affordable housing can be provided resulting in a substantial contribution to local people. Importantly, this proportion could include housing suitable for older people. Crucially, a mixed-use approach to the proposals has been embraced, in line with sustainability and placemaking objectives set out in SPP. This would enable the delivery of a 4,000m2 retail foodstore on the site, meeting an established and long recognised deficiency in retail provision in the town. The site is located immediately adjacent to planned infrastructure investment and could accommodate investment in education facilities. This could include a single stream primary school with GFA of 1,800m2, provided within a site measuring 1.2 Ha allowing sufficient area for playground and open space as well as parking and circulation. The design has been informed by a thorough Landscape and Visual Impact appraisal and assessment. This assessment has in turn inspired a landscape and planting strategy for the site that helps form strong character areas, and mediates the impact of development on strategic and local views while celebrating the exceptional outlook from the site. Stewart Milne propose to retain and redevelop the existing farm buildings for community use, the exact nature of which will be agreed with Aberdeenshire Council and local groups. A range of permanent green spaces and parkland amounting to 7.25ha will be created that not only serve future residents but will be attractive to existing residents of the town. Mains of Cowie evidently represents an opportunity for well located mixed use development in line with the policy principles of SPP. Sustainable and Deliverable The last year has seen a considerable amount of detailed work on the site in support of the current planning application, a copy of which accompanies this representation as background information. There will be two points of access servicing the site. On the western edge this will be from the B979, via a new signal controlled junction, including dedicated pedestrian crossing facilities. A secondary access from the south will be a standard priority controlled junction. Each of these access routes as well as the main route through the site will measure 6.5m in terms of carriage width to allow access for both supermarket service vehicles and buses. While the site lies in close proximity to the town centre, it can also be demonstrated that barrier free access can be provided via two paths to the site, one from the B979 and the other from the southern boundary. It is a major benefit that these can be delivered and is significantly better in terms of accessibility than many other areas of the town. Furthermore, this also adds to the barrier free path network across the town and provides the opportunity to access new parkland, open space and appreciate the views from the site. In addition to paths through new parkland and open space, proposed paths within the site are also created through the network of new streets with good lighting, wide footpaths suitable for wheelchair users and prams, with good passive supervision and attractive streetscape. The character and views will encourage visitors and new residents to these areas.
In forming the junctions into the site there will be enhancements to crossing points, streetlighting and footpaths approaching these and leading to the roundabout located at B979, making it safer for pedestrians using these routes. These paths could be increased to 2m and include drop kerbs with appropriate surfacing at crossing points. Within the site, networks of streets and paths will be developed in line with ‘Designing Streets’. Increased passive supervision and increased use of these paths should also make them feel safer for pedestrians going between the town and Mains of Cowie, caravan park, golf course, leisure centre as well as providing alternative routes for walking dogs, jogging, etc. The combined impact of increased activity, residential overlooking and use of the sloped area for amenity space is also likely to slow adjacent traffic. Flooding and drainage are key issues within Stonehaven and have received careful consideration within the development proposals. There are currently known flooding problems in the area, and there are also existing capacity constraints associated with the current surface and foul water drainage systems in the vicinity of the proposed development site mainly due to greenfield run off and poor maintenance of road gullies. In developing flood prevention measures and drainage system designs, sufficient capacity will be built into the new infrastructure to cater for the proposed development, ensuring that existing capacity constraints are not exacerbated. The topography of the site is such that additional flood prevention measures can be introduced, which are specifically designed to reduce the surface water run-off rate, resulting in an improvement over the existing situation – early estimates propose at least a 10% reduction in run-off compared with greenfield. Site specific surface water drainage measures will include permeable paving, porous asphalt, swales and retention ponds. Detailed discussions with Scottish Water are also underway to determine the exact requirements for foul water sewer design, to tie in to the existing foul water system, including, where appropriate, mitigation measures to address the existing capacity constraints. The site is in the single control of Stewart Milne Homes who have the means and resources to ensure swift delivery of mixed use development in the early phases of the plan period. The area is highly desirable and market demand for new housing development in Stonehaven is high. In conclusion, the development of Mains of Cowie is the logical choice for the sustainable growth of Stonehaven. The centre of the development site is within five minutes walking distance of the town’s shops and facilities. The proposal, in both its form and content will add to the rich mix of activities and environments within the town. SPP places sustainable economic growth at the heart of our planning system. Development at Mains of Cowie is a prime example of this type of sustainable development.
The following submission has had its supporting documents removed due to file size. If you require a copy of the original digital submission please contact Poliy Planning at [email protected]
Land at Broadshade North, Westhil l
Modification that you wish to see:
Objection:
On behalf of our client, Stewart Milne Homes, we object to Aberdeenshire Council’s failure to allocate
residential land at Broadshade North, Westhill within the emerging Local Development Plan (LDP).
Page/Policy Reference:
Westhill Settlement Statement (Pages 78 – 84 in Appendix 8 of the PLDP)
Modification Sought:
We wish to see the allocation of land at Broadshade North, Westhill, for residential
development (indicatively 150 homes) suitable for delivery within the first five years of the
emerging Local Development Plan, with the tables and proposals maps in the Westhill
Settlement Statement (Pages 78 – 84 in Appendix 8 of the PLDP) updated accordingly.
Failing that, it should be identified as a future allocation for the second phase of the LDP.
Reason for change: On behal f of our c l ient , Stewart Mi lne Homes, we object to Aberdeenshire Counci l ’ s
fa i lure to al locate resident ia l land at Broadshade North, Westhi l l within the
emerging Loca l Deve lopment Plan (LDP). Broadshade North could make a valuable
contr ibut ion toward address ing the short fa l l in housing de l ivery that has emerged
and wi l l cont inue as a resul t of re l iance on an underperforming hous ing land
supply, the extent of which is set out in our cl ient ’s separate representat ions on
Pol icy H1.
