INTRODUCTION

FORMER SCOTTISH FIRE & RESCUE SERVICE SITE

Gullane RESPONSE ON THE MIR February 2015

1 INTRODUCTION FIGURE 1 STRATEGIC CONTEXT

2 INTRODUCTION EXECUTIVE SUMMARY The Scottish Fire and Rescue Service (SFRS) acknowledge and support the principle of the identification, by , of the site of the Fire Training College as a ‘preferred new housing allocation’ in the Local Development Plan Main Issues Report. Whilst the SFRS supports the identification of housing (100 units) on the site, it does not consider employment or tourism (hotel) use appropriate.

The college closes at the end of March and training is now delivered from fully operational new state of the art training services/ facilities in a centralised single location at . For this reason, SFRS has been considering the Gullane site’s potential for redevelopment, appropriate to its context, with a view to reinvesting the capital receipt from the sale of the site. In order to continue to fund improvements to new training facilities, SFRS require to secure these capital receipts during the 2015/16 financial year.

It is considered unrealistic to develop the 4.2ha site for 100 houses as well as accommodate employment land and tourism use. To accommodate a mix of uses (housing/employment/ tourism) on this site and the number of homes identified in the MIR may necessitate the demolition of Henderson House. SFRS, however, acknowledge the merits of retaining Henderson House as part of the redevelopment of the site, mindful of its heritage value and potential legacy for the site and the wider settlement.

SFRS firmly believe that the site is most suited toredevelopment for residential use including mainstream and affordable new build housing in association with the redevelopment of Henderson House for retirement flats and or serviced apartments. This, in association with selective demolition of buildings/structures on the site will ensure that residential amenity of neighbouring properties is protected and enhanced. The use of Henderson House as retirement flats and or serviced apartments would add an element of employment on the site, in that staff would be required to support and meet the needs of the residents.

Given the site is to close at the end of March 2015, there are significant implications for investment programming, if the LDP route is followed. If the SFRS is to wait until Plan adoption before proceeding to develop the site, this would in all likelihood be sometime in 2017 and it would no doubt take several years following on from this for the site to be built out. Importantly, we have support from several housebuilder developers who have stated their interest in the site and their willingness to develop the site immediately for housing, certainly building out the site within the next four to five years.

The allocation of the site for residential development would assist East Lothian Council in meeting its housing requirements, promote a sustainable pattern of development in accordance with Scottish Planning Policy and ensure appropriate reuse of a brownfield site within an established settlement boundary.

The site’s redevelopment for housing would also complement surrounding uses and protect/ enhance existing residential amenity. Redevelopment for housing could take place relatively quickly and bring benefits to the local community in terms of helping to sustain local facilities including local retail. The redevelopment could also bolster the local community by accommodating the changing needs of existing residents and attracting new residents from a broad cross section of the population.

3 INTRODUCTION

CONTENTS

1 INTRODUCTION 5

2 SITE & SURROUNDING AREA 9 Site Opportunities & Constraints 13

3 PLANNING CONSIDERATIONS 17 Planning Policy Context & Site History 18 Assessment Of Preferred Council Option 19 Further Considerations 22

4 DEVELOPMENT OPTIONS 23 Development Options 24 Development Principles 26

5 SUMMARY & CONCLUSIONS 27 Site Effectiveness 28 Indicative Masterplan 30

A1 APPENDIX 1 33 Response to MIR Questions 33

4 INTRODUCTION

Gullane

1

INTRODUCTION

5 INTRODUCTION

INTRODUCTION

1.1 On behalf of the Scottish Fire and Rescue Service (SFRS), 1.5 There are significant implications for investment Barton Willmore has prepared this response to the East programming if SFRS is to wait until Plan adoption before Lothian Local Development Plan Main Issues Report (MIR). proceeding to develop the site (Please see diagram below). This would in all likelihood not be until sometime in 2017 and it 1.2 The SFRS acknowledge and support the principle of would take several years to be built out. Importantly, we have the identification, by East Lothian Council, of the site of support from several housebuilder developers who have stated the Scottish Fire Service College at Main Street Gullane as their interest in the site and their willingness to develop the site a ‘preferred new housing allocation’ for redevelopment immediately for housing, certainly building out the site within in the Local Development Plan MIR. SFRS note that East the next four to five years. In light of the timescales involved Lothian Council have identified the site for circa 100 homes, in plan preparation and the need to secure the capital receipt employment and tourism use. Whilst SFRS support the from the sale of the site, SFRS is keen to progress a planning identification of housing on the site, it has strong reservations application for redevelopment of the site at the earliest about the inclusion of employment and tourism (hotel) uses. opportunity (please see programme below).

1.3 The SFRS site in Gullane is identified in the current adopted 1.6 We have considered a number of development scenarios East Lothian Local Plan as the SFRS training college. In the for the redevelopment of the site including different mixes of context of a reduced budget, the SFRS is currently rationalising the uses set out in the MIR (three development options) and its estate as part of major restructuring of the service across identified our preferred option. The preferred proposal set the Country. It is important to note that the College has never out in this submission is for residential use only. We consider provided call outs and so the fire cover provision within East this will provide a significant boost to the local economy, to Lothian will not alter at all on closure of the training facility. the benefit of the local community and provide East Lothian In the local context, Fire Station is a retained Council with not insignificant council tax receipts. station that is fully operational and shall remain so. The Service has just spent a considerable capital sum on it following fire 1.7 We consider the proposals accord with national policy damage. There are no plans for the fire stations within the East which requires development plans to promote a sustainable Lothian area which are at the following locations: pattern of development and to adhere to policy principles including directing ‘the right development to the right place’. • North Berwick This includes considering the re-use or re-development of • brownfield land before new development takes place on greenfield sites. • 1.8 In the following sections of this MIR submission document, Haddington • we set out our preferred proposals for the redevelopment of • this brownfield site.Our responses to the MIR questions are contained in Appendix One. • 1.9 Whilst we wish to promote development of the site prior 1.4 The college closes at the end of March and training is to LDP adoption, we respectfully request that East Lothian now delivered from fully operational new state of the art Council favourably considers our submission and accepts that training services/ facilities in a centralised single location at the site should be allocated for housing, including a range and Cambuslang. For this reason, SFRS has been considering the mix of house types and tenures serving a cross section of the Gullane site’s potential for redevelopment, appropriate to its population. Accordingly, we request that the site is identified context, with a view to reinvesting the capital receipt from the only for residential development in the emerging Local sale of the site. In order to continue to fund improvements to Development Plan. new training facilities, SFRS require to secure these capital receipts during the 2015/16 financial year.

FIGURE 2 PROGRAMME

SubmissionPre of Application PAN Application Consultation SubmissionDetermination Commence of Application on sitePhase 1 Complete LDP Adoption

2015 2016 2017

Need to release capital receipts

6 INTRODUCTION

FIGURE 3 LOCATION PLAN

Muirfield Golf Course

to North Berwick

Gullane Golf Course

to

7 INTRODUCTION

8 INTRODUCTION

Gullane

2

SITE & SURROUNDING AREA

9 SITE & SURROUNDING AREA

SITE & SURROUNDING AREA

FIGURE 4 SITE AERIAL

eet Main Str 2

4 C111 1 5 8

M 3 uirfi

i eld D 6 ri v e 7

eet on Str let Gar

10 SITE & SURROUNDING AREA

2.1 The proposal site at Main Street, Gullane comprises the 2.7 The main administration and teaching block is provided Scottish Fire and Rescue Service (SFRS) training college which within Henderson House. This is a substantial 4 storey building, is to close at the end of March 2015. The site is located within dating from the early 20th century, with frontage onto Main the established settlement boundary of Gullane, on the eastern Street. The building has been subject to later extensions on the side of the settlement. east and west sides.

