FIFEplan Main Issues Report - March 2013

Site Specific Representations on behalf of Stewart Milne Homes and Linlathen Land at Kilmany Road,

FIFEplan MIR January 2013 Representation of behalf of Stewart Milne Homes & Linlathen Page 1

Introduction

Stewart Milne Homes (SMH) has an option on 89 acres (36 Hectares) of land to the south of Wormit. SMH consider this to be an effective site that can provide for new strategic housing and appropriate mixed use development including potential for a new rail halt to the serve the Head area of , as well as having direct access to the A92 trunk road. The site is in an accessible location close to City that will enable the provision of additional infrastructure and facilities to serve the community of Wormit and also the wider Tay Bridge Head area.

Stewart Milne Homes have prepared the following representation and concept development framework proposing that Fife Council include this site within the forthcoming Local Development Plan (FIFEplan) for a mixed use settlement with creation of up to 200 housing units including affordable.

This representation should be considered in conjunction with previous submissions by SMH made during the initial consultation exercise for the LDP in April 2012 (Appendix 1) together with previous planning application and supporting information for planning permission in principle (Appendix 2).

We would welcome an opportunity to discuss these proposals with Fife Council and would wish to be informed of the Council‟s consideration of these and all other submissions in respect of the Local Development Plan Main Issues Report (MIR).

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The Site

The settlement of Wormit forms the western end of a larger, linear settlement that extends east into Newport-on-Tay and onto the southern landfall of the . The settlement of Wormit is included within the Dundee City Region area as established by TAYplan, together with the settlements of and Newport-on-Tay.

The site under the control of Stewart Milne Homes extends to some 36 Ha and is located to the south of the existing settlement. The site is split in 2 by Naughton Road (B946), becoming Kilmany Road, which runs eastwards and links to the A92 trunk road. The site has a direct road frontage onto Naughton Road along both its eastern and western side. The site is bounded to the southern side by dwellings located along Naughton Road, on the western side by a farm vehicle storage area, its northern side by mature scrub and rising landform and on its eastern side by maturing tree belt.

An application was submitted for the site together with land to the south of Naughton Road in July 2009. The application was refused on grounds of lack of housing land requirement and premature pending the examination of the St. Andrews and East Area Local Plan. The refusal was subsequently appealed, with the appeal dismissed on grounds of prematurity.

The aerial image below, (Figure 1), identifies the location of the proposed site outlined in red.

Figure 1

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Development Plan Spatial Strategy

Stewart Milne Homes submit that FIFEplan should adopt a flexible approach to the high level TAYplan strategy for guiding the majority of new development to principal settlements. Although it is agreed that the larger settlements are suitable for growth, we consider that the strategy should also enable opportunities for strategic growth in suitable locations that can deliver strong social, economic or environmental benefits. SPP requires that plans deliver at least a 7 year effective housing land supply at all times by allocating a variety and choice of marketable sites in sustainable locations.

TAYplan confirms that “Local Development Plans may also provide for some development in settlements that are not defined as principal settlements where this can be accommodated and supported by the settlement.

The adopted St. Andrews and East Area Local Plan sets out that the Tay Bridge Head settlements, of which Wormit is one, are important to Fife‟s connections to the north because of the cross-Tay transport links, and the shopping, business and employment relationships with Dundee and Angus. The focus has been to identify sustainable sites for housing in order to reduce unnecessary commuter traffic. The adopted Local Plan sets out that the scale of development proposed meets the need for housing and employment land and supports the case for the opening of the rail halt at Wormit in the longer term. The current number of units proposed to support this infrastructure is 147 units.

The FIFEplan Main Issues Report (MIR) sets out within Section 2, “The Planning and Spatial Strategy” that the main land allocations will continue as planned through the existing development plan, which for the North East Area of Fife consists of the TAYplan as approved at June 2012 and the St. Andrews and East Area Local Plan adopted at October 2012. This is to include all the Strategic Land Allocations, which the MIR notes are to be re-named to “Strategic Development Areas”. Fife Council consider that the planning framework through the 3 recently adopted Local Plans together with the 2 Strategic Development Plans is largely set for the plan period.

Stewart Milne Homes have promoted land for development within the settlement of Wormit through the St. Andrews and East Area Local Plan and submitted the site for inclusion and consideration by Fife Council in the continuing call for sites for inclusion within the Local Development Plan “FIFEplan”.