As context , Appendix 8 of the Proposed Aberdeenshire Loca l Development Plan
(PALDP) ident i f ies land at Broadshade as S i te OP1, having been carr ied over from
the current LDP 2012. S ite OP1 represents the second phase of development at
Broadshade which had been al located in the Aberdeenshire Local Plan 2006 and is
present ly being constructed, and wi l l be completed in la te 2015. Broadshade has a
track record in del ivery and in making a rea l and valuable contr ibut ion toward the
avai lab i l i ty of new housing stock in the Aberdeen Housing Market Area.
Since the init ia l a l locat ion of land at Broadshade in 2006, Westhi l l has seen
signi f icant growth in employment development on its southern edges. This has
bolstered the town’s status as a centre of exce l lence for the specia l ist subsea
industry, growing the region’s l inks to o i l and gas. Addi t iona l housing in Westhi l l
wi l l help support i ts cont inued success through the provis ion of a choice o f
avai lab le homes within the l i fet ime of the emerging LDP.
At the same t ime, i t i s evident that the increase in the employment act ivity with in
Westhi l l has enhanced its status as a desirable p lace for people to l ive, as shown
by the rate of sa le of the ear l ier Broadshade al locat ions. This is despite the f i rst
phase being progressed and del ivered through one of the worst economic
recessions in recent h istory. Further hous ing wi l l support the growth of the
business sector and promote the pr inciples of placemaking and sustainabi l i ty
through the masterp lanning of a strengthened community with homes in walk ing
and cycl ing distance of local employment.
Stewart Mi lne Homes propose that the emerging LDP al locates further resident ia l
land at Broadshade North, which is north of OP1 and the adjo in ing exist ing housing
site , with an indicat ive capaci ty for 150 uni ts, as to be included in Appendix 5 of
the LDP and the Garioch Sett lement Statements sect ion. This s ite is under the
contro l of Stewart Mi lne Homes.
The land at Broadshade North had previously been excluded from the a l locat ion to
the south due to i t be ing constrained by the presence of a major gas pipel ine. This
pipe l ine has been rerouted as part of the approved housing s ite and now fol lows
the southern edge of the site . In rerout ing the pipel ine the pipe was upgraded,
reducing the required standoff distance to only 6m. The pipel ine, therefore, no
longer poses a constra int to development.
Our reasoning and just i f icat ion for th is proposa l is set out be low. Please a lso refer
to the fo l lowing support ing submissions:
• Masterp lan Report (May 2015);
• Access ibi l i ty Appraisal ;
• Landscape and V isual Appraisal ; and
• A separate representat ion by SMH propos ing amendments to Pol icy H1 and
the Counci l ’s approach towards its effect ive hous ing land supply (Submit ted
by Ryden on the ir behalf).
Scott ish Planning Pol icy (SPP) sets a strong focus on susta inabi l i ty and
placemaking as its Pr inc ipa l Pol ic ies and states that, “By locating the right
development in the right place, planning can provide opportunities for
people to make sustainable choices and improve their quality of l ife. ..
Planning therefore has an important role in promoting strong, resil ient
and inclusive communities” (Paragraph 15, Page 6) .
SPP also states that spat ia l strategies with in development plans should promote a
susta inable pattern of development appropr iate to the area, with planning
decis ions to be guided by pol icy pr inc ip les that include:
• “optimising the use of existing resource capacities, particularly by co-
ordinating housing and business development with infrastructure
investment…”; and
• “ locating development where investment in growth or improvement
would have most benefit for the amenity of local people and the
vitality of the local economy” (Paragraph 40, Page 13).
It further confirms (Paragraphs 270 and 273) that the planning system should
support patterns of deve lopment which opt imise the use of exist ing infrastructure
and reduce the need to t ravel .
It fol lows that in order to avoid overburdening the exist ing transport network, the
al locat ion and de l ivery of new housing at Broadshade North with the signi f icant
employment opportuni ty recent ly del ivered in the area, as wel l as that earmarked
for the future, would provide this workforce with a choice of homes to l ive in that
are close to jobs. Patterns of development such as these are conducive to
encouraging sustainable transport mode share and could serve in reducing the
number of workers trave l l ing from outside Westhi l l to Arnha l l Bus iness Park and
onto the local road network.
The provided Masterp lan Report and Accessib i l i ty Appraisal demonstrate that the
site is wel l served by publ ic transport, loca l fac i l i t ies and employment
opportunit ies, in l ine with the a ims and pol icy requirements of SPP and the
approved Strategic Development Plan.
The Aberdeen City and Shire Strategic Deve lopment Plan (SDP) has taken a
progress ive approach to hous ing del ivery through ident i f icat ion of a l locat ions for
major new sett lements. Al though the pr inciple of this approach is not necessari ly
f lawed, i t has not de l ivered new homes at the required rate. P lease see Stewart
Mi lne Homes’ separate representat ion regard ing the hous ing land supply for further
information on why this proposal is required to provide a generous supply of
housing land in appropriate locat ions. Westhi l l is one such locat ion.
The Aberdeenshire LDP Main Issues Report (MIR) assessment of th is s ite
considered that i t is unsuitab le for deve lopment due to i t being prominent .
However, the accompanying ind icat ive masterplan and Landscape and Visual
Appraisal (LVA) demonstrates that, by l imit ing deve lopment to the 175m AOD
contour l ine and by careful ly contro l l ing proposed densit ies and areas of open
space, a solut ion exists where the si te could sat is factor i ly accommodate new
development without g iv ing r ise to any signi f icant adverse landscape impact.
The potent ia l for addit ional deve lopment in Westhi l l was examined in detai l
through a signi f icant piece of work under the Westhi l l Capaci ty Study (WCS)
Update 2014. The WCS Update acknowledges the signi f icant provis ion of
employment land loca l ly and states that “It is considered likely that additional
employment related growth in Westhill would, at least in the medium
term, require to be supported by new housing provision…”. A lthough the
SDP does not ident i fy Westhi l l as a Strategic Growth Area, i t is our v iew that the
lack of hous ing a l locat ions in the PALDP is creat ing a signi f icant imbalance of
employment and housing provis ion. The inclusion of Broadshade North as a
resident ia l a l locat ion can address th is and support employment growth in Westhi l l .
