(LDP- STK001) Do You Agree with the Preferred S

Representation on behalf of Thomson Homes in respect of Sunnyside, Strathkinness (LDP- STK001)

Do you agree with the preferred strategy for the St Andrews Area? This Representation is submitted on behalf of Thomson Homes in respect of the FIFEplan Preferred Development Strategy for the St Andrews Area.

Thomson Homes does not agree with the preferred strategy for the St Andrews Area.

The submission made to the Main Issues Report for the development at Sunnyside, Strathkinness is for a major tourism development to serve the St Andrews Area, with housing in an enabling role to raise part of the investment to deliver the tourism project.

Thomson Homes is promoting 6.9 hectares of land at Sunnyside, Strathkinness, on the south eastern edge of Strathkinness for a bespoke leisure development comprising an antiques and collectables centre with an arts and craft village and a micro brewery.

This leisure development will be supported by residential development in an enabling role. Approximately 80 new homes for sale are required to cross fund the completion of this leisure proposal.

There is currently a deficit in tourism provision in this part of Fife outwith the visitor destination of St. Andrews. It is also understood that there are concerns with the availability of the employment land supply in the St Andrews area.

The Fife MIR confirms support for the need to deliver sustainable economic growth, and further states (page 33):

...The planning system has a significant role in supporting sustainable economic growth in rural areas. It indicates that a positive approach to new development can assist in creating the right conditions for rural businesses and communities to flourish. FIFEplan’s aim will be to enable development in all rural areas which supports prosperous and sustainable communities whilst protecting and enhancing environmental quality.

This Preferred Strategy needs to be compliant with the Council’s aim to support sustainable economic growth in rural areas.

Need for further housing land releases To identify the Preferred Development Strategy, the Council has undertaken an assessment of the housing land shortfall set out in Table 2.

The Council has indentifies a requirement for an additional 20% flexibility (or generosity) to be added to the housing land requirement for both the St Andrews and North East Fife Housing Market Area (HMA) and Cupar and West Fife HMA. This is in accord with the draft Scottish Planning Policy (SPP). For Fife (TAYplan) the annual housing land requirement would be 384 homes (132 homes for Cupar and West Fife HMA and 252 homes for St Andrews and North East Fife HMA)

The Preferred Development Strategy states that the housing land requirement for the period 2012-2024 is 4,990 homes for the Fife TAYplan area, with 4,780 homes already allocated in both Local Plans. This figure includes an allowance for windfall sites, small sites and demolitions. The consultation document states that land for a further 325 homes must be identified in FIFEplan.

TAYplan Policy 5A requires that Local Development Plan (LDP) ...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 years supply of effective housing land by 2015, to support economic growth.

Further, TAYplan Policy 5A requires that ...land should be allocated within each Housing Market Area (Proposal 2) 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. Average annual build rates are illustrated.

Therefore, time period under consideration for FIFEplan LDP is 2012 to 2024 and not 2012 to 2025. On this basis, FIFEplan Preferred Development Strategy should identify housing land requirement of 4,608 homes from 2012 to 2024 (384 homes per annum x 12 years) and not 4,990 homes as stated.

The approved Housing Land Audit (HLA) 2013 provides evidence to support the estimate of effective housing land supply to adopt. Geddes Consulting has analysed the effective supply to 2024 with completions continued from effective sites from 2020 to 2024 based on the final programming assumption in year 2019/20.

It is noted that in the approved HLA 2011 and HLA 2012, an assumption of 30 homes per annum is adopted for windfall calculation purposes. For the purposes of the housing land supply, only windfall sites should be included.

The assessment below identifies the housing land shortfall for Fife (TAYplan) and therefore the scale of housing land allocations which the Council should identify in the Proposed Plan.

Fife (TAYplan) 2012-2024 Housing Land Requirement (TAYplan SDP) (+20%) 4,608 minus Effective Housing Land Supply (Housing Land Audit 2013) 3,034 minus Windfall Allowance (30 homes per annum from 2013) 330 equals Housing Land Shortfall 1,244

The housing shortfall for 2012 to 2024 for Fife (TAYplan) is therefore 1,244 homes. Accordingly, the allocation of land for only 325 homes as set out in the Preferred Development Strategy will not meet the housing land requirement. This does not accord with the requirements of TAYplan Policy 5A.

