YOUR DETAILS · 4 Development Plan identified sites to accommodate 4,751 units (Appendix 5, Table 1), yet only 1,451 units are expected to be delivered by the end of 2016 (Appendix

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

Please email or send the form to reach us by

8th May 2015 at the following address:

Post: Planning Policy Team

Infrastructure Services

Aberdeenshire Council

Woodhill House

Westburn Road

ABERDEEN

AB16 5GB

Email: [email protected]

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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.

Mr

John

Findlay

6 May 2015

Ryden LLP, 25 Albyn Place, Aberdeen

AB10 1YL

01224 588866

[email protected]

✔

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Stewart Milne Homes

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

Reason for change

Please refer to Paper Apart.

Please refer to Paper Apart.

1

PAPER APART

REPRESENTATIONS ON BEHALF OF STEWART MILNE HOMES TO THE

PROPOSED ABERDEENSHIRE LOCAL DEVELOPMENT PLAN 2016

Introduction

Stewart Milne Homes welcome the fact that Aberdeenshire Council have published their

proposed Local Development Plan (LDP) 2016 with a view to it being progressed and adopted

timeously. Up-to-date Plans are essential in the current Plan led system.

However, the development industry, and indeed the wider public, must have confidence in the

content of the Plan given its implications for the North East over the next 5 year period.

Stewart Milne Homes have reviewed the proposed Plan and acknowledge that the Settlement

Strategy generally reflects that of the Strategic Development Plan (SDP). However, along with

much of the development industry, Stewart Milne Homes 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 in that regard.

The problems are first evident from the sections summarising the “shaping” of each of the

administrative areas. In Shaping Formartine, for example, the Council note the reliance on

large allocations to meet the SDP requirements and acknowledge that these have not delivered

the required numbers in the extant Plan period. As a consequence, additional sites should be

identified by the Plan to meet the targets set by the SDP. This issue is dealt with more fully

under Objection 2 below. Indeed, Stewart Milne Homes wish to comment and formally object

on a number of Policy and site specific matters. The following representations highlight the

areas of concern, the changes required to the Plan and the justification for seeking those

changes. Separate representations have been submitted in respect of the relevant settlement

statements.

OBJECTION 1:

POLICY R2, HOUSING AND BUSINESS DEVELOPMENT ELSEWHERE IN THE

COUNTRYSIDE

Background

Stewart Milne Homes generally welcome a Policy that encourages housing throughout

Aberdeenshire with the aim of supporting a long term sustainable pattern of development.

However, they object to the more restrictive nature of the Policy compared to that of the extant

LDP.

2

Modifications Required

The bullet points listing acceptable development should be extended to include small scale

growth of settlements; and in the rural housing market area, small scale employment proposals

and small scale additions to cohesive groups.

The distance criterion in relation to small scale growth should revert to 400m and the

redevelopment of brownfield sites should not be limited to small scale development.

Justification

Rural development is a key policy area for Aberdeenshire with the aim of supporting a long

term sustainable pattern of development that balances need, aspirations and demand for

development in rural areas outwith settlements. The Policy, introduced in the extant LDP

(2012), marked a step change in the Council’s approach to rural development. The change

was generally welcomed and the results are now evident throughout the Shire. Given this

success it is contended that it is too soon to amend policy and potentially constrain the

economic growth it is starting to deliver in rural areas. The full terms of the extant policy must

be given a longer period of time to properly assess how it is performing in terms of achieving

the aims of Aberdeenshire Council.

The encouragement to the redevelopment of brownfield land is supported by Stewart Milne

Homes. The reuse of brownfield sites is a key plank of Scottish Planning Policy’s drive to

secure sustainable development and is supported by the SDP.

However, concern must be expressed regarding the restriction to small scale development.

The capacity of the site will be dictated by many factors, not least its scale and the Plan should

not assume that all brownfield sites will be small scale. To do so limits the potential of such

sites to deliver sustainable development and regenerate an area. Examples in recent years

have included Kingseat and Ladysbridge Hospitals. It is accepted that these are an exception

rather than the rule, but it nevertheless demonstrates the need for flexibility in terms of Policy.

OBJECTION 2:

POLICY H1, HOUSING LAND

Introduction

As expressed in the introduction above, there has been a serious failure of the extant LDP to

deliver the housing land requirements set by the approved SDP. These issues were highlighted

by the housebuilders during preparation of the SDP, in response to the Main Issues Report

(MIR) and again, in response to the MIR Addendum. No action was taken and the shortfall is

now evident.

3

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 and the proposed Plan continues

to rely on a number of sites which have been carried forward from the 2006 Local Plan and the

subsequent 2012 Local Development Plan.

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.


A robust review of the deliverability of allocated sites should be undertaken to assess their

effectiveness. Additional sites should be allocated to replace those that cannot be delivered

during the Plan period.

The cap on the number of units that can be developed on an allocated site should be removed

with the unit numbers provided in Appendix 5 and the Settlement Statements being for guidance

only.

Justification

SPP published in June 2014 firmly focusses 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. 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. In allocating sites

paragraph 119 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.

Planning Authorities cannot simply allocate sites to meet the requirements and sit back. They

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 Aberdeenshire, additional sites must be allocated.

It is incumbent on Plans to deliver units on the ground. This is essential to ensure there are no

difficulties with delivering housing later in the Plan period.

The Council’s fall-back position is the 2014 Housing Land Audit, which highlights a supply in

excess of 5 years in the Aberdeen Housing Market Area. However, that 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

4

Development Plan identified sites to accommodate 4,751 units (Appendix 5, Table 1), yet only

1,451 units are expected to be delivered by the end of 2016 (Appendix 5, Tables 4,5 & 6). 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.

The extant Local Development Plan advocated a draw-down 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 draw-down sites are Phase 2 of these larger sites. If the first phase is not

delivering the second phase certainly cannot.

This can be highlighted by reference to two of the larger sites to the south and north of the city.

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. At Cromley

Bank, Ellon, that site was allocated to deliver 745 units in the period 2012-2016. To date, no

units have been delivered on that site and the 2015 draft Housing Land Audit indicates that, in

actual fact, no units will be delivered on that site by the end of 2016. Similar scenarios exist

throughout the Aberdeen Housing Market Area.

The only way this can be resolved is through the allocation of additional sites which are capable

of early delivery to ensure that housing is delivered within the time periods specified by the

SDP. All of these issues were raised during preparation of the SDP, in response to the MIR

and again in response to the MIR Addendum. Copies of representations submitted on behalf

of Stewart Milne Homes are attached at Appendix 1. The concerns raised were based on the

experience and expertise of the housebuilders in delivering development but, unfortunately,

have been ignored. As a consequence, the range and choice of housing has been restricted

by the policies of the planning authority.

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 is a material consideration

in the preparation of this Plan and, in itself, justifies a review of the housing allocations to ensure

a generous land supply, as required by SPP, capable of addressing the increased housing

requirement.

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,

the response to the MIR Addendum (Appendix 1) concluded that the housing land supply in the

Aberdeenshire part of the Aberdeen Housing Market Area should be increased by over 2,800

units.

5

On the basis of the above, and given the focus of Scottish Planning Policy on delivery of

housing, there is a compelling case for the allocation of additional sites through the Local

Development Plan 2016. Stewart Milne Homes have put forward a range of sites in a number

of settlements capable of addressing this. Objections to the failure of the Plan to allocate these

sites have been made to the relevant Settlement Statements. All are capable of early delivery

and should be considered for inclusion in the Local Development Plan 2016.

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.

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 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.

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.

OBJECTION 3:

POLICY H2 AFFORDABLE HOUSING AND ASSOCIATED SUPPLEMENTARY GUIDANCE

Introduction

Objection is taken to the wording of Policy H2 relative to affordable housing. It does not reflect

current Scottish Planning Policy on the subject and seeks to impose a minimum requirement

across Aberdeenshire, which can only be reduced in exceptional circumstances rather than

setting a benchmark figure as proposed by Scottish Planning Policy (SPP).

The provision of affordable housing relies on the delivery of mainstream housing and the onus

on landowners to make land available for development. If an unacceptable burden is placed

on land values there is likely to be a reluctance on the part of landowners to release land for

development. The associated Supplementary Guidance is also inflexible in terms of the

delivery of affordable housing and the range of tenures.

The commuted sums set out in Appendix 1 of the Supplementary Guidance are unacceptable.

No detail is provided regarding the calculation of these sums and the suggestion that they can

be updated periodically removes any certainty from the planning process.

6

Modification Required

Policy H2 should be amended to advise that Aberdeenshire Council will seek 25% of the

serviced plots for affordable housing. The term “no less than” should be removed as the

wording does not reflect Scottish Planning Policy. The word “only” should be removed from

the second sentence of the second paragraph. It places unnecessary emphasis on the

requirement to justify less than the 25%.

Supplementary Guidance should be more flexible in accordance with SPP to permit more

flexibility in terms of the tenures provided on site and to make off-site provision acceptable

rather than only in exceptional circumstances.

The proposed Plan should be more proactive in the delivery of affordable housing.

Consideration should be given to the allocation of specific sites for affordable housing and in

particular, surplus Local Authority owned land or buildings should be identified for affordable

housing as advocated by Planning Advice Note 2/2010: Affordable Housing and Housing Land

Audits.

Justification

Scottish Planning Policy advises that Local Development Plans should clearly set out the scale

and distribution of the affordable housing requirement for their area. It makes a clear statement

that “…the level of affordable housing required as a contribution within a market site

should generally be no more than 25% of the total number of houses”. The inference to

be drawn from this is that the affordable housing needs of each settlement should be identified

up to the benchmark figure of 25%. It is unacceptable for the proposed Plan to require no less

than 25% provision across the Plan area. There will inevitably be settlements or areas where

the requirement is less than 25% and this should be reflected in the proposed Plan. Indeed,

the extant Local Development Plan (2012) identified a number of settlements where the

requirement fell below 25%. Examples include Newburgh (20%), Cluny/Sauchen (10%) and

Dunecht (10%) yet the proposed Local Development Plan seeks to increase these without any

justification through a new Housing Need and Demand Assessment. It is for Aberdeenshire

Council to justify the requirement yet the wording of Policy places the onus on developers to

justify where it is not required.

Scottish Planning Policy at paragraph 129 advises that Planning Authorities should consider

the level of affordable housing contribution which is likely to be deliverable in the current

economic climate, as part of a viable housing development. In formulating their Policy and

Supplementary Guidance Aberdeenshire Council appear to have taken no cognisance of the

economic climate. The housebuilding industry throughout the UK is only now emerging from

the 2008/09 recession with build rates gradually increasing, but falling well short of pre-

recession levels. The affordable housing providers themselves have suffered from a lack of

funding and those individuals seeking Low Cost Home Ownership have been constrained due

to mortgage lending restrictions.

7

More particularly, the North East is currently experiencing a downturn in the economy as a

consequence of reduced oil prices and this is creating uncertainty in the North East. Given that

affordable housing provision is dependent upon the delivery of main stream housing it is

imperative that consideration be given to the economic climate when formulating Policy and

negotiating the level of onsite provision. It benefits neither the development industry nor the

Planning Authority in terms of its requirement to deliver affordable housing if development is

stifled by the Policy requirements of the Local Development Plan.

This issue is compounded by the fact that the Supplementary Guidance seeks to impose the

burden of provision on landowners. The Guidance acknowledges that little or no profit will be

generated from the affordable housing and expect this cost to be off-set when negotiating a

land value with site owners. Similarly, the cost of any infrastructure or community facilities are

expected to be met by a deduction from land values. Such assumptions are dangerous and

not based on good planning principles. The delivery of development relies on a willing seller

and a willing buyer and if the burden placed on land values become too great many landowners

will simply not be prepared to release their land for development. Not all are in a position where

they have to sell their land. Also, in the past, where developers have demonstrated that they

are prepared to off-set some of the costs against a reduction in profit that is not sustainable in

the long term. As a consequence, the housing land supply will ultimately reduce with those

who are prepared to sell commanding higher values, which in turn drives up house prices and

reduces the number of new homes, both main stream and affordable, being delivered.

Planning Advice Note 2/2010 is clear at paragraph 2 where it advises that the advice in the

Planning Advice Note has to be “…be applied constructively and with flexibility in

response to financial and market conditions”. The Local Development Plan places the

burden of delivering affordable housing firmly on housebuilders and landowners. It is

contended that the Plan should be more proactive in terms of identifying and allocating specific

sites for affordable housing. Planning Advice Note 2/2010 promotes four additional or

alternative means of delivering affordable housing which could be considered by Planning

Authorities. These include:

1. Allocating new sites in Local Development Plans specifically for affordable housing;

2. Identifying plots for self-build dwellings;

3. Using compulsory purchase powers to support the delivery of new supply and

regeneration;

4. Making appropriate surplus local authority land or buildings available for affordable

housing.

Given the encouragement and mechanisms available to Aberdeenshire Council to take a

proactive approach to delivery, this should be reflected through the Local Development Plan.

In those areas where demand is high for affordable housing the proposed Plan should identify

specific sites for such provision and the method by which they will be delivered.

Appendix 1 of the Supplementary Guidance recognises that contributions specific to a particular

development will be dependent on many fluctuating factors, such as an assessment of relevant

housing information at settlement level, and of local market conditions and site circumstances,

8

including site development costs. Whilst such an approach is welcome, the wording of Policy

H2 contradicts this. In effect, the Policy is predicated on the view that every settlement

throughout Aberdeenshire has a requirement of at least 25%. Accordingly, Policy requires

rewording, as suggested, to better reflect the Council’s own Supplementary Guidance and

Scottish Planning Policy.

Greater flexibility should be permitted in both the onsite delivery of affordable housing and off-

site delivery. Scottish Planning Policy at paragraph 126 highlights the various ways in which

affordable housing can be provided. Planning Advice Note 2/2010 sets out a range of tenure

types which can contribute to affordable housing and emphasises that it is important that Local

Authorities, developers and Registered Social Landlords (RSLs) consider the full range of

options and apply them as appropriate.

Unfortunately, whilst the Supplementary Guidance acknowledges the range of possible

tenures, the Supplementary Guidance then advises that the preferred means of provision is the

transfer of serviced land to an RSL or the Council. Stewart Milne Homes have a fundamental

issue with this approach as it limits choice and, in any event, there are many instances where

no funding is available to these bodies to enable them to take up the transfer of serviced land.

Yet, whether appropriate or not, this preference is applied throughout the Plan area. To assist

the development industry in their negotiations with landowners the proposed Plan should

provide an indication of the preferred tenure on a settlement basis, if not a site specific basis.

PAN 2/2010 at paragraph 5 is clear that the Local Authority should provide as much clarity as

they can in Local Housing Strategies and Development Plans given the impact of tenure type

on the valuation of land.

There should also be greater flexibility to allow off-site provision of affordable housing. In many

instances it may simply not be feasible or viable to provide affordable housing on site. In some

developments, the factoring costs for shared amenities and open space provision are simply

not capable of being met by RSL’s or the occupiers of affordable housing. Other reasons

specified in PAN 2/2010 include the size of site, its location, topography, conversion of buildings

where relevant standards cannot be met and other local circumstances, such as whether an

appropriate tenure mix can be delivered. These examples should be referred to in the

Supplementary Guidance and a welcoming and flexible approach taken to off-site provision.

Such an approach could assist with the delivery of affordable housing and ultimately deliver a

greater number of units.

The scope for payment of commuted sums where neither on-site nor off-site provision of

affordable housing is either feasible or desirable is to be welcomed. However, it should not be

seen as a “last resort”. The payment of commuted sums could greatly assist the Local

Authority and RSLs in funding affordable housing delivery in areas of acute need. Those

commuted sums could be the catalyst to enable development on sites owned by the Council or

an RSL.

The scale of the commuted sums expected, as set out in Appendix 1 of the Supplementary

Guidance, are unacceptable. No evidence nor justification has been provided to demonstrate

how those sums have been arrived at. The Local Development Plan must be transparent and

9

all parties must be confident that the sums being sought are justified. This is essential for

developers’ in negotiating with landowners and PAN 2/2010 specifically advises that

developers will expect certainty from the Development Plan and the development management

process.

Furthermore, a statement that “…The commuted sum plot requirements will be updated

periodically…” is entirely unacceptable. Not only have the Council failed to justify the level of

the commuted sums, they then suggest they can be changed at any time. This fails to provide

developers with the certainty required by Scottish Government Guidance and as such, the

reference should be removed from the Supplementary Guidance. Any review of the commuted

sums should only be undertaken in consultation with the development industry and the

appropriate forum for that is through the Development Plan process.

In summary, the Supplementary Guidance on affordable housing requires to be redrafted in

accordance with the guidance provided through Planning Advice Note 2/2010. That guidance

has to be applied constructively and with flexibility in response to financial and market

conditions. It specifically advises at paragraph 2 that the key matters where flexibility may be

exercised include:

1. A range of tenures;

2. a percentage of affordable units identified in the development plan policy and on a specific

site;

3. provision on another site; and, in some cases,

4. the use of a commuted sum.

For the reasons set out above these issues are not adequately addressed in Policy H2

Affordable Housing or its associated Supplementary Guidance.

OBJECTION 4:

POLICY P2 OPEN SPACE AND ACCESS IN NEW DEVELOPMENT

Introduction

The wording of Policy P2 relative to open space requirements is unacceptable. The 40% and

120 sq m requirements are inflexible and seek to impose a “one size fits all” requirement to

each and every situation.

The Policy approach advocated by the proposed Plan reflects that initially promoted through

the extant Plan when published as a proposed Plan in 2010. The requirements at that time

were the subject of substantial objection and the Policy wording was amended by Reporters at

the Examination in Public to address the concerns of objectors. The proposed Plan seeks to

reintroduce the original wording considered unacceptable by the Reporters.

10


Wording of Policy P2 should be amended to set a general target of 40% open space provision,

but be mindful of individual site and settlement circumstances. The Policy should make it clear

that in each case, the actual proportion will take account of the location, function and

characteristics of the development proposal and site; the function of the open space proposed;

and, where appropriate, the function and characteristics of existing open space in the area.

The above should also be applied to the requirements for open space provision on allocated

sites of less than 50 homes.

Justification

As currently worded, the Policy requirement to devote at least 40% of each major development

site to good quality open space is unacceptable. It takes no cognisance of the quality or quantity

of open space or other areas of recreation in the immediate vicinity or indeed, the wider

settlement. Each site and settlement is different in nature yet the Policy requirement fails to

draw any distinction between those sites lying in urban areas and those lying in rural areas,

which may already benefit from access to significant areas of recreational land. A site could sit

immediately adjacent to an existing parkland or an extensive amenity woodland, yet still be

expected to meet the 40% requirement.

Aberdeenshire is primarily a rural area, where residents have relatively easy access to vast

areas of beach, countryside and woodlands. For this reason, a “one size fits all” approach is

inappropriate and the Policy should be more targeted towards those communities where there

is an identified shortfall or they lack access to areas of countryside for public enjoyment. For

those reasons the Reporter at the previous Examination considered that the Policy should

provide some flexibility to accommodate site and settlement characteristics. This requires to

be recognised in the proposed Plan.

The requirement to provide at least 40% open space provision on larger sites and at least 120

sq m on sites of less than 50 homes demonstrates a distinct lack of understanding of the

commercial basis of land and property development. The burden placed on landowners and

developers is compounded when the requirements for affordable housing and developer

obligations are factored in. These burdens will have an inevitable impact on the delivery of both

mainstream and affordable housing. In addition to the provision of public open space land will

also be lost to accommodate distributor roads, community facilities etc, which taken together,

could make sites unviable for development.

The requirements also conflict with other Planning Policy aims, such as the efficient use of land

and the creation of sustainable mixed communities, where a mix of house types and affordable

housing are to be provided. The requirement could also prejudice the Strategic Development

Plan target for a density of 30 dwellings per hectare in Strategic Growth Areas. Aberdeenshire

Council in evidence to the previous Examination in Public acknowledged that their open space

expectation would result in a development density of 22 houses per hectare, a figure well below

the then Structure Plan requirement. As a consequence, the Reporters concluded that “In

11

providing a suitable density for development and a range of house types, there may not

be the opportunity to provide the open space envisaged and provide sustainable

developments”. The Reporter went on to advise that such provision may lead to

unsustainable development patterns, which do not comply with government objectives or the

requirements of the then Structure Plan. The Structure Plan requirements referred to have

been carried forward into the Strategic Development Plan, to which the proposed Local

Development Plan must conform. As a consequence, there is no justification for Aberdeenshire

Council seeking to reintroduce more onerous requirements in terms of the provision of public

open space.

OBJECTION 5:

POLICY P3, INFILL AND HOUSEHOLD DEVELOPMENTS WITHIN SETTLEMENTS

Introduction

Whilst Stewart Milne Homes generally welcome Policy P3 relative to the acceptance of infill

development, it is contended that it could offer greater encouragement to the development of

infill or more particularly, brownfield sites. Scottish Planning Policy specifically encourages

such development and the Strategic Development Plan imposes no limit on the number of

houses that can be developed on brownfield sites. Such sites can make an important

contribution to the housing land supply.


The Policy wording should be amended to remove reference to such development opportunities

being of only small to medium scale. The scale of development will be dictated by the site size.

The Policy should also be amended to acknowledge that such development has the ability to

utilise spare capacity in infrastructure and community facilities and in many cases, can help

sustain existing services and facilities, such as primary schools.

Justification

Scottish Planning Policy published in June 2014 introduced a presumption in favour of

development that contributes to sustainable development. This requires that the planning

system should support economically, environmentally and socially sustainable places by

enabling development that balances the costs and benefits of a proposal over the longer term.

The aim is to achieve the right development in the right place. This means that policies and

decisions should be guided by a range of principles. These include;

1. Giving due weight to net economic benefit;

2. making efficient use of existing capacities of land, buildings and infrastructure, including

supporting town centre and regeneration priorities; and,

3. supporting delivery of accessible housing, business, retailing and leisure development.

12

It further highlights that a key policy principle in directing the right development to the right place

is considering the reuse or redevelopment of brownfield land before new development takes

place on greenfield sites. These principles are enshrined in the Strategic Development Plan.

It requires that land brought forward for development must be used efficiently and brownfield

sites and regeneration areas should be given priority. Among its targets is to increase the

range and quality of housing and the residential environment in the regeneration priority areas

and for all housing development of over 1.0 hectare in Strategic Growth Areas to have no less

than 30 dwellings per hectare thereby maximising the use of land.

On the basis of Scottish Planning Policy and Strategic Development Plan requirements Policy

P3 should be amended to provide greater encouragement to the development of infill sites. In

particular, there should be no presumption made in terms of the size of site that constitutes infill

development and specific allowance should be made for higher density development on infill

sites where it does not erode the character or amenity of the surrounding area.

OBJECTION 6:

POLICY PR2, PROTECTING IMPORTANT DEVELOPMENT SITES

Introduction

Policy PR2 seeks to restrict development on sites that “may reasonably” be needed in the

future for a range of developments, including roads, community infrastructure etc. Such an

approach has the ability to create blight and stagnate the growth of communities.


The proposed Plan should only seek to protect those sites which are required for the various

infrastructure and facilities within the 5 year Plan period and where there is a commitment to

funding such facilities.

Justification

There are examples throughout the Plan where land has been reserved for infrastructure or

community facility projects. However, few of the sites have been developed and in many

instances, no approach has even been made by the acquiring authority to the landowner to

establish if there is a willingness to sell, or indeed, take any form of action in terms of

compulsory acquisition.

Many of those sites, being within or adjacent to settlements, would otherwise have had

development potential for the landowner or developer and they have been denied the

opportunity of realising that due to the restrictions imposed by the Plan. At Portlethen land,

with the benefit of consent for Class 4 Business Use, has been reserved since preparation of

the 2012 Local Development Plan for a park and ride car park. However, no steps have been

taken by the Council to acquire this land. This is unacceptable and results in the land becoming

13

blighted. Unless there is a funding commitment to the specified development and a clear

timescale for its implementation it should be omitted from the Plan.

OBJECTION 7:

POLICY C1, USING RESOURCES IN BUILDINGS

Introduction

Whilst Stewart Milne Homes recognise the importance of addressing climate change, the

requirements set out in Policy C1 should more appropriately be addressed through Building

Regulations rather than through the Local Development Plan. The Policy is in effect duplicating

other controls. The housebuilding industry maintains that a “fabric first” approach should be

adopted ahead of the requirement to install low and zero carbon generating technologies. Such

technologies are often unproven, significantly add to the cost of development, and are not

recognised by mortgage lenders.


Policy C1 should be substantially re-written to focus only on those matters which can be directly

influenced or delivered by the planning system. Specifically, the targets set for CO2 reduction

achieved by installing low and zero carbon generating technologies in new developments

should be removed. Reference to district heating schemes for all major development proposals

should be removed and the requirement to provide “appropriate infrastructure” from the

edge of the development site to a location adjacent to the rising main of each property should

be applied only to areas not served by mains gas.