The WCS Update assesses an area of land to the north west of Westhi l l which
includes OP1 and extends north beyond the boundar ies of Broadshade North. This
f inds the site “ less suitable” for deve lopment, due to s igni f icant constra ints .
However the scoring schedules make repeated references to the s ite being
constra ined by the pipel ine and that Hi l l of Ke ir presents a constra int. It fo l lows
that had the study have been updated to inc lude the rerouted and re inforced
pipe l ine arrangements, and cons idered our landscape informed approach that has
consistent ly been presented towards deve lopment of this s i te, these constraints
would be recognised to having been superseded and the si te would be found to be
“suitable” for development.
The WCS Update assessment also does not take into account that much of the s ite
which was assessed is now developed or under construct ion. Furthermore, the
potent ia l to contr ibute toward coalescence with Kirkton of Skene forms part of the
negat ive scor ing yet land which whol ly f i l ls the gap between Westhi l l and Kirkton
of Skene is found to be suitable for development.
The WCS Update cons iders that a l l s i tes which are proposed for development in
Westhi l l would g ive r ise to a requirement to make contr ibut ions to the road
infrastructure network in the area which is found to be over capacity at present ,
recommending a ser ies of intervent ions.
Loca l transport improvements have recent ly been made and the accompanying
Access ibi l i ty Appra isa l confi rms that , unt i l such t ime as wider transportat ion
intervent ions are real ised, th is sca le of development could be absorbed into the
sett lement with minimal impact on the local road network in and around Westhi l l .
Future benefi ts to local transport capacity wi l l include through a result of the
addit iona l dua l l ing on the A944, the signal isat ion of the A944 / B9119 Six Mi le Fork
junct ion and further benefits to the local road network expected with the
construct ion of the AWPR.
The WCS Update demonstrates that, with the except ion of a r idgel ine on the very
north west corner of Broadshade North, the site is predominant ly free of
constra ints. NB: The old and now superseded al ignment of the gas p ipe l ine is
shown in the capaci ty study, but for the reasons set out above has been
discounted as a constraint. There is adequate capacity at the Invercannie water
treatment works and sewage treatment works to accommodate large sca le
resident ia l development, far beyond the capacity of the site .
As the site is f ree from signi f icant physical and f inancia l constra ints, there wi l l be
no reduct ion in deve loper contr ibut ion requirements due to si te viabi l i ty and these
can be del ivered without h indering development, provided that the contr ibut ions
are appl ied in l ine with Circular 3/2012.
PAN 2/2010 Affordable Housing and Housing Land Audits , def ines the effect iveness
of s ites by reference to a range of headings. The land at Broadshade North is
considered in this context below:
• Ownership – The s ite is in the single control of Stewart Mi lne Homes, who
have the appropr iate resources and f inancing avai lable to develop the si te.
• Phys ical – The site is free from constraints related to s lope, aspect, f lood r isk
and ground stabi l i ty. It is a lso capable of vehicular access from the
surrounding road network. The site does contain land protected by the HSE
but the recent upgrade of the pipel ine has l imited the extent of this land and
as such it does not pose a constraint to development.
• Contaminat ion – Previous use of the si te has been almost exc lusively
agriculture therefore no issues of contaminat ion are ant ic ipated.
• Defici t Funding – No publ ic funding would be necessary to make the s ite
economical ly v iab le for resident ia l development.
• Marketabi l i ty – The si te is cons idered to be highly at tract ive to purchasers,
capable of addressing al l sectors of the hous ing market. It can therefore be
developed in the period of the P lan.
• Infrastructure – The site can be serv iced without abnormal cost . Some
improvements may be required in the future to loca l pr imary school capaci ty
subject to discuss ion and agreement with Aberdeenshire Counci l and a
contr ibut ion toward wider road network improvements could be made in l ine
with nat ional guidance.
• Land Use – Housing is promoted as the preferred use of the land in planning
terms with complementary mixed use where appropriate.
Our cl ient ’ s s ite at Broadshade North represents a logica l and susta inable
extension to Westhi l l which could accommodate a susta inable resident ia l
development with good access to employment opportuni t ies and serv ices, includ ing
publ ic transport . It is effect ive, free of absolute constraints to development and
could be del ivered quickly, easi ly and in fu l l , throughout the p lan period.
As shown in Stewart Mi lne Homes’ separate representat ion on hous ing land, there
is a s igni f icant need for effect ive new housing land. Broadshade North wi l l make a
real and valuable contr ibut ion toward the del ivery of this needed hous ing in an
area which is the focus of increasing employment act iv ity.
As such, we recommend that the Counci l ident if ies the s ite as a new housing
al locat ion in the Aberdeenshire Local Development Plan.
The accompanying Masterplan Report provides an assessment of s ite opportunit ies
and constra ints and demonstrates how the ind icat ive capacity of 150 units on the
site might integrate with the exist ing sett lement. The precise number of uni ts to
be deve loped wi l l u lt imately be determined through d iscussion and agreement with
Aberdeenshire Counci l and in compliance with Scott ish Government Pol icy and
advice on detai led des ign matters.
Any masterp lan proposals wi l l evolve through ongoing cons iderat ion and
consultat ion with Aberdeenshire Counci l and the loca l community to ensure the
best and most appropriate proposal that wi l l create a high qual i ty environment
with a st rong sense of place.
The following submission has had its supporting documents removed due to file size. If you require a copy of the original digital submission please contact Poliy Planning at [email protected]
Land at Strawberry Fields, Westhil l
Modification that you wish to see:
Object ion:
On behal f of our c l ient , Stewart Mi lne Homes, we object to Aberdeenshire Counci l ’ s
fa i lure to al locate resident ia l land at Strawberry F ie lds, Westhi l l wi th in the
emerging Local Development Plan (LDP).
Page/Pol icy Reference:
Westhi l l Sett lement Statement (Pages 78 – 84 in Appendix 8 of the PLDP)
Modi f icat ion Sought:
We wish to see the a l locat ion of land at Broadshade North, Westhi l l , for resident ia l
development ( indicat ively 150 units) suitable for del ivery within the f irst f ive years
of the emerging Loca l Development Plan, with the tables and proposals maps in the
Westhi l l Sett lement Statement (Pages 78 – 84 in Appendix 8 of the PLDP) updated
accordingly. Fa i l ing that , i t should be ident i f ied as a future housing s ite in the
second phase of the LDP.