The table below sets out the calculation of the housing land shortfall for St Andrews and North East Fife HMA. The Preferred Development Strategy housing land requirement is 3,276 homes for the period 2012 to 2025. In compliance with TAYplan Policy 5A, the housing land requirement is 3,024 homes from 2012 to 2024.

Analysis of the approved HLA 2013 confirms that the effective supply over the period 2012-2024 is 2,012 homes. This includes 220 completions from St Andrews West. The windfall allowance to adopt is 20 homes per annum.

Accordingly the housing land shortfall for the St Andrews and North East Fife HMA that must be addressed by allocations of effective housing land in the Proposed Plan is 792 homes and there is not a surplus of 13 homes as stated in Table 2.

Cupar and Howe of Fife HMA 2012-2024 Housing Land Requirement (TAYplan SDP) (+20%) 3,024 minus Effective Housing Land Supply (Housing Land Audit 2013) 2,012 (Dependency on St Andrews West – 300 homes over LDP period) minus Windfall Allowance (20 homes per annum) 220 equals Housing Land Shortfall 792

FIFEplan’s Preferred Development Strategy indicates land will be allocated at Crail (capacity unknown), Strathkinness (40 homes), Balmullo (20 homes) and Leuchars (200 homes). Part of the site at Pinkerton, Crail (CRA004A) is already allocated in the St Andrews and East Fife Local Plan for 100 homes and employment land over 12.5 hectares. The remainder of the site (CRA004B) has an area of 3.8 hectares. The capacity of this site at 25 homes per hectare (assuming all 3.8 hectares are developable) is 95 homes. Therefore, FIFEplan’s Preferred Development Strategy seeks to allocate circa 355 additional homes. Clearly this is not sufficient to meet the requirement for 792 homes for the period to 2024.

On this basis, the Preferred Development Strategy will not comply with TAYplan and matters need to be addressed to ensure that the housing land requirement is met in full.

In compliance with TAYplan Policy 5A, an assessment has been carried out as to whether the Preferred Development Strategy will maintain a 5 year effective land supply at all times. The outcome of this development strategy is dependent on progress of St Andrews West SDA.

Reporter’s findings on Issue 8 of St Andrews & East Fife Local Plan Examination concluded:

55. In summary, I conclude that the local plan has not met the structure plan requirements in full in the St Andrews HMA, as noted above. However, I do not consider this deficiency is serious, as it is relatively small, the structure plan period extends beyond the local plan period and the new strategic development plan, which will revisit strategic requirements, has now been submitted for examination.

56. Figure 4 of the council’s hearing statement shows that the 5 year rolling supply of housing land in the St Andrews HMA has a significant surplus in each of the 5 year periods from 2010-15 to 2017-22. Even when windfall and urban capacity allowances are excluded (which I have already concluded not to be justified) there are modest surpluses from 2013-18 to 2016-21.

57. I conclude that, even though there is a deficiency against the numerical requirements of the structure plan, as the 5 year rolling supply of housing land is in significant surplus in each of the years from 2010 to 2022, there is no need to make any additional allocations of housing land in the St Andrews and North East Fife Housing Market Area.

In conclusion, the Reporter made no further housing land allocations at the St Andrews and East Fife Local Plan Examination on the basis that the 5 year rolling effective supply would have a surplus.

This optimism expressed at the St Andrews and East Fife Local Plan Examination has not materialised and that the effective housing land supply for the St Andrews and East Fife HMA level is now critical.

If St Andrews West SDA continues to be delayed then the effective housing land supply for the St Andrews and North East Fife HMA will not meet the housing land requirement. The Council expects that St Andrews West will deliver 40 completions per annum for most of the LDP period. For every year there is a further delay to the delivery of St Andrews West, a further release of 40 homes on other sites will be required to make up the housing land shortfall.

The St Andrews Area lies within the St Andrews and North East Fife HMA. Further allocations in this area are required to meet the housing land requirement in full and maintain a 5 year effective housing land supply at all times.

This appraisal gives support for the use of housing as enabling development to secure the tourism project.

Does the preferred approach focus development on the right towns in this area? If not which towns should be chosen? TAYplan SDP provides strategic development guidance for the St Andrews Area and continues to support the allocations of St Andrews (Tier 2). There are no other areas identified to accommodate growth in the St Andrews Area.

Given the purpose of the Green Belt is to provide long term certainty on the future growth of the town the approach being taken in this LDP is to reject all housing and leisure proposals in the Green Belt.