2.2 The population of Gullane is 2,568 and is significantly older 2.8 Braidwood House, located on the corner of Main Street and than the Scottish average of 41. The average age in Gullane is the C111, is a modern 3 storey accommodation block with 122 48.5 and 35.4% of the population are aged over 60 compared rooms for fire personnel students. A garage and appliance/ with a Scottish average of 23.2% aged over 60. Unemployment equipment shed with a total of 8 bays fronts Drive. The is also notably low within Gullane; it stood at 2.6% compared to site includes approximately one hectare of private recreational the Scottish average of 4.8% at the time of the census in 2011. greenspace in its south eastern corner and facilities such as a lecture theatre and a gym. 2.3 There are a modest range of facilities in Gullane, including doctors and dental surgeries, a number of local shops and 2.9 In terms of topography the site is relatively flat. The site cafes, a primary school and a small scale Co-operative sits at 32m AOD to the north and undulates to 25m AOD to supermarket. There are also three hotels located within the southern boundary next to Garleton Street / C111. It is Gullane, providing a total of 52 guest rooms and 6 B&Bs. surrounded by residential properties on all sides with a telecom Archerfield, a resort hotel, is located 1.5 km outside of Gullane, building occupying land on the south western corner. There are on route to North Berwick. This hotel is associated with the three vehicular access points providing vehicular access to and Archfield Golf Course and provides guest bedrooms along egress from the site. The access points to the site are taken with lodges, villas, pavilions and cottage residences spread from Main Street to the north, Muirfield Drive to the west and throughout the grounds. the C111 on its eastern edge.

2.4 The Gullane Golf Course and the Muirfield Golf Course both 2.10 There is a category B listed building on the northern side bound Gullane and are located at the west and east sides of the of Main Street, located within 40m of the site. However, this settlement respectively. building is surrounded by development to the north.

2.5 The site is referenced by East Lothian Council in the 2014 MIR as ‘PREF-N5’. It is 4.2ha in size and contains eight buildings/ structures which up until the end of march 2015 have been used for training purposes and for housing trainees attending residential courses on the site.

2.6 The eight buildings/ structures on site are: • Henderson House (administration/accommodation/ meeting rooms) • Braidwood House (student accommodation) • Tactical Building • Drill Tower eet • Real Fire Tower on Str let • BA Training Facilities ar G • Gym • Garages

11 SITE & SURROUNDING AREA

FIGURE 5 SITE AERIAL

eet Main Str

C111

M uirfi

i eld D

ri v e

12 SITE & SURROUNDING AREA

Site Opportunities & Constraints 2.16 Screening is provided by mature trees and vegetation along the eastern boundary of the site. The southern site boundary Access & Circulation is also largely screened from adjacent development by mature trees and vegetation. The northern and western edges of the 2.11 The site is located immediately south of Main Street, development are prominent as part of the streetscape. the key east-west route through the settlement. This road connects Gullane with North Berwick and Dunbar to the east Natural Heritage and Aberlady and Musselburgh to the west. There is a bus stop located immediately next to the site’s northern boundary on 2.17 The site is not covered by any designations of international, Main Street providing access to public transport provision with national or local nature conservation interest. services operating between North Berwick and . 2.18 The settlement of Gullane is surrounded by agricultural 2.12 Footpath provision, immediately north of the site on Main land on all sides. The land is a mix of Class 2 and Class 3.1 Street, connects the site with local services and shops and the prime agricultural land. However, as the site is a brownfield wider settlement including Gullane Primary School. development within the established settlement boundary, it will not result in the loss of any prime agricultural land. The 2.13 A core path (98) lies approximately 400m to the south of site is predominantly covered in hardstanding except the south the southern edge of the SFRS site. It provides links to the wider east part which is an overgrown grassed area. This does not green network to the east and west. have any obvious ecological value. Mature vegetation is located around the southern and eastern edges. 2.14 There are three vehicular access points to the site: from Main Street, Muirfield Drive and from the C111 road bounding 2.19 Providing high quality open space within the proposed site the east of the site. will contribute to the improvement of the open space rating in the North Berwick Cluster. East Gullane is an area with an C111 Landscape / Townscape identified lack of accessibility to greenspace and play space. However this could be addressed by redevelopment of the site. 2.15 The site has been in use as a working SFRS training college and has thus been developed. Once the college closes in March Hydrology 2015 and all fire and rescue service activities on the site cease, it will be classified as brownfield land. Redevelopment of the 2.20 There are no watercourses within or adjacent to the site. site including the removal of buildings/ structures less sensitive There are no areas at risk of flooding in a 1:200 year event to the historic fabric of the town provides an opportunity to within, or near to the site. improve the settlement pattern, provide greater permeability of the built form and to provide a significant enhancement to 2.21 Whilst there is the potential for an increase in surface water the eastern side of the town. This is particularly important run-off as a result of redevelopment, appropriate mitigation given the prominence of existing buildings on approach to the measures could be put in place to address this issue. A settlement from the east. Henderson House, on the western sustainable urban drainage system could be incorporated corner of the site, acts as a notable landmark in the settlement as part of the future redevelopment of the site to handle and provides a focal point within the urban grain. attenuation and treatment for surface water run-off.

13 SITE & SURROUNDING AREA

FIGURE 6 FACILITIES PLAN

Muirfield Golf Course

Gullane Golf Course

14 SITE & SURROUNDING AREA

Surrounding Land Use Education

2.22 The site is bounded by residential development on all sides. 2.27 Gullane Primary School currently has a school roll of 209 and This provides opportunities for carefully considered linkages a capacity of 227, leaving 18 spaces available within the school through the site into the surrounding urban grain, creating (capacity at 8% based on 2014 school roll). The school is also greater permeability through the area and responding to the located on a site with room for expansion to provide additional built form. spaces as needed. Given the emphasis within Scottish Planning Policy to the re-use or redevelopment of brownfield land before Built Heritage new development takes places on greenfield sites, we consider that the school requirements of this site should take priority 2.23 There are no listed buildings on the site. There is a category over other sites in the surrounding area. North Berwick High B Listed gatehouse within 40m of the site and development School is at capacity, however expansion is already planned would avoid impacting on the setting of this listed building. on safeguarded land in order to meet the capacity needs of existing programmed developments. 2.24 Henderson House, whilst not listed, is of some architectural merit and contributes to the wider townscape. 2.28 Accordingly, it is concluded that redevelopment of the site: Service Infrastructure • can be accommodated without adverse impacts on the landscape or townscape quality; 2.25 Appropriate sewerage and waste water connections can be provided to the site. There is a capacity of 2,000 housing • a suitable ‘environmental fit’ can be achieved and the units at Castle Moffat Water Treatment Works and capacity of setting is capable of absorbing development in conjunction 333 housing units at Gullane Waste Water Treatment Works. with suitable mitigation measures; Discussions are being sought with Scottish Water to confirm this would not detract from the existing character of the spare capacity. • settlement, particularly due to the retention of Henderson 2.26 The location of existing services adjacent to the site causes House; no constraint to development. • would make positive landscape and ecological benefits at the local scale promoting permeability through the eastern portion of Gullane.