Reason for change:
On behal f of our c l ient , Stewart Mi lne Homes, we object to Aberdeenshire Counci l ’ s
fa i lure to al locate resident ia l land at Strawberry F ie lds, Westhi l l wi th in the
emerging Local Development Plan (LDP).
As context , Appendix 8 of the Proposed Aberdeenshire Loca l Development Plan
(PALDP) ident i f ies land at Broadshade as S i te OP1, having been carr ied over from
the current LDP 2012. S ite OP1 represents the second phase of development at
Broadshade which had been a l located in the Aberdeenshire Local Plan 2006, is the
subject of p lanning permiss ion and is present ly be ing constructed, and wi l l be
complete in late 2015. Broadshade has a t rack record in de l ivery and in making a
real and va luable contr ibut ion toward the avai lab i l i ty of new housing stock in the
Aberdeen Housing Market Area.
Since the init ia l a l locat ion of land at Broadshade in 2006, Westhi l l has seen
signi f icant growth in employment development on its southern edges. This has
bolstered the town’s status as a centre of exce l lence for the specia l ist subsea
industry, growing the region’s l inks to o i l and gas. Addi t iona l housing in Westhi l l
wi l l help support i ts cont inued success through the provis ion of a choice o f
avai lab le homes within the l i fet ime of the emerging LDP.
At the same t ime, i t i s evident that the increase in the employment act ivity with in
Westhi l l has enhanced its status as a desirable p lace for people to l ive , as shown
by the rate of sa le of the ear l ier Broadshade al locat ions. This is despite the f i rst
phase being progressed and del ivered through one of the worst economic
recessions in recent h istory. Further hous ing wi l l support the growth of the
business sector and promote the pr inciples of placemaking and sustainabi l i ty
through the masterp lanning of a strengthened community with homes in walk ing
and cycl ing d istance of local employment. However, despite the cont inued focus on
employment in the town, this has not been accompanied by accompanying release
of land for new housing.
Stewart Mi lne Homes propose that the emerging LDP al locates further resident ia l
land on the southern side of Old Skene Road (herein referred to as Strawberry
Fie lds) with an ind icat ive capacity for 150 units, as to be inc luded in Appendix 5 of
the LDP and the Garioch Sett lement Statements sect ion. This s ite l ies to the south
of S ite OP1, “Broadshade Masterplan” and is a lso under the control of Stewart
Mi lne Homes. This land at Strawberry F ie lds was previous ly ident i f ied in the
Aberdeenshire Local P lan 2006 as part of “ future housing land” s i te fh3, a lthough
was not subsequently carr ied over into the Aberdeenshire LDP 2012.
Our reasoning and just i f icat ion for th is proposa l is set out be low. Please a lso refer
to the fo l lowing support ing submissions:
• Masterp lan Report (May 2015);
• Access ibi l i ty Appraisal ;
• Landscape and V isual Appraisal ; and
• A separate representat ion by our SMH proposing amendments to Pol icy H1
and the Counci l ’s approach towards i ts effect ive housing land supply
(Submitted by Ryden on the ir behal f) .
Scott ish Planning Pol icy (SPP) sets a strong focus on susta inabi l i ty and
placemaking as its Pr inc ipa l Pol ic ies and states that, “By locating the right
development in the right place, planning can provide opportunities for
people to make sustainable choices and improve their quality of l ife...
Planning therefore has an important role in promoting strong, resil ient
and inclusive communities” (Paragraph 15, Page 6) .
SPP also states that spat ia l strategies with in development plans should promote a
susta inable pattern of development appropr iate to the area, with planning
decis ions to be guided by pol icy pr inc ip les that include:
• “optimising the use of existing resource capacities, particularly by co-
ordinating housing and business development with infrastructure
investment…”; and
• “ locating development where investment in growth or improvement
would have most benefit for the amenity of local people and the
vitality of the local economy” (Paragraph 40, Page 13).
It further confirms (Paragraphs 270 and 273) that the planning system should
support patterns of deve lopment which opt imise the use of exist ing infrastructure
and reduce the need to t ravel .
It fol lows that in order to avoid overburdening the exist ing transport network, the
al locat ion and del ivery of new housing at Strawberry F ie lds with the s igni f icant
employment opportuni ty recent ly del ivered in the area, as wel l as that earmarked
for the future, would provide this workforce with a choice of homes to l ive in that
are close to jobs. Patterns of development such as these are conducive to
encouraging sustainable transport mode share and could serve in reducing the
number of workers trave l l ing from outside Westhi l l to Arnha l l Bus iness Park and
onto the local road network.
The provided Masterp lan Report and Accessib i l i ty Appraisal demonstrate that the
site is wel l served by publ ic transport, loca l fac i l i t ies and employment
opportunit ies, in l ine with the a ims and pol icy requirements of SPP and the
approved Strategic Development Plan.
The Aberdeen City and Shire Strategic Deve lopment Plan (SDP) has taken a
progress ive approach to hous ing del ivery through ident i f icat ion of a l locat ions for
major new sett lements. Al though the pr inciple of this approach is not necessari ly
f lawed, i t has not de l ivered new homes at the required rate. P lease see Stewart
Mi lne Homes’ separate representat ion regard ing the hous ing land supply for further
information on why this proposal is required to provide a generous supply of
housing land in appropriate locat ions. Westhi l l is one such appropriate locat ion.
The Aberdeenshire LDP Main Issues Report (MIR) assessed the land at Strawberry
Fie lds and acknowledged that potent ia l s i te constra ints can be resolved, stat ing
“The site is constrained by a pipeline and overhead power lines, however
the pipeline has been upgraded reducing the required stand-off to 6
metres, and the route of the overhead power line could be incorporated
into the open space provision for the site” and “Skene Primary is also
projected to be signif icantly over capacity, though this issue could be
solved by re-zoning as there are other primary schools in Westhil l with
capacity”. It should be noted that re-zoning is current ly taking p lace.
