013 Main Issue 12 - Land Supply and Distribution

Response ID Respondent Response ID Respondent

15 Mr Richard Morris 1416 Scottish Property Federation 67 Mr W.J. & S.J. McCafferty 1418 Burness Paull on behalf of Iain Adams 76 Dr. Edward Hugh Morel 1420 Bancon Developments 83 Ryden LLP on behalf of 1426 Knight Frank LLP on Fotheringham Property behalf of Colaren Developments Limited Properties 84 Ryden LLP on behalf of 1432 Knight Frank on behalf of Fotheringham Property Colaren Properties Developments Limited 85 Ryden LLP on behalf of Mrs L 1434 Crathes, & Pirie Durris Community Council 87 Ryden LLP on behalf of Mr 1436 Mr Robin Patterson John Farquharson 102 Ryden LLP on behalf of Mr M. 1443 North Kincardine Rural Mountford & Mr I. Mathers Community Council 111 Echt & Skene Community 1445 Ms Christine Mechie Council 130 Birse and Ballogie Community 1458 Halliday Fraser Munro on Council behalf of CALA Homes Ltd 155 Mr John Paul Smith 1462 David Murray Associates 415 & District 1465 Bancon Developments Community Council 430 Mr Martin Patrick 1467 Development Trust 477 Mr Kenneth Phin 1472 Halliday Fraser Munro on behalf of Harper & Cochrane LTD 562 Mr Edward Valentine 1477 Community Council 572 Ryden LLP on behalf of Mr R. 1486 David Murray Associates Thorne 576 Gladman Developments 1488 David Murray Associates 605 Mrs Elisabeth Ritchie 1515 Halliday Fraser Munro on behalf of Strathdee Properties Ltd

Page 1 of 14 632 Deveron Homes Ltd & 1519 Halliday Fraser Munro on Housing behalf of ANM Group Ltd Partnership 640 Taylor Wimpey 1521 Mr Scott Leitch 693 Mr John Forbes 1522 Bancon Developments 720 Mr Alan Dick 1525 Graham & Sibbald on behalf of Crerar Hotels 748 Mr and Mrs Graham & 1529 Halliday Fraser Munro on Elisabeth Brown behalf of The Blackburn Consortium 755 Ryden on behalf of 1530 Halliday Fraser Munro on Drumrossie Land behalf of ARD Properties Development Co Ltd Ltd 797 Mr David Dix 1532 Ms Mary Scott 806 Mr Robert Bamlett 1539 Stewart Milne Group on behalf of Stewart Milne Homes 830 Ryden LLP on behalf of 1541 Halliday Fraser Munro on Drumrossie Land behalf of Mr J Forbes Development Company LTD 858 Ryden LLP on behalf of 1557 Scottish Enterprise Riveroak Properties Ltd 861 Knight Frank LLP on behalf of 1558 John Halkett Mr Thomson, Castleglen Properties & Tor Ecosse Ltd 867 Ryden LLP on behalf of 1559 Bancon Developments Graham Homes Limited 891 Mr Colin Green 1560 David McDonald 924 Mr Richard Orren 1563 Ryden LLP on behalf of Stewart Milne Homes 928 Gourdon Community Council 1577 Mr Robin Davies 930 Laurence McMahon 1584 Inverurie Business Association 938 Dr. Sheila & Marcus Marsh 1588 Burness Paull on behalf of South Fornet Estates Limited 956 , & Dunnotar 1595 Mrs Mary Murray Community Council 1012 R.V. Armstrong 1597 Mr Trevor Hodgson 1038 Ryden LLP on behalf of 1605 Mr Nick Carroll Cabardunn Development Company Ltd. 1070 Ryden LLP on behalf of Ms 1606 Halliday Fraser Munro on

Page 2 of 14 Jennifer Watt & Mr Alan behalf of Mr J McIntosh MacDonald 1078 Knight Frank on behalf of Mr 1607 Halliday Fraser Munro on Duff behalf of Mr J McIntosh 1089 Knight Frank on behalf of Mr 1610 Halliday Fraser Munro on Mackie behalf of Mr & Mrs Howie and Mr & Mrs Brownie 1106 Ms Cara Campbell 1611 Bancon Developments on behalf of DLD Associates 1107 Ms Sarah Campbell 1612 Halliday Fraser Munro on behalf of Mr & Ms Gilbert 1108 Ms Helen Campbell 1632 Inverurie Business Association 1109 Ms Ian Campbell 1633 D. Fairlie Partnership 1122 Ms Anne Mansfield 1634 Colliers on behalf of Kilbride Resources Limited 1124 Burness Paull LLP on behalf 1636 Ryden LLP on behalf of of Alan & Ian Buchan A. Rhind & S. Wilson 1125 David Wardrop Planning 1637 Ryden LLP on behalf of Consultant on behalf of A. Rhind & S. Wilson Strategic Land (Scotland) Ltd 1135 Aberdeenshire Council 1640 Keppie Design on behalf Housing and Social Work of Stewart Milne Homes 1149 Bancon Developments 1650 Homes for Scotland 1157 Stewart Milne Homes 1651 Case Consulting 1164 Bancon Developments 1656 Strutt & Parker on behalf of The Endowments Trust 1194 David McDonald 1661 Case Consulting on behalf of Site Owner 1196 John Halkett 1666 Ryden LLP on behalf of Kirkwood Homes Ltd 1216 William Lippe Architects on 1669 Knight Frank on behalf of behalf of Hamish Mcdonald Gladedale Estates in conjunction with Bett Homes 1225 Aberdeenshire Council 1670 Ryden on behalf of Mr & Economic Development Mrs Buchan 1235 Ms Rachel Shanks 1675 Ms Ruth Taylor 1302 Mr Nigel Griffiths 1676 Mr Miachael Rose 1317 Barratt Homes on behalf of 1687 Ryden LLP on behalf of