15 16 Gullane

3

PLANNING CONSIDERATIONS planning considerations

PLANNING CONSIDERATIONS

Planning Policy Context & Site History Scottish Planning Policy (SPP) 2014 3.8 The latest iteration of Scottish Planning Policy was published 3.1 The approved development plan for the site comprises on 23 June 2014 and provides updated policy principles, SESPlan 2013 and the East Lothian Local Plan 2008. The including: emerging East Lothian Local Development Plan, once adopted, will supersede the adopted East Lothian Local Plan with formal ‘A presumption in favour of development adoption of the LDP not anticipated until late 2016/early 2017. that contributes to sustainable development.’ (Paragraph 27) 3.2 The site sits within the established settlement boundary of Gullane and is covered by Local Plan Policy INF4 – The 3.9 There is also a focus on prioritising brownfield development Scottish Fire Service Training School, Gullane. The Council before greenfield development, where possible. The proposed acknowledges that the activities of the training centre can development site is an effective brownfield opportunity, that create environmental impacts that might not otherwise be will contribute to the sustainable development of Gullane. appropriate within what is predominantly a residential area Detailed design of the site will also strive to meet the 6 qualities and the Council seeks that any such impacts are minimised. of successful places set out in SPP: Policy INF4 states that any adverse environmental impacts resulting from the use of the site by the fire service will be • Distinctive minimised as far as possible and that regard will be had to any Safe and Pleasant possible impacts from surrounding uses on the operational • requirements of the SFRS Training Centre. • Welcoming

3.3 This policy seeks to mediate conflict between the fire • Adaptable service use and the surrounding residential land uses; it does • Resource Efficient not zone the land as a particular use class or outline the potential need to safeguard the site for continual fire service • Easy to Move Around and Beyond use nor for employment use. 3.10 SPP states, in relation to ‘employment land’ that: 3.4 In terms of mitigating conflicts between the site and the surrounding residential area, residential development is ‘Local development plans should allocate a likely to be the use with the least impact on the neighbouring range of sites for business, taking account of properties. current market demand; location, size, quality and infrastructure requirements; whether sites 3.5 The East Lothian Main Issues Report (MIR) was published on are serviced or serviceable within five years; the 17 November 2014. It includes the site as a ‘Preferred Option’ potential for a mix of uses; their accessibility to for housing development (circa 100 units), employment use and transport networks by walking, cycling and public tourism use on site. transport and their integration with and access to existing transport networks.’ (paragraph 101) 3.6 The analysis of the site by East Lothian Council is generally positive with 18 out of the 19 criteria that the site was assessed 3.11 The proposed site in Gullane is unlikely to be serviceable for against, graded as either ‘positive’ or ‘reasonable’. employment/ tourism use within the 5 year period noted in SPP due to the limited hotel and employment market in Gullane and 3.7 There is no relevant planning history in relation to the East Lothian as a whole. proposed site.

18 PLANNING CONSIDERATIONS

Assessment Of Preferred Council Option 3.17 Generally, employment use on the site is unlikely to prove attractive. There are no agglomeration benefits to locating 3.12 Whilst SFRS agree, as per the MIR, that the site is suitable in Gullane or economies of scale to benefit from. The site is for housing and our initial capacity work has indicated potential also not located in close proximity to the strategic transport for c.100 units, this would require the entire site. For this and network and to a significant extent the site’s geographic other reasons SFRS does not consider the site appropriate location is one of the main reasons for its closure in the first for employment or tourism uses as well. On behalf of SFRS, place. There is a low labour pool within Gullane to draw from Barton Willmore have considered various options for the with a small total population of 2,568. The latest employment redevelopment of the site (including employment / toursim use) figures for Gullane are based on the 2011 census, at that point and are convinced that housing, whether mainstream (option unemployment in Gullane stood at 2.6% compared to a Scottish 1) or a combination of mainstream and retirement flats (option average at the time of 4.8%. 3), is the most logical and most appropriate use as part of the redevelopment of the site. 3.18 Importantly, SESPlan states that employment development in East Lothian should be focused around the Economic 3.13 Having considered the potential for employment or tourism Corridor that stretches from Musselburgh to Dunbar in the east. use such as a hotel, we are of the view that these are not Gullane falls significantly outside of this area and away from the practical or indeed viable as potential considerations. This is, strategic road network. SESPlan also identifies intensification in in part, based on our experience of similar sites in comparable current employment locations as a more effective method of locations across and based on our understanding achieving employment development: of the employment market in East Lothian and the tourism industry in the region. ‘Consolidating growth by reusing brownfield land and intensification of development on sites within existing Employment business parks and industrial estates is one of the most sustainable methods for economic growth.’ 3.14 There will be a very limited impact on the local area in (SESPlan Economy Technical Note Nov 2011, p32) terms of job losses as a result of the decommissioning of the Fire and Rescue Service Training Centre at the end of 3.19 The proposed site in Gullane does not achieve March; the site is not a significant generator of local jobs. Ten intensification of an existing business. former low skilled jobs have been lost from staff located in the local area. However, we understand that these people 3.20 Only 6.25ha of employment land has been developed in have subsequently found alternative employment locally. East Lothian since 2006. Furthermore, serviced apartments and/or retirement 3.21 There are 102ha of employment land allocated in East flats would also generate job creation for the purpose of Lothian. However, none of this is considered effective, as maintenance etc. outlined by SESPlan, even within the preferred development locations with larger working populations and better links to 3.15 All specialist jobs based at the training college have been the strategic road network. If these such sites are unable to held by staff located outwith Gullane and the surrounding area come forward, it is highly unlikely that the site at Gullane will and this has resulted in significant vehicle journeys to the site be successfully developed for business or office use. These are with staff travelling from as far as and Falkirk Council areas. amongst the factors that have influenced the SFRS to relocate 3.16 More generally, the economic impact of the closure of the from this site. training college on Gullane is not likely to be significant because 3.22 The redevelopment of the site is likely to have a those based at the training centre have had access to various significant positive economic impact locally not just during the facilities on site, including catering and a gym. This has meant construction stage but when properties are occupied. For that there have been limited reasons to leave the campus for example: local spend in the settlement, council tax receipts as the duration of training courses. well as the positive impact of more people helping to sustain local community facilities and contributing to the sustainability of the community, generally.

19 PLANNING CONSIDERATIONS

Lack of Tourism (Hotel) Potential 3.26 Notably there are already 3 hotels in Gullane providing 52 bedrooms, along with 6 B&Bs. As stated above, Archerfield 3.23 Hotel potential in Gullane is limited. 75% of visitors to Hotel, just outside Gullane, towards North Berwick, provides East Lothian visit only for day trips and hotel stays in the area a range of tourist accommodation. With declining demand in have declined significantly since 2009/10 from 1,750,000 East Lothian, additional hotel space does not seem likely to be visits to 1,500,000 in 2013/14. It is also noted in the 2012 viable. ‘Employment Opportunities in the Public Sector Submission from East Lothian Council to the Scottish Government Finance 3.27 East Lothian Council last measured hotel occupancy Committee’ that hotel development in East Lothian should be within the council area in 2006 and found it to be 58%. This is focused on resort style hotels (such as Archerfield which is compared to more buoyant markets such as Edinburgh where located 1.5km east of Gullane); this is reiterated in the Tourism occupancy sits at around 80%. Development Strategy for Scotland 2013. Hotel Occupancy Scotland 3.24 Resort style hotels provide a luxury facility and offer a wide range of facilities and activities such as spas and swimming 3.28 Hotel occupancy is seasonal and notably lower in both pools. Whilst some resorts operate on a seasonal basis, the villages and seaside towns when compared with cities. It is also majority now try to operate all year round. They tend to be lower when comparing hotels with between 11-25 rooms with larger than standard hotels and provide larger numbers of larger competitors of 51-100 rooms and 101+. In 2013 there was rooms (Gleneagles 232 rooms/ Fairmont, St Andrews 209 a 17% difference in occupancy between seaside and city hotel rooms) occupancy. In terms of hotel size comparators there was a 14- 16% difference between hotels with 11-25 rooms and those with 3.25 The Henderson House building is simply not large enough, 50-100 and 101+. nor does it provide the range of onsite facilities to meet the criteria of a resort style hotel or have the potential to be 3.29 In light of the hotel occupancy information it is highly developed as such and is likely to be unviable. unlikely that an additional hotel in Gullane would be in significant demand, coupled with the 14.3% decline in overnight stays in Gullane between 2009/10 - 2013/14.