The MIR acknowledged that the si te is wel l re lated to exist ing resident ia l areas at
Broadshade and is within walk ing distance of bus services, a lthough it considered
that there is insuff ic ient capacity in the road network to accommodate the
proposed deve lopment. Local transport improvements have recent ly been made and
our accompanying Accessibi l i ty Appraisal conf irms that, unt i l such t ime as wider
transportat ion intervent ions are rea l ised, this scale of development could be
absorbed into the sett lement with minimal impact on the local road network in and
around Westhi l l . Future benef its to local transport capacity wi l l include through a
result of the addit iona l dua l l ing on the A944, the s ignal isat ion of the A944 / B9119
Six Mi le Fork junct ion and further benef its to the local road network expected with
the construct ion of the AWPR.
In terms of any concerns on coalescence and landscape impact , the submit ted
Landscape and V isua l Appraisal sets how Strawberry Fie lds represents a log ical
extension to the set t lement and wi l l re late wel l to the row of res ident ia l propert ies
to the south east and land al located at Strawberry Fie lds Road for 10 houses.
The potent ia l for addit ional deve lopment in Westhi l l was examined in detai l
through a signi f icant piece of work under the Westhi l l Capaci ty Study (WCS)
Update 2014. Land at Strawberry Fie lds is scored favourably in the WCS and is
recommended as “most suitable” for deve lopment, with a st rong preference for
these areas to be del ivered f irst .
It considers that a l l s i tes which are proposed for development in Westhi l l would
give r ise to a requirement to make contr ibut ions to the road infrastructure network
in the area which is found to be over capacity at present, recommending a ser ies
of intervent ions. It adds that any potent ia l disadvantages, including congest ion,
“are arguably outweighed by the need to maintain the success of Westhill
as a centre of sub-sea engineering excellence”.
The WCS Update acknowledges the signi f icant provis ion of employment land loca l ly
and states that “It is considered likely that additional employment related
growth in Westhill would, at least in the medium term, require to be
supported by new housing provision…”. Although the SDP does not ident i fy
Westhi l l as a Strategic Growth Area, i t is our view that the lack of hous ing
al locat ions in the PALDP is creat ing a s igni f icant imbalance of employment and
housing provis ion. The inclusion of Strawberry Fie lds as a resident ia l a l locat ion can
address this and support employment growth in Westhi l l .
From review of the WCS Update it i s evident that the site is predominant ly free of
constra ints. The o ld and now superseded al ignment of the gas pipel ine is shown in
the capacity study, but for the reasons set out above has been discounted as a
constra int. There is adequate capacity at the Invercannie water treatment works
and sewage t reatment works to accommodate large sca le resident ia l deve lopment,
far beyond the capaci ty of the s ite .
As the site is f ree from signi f icant physical and f inancia l constra ints, there wi l l be
no reduct ion in deve loper contr ibut ion requirements due to si te viabi l i ty and these
can be del ivered without h indering development, provided that the contr ibut ions
are appl ied in l ine with Circular 3/2012.
PAN 2/2010 Affordable Housing and Housing Land Audits , def ines the effect iveness
of s i tes by reference to a range of headings. The land at Strawberry F ie lds is
considered in this context below:
• Ownership – The s ite is in the single control of Stewart Mi lne Homes, who
have the appropr iate resources and f inancing avai lable to develop the si te.
• Phys ical – The site is free from constraints related to s lope, aspect, f lood r isk
and ground stabi l i ty. It is a lso capable of vehicular access from the
surrounding road network. The site does contain land protected by the HSE
but the recent upgrade of the pipel ine has l imited the extent of this land and
as such it does not pose a constra int to development. Simi lar ly, the presence
of an overhead pylon can be suitably designed around as demonstrated in the
accompanying Masterp lan Report .
• Contaminat ion – Previous use of the si te has been almost exc lusively
agriculture therefore no issues of contaminat ion are ant ic ipated.
• Defici t Funding – No publ ic funding would be necessary to make the s ite
economical ly v iab le for resident ia l development.
• Marketabi l i ty – The si te is cons idered to be highly at tract ive to purchasers,
capable of addressing al l sectors of the hous ing market. It can therefore be
developed in the period of the P lan.
• Infrastructure – The site can be serv iced without abnormal cost . Some
improvements may be required in the future to loca l pr imary school capaci ty
subject to discuss ion and agreement with Aberdeenshire Counci l and a
contr ibut ion toward wider road network improvements could be made in l ine
with nat ional guidance.
• Land Use – Housing is promoted as the preferred use of the land in planning
terms with complementary mixed use where appropriate.
Our cl ient ’s s ite at Strawberry Fie lds represents a logica l and susta inable extens ion
to Westhi l l which could accommodate a sustainable res ident ia l development of up
to 150 houses, with good access to employment opportunit ies and serv ices,
including publ ic t ransport . It is e ffect ive, free of absolute constra ints to
development and could be de l ivered quick ly and easi ly, and in ful l , throughout the
plan period.
As shown in Stewart Mi lne Homes’ separate representat ion on hous ing land, there
is a s igni f icant need for effect ive new housing land. Strawberry Fie lds wi l l make a
real and valuable contr ibut ion toward the del ivery of this needed hous ing in an
area which is the focus of increasing employment act iv ity.
As such, we recommend that the Counci l ident if ies the s ite as a new housing
al locat ion in the Aberdeenshire Local Development Plan.
The accompanying Masterplan Report provides an assessment of s ite opportunit ies
and constraints and demonstrates how an ind icat ive capaci ty of up to 150 units on
the si te might integrate with the ex ist ing set t lement. The prec ise number of units
to be developed wi l l ult imately be determined through d iscussion and agreement
with Aberdeenshire Counci l and in compliance with Scott ish Government Pol icy and
advice on detai led des ign matters.
Any masterp lan proposals wi l l evolve through ongoing cons iderat ion and
consultat ion with Aberdeenshire Counci l and the loca l community to ensure the
best and most appropriate proposal that wi l l create a high qual i ty environment
with a st rong sense of place.