Page 3 of 14 Barratt North Scotland NHs Grampian 1349 Halliday Fraser Munro on 1688 Kilbride Resources behalf of Kincluny Limited Development Trust

1350 Bancon Developments 1694 Knight Frank on behalf of Kirkwood Homes Limited 1355 Aberdeen & Grampian 1702 Burness Paull LLP on Chamber of Commerce behalf of Alan Buchan & Ian Buchan

1358 Bancon Developments 1706 G.H. D. Sommerville

1360 Community Council 1708 Case Consulting Limited

1361 Bancon Developments 1721 Emac Planning on behalf of Medlock & Medlock 1362 Bancon Developments 1725 Emac Planning on behalf of Polmuir Properties () Limited & Apex trust company

1366 Ryden LLP on behalf of 1730 Castleglen Properties Stewart Milne Homes Limited (Aberdeen) LTD on behalf of RAM Tubulars

Scotland LTD

1371 Halliday Fraser Munro 1747 Mitchells Planning on behalf of Barratt North Scotland & Drum Property Group

1380 John Handley Associates Ltd 1806 David James-Duff

1381 Bancon Developments Ltd 1811 Scottish Government

1400 Halliday Fraser Munro on 1815 Mr Stuart Rennie behalf of Cushnie Farming Company 1409 Ryden LLP on behalf of 1825 ACSEF Sandlaw Farming Co Ltd

1. Issues There was a mixed response to the issue of land supply and distribution, with some respondents expressing support for the preferred option of not allocating additional land for development in the 2016 LDP and others expressing the view that further land must be allocated for both housing and employment purposes. Support for Preferred Option A number of respondents expressed specific support for the preferred option. These respondents generally considered that the allocations in the 2012 LDP were sufficient to meet needs over the period of the 2016 LDP, and that there was therefore no reason to allocate additional land (15, 67, 76, 111, 415, 605, 748, 797, 891, 924, 928, 930, 928, 930, 938, 1012, 1106, 1107, 1108, 1109, 1122, 1235, 1302, 1360, 1418, 1434, 1436, 1443, 1445, 1532, 1577, 1595, 1605, 1675, 1676, 1706, 1815, 1825). One respondent noted the existing supply of