FIGURE 7 SCOTTISH HOTEL OCCUPANCY

20 PLANNING CONSIDERATIONS

Development Potential 3.31 For these reasons, we firmly believe that the site is most suited to redevelopment for residential use including 3.30 In terms of site size, it is considered unrealistic to develop mainstream and affordable new build housing in association the 4.2ha site for 100 houses as well as accommodate with the redevelopment of Henderson House for retirement employment land and tourism use. To accommodate a mix flats and or serviced apartments. This, in association with of uses (housing/employment/tourism) on this site and the selective demolition of buildings/ structures on the site will number of homes identified in the MIR may necessitate the ensure that residential amenity of neighbouring properties demolition of Henderson House (option 2). SFRS, however, is protected and enhanced. The use of Henderson House as acknowledge the merits of retaining Henderson House as part retirement flats and or serviced apartments would add an of the redevelopment of the site, mindful of its heritage value element of employment on the site, in that staff would be and potential legacy for the site and the wider settlement. required to support and meet the needs of the residents. However, in order to achieve circa 100 units on the site would involve the refurbishment and subdivision of Henderson House 3.32 Even if all this was achieved via the LDP route, there are for flatted accommodation. significant implications for investment programming (Please see Programme below). If SFRS is to wait until Plan adoption before We do not think the site is physically capable of • proceeding to develop the site, this would in all likelihood be accommodating 100 residential properties, dedicated sometime in 2017 and it would no doubt take several years employment use and a hotel. following on from this for the site to be built out. Importantly, • With a focus on resort style hotels, the implications are that we have support from several housebuilder developers who the whole site would potentially be required for such a use. have stated their interest in the site and their willingness to develop the site immediately for housing, certainly building out • Even if the locational disadvantages were to be resolved, the site within the next four to five years. employment use would either be new build or located within Henderson House which does not lend itself well to modern working environments. The building has a much better fit for residential use if it was to be retained.

FIGURE 8 DELIVERY PROGRAMME

Development Plan Route

MIR publication 2014LDP PublicationLDP Examination Plan adopted

Planning Application Route

SubmissionPre of Application PAN Application Consultation Submission DeterminationSecure of Application Commencecapital receipts onPhase site 1 Complete

2014 2015 2016 2017

21 PLANNING CONSIDERATIONS

Further Considerations 3.39 The location of the site is such that it provides appropriate infill development in the settlement of Gullane and it is located 3.33 There are a number of other considerations that identify within 800m of local facilities including shops, health care the most appropriate form of development on site. These key surgeries and Gullane Primary School. The site is also served considerations are considered below: by public transport, with services to both North Berwick and Edinburgh. Provision of New Housing within East Lothian 3.40 The proposed development of housing on the site is 3.34 The provision of housing on the site contributes to the compatible with the surrounding land uses which are almost need for 11,288 houses in East Lothian over the 2009-2024 entirely residential. There are also potential benefits to the period, as set out in both SESPlan Supplementary Housing Land amenity of the surrounding area in that it is currently poorly Guidance (2014) and in the East Lothian MIR (2014). served by greenspace provision and this will be improved as a result of the development. The development will be permeable 3.35 Whist the site has an initial classification of ‘Preferred’ for pedestrians and because of its brownfield location and as set out in the East Lothian MIR, we have reviewed the site status as infill development will not result in any change to against the Housing Land Supply: Interim Planning Guidance Gullane’s defensible boundaries, or set a precedent for future (2014), used to address the current shortfall of housing in development. the area. This guidance sets out the benefits of sites that are acceptable in planning terms and that are able to deliver Giving Something Back - Henderson House Retention quickly but which are not allocated in the Development Plan for housing. The proposed site at Gullane, complies with the thrust 3.41 Henderson House, whilst not listed, is a landmark historic of the criteria set out in that document. building in Gullane that is visible on the skyline as the town is approached from the west. In light of the importance of 3.36 In terms of site effectiveness, the site is likely to be this historic building to the townscape and if agreement can substantially complete within 5 years of permission being be reached on a residential focussed solution, SFRS will seek granted. The commitment and support for the site from several to retain the House. It is considered preferable to retain the housebuilders demonstrates not only keen interest in the site building and convert it for residential use. This allows the but also commitment in terms of delivering houisng within building to be retained and protects the surrounding residential the next 5 years. The scale of the development will be less character of the area. than 200 units and would be unlikely to prejudice any further housing proposals, partially because the site is brownfield and Architectural Statement there are unlikely to be equivalent sites in the Gullane area coming forward over and above committed local plan sites and 3.42 The existing fabric of Henderson House appears to be in preferred sites in the MIR. It will not impact on the provision good condition and has been well maintained by SFRS. The of a range of effective sites as set out in SPP. Were the site to existing construction of the walls, floors and roof are such provide hotel development, there would be a significant loss that conversion and upgrade to the standards required for of housing capacity – approximately 30 units – and the hotel residential use is feasible using common modern construction portion of the site is unlikely to come forward within 5 years technology. The existing floor plan layout lends itself well to due to limited demand. accommodating residential apartments of a suitable scale. The floor plate depth of 15m, numerous windows on all elevations 3.37 The timing of this development and the needs of the SFRS and a central circulation core allows a pragmatic and relatively mean that it can come forward quickly, towards the beginning efficient division of the plan layout. The high windows, high of the next plan period, making it an attractive site in terms of ceilings, retention of original architectural features externally maintaining an effective 5 year housing land supply. and internally, as well as the attractive outlook from upper levels results in the potential for high quality and very desirable 3.38 There is adequate infrastructure to enable delivery of the accommodation. site, as outlined in the East Lothian MIR. This includes transport capacity and water network capacity. Solutions are available to ensure that there is capacity within the educational estate. The delivery of this site will not prejudice other development plan sites.

22 DEVELOPMENT OPTIONS

Gullane

4

DEVELOPMENT OPTIONS

23 PLANNING CONSIDERATIONS

DEVELOPMENT OPTIONS

Development Options

4.1 We have considered various scenarios for the redevelopment of the site. These are shown in the following three development options.