Please use this form to make comments on the Proposed Aberdeenshire Local Development 2016. If you are making comments about more than one topic it would be very helpful if you could fill in a separate form for each comment.
Please email or send the form to reach us by 8th May 2015 at the following address:
Post: Planning Policy Team Infrastructure ServicesAberdeenshire CouncilWoodhill HouseWestburn RoadABERDEENAB16 5GB
Email: [email protected]
Title
First name
Surname
Date
Postal Address
Postcode
Telephone Number
Are you happy to receive future correspondence only by email - Yes No
Are you responding on behalf of another person? Yes No
If yes who are you representing
YOUR DETAILS
An acknowledgement will be sent to this address soon after the close of consultation.
low. Please feel free to add any extra pages you
deenshire Council’s
Mr
Gordon
Thomson
8 May 2015
Barton Willmore, 68-70 George Street, EDINBURGH
EH2 2LR
0131 220 7777
✔
Stewart Milne Homes
The following submission has had its supporting documents removed due to file size. If you require a copy of the original digital submission please contact Poliy Planning at [email protected]
Please use this form to make comments on the Proposed Aberdeenshire Local Development 2016. If you are making comments about more than one topic it would be very helpful if you could fill in a separate form for each comment.
Please email or send the form to reach us by 8th May 2015 at the following address:
Post: Planning Policy Team Infrastructure ServicesAberdeenshire CouncilWoodhill HouseWestburn RoadABERDEENAB16 5GB
Email: [email protected]
Title
First name
Surname
Date
Postal Address
Postcode
Telephone Number
Are you happy to receive future correspondence only by email - Yes No
Are you responding on behalf of another person? Yes No
If yes who are you representing
YOUR DETAILS
An acknowledgement will be sent to this address soon after the close of consultation.
Please provide us with your comments below. Please feel free to add any extra pages you may require. We will summarise comments and in our analysis will consider every point that is made. Once we have done this we will write back to you with Aberdeenshire Council’s views on the submissions made. We will publish your name as the author of the comment, but will not make your address public.
YOUR COMMENTS
Modification that you wish to see
Reason for change
Please see attached pages.
Please see attached pages.
Retail Provision in Stonehaven Objection: Objection is made to:
• the continued identification of Site CC1: Spurryhillock as a foodstore allocation; and • the failure to allocate the Mains of Cowie site at Stonehaven for retail development as part
of housing-led mixed use development in accordance with proposals contained in accompanying submission.
Modification Sought: Objection is made to the Stonehaven Settlement Statement and maps in Appendix 8 Settlement Statements of the Proposed Plan which continues to identify CC1: Spurryhillock and fails to identify the site at Mains of Cowie for retail development as part of a housing-led mixed-used development. It is submitted that:
• Site CC1 should be removed from the settlement statement for Stonehaven; and • Mains of Cowie (as per the accompanying site plan) should be identified as a housing led
mixed use development site, incorporating a retail foodstore (up to 4,000m2) and land for a primary school.
Justification: Site CC1: Spurryhillock The Aberdeen City & Aberdeenshire Retail Study 2013 (the Hargest study), which of the documents supporting this LDP and a material consideration in the preparation of the plan states that Stonehaven requires a superstore of 4,000m2 (gross). However, the study makes no comment on the potential location for such a store within the town. The report makes it clear that the requirement for Stonehaven is separate from, and in addition to, the same report’s proposals for retail floorspace at the proposed new settlement at Chapelton of Elsick. Stonehaven is recognised as having a clear and urgent need for a new store. The PLDP continues to promote the existing local development plan site (Site CC1 at Spurryhillock) as the preferred location for new retail development, having been carried over from the adopted LDP. In our considered opinion and in the opinion of the Council and local communities, the delivery of a new superstore for Stonehaven is a pressing requirement. However, the local development plan allocation at Spurryhillock has prevented, rather than facilitated, the needs of the people of the town in terms of shopping facilities. When considered against SPP’s sequential approach to retail provision (Paragraph 68) Spurryhillock represents an ‘out-of-centre’ site. SPP requires (Paragraphs 30 and 47) that development plans be based on spatial strategies which are both sustainable and deliverable, taking into account the scale of development pressure and providing confidence to stakeholders that the outcomes can be achieved. Spurryhillock is unsuitable to deliver retail development due to both lack of market interest to date and that there is unlikely to be any market interest in the future. The site is also physically
constrained by the local road network, ownership and the existence of 100 year leases and is insufficient to accommodate a foodstore at the scale required for Stonehaven. Site CC1 therefore fails the requirements of SPP and should be deleted from the PLDP. A Vision for Stonehaven - Mains of Cowie SPP confirms (Paragraph 29) that policies should be guided by a series of principles including:
• Responding to economic issues challenges and opportunities; • Making efficient use of existing capacities of land, building and infrastructure, including
supporting town centre priorities; and • Supporting delivery of accessible housing, business, retailing and leisure development.
It goes on to confirm (Paragraph 40) that planning should direct development to the right places, optimising the use of existing resources, particularly by co-ordinating housing and business development with infrastructure investment. The Council have failed to recognise the significance of the AWPR to Stonehaven. The construction of the Aberdeen Western Peripheral Route (AWPR) will mean quicker and easier access to jobs within Aberdeen City, its western business parks and job markets further north. The catchment for workers looking for places to live will extend and Stonehaven will see even greater demand for housing. Therefore, the existing high demand for housing will, in our view, only increase. From experience, the creation of this new junction will likely bring interest in development sites and opportunities nearby. There is a need for the LDP to recognise that the context for Stonehaven will change significantly with the opening of the Aberdeen Western Peripheral Route (AWPR), and that the LDP’s development allocations for Stonehaven (in terms of both content and location) should take advantage of that change of context. We maintain that the Proposed LDP must not only deliver a credible site, it must deliver a site that is capable of being developed as quickly as possible and in an accessible location. Stewart Mile Homes believes that the site at Mains of Cowie is capable of delivering quickly in relation to both the provision of a superstore for Stonehaven and for new housing. The superstore would be well-located in relation to the town centre, the travelling patterns of shoppers, and the new AWPR junction. Above all, it would be a credible site for the market, likely to attract early interest from a retailer, and therefore early delivery for the people of the town and its wider catchment. A capacity study for Stonehaven “Imagine Stonehaven”, prepared by Aberdeenshire Council in 2009, identified the site as being suitable for residential development with a retail component. In the 2009 MIR for what is now the adopted LDP, the site was identified as a preferred option for development, however this allocation was not carried over into the LDP. A Retail Impact Assessment undertaken as part of the application proposal currently before the Council for the site at Mains of Cowie provides a number of conclusions in relation to retail provision. It concludes that the proposed store at Stonehaven would:
• Deliver significant benefits in terms of reductions of journey lengths and times for shoppers;
• Repatriate to Stonehaven, expenditure and jobs which are currently leaking to other areas;
• Retain shoppers within the town (and potentially attract new shoppers to the town) thereby delivering a potentially larger customer base for existing businesses within the town, including specialist shops; and
• Achieve all of this without undermining commercial viability of any of the stores from which trade would be diverted.