Page 4 of 14 unused employment land as an argument no more was required to be allocated (928), whilst another considered there to be no logic in destroying the rural character of small hamlets though suburban housing development (130). Concerns were also raised that housing completions in Aberdeenshire are continuing to outstrip completions in the City, and that the allocation of more greenfield sites in the Shire would not help to address this imbalance (1235, 1532, 1605). A number of respondents went on to express the view that no further housing development was required in specific areas, including Banchory (1418, 1577, 1825), (797, 1595, 1676, 1815), Kincardine & Mearns (748, 1106, 1107, 1108, 1109, 1302), North Kincardineshie (1443, 1706), Portlethen and vicinity (415), Rathen (930), and vicinity (76, 1012), and (891). Some comments expressed support for the preferred option subject to specific exceptions, with one expressing support for new development to support the sub-sea sector in Westhill (1360) and another requesting the allocation of a single site in Macduff for housing (1135). A number of respondents considered there to be no requirement to add to the existing housing land supply, but felt that employment land should be provided on brownfield sites, and sites within or near to settlements, to increase local employment opportunities and reduce commuting (1436, 1467, 1597) The Scottish Government acknowledged that neither new housing nor employment land allocations are likely to be required and stated agreement with the principles of this approach (1811). Respondents also commented on the continuing need for facilities and services within the 2012 LDP allocations (1122), with one comment stating that the current need for healthcare facilities should be specifically identified within settlement statements and provided the necessary details (1687). One respondent notes that greenfield sites could be used for a range of purposes with potentially more value than the orthodox understanding of development, when considered for the ecosystem services or natural capacity they provide (1225). Support for Reasonable Alternative A number of respondents objected to the MIR’s statement that there is no reasonable alternative option in respect of land supply (1157, 1366, 1650), and a significant number provided reasons for increasing the land supply by allocating additional sites. The main reasons that were put forward for allocating additional land include: Objections to SDP Allowances / Household Projections A number of respondents noted that the housing allowances in the SDP have been subject to significant objection and considered it possible that the allowances could still be increased (83, 84, 85, 87, 430, 577, 755, 830, 858, 867, 1038, 1070, 1164, 1409, 1666, 1670). Concerns were also raised that recent projections from the National Records of Scotland (NRS) suggest significantly higher rates of population and household growth, and it was felt that these projections should be taken into account within the LDP despite not being included within the SDP (632, 1164, 1349, 1361, 1362, 1380, 1381, 1400, 1409, 1458, 1472, 1515, 1521, 1530, 1541, 1606, 1607, 1610, 1612, 1633). Delivery and Effectiveness of Existing Housing Allocations A large number of respondents challenged the housing allocations in the 2012 LDP, stating that many are either: no longer effective, with constraints preventing their delivery; delivering at rates that are slower than originally predicted; or not delivering the overall numbers of houses that were expected. A number of these respondents felt that the deliverability and effectiveness of existing allocations should be subject to a rigorous testing process. (83, 84, 85, 87, 430, 572, 576, 632, 640, 755, 806, 830, 858, 867, 1038, 1070, 1078, 1089, 1194, 1196, 1317, 1157, 1349, 1361, 1362, 1366, 1400, 1409, 1458, 1462, 1472, 1515, 1521, 1530, 1541, 1558, 1560, 1563, 1606, 1607, 1610, 1612, 1633, 1634, 1640, 1650, 1651, 1666, 1670, 1688, 1694). Specific sites that

Page 5 of 14 were considered not to be effective included Menie and Cromleybank (806), along with allocations at Blackburn and Kintore (640). Some respondents considered the projected completion rates within the Housing Land Audit (HLA) to be over-optimistic. They expressed the view that the development industry would not be able deliver at these projected rates, and that this would result in a shortfall in housing supply (1349, 1400, 1458, 1472, 1515, 1521, 1530, 1541, 1606, 1607, 1610, 1612, 1651, 1194, 1196, 1558, 1560). A number of respondents considered there to be a lack of supply in the Aberdeen Housing Market Area (AHMA) and Strategic Growth Areas (SGAs). Respondents commented that if the housing requirement for the AHMA is disaggregated on a 50:50 basis between the City and the Shire, and compared against the effective sites within the Shire part of the AHMA (using data from the 2013 Housing Land Audit), the effective supply in the Shire falls to less than 5 years (1350, 1361, 1362, 1465, 1522, 1559, 1611, 1656). They also commented that there is a lack of post 5 year effective sites (1350, 1361, 1362, 1420, 1465, 1651). Concerns about under-supply against the SDP allowances were also raised in respect of the Portlethen-Stonehaven SGA (1358, 1371, 1669), the Ellon- SGA (1465, 1708), and the local growth area within (1661). Within the Ellon-Blackdog SGA concern was raised in respect of the inclusion of the Menie development as part of the land supply, and it was contended that an alternative site should be identified for the provision of 500 houses in this SGA (1465, 1661, 1708). Respondents also raised concerns about a perceived under-supply / lack of provision for housing in specific settlements including: Banchory (1409); Inverurie (1522); (1196, 1558); Newtonhill (1611); (1149); (1194, 1560); and Westhill (1350, 1521, 1539). A number of respondents considered there to be a requirement for additional housing at to help deliver the proposed bypass (1124, 1125, 1702). Numerous respondents stated that the 2012 LDP allocates land in areas where there is very little market demand, including within the Rural Housing Market Area (RHMA). They felt that in order to maintain the economic competitiveness of the region, and to capitalise on the development of the AWPR, more land should be allocated in areas where demand is highest and where the industry can deliver development, including the AHMA. It was also suggested that a draw down mechanism be constructed to allow the transfer of allowances from the RHMA to the AHMA. (632, 861, 1078, 1089, 1157, 1349, 1355, 1400, 1416, 1426, 1432, 1458, 1472, 1486, 1488, 1515, 1521, 1530, 1541, 1557, 1606, 1607, 1610, 1612, 1640, 1650, 1669, 1694). One respondent raised concerns over the reliance on windfalls to deliver the required amount of housing (1416) Reliance on Large Sites Respondents challenged the 2012 LDP’s reliance on a small number of large sites, particularly within the Aberdeen Housing Market Area (AHMA), and felt that these sites would deliver over longer timescales and with lower completion rates than envisaged owing to major infrastructure requirements. Views were expressed that this resulted in an inability to be flexible and look to alternative sites to address any shortfall in supply. (632, 861, 1157, 1194, 1196, 1317, 1349, 1361, 1362, 1366, 1400, 1458, 1472, 1515, 1521, 1530, 1541, 1558, 1560, 1563, 1606, 1607, 1610, 1612, 1633, 1651, 1669, 1721, 1725). The new settlement at Chapelton of Elsick was particularly identified as delivering slower than originally envisaged (1157, 1361). Similar concerns were raised over the 2012 LDP’s reliance on sites that are split over two plan phases. It was noted that this limits flexibility, as if the first phase of these sites does not deliver as envisaged it is not possible to draw down the second phase early to augment the land supply (640, 1125, 1157, 1366, 1651).