Justification

The need to address climate change is recognised and the focus of Scottish Planning Policy

on sustainable development is welcomed by Stewart Milne Homes. However, in seeking to

reduce carbon emissions and adapting to climate change to create a low carbon place, the

focus of SPP is in supporting diversification of the energy sector with the spatial strategy of the

National Planning Framework 3 (NPF3) aimed at reducing greenhouse gas emissions and

facilitating adaption to climate change. The focus is on the development of generation

technologies that will help to reduce greenhouse gas emissions from the energy sector.

The requirement to install low and zero carbon generating technologies in new residential

developments does not flow directly from SPP. It encourages Local Development Plans to take

a more holistic view by, for example, using heat mapping to identify the potential for the co-

location of developments with a high heat demand with sources of heat supply. It advises that

heat demand sites for particular consideration include high density developments, communities

off the gas grid, fuel poor areas and anchor developments, such as hospitals, schools, leisure

centres and heat intensive industry. The onus is, therefore, on the planning authority through

their Local Development Plans to be more proactive in terms of identifying opportunities for co-

location of development. Paragraph 159 specifically advises that Local Development Plans

14

should identify where heat networks, heat storage and energy centres exist or would be

appropriate and include the policies to support their implementation. Aberdeenshire Council

policy as presently worded places the burden firmly on the housebuilding industry.

Low and zero carbon generating technologies are complex, as are the legislative issues

regarding their implementation. These are beyond the scope of planning control and in

particular, the Local Development Plan process. It is essential that technical matters of

construction and design are regulated by the building standards rather than by planning policy.

The standards expected of new development are set by the Building Regulations and should

not be undermined on an arbitrary basis by planning policy.

The housebuilding industry is clear and made the point in representations at the MIR stage,

that such technologies are uneconomic, not wanted by most customers, cause problems for

funding, insurance and maintenance, and do not contribute significant energy and carbon

savings in a context where Scottish housebuilding is already amongst the most energy efficient

and low carbon in Europe. The housebuilding industry contend that the focus should firmly be

on a “fabric first” approach.

The Climate Change Act, which contains some of the provisions on micro-renewables, was

subject to Statutory Review by Ministers in 2014 and the Government recognises that the

requirement to use low and zero carbon technologies is proving impractical and problematic.

The Sullivan Panel, appointed by Scottish Ministers in 2013 to provide an update on a Low

Carbon Building Strategy for Scotland specifically noted that concerns can arise from

requirements and prescription on low carbon equipment within the Scottish Planning System,

in addition to provisions under Building Regulations. In reviewing the staged improvements,

the Panel asked the Scottish Government to examine elements of the planning & building

standards system which addressed greenhouse gas emissions. They advised that “…these

should offer consistency and alignment in policy approach and delivery, providing

clarity to developers”.

The Panel also acknowledged that delivery of zero carbon objectives through an entirely on-

site strategy is not currently a realistic approach for mainstream housing production, due to

issues of cost and practicality of building to such a standard on many sites. In taking forward

the standard set for building-related measures the Panel took the view that development should

focus on reducing energy demand through a “fabric first” approach, with efficient services,

supported by the use of renewable technologies, where appropriate. They emphasised that

this was particularly relevant for new homes and strongly advocate the use of simple solutions

rather than layering of complex technologies.

The Policy, as presently worded, takes little cognisance of the issues raised by the Sullivan

Panel. Policy C1 advocates a complex multi-layered approach with the onus placed firmly on

developers to deliver savings through the installation of low and zero carbon generating

technologies. It further places the burden on developers to assess the feasibility of district

hearing schemes and imposes a requirement on developers to install infrastructure for heat

networks even where there is no prospect of a district heating system being installed. These

15

burdens place yet further financial demands on the housebuilding industry, which in turn, could

significantly reduce its ability to deliver the scale of new homes required.

OBJECTION 8:

POLICY C4, FLOODING

Introduction

Stewart Milne Homes fully recognises the impact flooding can have on people and businesses

and are supportive of the precautionary approach to flood risk. NPF3 supports a catchment-

scale approach to sustainable flood risk management and SPP provides a flood risk framework

to guide development. However, Aberdeenshire Council appear to ignore this and introduce

an entirely new framework in Policy C4. As a consequence, Stewart Milne Homes strongly

object to the wording of Policy C4, which would seriously constrain the amount of developable

land.


Policy C4 should be amended to properly reflect the flood risk framework set out in Scottish

Planning Policy at Section 263.

Justification

Stewart Milne Homes acknowledge that it is incumbent upon planning authorities to have regard

to the probability of flooding from all sources and take flood risk into account when preparing

development plans and determining planning applications. This is advocated by Scottish

Planning Policy at paragraph 258. However, SPP then goes on at paragraph 263 to advise

that Local Development Plans should use the flood risk framework set out in that paragraph to

guide development. This sets our three categories of coastal and water course flood risk,

together with guidance on surface water flooding, and the appropriate planning approach for

each.

It defines little or no risk as an annual probability of coastal or water course flooding of less than

0.1% (1:1000 years), yet Policy C4 requires development in these areas to be designed to be

flood resistant and use construction methods to assist in the evacuation of people and minimise

damage. This adds yet further cost to development when there is absolutely no basis for such

a requirement.

Low to medium risk is defined as an annual probability between 0.1% and 0.5% (1:1000 – 1:200

years). Scottish Planning Policy considers such land to be suitable for most development

although it notes that a Flood Risk Assessment may be required at the upper end of the

probability range (1:200 years), and for essential infrastructure and the most vulnerable uses.

Whilst medium to high risk is defined by Scottish Planning Policy as an annual probability of

flooding greater than 0.5% (1:200 years), it considers that such land may be suitable for

residential, institutional, commercial or industrial development within built up areas, provided

16

flood protection measures to appropriate standard already exist and are maintained, are under

construction, or are a planned measure in a current Flood Risk Management Plan. In terms of

surface water flooding, infrastructure and building should generally be designed to be free from

surface water flooding and rainfall events where the probability of occurrence is greater than

0.5% (1:200 years).

Despite the clear framework set out in Scottish Planning Policy, Policy C4 imposes an entirely

arbitrary risk level of 1:400 years and advises that they will not approve development on what

they term to be land at medium or high risk of flooding. This limitation has entirely no basis and

should be removed. The existing levels of flood risk have been devised on the basis of analysis

of weather trends and flood events, and already include a free board allowance above the 1:200

years risk.

OBJECTION 9:

POLICY RD1 PROVIDING SUITABLE SERVICES

Introduction

Stewart Milne Homes, whilst recognising the need for adequate infrastructure provision to allow

development to proceed, has a fundamental issue with the burden placed on the development

industry by Policy RD1. Specifically, water and waste water are the responsibility of Scottish

Water and provided their five criteria are met, they will allow connection to their network.


The opening paragraph to Policy RD1 should be amended to read “we will only allow

development where adequate road, waste management, water or waste water treatment

facilities, connections and treatment are available or can be provided”.

The subsequent text should be amended to recognise the responsibilities of Scottish Water and

specifically highlight their criteria for connection to services.

Justification

Stewart Milne Homes recognise their responsibilities to provide infrastructure to service their

development. However, Policy RD1 goes beyond what can be expected of a developer and

places yet further burdens on the development industry.

The opening paragraph to Policy RD1 places the requirement for infrastructure provision firmly

on the developer. However, responsibility for the provision of water and waste water services

also rests with Scottish Water and this should be recognised in the Policy.

Under current funding rules, the cost and programming of any work associated with upgrading

Part 4 infrastructure, which includes strategic assets such as water intakes, water impounding

reservoirs, water pumping stations and aqueducts and, water and waste water treatment works,

17

is the responsibility of Scottish Water. Scottish Water will provide and allow connection to such

facilities where the criteria are met. These comprise:

1. The development is supported by the Local Development Plan and has outline or full

planning permission;

2. the land is controlled by a developer;

3. network constraints will be mitigated by the developer;

4. there is time remaining on the planning permission; and,

5. annual build rates are shown to be reasonable.

The Policy advises that Scottish Water and The Scottish Environment Protection Agency are

key consultees regarding water and waste water infrastructure and should be approached at

an early stage to establish what capacity may be available or if the provision of new capacity

can be made available. However, it is also incumbent upon the planning authorities to consult

these bodies during the preparation of their Local Development Plans. Similarly, in preparing

Action Programmes required by Section 21 of the Town and Country Planning (Scotland) Act

1997, the onus is firmly on the planning authority to consult with key agencies. As such, if a

site is allocated in the Plan, there should be a presumption that adequate water and drainage

infrastructure will be available or can be made available to service that development. The

assessment of available infrastructure requirements to provide such infrastructure should be a

fundamental part of Plan preparation.

The requirement for a Development Impact Assessment or other form of investigation or

modelling work to identify the impacts of development on current infrastructure should not be

included in the Local Development Plan. That is an issue to be addressed between the

developer and Scottish Water. Currently, Scottish Water has a monopoly on undertaking such

assessments and the development industry has serious concerns in that regard. The

Development Plan should not add credibility to that monopoly.

OBJECTION 10:

POLICY RD2, DEVELOPER OBLIGATIONS AND ASSOCIATED SUPPLEMENTARY

GUIDANCE

Introduction

It is a concern of Stewart Milne Homes, and indeed the wider house building industry, that the

developer obligations being imposed by Aberdeenshire Council are simply becoming a “roof

tax” on development. Objection is also taken to the ever expanding list of services and

infrastructure which developers are expected to contribute to, particularly where those services

are the statutory responsibility of other bodies who receive central government funding through

taxation for their functions.

The Policy and Supplementary Guidance fail to have proper regard to Scottish Government

Circular 3/2012: Planning Obligations and Good Neighbour Agreements. They should be

reviewed in accordance with the strict principles set down in that circular.

18


The introductory paragraph to RD2 should be amended to properly reflect the requirements of

Circular 3/2012. In particular, the terms “fairly and reasonably relate” are not recognised in

the Circular.

The requirement for contributions to the Strategic Transport Fund and to healthcare facilities

should be removed from the plan. Supplementary Guidance relative to the remaining

requirements should be reviewed and a more robust justification provided in accordance with

Circular 3/2012. The Settlement Statements should also be amended to make it clear whether

certain infrastructure contributions will be required and provide an indication of the magnitude

of those contributions.

Justification

Paragraph 2 of Circular 3/2012 advises that it sets out the circumstances in which Planning

Obligations and Good Neighbour Agreements can be used and how they can be concluded

efficiently. It emphasises that planning authorities should promote obligations in strict

compliance with the tests set out in Circular 3/2012. Those tests are reiterated in the

Supplementary Guidance but the preamble fails to note that planning obligations should only

be sought where they meet all of the tests. The wording of the third test must also be amended

to accurately reflect the wording in the circular. The word “or” has been omitted.

The Circular further advises that planning obligations have a limited, but useful, role to play in

the development management process where they can be used to overcome obstacles to the

grant of Planning Permission. It emphasises that planning obligations should be agreed

between the parties involved; developers should not be required to enter into a planning

obligation. Increasingly however, developers are being left with no alternative but to enter into

a planning obligation. The formulaic approach adopted by Aberdeenshire Council and

conveyed through the Supplementary Guidance prevents developers with a “fait accompli”

leaving little scope for flexibility or negotiation. The wording of Policy RD2 simply seeks to

reinforce that.

The opening sentence to policy advises that a Council will support development if the developer

makes a reasonable contribution in cash or in kind. It reiterates this in the following sentence

that contributions must fairly and reasonably relate in scale to the proposed development.

However, “fairly and reasonably” are not terms used in the circular. It requires that

contributions “...must always be related and proportionate in scale and kind to the

development in question”. This needs to be accurately reflected in the policy wording.

The subsequent paragraph advises that further guidance on developer obligations is provided

in the Settlement Statements. However, many of the statements contained ambiguous

references as to the requirements for certain types of obligations. It would appear to be a case

of “if in doubt ask for it”. This approach hardly provides the development industry with the

certainty required or expected by Scottish Planning Policy and makes negotiation with land

19

owners extremely difficult. The Circular is perfectly clear that the Development Plan should be

the point at which consideration of the potential need for, and use of, planning obligations

begins. Paragraph 32 advises that in drafting Development Plans, planning authorities should

work with infrastructure providers, other local authority departments and consultees to

undertake a robust assessment of infrastructure requirements, the funding implications and the

timescales involved. On this basis, it is perfectly reasonable to expect that the Local

Development Plan, and Settlement Statements in particular, should provide clarity on the range

and scale of contributions expected.

Experience would suggest that planning obligations are being sought on nearly every

development, whether that be for community facilities, education, healthcare, etc. Often those

obligations are being sought even where there is pre-existing capacity, particularly in relation

to education and healthcare. Stewart Milne Homes contend that if capacity exists in any facility

or infrastructure, the development should be allowed to utilise that spare capacity without

having to make contributions.

The formulaic approach currently used by Aberdeenshire Council and set out in the

Supplementary Guidance to calculate the scale of contributions should be reviewed. It takes

no account of individual site and local circumstances. For example, the cost of a new build

primary school in Fraserburgh could be significantly different from that in Laurencekirk.

Similarly, the reconfiguration costs of no two building will be the same. If the Council are to

persist in such an approach, there should be scope for the return of any unspent funds.

Turning to the items to which contributions are expected, Stewart Milne Homes contend that

there are no grounds for contributions to the Strategic Transport Fund, which primarily relates

to Aberdeen City, or to healthcare provision. The Strategic Transport Fund seeks a defined

contribution from every house falling within a Strategic Growth Area, and in some exceptional

cases falling within local Growth and Diversification Areas, regardless of the impact in scale

and kind that the development proposed has on the junctions to be improved as part of the

Strategic Transport Fund. The Fund was promoted through the Strategic Development Plan

and considered at the Examination in Public into that Plan. The Reporter concluded that

contributions could only be sought to the Strategic Transport Fund where there was a direct

impact arising from the development. This was effectively to comply with Circular 3/2012.

Policy and Supplementary Guidance as presently worded, fails to recognise this.

Stewart Milne Homes contend that contributions to health facilities are entirely unacceptable,

many medical centres, dental facilities and community pharmacies primarily operate as

commercial ventures and should not expect to receive funding from developers. Healthcare is

funded by central government through taxation. It is inappropriate for the development industry

to be expected to provide subsidy to the National Health Service.

Appendix 1

The Main Issues Report is the main focus for engagement on the Aberdeenshire Local Development Plan 2016. The report sets out choices and options for the land allocations that could be set for development, and for the policies that Aberdeenshire Council will use to make decisions on planning applications. The Main Issues Report was published on 28th October 2013 along with a Monitoring Report and an interim Environmental Report of the Strategic Environmental Assessment. It is supported by a series of analysis papers. All of these documents can be found at www.aberdeenshire.gov.uk/ldp.

This form should be used to provide us with your views on these questions, or on any other issue raised by either the Main Issues Report, the Monitoring Report, the interim Environmental report or, indeed any other matter that you feel that we need to consider.

MAIN ISSUES REPORT RESPONSE FORM

All comments received will be carefully assessed and will be used to inform the preparation of the Proposed Aberdeenshire Local Development Plan. There will be a further opportunity to comment on the specific proposals contained in this plan when it is published, in October 2014.

Please email to [email protected] or send this form to reach us by 1st February 2014.

FAIR PROCESSING NOTICE

The Data Controller for this information is Aberdeenshire Council.

The data on the form will be used to inform a public debate on the issues and choices presented in the Main Issues Report of the Aberdeenshire Local Development Plan 2016. It will inform the content of the Proposed Aberdeenshire Local Development Plan.

This data will potentially be disclosed worldwide (via publication on Internet). We will not publish any address information, but may publish the name of the person completing the form.

By completing and submitting this form, you are consenting to the above processing.

IF YOU HAVE ANY QUERIES REGARDING THE COMPLETION OF THIS FORM, OR REQUIRE FURTHER ASSISTANCE, PLEASE CONTACT:

Aberdeenshire Council, Planning Policy Team Tel: 01224 664221

Aberdeenshire Local Development PlanWoodhill HouseWestburn RoadAberdeenAB16 5GB

Tel: 01224 664221Fax: 01224 664679Web: www.aberdeenshire.gov.uk/ldpEmail: [email protected]

LDPLOCAL DEVELOPMENT PLAN 2016

ABERDEENSHIRE

This is the Main Issues Report and associated documents of the Aberdeenshire Local Development Plan 2016.

If you have difficulty understanding this document and require a translation, or would like a copy in larger print, please phone us on 01224 665168.

Aberdino srities 2016 metų Vietos plėtros plano Pagrindinių klausimų sprendimo pranešimas ir su juo susiję dokumentai. Jei jums yra sunku suprasti šį dokumentą ir norėtumėte šio dokumento verstos kopijos, ar Dideliu šriftu, prašau kreipkitės telefonu 01224 665168.

Это - Отчет по основным вопросам и документы, связанные с Местным планом развития области Абердиншир до 2016 г.Если у вас имеются трудности в понимании этого документа, и если вы нуждаетесь в его переводе или в копии укрупненным шрифтом, просим позвонить по телефону 01224 665168.

To jest Sprawozdanie na temat Głównych Zagadnień Lokalnego Planu Rozwojowego Aberdeenshire 2016 i powiązane z nimi dokumenty. Jeśli mają Państwo trudności ze zrozumieniem tego dokumentu i wymagają tłumaczenia, lub chcieliby otrzymać odpis w dużym druku, proszę się z nami skontaktować pod numerem telefonu 01224 665168.

Šis ir Aberdīnšīras 2016. gada Vietējās attīstības plāna Galveno jautājumu pārskats un ar to saistītie dokumenti. Ja Jums ir grūtības saprast šo dokumentu un Jums vajadzīgs tulkojums, vai arī ja Jūs gribētu saņemt tā eksemplāru lielākā drukā, lūdzu, piezvaniet mums pa tel. 01224 665168

2016

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Please provide us with your comments below ensuring you tick the appropriate box to highlight what issue you are commenting on. Please feel free to add any extra pages you may require, ensuring you highlight the issue. We will summarise long 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.

Are you answering a question? Yes / No

Question Number being answer

YOUR COMMENTSPlease use this form to make comments on the Aberdeenshire Local Development Plan Main Issues Report 2013. 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 1st February 2014 at the following address:

Post: Planning Policy Team Infrastructure ServicesAberdeenshire CouncilWoodhill HouseWestburn RoadABERDEENAB16 5GB


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YOUR DETAILS


01224 588866

Findlay Mr

[email protected] X

X

John

AB10 1YL

Stewart Milne Homes

Ryden LLP, 25 Albyn Place, Aberdeen 31 January 2014

Please provide us with your comments below ensuring you tick the appropriate box to highlight what issue you are commenting on. Please feel free to add any extra pages you may require, ensuring you highlight the issue. We will summarise long 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 COMMENTSPlease use this form to make comments on the Aberdeenshire Local Development Plan Main Issues Report 2013. 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 1st February 2014 at the following address:



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Save this form to your system for your own records and send a copy to the address on the previous page

13

PLEASE REFER TO PAPER APART IN RESPONSE TO QUESTION 13.

The Main Issues Report is the main focus for engagement on the Aberdeenshire Local Development Plan 2016. The report sets out choices and options for the land allocations that could be set for development, and for the policies that Aberdeenshire Council will use to make decisions on planning applications. The Main Issues Report was published on 28th October 2013 along with a Monitoring Report and an interim Environmental Report of the Strategic Environmental Assessment. It is supported by a series of analysis papers. All of these documents can be found at www.aberdeenshire.gov.uk/ldp.

This form should be used to provide us with your views on these questions, or on any other issue raised by either the Main Issues Report, the Monitoring Report, the interim Environmental report or, indeed any other matter that you feel that we need to consider.

MAIN ISSUES REPORT RESPONSE FORM

All comments received will be carefully assessed and will be used to inform the preparation of the Proposed Aberdeenshire Local Development Plan. There will be a further opportunity to comment on the specific proposals contained in this plan when it is published, in October 2014.

Please email to [email protected] or send this form to reach us by 1st February 2014.

FAIR PROCESSING NOTICE

The Data Controller for this information is Aberdeenshire Council.

The data on the form will be used to inform a public debate on the issues and choices presented in the Main Issues Report of the Aberdeenshire Local Development Plan 2016. It will inform the content of the Proposed Aberdeenshire Local Development Plan.

This data will potentially be disclosed worldwide (via publication on Internet). We will not publish any address information, but may publish the name of the person completing the form.

By completing and submitting this form, you are consenting to the above processing.

IF YOU HAVE ANY QUERIES REGARDING THE COMPLETION OF THIS FORM, OR REQUIRE FURTHER ASSISTANCE, PLEASE CONTACT:

Aberdeenshire Council, Planning Policy Team Tel: 01224 664221

Aberdeenshire Local Development PlanWoodhill HouseWestburn RoadAberdeenAB16 5GB

Tel: 01224 664221Fax: 01224 664679Web: www.aberdeenshire.gov.uk/ldpEmail: [email protected]


ABERDEENSHIRE

This is the Main Issues Report and associated documents of the Aberdeenshire Local Development Plan 2016.

If you have difficulty understanding this document and require a translation, or would like a copy in larger print, please phone us on 01224 665168.

Aberdino srities 2016 metų Vietos plėtros plano Pagrindinių klausimų sprendimo pranešimas ir su juo susiję dokumentai. Jei jums yra sunku suprasti šį dokumentą ir norėtumėte šio dokumento verstos kopijos, ar Dideliu šriftu, prašau kreipkitės telefonu 01224 665168.

Это - Отчет по основным вопросам и документы, связанные с Местным планом развития области Абердиншир до 2016 г.Если у вас имеются трудности в понимании этого документа, и если вы нуждаетесь в его переводе или в копии укрупненным шрифтом, просим позвонить по телефону 01224 665168.



2016

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PAPER APART Representations to the Main Issues Report on behalf of Stewart Milne Homes in response to Question 13 relative to the allocation of additional housing sites The settlement strategy reflects that of the Extant Structure Plan and the proposed Strategic Development Plan. Whilst Stewart Milne Homes is supportive of this strategy, serious reservations must be expressed regarding the Main Issues Report’s (MIR) preferred land supply option. It is contended that the Local Development Plan Review should be allocating more sites for residential development to ensure that there is sufficient land to provide for at least a 5 year effective supply of housing land at the end of the Plan period in 2023. The MIR notes that completion rates for new housing are anticipated to double by 2016 and if, as expected, contrary to Figure 8, that that trend continues, then it would be prudent to make adequate provision in an effort to provide an adequate supply and avoid planning by appeal. The MIR notes that the proposed Strategic Development Plan “….is clear that allocations made previously for the period up to 2023 are now expected to provide an effective supply of development land for the whole Plan period (2017-2026)”. However, such an assertion provoked significant objection from the development industry, including Stewart Milne Homes, to the proposed Strategic Development Plan. Notwithstanding the Reporters recommendations, which have still to be accepted by Scottish Ministers, on the proposed Strategic Development Plan, the development industry maintain their concerns regarding the adequacy of the land supply and contend that further sites should be allocated to ensure at least a 5 year supply of effective sites at the end of the Plan period. The likely deficit is compounded by the fact that a number of large sites identified for development within the extant Local Development Plan have not come forward for development within the timescales envisaged. There are a number of examples throughout the Aberdeen Housing Market Area (AHMA), not least Elsick, and the 5 year land supply highlighted in the most recent 2013 Housing Land Audit, has only been achieved as a consequence of sites coming forward in Aberdeen City. Whilst some sites have been drawn down early to augment the 2012-2016 supply, a number of other sites carried forward from the previous Local Plan are no longer effective, or are being delivered at a slower rate than predicted, all of which exacerbates the problem. Further allocations are therefore necessary to ensure that there is no shortfall in the housing land supply and, particularly, as highlighted above, there remains at least a 5 year supply of effective sites at the end of the Plan period.

Aberdeenshire Council must also ensure that those sites identified in the Plan for development are deliverable and assist, where possible, in their delivery. It is accepted, as indicated in paragraph 5.11, that “….predicting the land supply situation 10 years into the future is a very difficult task”. However, this is a requirement of Scottish Planning Policy and it is for that very reason that a precautionary approach should be taken and additional sites identified to ensure that there is an adequate supply. It is not accepted that there are mechanisms within the Plan to address a deficit in the effective supply. In any event, such an approach is reactionary and is not necessarily a satisfactory approach to planned settlement expansion or, indeed, for providing a long term context for major investment decisions. In light of the above, objection is taken to the preferred approach and it is not accepted that there is “….no reasonable alternative”. Every effort should be made to predict the under-supply of effective land at 2023 and identify additional sites to ensure that there is at least a 5 year supply of effective land at the end of the Plan period.

As part of the development of the Proposed Local Development Plan a "Main Issues Report" was published in October 2013. This contained 19 questions, the responses to which we are using to inform the content of the new plan. Importantly the 2013 Main Issues Report was based on a draft Scottish Planning Policy document, which was published by Scottish Ministers in April 2013.

Planning Policy in June 2014 raised a very small number of new issues on which we would welcome your views. Because of this we have chosen to publish an addendum to the Main Issues Report to highlight possible local interpretations of Scottish Planning Policy.