An independent review of the RIA which accompanied the planning application was undertaken by Hargest Planning Ltd on behalf of Aberdeenshire Council. This confirms that the site would meet the sequential approach to locating new retail development if:
• “Aberdeenshire Council officers are satisfied that the Spurryhillock site (CC1) is either:
- not reasonably suitable for accommodating the minimum size store to meet main food shopping requirements (i.e. a store of approximately 4000 sq m GFA or larger); or
- not reasonably available.
• That the proposed foodstore forms part of a mixed development including substantial new housing (as is currently proposed in the planning application).
• That the proposed development includes a condition/agreement to extend public transport services to provide easy access to the proposed foodstore.”
As Spurryhillock cannot accommodate a 4,000m2 foodstore, as the proposals for Mains of Cowie form part of a mixed-use development with a residential component and as SMH are agreeable to enhancing public transport provision, it is evident that the proposals are in accord with the sequential approach. Indeed, Mains of Cowie scores more favourably than site CC1: Spurryhillock. It is therefore submitted that Mains of Cowie represents the most sustainable location for new retail development at a scale sufficient to meet the identified needs of the town. All cities, towns and villages develop, with housing playing a critical role in growth. Effective housing supply in the correct location can have significant benefits for a place by supporting and growing a wide range of community facilities, leisure provision as well as vibrant town centres. Council officers acknowledged in their MIR that new housing development alongside new retail development could provide additional catchment for the retail component. From the outset Stewart Milne Homes has been committed to delivering an attractive development that respects and reflects the best of Stonehaven. The current application has emerged from a significant design exercise and has been shaped by considerable community engagement. A full application package accompanies this representation as background information to demonstrate the significant body of work and progress made to date. The design has been informed by a thorough Landscape and Visual Impact appraisal and assessment. This assessment has in turn inspired a landscape and planting strategy for the site that helps form strong character areas, and mediates the impact of development on strategic and local views while celebrating the exceptional outlook from the site. Mains of Cowie can also accommodate a single stream primary school with GFA of 1,800 sqm, provided within a site measuring 1.2 Ha allowing sufficient area for playground and open space as well as parking and circulation.
Stewart Milne Homes propose to retain and redevelop the existing farm buildings for community use. The exact nature of which will be the subject of further discussion with the community. The proposals (based on an indicative masterplan) at Mains of Cowie include approximately 7.25 Ha of open space (excluding open space associated with the primary school) which primarily comprises south facing slopes. These spaces will vary in character and on the slopes around the site (the western and southern corner - 5 Ha), there is the potential for enhanced biodiversity using native species. Existing stonewalls that bound the site will also be incorporated. In conclusion, the development of Mains of Cowie is the natural choice for the sustainable growth of Stonehaven with foodstore retail (4,000m2) comprising a key component. The centre of the development site is within five minutes walking distance of many of the town’s shops and facilities. The proposal, in both its form and content will add to the rich mix of activities and environments within the town. The proposal is deliverable within the plan period, with the foodstore representing part of a first phase in the early part of the plan period. SPP rightly places sustainable economic growth at the heart of our planning system. Development at Mains of Cowie is a prime example of this type of sustainable development. In light of the matters set out above it is submitted that Mains of Cowie should be identified as an allocation for foodstore retail (up to 4,000m2) as part of a wider mixed use development.
To Aberdeenshire CouncilVia emailRe: Pldb/pbOp 1St Cyrus, Roadside
Hi,
We live at , , . The attached pdf shows an arrow pointing out a tiny square where we live. The red development areas around us are proposed in OP1.
We have grave personal and financial concerns regarding the development of OP1
1. When planning went ahead we listed our house for sale, but were unable to sell as a result of the impending development ( as evidenced by attached copy of email from my solicitor).
2. We currently enjoy unobstructed views of the sea and the village. The reason why we purchased the house (ironically from the party proposing development) was for this very reason. The development plans include a number of houses that would destroy this view.
3. We engaged with the developer to see if we could buy some property to screen us from the development. The developer said they would 'possibly sell less than half an acre at [a pro-rata of] £80,000 per acre'.
4. The disruption to our own home extension plans, the diminished prospects of selling our home and the thought of having to endure years development are very distressing.
We find ourselves stuck in a house we can't sell with the prospect of our views being replaced with construction sites; the noise of the sea replaced with that of JCB's. Please help!
Thank you,
The following submission has had its supporting documents removed due to file size. If you require a copy of the original digital submission please contact Poliy Planning at [email protected]
The following submission has had its supporting documents removed due to file size. If you require a copy of the original digital submission please contact Poliy Planning at [email protected]
2
to the Commercial Development. In particular the housing element of which was allowed enabling funds for the commercial development and in any event were phased to follow the commercial development . To exchange permission for the above including the alleged economic and social benefit of National significance for a vast residential complex, could be see as an attempt to manipulate the planning process. Kind Regards
Would you confirm receipt of this email,
2
Modification that you wish to see
We would like to see some additional areas in and around the village of Daviot given ‘protected’ status. As such we would propose that the following modifications are made to the current draft of the 2016 LDP to give ‘protected’ status to:
the entire field at the bottom of Wellbrae which is bounded by Wellbrae, Wellpark and Daviot Estate (area marked X1 on the attached map);
the entire field to the east and south-east of Loanhead of Daviot Stone Circle and ancient monument looking south-eastward towards Pitblain/Highbury cluster,. (area marked as X2 on the attached map);
the designated area of open space at the new development called Hunter's Park (area marked X£ on the attached map).; and
the small play park within Kirkton Park.