Page 6 of 14 Impact of Land Supply on Price A number of respondents pointed to the current high cost of housing, particularly within the AHMA. They felt that restricting land supply would increase the price further, whereas increasing supply would reduce prices (477, 806, 1157, 1366, 1462, 1477, 1584, 1632, 1747, 1806). One respondent felt that more housing sites should be provided for self-build (562). Need for Generous Supply and a Range of Sites A large number of respondents considered there to be a need for a wider range of sites, including smaller scale sites that can be delivered in the short term, in order to provide a generous supply of housing land. They particularly made reference to the comments of the Reporter following the recent SDP examination, who stated that “I am in no doubt that a mix of site sizes would be best placed to achieve the growth rates required in the proposed plan” (576, 806, 867, 1038, 1157, 1349, 1361, 1362, 1366, 1380, 1400, 1458, 1472, 1515, 1521, 1530, 1541, 1557, 1559, 1563, 1606, 1607, 1610, 1612, 1633, 1650, 1651). Need for More Employment Land Respondents suggested that more employment land should be made available to support local jobs (693) and that more smaller units should be developed for start-up businesses (956). One respondent proposed that additional employment land be allocated in the Badentoy/Portlethen area (1216). A number of respondents suggested that additional employment land should be allocated in the Blackburn-Inverurie SGA / Crichie area, particularly to compensate for the loss of employment land associated with preferred bid Ga060, although they each went on to propose different sites for inclusion in the plan (1519, 1525, 1529, 1588, 1730). Proposed Alternative Approaches Three respondents proposed that a new Western SGA should be defined from Westhill to Banchory, and that additional allocations should be made here (1606, 1607, 1610), whilst another considered that housing allocations for the period 2027-2035 should be made now in order to allow early draw down in the event of any undersupply (1633).

2. Actions There has clearly been a mixed reaction to the land supply main issue, with opposing views being expressed over whether or not additional land needs to be allocated in the 2016 LDP. In addition, since the consultation on the MIR Scottish Ministers have approved the Strategic Development Plan (SDP) and there is a legal requirement for consistency between the SDP and the LDP. There is evidently a large volume of support for the MIR’s preferred approach of not allocating additional land within the 2016 LDP, and these comments are acknowledged. In response to the comments that expressed conditional support for the preferred approach it is noted that the need for development to support the sub-sea sector in Westhill, and the need for housing allocations in Macduff, are discussed in detail within the settlement specific issues and actions papers. The comments relating to the need to deliver facilities and services within the 2012 LDP allocations, and the request for healthcare facility requirements to be identified in the settlement statements, are also noted. The need for new developments to make appropriate contributions to public services, facilities and infrastructure will continue to be addressed through implementation of Policy 9 Developer Contributions, and the settlement statements already identify the requirement for contributions towards health facilities where a shortfall has been identified. Strategic Development Plan Allowances and Housing Projections The comments that the SDP housing allowances could still change are acknowledged, but these views have now been overtaken by more recent events. The SDP Examination Report has clearly concluded that the SDP housing allowances are appropriately generous, and that the