The spatial strategy for the north east area of Fife, which includes the strategic development area of the Tay Bridge Head, incorporating the settlement of Wormit, has not been considered within the MIR for any further development. The Strategic Development Areas (SDA‟s) are to remain as existing with the Cupar North and St. Andrews SDA‟s providing the majority of land for housing across the region. It is not sufficient for the FIFEplan to rely fully on the allocations of the previous plans and they must ensure through scrutiny that the allocations are robust and will deliver a 7 year supply of effective housing land at the end of the plan period. Within this there also requires to be flexibility exhibited so that smaller sites are available to plug any gaps if larger sites fail to deliver in the plan period. If this

FIFEplan MIR January 2013 Representation of behalf of Stewart Milne Homes & Linlathen Page 4 results in an over allocation of land then so bit it, but it will allow Fife Council to best provide the assurance to the development industry they are serious about economic recovery and kick starting the construction industry which has been sorely lacking in the local authority area for the last 5 years. Any failure on the part of the Council and Local Development Plan to provide such marketable, sustainable, deliverable sites will mean a continued lack of investment in Fife which will stifle any economic recovery.

Through the process of examination of the St. Andrews and East Area Local Plan, the Housing Land Supply for the plan area was put under some scrutiny, but the Scottish Government Reporters recommending no changes to the allocations in this particular instance on the basis that TAYplan and FIFEplan were emerging. The fact remains for the north east Fife area that given the pressures on the large strategic sites to deliver large and expensive infrastructure prior to, or at least simultaneously to development, the projects are unlikely to be delivered within the first 3 years of the Development Plan period, leaving the housing delivery mechanism within FIFEplan severely short and unable to meet their housing delivery targets.

A greater spread of smaller sites across the region will enable development to come forward within the timescales set out by the Local Plan, but with the existing strategy, the unit numbers and infrastructure required are currently undeliverable.

This is backed by Scottish Governments commitment to increasing the amount of housing delivered in identified in Firm Foundations.: The Future of Housing in Scotland (2007). This confirms (pg.12) that the Government believes that the rate of new housing-building can, and must, increase if Scotland‟s housing needs are to be met. Jim McKinnon‟s letter to Heads of Planning in October 2010 set out to Planning Authorities that an effective 5 year housing land supply was now more important than ever to ensure the development industry had a choice of effective, deliverable sites to allow them to deliver essential housing in line with Government targets. The Chief Planner urged the Heads of Planning to set flexible and realistic targets.

The Government‟s aspirations for Scotland, set out in National Planning Framework 2 (December 2008) and reflected in targets for greater economic and population growth, imply higher overall household growth than current projections indicate and that planning should reflect this, to ensure a „generous‟ supply of land for housing.

Scottish Planning Policy (SPP) also confirms throughout that the planning system should deliver a generous supply of housing land in the right locations that is effective, deliverable and contributes to the maintenance of at least a 5 year housing land supply at all times.

It is evident that providing a generous amount of housing land with a view to increasing the rate of supply is a key intension of Scottish Government Policy.

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FIFEplan MIR however states, that due to the recent adopted nature of the 3 Fife Local Plans, much of the content of these plans will remain unchanged.

TAYplan states in Policy 5: Housing (pg.17) that “Local Development Plans shall: ….Allocate land which is effective or capable of becoming effective to meet the housing land requirement up to year 10 from the predicted date of adoption, ensuring a minimum of 5 years effective land supply at all times, and work towards the provision of a 7 year supply of effective housing land by 2015, to support economic growth. Land should be allocated within each Housing Market Area through Local Development Plans to provide an effective and generous supply of land to assist in the delivery of in the order of 26,000 units up to year 2024 across TAYplan”.

No such reference exists within the FIFEplan MIR, in fact the MIR is completely devoid of any specific reference to the Cupar and St, Andrews Housing Market Areas. No references are made to preferred sites, other than those as existing within the adopted Local Plan, nor have the Council chosen to look at possible development alternatives to these sites. Housing Land delivery has been set at 110 per annum for the Cupar and North HMA and 210 per annum for the St. Andrews and East Area HMA. The lack of strategy set out within the MIR prevents any meaningful comment coming forward.

Fife Council is reliant on the allocations made within the adopted Local Plan being delivered within the Plan timescales. Should a proportion of the committed or proposed allocations which make up the total within the north east area of Fife, then the maintenance of a 5 year supply could be jeopardised, contrary to the requirements of SPP and severely hindering the realisation of the wider LDP strategy that seeks to plan for growth and economic recovery.

It is submitted that the allocation of a healthy supply of land for new housing will increase the rate of delivery of development through providing a range and choice of land for developers, in turn stimulating the development industry and the local and regional economy.

The implementation of the previous strategy through continued support for committed sites is accepted. However, these should be supplemented by additional sites, over and above those existing that are effective and have developer support. This will ensure that in the event that the committed sites to not deliver and demand has increased following easing of lending restrictions, then need and demand can be met instead of a continued approach to deliberately stifle the market by not over allocating in line with policy and advice from the Scottish Government Chief Planner.

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Context

The proposed development site covers a total area of approximately 36 Ha (89 acres). It consists of 3 land parcels split by Naughton Road (Figure 2).