We are not reopening consultation on the range of other issues that were considered as part of the 2013 Main Issues Report, and ask that you only consider the limited number of additional issues set out in the Main Issues Report Addendum in any response you make.

MAIN ISSUES REPORT ADDENDUM RESPONSE FORM

Please note that further comments on any

of the other issues that were included in the

2013 Main Issues Report will not be

considered at this stage.

All comments received will be carefully

assessed and will be used to inform the

preparation of the Proposed

Aberdeenshire Local Development Plan.

There will be a further opportunity to

contained in this plan when it is published,

in January 2015.

Please email to [email protected] or send this form to reach us by 19th September 2014.


ABERDEENSHIRE




Aberdeenshire Local Development Plan Main

Issues Report Addendum 2014. If you are making

comments about more than one topic it would

for each comment.


19th September 2014 at the following address:




Woodhill House

Westburn Road

ABERDEEN

AB16 5GB


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1

PAPER APART

Aberdeenshire Local Development Plan 2016: Main Issues Report Addendum 2014

Representations on behalf of Stewart Milne Homes relative to Land Supply &

Distribution

Introduction

Stewart Milne Homes do not agree with the assessment of land supply in light of the updated

information. In responding to the Main Issues Report, Stewart Milne Homes contended that

the Local Development Plan review should be allocating more sites for residential

development to ensure that there is sufficient land to provide for at least a 5 year effective

supply of housing land at the end of the Plan period in 2021. The addendum makes no

additional allocations, but simply draws on more recent household projections and the 2014

Housing Land Audit to justify making no further land allocations.

The MIR noted that completion rates for new housing were anticipated to double by 2016 and,

if as expected, that trend continues Stewart Milne Homes argued that it would be prudent to

make adequate provision in an effort to provide an adequate supply of housing land and avoid

planning by appeal. Although the MIR noted that “predicting the land supply situation 10

years into the future is a very difficult task”, Stewart Milne Homes highlighted that this

was a requirement of Scottish Planning Policy and for that very reason a precautionary

approach should be taken and additional sites identified to ensure that there is an adequate

supply. It remains Stewart Milne Homes’ position that every effort should be made to predict

the under-supply of effective land at 2021 and identify additional sites to ensure that there is

at least a 5 year supply of effective land at the end of the Plan period.

Setting aside the revised household projections a robust analysis should be undertaken, in

light of the changes introduced by Scottish Planning Policy relative to the effective land

supply, to ensure that there are sufficient allocations that are effective or expected to become

effective in the Plan period to maintain at least a 5 year land supply at all times. This is

reinforced by Scottish Planning Policy’s requirement to identify a “generous” supply of land for

each housing market area and the fact that it advises that the housing supply target should be

increased by a margin of 10% to 20% (Paragraph 116).

Revised Household Projections

The revised household projections, which are lower than the 2010 based projections

published in June 2012, are cited in the addendum as justification for not increasing the

housing allocations. However, an analysis of the 2012 based projections published in July

2014 indicate that, notwithstanding the fact that a lower number of new households are

projected than in the 2010 based projections, the principle projection still demonstrates a

higher requirement for the period 2017 to 2026 than is set out in Figure 10 of the Strategic

Development Plan. Overall in the City and Shire the shortfall is approximately 2,000 units.

2

Whilst not a significant number when split between the housing market areas in the City and

Shire it nevertheless demonstrates that if a “generous” land supply is to be provided

additional allocations should be made.

Indeed, to ensure at the very least an adequate supply of land, the high migration variant of

the household projections should be used. This would suggest a shortfall in the City and

Shire over the period 2017 to 2026 of around 6,700 units.

On the basis of the above it is contended that notwithstanding the lower household

projections, there is justification for increasing the housing allocations to ensure a generous

supply of land capable of maintaining a 5 year effective supply at all times and in particular at

the end of the Plan period.

Housing Land Supply

The Addendum majors on the fact that the 2014 Land Audit identified a 6.2 years supply of

effective land in the Aberdeen Housing Market Area. This, however, falls short of the 20%

flexibility suggested by SPP. It further highlights the post-5 year supply of 20,283 units in the

Aberdeen Housing Market Area as justification for maintaining the status quo in terms of

housing land allocations. Overall in the City and Shire the post-5 year effective supply is

highlighted as 24,400 dwellings.

To put this in context the Strategic Development Plan, approved by Scottish Ministers earlier

this year, sets a target of 2,500 homes per annum by 2016 increasing to 3,000 per annum by

2020. This would suggest, at a conservative estimate, a requirement for an effective land

supply of 28,000 houses, some 4,000 houses more than the current post-5 year supply.

In failing to increase the housing land allocations, Aberdeenshire Council are relying on

Aberdeen City to maintain a 5 year supply of effective housing sites at all times, particularly

towards the end of the Plan period. A detailed analysis by the Grampian Housebuilders

Committee of Homes for Scotland clearly demonstrates that there will be a shortfall in the

Aberdeenshire part of the Aberdeen Housing Market Area towards the end of the Plan period.

This shortfall is also evident from a broad overview. The Addendum highlights a post-5 year’s

effective supply in the Aberdeen Housing Market Area of 20,283 units, of this 12,482 lie within

the City with the remaining 7,801 units within the Shire part of the Aberdeen Housing Market

Area. This equates to 62% and 38% respectively. By comparison the housing allowances

set out in Schedule 1 of the Strategic Development Plan allocate 54% to the City and 46% to

the Shire. There is, therefore, a significant imbalance which requires to be addressed. To

achieve the same proportions the post-5 year effective supply in the Shire part of the

Aberdeen Housing Market Area should be 10,632 units, an increase of over 2,800 units.

The problem is further highlighted when the makeup of the post-5 year supply is considered.

It currently comprises 16 sites in the City compared to 32 in the Shire. The Shire part of the

Aberdeen Housing Market area covers a much greater geographic area and as such, the

3

higher number of sites is not surprising. That said, nearly 70% of the post-5 year effective

supply lying within the Shire comprises only 4 sites with Elsick new settlement accounting for

over 44% of the supply. This suggests an over-reliance on a small number of sites which ,

should any difficulties arise in terms of servicing, could create serious problems in terms of

maintaining a 5 year supply of effective housing land at all times.

In his conclusions following the Examination in Public into the Aberdeen City and Shire

Strategic Development Plan, the Reporter advised that he was in no doubt that “…..a mix of

site sizes would be best placed to achieve the growth rates required in the proposed

plan.” He further emphasised the responsibility placed on the two Councils to ensure that

their local development plans allocate “appropriate and sufficient” effective land.

It is accepted that additional sites will become effective as the Plan rolls forward. However, a

robust assessment is required of all the allocated sites to determine their contribution to the

effective land supply over the Plan period. Presently neither the Housing Land Audit nor the

Action Programme Update published in May 2014 provide that level of information nor the

confidence that an effective 5 year supply at all times can be maintained throughout the Plan

period.

Summary

It is evident from the above overview that a generous supply of land, sufficient to maintain at

least a 5 year supply of effective housing land at all times throughout the Plan period cannot

be achieved on the basis of the currently allocated sites. The Main Issues Report and

subsequent Addendum indicates a degree of complacency on the part of Aberdeenshire

Council in terms of failing to allocate additional land.

The most recent 2012 based household projections, albeit lower than the 2010 based

projections, continue to demonstrate a higher requirement than identified in the approved

Strategic Development Plan.

Significant reliance is placed on the fact that a post-5 year effective housing land supply of

20,283 units has been identified in the Aberdeen Housing Market Area. However, to put this

in context, if the proportions of effective land are to be the same between the City and Shire

as the housing allowances in the Strategic Development Plan, there is currently a shortfall of

over 2,800 units in the Shire part of the Aberdeen Housing Market Area.

This shortfall is compounded by the fact that there is an over-reliance on a small number of

large sites within the Shire to satisfy the housing land supply. To remedy this additional sites

require to be identified for development in the Aberdeen Housing Market Area.

In order to assist with this it is suggested that a robust analysis should be undertaken with the

housebuilders to consider the contribution the existing allocated sites will make to the

effective housing land supply over the Plan period. Once agreed, the shortfall should be

addressed by the allocation of additional sites.

PAPER APART

Introduction

Objection is made by to the failure of the Proposed

Aberdeenshire Local Development Plan (ALDP) in identifying site Ga019 to the west of

Blackhall Road, Inverurie for the development of 110 residential units and community

facilities.

This objection should be read in conjunction with the Development Bid (Appendix 1) and the

responses to Questions 14 and 17 the Main Issues Report (MIR) promoting site reference

Ga019 for residential land use (Appendix 2). Allocation as such is considered a viable and

logical extension to the opportunity site OP10 lying adjacent to the east which will provide long

term opportunity for growth of the settlement, in accordance with its planning objectives as

detailed within the extant ALDP.

Modification that you wish to see:

It is contended that site Ga019, as promoted through the Development Bid of April 2013 and

Representations to the Main Issues Report (MIR) submitted in January 2014, should be

identified within the Aberdeenshire Local Development Plan 2016 for residential development

and community facilities. The boundary of the site should be reduced, as intimated in the MIR

representations, to accommodate 110 dwellings and the allocation at P15 for the relocation of

St Andrews Special School, if required. As such, the proposals map for Inverurie & Port

Elphinstone, as well as Table 5 of Appendix A5: New Housing Land Allocations, should be

amended to reflect this.

Reason for change:

Background

Land to the west of Blackhall Road, extending to 34.1ha, has been promoted through the

extant 2012 ALDP and its Review. The Reporter into the examination of 2012 ALDP failed to

allocate the site for development due to concerns regarding the impact of traffic on the

Blackhall roundabout which has now been upgraded. In a response to the Council’s call for

sites, a Development Bid was submitted in April 2013 requesting the identification of the site

for residential development and community uses.

The Main Issues Report (MIR) of October 2013 failed to identify the site as an officer’s

preference due to perceived additional congestion on the A96 and Inverurie town centre.

However, officers recognised that the site is ‘fairly well contained by the landscape and is free

from absolute constraints’, therefore making it effective and developable. Issue was raised

over the site’s proximity to the potential western bypass which may be implemented by

Transport Scotland, though there has been no confirmation or commitment to such a

development. In any case, land at site Ga019 identified for development would lie adjacent

to the existing settlement boundary and therefore not in conflict with the potential route of the

bypass. Officers acknowledged the submitted indicative masterplan and how it identifies land

allocated P15 within the Proposed ALDP for community facilities to enable the relocation of St

Andrews Special School. This approach would be retained within any future development on

site.

Representation was made in January 2014 to Questions 14 and 17 of the MIR and the failure

of this in identifying the site for the proposed residential and community use. In response to

issues raised relative to site Ga019 within the MIR, a refined option of limiting the extent of

the site to accommodate 110 dwellings and community uses was promoted. This would

ensure that spare capacity at Strathburn Primary School would not be exceeded post 2016

and that improvements at Blackhall roundabout would provide capacity to accommodate the

proposals.

The Council’s Policy Team recommendations were accepted by Garioch Area Committee in

May 2014 and as a result, the Proposed ALDP failed to include Ga019 as an option for

development. Objection is now made to this. The allocation of a reduced area of the Ga019

site to comprise Phase 1 of development, as illustrated by the indicative masterplan included

within the Appendix 1, would enable the integration with and logical expansion of the OP10

site at Blackhall Road, Westgate South as well as aiding the delivery of the new primary

school, if required. In doing so it would continue the established principle of mixed use

development and allow the preparation of a proactive and cohesive infrastructure strategy to

accommodate and mitigate impacts of future development in the area. Consequently this

would ensure that opportunities for the long term growth of the settlement are identified, as

set out by the extant ALDP.

Delivery on Allocated Sites

The extant ALDP allocated 920 housing units to be delivered in Phase 1 of the plan, up to

2016. As noted by Table 5 of Appendix A5, 785 of the 920 units allocated within Phase 1 are

still to be built out by the end of 2016. This is indicative of a universal failure in the construction

and delivery on housing land supply sites arising from constraints and delays. This will

inevitably result in large amounts of homes left to be built in the period 2017-2026 to redress

this failure in delivery, in addition to the 572 units allocated for the period 2017-2026 and

included within Table 5 of Appendix A5 of the Proposed ALDP.

As noted by the MIR, land at site Ga019 is ‘free from absolute constraints’ and therefore would

be immediately effective and developable. Therefore allocation of a reduced parcel of land at

Ga019 would be considered prudent in order to achieve the planning objectives laid out in the

extant ALDP and continue to ensure that the town plays a ‘key role in delivering both housing

and employment development to meet requirements’ and support its ‘role as sub-regional

service and retail centre’.

Furthermore, allocation at Ga019 would go some way to mitigating the loss of 413 units

identified by the MIR as ‘F’ sites. These were excluded from the Proposed ALDP due to the

proposed development of an eastern relief road which would restrict options for the

settlement’s expansion.

Strategic Growth & Infrastructure

As designated by the Aberdeen City & Shire Strategic Development Plan (SDP), approved in

March 2014, Inverurie falls within the Strategic Growth Area (SGA) between Aberdeen and

Huntly. These areas are key to enabling the delivery of around 75% of all development in the

North East in the period to 2035, with 6,200 homes and 70 hectares of employment land

allocated for delivery in the Aberdeen to Huntly corridor. Paragraph 3.32 of the SDP

recognises the substantial road improvements scheduled for the A96 over the 20 year period

as well as the improvement of trunk road junctions at Inverurie, such as the Blackhall

roundabout, lying in close proximity east of site Ga019.

The identification of a reduced area of Ga019, as promoted by representation to the MIR, to

enable phased delivery of 110 units, inclusive of the proposed allocation at P15 for the

potential relocation of St Andrews Special School, would ensure that development is

accommodated by the capacity of improvements to Blackhall roundabout anticipated in the

short term. Developer Obligations and Strategic Transport Fund contributions from the

development of Ga019 will further enable the mitigation of traffic and roads impact arising and

will allow for the phased build out of the entire area in due course.

Accessibility & Services

The site at Ga019 is well connected to local services as well as to the east side of the A96.

The Highclere Business Park is located 55m east of the site which offers convenience goods

and retail facilities. An underpass is routed beneath the trunk road and provides pedestrian

and cycle links to the Garioch Sports Centre and Strathburn Primary School, located 1.3km

and 1.6km from Ga019 respectively. Strathburn Primary School is forecast to possess

capacity beyond 2016 and as such is in a position to accommodate pupils from a new

development at Ga019, unlike other primary schools in Inverurie.

The closest supermarket is located within an 800m radius and as such, the site falls within the

distance thresholds stipulated by PAN 75: Planning for Transport. The A96 provides optimal

links to local business and employment centres at Thainstone, Kintore and beyond to

Aberdeen, approximately 25km to the south east. Therefore the site is considered as

possessing excellent connectivity and is well placed to avail of the improved accessibility to

Inverurie through vehicular and pedestrian integration with the adjacent site at OP10.

Masterplan

The proposed masterplan for site Ga019, as included in Appendix 1, demonstrates its phased

development as a logical extension of site OP10, adjacent to the east incorporating Westgate

residential development and Highclere Business Park. The masterplan illustrates new

pedestrian and vehicular access points at Blackhall Road and the adjacent Malcolm Allan

residential development, improving the permeability of the area and ensuring that links with a

mix of services as well as Inverurie town centre are forged and consolidated. This will

contribute to the creation of an integrated sustainable mixed community which is accessible

and well connected.

Substantial areas of strategic landscaping are proposed at Ga019 which will enhance the

character and visual appearance of the site, with development restricted to below the 130m

contour. This will ensure that the site remains ‘well contained by the landscape’, as recognised

by the MIR. Furthermore, development would be focused upon the eastern segment of the

site in order to aesthetically integrate with the neighbouring allocation. The allocation at P15

is incorporated into the site masterplan and will contribute to a mix of uses in the area.

Conclusion & Recommendation

The proposed vision statement for Inverurie and Port Elphinstone recognises that ‘accessible

housing is a priority for the town’. The allocation of lands at Blackhall Road as an extension

to site OP10 will ensure that this objective is achieved due to the location of Ga019 and its

excellent connectivity, as discussed above. The inclusion of a reduced segment of the site as

an option for the phased development of 110 homes and community facilities in the 2016

ALDP is considered appropriate in the context of the road network and education capacity.

Furthermore, the allocation of the site would ‘provide opportunity for the long term growth of

the settlement’, stipulated as an objective of the extant ALDP and allow an opportunity for an

infrastructure improvement strategy to be established prior to future development in the area.

Based on the foregoing is it respectfully requested that the settlement boundary be extended

to include a reduced segment of Ga019 for inclusion in the 2016 ALDP with an allocation for

110 residential units and community facilities. Accordingly, Table 5 of Appendix A5 and the

proposal map for Inverurie and Port Elphinstone should be modified to reflect this.

DEVELOPMENT BID FOR LAND TO THE WEST OF BLACKHALL ROAD INVERURIE

APRIL 2013

Ryden LLP

25 Albyn Place

Aberdeen

AB10 1YL

Tel: 01224 588866

Fax: 01224 589669

BLACKHALL ROAD, INVERURIE

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Contents

1.0 Introduction

2.0 Planning History

3.0 Description of Site and Proposals

4.0 Indicative Masterplan

5.0 National Planning Policy Context

6.0 Strategic Planning Policy Context

7.0 Imagine Inverurie & Kintore Capacity Study

8.0 Services

9.0 Justification

10.0 Conclusion


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1.0 INTRODUCTION 1.1 This development bid is submitted on behalf of

who own the land to the west of Blackhall Road, Inverurie

highlighted on the location plan shown below in Figure 1 below.

Figure 1: Location Plan

1.2 This site lies immediately adjacent to the north-western settlement

boundary of Inverurie, adjoining residential development sites EH3 and

EH4 which form part of Malcolm Allan’s Westgate development. It is a

logical area for expansion and should be identified for residential

development in the review of the Aberdeenshire Local Development Plan

(ALDP), as discussed in section 9.0 below.

1.3 Inverurie is the largest and main service centre for the Garioch area;

located approximately 17 miles north-west of Aberdeen, Inverurie has a

growing population of approximately 11,590 inhabitants1. Inverurie is

serviced by a secondary and 4 primary schools, swimming pool, sports

1 http://www.aberdeenshire.gov.uk/statistics/population/


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centre, medical centre, police headquarters and Aberdeenshire Command

Area HQ, hospital, two major supermarkets and many other community

facilities. The town has a vibrant centre, with a range of specialist,

comparison and convenience stores, restaurants, services and retail park.

Inverurie is relatively self-sustaining, a large proportion, 46.6% of

Inverurie’s population works within the settlement itself, with only 32.9% of

the population working within Aberdeen city.

1.4 Inverurie lies on the Aberdeen – Inverness railway line, which connects to

services throughout the UK and the station is a major hub within the area.

The settlement similarly lies along the A96 Aberdeen – Inverness trunk

road. The A96 Kintore-Inverurie corridor is an important employment

corridor, with 2 main industrial parks. The Kintore-Inverurie employment

corridor accommodates a range of international, national and local

businesses from a diverse range of business sectors.

1.5 In terms of the current ALDP (2012), the key planning objectives for

Inverurie are listed as:

• Meet the need for housing in the settlement and the strategic growth

area.

• Meet the need for employment land in the strategic growth area.

• Support the role of Inverurie and Port Elphinstone as a sub-regional

service and retail centre.

• Provide opportunity for the long term growth of the settlement.

1.6 The land which is the subject of this development bid includes site R3 and

lies adjacent to sites reference EH3 and EH4. Site reference R3 is

identified for the relocation of St Andrews Primary School and sites


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reference EH3 and EH4 have been carried forward from the Aberdeenshire

Local Plan (2006) for the development of housing. Development of site

EH4 is ongoing and due to complete in 2014; site EH3 is allocated to

provide 250 dwellinghouses, commencing 2013 and schedule for

completion in 2018 - both sites are continuations of Malcolm Allan’s

Westgate development. The development of these sites will bring

upgraded road infrastructure and public transport routes through this part of

the site. As such, this area to the west of Blackhall Road is an established

residential development area which benefits from public transport and local

retail services and is well-placed to contribute to providing housing within

the settlement and the SGA. Accordingly this development bid site should

be allocated to provide a further phase of residential development in the

period commencing 2017 as an extension to site reference EH3.

2.0 PLANNING HISTORY

Local Development Plan

2.1 This development bid site was identified as site reference G36 in the Main

Issues Report (MIR) which identified the site as a possible alternative to the

preferred options. Concurrently, Aberdeenshire Council submitted a

development bid for the relocation of St Andrew’s Primary School to the

eastern part of the site, given the reference G166.

2.2 Representations were submitted to the MIR in July 2009 which objected to

its failure to allocate the site for residential development.


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2.3 The proposed ALDP failed to allocate site G36 for residential development,

but included the G166 proposal for the school. Further representations

were submitted in response to the proposed ALDP in October 2010. Again

the representations objected to the proposed ALDP’s failure to identify the

site for development.

2.4 Aberdeenshire Council issued Schedule 4 submissions to Scottish

Ministers to summarise their views on representations received to the

proposed ALDP. In discussing development at G36 Aberdeenshire Council

stated their preference not to allocate further development to the north of

Port Elphinstone, and their concern of the impact of further traffic on the

Blackhall Roundabout.

2.5 The report of examination into unresolved objection to the ALDP was

published in March 2012; issue 35 of the report discusses development in

Inverurie and sets out that the Reporter failed to allocate the site for

development due to concerns regarding the impact of traffic on the

Blackhall roundabout.

Adjacent Planning Approval

2.6 Development to the west of the Blackhall Road roundabout has been

ongoing for over 13 years, with the established residential development at

Westgate and the employment land at Highclere Business Park now

established within Inverurie.


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2.7 Development of site EH3 and BUS 3 was approved by the Garioch Area

Committee in October 20122, subject to a S75 agreement which is

currently being finalised. In addition to 221 dwellings, including houses,

flats and affordable houses, the development will deliver infrastructure

improvements, including upgrades to the A96 Blackhall Road roundabout

to create a fifth spur from the roundabout to a distributor road through the

EH3 site; a new roundabout at Blackhall Road (Elphinstone roundabout)

and provision of bus shelters along the distributor road.

2.8 At the invite of Aberdeenshire Council a ‘development bid’ was submitted in

November 2008. This bid sought the inclusion of land at Blackhall Road,

Inverurie for residential development. The development bid highlighted

that there were no constraints to the development of the site and that

development should be seen as an extension to the allocation to the east

of the site now known as EH3.

3.0 DESCRIPTION OF SITE AND PROPOSALS

3.1 The site which is the subject of this development bid is currently in

agricultural use and extends to approximately 34.1hectares (84.3 acres).

The site is traversed by Blackhall Road, which continues from the B9170

Blackhall Road to the east of the A96, and runs east – west through the

site, with Mains of Blackhall and scattered residential dwellinghouses along

its route. The land to the north of Blackhall Road (5ha, 12.3 acres) wraps

around the north of Mains of Blackhall Farmstead, adjoining ALDP (2012)

2 http://aberdeenshire.gov.uk/committees/files meta/802572870061668E80257A8B00390A36/(6B)%20Blackhall%20Farm,%20Inverurie.pdf


Page 8 of 25

site reference EH4 to the north-east and the EH3 site to the south-east; the

site rises to the north, where the boundary is marked by dry stone dykes,

with further agricultural land beyond. The north-eastern corner of this part

of the site is traversed by a high voltage electricity line. The lower portion of

the site (29.1ha, 72 acres) lies to the south of Blackhall Road, which also

defines the western site boundary, with agricultural land beyond; the

southern and eastern site boundaries are defined by dry stone dykes, with

the surrounding land uses agricultural.

3.2 The bid site lies within a valley; the majority of the site lies on the northern

slopes of the Hill of Ardtannes and Davah, and rises gently to the south,

sloping gradually to the northwest and north-east at either side. The south-

eastern corner of the site lies at the highest point, along the 140m contour

line; the northern and western boundaries lie at approximately 100m above

sea level, with the eastern boundary graduating to 105m at Blackhall Road.

A gradual ridgeline can be identified running NW – SE within the site. To

the north of the bid site, and Mains of Blackhall Farmyard, the topography

is south-east facing, on the southern slopes of Dilly Hill. The apex of the

site is at approximately 125m above sea level, graduating to 100m at the

southern site boundary.

3.3 Within the vicinity of the site there are excellent pedestrian links with

Inverurie and the surrounding residential and employment development to

the west of the bypass. As part of the approved development of the

adjacent site EH3 a number of pedestrian links are proposed providing

linkages with the surrounding area. The site lies within walking distance of

public transport facilities.


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4.0 INDICATIVE MASTERPLAN

4.1 This development bid encompasses an indicative masterplan to illustrate

the capacity of the site to sustainably accommodate development and

areas where development would be acceptable. The masterplan was

initially prepared to accompany the development bid submitted in 2008;

subsequently the ALDP has allocated land within the site as R3 for the

relocation of St Andrews Primary School. Whilst the R3 allocation is larger

than the community space originally identified for this part of the

masterplan, the layout is sufficiently flexible to accommodate the R3

allocation.