Page 7 of 14 scale and distribution of growth provided through the allowances are appropriate and sufficient to meet needs over the plan period, and the SDP has now been approved by Scottish Ministers. Issues in relation to the recent 2010-based projections from the NRS were similarly discussed at the SDP Examination. The Reporter noted that the current Housing Needs and Demand Assessment (HNDA) formed an appropriate evidence base for the SDP, and that it would not be appropriate to superimpose more recent population and household projections into the SDP without following the implications of these through a revised HNDA. The Reporter therefore concluded that the housing allowances in the SDP should be approved without modification in order to allow the next round of LDP preparation to proceed expeditiously, and that the next iteration of the HNDA and SDP could then be based on the 2010-based projections. In any event, the Reporter concluded that the housing allowances within the SDP are sufficiently generous so that the SDP cannot be fairly said to fail to provide for even the significantly higher 2010-based NRS projections. The revised NRS population projections are therefore not considered to provide grounds for the 2016 LDP to allocate more housing land than is specified within the SDP housing allowances. Effectiveness of the Housing Allocations A large number of respondents have challenged the deliverability and effectiveness of the 2012 LDP housing allocations. It is worthwhile to note a number of factors in response to these comments. Firstly, most of the allocations were promoted by developers and landowners, and the allocations were made based on information supplied by the development industry advising that the sites were deliverable. More importantly, the Action Programme provides a mechanism by which progress on delivering the allocations can be monitored. The Action Programme shows that progress is being made in delivering the vast majority of the allocated sites, with the majority of the sites within the Action Programme being considered either effective or capable of becoming effective during the relevant plan phase (phase 1: 2007-2016 and phase 2: 2017- 2023). The Council’s Delivery Team also continues to work closely with the development industry to help bring sites forward for development and assist in overcoming development constraints where possible. In response to the views that the delivery assumptions within the Housing Land Audit (HLA) are over-optimistic, it is also worthwhile to note that the HLA is produced in consultation with the development industry and that the predicted build rates are largely based on information provided by developers. The 2013 HLA was agreed by Homes for Scotland with no disputes. It is also worth highlighting that the SDP does not require sites to be delivered within particular timeframes (SDP para 4.24) – targets for completions are at an SDP level rather than the level of individual sites. Supply in the Aberdeen Housing Market Area (AHMA) The criticisms over the lack of supply within the AHMA are considered to be unfounded. Respondents have contended that if the housing requirement for the AHMA is disaggregated on a 50:50 basis between the City and Shire, and compared against the supply of effective sites in the Shire part of the AHMA, there is not a 5 year land supply. However, the SDP does not provide any justification for disaggregating the AHMA requirement in this way. The only reference to a 50% apportionment within the SDP is made in paragraph 3.5, where a target is set that 50% of all homes built over the period to 2035 should be within Aberdeen City. The AHMA housing requirement therefore applies to the Housing Market Area (HMA) as a whole, and the assessment of land supply must be made at the HMA level. The 2013 HLA clearly demonstrates a 5.7 year effective land supply within the AHMA when measured against the previous Structure Plan (SP) housing requirement, whilst the draft 2014 HLA demonstrates an effective land supply of 6.6 years within the AHMA when measured against the SP requirement and 8 years when measured against the SDP requirement. In response to concerns over the lack of post 5 year effective sites, it is important to stress that the 2013 HLA does not include 2012 LDP phase 2 allocations (sites allocated for development in the period 2017-2023) unless planning consent had been granted on these sites by 1 January 2013. These allocations will therefore further

Page 8 of 14 augment the housing land supply from 2017 onwards. It is also worthwhile noting that the draft 2014 HLA shows a significant increase in the post 5 year effective land supply in the Aberdeenshire part of the AHMA, with a rise of almost 96% from 2,838 (in 2013) to 5,552 (in 2014). Ellon – Blackdog Strategic Growth Area (SGA) Similarly, the criticisms over the lack of supply within the SGAs are not considered to fully reflect the land supply position. Within the Ellon-Blackdog SGA, the 2012 LDP allocates sites for 810 dwellings in the 2007-2016 period against the SDP’s allowance of 800 units. It also allocates sites for 1,035 dwellings in the 2017-2023 period against the SDP’s allowance of 1,500 units (with the remainder of the SDP allowance being taken up by a windfall contribution of 500 houses at Menie). All but one of the phase 1 allocations sites are defined as effective within the 2013 HLA - the only exception being the H1 site at (which is currently identified as constrained, but accounts for only 10 dwellings of the total supply in the SGA). It has been contended that there is a supply of only 474 effective dwellings within the Ellon-Blackdog SGA, which falls below the SDP’s allowance of 800 houses for the period 2007-2016. However, this assessment takes no account of the majority of the M1 phase 1 allocation at Ellon (Cromleybank), which forms part of the effective supply (albeit beyond 5 years). Paragraph 4.24 of the SDP recognises that it cannot be expected that all homes will be built within the relevant plan period, and that given the overall generosity within the housing allowances, this will not prejudice the ability to meet the overall housing requirement. The time that is likely to be taken to bring forward the Cromleybank site is therefore not considered to fundamentally undermine the ability to meet housing needs within the SGA. Whilst a number of respondents considered the Cromleybank site to be ineffective, the Action Programme demonstrates that progress is being made in delivering this site, with masterplanning and traffic modelling work being undertaken at present. The effective status of the site within the HLA is therefore considered appropriate. Specific concerns have been raised over the 2012 LDP’s assumption that the site at Menie will contribute 500 houses to the supply within the Ellon-Blackdog SGA during the period 2017-2023. Respondents have expressed the view that the outline planning consent for this site has lapsed and that, in any event, it has no prospect of becoming effective within the plan period. This issue has been subject to detailed consideration.The Council’s legal service has provided a view on the validity of the outline consent at Menie, and considers the permission to remain live. As such, the possibility of this site contributing to the land supply within the SGA needs to be taken into account. It must also be noted that paragraph 3.29 of the Strategic Development Plan (SDP) identifies that realising the economic potential of the Menie Estate golf resort will form an important part of the development strategy for this SGA. Continuing to pursue the Menie development therefore remains important in order to comply with this aspect of the SDP. It is acknowledged that the site is currently constrained on infrastructure grounds. However, the SDP has extended the time period within which the Menie site would need to become effective by an additional 3 years (from 2017-2023 to 2017-2026), and this gives additional time for development constraints to be addressed. Therefore, whilst the position with the Menie site is uncertain at present, there remains a reasonable prospect that the development will be taken forward and that the site will become effective within the lifetime of the plan, albeit that this is likely to be within the latter half of the 2017-2026 period. For these reasons, it is recommended that the Menie site should remain part of the land supply for the Ellon-Blackdog SGA, although the delivery of the site should be kept under review during the lifetime of the 2016 LDP. This will be achieved through the Action Programme. In the event that no further progress has been made in delivering the Menie site by the time the 2021 LDP begins preparation, an alternative site(s) could be identified at that time and still have sufficient time to become effective within the 2017-2026 period.