FIGURE 9 OPTION 1 FIGURE 10 OPTION 2 FIGURE 11 OPTION 3

Option 1 - Development of the site Option 2 – Development of the site Option 3 – Development of the site for residential use for residential, employment and for houses and flats tourism uses 4.2 The site has the capacity to host c.100 4.6 The site has capacity for 70 mainstream houses. 4.4 In this option the site has the capacity mainstream houses and 30 flats within to host 70 mainstream houses with Henderson House. 4.3 Summary: the Henderson House / Henderson House site retained for either a hotel or 4.7 Summary: Henderson House cleared • employment uses. • Henderson House retained (30 flats) • 100 residential units 4.5 Summary: • Henderson House could accomodate retirement flats and or serviced Hotel / employment site (0.4 Ha) • apartments 70 residential units • • 70 residential units

24 DEVELOPMENT OPTIONS

FIGURE 12 DEVELOPMENT PRINCIPALS

25 DEVELOPMENT OPTIONS

Development Principles Design 4.10 The Masterplan should be contextually driven and respond Access to the following principles: 4.8 Four points of vehicle access will be taken from: • Potential to retain Henderson House and convert to 30 units for flatted accommodation • North (Main Street) - in close proximity to the existing access • Remainder of the site redeveloped for c. 70 homes delivered through an appropriate mix to reflect the local East (C111) - at the same point of the existing access • housing market needs West (Muirfield Drive) - an access to serve just Henderson • Ensure the redevelopment of the site provides a suitable House from an existing point of access • gateway to Gullane West (Muirfield Drive) - an access into the main site from • Provide a legible and permeable street structure that a mid point between Muirfield Station (road) and Muirfield • responds positively to its context Terrace • Scale and massing should be appropriate to its context. 4.9 All access points will be linked through the site by a For example, proposed built form on Main Street should hierarchy of streets that provide high levels of pedestrian take cognisance of the four storey Henderson House while and vehicle permeability. This approach will achieve the road its eastern edge lies in close proximity to single storey link through the site which the Council has identified as a ‘steadings’ requirement of the site’s redevelopment. • Potential for view corridors to Henderson House • The appearance of the new build elements • Where possible, high quality existing vegetation will be retained • Ensure that all streets, spaces and paths are well overlooked, providing passing surveillance • Centrally located open space • SUDs provided within the lowest part of the site to allow natural drainage

26 DEVELOPMENT OPTIONS

Gullane

5

SUMMARY & CONCLUSIONS

27 planning considerations SUMMARY & CONCLUSIONS

5.1 The allocation of the site for residential development Site Effectiveness (mainstream, ‘affordable’ and retirement flats) would assist East Lothian Council in meeting its housing requirements, 5.4 When assessed against the effectiveness criteria contained promote a sustainable pattern of development in accordance within Planning Advice Note 2/2010: Affordable Housing with Scottish Planning Policy and ensure appropriate reuse of and Housing Land Audits (September 2010), the site can be a brownfield site within an established settlement boundary. considered to meet the advice of the Scottish Government in terms of establishing the effectiveness of housing sites: 5.2 The site’s redevelopment for housing would also complement surrounding uses and protect/ enhance Ownership existing residential amenity. Redevelopment for housing could take place relatively quickly and bring benefits to the 5.5 The site is in the single ownership of the Scottish Fire and local community in terms of helping to sustain local facilities Rescue Service. including local retail. The redevelopment could also bolster the local community by accommodating the changing needs of Physical existing residents and attracting new residents from a broad cross section of the population. 5.6 The site is not physically constrained and is capable of accommodating residential development. 5.3 Redevelopment of the site will result in economic benefits during the construction period and an element of 5.7 The site is not in an area identified by SEPA as at risk of local employment is likely as a result of the development of flooding in a 1:200 year event. Development of the site should retirement flats on the site. not result in a significant increase in flooding elsewhere and any increase can be mitigated through the use of SUDs on site. An initial Flood Risk Assessment can be prepared for the site following the detailed design of any future development, if required by the Council. However SEPA have stated that a Flood Risk Assessment is not required. The majority of the site is flat with some raised land around the tree planting on site. No adverse ground conditions are known of on site.

28 SUMMARY & CONCLUSIONS

Contamination Infrastructure

5.8 The site was previously used as a SFRS Training College 5.11 The site is located within Gullane and there is a bus stop on and so may have been subject to some contamination as a Main Street on the northern boundary of the site with services result of their activities, along with the storage of vehicles on running to North Berwick and Edinburgh. Buses to North site. A site investigation is required to assess any potential Berwick run every 30 minutes through the day and buses to site contamination and what remediation would be required. Edinburgh run every 30 minutes through the day, declining to However any potential contamination is not considered serious one an hour after 4.30pm. The site is also within 700m of the enough to impact on the viability or effectiveness of the site. local shopping centre of Gullane, including food shops, cafes and Gullane Medical Practice. Pedestrian linkages through the Deficit Funding site can be added, improving the permeability of the urban grain. The site is also within 1,600m of Gullane Primary school 5.9 No public funding would be required to make the site which currently has some available capacity and potential for economically viable for residential development. expansion.

Marketability 5.12 There is also available capacity for both water and waste water within the network available from Castle Moffat Waste 5.10 The location of this site within the settlement boundary of Water Treatment Facility and the Sewerage Treatment Plant at Gullane is considered to be highly marketable to prospective Gullane. purchasers of properties. A mixture of new family and affordable housing and retirement flats within the converted Henderson House can be delivered on site. The site is not Land Use considered marketable for tourism and employment uses. 5.13 Residential use is considered appropriate for the proposed There is no identified market in Gullane for such uses, site due to its location within Gullane. It is particularly suitable particularly for employment land. because of the residential development that surrounds all sides of the site.

29 SUMMARY & CONCLUSIONS

Indicative Masterplan

5.14 The indicative masterplan provides a visual interpretation of the site opportunities and constraints as well as development principles. It has been contextually driven in order to provide a piece of townscape that is appropriate to its location at a gateway to Gullane and than helps to improve connectivity across the southern part of the town.

Development Blocks

5.15 The form of development has followed a perimeter block structure with a rectilinear street structure to reflect many areas of Gullane which use legible north - south and east - west routes to provide a permeable and ultimately legible street pattern.

Access & Circulation

5.16 One point of vehicle access is provided for Henderson House with three separate access points provided for the main site. These access points connect through a grid street pattern allowing suitable vehicle and pedestrian access between the C111 on its eastern boundary and Muirfield Drive on its western boundary.

Scale & Amount

5.17 Dwellings on site will not exceed four storeys. Dwellings of around three storeys, potentially townhouses could be used to define important edges or reflect adjacent building heights and scale.

5.18 The indicative masterplan shows c.70 units, predominantly family homes, delivered through a mix which addresses local demand.

30 SUMMARY & CONCLUSIONS

FIGURE 13 PREFERRED OPTION

31 SUMMARY & CONCLUSIONS

32 SUMMARY & CONCLUSIONS

Gullane

A1

APPENDIX 1 RESPONSE TO MIR QUESTIONS

33 APPENDIX 1

Question 1: In support of the promotion of sustainable economic growth, in accordance with NPF3 and SPP, supporting the development of Aims, Objectives and Outcomes the site in a timely manner is promoted by SFRS.

Do you have any comments on the aims and objectives We also note that ELC seeks to meet housing requirements for the LDP? in appropriate marketable locations and, according to the The latest iteration of Scottish Planning Policy was published on MIR, ‘In so doing, promote regeneration and the creation of 23 June 2014 and provides updated policy principles, including: mixed communities which provide opportunities for …housing, ‘A presumption in favour of development that contributes to focusing on town centres first.’ sustainable development.’ (Paragraph 27) The SFRS acknowledges and supports the approach set out in There is also a focus in SPP on prioritising brownfield the MIR under the heading Objectives and Outcomes (albeit development before greenfield development, where possible. with reservations about the demand for employment land We note, under ‘Objectives and Outcomes’ in the MIR, that within the smaller settlements). in accordance with SPP, the Council seeks ‘To make efficient use of land, buildings and infrastructure, prioritising the Question 2: development of previously developed land over greenfield land where possible….’ Sustainability & Climate Change