4.2 The indicative layout of the site consists of residential development, split

into 4 distinct zones, with areas zoned for community space, open space

and landscaping/ amenity. Principal vehicular access is taken from

Blackhall Road which traverses the site, providing access to the areas to

the north and south, there is potential for the provision of a roundabout at

this location, should a requirement be identified; this links the site to the

north to a distributor road running through the southern portion of the site,

which rejoins Blackhall Road at the western boundary, and links into the

Malcolm Allan development of the EH3 site to the east; the plans and

layout for which have been approved by the Garioch Area Committee, with

approval pending the conclusion of a S75 agreement.


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4.5 Zone 1 encompasses the northern part of the site, to the north and west of

Mains of Blackhall farmyard. The farmyard contains a farmhouse,

redundant steading and associated agricultural buildings, and cottage, and

would be suitable to accommodate sensitive redevelopment, potentially for

a mix of uses. As previously stated, high level landscaping is proposed to

the north-west and north-eastern areas of the site, in order to affirm the

containment of development within the south-facing valley.

4.6 Within the larger site, an area for ‘community space’ is located to the north-

east, adjacent to the public road and junction between the sites, with

pedestrian and cycle links to the Malcolm Allan EH3 development, and to

the Malcolm Allan Westgate phase 1-4 development at site EH4 to the

north-east. This location has been allocated as site R3 in the ALDP (2012)

and is identified as having excellent accessibility to the existing residential

areas to the west of the bypass, with strong pedestrian and cycle linkages,

and lies directly west of the proposed commercial site within the Malcolm

Allan development at site EH3. Community facilities of a size to

complement the town centre and serve the immediate requirements of the

residents within the area would ensure a sustainable balance of uses.

Facilities would be developed in line with the requirements of the

community.

4.7 The residential land within the larger part of the site is identified as zones 2,

3, and 4. This area slopes gently downwards to the north-west, to address

the northern part of the site. Open space for amenity and recreation, with

associated strategic landscaping between the three areas promotes

interaction between the zones.


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5.0 NATIONAL PLANNING POLICY CONTEXT

Scottish Planning Policy

5.1 Scottish Planning Policy (2010) (SPP) directs that “planning is about where

development should happen, where it should not and how it interacts with

its surroundings” (para. 3). Regarding Development Plans, SPP requires

monitoring to set the direction for reviews of the plan; authorities are to

“focus on what has changed (in particular) the extent to which key

assumptions remain valid, (and) whether land allocations have proved

viable” (para. 20).

5.2 The Scottish Government are committed to sustainable development,

paragraph 37 of SPP explains the important role the planning system has

to play in supporting the achievement of sustainable development through

its influence on the location, layout and design of new development. In

deciding the locations of new development SPP directs local authorities to:

• Promote regeneration and the re-use of previously developed land,

•• Reduce the need to travel and prioritise sustainable travel and

transport opportunities,

• Promote the development of mixed communities,

• Take account of the capacity of existing infrastructure,

• Promote rural development and regeneration, and

• Prevent further development which would be at risk from flooding or

coastal erosion.


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5.3 Town Centres are identified as “a key element of the economic and social

fabric of Scotland, acting as centres of employment and services for local

communities and a focus for civic activity, and (making) an important

contribution to sustainable economic growth” (para.52); and SPP seeks

that new development “integrates successfully and create effective links

with the surrounding urban fabric” (para. 57). A focus is placed on ensuring

that “town and commercial centres should be accessible at all times to all

sectors of the community; retail, leisure and related developments should

be accessible by walking, cycling and public transport” (para. 61). In

addition to town centres, development plans are required to identify a

network of centres, which will include “town centres, commercial centres

and other local centres, and may take the form of a hierarchy. Within the

network the individual role of each centre should support and be supported

by the role of other centres”. SPP recognises that “networks will change

over time” (para. 53).

5.4 In relation to Housing, SPP reiterates The Scottish Government’s

commitment to increasing the supply of new homes, requiring “the planning

system (to) contribute to raising the rate of new housebuilding by identifying

a generous supply of land for the provision of a range of housing in the

right places”. Development plans “should enable the development of well

designed, energy efficient, good quality housing in sustainable locations”

(para. 66). In supporting Sustainable Mixed Communities, the “delivery

of housing through the development plan depends (not only) on a generous

supply” of development land, but that on a range of “appropriate and

effective sites being made available to meet need and demand, and on the

timely release of (these) allocated sites.


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5.5 As regards the Location and Design of New Development, the efficient

use of existing land and infrastructure, accessibility of homes, services,

open space and employment opportunities by a range of transport options,

co-ordination of housing land release with investment in infrastructure

including transport and educational investment, the deliverability of the

strategy, and the protection and enhancement of landscape, natural, built

and cultural heritage, biodiversity and the wider environment; are all key

considerations in a settlement strategy para. 77).

5.6 SPP dictates that “The Scottish Government’s objectives of creating

successful places and achieving quality residential environments should

guide the whole process of delivering new housing”. In doing so, the “aim

should be to create places with a distinct character and identity, promoting

a well integrated mix of land uses including well designed homes of

different types and tenures. Development plans should encourage and

enable the creation of successful places which contribute to the identity of

the area” (para. 78).

5.7 In doing so, “new housing developments should be integrated with public

transport and active travel networks, such as footpaths and cycle routes,

rather than encouraging dependence on the car. New streets should

connect well with existing streets and with walking and cycling networks,

and allow for links into future areas of development” (para. 79). It is

envisaged that “the majority of housing land requirements will be met within

or adjacent to existing settlements and this approach will help to minimise

servicing costs and sustain local schools, shops and services “(para. 84).

5.8 SPP acknowledges that the Landscape “in both the countryside and urban

areas is constantly changing and the aim is to facilitate positive change


Page 16 of 25

Planning Advice Note 44: Fitting New Housing Development into the

Landscape

5.12 The focus of PAN 44 is ‘to create more widespread good quality rural

housing which respects the Scottish landscape’ (page 6); Scotland enjoys a

long and distinctive tradition of urban design, with urban form closely fitted

to the landscape and insensitive development can undermine the special

environmental quality of towns and their setting in the countryside which

have drawn people to live and invest in them in the first place (para. 9).

5.13 In general, the PAN provides guidance on landscape fit and rural design,

with key messages for developers and authorities ‘to set the scale of

change that is acceptable; establish a clear policy framework which

promotes opportunities to create sustainable and affordable new homes,

and apply it consistently; ensure that developments enhance local

character; and make a positive contribution’ (page 22).

Planning Advice Note 67: Housing Quality

5.14 PAN 67 cites the role of the planning process as one that ensures that the

design of new housing reflects a full understanding of its context – in terms

of both its physical location and market conditions; that the design of new

housing reinforces local and Scottish identity; and new housing is

integrated into the movement and settlement patterns of the wider area

(page 6). PAN 67 defines successful places and quality housing

developments as those which are ‘distinctive; safe and pleasant; easy to

get to and move around; welcoming; adaptable; and, resource efficient’

(page 8).


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Planning Advice Note 75: Planning for Transport

5.15 In terms of accessibility to local facilities by walking and cycling, appendix B

of PAN 75 identifies a “maximum threshold of 1600m for walking is broadly

in line with observed travel behaviour” (para. B13).

6.0 STRATEGIC PLANNING POLICY CONTEXT

Aberdeen City & Shire Structure Plan

6.1 The extant structure plan aims to grow and diversify the economy of the

city region whilst protecting the natural assets that contribute to the

environmental quality that the area is renowned for. The spatial strategy

identifies three ‘Strategic Growth Areas’ (SGA), as the ‘main focus for

development in the area up to 2030’ (para 3.6) to ‘account for around 75%

to 80% of the growth over the next 20 years or more’. The SGAs are

‘centred on Aberdeen and the main public transport routes’, 5km-wide

corridors along the A90 and A96 road and rail routes (para. 3.7); Inverurie

is a key settlement within the Huntly – Laurencekirk SGA: “significant

development will take place in (this) road and rail corridor, much of which is

served by a dual carriageway and the railway lines from Edinburgh and

Glasgow to Aberdeen and Aberdeen to Inverness” and “this will be

supported by development in this corridor. Bus services on this corridor are

already good, although we will need to make further improvements to make

these services an even more attractive choice” (para. 3.9).

6.2 The structure plan identifies a requirement for around 72,000 dwellings

throughout the area over a 20 – 25 year period, allocations for the Inverurie

– Blackburn part of the SGA are as follows:


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2007-2016 2017-2023 2024-2030

No. Dwellinghouses 1,000 1,500 4,000 Table 1: Structure Plan Housing Requirement for Inverurie-Blackburn SGA

6.3 The plan aims to focus “new housing in, or as an extension to, existing

settlements, particularly those which are well served by public transport; (in

order to) help to create and maintain successful places and be more

sustainable” (para. 3.14).

Aberdeen City & Shire Strategic Development Plan

6.4 As set out above, the proposed SDP is an evolution of the 2009 structure

plan, retaining and refining the strategy and guiding principles of that

document. The Proposed SDP again identifies three SGA’s and additional

growth is proposed outwith these areas in the local growth and

diversification areas. Within the Inverurie to Blackburn section of the

Huntly to Laurencekirk SGA the Proposed SDP states that 5,500 new

homes should be developed during the period 2017 – 2035.

Existing-2016 2017-2026 2027-2035

No. Dwellinghouses 1,000 1,500 4,000 Table 1: Proposed SDP Housing Requirement for Inverurie-Blackburn SGA

6.5 As the proposed SDP has elongated the delivery phases, rather than

identified any increase in allocations, the SDP has effectively reduced the

rate of delivery of housing and employment development in the region; in

terms of residential and employment land it is the subject of objection from

the development industry. Should Scottish Ministers be minded to increase

allocations in the SDP, the ALDP, with many sites being ‘drawn down’ early

to augment the 2012 – 2016 supply and a number of sites are no longer


Page 19 of 25

effective or are being developed at a slower rate than expected, will fall

short of meeting housing and employment land requirements.

6.6 The plan’s objective relating to sustainable development and climate

change highlights the need for employing energy saving technologies in all

new development, setting a target for all new buildings be carbon neutral

by 2020. Transportation use, as it impacts on climate change, is another

focus of this policy and new developments are encouraged to consider a

proposal’s impact on the environment from increased unsustainable forms

of transport.

6.7 With regard to population growth, the region’s population has risen in

recent years and the plan is based on the assumption that this will continue

to grow up to 500,000 people by 2035. However, these projections

significantly under-estimate the anticipated population growth published by

the National Records of Scotland (NRS). They project the population of the

Aberdeen City and Shire Strategic Development Plan Area to rise to

567,800 by 2035. This is reinforced by the projections for household growth

published by the NRS which is set to increase by 35% over the period from

2010 – 2035. Overall, whilst the SDP sets an annual average housing

requirement of 2,159 units for the period 2011 – 2035, according to realistic

projections, this figure is more likely to be 2,815 units a year, creating an

annual shortfall of 656 units across the plan period.

6.8 The promotion of sustainable mixed communities as a key objective of

the SDP relates to the concern that settlements in Aberdeenshire act as

commuter towns for Aberdeen city. In achieving this objective,

communities must integrate a mix of housing, jobs, services and recreation

facilities - available to as wide a range of people within existing settlements.


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6.9 The promotion of sustainable mixed communities runs in tandem with the

goal to reduce the need for unsustainable modes of transport as well as

improving the quality of life of the people of the North East of Scotland.

The accessibility objective promotes an inclusive society that can

accommodate the needs of all abilities. It looks to strengthen the links

between transport and land use to ensure that the need to travel by private

car are reduced. This objective is designed to promote a range of social,

environmental as well as economic benefits.

7.0 SERVICES

7.1 Scottish Water’s Asset Capacity Plans indicate that, in terms of waste

water, there is capacity at Inverurie Waster Water Treatment Works for up

to 699 dwellings and that there is sufficient capacity for identified

development needs. In terms of Water Treatment Works both the

Invercannie and Mannofield Water Treatment Works supply water to the

area and have capacity each for 2000+ homes with sufficient capacity for

identified development needs.


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Figure 2: Extract from Indicative River & Coastal Flood Map (Scotland) SEPA

7.2 SEPA’s Indicative River & Coastal Flood Map (Scotland), shown in figure 2,

above highlights that there is no flood risk associated with the site.

8.0 JUSTIFICATION

8.1 As set out above, the proposed SDP did not set any further housing

allocations for Aberdeen and Aberdeenshire, but extended the existing

delivery periods by 4-years, effectively slowing the rate of development in

the region. This is subject to strong objection from the development

industry and unresolved objection to the proposed SDP is to be reported to

Scottish Ministers in August 2013 for an Examination in Public. This does

not accord with SPP which reiterates The Scottish Government’s

commitment to increasing the supply of new homes by requiring the

planning system to contribute to raising the rate of new housebuilding by

identifying a generous supply of land for the provision of a range of housing

in the right places. Should Scottish Ministers find fault with the proposed

SDP the forthcoming ALDP will require to identify further housing

allocations post 2017.

8.2 Inverurie is a main settlement within AHMA and the Garioch area of

Aberdeenshire. Inverurie lies within the Huntly – Laurencekirk Strategic

Growth Area, identified within the structure plan to accommodate a

significant proportion of Aberdeenshire’s population growth over the next

25 years.


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8.3 Since 2000, Inverurie has expanded to the west of the A96, with significant

infrastructure being invested in the area to accommodate sustainable

development of the location over 13 years. Residential and employment

development at sites EH3, EH4 and BUS3 are identifies as a continuation

of the large allocations made to this area through the previous

Aberdeenshire Local Plan (2006) adjoining the residential development at

Westgate and the Highclere Business Park.

8.4 In terms of service provision, the area is not encumbered by low-pressure

in the water supply, as are experienced to the east of the settlement. The

site is not located in an area of flood risk. As part of their development, site

EH3 is required to provide significant upgrades to the A96/ Blackhall Road

roundabout; further development will maximise the benefit of investment in

this infrastructure.

8.5 Connectivity to the east of the A96 by means other than private car is

excellent, with a pedestrian underpass developed underneath the A96 to

connect the existing Westgate and Highclere residential and business

developments; the pedestrian/ cycle route to Strathburn Primary School is

approximately 1.6km. The Garioch Sports Centre is 1.3km from the site

and the closest supermarket is 760m from the site. The closest local

convenience store to the site however is located at Highclere Business

Park, 55m to the west, within the JG Ross bakery/ café/ retail development.

Commercial uses, appropriate to the location are further to be developed

adjacent to the north-east corner of the site, as part of the neighbouring

Malcolm Allan development at site EH3.


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8.6 The topography of the surrounding land would ensure that any

development would be well contained in the landscape as the site lies

within a gentle valley between Davah and Dilly hills, with rising land to the

north and south. The topography of the site itself would cause no

impediment to development as the slopes are gentle, and there would be

minimal visual impact on the surrounding area. Development would be

restricted to below the 130m contour line, with strategic landscaping and

public recreational and amenity space, and pedestrian linkages preserving

the skyline views; development would therefore remain below 2007-based

school roll forecast, Aberdeenshire Council the top of what is discernible on

the ground as a broad and gentle ridge. The varied topography of the area

and scattered tree belts that characterise the landscape of this locality

provide the basis for developing a landscape structure, compatible with the

existing.

9.0 CONCLUSION AND RECOMMENDATIONS

9.1 The expansion of Inverurie to the west of the A96 is an established part of

the settlement, with significant infrastructure having been invested in the

area to accommodate sustainable development of the location over the

past 13 years. The area now benefits from a dedicated pedestrian/ cycle

underpass under the A96, and a mix of residential, retail and commercial

uses. As a result of the Malcolm Allan development at site EH3 for a further

221 dwellings and appropriate commercial uses, public transport links

through the site will be provided and existing services re-routed to further

strengthen the integration of the site with the older part of the settlement.


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9.2 The site enjoys excellent access to local services at Highclere Business

Park, with a major supermarket sited less than 1km to the east, adjacent to

the pedestrian underpass. While proximity to the closest primary school

and sports centre are within the limits for observed travel behaviour as set

out in PAN75.

9.3 SPP advocates development in such areas of high accessibility by means

of transport other than private car, where development can utilise existing

infrastructure in order to enhance the sustainability of the location. The

development of the fh3 site will be accessed via a new spur from the A96/

Blackhall Road roundabout, along a dedicated distributor road through the

fh3 site and exiting onto Blackhall Road to the west of the bypass and as a

condition of the planning consent, new and rerouted bus services will

require to be diverted through the site to further integrate the development

with the Inverurie town centre. In terms of the hierarchy in Inverurie, local

retail services at Highclere Business Park are within 400m walking distance

of the site.

9.4 In landscape terms, the site is well-positioned to strengthen and provide a

defensible, landscaped edge to the western part of the settlement.

Restricting development below the 130m contour line will visually contain

the development, which will lie within a natural and gradual valley, and

provide development and services to complement the existing development

to the east and north-east of the site.

9.5 Given the above, it is considered that the site is well-placed to

accommodate a proportion of Inverurie’s long-term future growth in a


Page 25 of 25

sustainable and organic continuation of the development to the west of the

bypass, in accordance with the targets for housing density within the SGAs.

Paper Apart

Representations to the Main Issues Report on behalf of in

response to Question 14 –comments on the settlement objectives, protected land or

sites proposed by developers, in respect of Inverurie

Introduction

In conjunction with the development bid for site Ga019 at Blackhall Road and their answer to

question 17 of the Main Issues Report (MIR), object to that site

Ga019 is not listed as an officer’s preference to accommodate residential development in the

forthcoming ALDP. Ga019 is an ideal site to accommodate a small-scale of development, 110

units; which falls within the capacity of Strathburn Primary School, the improvements to the

A96 Blackhall Road roundabout and the surrounding landscape. Housing in this location will

be delivered as an extension to the development of EH3, which is set to complete in 2018 and

the layout, planning and landscaping of the development is able to incorporate the R4 site for

a replacement St Andrew’s School.

School Capacity

Site Ga019 falls within the catchment area of Strathburn Primary School, which is predicted

to have capacity available to accommodate pupils from new development post 2016, unlike

the other primary schools in Inverurie, which are forecast to be over capacity, with a rising roll.

Ga019 Blackhall Road

The MIR analysis of Ga019 notes that the “site is fairly well contained by the landscape and

is free from absolute constraints”.

The MIR assessment of the site is based on a proposal to accommodate 360 units at this

location; and the site was considered unsuitable for that scale of development on account of

“the additional congestion it could cause in Inverurie town centre and on the A96 and the lack

of a clear strategic resolution to this issue”, in addition, “if a western bypass is proposed by

Transport Scotland as part of the A96 upgrade this may also impact directly on the

development of this site”.

Again, the proposal assessed through the MIR was for 360 houses, and it was considered that

“this proposal also extends beyond pylons which provide a landscape boundary to residential

development to the west of the town. Development on the western slope of Hill of Ardtannes

would also appear visually divorced from Inverurie”

It is noted that whilst site Ga019 encompasses allocated sire R4, “it is noted that the

masterplan submitted by the applicant identifies this area for community facilities”.

Reporter’s Recommendations

The report of examination into objections to the proposed Aberdeenshire Local Development

Plan (2010) assessed site Ga019, then reference G36, on the basis of its capacity to

accommodate 395 dwellinghouses as an extension to site EH3, which has been carried

forward from the Aberdeenshire Local Plan (2006) with a capacity of 250 house units,

scheduled to complete in 2018. The reporter considered that although “pupils from

approximately 90 houses could be accommodated by Strathburn Primary School”,

“development on the scale proposed would require a new primary school and no site for such

a school has been identified” (issue 35, para. 58).

It was noted that “access to this site would be from the Blackhall Road roundabout and that

“the committed improvements at this roundabout might permit limited, as yet, unquantified

development at this location”. Whilst the reporter considered that “the capacity constraints at

the Port Elphinstone and Thainstone roundabouts would be exacerbated with additional

development off the Blackhall Road roundabout” and that “the scale of development proposed

would be likely to require a grade separated interchange at the Blackhall Road roundabout

and this is unlikely to be achieved because of the proximity of development to the trunk road

and the need to provide additional lanes on the A96”. Again, these assumptions were based

on a development of 395 houses and did not acknowledge Transport Scotland’s commitment

to upgrade the A96.

Aberdeenshire Local Development Plan: Phase 2 Residential Allocations

The Aberdeenshire Local Development Plan (2012)(ALDP) allocates land to accommodate

850 residential units over phase 2 of the plan; the MIR proposes the removal of the “F” sites,

which account for 413 units, on account of uncertainty surrounding the necessary transport

infrastructure. Whilst the 2013 Housing Land Audit demonstrates that sufficient residential

development is programmed for delivery over phase 2 without inclusion of these “F” sites, para

6.44 of the MIR debates the reallocation of the 413 units.

Ga019, Blackhall Road: 110 residential units

It is proposed that a smaller scale of allocation of 110 units should be made to site Ga019,

Blackhall Road, which accords with the capacity available at Strathburn Primary School. This

would be a continuation of the development of site EH3, to the south of Blackhall Road, which

is scheduled to complete in 2018 and would allow for sensitive small-scale development in

conjunction with the R4 site, allocated within Ga019 for a replacement special needs school.

This would address the reporter’s concerns, which were primarily based on the capacity of the

local transport and education infrastructure to accommodate a development in excess of 360

units at this location. This smaller scale of development, could be contained within the

landscape, on zone 1 and part of zone 2, as identified in the indicative masterplan submitted

in support of the development bid (appendix 1). The development would fall within the

available capacity of Strathburn Primary School and the improvements to Blackhall Road

roundabout; it would also go some way to provide a deliverable alternative to the currently

allocated “F” sites and provide necessary developer contributions, should replacement sites

be sought.

Zones 1 and 2 comprise the eastern part of the site and are unlikely to be affected by any

proposals regarding the provision of a western bypass as part of the A96 upgrade, addressing

comments made in the MIR assessment of Ga019. The indicative masterplan highlights an

area for community facilities, which will incorporate the replacement St Andrew’s school which

is designated R4 in the extent ALDP.

Conclusion

For the reasons above it is requested that site Ga019 allocated in the forthcoming ALDP to

accommodate the development of 110 houses, incorporating the existing R4 allocation. The

boundary of the site should be reduced in size accordingly, accommodating zones 1 and 2 of

the indicative masterplan for the development of this site.

Ryden LLP

January 2014

Appendix 1: Indicative Masterplan for the Development of Site Ga019

Paper Apart

Representations to the Main Issues Report on behalf of in

response to Question 17 – In Inverurie is uncertainty so great, and land supply so

buoyant, that we should defer decisions on where future housing land should be

released to a future development plan?

Introduction

support the Council’s preferred option in response to Main Issue

15 What are the implications of uncertainty regarding trunk road development in

Inverurie?, to delete the “F” allocations at Conglass, Balhagardy and Keithall, where the

delivery of a link road may no longer justify their allocation. Recent reports demonstrate that

the negative impact on the designed landscape and wider townscape would be contrary to

national planning policy, which permits such devastation only in exceptional circumstances,

where there are no alternatives. However it is also demonstrated that scheduled works to the

A96 may alleviate some of the congestion that the eastern link road would seek to divert,

providing viable alternatives to the development of an eastern bypass around Inverurie and

thus the development of the “F” sites.

Inverurie Eastern Bypass

The delivery of development across the “F” sites is dependent on the feasibility of an Inverurie

eastern by-pass; the Appraisal of the Potential Effects of a Proposed Inverurie Bypass

upon Keith Hall Designed Landscape and other Cultural Heritage Features (2013) report

acknowledges that there “will undoubtedly be significant adverse effects upon this resource,

particularly within the western farmland and parkland the Inventory-listed of Keith Hall

designed landscape”; and that “mitigation proposals along the entire route corridor are likely

to become increasingly more effective moving southwards, especially in the context of the

extensive allocated development sites that the Crichie junction and side roads would serve”

(para. 7.4.2).

The report suggests that whilst an eastern link road would be beneficial, given the extensive

improvements to the A96 junctions to accommodate development at Crichie, the justification

for an eastern link road to ease traffic congestion becomes questionable. This would run

contrary to Scottish Planning Policy which requires development plans to consider “the

capacity of settlements and the surrounding areas to accommodate development without

damage to their historic value” (para. 112); and is echoed in the latest Consultation Draft,

requiring development plans to “protect and promote the strategically important elements of

the historic environment. (Taking) account of the capacity of settlements and surrounding

areas to accommodate development without damage to their historic significance” (para.116).

Similarly, scheduled monuments are to be protected “in situ and in an appropriate setting,

unless there are exceptional circumstances” (para. 120). Under these circumstances and

where there are alternatives to provision of land for development, the continued identification

of the F-sites at Keithhall is contrary to national planning policy.

Transport Scotland A96 Improvements

The Scottish Government’s Infrastructure Investment Plan (2011) and National Planning

Framework 3 (2013) reiterate the commitment for dualling of the A96 to be complete by 2030,

including “measures to improve the safety, capacity and performance of the strategic inter-city

road network”. (para. 5.16). DMRB stage 2 assessment identifies route options, which will

have implications for housing land in Inverurie, for example whether the current section of road

to the north of Port Elphinstone is dualled, or whether the preferred option de-trunks this

section of the A96 in favour of a bypass. Given this uncertainty and the surplus of effective

development land in Inverurie it would be irresponsible to pre-judge the outcomes of the study

through the identification of land that was not immediately required for development and these

decisions should be deferred for determination through a further development plan.