Page 9 of 14 Portlethen – Stonehaven SGA In response to concerns regarding the housing supply within the Portlethen-Stonehaven SGA, it is noted that the 2012 LDP allocates sites for 2,135 dwellings in the 2007-2016 period, against the SDP’s allowance of 2,200 units (with the remainder of the allowance being taken up by windfall sites with planning permission accounting for 232 houses). It also allocates 2,370 houses for the 2017-2023 period against the SDP’s allowance of 2,400 units. All of the phase 1 allocations are identified as being effective in the 2013 HLA, although a large part of the M1 site at Chapelton of Elsick is identified within the post 5 year effective supply. In line with the guidance in paragraph 4.24 of the SDP, it is not considered that the time that is likely to be taken to deliver the Chapelton development will fundamentally undermine the land supply position either overall or within the Portlethen-Stonehaven SGA. Whilst a number of respondents have challenged the effectiveness of the Chapelton site, the HLA clearly identifies this site as being effective. Full planning permission has also now been approved for the first 802 units, with planning permission in principle also being granted for the remainder, and a construction programme for the site has been provided. Local Growth & Diversification and Other Settlements Comments have also identified the need for additional housing allocations within the Formartine Local Growth Area and a number of other settlements. However, the 2012 LDP has allocated land in accordance with the SDP allowances for the AHMA, RHMA and SGAs, and there is no requirement within the SDP to allocate sites according to other geographical or administrative boundaries. Remaining settlement specific issues are discussed within the issues and actions papers for the relevant settlement. In response to concerns that the 2012 LDP allocates too many sites in areas of low demand, it should be noted that the majority of the housing allocations are within the AHMA. More fundamentally, the distribution of housing allowances between the AHMA and RHMA is a matter for the SDP, and this issue was subject to specific consideration during the recent SDP Examination. The Reporter concluded that the balance of allowances between the AHMA and RHMA is derived from the HNDA and is therefore appropriate and clearly evidenced. To introduce any mechanism into the LDP that would result in the transfer of housing allowances from the RHMA to the AHMA would be contrary to the SDP strategy and is therefore not considered appropriate. Windfalls Whilst one respondent was concerned over the reliance on windfalls in meeting the overall housing requirement, it should be noted that the ‘windfalls’ that are taken into account in Schedule 1 of the 2012 LDP are unallocated sites that already have planning permission and are identified as being effective within the HLA. The only notable exception to this is the Menie site, which has been discussed in more detail above. This approach fully accords with guidance in PAN 2/2010. The only part of Aberdeenshire where the full SDP allowances have not been allocated is within the local growth part of the RHMA – where 12% (959 units) of the total SDP allowances for the full 2007-2027 period have not been specifically allocated. However, this is because long-term trends show that a large proportion of all housing completions within the RHMA come from small sites. The 2013 HLA shows that, based on a 5 year average, some 154 dwellings are built on small sites (defined as sites of less than 5 dwellings) each year within the RHMA. It is therefore reasonable to assume that the continued contribution from small sites over the plan period will more than satisfy the remaining unallocated component of the SDP’s allowance for local growth in the RHMA – particularly given the LDPs supportive and flexible policies on housing development in the countryside. Large Sites It is acknowledged that the strategy of the 2012 LDP is based upon the delivery of a number of large sites within the AHMA. However, this strategy was specifically adopted as the scale of housing growth over the plan period will result in the need for significant infrastructure