The Scottish Fire and Rescue Service (SFRS) acknowledge and In terms of the approach to sustainability and climate support the principle of the identification, by East Lothian change mitigation and adaptation, section 3E of The Council, of the site of the Scottish Fire Service College at Main Town and Country Planning (Scotland) Act 1997 (as Street Gullane (Site PREF-N5) as a ‘preferred new housing amended) as well as SPP and the SDP require the LDP to allocation’ for redevelopment in the Local Development Plan follow the preferred approach. MIR (albeit with strong reservations about the inclusion of employment and tourism uses) Are there any other matters related to sustainability and climate change mitigation and adaptation that you think The college closes at the end of March 2015 with training the LDP should seek to address? being delivered from fully operational new state of the art training services/ facilities in a centralised single location at The MIR states that the LDP should amongst other things ‘… Cambuslang. Once fire service activities on the site cease, it will prioritise the use of brownfield land over greenfield land; be classified as brownfield land. For this reason, SFRS has been promote the efficient use of land, buildings and infrastructure; considering the Gullane site’s potential for redevelopment, help secure regeneration and the creation of mixed appropriate to its context, with a view to reinvesting the capital communities…help manage the use of resources including receipt from the sale of the site. In order to continue to fund ..soil…’ improvements to new training facilities, SFRS require to secure Such issues, according to the MIR should underpin the LDP’s these capital receipts during the 2015/16 financial year. spatial strategy, site selection and policy approach.’ There are significant implications for investment programming We note and support the Council’s preferred approach in the if SFRS is to wait until Plan adoption before proceeding to MIR to promote sustainability and climate change mitigation develop the site. This would in all likelihood not be until and adaptation which includes embedding the principles of sometime in 2017 and it would take several years for the site sustainable development in the LDP’s spatial strategy, policies to be built out. Importantly, we have support from several and proposals. housebuilder developers who have stated their interest in the site and their willingness to develop the site immediately for Allocation of the Scottish Fire and Rescue Service training housing, certainly building out the site within the next four to college at Main Street, Gullane (Site PREF-N5) as a ‘preferred five years. In light of the timescales involved in Plan preparation new housing allocation’ for redevelopment in the Local and the need to secure the capital receipt from the sale of the Development Plan MIR will help to support redevelopment site, the SFRS is keen to progress a planning application for proposals for a prominent brownfield site within an established redevelopment of the site at the earliest opportunity. settlement boundary. The proposed development site is an effective brownfield opportunity, that will contribute to the sustainable Question 3: development of Gullane. Development on the site can come Development Locations forward relatively quickly making it an attractive site in terms of maintaining an effective 5 year housing land supply. No Comment

34 APPENDIX 1

Question 4: More generally, the economic impact of the closure of the training college on Gullane is not likely to be significant because Town Centres those based at the training centre have had access to various No Comment facilities on site, including catering and a gym. This has meant that there have been limited reasons to leave the campus for Question 5: the duration of training courses. Planning for Employment Generally, employment use on the site is unlikely to prove attractive. There are no agglomeration benefits to locating Do you think that the review of the employment land in Gullane or economies of scale to benefit from. The site is supply should be as set out under the preferred also not located in close proximity to the strategic transport approach, alternative approach, or neither? network and to a significant extent the site’s geographic location was the reason for its closure in the first place. There is Please explain your answer. If you support neither of the a low labour pool within Gullane to draw from with a small total above options, what alternatives do you suggest? population of 2,568.

It is noted in the MIR Monitoring Statement 2014 that there is Importantly, SESPlan states that employment development in in excess of 100ha of allocated employment land. However, East Lothian should be focused around the Economic Corridor approximately 90ha of this is subject to major constraints and that stretches from Musselburgh to Dunbar in the east. Gullane there has been very minimal development of employment falls significantly outside of this area and away from the land during the current plan period; between 2006 and 2012 strategic road network. SESPlan also identifies intensification in approximately 6.25ha of employment land was taken up. In current employment locations as a more effective method of light of this, it is clear that there is very limited demand for achieving employment development: employment land in East Lothian. ‘Consolidating growth by reusing brownfield land and Site PREF-N5 at Gullane is located outwith the East Lothian intensification of development on sites within existing business Strategic Development Area (SDA) which incorporates the parks and industrial estates is one of the most sustainable east coast main rail line and the A1 Road corridor and is in the methods for economic growth.’ (SESPlan Economy Technical eastern section of East Lothian, further removed from the city Note Nov 2011, p32) of Edinburgh and the wider strategic transportation network. We are, therefore, not convinced that the site is appropriately The proposed site in Gullane does not achieve intensification of located in order to attract employment use. an existing business.

The population of Gullane is 2,568 and is significantly older than There are 102ha of employment land allocated in East Lothian. the Scottish average of 41. The average age in Gullane is 48.5 However, none of this is considered effective, as outlined by and 35.4% of the population are aged over 60 compared with a SESPlan, even within the preferred development locations with Scottish average of 23.2% aged over 60. Unemployment is also larger working populations and better links to the strategic notably low within Gullane; it stood at 2.6% compared to the roads network. If such sites are unable to come forward, it is Scottish average of 4.8% at the time of the census in 2011. unlikely that the site at Gullane will be successfully developed for business or office use. These are amongst the factors that There will be a very limited impact on the local area in terms have influenced the SFRS to relocate from this site. of job losses as a result of the decommissioning of the Fire and Rescue Service Training Centre at the end of March; the The redevelopment of the site is likely to have a significant site is not a significant generator of local jobs. Ten former low positive economic impact locally not just during the skilled jobs have been lost from staff located in the local area. construction stage but when properties are occupied. For However, we understand that these people have subsequently example: local spend in the settlement, council tax receipts as found alternative employment locally. Furthermore, serviced well as the positive impact of more people helping to sustain apartments and/or retirement flats would also generate job local community facilities and contributing to the sustainability creation for the purpose of maintenance etc. of the community, generally.

All specialist jobs based at the training college have been held In terms of the development of a hotel use on site, it is by staff located outwith Gullane and the surrounding area and noted in the 2012 ‘Employment Opportunities in the Public this has resulted in significant vehicle journeys to the site with Sector Submission from East Lothian Council to the Scottish staff traveling from as Fife and Falkirk Council areas. Government Finance Committee’ that hotel development in East Lothian should be focused on resort style hotels.