Aberdeen City and Aberdeenshire Housing Land Audit 2013

Reallocation of the 413 units allocated for delivery on the “F” sites over phase 2 is debated at

para 6.44 of the MIR. However whilst 850 units are required at Inverurie over phase 2 of the

Aberdeenshire Local Development Plan (ALDP), the 2013 Housing Land Audit shows that

1288 units are currently scheduled for completion in the period 2017-2023, without the

inclusion of the “F” sites, demonstrating a healthy land supply for phase 2 of the ALDP.

The ALDP (2012) allocated new land for the delivery of 920 units over phase 1; and whilst

development in phase 1 of the plan exceeded, or will exceed this, only 256 of the new units

allocated for phase 1 delivery were, or will be developed in this period, a shortfall of 664 units.

The majority of development over the phase 1 period occurred, or will occur at effective sites

EH1-4, infill sites and earlier phases of development at M1 and M2 which took, or are taking

longer to build than anticipated.

As a result, 628 of these new units allocated to phase 1 are programmed for delivery in phase

2 (H1, H4, M1, M2, M3). The HLA records a shortfall of 6 units being delivered at H2 and H4;

and 30 units (M3) are programmed for completion in 2024. In addition to the phase 1

allocations, 260 units of the 437 phase 2 units allocated to H1 will be delivered within that

period; with the remaining 207 programmed for post 2024. 371 units from effective sites EH1-

3 are also scheduled for delivery over phase 2. Based on the latest HLA figures there is a

forecasted supply of 1259 residential units scheduled for delivery over phase 2 of the

ALDP, an increase of over 48% of the requirement.

Conclusion

In response to question 17 agree that decisions on where future

housing land should be released should be deferred to a future development plan. Support is

given to the Council’s preferred option, stated at para. 6.48 that “due to the uncertainties

associated with what road traffic solutions may be proposed, and the clear development

opportunities that would result that should the current A96 be de-trunked, it is proposed to

delete the “F” allocations to remove unrealistic expectations of development potential for these

sites”, including the “nationally important designed landscape of Keith Hall where the delivery

of a link road may no longer justify their allocation” (para. 6.48).

For the above reasons the deletion of the “F” allocations and deferment of decisions on the

location of future housing land until a further development plan is requested.

Ryden LLP

January 2014

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.

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Modification that you wish to see

Reason for change

Mr

Ian

Livingstone

8 May 2015

Ryden LLP, 25 Albyn Place, Aberdeen

AB10 1YL

01224 588866

[email protected],uk

✔

✔

Drumrossie Land Development Company Ltd





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YOUR COMMENTS


Reason for change

See Paper Apart regarding: Site Ga043 Whiteford

See Paper Apart regarding: Site Ga043 Whiteford

PAPER APART

Introduction

Objection is made by Drumrossie Land Development Company Ltd to the failure of the

Proposed Aberdeenshire Local Development Plan (ALDP) in identifying site Ga043 at

Whiteford for residential development.

This objection should be read in conjunction with the Development Bid (Appendix 1) and the

response to the Main Issues Report (MIR), promoting site Ga043 for residential land use

(Appendix 2). Allocation of the site would ensure the sustainable growth of Whiteford as an

appropriate addition to the existing settlement and recently approved dwellings, whilst also

contributing to the area achieving strategic housing targets as set out by the Aberdeen City &

Shire Strategic Development Plan (SDP) approved in March 2014.


Site Ga043 at Whiteford, as identified by the MIR should be included within the Aberdeenshire

Local Development Plan 2016 for residential development. Accordingly, the proposals map

for Whiteford should be amended to reflect this and Table 5 of Appendix A5: New Housing

Land Allocations modified to include the allocation of approximately 15 units on site Ga043.

Reason for change:

Background

It should not be overlooked that this site was allocated for residential development within the

Aberdeenshire Local Plan (ALP) 2006 and on this basis, the principle of residential

development has effectively been accepted by the Council. Drumrossie Land Development

Company Ltd has demonstrated their commitment to the site and two applications for a total

of 18 residential dwellings (Ref: APP/2011/1926 & APP/2011/1927) were recommended for

approval by the Case Officer in August 2012. Within the Committee Report the officer

recognised that both applications had been made when the site was allocated in the ALP, and

that through previous discussions with Infrastructure Services Development Management and

Flood Prevention Unit as well as Planning Gain, solutions to technical issues had been

identified and could be conditioned upon the grant of planning permission. This situation

remains relevant and any new development would make efficient use of existing infrastructure

on effective land which would permit a prudent extension to an existing settlement in

compliance with paragraph 40 of Scottish Planning Policy (SPP), adopted in June 2014.

In response to the Council’s call for sites, a Development Bid was submitted in April 2013

promoting land at Whiteford for inclusion in the Proposed ALDP. The MIR of October 2013

failed to identify the site as an officer’s preference and representation on behalf of Drumrossie

Land Development Company Ltd was lodged in objection to this in January 2014. Garioch

Area Committee accepted officer’s recommendations in May 2014 and the site at Ga043 was

not included within the Proposed ALDP.

However in the interim, the suitability of site Ga043 for residential development has been

further confirmed by the approval of application APP/2013/2710 for three dwellings in the

southern segment of the area in July 2014. This application superseded the previous

application for 3 dwellinghouses (APP/2011/1926). Within the Case Officer’s Committee

Report significant material weight was attached to the land being previously allocated within

the ALP and the application was approved by Members predominantly on this basis.

Objection is now made to the failure of the Proposed ALDP in identifying the balance of site

Ga043 Whiteford for the development of 15 residential units.

Justification

The principle of residential development has been accepted on site Ga043 through its former

allocation with the ALP 2006 and the approval of 3 dwellings on land within the southern

segment of the site. On this basis it is firmly contended that the site is ideally located for the

logical expansion of Whiteford. As noted within the Case Officer’s Committee Report relative

to application APP/2011/1927 the ‘principle of developing the site has been previously

accepted, however the site does not feature in the newly adopted Aberdeenshire LDP (2012).

It is considered that material weight should be given to previous discussions’. This position

remains relevant.

Whiteford lies within the Huntly - Pitcaple section of the Aberdeen to Huntly Strategic Growth

Area, as designated by the SDP. This area is expected to deliver 500 units in the period 2017-

26 and a further 200 homes between 2027 and 2035 in addition to the 300 existing allocations

to 2016. Of these existing allocations, and as noted by Table 7 of Appendix 5A: New Housing

Land Allocations, 176 units allocated to Huntly for the period to 2016 remain unbuilt. Indeed,

only 37 are expected to be completed, according to Appendix 3 of the 2014 Housing Land

Audit, within that period. This will result in an anticipated deficit of 139 homes by 2016,

therefore falling short of the expected delivery targets for the Huntly - Pitcaple section of the

SGA. Also, the figures in Table 1 of Appendix 5A relative to the area, inclusive of effective

supply, windfall sites and Proposed ALDP housing allocations, continue to show an overall

deficit of 34 units in the period to 2035. It is clear from the HLA that 630 units across three

allocated sites (OP1, OP2 and OP4) in Huntly continue to be subject to constraints, which is

likely to exacerbate delivery further.

The Council can ill afford to ignore this situation which will ultimately result in the Huntly -

Pitcaple section of the SGA failing to meet its strategic housing targets. These constrained

sites should be removed from the Plan and allocated to alternative sites, one of which should

be site Ga043 at Whiteford. Separate objection has been made to the sites in Huntly.

Furthermore, the SDP has calculated its housing targets upon outdated 2008-based figures

which estimate the population of the North East at 500,000 in 2035. This is a significant

understatement in light of the National Records of Scotland figures published in June 2014

which project the population of the area to rise to around 570,000 by 2035. Additionally, a

number of sites have been drawn down early to augment the 2012-16 supply and, as

evidenced above, many of these are being delivered at a slower rate than predicted. The

identification of additional land for residential use, such as at Whiteford, can make an effective

contribution to addressing the inevitable shortfall in housing land supply and help to achieve

housing targets in the period to 2035.

Site Ga043 is no longer constrained for development. Prior to the determination of

APP/2011/1927, discussions took place with SEPA and the Council’s Flood Prevention Unit in

order to identify a solution to flood risk on site. This was concluded by the approval of

application APP/2012/1351 for a replacement culvert and construction of a temporary access

road. This is no longer an issue, deeming the entire site as effective for development. The

planning system should demonstrate flexibility to accommodate changing circumstances and

optimise land resource by utilising effective supply, in line with SPP. The approval of

APP/2013/2710 for 3 dwellinghouses at Whiteford also ensures that access and visibility splay

requirements are already in place, benefiting the development of the entire Ga043 site.

Furthermore, infrastructure concerns over school capacity at Logie Durno primary school were

resolved and education contributions agreed between the developer and the Council’s

Planning Gain team. This ensured that the development of the site for residential use would

not adversely impact upon the capacity of the local primary school. The MIR identifying this

as a constraint is considered untenable.

The proposed site layout, as included within Appendix 1, illustrates an appropriately scaled

development which reflects the pattern and density of dwellings currently existing and

approved within Whiteford. The Committee Report confirms this by stating that ‘the site

follows a natural boundary with the watercourse along the northern side and a strategic

landscape belt is proposed to the west boundary whilst the eastern side of the development

shall integrate reasonably well with the existing dwellings in the village’, attesting to its

suitability as a logical extension to Whiteford. This observation has clearly been overlooked

in the assessment of the site by officers and Members. The site is of gentle gradient sloping

from south to north towards the minor burn which defines its north eastern boundary. The site

is well screened by tree lined hedgerows to the south. Strategic landscaping will ensure that

the development fits well within the landscape and is not to the detriment of the existing

character of the settlement. This complies with the settlement objective of protecting the

amenity of Whiteford.

Whiteford is an accessible village within the SGA and as such, benefits from a range of

services found at Inverurie and Oldmeldrum, located 5km south east and 12km east of the

settlement respectively. Whiteford lies in close proximity to the A96 corridor and the A947,

providing optimal links to the surrounding area. It is contended that allocation of site Ga043

for residential development will safeguard services and act as a catalyst for improved public

transport links which would benefit the residents of Whiteford. The SDP encourages

sustainable mixed communities through allocation of land in accessible locations and

Whiteford is well place to take advantage of its position within the SGA in close proximity to

the A96 corridor as well as towns such as Oldmeldrum and Inverurie.


Based on the foregoing it is respectfully requested that the settlement boundary of Whiteford

be extended within the proposals map to encompass site Ga043. Accordingly, Table 5 of

Appendix 5A: New Housing Land Allocations should be modified to include an allocation for

15 residential units. This will ensure that Whiteford grows appropriately, optimises effective

land resource and promotes accessibility within the SGA, as well as making a valid contribution

to strategic housing targets.

DRUMROSSIE LAND DEVELOPMENT

CO. LTD

DEVELOPMENT BID: LAND AT

WHITEFORD ROAD, WHITEFORD

APRIL 2013

Ryden LLP

25 Albyn Place

Aberdeen

AB10 1YL

Tel: 01224 588866

Fax: 01224 589669

Drumrossie Land Development Co Ltd Whiteford

Page 2 of 17

Contents

1.0 Introduction

2.0 Planning History

3.0 Description of Site and Proposals

4.0 National Planning Policies

5.0 Structure Plan

6.0 Proposed Aberdeen City and Shire Strategic

Development Plan (February 2013)

7.0 Aberdeenshire Local Development Plan 2012

8.0 Services

9.0 Justification

10.0 Conclusion and Recommendations


Page 3 of 17

1.0 INTRODUCTION

1.1 This development bid is submitted on behalf of Drumrossie Land Development Co.

Ltd who have control over land to the north of Whiteford Road, Whiteford as

highlighted on the location plan in Figure 1 below.

Figure 1: Location Plan

1.2 Whiteford is an estate village located to the north of Pitcaple. The settlement lies 5

miles to the north west of Inverurie and 10 miles to the west of Oldmeldrum. The

settlement is accessed from the A947 which leads to the A96. The settlement

benefits from its proximity to Inverurie and Oldmeldrum both of which provide a

range of services and facilities including primary schools, secondary schools, health

centres, church, sports facilities, shops and employment opportunities.

1.3 In terms of the extant Plan no development is identified within Whiteford. The

settlement statement prepared for Whiteford states the key planning objectives are

to preserve the amenity of the settlement.


Page 4 of 17

2.0 PLANNING HISTORY

Local Plan 2006

2.1 The Aberdeenshire Local Plan (2006) (ALP) identified the site as falling within the

Whiteford settlement boundary and allocated it as site reference fh1, capable of

accommodating around 15 houses. Land to the east of fh1 was allocated as site

reference eh1, capable of accommodating 74 houses.

Local Development Plan 2012

2.2 The site was not carried forward into the Proposed Aberdeenshire Local

Development Plan. Representations were submitted in response to the Proposed

Plan in October 2010 objecting to this.

2.3 Aberdeenshire Council issued Schedule 4 submissions to Scottish Ministers to

summarise their views on representations received to the Proposed Plan. In

discussing development at Whiteford, Aberdeenshire Council contended that

infrastructure constraints could only be overcome through significant growth which

would be out of proportion with the character of the settlement.

2.4 The Report of Examination for the Aberdeenshire Local Development Plan was

published on 9th March 2012. Issue 33 of the report discusses Other Sites in the

Huntly to Pitcaple SGA with regards to development of the site the Reporter found

that in the absence of any development on site eh1, development at fh1 would

project into the open countryside.

Planning Applications

2.5 In response to the allocation within ALP, two applications were submitted on 13th

October 2010; one for 13 dwellings (application reference APP/2010/3254) and one

for 5 dwellings (application reference APP/2010/3368). These applications were


Page 5 of 17

withdrawn on 11th July 2011 following discussions with officers to allow for

amendments to be made to the site layout and boundary.

2.6 Following adjustments to the layout, as discussed with the Planning Officer, two

new applications for the site were submitted on 1st July 2011. The larger

application (APP/2011/1927) proposed 15 houses whilst a smaller application, on

the balance of the fh1 site, proposed 3 houses. A third application

(APP/2012/1351) for the provision of a replacement culvert and construction of a

temporary access road was submitted on 20th April 2012. This application followed

the preparation of a flood risk assessment for the site and sought to alleviate a pre-

existing problem affecting a number of existing residential properties.

2.7 All three applications were reported to the Garioch Area Committee on 28th August

2012 to be considered as part of a package with a recommendation for conditional

approval. In determining the applications the Committee resolved to refuse

application reference APP/2011/1927 as they considered that it failed to comply

with the recently adopted Local Development Plan. The two related applications for

the erection of 3 dwellings and replacement culvert were approved. An appeal was

submitted to the Directorate for Planning and Environmental Appeals which was

dismissed.

3.0 DESCRIPTION OF SITE AND PROPOSALS

3.1 The bid site lies to the west of the settlement of Whiteford and is located to the

north of Whiteford Road. It lies to the north of a recent application for 3 units

(application reference: APP/2011/1926), which was approved on 4th October 2012.

A small tree belt forms the sites southern boundary. To the north the site is bound

by a small watercourse which flows into the River Urie. Existing residential

dwellings lie on the sites eastern boundary with agricultural land lying to the west of


Page 6 of 17

the site. In topographic terms the site is generally undulating and falls towards the

watercourse. The site extends to 1.81ha and currently comprises agricultural land.

3.2 The site lies within 685m of Logie Durno Primary School and is within the

catchment area for Meldrum Academy which is located in the nearby village of

Oldmeldrum, approximately 8 kilometres to the east.

3.3 House types in Whiteford range from traditional cottage style house types on

Whiteford Road to more recent semi detached dwellings of 1 – 1.5 storeys in height

on Whiteford Place and Whiteford Gardens.

3.4 The development bid proposes the erection of 15 dwellings comprising a variety of

house types ranging from 1 to 1.5 storeys in height. The dwellings proposed would

provide a mix of 2 – 5 bedroom properties varying from circa 62sqm to 252sqm in

size. Along with the 3 dwellings approved under application reference

APP/2011/1926 they are set around an area of public open space which, when

completed, will form an attractive village green.

4.0 NATIONAL PLANNING POLICY

Scottish Planning Policy (SPP)

4.1 Paragraph 3 of SPP states that the purpose of planning is to guide ‘the future use of

land. Planning is about where development should happen, where it should not

and how it interacts with its surroundings’. Paragraph 5 goes on to explain that

plans will ‘provide guidance to potential developers and investors; provide various

interests with the opportunity to participate in shaping the future of their nation and

their communities; and give public authorities a structure within which decisions can

be made with confidence’. Paragraph 6 notes that whilst ‘the planning system

cannot satisfy all interests all of the time. It should, however, enable speedy

decision making in ways which are transparent and demonstrably fair’. Paragraph

11 states that the purpose of Development Plans is to ‘guide the future use of land


Page 7 of 17

and the appearance of cities, towns and rural areas. They should indicate where

development, including regeneration, should happen and where it should not’.

4.2 Paragraph 33 advises that planning authorities should take a positive approach to

development, recognising and responding to economic and financial conditions in

considering proposals.

4.3 The Scottish Government are committed to sustainable development, paragraph 37

of SPP explains the important role the planning system has to play in supporting the

achievement of sustainable development through its influence on the location,

layout and design of new development. In deciding the locations of new

development SPP directs local authorities to:

Promote regeneration and the re-use of previously developed land,

Reduce the need to travel and prioritise sustainable travel and transport

opportunities,

Promote the development of mixed communities,

Take account of the capacity of existing infrastructure,

Promote rural development and regeneration, and

Prevent further development which would be at risk from flooding or coastal

erosion.

4.4 Paragraph 40 explains that the ‘settlement strategy set out in the development plan

should promote a more sustainable pattern of growth for an area, taking account of

the scale and type of development pressure and the need for growth and

regeneration’.

4.5 In discussing the delivery of new housing SPP states that ‘the delivery of housing

through the development plan to support the creation of sustainable mixed

communities depends on a generous supply of appropriate and effective sites being

made to meet the demand, and on the timely release of allocated sites’ (Paragraph

70). SPP goes on to explain the ‘allocating a generous supply of land for housing in


Page 8 of 17

the development plan will give the flexibility necessary for the continued delivery of

new housing even if unpredictable changes to the effective land supply occur during

the lifetime of the plan’ (paragraph 71).

4.6 To deliver successful places SPP (paragraph 78) advises that the ‘siting and design

of new housing should take account of its setting, the surrounding landscape,

topography, character, appearance, ecologies and the scope for using local

materials’. In delivering new homes the aim should be to ‘create places with a

distinct character and identity, promoting a well integrated mix of land uses

including well designed homes’.

4.7 Paragraph 94 of SPP highlights that the requirement to allocate a generous supply

of land applies equally to rural and urban areas. Accordingly SPP directs local

authorities to ‘support more opportunities for small scale housing development in all

rural areas’. SPP goes on to note that ‘in more accessible and densely populated

rural areas most new development should be in or adjacent to settlements’

(paragraph 95). It goes on to explain that ‘all new development should respond to

the specific local character of the location, fit in the landscape and seek to achieve

high design and environmental standards.’ Planning authorities are directed to

‘apply proportionate standards to access roads to enable small developments to

remain viable.’

4.8 In discussing flooding SPP presumes against development that would be affected

by flooding or would increase the risk of flooding elsewhere (paragraph 197).

Accordingly SPP directs developers to take flood risk into account before

committing themselves to site or project.

4.9 To support sustainable development SPP states that planning permission should

not be granted for significant travel generating uses in locations which would

encourage the private car and where access to public transport would involve

walking more than 400m.


Page 9 of 17

PAN 69 Planning and Building Standards Advice on Flooding

4.10 PAN 69 (August 2004) provides background information on good practice for

development in areas which could be affected by flooding or would increase the

probability of flooding elsewhere.

Planning Advice Note 75: Planning for Transport

4.11 Planning Advice Note 75: Planning for Transport accompanies Scottish Planning

Policy it states that planning authorities should establish accessibility profiles for

sites. The profile should reflect the catchment areas served, likely quality of service

and result in indicators of accessibility. A maximum threshold of 1600 metres in

terms of accessibility to local services by walking and cycling should be achieved

for new developments.

5.0 STRUCTURE PLAN

5.1 The Structure Plan (2009) identifies a requirement for around 72,000 dwellings

within the Structure Plan area over the next 20-25 years. Three Strategic Growth

Areas (SGA’s) are identified which will be the main focus for development and are

expected to accommodate 75-80% of growth over the next 20 years and more.

Around half of new development will be located within Aberdeen City, with

significant development expected in the Aberdeen to Huntly SGA, Aberdeen to

Laurencekirk SGA and the Aberdeen to Peterhead SGA. Additional growth is

proposed outwith these areas in the local growth and diversification areas. Levels

of growth within these areas should relate to local need and will vary from place to

place.


Page 10 of 17

5.2 Whiteford is located within the Rural Housing Market Area of the Huntly to Pitcaple

SGA. Within this corridor the Structure Plan states a requirement for 1,000

dwellings over the period 2007 – 2030.

5.3 The Structure Plan also advocates sustainable mixed communities and seeks to

achieve new development that meets the needs of the whole community, both now

and in the future, and makes the area a more attractive place for residents and

businesses to move to.

6.0 PROPOSED ABERDEEN CITY AND SHIRE STRATEGIC DEVELOPMENT PLAN

(FEBRUARY 2013)

6.1 Consultation into The Proposed Strategic Development Plan (SDP) closed on 12th

April 2013. Once adopted it will replace the extant Structure Plan. Accordingly it

forms a material consideration in the determination of this development bid.

6.2 The Proposed SDP carries forward the extant Plans vision for Aberdeen City and

Shire. In doing so it also carries forward the aims and objectives of the extant Plan.

6.3 The Proposed SDP again identifies three SGA’s and additional growth is proposed

outwith these areas in the local growth and diversification areas. Within the Huntly

to Pitcaple SGA the proposed SDP states that 1,000 new homes should be

developed during the period 2017 – 2035.

6.4 As the proposed SDP has not identified any increase in allocations in terms of

residential and employment land despite an increase in population projections, it is

the subject of objection from the Development Industry. The Development Industry

consider that allocations should increase in line with population projections. Should

a Reporter be minded to increase the Strategic Development Plan allocations, the

Local Development Plan will have to allocate additional sites over and above those

required to make up for those already allocated but not delivered, such as Huntly.


Page 11 of 17

7.0 ABERDEENSHIRE LOCAL DEVELOPMENT PLAN 2012

7.1 The Aberdeen Local Development Plan identifies sites to meet the housing land

allocations within the Aberdeen City and Shire Structure Plan. Within the Huntly to

Pitcaple SGA the ALDP has allocated new sites and also carried forward a number

of sites from ALP. Allocations have been made in Insch (R1-R7, H1, H2, H3,E1,

EH1 and EH2) and Huntly (H1, E1 and R1). Within Insch allocations are either

completed or under construction with completion expected by 2017. By

comparison, development in Huntly has stagnated and a number of sites are listed

as being constrained within the Draft Housing Land Audit 2013. This equates to a

total of 135 units of housing being constrained and unable to come forward within

Huntly. Worryingly site reference EH3 (ALP code fh2) carried forward from ALP for

105 dwellings is constrained.

8.0 SERVICES

8.1 There is a watercourse along the sites southern boundary however, an application

(APP/2012/1351) for the provision of a replacement culvert and construction of a

temporary access road was approved in August 2012. During consultation into

planning application reference APP/2011/1027 Aberdeenshire Councils Flood

Prevention Unit confirmed that they were satisfied with the proposed measures to

deal with surface water drainage and the levels of flood risk associated with the

application.

8.2 During consultation into application reference APP/2011/1927 Scottish Water

confirmed that the water network is currently able to supply the new demand.

However, there is limited capacity in the Whiteford North Wastewater treatment

works. Accordingly upgrades would be required to facilitate development.

8.3 The site lies within the catchment area for Logie Durno Primary School which is

operating above capacity. Discussions with Aberdeenshire Councils Planning Gain


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Department during consultation into planning application reference APP/2011/1927

agreed contributions towards education provision. As such, the development would

not have a detrimental impact on the capacity of the local primary school.

9.0 JUSTIFICATION

9.1 At the outset it must be emphasised that this site was the subject of an allocation

within the Aberdeenshire Local Plan which was only removed due to infrastructure

constraints, which have been subsequently overcome.

9.2 As discussed above representations were submitted objecting to the sites removal

from the Proposed Plan. The Reporters views on the relationship with the form and

character of the existing settlement, is contested. The site follows a natural

boundary with the watercourse along the northern side and a strategic landscape

belt is proposed to the west boundary whilst the eastern side of the development

would integrate well with the existing dwellings in the village. As recognised by the

planning officer during the determination of the application, it is unreasonable to

compare the layout of a new development with a historic settlement pattern.