Page 10 of 14 investment. The housing allocations within the 2012 LDP are therefore of a scale to deliver the required infrastructure improvements. These overall infrastructure requirements would not disappear if the housing growth were to be provided through a larger number of smaller sites, and it is considered unlikely that smaller sites would be able to provide the required infrastructure and remain commercially viable. The Action Programme shows that the large allocations within the 2012 LDP are currently making demonstrable progress and are therefore either effective or capable of becoming effective within the plan period in accordance with the requirements of SPP. In response to criticisms that the delivery of these larger sites is likely to take longer than envisaged, it is noted again that paragraph 4.24 of the SDP makes it clear that that the housing allowances provide a generous supply of land for housing on top of the overall housing requirement and that, owing to this level of generosity, we cannot expect all the new homes to be built within the relevant plan period. As such, whilst some of the larger allocations may take more than one plan period to deliver this will not prejudice the ability to meet the overall housing requirement. As mentioned previously, the Council’s Delivery Team is also working pro-actively with the development industry to help bring forward the 2012 LDP allocations, and measures are being taken wherever appropriate to assist delivery and overcome development constraints. For instance, two of the 2012 LDP allocations (Uryside and Chapelton) have recently been selected to be taken forward under The Scottish Government’s pilot Accelerating Housebuilding scheme. This may particularly help to accelerate the delivery of the second phase of the Chapelton site. Concerns have also been raised over the 2012 LDP’s reliance on sites that are split over more than one plan phase, and the consequent inability to draw down subsequent phases early if the first phase does not deliver as envisaged. In this regard it is important to note that the requirement to maintain a 5 year effective housing land supply applies at the HMA level. In the event of any deficit in the 5 year effective supply, alternative sites would therefore need to be drawn down from the same HMA but not necessarily the same SGA or immediate locality. The range of existing allocations within both HMAs provides options that could be drawn down early to augment supply, and policy SG Housing 2 outlines the mechanisms that would be used to trigger an early draw down if necessary. Small Sites Many respondents have commented that there is a need for a range of smaller sites to augment the housing land supply, with a number specifically pointing to the SDP Reporter’s recent comments that “I am in no doubt that a mix of site sizes would be best placed to achieve the growth rates required in the proposed plan”. The reasons for pursuing large allocations, particularly within the AHMA, are set out above and have previously been endorsed at the Examination of the 2012 LDP. Notwithstanding, it is also important to note that the 2012 LDP also contains a wide range of smaller site allocations within both HMAs and the SGAs. For instance, there are some 30 allocations of less than 50 dwellings within the local growth part of the AHMA, and more than 100 allocations with less than 50 dwellings within the local growth part of the RHMA (with the Action Programme showing that the vast majority of these are making significant progress towards delivery). Outside the Local Growth Areas, there are 12, 9 and 4 allocations of 50 dwellings or less in the Aberdeen to , Aberdeen to , and Aberdeen to Laurencekirk SGAs respectively. It is therefore considered that the 2012 LDP provides an appropriate mix of smaller sized allocations in addition to the larger sites that are required to deliver major infrastructure investments within the AHMA/SGAs. House Price The concerns over the impact of land supply on price are noted, although to a large extent mis- directed. It is the availability of housing (both new and second-hand) which impacts on house price rather than the supply of housing land. Whilst it is acknowledged that unduly restricting land supply could have an adverse impact on the affordability of housing, it has been demonstrated above that appropriate land has been allocated in accordance with the SDP allowances, and that