Figure 2

Approximately 17.3 Hectares are located to the north and 18.1 Hectares to the south of the main road. The entire site is currently arable farmland (Greenfield) and comprises a total of four agricultural fields. A broad appraisal of the wider landscape character has been undertaken to understand relationships between built form and landscape that then define the character and inform a site development strategy. This assessment can be viewed in full within Appendix 2. All the fields that constitute the site are currently maintained within agricultural use and as such have no significant vegetation. The fields to the south of the B946 are generally bounded by post and wire fences and the field to the north is bounded by low scrub and existing residential development.

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Transport/Accessibility

The preferred strategy of the MIR is to locate development in areas that promote good access and relate to the main strategic connections in the Plan area including the Tay Bridgehead. Emphasis within the Local Plan is on promoting development where homes, jobs and services are in close proximity, and, where possible, accessible to public transport to minimise the impact of commuting.

The site is well situated strategically and has good links to the A92 and the Tay Bridge Head. The land is also within walking distance to the proposed new rail halt site, making the site very accessible.

Employment

The site is within easy commuting distance of Dundee City Centre and associated employment opportunities. Wormit is also within commuting distance by a variety of means of transport to Glenrothes and Kirkcaldy to the south which offer good employment opportunities within central Fife.

Education

Initial discussions have been held with Fife Council‟s Education Department. The site would fall within the catchment of Wormit and Newport Primary Schools. At the time of the discussions Wormit primary school was functioning at 75% capacity and Newport at 80%. The rolls are falling in both and that trend is likely to continue in the coming years. The secondary school within the sites catchment is Madras College. Predictions on role for the school indicated that by 2015 it would be operating at 76% capacity.

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Opportunities and Constraints

Access and Circulation

The site benefits from 2 suitable vehicular access points, both of which will be from Naughton Road, which splits the site. Indicative access points for first phase is shown within the indicative Framework Plan shown (Figure 3).

Figure 3

Natural Heritage

There are no national environmental designations within, or close to the site. The current use of the site as agricultural land means it is unlikely to have any flora or fauna of significant ecological value.

Hydrology

There are no watercourses within the site.

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Infrastructure

Initial review of the surrounding road network and service infrastructure suggests that strategic growth could be absorbed with minimal additional requirements. Further detailed investigations will be undertaken in due course. Whilst the initial phase of development would be seeking residential use, future phasing on the land to the south would present opportunity for mixed use development of an appropriate and feasible nature.

Justification

Wormit is an important strategic town being one of the 3 Tay Bridge Head Settlements together with Tayport and Newport-on-Tay. It is in a strategic location with excellent transport networks with bus services in addition to the A92 as well as the future proposed rail halt proposed by Fife Council, which land is already identified and safeguarded for. The housing site (Wormit Sandpit 02) allocated within the adopted St. Andrews and East Area Local Plan is a constrained brownfield site, yet is allocated for 135 units and is unlikely to be delivered within the timescales set out within the Plan. Housing, including affordable housing is essential to ensure that the town‟s key services and facilities are maintained, and that there is development continuity in this key strategic location.

A preliminary Landscape & Visual Impact Assessment has been undertaken to inform the supporting information submitted with the outline application for the site in 2009. Further studies will be undertaken to inform the preparation of a Masterplan for the site. This would highlight any necessary landscape mitigation that may be required.

Further development could result in enhancement to public transport serving the area with the introduction of a further bus stop on Naughton Road with the potential scope for bus services being diverted through the site if desired in the fullness of time. A Traffic Impact Assessment prepared in support of the outline application demonstrates that no net detriment is caused to the network.

Adequate water and waste water provision is available to serve the scale of development proposed. This is confirmed by reference to Scottish Water‟s Asset Capacity Plans. Electricity, gas and telecom services are all available to service the development with adjacent to the site.

In terms of education provision, capacity exists at both Wormit and Newport Primary schools and secondary education at Madras College. This would ensure maximum use of education facilities in the settlement.

There are no known archaeological, ecological or landscape issues which would constrain the development of the site.

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Phasing

The first phase of 200 units would be delivered over the initial plan period, setting a minimum of 40 units delivered per year. Land outwith the initial phase could be delivered within second phase of the LDP. This would ensure continuity of build and enable the delivery of key infrastructure such as the rail halt.

Conclusion

Wormit, together with Newport-on-Tay and Tayport are strategic towns and serve as important links to the City Region of Dundee.

It is essential that further housing land as well as appropriate mixed use commercial development land is identified within Wormit through the Local Development Plan. The sites within Wormit provide the opportunity to provide much needed housing and appropriate mixed use commercial land alongside recreational space, open space and strengthened strategic landscaping. The site is in an accessible location and accessible by walking, cycling and public transport as well as the private car.

There are no known infrastructure constraints which would limit the development of the site. The availability of spare water and drainage capacity would also suggest that the site should be developed in order to take advantage of that capacity in preference to sites elsewhere which may require drainage provision or enhancement.

Accordingly, on the basis of all of the above, it is respectfully requested that this site be included in the emerging Local Development Plan for immediate development for residential purposes and appropriate mix use commercial development.

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