Furthermore in most cases, new residential development is allocated on sites that

are in open countryside. It is evident that the village characteristics have been

considered during the design of the layout, which proposes that all dwellings

overlook an area of open space resembling a village green. Densities proposed by

the development are low and in keeping with the densities present within the

village.

9.3 Any development on the site would be seen as an expansion of the approved

development to the south. The approval of the application to the south and indeed

the sites allocation in ALP demonstrates that this is a suitable direction for growth

within the village. Any further development in this direction should be supported.


Page 13 of 17

9.4 Development in this location would fit well into the landscape as it is bound on two

sides by development in the form of recently approved housing to the south and

existing dwellings on Whiteford Road and, dwellings to the east. As shown in

Figure 1 strategic landscaping is proposed on the sites western boundary and a

village green is also proposed. This will provide an attractive setting for any

development and will deliver a desirable landscape feature which will benefit the

local community. To the north of the site lies a small watercourse which will contain

development. Development of the site would be screened by existing development

in the village when approaching from the west. From the east the development

would be screened by proposed strategic landscaping. Accordingly development

would not detract from the landscape setting of the settlement.

9.5 The proposed development would be of the highest quality and would pay due

attention to its setting, surrounding landscape and character. This is reflected in the

design of the dwellings proposed which have been specifically designed to ensure

that they not only fit in well with the landscape, but respect the natural and built

features of the site. As demonstrated by Figure 1 a range of housetypes including

semi detached and detached are proposed on the site including affordable housing.

Attention has been duly paid to the layout of the proposed development with

dwellings located around a traditional village green; which provides a focal point.

The high quality development that would be created is in compliance with the

objectives of the Structure Plan and SPP, both of which strive to deliver high quality

developments.

9.6 The site lying immediately adjacent to the settlement boundary of Whiteford and to

the north of recently approved development represents a logical area for expansion.

Lying within the Huntly to Pitcaple SGA, within proximity to both Inverurie and

Oldmeldrum, it is well placed to take advantage of services located within these

settlements. Development in this location would be in keeping with the ethos of

SPP which states that within rural areas most new development should be within

more accessible rural areas or located adjacent to settlements.


Page 14 of 17

9.7 The proposal should be viewed within the context of the application approved for

the development of three dwellings and the replacement culvert, together they

would have developed out the fh1 allocation delivering a coherent and carefully

planned development with associated infrastructure, strategic landscaping and

extensive public open space. Accordingly the site should be allocated to allow it to

be developed in its entirety thus ensuring a high quality development is delivered in

compliance with SPP.

9.8 The replacement culvert is required to alleviate an existing flooding problem

affecting a number of existing properties, the problem was initially identified through

a flood assessment undertaken by Aberdeenshire Council but was incapable of

being resolved by them due to the difficulty of providing vehicular and pedestrian

access to existing properties whilst the replacement works were underway. The

allocation of the site which is the subject of this development bid not only provides

an opportunity to fund the replacement works but also to provide a temporary

access through the bid site and the land to the north which is under the control of

the appellant.

9.9 SEPA and the Councils own Flood Prevention Unit were both heavily involved in

the application process for all three applications and were satisfied with the level of

flood risk associated with the development. Both confirmed that the replacement

culvert would not only benefit the proposed development but would also benefit the

existing dwellings, as it will replace the existing culvert with a much larger structure

which will reduce flood risk in the area. This is a significant advantage of the

proposal. The proposal is therefore compliant with the provisions SPP and PAN 69

as the development would not be at risk of flooding.

9.10 As discussed in paragraph 6.1 consultation into the proposed SDP closed on 12 th

April 2013. Without any increase to employment and residential allocations

objections have been submitted by the Development Industry. Should the Strategic


Page 15 of 17

Development Authority or Reporter be minded to increase allocations there will be

insufficient allocations within the forthcoming LDP. Furthermore a number of sites

allocated within the LDP, such as those in Huntly, have failed to deliver or are being

delivered at a slower rate than predicted and in addition to this, sites carried forward

from the Local Plan are no longer considered to be effective. As such, new

allocations are required to meet the inevitable shortfall in housing land supply.

Sites such as this, in proximity to existing services, that can be delivered in the

short term and can continue to provide housing for local needs within the RHMA of

the SGA, should be identified within the Review of the LDP for development.

9.11 As noted above, the site lies within the Huntly to Pitcaple SGA. Within this SGA

allocations in Huntly have failed to come forward and as noted in paragraph 7.1

above, are listed as being constrained within the Draft Housing Land Audit 2013. It

is evident that Huntly is unable to deliver the levels of growth required to satisfy the

requirements of both the 2009 Structure Plan and the Proposed Strategic

Development Plan. In compliance with guidance contained within SPP

Aberdeenshire Council should review previous assumptions made with regards to

development in Huntly and question if current allocations remain valid. It is

contended that the allocations within Huntly, including EH3, are no longer effective

and accordingly should be removed and transferred to other sites, such as

Whiteford, within the Huntly to Pitcaple SGA, which can deliver in the short term.

9.12 Development at Whiteford would assist in meeting the levels of growth required to

satisfy the Structure Plan requirements. As demonstrated above, the landowner of

the bid site is committed to delivering the site, this is evident through progressing

planning applications for not only the development of the site, but also by

progressing an application for a replacement culvert. Accordingly the site can be

delivered in the short term thus contributing to the housing supply within the Huntly

to Pitcaple SGA and should be identified for development in the period 2017 - 2021.


Page 16 of 17

10.0 CONCLUSION AND RECOMMENDATIONS

10.1 It is of paramount importance to recognise that this site was previously allocated for

development within ALP and in acknowledgement of this, land to the south of the

site was recently approved for the development of three dwellings. This site

therefore is accepted as logical area for the expansion of Whiteford. The

development of the site in this location would deliver a sustainable development

which is supported by both SPP and the Structure Plan.

10.2 Development on this site would be well contained in the landscape being bound on

two sides by development and a further side by a burn which would provide a

defensible boundary to development in the settlement. As demonstrated above

development of this site would not have a significant impact on the visual setting of

Whiteford.

10.3 Whiteford has good links with Inverurie and Oldmeldrum and as such it is

considered that this is an ideal location to deliver development in keeping with

guidance contained in SPP which directs new rural development to accessible

areas.

10.4 The indicative layout presented demonstrates that the development proposed is of

the highest quality and will form an attractive addition to the local area.

Furthermore the proposal has been specifically designed and strategic landscaping

duly placed to ensure that it does not have a detrimental impact on the landscape

character of the area.

10.5 It is therefore respectfully requested that the bid site is identified for residential

development within the Review of the Aberdeenshire Local Development Plan.

10.6 As discussed above, it is inevitable that there will be a lack of housing land due to a

number of sites allocated in the ALDP being constrained and delivered at a slower


Page 17 of 17

rate than expected. The lack of housing land supply will be further exacerbated

should additional land requirements be identified following consultation into the

Proposed Strategic Development Plan. It is requested that allocations in Huntly

which are noted as being constrained in the Draft Housing Land Audit 2013,

including site reference EH3, are deleted from the ALDP and their allocations

transferred to other sites within the Huntly to Pitcaple SGA, including land subject of

this development bid. Failure to do so will result in the Review of the Local

Development Plan being unable to deliver the levels of growth required by the

Proposed Strategic Development Plan for the Huntly to Pitcaple SGA.

Paper Apart

Representation to the Main Issues Report on behalf of Drumrossie Land Development

Company Ltd

Site Reference GA043 (Whiteford)

Objection is made to the failure of the Main Issues Report (MIR) to identify land at GA043 as a preferred option for development. It is respectfully requested that the site is allocated for development in the Proposed Aberdeenshire Local Development Plan 2016.

At the outset it is of paramount importance to recognise that this site was previously allocated for development within ALP and in acknowledgement of this, land to the south of the site was recently approved for the development of three dwellings. This site therefore is accepted as a logical area for the expansion of Whiteford.

Issue is taken to comments made in relation to the site in the MIR. The MIR notes that development of the site and indeed Whiteford itself is not supported as there is a ‘lack of ‘sustainable travel links and services in the settlement’. This is disputed. Whiteford is ideally located between Inverurie, Oldmeldrum and Insch to accommodate development and take advantage of services available in these areas including: shops, leisure, public transport and rail. It is considered that the site is an ideal location to deliver development in keeping with guidance contained in SPP which directs new rural development to accessible areas.

In addition to the above, Whiteford is served by ‘Dial a Bus’ which provides services on Mondays and Fridays. In any event, should the site be allocated engagement would be undertaken with local public transport service providers with a view of providing a service to Whiteford. This would only be justified by development in the settlement and accordingly is a wider benefit of the proposal.

The MIR goes onto state that ‘Whiteford is not considered a sustainable location for development due to the lack of services in the settlement and the additional strain development would place on Logie Durno Primary School’. As highlighted in the Development Bid previously submitted discussions were undertaken with Aberdeenshire Councils Planning Gain Department during consultation into planning application reference APP/2011/1927 which agreed contributions towards education provision. As such, the development would not have a detrimental impact on the capacity of the local primary school. For the MIR to state capacity issues as a reason not to allocate development in Whiteford when contributions had previously been agreed in principle with Aberdeenshire Councils Planning Gain Department is unacceptable.

In citing comments made by the Reporter during the examination into the Proposed Aberdeenshire Local Development Plan 2012 the MIR has failed to acknowledge comments made by the Planning Officer who determined previous planning applications for the site. The

Planning Officer, in considering development of the site, disputed the Reporters’ findings and

considered that ‘…the site follows a natural boundary with the watercourse along the northern side and a strategic landscape belt is proposed to the west boundary whilst the eastern side of the development shall integrate reasonably well with the existing dwellings in the village. In any case, it is not reasonable to compare the layout of a new development site with the historic settlement pattern which is present in the older part of the village. In most cases, new residential development is allocated on sites that are in open countryside.’ (Committee Report attached).

It is contended that development of the site would, as recognised by the Planning Officer, fit well into the landscape, as it is bound on two sides by development in the form of recently approved housing to the south, existing dwellings on Whiteford Road and dwellings to the east. Strategic landscaping is proposed on the sites western boundary and a village green is also proposed. This will provide an attractive setting for any development and will deliver a desirable landscape feature which will benefit the local community. To the north of the site lies a small watercourse which will contain development. Development of the site would be screened by existing development in the village when approaching from the west. From the east the development would be screened by proposed strategic landscaping. Accordingly development would not detract from the landscape setting of the settlement.

Development on the site would be seen as an expansion of the approved development to the south. The approval of the application to the south and indeed the sites allocation in ALP demonstrates that this is a suitable direction for growth within the village. Any further development in this direction should be supported.

Notwithstanding the Reporters Recommendations on the Proposed Strategic Development Plan, the development industry make their concerns regarding the adequacy of the land supply and contend that further sites should be allocated to ensure that at least a fife year supply at the end of the Plan period. Furthermore a number of sites within the LDP have been drawn down early to augment the 2012 – 2016 supply and a number of sites carried forward from the Local Plan are no longer effective or are being delivered at a slower rate than predicted. As such, new allocations are required to meet the inevitable shortfall in housing land supply. Sites such as this, that can be delivered in the short term and can continue to provide housing for local needs, should be identified within the Review of the LDP for residential development.

In light of the reasoning set out above, it is respectfully requested that GA043 is identified as a preferred option for development. Doing so will ensure that an effective supply of housing is delivered in Whiteford.

PAPER APART

Introduction

Objection is made by Drumrossie Land Development Company Ltd to the failure of the

Proposed Aberdeenshire Local Development Plan (ALDP) in identifying sites Ga039

Denwell Farm and Ga040 Drumrossie Farm for residential development.

This objection should be read in conjunction with the Development Bids (Appendix 1 & 2) and

the response to the Main Issues Report (MIR), promoting sites Ga039 and Ga040 for

residential land use (Appendix 3). Allocation of these sites, would ensure the sustainable and

balanced growth of Insch, contribute to the area achieving strategic housing targets as set out

by the Aberdeen City & Shire Strategic Development Plan (SDP) approved in March 2014,

and support local services and transport infrastructure.


It is contended that site Ga039 at Denwell Farm and site Ga040 at Drumrossie Farm, as

promoted through the respective Development Bids of April 2013 and Representations to the

Main Issues Report (MIR) submitted in January 2014, should be identified within the

Aberdeenshire Local Development Plan 2016 for residential development. Accordingly, the

proposals map for Insch should be amended to encompass both sites and Table 5 of Appendix

A5: New Housing Land Allocations modified to reflect allocations for approximately 70 and 186

units on sites Ga039 and Ga040 respectively.

Reason for change:

Background

Site Ga039 was initially promoted through the 2006 Local Plan review, and more recently in a

response to the Council’s call for sites in respect of the emerging Local Development Plan,

Development Bids were submitted in April 2013 requesting the inclusion of both Ga039 and

Ga040 within the 2016 ALDP. The Main Issues Report considered both sites, however neither

were deemed as a preferred option by officers.

The MIR did not consider the proposed 260 units at Ga039 to be appropriate in relation to the

existing size of the town. Representation to the MIR (Appendix 3) proposed a partial allocation

in response to the site’s assessment within the MIR, however Garioch Area Committee chose

to accept officer recommendation not to include the site at Denwell Farm for residential use.

Simultaneously, the MIR recognised that site Ga040 at Drumrossie Farm is ‘well located…

close to the town centre’, again however, as per officer’s recommendation, the site was not

identified within the Proposed ALDP. Objection is now made to this.

Strategic Housing Land Supply

Insch lies within the Huntly to Pitcaple section of the Aberdeen to Huntly Strategic Growth

Area, as designated by the SDP. This area is expected to deliver 500 units in the period 2017-

26 and a further 200 homes between 2027 and 2035 in addition to the 300 existing allocations

to 2016. Of these existing allocations, and as noted by Table 7 of Appendix 5A: New Housing

Land Allocations, 176 units allocated to Huntly for the period to 2016 remain unbuilt. Indeed,

only 37 are expected to be completed, according to Appendix 3 of the 2014 Housing Land

Audit, within that period. This will result in an anticipated deficit of 139 homes by 2016,

therefore falling short of the expected delivery targets for the Huntly – Pitcaple section of the

SGA. Also, the figures in Table 1 of Appendix 5A relative to the area, inclusive of effective

supply, windfall sites and Proposed ALDP housing allocations, continue to show an overall

deficit of 34 units in the period to 2035.

It is clear from the HLA that 630 units across three allocated sites (OP1, OP2 and OP4) in

Huntly continue to be subject to constraints, which is likely to exacerbate delivery further. The

MIR states that sites Ga039 and Ga040 ‘should only be considered an option If large scale

development is required due to constraints to development in Huntly’. A separate

representation has been submitted objecting to the continued allocation of land to Huntly when

there is no realistic prospect of it being developed.

This situation is now a reality and should be recognised by the Council as justification for the

transfer of constrained units in Huntly to effective sites such as Ga039 and Ga040 at Insch.

In line with Scottish Planning Policy (SPP), published in June 2014, the planning system

should demonstrate flexibility to accommodate changing circumstances and allocate

developable land which will guarantee delivery. This will ensure that an effective 5 year

housing land supply is maintained within Aberdeenshire.

Drumrossie Land Development Company Ltd has been involved in the build out of 70 homes

at EH1, due for completion by 2016 as well as the completion of 25 homes at EH2. An

application for 48 homes at H1 is currently pending consideration, demonstrating the

developer’s commitment to the sustainable and appropriate growth of Insch. This also

demonstrates a consistent high level of demand for housing in the area and as such,

transferring a portion of the constrained allocations at Huntly to effective land supply at Insch

would enable this demand to be met. It would also provide an opportunity for this section of

the SGA to meet its housing land supply target, which at present it is unlikely to deliver, in

conflict with paragraph 119 of SPP.

Furthermore, the SDP has calculated its housing targets upon outdated 2008-based figures

which estimate the population of the North East at 500,000 in 2035. This is a significant

understatement in light of the National Records of Scotland figures published in June 2014

which project the population of the area to rise to around 570,000 by 2035. Additionally, a

number of sites have been drawn down early to augment the 2012-16 supply and, as

evidenced above, many of these are being delivered at a slower rate than predicted. As such,

the identification of additional land for residential use at sites Ga039 and Ga040 at Insch can

make an effective contribution to addressing the inevitable shortfall in housing land supply and

help to achieve housing targets in the period to 2035.

Site Ga039 Denwell Farm

This site is considered a logical extension to the adjacent OP4 site which is currently being

built out. Its allocation will provide a mix of uses in the northern segment of the town and

promote new development around employment opportunities at Insch Business Park and the

proposed primary school. It is situated within walking distance of nearby leisure facilities as

well as the town centre. The allocation of OP5 indicates the expectation of additional business

and commercial investment within Insch. The location of housing in close proximity to areas

of employment is encouraged by SPP in order to promote sustainable communities as well as

reducing travel to work distances and reliance on the private car.

Within the Development Bid (Appendix 1), the site was promoted for 260 units and possesses

the capacity to accommodate such an allocation. However, an allocation of Ga039 for around

70 units is viewed as an appropriate extension to OP4 in the short term, and would allow for

the initial phasing of the greater area of the site for development during phase 2 of the

emerging ALDP.

Design, layout and density would reflect that of the adjacent allocation and would be sensitively

scaled. Landscaping and buffer strip planting would maintain a sense of place within the

development ensuring that residential amenity is unaffected by commercial uses at the BUS

allocation opposite. The inclusion of site Ga039 in the ALDP would match well with the

employment land allocation at OP5 and establish a definitive boundary to the settlement. The

site is effective and developable in the short term and is therefore considered a viable

opportunity for the appropriate growth of Insch.

Ga040 Drumrossie Farm

The site at Ga040 is considered infill due to its location. The MIR assesses that site Ga035

is a ‘good option’ for further development in Insch. It is therefore reasonable to assume site

Ga040 in a similar context as it adjoins Ga035 and shares virtually identical attributes.

Allocation of Ga040 would reflect the pattern of growth in Insch and its development as an

extension of the former EH2 site would be in line with SPP as an appropriate addition to a

settlement, therefore optimising existing infrastructure and services. The site is effective and

developable in the term and hence is well placed to contribute to the sustainable growth of the

settlement. As recognised by the MIR, the site is ‘well located… close to the town centre’. As

such, residents can take advantage of optimum levels of accessibility and strengthen the links

with the wider settlement forged through the allocation of R3 which aims to enhance local

walkways.

Concerns over the impact on the B Listed Drumrossie House are unfounded. Development

on site would provide sensitive landscaping buffers at the south eastern perimeter, adding to

the considerable screening already in place. Careful planning and consideration can ensure

that this perceived constraint can be overcome. Appropriately scaled and designed residential

dwellings would integrate with and reflect the density of the completed development at the

former EH2 site, promoting placemaking and sustainability, the two principle objectives of

SPP.


The SDP encourages development in accessible areas which contributes to creation of

sustainable mixed communities and population growth. The allocation of sites Ga039 and

Ga040 are accessible and will ensure a balanced supply of housing land in proportion to

business allocations within the settlement. Insch is well positioned to capitalise upon its

connectivity, aided by its proximity to the A96 and its position on the main Aberdeen to

Inverness railway line, and through the appropriate allocations of land at Denwell Farm and

Drumrossie Farm, it can grow to further establish itself as a sustainable settlement as well as

a desirable commuter location. Development will help in ‘sustaining and enhancing existing

facilities’, as promoted through the vision statement for Insch.

It is firmly contended that these sites should be considered as, in compliance the MIR,

‘development is required due to constraints to development at Huntly’. As such, a proportion

of units should be transferred to effective sites at Insch to enable the delivery of strategic

housing land targets within the SGA as laid out by the SDP.

Based on the foregoing it is respectfully respected that the settlement boundary of Insch is

extended to encompass sites Ga039 and Ga040. Accordingly, Table 5 of Appendix A5: New

Housing Land Allocations should be modified to include an allocation for 70 and 186 residential

units at Denwell Farm and Drumrossie Farm respectively.

PAPER APART

Introduction

Objection is made by Drumrossie Land Development Company Ltd to the Proposed

Aberdeenshire Local Development Plan (ALDP) in the allocation constrained sites in

Huntly for the delivery of strategic housing targets.

This objection should be read in conjunction with the Development Bids (Appendix 1 & 2)

relative to the promotion of sites Ga039 and Ga040 at Insch and site Ga043 at Whiteford for

residential land use. It is contended that sites OP1, OP2, OP3 and OP4 at Huntly, allocated

for 661 homes are not deliverable during the Plan period. To maintain an effective land supply

and meet Strategic Development Plan (SDP) requirements for the Huntly - Pitcaple Strategic

Growth Area (SGA) all, or some of these sites should be removed from the Plan and replaced

with those at Insch and Whiteford. Concerns were expressed regarding the deliverability of

these sites at the Examination in Public into the last ALDP and these have been confirmed by

the failure to bring the sites forward for development.


The OP1, OP2, OP3 and OP4 allocations at Huntly should be removed from the Plan and be

replaced with effective sites at Insch and Whiteford, as promoted by Drumrossie Development

Company Ltd. Table 7 of Appendix 5A: New Housing Land Allocations should be modified

accordingly. Sites Ga039 (70 units), Ga040 (186 units) and Ga043 (15 units) at Insch and

Whiteford respectively should be allocated for development in their respective settlement

statements. Table 5 of Appendix 5A should also be modified to reflect this change.

Reason for change:

Background

As mentioned above, concerns were raised on behalf of Drumrossie Land Development

Company Ltd during the review of the Aberdeenshire Local Plan 2006 as the Main Issues

Report of May 2009 identified constrained land at Huntly for residential development.

Objection was made to this at both MIR (Appendix 3) and Proposed Plan stages (Appendix

4), as well as being challenged via written submission (Appendix 5) and presentation at a

Hearing Session during the Examination in Public of the extant ALDP in September 2011.

However, the ALDP proceeded to allocate units to constrained sites at Huntly.

The allocation of these ineffective sites at Huntly was again disputed by Development Bids

(Appendix 1 & 2) made in April 2013 promoting land at Insch and Whiteford for inclusion in the

emerging ALDP. Objection is now made to the inclusion of sites OP1 – OP4 at Huntly for

residential units in the Proposed ALDP. These sites continue to be constrained and incapable

of delivery and as a result, threaten the ability of Huntly - Pitcaple section of the SGA in meeting

strategic housing requirements.

Constrained Supply

Scottish Planning Policy (SPP), adopted in June 2014, requires local development plans to

identify and allocate land to ensure a 5 year supply of effective housing land at all times.

Paragraph 119 states that ‘in allocating sites, 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 targets to be met’. Paragraph 122 proceeds to advise

that ‘a site is only considered effective when it can be demonstrated that within 5 years it will

be free of constraints and can be developed for housing’. Objection is made to the Proposed

ALDP in respect of the significant number of housing units currently allocated to sites at Huntly

which are constrained and are not anticipated to come forward for development within a 5 year

period.

Planning Advice Note 2/2010: ‘Affordable Housing and Housing Land Audits’ identifies the key

elements of site effectiveness as based on physical, marketability and infrastructure attributes.

Appendix 4 of the 2014 Housing Land Audit (HLA) includes sites OP1, allocated for 485 units;

site OP2, allocated for 105 units; and, site OP4, allocated for 40 units at Huntly as constrained

due to physical and infrastructure issues. Sites OP2 and OP4 are also included within

Appendix 5 as ‘Long Term Constrained Sites’, having been included within the HLA since 2006

and 2004 respectively. This is a clear indication that these sites have not, and are not

expected to come forward for development in the short term, justifying the argument that

alternative sites should be identified to mitigate this failure to deliver.

Furthermore, the recent introduction of site OP1 into the HLA is disputed due to its immediate

categorisation as a constrained site due to flood risk and sewage issues. Addition of this site

for large scale residential development is considered untenable and will ultimately contribute

to the failure of the Aberdeenshire LDP 2016 to comply with SPP. It is firmly contended that

the Council should reconsider the allocations at Huntly and instead allocate effective sites,

such as those at Insch and Whiteford, to allow the delivery of vital residential development

within the SGA. Doing so will help to achieve the objectives of the SDP through population

growth and creation of sustainable mixed communities at accessible locations.

Strategic Growth Area

Huntly is a major town within the Huntly - Pitcaple section of the Aberdeen - Huntly Strategic

Growth Area, as designated by the SDP. This SGA area is expected to deliver 500 units in

the period 2017-26 and a further 200 homes between 2027 and 2035 in addition to the 300

units allocated for the period to 2016. Allocating such a significant number of units to a small

number of sites in a settlement which is subject to physical and infrastructure constraints is a

major concern. The Council are putting ‘all their eggs in one basket’ and due to constraints it

simply cannot deliver the required housing numbers.

Of the total allocated sites in Huntly to 2016, as noted by Table 7 of Appendix 5A: New Housing

Land Allocations, 176 units remain unbuilt. Indeed, only 37 are expected to be completed,

according to Appendix 3 of the 2014 Housing Land Audit, within that period. This will result in

an anticipated deficit of 139 homes by 2016, therefore falling short of the expected delivery

targets for the Huntly - Pitcaple section of the SGA. Also, the figures in Table 1 of Appendix

5A relative to the area, inclusive of effective supply, windfall sites and Proposed ALDP housing

allocations, continue to show an overall deficit of 34 units in the period to 2035.