Page 11 of 14 the SDP allowances provide a significant degree of generosity above the housing requirement. As such, it is not considered that the land supply is acting to increase house prices, or that more land should be allocated simply to reduce prices. Increasing supply of housing land in 2012 has had no impact on house prices, which continue to rise. More detail on the way in which the LDP will help to secure contributions towards affordable housing from new developments, which can include plots for self-build, is outlined in the issues and actions paper on housing for people on modest incomes. Additional Strategic Allocations For the reasons outlined above, it is considered that the 2012 LDP provides a generous supply of housing land within the plan period in accordance with SPP requirements and the SDP. The comments that state otherwise do not provide any further evidence to justify making additional allocations within the 2016 LDP. Whilst there have been calls for a Western SGA to be defined extending through Westhill to Banchory, and for additional allocations to be made within this corridor, these proposals would be a matter of strategic significance for the region and would need to be pursued through the SDP. Adopting this approach within the LDP was considered at the SDP examination and would be contrary to the approved SDP. Similarly, in response to calls for allocations to be made to meet the SDP allowances for the 2027-2035 period, it is noted that SPP requires LDP allocations to meet the requirements of the SDP up to year 10 from the expected year of adoption. Given that the LDP is expected to be adopted in 2016, there is therefore no requirement to allocate sites for the 2027-2035 period at this stage. Employment Land Supply In relation to employment land supply, the SDP identifies allocations for the period to 2026, along with strategic reserve requirements for the period 2027-2035. It also states that a minimum of 60 hectares of marketable land should be available at all times within the SGAs in Aberdeenshire, with this figure being broken down into a requirement for 40 hectares in the Huntly-Laurencekirk SGA and 20 hectares in the Blackdog-Peterhead SGA. The 2012 LDP has allocated sites for employment purposes in line with these requirements. The 2013 Employment Land Audit (ELA) shows that 397 hectares of marketable employment land is available across Aberdeenshire, with 108 hectares in the Blackdog-Peterhead SGA and 149 hectares in the Huntly-Laurencekirk SGA. The Action Programme shows that progress is being made in delivering the majority of these allocations. Overall, there is therefore not considered to be any requirement to allocate additional land for employment purposes in the 2016 LDP. The only exception to this relates to the comments on the Ga060 bid. It is acknowledged that if the LDP is amended in accordance with the preferred approach within the MIR this would result in the loss of strategic reserve employment land within the Blackburn-Inverurie part of the Huntly-Laurecekirk SGA. Notwithstanding the overall healthy supply of employment land, this may provide a justification for including additional strategic reserve land within the Blackburn-Inverurie part of this SGA. A number of specific site options have been proposed in response to this potential requirement, and these are discussed in detail within the settlement specific issues and actions papers. Summary The housing and employment land supply within Aberdeenshire remains healthy. The 2013 HLA shows in excess of 5 years effective land supply within both the AHMA (5.7 years supply) and the RHMA (6.2 years supply) when measured against the former SP requirement. The draft 2014 HLA continues to show a healthy land supply, with a supply of 8.0 years effective sites in the AHMA and 6.3 years in the RHMA when measured against the SDP requirement. The draft 2014 HLA also shows a significant increase in the post 5 year effective land supply in both the AHMA and RHMA, and the supply will continue to be augmented as phase 2 allocations from the 2012 LPD come forward for development. A similar position is evident in respect of the employment land supply, where the ELA shows that 397 hectares of marketable employment land is available across Aberdeenshire, with 108 hectares in the Blackdog-Peterhead SGA and 149 hectares in the Huntly-Laurencekirk SGA.

Page 12 of 14 The housing allowances set by the SDP have been supported by an independent Reporter, and have been found to be both generous and to significantly exceed the housing requirement over the plan period. The 2012 LDP has allocated a mix of sites to meet these allowances and, whilst challenged by the development industry, evidence from the HLA and the Action Programme show that demonstrable progress has been made in delivering the vast majority of the allocations. The housing allocations are therefore either effective or capable of becoming effective during the plan period in accordance with SPP requirements. Whilst it is acknowledged that some of the larger allocations may take time to deliver, allocations of this scale are necessary to overcome the significant infrastructure constraints to growth within the AHMA. The SDP also makes clear that we cannot expect all new homes to be built within the relevant plan period, and that given the generosity of the allowances this will not prejudice the ability to meet the overall housing requirement within the plan period. A similar position is again evident with the employment land supply, where the SDP Examination Reporter considered the employment land allocations to be appropriate and the Action Programme shows that significant progress is being made in delivering the 2012 LDP’s allocations. The only exception to this relates to the potential need to allocate additional strategic reserve employment land within the Blackburn-Inverurie part of the Huntly-Laurencekirk SGA to make good any shortfall in the event that bid Ga060 is approved in line with the MIR’s preferred approach. Taking these factors into account, it is considered that there is no overall requirement to add to the existing housing and employment allocations through the 2016 LDP for the period to 2026.

3. Recommendation to Committee 1. That the MIR’s preferred approach to land supply be adopted and that, subject to the exception below, no new allocations be made within the 2016 LDP. 2. That consideration be given to allocating strategic reserve employment land within the Inverurie-Blackburn part of the Huntly-Laurencekirk SGA to make good any shortfall in the event that bid Ga060 is approved in line with the MIR’s preferred approach.

4. Committee Decisions 1. Area Committee agreed that the MIR’s preferred approach to land supply be adopted within Kincardine and Mearns and made no comment on site Ga060 in at their meeting on 6 May 2014. 2. Area Committee agreed the above recommendations at their meeting on 13 May 2014. The Committee also agreed an additional recommendation of: 3. That greater focus be placed on the availability of employment land in regeneration areas. 3. Garioch Area Committee agreed the recommendation 2 at their meeting on 28 May 2014. The committee also agreed that the wording of recommendation 1 should read; 1. That the MIR’s preferred approach to land supply be adopted, subject to the exemption below and appropriate discussion on settlements to deal with local issues, no new allocations be made within the 2016 LDP. 4. Area Committee agreed the above recommendations at their meeting on 3 June 2014. 5. Buchan Area Committee agreed the above recommendations at their meeting on 10 June 2014. 6. Formartine Area Committee agreed the above recommendations at their meeting on 17 June 2014.

Page 13 of 14 7. Infrastructure Services Committee noted the recommendations of the Area Committees and agreed the recommendations at their meeting of the 3 July 2014.

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