35 APPENDIX 1

Resort style hotels provide a luxury facility and offer a wide Question 6: range of facilities and activities such as spas and swimming pools. Whilst some resorts operate on a seasonal basis, the Planning for Housing majority now try to operate all year round. They tend to be Should the LDP plan for a longer term settlement larger than standard hotels and provide larger numbers of strategy to meet the SDPs housing requirements as well rooms (Gleneagles 232 rooms/ Fairmont, St Andrews 209 rooms). as help contribute to signposted need and demand for housing post 2024 (preferred approach), or should The Henderson House building is simply not large enough, nor it plan only to meet the SDPs confirmed housing does it provide the range of onsite facilities to meet the criteria requirements to 2019 and 2024 (alternative approach), of a resort style hotel or have the potential to be developed as or neither? such and is likely to be unviable. Please explain your answer. If you support neither of the There are already 3 hotels in Gullane providing 52 bedrooms, above options, what alternatives do you suggest? along with 6 B&Bs. Archerfield, a resort hotel, is located 1.5km outside of Gullane, on route to North Berwick. This hotel is In line with SPP, the East Lothian LDP should provide a generous associated with the Archfield Golf Course and provides guest supply of housing land and an effective housing land supply that bedrooms along with lodges, villas, pavilions and cottage can come forward within the first 5 years of the plan. Whilst residences spread throughout the grounds. Tourism in East we support long term planning of housing land supply beyond Lothian is mostly made up of day trippers with only 25% of 2024, this must be done with an adequate and effective supply visitors electing to stay overnight (East Lothian Tourism Strategy provided pre 2024 and with consideration for increasing the 2010-13). The number of overnight hotel stays has also declined generosity margin closer to 20% to make the provision of an in recent years from approximately 1,750,000 to 1,500,000 adequate supply more likely. between 2009/10 and 2013/14. Provision of New Housing within East Lothian – East Lothian Council last measured hotel occupancy within the Site PREF-N5 council area in 2006 and found it to be 58%. This is compared to more buoyant markets such as Edinburgh where occupancy 5.19 The provision of housing on Site PREF-N5 at Gullane sits at around 80%. would contribute to the need for 11,288 houses in East Lothian over the 2009-2024 period, as set out in both SESPlan Hotel occupancy in Scotland is seasonal and notably lower in Supplementary Housing Land Guidance (2014) and in the East both villages and seaside towns when compared with cities. It Lothian MIR (2014). is also lower when comparing hotels with between 11-25 rooms with larger competitors of 51-100 rooms and 101+. In 2013 there Whist the site has an initial classification of ‘Preferred’ as set was a 17% difference in occupancy between seaside and city out in the East Lothian MIR, we have reviewed the site against hotel occupancy. In terms of hotel size comparators there was the Housing Land Supply: Interim Planning Guidance (2014), a 14-16% difference between hotels with 11-25 rooms and those used to address the current shortfall of housing in the area. with 50-100 and 101+. This guidance sets out the benefits of sites that are acceptable in planning terms and that are able to deliver quickly but In light of the hotel occupancy information, it is highly unlikely which are not allocated in the Development Plan for housing. that an additional hotel in Gullane would be in significant The proposed site at Gullane, complies with the thrust of the demand, coupled with the 14.3% decline in overnight stays in criteria set out in that document. Gullane between 2009/10 - 2013/14. In terms of site effectiveness, the site is likely to be substantially In light of this, the development of a further hotel use in Gullane complete within 5 years of permission being granted. The does not seem likely to be necessary to service demand. support for the site from several housebuilders demonstrates not only keen interest in the site but also commitment in terms The preferred option and reasonable alternative both seem of delivering housing within the next 5 years. The scale of the unsuitable, particularly for mixed use housing sites. There is development will be less than 200 units and would be unlikely very limited demand for employment land in East Lothian. The to prejudice any further housing proposals, partially because insistence upon the inclusion of employment development on the site is brownfield and there are unlikely to be equivalent brownfield sites outwith the Strategic Development Area has sites in the Gullane area coming forward over and above the potential to negatively impact on the viability of the future committed local plan sites and preferred sites in the MIR. It will development of such sites. This is particularly pertinent to not impact on the provision of a range of effective sites as set a settlement such as Gullane where there is likely to be very out in SPP. Were the site to provide hotel development, there limited demand for further employment in the immediate area. would be a significant loss of housing capacity – approximately 30 units – and the hotel portion of the site is unlikely to come It would be preferable for East Lothian to support the forward within 5 years due to limited demand. development of housing in areas of market demand rather than limit the development potential of sites by adding a potentially The timing of this development and the needs of the SFRS unviable burden of employment land. mean that it can come forward quickly, towards the beginning

36 APPENDIX 1 of the next plan period, making it an attractive site in terms of surrounding area, as part of efforts to enhance recreational maintaining an effective 5 year housing land supply. opportunities and to seek connections with adjoining areas for the movement of people and wildlife. There is adequate infrastructure to enable delivery of the site, as outlined in the East Lothian MIR. This includes transport Our client’s proposals for site PREF-N5 at Gullane are capacity and water network capacity. Solutions are available to supportive of CSGN objectives for enhancing green ensure that there is capacity within the educational estate. The infrastructure. delivery of this site will not prejudice other development plan sites. Question 10: The location of the site is such that it provides appropriate Development in the Countryside infill development in the settlement of Gullane and it is located and on the Coast within 800m of local facilities including shops, health care surgeries and Gullane Primary School. The site is also served No Comment by public transport, with services to both North Berwick and Edinburgh. Question 16: The proposed development of housing on the site is compatible North Berwick Cluster with the surrounding land uses which are almost entirely residential. There are also potential benefits to the amenity Do you support the preferred approach to new of the surrounding area in that it is currently poorly served economic development and housing opportunities in the by greenspace provision and this will be improved as a result North Berwick cluster? of the development. The development will be permeable for pedestrians and because of its brownfield location and Do you think that all of the preferred housing sites status as infill development will not result in any change to can be delivered in the anticipated timeframe? Please Gullane’s defensible boundaries, or set a precedent for future explain why. development. Potential options have been identified for how education Question 7: capacity might be increased in the cluster. How do you think those options could be funded and delivered? Green Belt No Comment Where might any new education facilities be located if required?

Question 8: Please indicate if you support or oppose particular Countryside Around Town preferred sites, reasonable alternative sites, or other site options, and explain why? No Comment If you do not support the preferred sites, please indicate Question 9: what alternative sites you would suggest? Central Scotland Green Network Do you have any other comments on the North Berwick In terms of approach to the Central Scotland Green cluster area? Network in East Lothian, do you support the preferred Employment Land approach, the reasonable alternative, or neither? Please explain your answer. If you support neither of the above The preferred approach to new economic development is options, what alternatives do you suggest? outlined in the MIR: ‘The preferred strategy supports the retention of existing operational employment areas as well as What do you think the priorities are for the green the employment allocations of the current local plan.’ (p. 79) network for East Lothian or for your local area? This approach is not generally supported in that there is a We note that the Preferred approach in the MIR is for policies focus on the maintenance of employment sites that have been and proposals to provide protection to existing features that notably ineffective over the lifetime of the previous plan. contribute to Central Scotland Green Network objectives and This is particularly of interest in that East Lothian Council to seek to make connections between them, including in the have recognised this problem: ‘East Lothian is currently a development sites. less preferential location for attracting large scale economic development and employment opportunities’ (p. 23). The status Our client is not opposed to the concept/idea of their site of the area as ‘less preferential’ is unlikely to change because connecting with wider objectives of the CSGN and in fact of the proximity to Edinburgh and the poor connectivity of the their draft proposals for the redevelopment of the site eastern aspect of East Lothian. seek to provide for enhanced linkages between the site and

37 APPENDIX 1

Housing Land or serviced apartments would add an element of employment on the site, in that staff would be required to support and meet We note that the Council advises that the North Berwick area, the needs of the residents. including the settlement of Gullane, is not within the East Lothian SDA and because it is on the east side of East Lothian, The allocation of the site for residential development would it is not proposed as the focus for additional strategic land assist East Lothian Council in meeting its housing requirements, allocations. promote a sustainable pattern of development in accordance with Scottish Planning Policy and ensure appropriate reuse of a We also note that the MIR also acknowledges that sites outwith brownfield site within an established settlement boundary. the SDA may be considered to help meet the East Lothian housing land requirement and to help provide a range of sites The site’s redevelopment for housing would also complement of different types and sizes in different locations in order to surrounding uses and protect/ enhance existing residential maintain a five year effective housing land supply at all times. amenity. Redevelopment for housing could take place relatively quickly and bring benefits to the local community in terms The MIR comments that in such circumstances, such housing of helping to sustain local facilities including local retail. The sites may be identified if they are appropriate ones and if they redevelopment could also bolster the local community by would help to maintain a five year housing land supply. accommodating the changing needs of existing residents and attracting new residents from a broad cross section of the Supported Sites - PREF-N5 population. We support the identification of the Fire Service College (Gullane) (Site Ref. PREF-N5) as a preferred new housing Site Opportunities and Constraints allocation in the MIR. The MIR acknowledges that the site Access and Circulation presents a brownfield redevelopment opportunity suitable for housing (albeit it references employment use and tourism uses). The site is located immediately south of Main Street, the key We are confident that the site can be delivered within the next east-west route through the settlement. This road connects five years and we have housebuilder backing to take this site Gullane with North Berwick and Dunbar to the east and forward as soon as possible. Aberlady and Musselburgh to the west. There is a bus stop located immediately next to the site’s northern boundary on In accordance with the MIR, a masterplan has been prepared Main Street providing access to public transport provision with for Site PREF-N5 and included with this submission that services operating between North Berwick and Edinburgh. recommends a preferred option that shows how the site could be developed to successfully integrate with the surrounding Footpath provision, immediately north of the site on Main area and wider settlement and also importantly provide an Street, connects the site with local services and shops and the enhanced entrance to the settlement from the east whilst wider settlement including Gullane Primary School. respecting the existing townscape and sense of place. The site could accommodate 70 new build homes and 30 flats A core path (98) lies approximately 400m to the south of the (retirement flats and or serviced apartments) within the southern edge of the SFRS site. It provides links to the wider redeveloped Henderson House. green network to the east and west.