It is clear from the Proposed ALDP that 661 units across three allocated sites (OP1, OP2, OP3

and OP4) in Huntly continue to be subject to constraints, which is likely to exacerbate delivery

further. Large scale capital investment is required to mitigate constraints to enable the release

and delivery of these units, however to date, developers have yet to be identified at sites OP1,

OP2 or OP4 with the situation likely to endure in the short term. It is therefore clear that these

sites are not expected to come forward for development within a 5 year period and as a result,

alternative effective sites should be identified to ensure a 5 year housing supply in line with

SPP.

The Council can ill afford to ignore this situation which will ultimately result in the Huntly -

Pitcaple section of the SGA failing to meet its strategic housing targets which will result in non-

compliance with SPP. The units should be reallocated to effective sites at Insch and Whiteford.

Insch has demonstrated efficiency in the delivery of allocated housing land supply, with all

allocated sites anticipated for completion by 2017, testament to levels of demand and the

responsiveness of developers to deliver housing on effective land at an accessible and

sustainable location. It is clear that Huntly is not in a position to make good on the delivery of

its allocated units due to constraints and as a result, action should be taken to ensure these

are delivered at effective sites such as at Insch and Whiteford.


It is clear that sites OP1 – OP4 at Huntly cannot deliver the SDP housing requirements in the

Huntly - Pitcaple section of the SGA. These concerns were expressed at the Examination in

Public into the previous ALDP. This situation can no longer be ignored as persisting with the

approach detailed within the Proposed ALDP will ultimately lead to the failure of the 2016

ALDP in complying with SPP by ensuring that an effective 5 year housing supply is achieved

in Aberdeenshire.

Accordingly, all or some should be removed from the Plan. Instead sites Ga039 (70 units),

Ga040 (186 units) and Ga043 (15 units) at Insch and Whiteford respectively should be

allocated to help address the failings of these sites. Both Table 5 and Table 7 of Appendix

5A: New Housing Land Allocations should be modified to include these allocations. This will

ensure that both Insch and Whiteford optimise effective land resource capable of delivery of

residential units at accessible locations within the SGA as well as making a vital contribution

to meeting strategic housing targets which are unlikely to be achieved through the approach

detailed within the Proposed ALDP.

PAPER APART

Introduction

Objection is made on behalf of to the failure of the Proposed

Aberdeenshire Local Development Plan (ALDP) in identifying land to the south west of

St Cyrus for residential development.

objects to the failure of the Proposed ALDP to identify additional housing land

to make provision for the long term growth of St Cyrus. Allocation of the lands immediately to

the south west of the allocated OP1 site, and to the north of the A92 / Lochside Road junction,

as illustrated within Appendix 1, for delivery within the second phase of the emerging

Aberdeenshire Local Development Plan 2016 would ensure an effective supply of housing

land is maintained in the settlement. This would enable St Cyrus to achieve the objectives for

the settlement in meeting local housing need whilst sustaining and providing opportunities for

new services and employment.


Table 6 of Appendix A5 ‘New Housing Land Allocations’ should be amended to include two

additional allocations of 20 units at Lochside Road and 50 units as an extension to the OP1

site for delivery in the period 2017-2026. The settlement statement and proposals map for St

Cyrus should be modified accordingly to reflect this. This will ensure that an effective housing

land supply is maintained in St Cyrus in the long term to enable population growth and the

creation of sustainable mixed communities, as promoted through the objectives of the

Strategic Development Plan, approved in March 2014.

Reason for change:

Background

The Aberdeenshire Local Plan 2006 included land at Lochside Road as fh4* for future housing

use. The Council have therefore accepted the principle of residential development coming

forward at the site. In response to the publication of the Main Issues Report of the extant

ALDP review in October 2013, representation was made promoting these lands, as well as

those adjoining the south western perimeter of the OP1 Roadside site, for residential

development (Appendix 1).

Kincardine & Mearns Area Committee accepted officer’s recommendation at their meeting of

June 2014 and consequently, no additional housing land was included in the Proposed ALDP.

Objection is now made to this. The sites relate well to the settlement of St Cyrus and possess

the potential to integrate successfully with the OP1 site, for which a Masterplan was approved

by Kincardine & Mearns Area Committee in September 2014. Pedestrian links and

connectivity to the Loch Side area of the settlement will be strengthened and an allocation for

residential use will contribute to the sustainable development of the south west segment of St

Cyrus.

Justification

The SDP has designated St Cyrus as an area for local growth and diversification as well as a

priority for regeneration. Paragraph 3.42 states that growth in individual settlements should

relate to local needs and provide a mix of housing, whilst paragraph 3.39 encourages

development that provides employment to the area. Paragraph 3.48 insists that change in

regeneration priority areas must ‘bring lasting benefits and have positive effects on their vitality

and viability’. Such objectives are reflected by the settlement statement for St Cyrus to assist

in attracting economic growth and benefit to the area.

St Cyrus is located within the Rural Housing Market Area (RHMA) which Schedule 1 of the

SDP designates for the delivery of 12,200 homes in the period to 2035, with 4,200 of these

existing allocations to 2016. Table 4 of Appendix 5A New Housing Allocations denotes that of

the 480 units allocated within the RHMA of Kincardine & Mearns, 432 houses remain to be

built out by 2016. This delay in delivery is attributable to constrained housing land supply and

the ineffectiveness of allocated sites coming forward for development. In accordance with

Scottish Planning Policy (SPP), the Council should identify land which is expected to be

developable within a 5 year period. It is contended that the promoted lands to the south west

of St Cyrus are capable of being effective and appropriate for residential development. Indeed,

this principle has previously been accepted by Aberdeenshire Council through the

identification of site fh4* for future housing use in the Local Plan 2006.

The inclusion of the area adjoining the south west perimeter of OP1, in line with paragraph 40

of SPP, is viewed as a logical extension to the village and in combination, the allocation of

both promoted parcels of land will serve to ‘round off’ the settlement and contribute to the

creation of an attractive visual entrance to St Cyrus. Both sites are well related to the

settlement and would integrate with the village centre and the amenities and services provided

at the OP1 site through pedestrian linkages and footpaths along the A92. The Proposed ALDP

vision for St Cyrus recognises its ‘good transport links north and south’. Accessibility, as stated

by the SDP, is an attribute which should be capitalised upon and St Cyrus is well located to

grow as a sustainable location as well as an attractive commuter settlement with good links to

Montrose, 6 miles south and Laurencekirk and Aberdeen approximately 7 and 35 miles north

respectively.

Employment opportunities, through building and construction by local house builders and

contractors, will be enhanced, bringing net economic gain to the area, as well as promoting

population growth and sustainable mixed communities, in accordance with the objectives of

the SDP.

Furthermore, National Records of Scotland figures published in July 2014 project the

population of the North East region to rise to around 570,000 by 2035. This is significantly in

excess of the figure of 500,000 upon which SDP housing allowances have been based. This

will inevitably result in a shortfall in housing supply over the next 20 years, requiring additional

sites to be identified to alleviate this problem. Therefore the identification of additional sites

for residential development in St Cyrus is justifiable and will ensure that the settlement is well

placed to accommodate steady housing demand in the area, evidenced by the build out of 17

units at site OP2 due for completion by 2017. Significant local demand exists for a range of

accommodation types in St Cyrus, highlighted during the public consultation into the

preparation of the Masterplan at OP1.

The Masterplan for site OP1 at Roadside for a mix of up to 125 units, employment land, retail

and open space was approved at Kincardine & Mearns Area Committee in September 2014.

As indicated within representation to the Main Issues Report (MIR), this allocation is unlikely

to accommodate 125 units due to 25% of the site having been reserved for employment and

retail use. Additionally, 40% has been earmarked for open space, leaving limited land for

residential use. A planning application is likely later in 2015, with build out commencing by

2017 at a rate of 15 dwellings per annum, resulting in completion by 2024. This requires

further land to be allocated in the period 2017-26 in order to maintain an effective supply of

housing land in St Cyrus which will ensure its long term growth, support services and create

further opportunities for employment.

Roll numbers at St Cyrus Primary School are decreasing with the school projected to be

operating at 90% of its maximum capacity of 145 by 2019, based on 2013 forecasts. It was

recently verified that the physical capacity of the school is 163 and Aberdeenshire Council

Education Service confirmed in June 2014 that a pilot teaching scheme was being launched

to increase teaching staff numbers. Notwithstanding the predicted 6 pupils arising from the

build out of OP1 at a rate of 15 dwellings per annum from 2017, the primary school would not

reach capacity until 2024, at which time developer contributions from allocated residential

development would mitigate pressure to the service. Additional land allocations for residential

development to the south west of St Cyrus will consolidate the school roll as well as sustaining

and contributing to employment creation in the area.


St Cyrus is well located to take advantage of its good transport links, accessible location and

its steady levels of demand in order to make a real and valid contribution to the strategic RHMA

housing targets as set out in the SDP. The development of OP1 will set a mixed use precedent

to the south west of the settlement which can be capitalised upon and integrated with additional

allocations of land adjacent to the south of the A92, and also north of its junction with Lochside

Road. This will contribute to the creation of sustainable mixed communities and the delivery

of development effective land where the principle of residential use has previously been

established by the 2006 Local Plan. This will ensure that the long term growth of St Cyrus is

safeguarded and services are maintained through identifying future housing opportunities, as

supported by the vision statement for the settlement in the Proposed ALDP.

Based on the foregoing it is recommended that the settlement boundary of St Cyrus be

extended to encompass the parcels of land to the south west of OP1 and north of the A92 and

Lochside Road junction, as illustrated within Appendix 1. These sites should be allocated as

opportunity sites for the development of 50 and 25 residential units respectively for delivery in

phase 2 of the Aberdeenshire LDP 2016. Table 4 of Appendix 5A ‘New Housing Land

Allocations’ should be amended accordingly to reflect this. Allocation as such, will contribute

to the local growth and regeneration of the area and attract services and employment, in

accordance with the objectives of the SDP.

Paper Apart

Representations to the Main Issues Report on behalf of in response to Question 14, in respect of St Cyrus.

Introduction

The Masterplan for St Cyrus may not deliver the full 125 housing units allocated in the Aberdeenshire Local Development Plan (LDP)(2012). The Masterplan for development of the site is at a finalised stage, pending formal approval by Aberdeenshire Council. Approval of the finalised Masterplan is anticipated in the second quarter of 2014, with an application for planning permission anticipated shortly thereafter. On this basis the housing land supply in St Cyrus will be readily quantifiable before the preparation of the Proposed Local Development Plan.

Based on the anticipated start date and rate of build, development of site M1 will be complete before the end of the current phase 2. In order to maintain a buoyant supply of housing land and to address the shortfall in the number of units to be delivered on site M1, the two sites to the north-east of Lochside Road and the south-west of the A92/Lochside Road Junction, as identified in appendix 1, are well-related to the existing settlement and to the M1 site and are ideally placed to accommodate this development.

It is requested that the sites to the north-east of Lochside Road and the south-west of the A92/Lochside Road Junction, as identified on the plan at appendix 1 are allocated to accommodate development in phase 2 of the LDP, 2017-2023.

Land to the North-East of Lochside Road

The land to the north-east of Lochside Road (appendix 1) measures approximately 1.97ha, the predominant surrounding land use is residential, with the caravan park to the north. The site is bound by Lochside Road on the south-west, residential dwellinghouses to the north-west, an open field to the north-east, residential development to the east, and the A92 to the south beyond which there is a petrol filling station, a row of dwellinghouses and the soon-to-be developed M1 site.

Development in this location would fit in with the character of development of this area, which will eventually be surrounded by dwellinghouses on three sides once the development of M1 is complete. This site was identified as future housing land in the previous Aberdeen Local Plan (2006) as fh4*. The site has excellent proximity to services and pedestrian connections to the existing settlement and the M1 development, which will provide local areas for recreation, dedicated pedestrian footways and services.

Land to the South-West of the A92/Lochside Road Junction

The land to the south-west of the A92/Lochside Road Junction adjoins the M1 site on its south-western boundary (appendix 1) and extends approximately 4ha along the south side of the A92 between the boundary of the M1 site, to Scotston Cottages in the south-west although development could extend as far as the 30mph sign, rather than up to the cottages, should

the scale of land required be less. As with M1, the unclassified Croft Road defines the south-eastern boundary of the site.

Development of this site would be a continuation of the development of M1 and the Masterplanned development could accommodate links through to this site.

St Cyrus

Whilst not as strong as locations closer to Aberdeen or main transport corridors, demand for

residential development in St Cyrus is robust and steady. Sales of recent residential

developments in St Cyrus have exceeded expectations; and demand for a range of

accommodation types is strong, as evidenced by the public consultation events held in the

Village Hall during the Masterplan preparation.

Aberdeen City and Aberdeenshire Housing Land Audit 2013

The 2013 Housing Land Audit reports that development of site M1 is predicted to commence

in 2017 at a rate of 5 dwellinghouses per annum. The Masterplan for the site is at an advanced

stage and given the steady demand for residential properties in St Cyrus, the developer for

the site anticipates development commencing in 2015, at a rate of 15 units per annum.

As set out above, this is likely to be at a reduced capacity to that allocated in the 2012 LDP

(125 units over both phases of the LDP). At this rate the development of site M1 will be

completed before the end of phase 2, 2023. Land to accommodate additional development

should be allocated to ensure that there is adequate land for development in St Cyrus following

the completion of development at site M1.

Development of the site will be by a local developer, employing local tradesmen from the local

area. Continuation of a housing supply at St Cyrus is therefore necessary in order to meet all

three of the planning objectives for the settlement set out in the LDP:

• meet local housing need;

• sustain existing services and provide opportunity for new services; and

• provide opportunity for employment.

School Capacity

Aberdeenshire Council agreed a flexible approach to determining the capacity of primary

schools on their individual merits in May 2013; the revised capacity of St Cyrus Primary School

is 145 pupils, which corresponds with Scottish Office Education Department Circular 1029

recommendations for the maximum number of pupils permitted for 6no. teachers, the number

of teachers at the school at present1. Based on the physical capacity of teaching areas the

school has capacity to accommodate 163 pupils. Employment of an additional teacher would

be required to cater for this number of pupils.

1 http://www.snct.org.uk/library/1601/Primary%20School%20Staffing%20Formula%202013.pdf

In 2016, the anticipated year of adoption of the forthcoming LDP, the 2012-based school roll

forecast currently estimates that there is room for 18 pupils within the existing 145-pupil

capacity at St Cyrus; this increases to capacity to accommodate 25 pupils in 2018.

The 2012-based roll forecast includes the housing projections reported in the Housing Land

Audit, therefore development from the M1 site is included at a rate of 5 houses per annum

from 2017 onwards. At a build-rate of 15 houses per year, development from the M1 site will

only yield an additional 6 pupils per annum, based on the Council’s ratio of 0.4 pupils per

household for St Cyrus primary school. Based on the above, St Cyrus Primary School has

adequate capacity to accommodate further development within its existing and notional

capacity. If a requirement for additional education facilities identified, developer contributions

from the M1 and additionally allocated development will address this.

Justification

It is likely that site M1 will not be able to accommodate the full scale of its allocation for 125

units, with 25% of the site for employment/ retail uses. The Masterplan for the site is at a

finalised stage and is likely to be reported to the Kincardine & Mearns Area Committee for

approval in the second quarter of 2014. The Masterplan has been designed in accordance

with robust analysis of the achievable site capacity; and approval of the document will be

closely followed by an application for planning permission for the development of the site,

which will provide additional certainty regarding the amount of development that can be

accommodated on site M1 before the end of 2014.

Development of the site is likely to commence in 2015, at a rate of 15 units per annum; a rate

reflecting demand for development in the settlement. At this rate however, development of

the site will be complete before the end of phase 2. Land to accommodate further

development is therefore required to be allocated in the forthcoming LDP in order to provide

a continued land supply and meet the three planning objectives for the settlement, to meet

local housing need; sustain existing services and provide opportunity for new services; and

provide opportunity for employment.

As set out above, the sites to the north-east of Lochside Road and the south-west of the

A92/Lochside Road Junction and to the north-east of Scotston Cottages (appendix 1) are

ideally located to cater for this additional demand.

The land to the North-East of Lochside Road can be developed independently of site M1,

with existing footpath connections to the services within the settlement. Once complete,

pedestrian footways through the M1 site will also provide attractive alternative routes to the

local Primary School.

The land to the South-West of the A92/Lochside Road Junction

This site adjoins the south-eastern boundary of the M1 site, which is arbitrarily drawn and has

no physical features. It could be developed as a continuation of the M1 development, utilising

the pedestrian linkages through to the settlement and services at M1, which will be established

by that time.

Conclusion

The amount of development that will be delivered on the M1 site will be defined later this year,

however it is certain that the site will not be able to accommodate its full allocation of 125 units.

Based on the anticipated start date for development and rate of build, the development of the

M1 site will finish before the end of phase 2. On this basis it is necessary to allocate additional

land to accommodate residential development to meet local demand in the settlement, provide

continued employment for local tradesmen, to provide for and enhance local service provision

by growing the population at a sustainable rate, and to maintain the roll of St Cyrus Primary

School, which without development is predicted to fall sharply.

The sites to the north-east of Lochside Road and the south-west of the A92/Lochside Road

Junction are well-placed to accommodate future development, one as a standalone

development and the other as a natural extension of the M1 development.

In light of the foregoing it is requested that the sites to the north-east of Lochside Road and

the south-west of the A92/Lochside Road Junction, as identified on the plan at appendix 1 are

allocated to accommodate development in phase 2 of the LDP, 2017-2023.

Appendix 2: Extract from Aberdeenshire Local Plan (2006), Kincardine & Mearns – Rural Service Centres


Proposed Aberdeenshire Local Development

2016. If you are making comments about more

than one topic it would be very helpful if you


8th May 2015 at the following address:




Woodhill House

Westburn Road

ABERDEEN

AB16 5GB


Title

First name

Surname

Date

Postal Address

Postcode

Telephone Number

E-mail




YOUR DETAILS


Mrs

Claire

Coutts

7 May 2015

25 Albyn Place, Aberdeen

AB10 1YL

01224 588866

[email protected]

✔

✔

NHS Grampian

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

Reason for change

See attached Paper Apart

See attached Paper Apart

PAPER APART

REPRESENTATION TO THE PROPOSED LOCAL DEVELOPMENT PLAN ON BEHALF OF NHS GRAMPIAN

NHS Grampian is generally supportive of the spatial strategy proposed by the Plan and the recognition

of the importance of ensuring that adequate provision is made for healthcare facilities. Many existing

facilities are already pressured and are incapable of expansion to cater for new development. In these

instances, sites require to be identified and set aside for healthcare facilities and should have the

ability to accommodate 50% expansion in the future should it be necessary.


Through this representation, NHS Grampian suggests minor amendments to the Plan to increase

clarity to landowners and developers.

Reason for change

Background

NHS Grampian is the fourth largest Health Board in Scotland, consisting of three Community Health

and Social Care Partnerships – Aberdeen City, Aberdeenshire and Moray and an acute sector, all

supported by corporate services. NHS Grampian aims to deliver services as close to patient’s homes

as is clinically safe to do so. Services are provided in a range of community settings – work places,

people’s homes, in one of the GP Practices or Community Hospitals within their area. Highly

specialised care is delivered in the acute hospitals of Dr Gray’s in Elgin, Woodend and Aberdeen Royal

Infirmary. Royal Cornhill Hospital provides inpatient and community support for mental health

services. For women and children, specialist services are provided at Aberdeen Maternity Hospital

and the Sick Children’s Hospital.

NHS Grampian work closely with local authorities on the delivery of services and have agreed to set

up a joint board to manage integrated health and social care services. The ‘Health and Social Care

Integration’ service came into force in April 2015 creating a new entity to which NHS Grampian and

Aberdeenshire Council will delegate a number of services. The aim is to build upon positive

relationships to provide quality health and social care across Aberdeenshire.

The Main Issues Report (MIR) was published on 28th October 2013 and a representation to this was

submitted to Aberdeenshire Council on 31st January 2014 (Appendix 1). Some of these comments

have been taken on board which is welcomed, however, there remain some outstanding issues.

Green Networks

NHS Grampian is supportive of green networks due to the associated health and lifestyle benefits this

brings. There was concern that this may restrict the ability of existing healthcare sites to and it was

requested that consideration be given to the expansion requirements of healthcare facilities when

identifying and enhancing green networks. Policy R1 in Section 12 permits development in the green

belt where it involves the extension of an existing building or a use that is ancillary to the main use.

This is welcomed, however, it is argued that this specifically relates to housing and business

development. Healthcare sites should fall under this definition and this Policy should be amended to

reflect this.

Policy R1 goes on to state that “Development identified under the policy for safeguarding of resources

as required to meet an established need” is also permitted in the greenbelt, and it is assumed that

this relates to Section 17. Section 17 makes reference to the development of essential community

facilities which healthcare falls under, however, Policy R1 should be amended to make this clear.

There is no specific policy for safeguarding resources as required to meet “an established need” as

stated in section 12 and this also requires to be clarified.

Policy PR1 allows for development on protected land within settlements where it is an essential

community facility. It is requested that this policy is amended to specifically include healthcare sites.

For example, in Mintlaw, the existing practice requires to be extended to cope with the additional

patients expected by the significant development identified for the settlement. However, the practice

is surrounded by built development and protected land. This is such an instance where Policy PR1

must be relaxed to allow an extension to be built to meet the health care needs of the area.

Supporting Town Centres

NHS Grampian previously supported the MIR’s preferred approach to town centres. However, the

only policy related to town centres in the Proposed Plan is Policy B2: Town Centres and Office

Development. The Plan should be amended to cover all development in town centres, not just

business development.

Health Centres, due to their nature, bring significant footfall into town centres. This increase in footfall

not only benefits health related stores, but other retailers who can take advantage of the additional

footfall. The location of health centres in town centres would therefore enhance the vitality and

viability of town centres and recognition should be given to this use in these areas. Specific reference

to health centres should therefore be made in Appendix 2: Retail Centres.

Support should also be given to the continued presence of health centres in town centres and their

scope for expansion. Clearly there will be occasions where it will not be possible to extend in town

centres due to the constrained nature of sites. In these instances, should a health centre require to

move outwith the town centre, the redundant site should be identified as an opportunity site. Policy

P5 in Section 14 recognises that where existing community facilities within settlements have become

surplus to requirements, proposals for their reuse or redevelopment will be approved subject to

compliance with other policies. This is welcomed, however, the text should be amended to include

specific reference to healthcare facilities. Where health centres require to locate outwith the town

centre, they should be in locations which remain accessible by a variety of modes of transport,

preferably on a main transport corridor.

Rural Development

Section 12 deals with rural development and comments have been provided to this above. However,

this section does not go far enough in specifying that rural development should be easily accessible

by public transport and linked to health centres. Rural development that is not accessed by public

transport and is remote from healthcare provision has a detrimental impact on healthcare services

and places an additional, unnecessary burden on them.

Policy P1 in Section 14, requires development to demonstrate the six qualities of successful places.

This includes being “well connected to create well connected places that promote intermodal shifts

and active travel”. This is welcomed, however, reference should be made to this policy within Section

12 to make it clear that development in rural areas has to comply with this.

Through the MIR representation it was advised that the cumulative impact of rural development must

be considered to ensure there is no adverse impact on healthcare services which may be

oversubscribed. Contributions should be sought to mitigate the impacts directly arising as a

consequence of that development in accordance with Circular 3/2012. It is welcomed that the

settlement statements make specific reference to contributions to health care facilities where

required.

Housing for People on Modest Incomes

NHS Grampian supports the development of balanced communities which have a mix of house types

and tenures. The 25% affordable housing requirement in Policy H1 is welcomed. Support is also given

to Policy H3 which supports housing proposals for the elderly or those with special support needs. It

is suggested that the proximity to health centres should also be referenced as well as easy access to

public transport, local services and public open space.

Carbon Neutrality in New Developments

It was argued in the MIR representation that NHS Grampian struggle to deliver buildings, due to the

level and type of care that they provide, which meet the standards required by SG LSD11: Carbon

Neutrality in New Development. It was suggested that an exception is added to this which would

exclude specialist buildings where it could be demonstrated that targets could not be met.

The response from Aberdeenshire Council was that the SDP recommends alignment with the Building

Standards Sustainability Labelling Scheme, which does not exempt specialist facilities such as health

centres. Objection is therefore made to the failure of the Plan to exclude specialist buildings from

meeting the standards where this can be justified. As such, Section 18: Climate Change should be

amended to reflect this.

Land Supply and Distribution

The levels of development proposed in the extant Plan will require considerable investment in

healthcare facilities to maintain high levels of service for an increasing, and ageing, population.

Suitable sites within growth areas and in the centre of new and expanding communities require to be

identified at an early stage, to ensure the physical infrastructure is adequate to meet existing and

future demands, but also that the human resources are available to efficiently operate new facilities.