Reason for change
The reason for the desired change is quite clear - unless areas near to the village are protected, the uniqueness of the village will be destroyed for ever.
We (and many others in and around the village) would be hugely concerned if any further development is allowed between Wellbrae, Wellpark and Daviot Estate as this will be detrimental to the landscape setting of Daviot village, Daviot Estate and the Daviot Community Trust's walks/woodland areas. In addition this area (X1) is classified as Class 3.1 Prime Agricultural Land and development here is not preferred by Aberdeenshire Councillor and Scottish Reporters have turned down Planning Applications in this area on a number of occasions.
The area east and south-east from the Stone Circle towards Pitblain/Highbury cluster should be protected to ensure there is no further development so that future generations can enjoy the wonderful views from this ancient monument and local place of interest.
The designated open space within the Hunters View development should be protected in line with the planning consent given to ensure no further houses are squeezed into this site in the coming years. For the same reason the play park within Kirkton Park should also be protected.
We would like to take this opportunity to emphasise that the above modification requested are additional areas that should be protected on top of all the areas given ‘protected’ status in the 2012 LDP. We do hope that Planners and Councillors do take action and support the wishes of the majority of the Daviot village residents by protecting these areas
5th May 2015.
To whom it may concern,
The following points are concerns I have about the proposed development as land marked as
OP2 in the local development plan.
Flooding and drainage of OP2 – in the 4 years I have lived in this property I have observed
that the volume of water that creates a small pond on land alongside OP2 grow considerably.
Furthermore the Water of Cruden regularly breaks it’s banks and floods the land – which is to
expected as it’s the burns natural flood Plain. This was very obvious, when a few years back,
the bridge on Hatton Farm Road was washed away by flood water just before Christmas.
Pre-existing developments in Hatton – the 2 existing developments in Hatton have both had
problems. The newer development near the main road stalled after phase 1, leaving in its
wake an ugly idle building site for nearly 3 years. The second development at the top of the
village – they struggled for a number of years to sell the last of the already built houses.
Also great thought has to be given to the services in the village – school, Drs surgery, pre-
school/playgroup etc
Traffic and school busses – Park View is a narrow road, and very few houses have off the
road parking – resulting in cars parking on the street. At busy times of the day this can be
very problematic. Added to this the Academy buses use the loop of Hatton Farm Gardens to
turn the buses round so they are ready to pull out onto Main Street to leave the village. Cars
parked on the street can make this impossible, so they reverse around the junction where
Hatton Farm Road becomes Park View. Due to the design of the junction, the buses regularly
mount the pavement during this manoeuvre. While this is happening children are walking to
school. During the time it takes for the children to get aboard the buses, the buses cause
severe congestion at the end of Hatton Farm Road – with regular traffic, cars dropping off
children and other smaller buses bringing children into the village from outlying areas. A
number of larger vehicles use Park View as access to the Water Treatment Plant and the
village household waste and recycling centre.
Green space in the village – OP2 is used daily by playing children and dog walkers. The
village hold the annual bonfire night celebrations on the land. As I mentioned earlier, an area
of the land is already protected and the building work may displace the existing wildlife – of
frogs, herons, newts, other birds and the like. OP2 is very much the heart of the village and
it would be a great loss to a community such as Hatton.
Thank you for your time and consideration on this matter.
Yours faithfully
1
Fiona Thompson
From:Sent: 07 May 2015 19:14To: LDPSubject: Aberdeenshire LDP 2016 ResponseAttachments: LDP modification.docx; LPD 2016 - Map for Additional Protected Areas.pdf
Good Afternoon I wish the following response to be taken into consideration when finalising the Aberdeenshire LDP 2016. My details are noted below:
7th May 2015
Tel.
I am not responding on behalf of anyone else. Yours faithfully
Modification that you wish to see
I would like to see some additional areas in and around the village of Daviot given ‘protected’ status. As such we would propose that the following modifications are made to the current draft of the 2016 LDP to give ‘protected’ status to:
the entire field at the bottom of Wellbrae which is bounded by Wellbrae, Wellpark and Daviot Estate (area marked X1 on the attached map);
the entire field to the east and south-east of Loanhead of Daviot Stone Circle and ancient monument looking south-eastward towards Pitblain/Highbury cluster,. (area marked as X2 on the attached map);
the designated area of open space at the new development called Hunter's Park (area marked X£ on the attached map).; and
the small play park within Kirkton Park.
Reason for change
The reason for the desired change is quite clear - unless areas near to the village are protected, the uniqueness of the village will be destroyed for ever.
I (and many others in and around the village) would be hugely concerned if any further development is allowed between Wellbrae, Wellpark and Daviot Estate as this will be detrimental to the landscape setting of Daviot village, Daviot Estate and the Daviot Community Trust's walks/woodland areas. In addition this area (X1) is classified as Class 3.1 Prime Agricultural Land and development here is not preferred by Aberdeenshire Councillor and Scottish Reporters have turned down Planning Applications in this area on a number of occasions.
The area east and south-east from the Stone Circle towards Pitblain/Highbury cluster should be protected to ensure there is no further development so that future generations can enjoy the wonderful views from this ancient monument and local place of interest.
The designated open space within the Hunters View development should be protected in line with the planning consent given to ensure no further houses are squeezed into this site in the coming years. For the same reason the play park within Kirkton Park should also be protected.
I would like to take this opportunity to emphasise that the above modification requested are additional areas that should be protected on top of all the areas given ‘protected’ status in the 2012 LDP. We do hope that Planners and Councillors do take action and support the wishes of the majority of the Daviot village residents by protecting these areas