We support the identification of the site for housing There are three vehicular access points to the site: from Main development only and do not support hotel or employment Street, Muirfield Drive and from the C111 road bounding the east provision on the site. This brownfield site within the of the site. established settlement boundary, could accommodate 100 homes as proposed in the MIR. However, it would be unable Landscape / Townscape to accommodate employment use and a hotel and achieve the The site has been in use as a working SFRS training college and same number of residential units. has thus been developed. Once the college closes in march To accommodate a mix of uses (housing/ employment/ tourism) 2015 and all fire service activities on the site cease, it will on this site and the number of homes identified in the MIR may be classified as brownfield land. Redevelopment of the site necessitate the demolition of Henderson House. SFRS, however, including the removal of buildings/ structures less sensitive acknowledge the merits of retaining Henderson House as part to the historic fabric of the town provides an opportunity to of the redevelopment of the site, mindful of its heritage value improve the settlement pattern, provide greater permeability and potential legacy for the site and the wider settlement. of the built form and to provide a significant enhancement to the eastern side of the town. This is particularly important SFRS firmly believe that the site is most suited to given the prominence of existing buildings on approach to the redevelopment for residential use including mainstream settlement from the east. Henderson House, on the western and affordable new build housing in association with the corner of the site, acts as a notable landmark in the settlement redevelopment of Henderson House for retirement flats and and provides a focal point within the urban grain. or serviced apartments. This, in association with selective demolition of buildings/ structures on the site will ensure that Screening is provided by mature trees and vegetation along residential amenity of neighbouring properties is protected and the eastern boundary of the site. The southern site boundary enhanced. The use of Henderson House as retirement flats and is also largely screened from adjacent development by mature trees and vegetation. The northern and western edges of the development are prominent as part of the streetscape.

38 APPENDIX 1

Natural Heritage Education

The site is not covered by any designations of international, Gullane Primary School currently has a school roll of 209 and national or local nature conservation interest. a capacity of 227, leaving 18 spaces available within the school (capacity at 8% based on 2014 school roll). The school is also The settlement of Gullane is surrounded by agricultural located on a site with room for expansion to provide additional land on all sides. The land is a mix of Class 2 and Class 3.1 spaces as needed. Given the emphasis within Scottish Planning prime agricultural land. However, as the site is a brownfield Policy to the re-use or redevelopment of brownfield land before development within the established settlement boundary, it new development takes places on greenfield sites, we consider will not result in the loss of any prime agricultural land. The that the school requirements of this site should take priority site is predominantly covered in hardstanding except the south over other sites in the surrounding area. North Berwick High east part which is an overgrown grassed area. This does not School is at capacity, however expansion is already planned have any obvious ecological value. Mature vegetation is located on safeguarded land in order to meet the capacity needs of around the southern and eastern edges. existing programmed developments.

Providing high quality open space within the proposed site will Accordingly, it is concluded that redevelopment of the site: contribute to the improvement of the open space rating in the North Berwick Cluster. East Gullane is an area with an identified can be accommodated without adverse impacts on the lack of accessibility to greenspace and play space. However this landscape or townscape quality; could be addressed by redevelopment of the site. a suitable ‘environmental fit’ can be achieved and the setting is Hydrology capable of absorbing development in conjunction with suitable mitigation measures; There are no watercourses within or adjacent to the site. There are no areas at risk of flooding in a 1:200 year event within, or would not detract from the existing character of the near to the site. settlement, particularly due to the retention of Henderson House; Whilst there is the potential for an increase in surface water run-off as a result of redevelopment, appropriate mitigation would make positive landscape and ecological benefits at the measures could be put in place to address this issue. A local scale promoting permeability through the eastern portion sustainable urban drainage system could be incorporated of Gullane. as part of the future redevelopment of the site to handle attenuation and treatment for surface water run-off. Unsupported Sites

Surrounding Land Use We do not support the ‘reasonable alternative’ sites of ALT- 6 and ALT-7, Gullane. These Greenfield sites are outwith the The site is bounded by residential development on all sides. established settlement boundary on prime agricultural land This provides opportunities for carefully considered linkages (grade 2 and grade 3(1)). Site ALT-N6 is located south of the through the site into the surrounding urban grain, creating Garden and Design Landscape and any development here is greater permeability through the area and responding to the likely to impact on the setting of this. built form.

Built Heritage Question 18: Housing Land Requirements and Housing Land Supply There are no listed buildings on the site. There is a category B Listed gatehouse within 40m of the site and development would Does Table 26 set out the proper way of calculating avoid impacting on the setting of this listed building. how the SDP housing requirement is to be met? Please Henderson House, whilst not listed, is of some architectural explain your answer. merit and contributes to the wider townscape. Yes, the table adequately sets out the calculation of housing land supply. Service Infrastructure

Appropriate sewerage and waste water connections can be provided to the site. There is a capacity of 2,000 housing units at Castle Moffat Water Treatment Works and capacity of 333 housing units at Gullane Waste Water Treatment Works. Discussions are being sought with Scottish Water to confirm this spare capacity.

The location of existing services adjacent to the site causes no constraint to development.

39 APPENDIX 1

Question 19: Developer Contributions Question 20: Affordable Housing Quota In terms of approach to infrastructure and developer In terms of approach to the affordable housing quota contributions do you support the preferred approach, do you support the preferred approach, the reasonable the reasonable alternative, or neither? alternative, or neither?

Please explain your answer. If you support neither of the Please explain your answer. If you support neither of the above options, what alternatives do you suggest? above options, what alternatives do you suggest? In terms of approach to infrastructure and developer In terms of approach to the affordable housing quota do you contributions do you support the preferred approach, the support the preferred approach, the reasonable alternative, or reasonable alternative, or neither? neither?

Please explain your answer. If you support neither of the above Please explain your answer. If you support neither of the above options, what alternatives do you suggest? options, what alternatives do you suggest?

We are supportive of the preferred option to: ‘continue We support the preferred approach in that it maintains the with the current approach for all applications. A cumulative provision at 25%. However SPP 2014 iterates that affordable assessment would continue to be undertaken on a case by case housing requirements should not be so onerous that they basis as and when applications are made’. impact on the viability of a site and this should be reflected in the policy. SPP states: ‘Consideration should also be given to We support careful consideration and discussion of what the nature of the affordable housing required and the extent contributions are necessary and relevant to mitigate any to which this can be met by proposals capable of development development impact. with little or no public subsidy.’

40 APPENDIX 1

41 42