NHS Grampian would wish to continue to be consulted in Masterplanning exercises especially where

there is a requirement for healthcare sites.

Although it is welcomed that the healthcare requirements of each location is listed within the

settlement statements, suitable sites should also be identified on the proposals map where

appropriate. NHS Grampian would specifically request that the proposed new health centre at

Inverurie Hospital is identified on the Inverurie Proposals Map. It is also questioned why the entire

extent of the Ellon Academy site is not included within the OP2 site. It is acknowledged that some

existing facilities will be expanded, however, the location of these should also be identified on the

map.

Settlement and Site Specific

Objection was previously made in relation of the failure of the MIR to identify settlement specific

healthcare requirements in the settlement statements. This has now been included in the Proposed

Plan in the majority of instances and this is supported. However, some outstanding settlement

statements require amendment, including:

Banff & Buchan

Aberchirder – The settlement statement requires contributions to the extension of the existing

medical practice. However, this should be amended to state that contributions are required for “a

new 3GP Health Centre”.

Banff & Macduff – Although a replacement health centre is required at Macduff, reference should

also be made to the need for additional land to deliver this.

Rathen – Reference to the Crimmond practice should be removed.

Buchan

Maud – The Maud Hospital site should be identified as an opportunity site for development. This

would include a parcel of land to the south which is also in NHS Grampian’s ownership.

Peterhead – Land is required in Peterhead for a new health centre and the requirement that “all

development must contribute towards a new health centre in Peterhead” is welcomed. Allocated Site

OP1, Inverugie Meadows, notes that provision of land for a health centre “may be required”.

However, given the pressure for such a facility, this should be amended to “is required”.

Formartine

Udny Station – There is no reference to healthcare contributions. This should be amended and

contributions should go towards health care provision at Balmedie.

Garioch

Cluny and Sauchen – There is no reference to healthcare contributions. This should be amended and

contributions should go towards healthcare provision at Kemnay.

Millbank – There is no reference to healthcare contributions. This should be amended and

contributions should go towards Alford Medical Practice.

Kincardine and Mearns

Kirkton of Maryculter – There is no reference to healthcare contributions. This should be amended

and contributions should go towards Peterculter Health Centre.

Marr

Lumphanan – There is no reference to healthcare contributions. This should be amended and

contributions should go to Torphins Health and Resource Centre.

Tarland – There is no reference to healthcare contributions. This should be amended and

contributions should go towards Aboyne.

NHS Grampian reaffirm their commitment to work with Aberdeenshire Council to identify the

healthcare requirements arising from the preferred development strategy through their involvement

with the FIRS Group. It is also important to recognise that NHS Grampian also covers Aberdeen City

Council’s administrative areas and in certain circumstances there may be cross border issues which

require to be addressed.

Conclusion

The majority of issues raised in the MIR representation have been carried forward into the Proposed

Plan. However, it is considered that there are still some areas of concern in relation to health care

sites and the interests of NHS Grampian which require to be taken into consideration in taking the

Plan forward.

Recommendation

It is therefore respectfully requested that the specific changes requested by NHS Grampian are carried

forward in the Local Development Plan.

Appendix 1

PROPOSED ABERDEENSHIRE LOCAL DEVELOPMENT PLAN

APPENDIX 2: MIR REPRESENTATION

Paper Apart

Representations to the Main Issues Report on behalf of NHS Grampian

Introduction

NHS Grampian welcomes the opportunity to submit representations on the Aberdeenshire Council’s

Local Development Plan 2016 Main Issues Report. It is generally supportive of the spatial strategy

proposed by the Plan, but wishes to emphasise the importance of ensuring that adequate provision is

made for healthcare facilities to serve new development. Many existing facilities are already pressured

and are incapable of expansion to cater for new development. In those instances sites require to be

identified and set aside for healthcare facilities. Those sites should have the ability to accommodate

50% expansion in the future should it become necessary.

To achieve this, NHS Grampian are committed to working with the Future Infrastructure Requirements

for Services (FIRS) Group to continue to identify areas where new or improved facilities are required.

NHS Grampian have previously advised of the healthcare requirements for Aberdeenshire and a copy

of the requirements is appended to this representation.

Background

NHS Grampian is the fourth largest Health Board in Scotland, consisting of three Community Health

Partnerships – Aberdeen City, Aberdeenshire and Moray and an acute sector, all supported by

corporate services. NHS Grampian aims to deliver services as close to patients’ homes as it is clinically

safe to do so. Services are provided in a range of community settings – work places, peoples’ homes,

in one of the GP Practices or Community Hospitals within their area. Highly specialised care is delivered

in the acute hospitals of Dr Gray’s in Elgin, Woodend and Aberdeen Royal Infirmary. Royal Cornhill

Hospital provides inpatient and community support for mental health services. For women and children,

specialist services are provided at Aberdeen Maternity Hospital and the Sick Children’s Hospital.

NHS Grampian also work closely with local authorities on the delivery of services and have agreed to

set up a joint board to manage the integrated health and social care services in Aberdeenshire. The

‘Health and Social Care Integration’ service will come into force in April 2015 creating a new entity to

which NHS Grampian and Aberdeenshire Council will delegate a number of services. The aim of the

new venture is to build upon the positive relationships already in place to provide quality health and

social care across Aberdeenshire.

Main Issue 2 – Green Networks

NHS Grampian is supportive of the preferred option proposed by the MIR ‘to promote the creation of

green networks within and between settlements’ due to the associated health and lifestyle benefits.

However, it should be recognised that existing healthcare sites may need to expand in the future and

as a result consideration should be given to the expansion requirements of healthcare facilities when

identifying and enhancing green networks.



Main Issue 3 – Supporting Town Centres

Support is given to the MIR’s preferred approach to town centres. Where health centres are located in

town centres support should be given to their continued presence and scope for expansion. Health

Centres must be accessible to all and town centres tend to be the main focus of public transport

services. Also health centres, due to their nature, bring significant footfall into town centres. This

increase in footfall not only benefits health related stores, such as pharmacy’s, but other retailers who

can take advantage of the additional footfall. The location of health centres in town centres would

therefore enhance the vitality and viability of town centres.

Clearly there are instances where it will not be possible to extend in town centres due to the constrained

nature of the sites. In these instances should a health centre require to move outwith the town centre,

the redundant site should be identified as an opportunity site suitable for development.

Where health centres require to locate outwith the town centre they should be in locations which remain

accessible by a variety of modes of transport, preferably on a main transport corridor.

Main Issue 4 – Rural Development

NHS Grampian is broadly supportive of Aberdeenshire Council’s position on rural development. NHS

Grampian would highlight that proposals for rural development should be easily accessible by public

transport and linked to health centres. Rural development that is not accessed by public transport and

is remote from health care provision has a detrimental impact on health care services and places an

additional, unnecessary burden on them.

The cumulative impact of rural development must also be considered to ensure it does not adversely

impact on health care services which may already be oversubscribed. In such instances developer

contributions should be sought to mitigate the impacts arising directly as a consequence of that

development.

Main Issue 7 – Housing for People on Modest Incomes

NHS Grampian supports the development of balanced communities which have a mix of house types

and tenures. The approach adopted by the MIR spreads the burden experienced by health care

services who experience an increased demand for services in areas where there is a high proportion

of elderly or properties in public services tenure.

Issue 9 – Carbon Neutrality in New Developments

Due to the nature of health care facilities a number of services are specialised and require specialised

buildings, exclusively tailored for the needs of that specific service provider ie air conditioning/



ventilation, specialised lighting and higher temperatures for medical examination areas. NHS Grampian

struggle to deliver buildings, due to the level and type of care they provide, which meet the standards

required by policy SG LSD11: Carbon neutrality in new development. It is suggested that a further

exception is added to SG LSD11: Carbon neutrality in new development which would exclude specialist

buildings where it could be demonstrated that targets could not be met.

Main Issue 12 – Land Supply and Distribution

Whilst NHS Grampian is broadly supportive of the spatial strategy, the levels of development proposed

in the extant Plan and any further development identified in the proposed Aberdeenshire Local

Development Plan 2016 will require considerable investment in healthcare facilities, in order to maintain

high levels of service for an increasing, and ageing, population. Suitable sites within growth areas and

in the centre of new and expanding communities will require to be identified at an early stage, in order

to ensure that not only is the physical infrastructure (roads, premises etc) adequate to meet existing

and future demands, but that manpower issues and human resources are available in these areas to

efficiently operate new facilities. Suitable sites should be located centrally to the community to which it

serves, visible, accessible and where public transport exists within that community, the site should be

well served by that public transport.

Health care provision is a fundamental requirement for the long term health and well being of a

community. As such, it requires to be central to that community and accessible to all. The proposed

Aberdeenshire Local Development Plan 2016 requires to recognise the importance of healthcare and

should identify it as a fundamental component of a community, similar to education and community

facilities. Accordingly it should be listed in the Key Planning Objectives for Settlements.

Settlement and Site Specific

It is noted that in assessing the submitted Development Bids and identifying Officers preferred sites for

development that infrastructure requirements was a consideration. However, concern must be

expressed of the failure of the Main Issues Report (MIR) to identify settlement specific healthcare

requirements in the Key Planning Settlement Objectives section of the settlement statements. It is

respectfully requested that settlement statements are amended accordingly to reflect discussions

previously held with NHS Grampian at meetings with the Future Infrastructure Requirements for

Services Group (FIRS Group) which identified health care requirements on a settlement by settlement

basis. As highlighted above, a list of these requirements are appended to this representation.

NHS Grampian would reaffirm their commitment to work with Aberdeenshire Council to identify the

healthcare requirements arising from the preferred development strategy through their involvement with

the FIRS Group. It is also important to recognise that as NHS Grampian also covers Aberdeen City

Council’s administrative area and in certain instances there may be cross-border issues which require



to be addressed. The provision of facilities in Aberdeenshire may also serve areas lying within

Aberdeen city and vice versa.

In light of the aforementioned, it is respectfully requested that healthcare requirements are clearly listed

in the Key Planning Objectives for settlements in the settlement statement section of the proposed

Aberdeenshire Local Development Plan 2016.





Title

First name

Surname

Date

Postal Address

Postcode

Telephone Number

E-mail




YOUR DETAILS


low. Please feel free to add any extra pages you

deenshire Council’s

MR

MICHAEL

LORIMER

8.5.15

RYDEN LLP, 25 ALBYN PLACE, ABERDEEN

AB10 1YL

01224 588866

[email protected]

✔

✔

SANDLAW FARMING COMPANY LTD

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]

1

PAPER APART

Representation to the Proposed Aberdeenshire Local Development Plan 2016 on behalf of

Sandlaw Farming Co Ltd.

Land at Braehead Farm, Auchattie, Banchory.

Introduction

Objection is made to the Proposed Aberdeenshire Local Development Plan 2016 (PLDP), which has

failed to identify land at previously identified as site “MA016” within the published Main Issues Report,

for residential development at Braehead, Auchattie, Banchory. The PLDP should identify this land for a

residential development of 400 new homes to coincide with an application for Planning Permission in

Principle (PPiP) which is currently pending with Aberdeenshire Council under APP/2015/0225, seeking

permission for 300 homes for private rent, as well as 75 affordable and 25 homes for assisted living.

The site is considered an appropriate expansion to the existing settlement of Banchory, within easy

walking distance of a diverse range of services central to the town. This objection should be considered

in conjunction with the Development Bid (Appendix 1) for the promotion of the land at Braehead

submitted in April 2013 as well as the further representation to the Main Issues Report, submitted in

January 2014 (Appendix 2) and MIR Addendum in September 2014 (Appendix 3) with particular

emphasis placed on housing land supply.

A significant level of supporting information has been submitted in respect of the pending PPiP

application including an Environmental Impact Assessment, Landscape and Visual Impact Assessment

and a Transport Assessment. These documents have been subject to significant scrutiny by both

Statutory and Non-Statutory Consultees and demonstrate that the proposed development could be

adequately accessed and serviced, would be contained within the existing landscape and surrounding

mature trees, thus resulting in no overriding detriment to the quality of the surrounding environment, as

has previously been suggested at MIR stage of the LDP Review process. The PPiP application has

also been subject to robust public consultation and the proposals modified to form a development of

purely private rented and affordable units on the basis of the feedback received.

Objection is also made to the failure of the PLDP to recognise the need for Private Rented Sector (PRS)

housing within the overall housing supply or account for it within its proposed policies.


Table 7 of Appendix 5 ‘New Housing Land Allocations’ should be modified to include a new

allocation for 400 residential units at Braehead, Banchory for delivery in the period 2017-2026.

The allocation should also be included within the associated PLDP Settlement Statement and

map for Banchory.

2

In addition, Section 13 of the “Shaping Homes and Housing” should be modified to contain specific local

policy in respect of Private Rented Sector housing, in addition to proposed policies H1 housing land,

H2 Affordable housing and H3 Special Needs Housing, in order to provide greater flexibility to enable

private rented housing on suitable sites, such as Braehead, where it meets local demand.

Reason for change

Background

This representation should be read in conjunction with the previous Development Bid submitted in April

2013 (Appendix 1) requesting consideration of land at Braehead for a residential allocation within the

new Aberdeenshire LDP. The Main Issues Report was published on 28th October 2013, which identified

the site as MA016. The MIR failed to include the site as an ‘Officer’s Recommendation’ stating scale,

separation from the main town, perceived infrastructure and traffic issues and also perceived landscape

impacts. Representation to the MIR was submitted in January 2014 (Appendix 2) Objecting to the

assumptions made within the MIR. In addition a further representation was submitted in September

2014, raising further concerns, primarily relating to land supply calculations (Appendix 3). Despite

continued promotion of the site and representations submitted at each appropriate stage, the PLDP has

failed to include the land at Braehead for development.

Outdated Population and Household Projections

Sandlaw Farming Co maintain their concerns previously set out in their representation to the MIR

(Appendix 2), with the Council’s approach to the allocation of land for housing development. The PLDP

is in line with Schedule 1 of the Adopted SDP, which simply rolls forward housing allocations formulated

by the previous Structure Plan and extends the time horizon of the plan to 2035. SPP requires plans to

be “up-to-date and relevant”, however the previous Structure Plan was based on 2008 population

projections, which have been superseded by more recent and accurate projections carried out in 2010

and 2012. As such, Sandlaw Farming would stress that paragraph 113 of SPP which requires HNDA’s

used to inform the local housing strategies and development plans to be “robust and credible”, is clearly

not the case for the PLDP as it is based on information carried out 7 years ago to plan for a period 13

years in the future. Detailed assessment of the most recent 2012-based projections suggest a

discrepancy of some 73,000 people at the end of the plan period, 37,000 of which would be apportioned

to the Shire. Sandlaw Farming Co therefore maintain their strong opposition to the reliance on outdated

information, carried out in 2008, to inform housing allocations for a LDP due for adoption in 2017.

Household projections, derived from the outdated 2008 population projections were compiled against a

backdrop of economic uncertainty and downturn in the housebuilding industry. Projections carried out

in 2010 and published in 2012, predicted a significant increase in household formation. These have

subsequently been updated again in 2012 (published in July 2014) and are slightly lower than the 2010

based projections and this has formed the basis of not increasing housing allowances in the Reporter’s

3

examination into the now approved SDP and also cited in the MIR Addendum for not increasing housing

allocations.

Substantial reliance is placed on a post-5 year effective land supply of 20,283 homes which have been

identified in the AHMA. Proportionately however, if effective land is to be the same between the City

and Shire as the allowances detailed in the SDP, this equates to a shortfall of over 2,800 homes in the

Shire part of the AHMA in the post 5 year supply. Overreliance on large scale sites with significant

infrastructure requirements in order to satisfy land supply, poses significant risks to achieving an

effective supply. Therefore further sites such as Braehead, which is capable of delivery in the short

term, should be accommodated within the PLDP to ensure an effective supply is achieved at all times

and within the 5 year supply and beyond in accordance with SPP.

Delivery of Private Rented Accommodation

The Scottish Government Strategy, “A place to Stay, A place to Call Home”, sets out the Government’s

vision and strategic aims for the Private Rented Sector (PRS). It requires local authorities to plan for

private rented housing in the overall housing supply and for this to be reflected and integrated into local

housing strategies. It also stipulates that local authorities need to exercise a degree of flexibility in the

planning process to stimulate and manage institutional investment in the PRS. To date, Aberdeenshire

Council has failed to accommodate the PRS into the LDP process, which is evidenced in the PLDP’s

silence on the matter. This is despite Sandlaw Farming Co’s previous detailed representations to the

MIR and subsequent MIR Addendum (Appendices 2 & 3) which highlight this issue extensively.

Evidence gathered from two consecutive days of public consultation in August 2014 showed

considerable interest and support for Private Rented housing in Banchory, to help accommodate local

people and bridge a much needed gap between standard affordable housing and homes for sale on the

open market. Evidence suggests that a growing number of families are being forced to leave the

Banchory area due to over inflated house prices and also their failure to qualify for affordable housing

criteria set out by Aberdeenshire Council.

Accordingly, the PLDP should meet the needs of the entire community and address a lack of supply of

private rented housing options. Presently it fails to account for this, therefore Section 13 of the “Shaping

Homes and Housing” should be modified to contain specific local policy in respect of PRS housing,

which will facilitate a more inclusive range of housing tenures, in addition to affordable and assisted

living accommodation.

Perceived Impacts

Since the earlier Development Bid submission and subsequent Representations (Appendices 2 & 3) to

the MIR and MIR Addendum, a planning application has been submitted for 400 units on site, 300 of

which are for private rent, 75 affordable and 25 assisted living units. An indicative Masterplan has also

4

been submitted to supplement the application as well as a substantial number of supporting documents

which demonstrate how the site will be delivered, the associated impacts posed to the surrounding

environment and existing infrastructure arrangements. These have aimed to tackle a number of

unsubstantiated claims which been made regarding the scale of the development at Braehead,

landscape & environmental impact, perceived disconnect from Banchory as well as potential

overloading on existing infrastructure and transport networks, throughout the LDP review Process to

date. Reports include;

Environmental Impact Assessment

Landscape and Visual Impact Assessment

Transportation Assessment

Drainage Assessment

Ecology Assessment

This information has been subject to significant scrutiny by consultees and Sandlaw Farming Co would

respectfully request that it is taken into consideration and read in conjunction with this representation.

Development in this location is supported by current Scottish Planning Policy, which states that new

allocations within more accessible rural areas should be located adjacent to settlements. Therefore

Braehead offers a logical area for the expansion of Banchory; it is close to the existing settlement

boundary and is within easy walking distance of a diverse and vibrant range of services within the centre

of the town. This is reflected in the Council’s Transportation Service consultation response to the PPiP

application, which highlights the centre of the site is within 1000m of Banchory Town Centre providing

good accessibility. Transportation is also content with the sites connectivity to surrounding schools.

Previous suggestions during the LDP review process that the site “does not relate to the existing town”

is clearly contradictory, unwarranted and strongly refuted.

Sandlaw Farming would therefore maintain that the proximity of the Braehead site to the heart of the

town offers outstanding potential to counter-balance the eastward-stretching corridor of housing and

commercial development that has taken place in recent years in Banchory, with current PLDP

allocations now approaching 2-3km from the town centre. The entire Braehead site is however is within

1600m of local services and within 400m of bus stops as stipulated in Planning Advice Note 45: Planning

for Transport. The site clearly relates to the existing town and will be much less car dependant than

conflicting developments to the north east. Scottish Planning Policy supports a pattern of development

which limits the need for car based-travel and supports a range of travel options.

Sandlaw Farming Co recognise the sensitivity of the surrounding environment and in particular the River

Dee SAC. A robust assessment of any potential environmental and ecological impacts has been carried

out within the Environmental Impact Assessment which has been submitted in support of the PPiP

application. The Environmental Statement has brought together survey and analysis work carried out

5

in relation to the proposed development and assessed, under a series of technical headings, the

potential impacts on the environment that could be caused by the development and demonstrates that:

There are no significant environmental, ecological or landscape impacts which could not be

reduced through appropriately conditioned mitigating measures; and

The residual impacts are not significant

Furthermore SNH, who’s statutory duty it is to assess such information, has no objection to the

proposed development subject to standard conditions. Likewise Historic Scotland are content as

Statutory Consultee that there would be no impacts on nationally important heritage interests. SEPA

are also content with the foul and surface water drainage proposals for the site, subject to appropriate

conditions and they are satisfied that there would be no flood risk posed.

As has been previously highlighted in the attached MIR representation (Appendix 2), the Braehead

development proposes re-routing the B974 through the site, providing a safer and more direct gateway

to Banchory town centre from the south. Detailed traffic modelling has been provided within a Transport

Assessment in support of the PPiP application with appropriate mitigation to accommodate the

proposals. Positive discussions with the Councils Roads Development and Transportation Service are

ongoing with a view to concluding an agreeable technical solution, prior to determination.

Suggestion that the development would pose a detrimental impact on existing education provision is

also uncorroborated. Sandlaw Farming Co have been in positive discussions with the Council's Developer

Obligations Team, who have sought appropriate contributions to mitigate the impact of the proposed

development on surrounding Schools, seeking a financial contribution be made towards alleviating the

capacity issue at Banchory Academy, which would be put towards the provision of a new extension. These

contributions have been agreed and would form part of a suitable S75 agreement, should permission be

granted.

CONCLUSION

The above challenges to the PLDP, coupled with the previously submitted Development Bid, and

representations to the MIR and MIR addendum highlight:

Sandlaw Farming’s intention is to create a high quality development, with a diverse housing

mix, with a focus on homes for private rent to meet acute demand as demonstrated through

submission of the PPiP application APP/2015/0225.

Development in this location is supported by Scottish Planning Policy, which states that new

allocations within more accessible rural areas should be located adjacent to settlements.

The proposed development is integrated into the landscape and topography with a sympathetic,

contained layout and design as demonstrated within the robust supporting information

6

submitted with the PPiP application which has been subject to extensive scrutiny and found to

be acceptable by statutory consultees.

The site is effective, has no infrastructure constraint and seeks to address an evident shortfall

in housing supply given outdated population and household projections which have formed the

basis of the SDP and, consequently, the PLDP’s land supply recommendations.

On the basis of the foregoing, we respectfully request that land at Braehead, Banchory is

allocated in the new LDP and appropriate policy provision for the PRS is also incorporated

within the associated policy section of the new LDP.





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Page 2

• Be consistent with the policies set out in the SPP including the presumption in favour of development that contributes to sustainable development;

• Positively seek opportunities to meet the development needs of the plan area in a way which is flexible enough to adapt to changing circumstances over time;

• Set out a spatial strategy which is both sustainable and deliverable. A key aims of the document is to “direct the right development to the right place” which should be achieved by:

• optimising the use of existing resources; • considering the re-use or re-development of Brownfield land before new development takes

place on Greenfield sites. With regard to Enabling Delivery of New Homes, the SPP sets out that the planning system should:

• identify a generous supply of land for each housing market area within the plan area to support the achievement of the housing land requirement across all tenures;

• maintain at least a 5 year supply of effective land at all times. Emerging Local Development Plan There are a number of relevant policies contained within the emerging Local Development Plan. Policy B3 – Tourist Facilities, sets out that: We will support the development of new tourist facilities or accommodation that are well related to settlements and deliver net economic and social benefits....we will protect existing tourist sites from being converted to other uses unless there is evidence that the business has been marketed for at least 12 months including in the local area and is no longer viable. We consider that the need to protect viable tourist sites needs to be balanced against the need to deliver housing and that there will be circumstances, such as with Silverbank where the need to protect viable sites has to be set against the potential to delivery much needed housing. Policy H1 - Housing Land sets out that: We will support the development of housing on sites allocated of that purpose within the local development plan and settlement statements. Section 10 of the emerging Local Plan relates to “Shaping Marr” and in relation to Banchory the plan states that “Banchory is an important town in the are which can accept significant development”. Settlement Statement – Banchory This statement relates specifically to Banchory. The settlement is described is a “thriving town, popular with commuters and tourists”. The settlement is in close proximity to Aberdeen City and has a range if shops and community facilities. It is stated that “the scale of new development has to balance demand for housing in the area with the needs of the community”. Housing Allocation in Banchory The following sites are identified as allocations for development in Banchory:

• OP1 (M1) – East Banchory/Eco Village – Allocation for mixed uses including a 30 homes • OP2 (M2) – Hill of Banchory – Allocation for a mix of uses including up to 345 homes • OP3 (H2) – Hill of banchory – allocation of up to 50 homes • OP4 (H1) – Hill of Banchory – Allocation for up to 15 homes

All of these sites were originally allocated in the 2012 Local Development Framework and none have as of yet been substantially built out with some currently not benefitting from planning permission. The draft Housing Land Audit sets out on these allocated sites only 184 out of 440 housing units will be completed in the next 5 years.

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Enc. Site Location Plan Site Block Plan Representation Forms

Documents

YOUR DETAILS · 4 Development Plan identified sites to accommodate 4,751 units (Appendix 5, Table 1), yet only 1,451 units are expected to be delivered by the end of 2016 (Appendix