The Council’s Preferred Development Strategy with regard to leisure proposals does not accord with the policy requires of Scottish Government as set out in SPP, NPF and Visit Scotland Tourism Development Framework for Scotland.

In particular, the Preferred Development Strategy fails to recognise that leisure opportunities need to be located in areas that are attractive to visitors and tourists. This means that suitable locations within the Green Belt should be allocated for leisure development – this is in accord with Scottish Ministers’ policy requirements.

Support for further housing at Strathkinness in an enabling role TAYplan SDP provides strategic development guidance for the St Andrews Area and continues to support the allocation of St Andrews West SDA (Tier 2). There are no other areas identified to accommodate growth in the St Andrews Area.

St Andrews has a strategic scale allocation which continues to be progressed through the early masterplan stages. There is also a considerable amount of brownfield development underway or proposed for the town. Together these provide sufficient opportunity for housing development for the lifetime of the Local Development Plan and beyond. Several of the sites submitted into the LDP process lie within the Green Belt. Given the purpose of the Green Belt is to provide long term certainty on the future growth of the town the approach being taken in this LDP is to reject all housing and leisure proposals in the Green Belt.

The Council’s Preferred Development Strategy seeks to continue support for the existing allocation at St Andrews West SDA. However, it is apparent that further locations to meet the housing land shortfall of 792 homes are required.

In addition to St Andrews, Strathkinness has been identified in the Preferred Development Strategy to accommodate future growth. Thomson Homes supports the identification of Strathkinness as a preferred location for further development.

Does the preferred approach focus development on the right sites? If not, from those submitted, which sites should be chosen? Thomson Homes controls 6.9 hectares of land at Sunnyside, Strathkinness (LDP-STK001) for a bespoke leisure development comprising an antiques and collectables centre with an arts and craft village and a micro brewery.

This leisure development will be supported by residential development in an enabling role. Approximately 80 new homes for sale are required to cross fund the completion of this leisure proposal.

The aspiration for this development is to be a low carbon environmentally sensitive proposal.

It is proposed that this leisure development and associated enabling development will be delivered around the end of the initial LDP period.

This further expansion of Strathkinness will be after the completion of the homes proposed at Bonfield Road (site ref: LDP-STK002) ensuring a phased approach to sustainable growth in Strathkinness. A separate representation has been made to the Preferred Development Strategy consultation for this residential development at Bonfield Road.

The Council’s Site Assessment for LDP-STK001 has been reviewed to consider the consistency of their findings as well as the evidence to support the validity of the conclusions reached.

The Site Assessment for LDP-STK001 concludes:

…This proposal is not supported by the FIFEplan strategy. Site is within the green belt and is likely to negatively impact on landscape. Scale of development too large for settlement. Transportation issues due to single point of access. Site not supported.

The Fife MIR confirms support for the need to deliver sustainable economic growth, and further states:

This proposal is compliant with the Council’s aim to support sustainable economic growth which supports prosperous and sustainable communities in rural areas. This can include land within the Green Belt.

It should be noted that the Council’s Site Assessment does not consider the tourism project and wholly focusses on enabling housing element. Further, it should be clarified that the need for 114 homes is based on 80 private homes providing the cross funding together with a further 34 affordable homes to comply with the affordable housing policy.

The Site Assessment for Sunnyside, Strathkinness does not identify any infrastructure capacity constraint regarding the scale of development proposed.

A Development Framework Report and Site Effectiveness Matrix were submitted in support of Thomson Homes’ proposals at MIR stage.

Fife Council’s Strategic Housing Investment Plan (SHIP) 2013/14 – 2017/18 confirms that Strathkinness has been designated with Pressured Area Status. This is indicative of a need for affordable homes, particularly in the social rented sector. The proposed development Sunnyside includes circa 34 affordable homes which would help to address this need. As confirmed in the attached Site Effectiveness Matrix, these affordable homes could be delivered immediately as soon as construction begins on site.

Reasons provided in the Council’s Site Assessment for not allocating the site are stated as landscape impact and location within Green Belt.

The attached Development Framework Report and revised SEA Site Assessment provide a rebuttal for the landscape concerns. It is acknowledged that all built development will have an impact on its surroundings. In this case the site is visible from the south and east. However, rising landform to the north and the existing built form to the north and west provides visual containment for the proposed development. The proposed additional landscaping measures will ensure that the development integrates with its surroundings.

Therefore, the key issue is impact on the Green Belt’s objectives.

Paragraph 159 of SPP states:

Green belt designation should be used to direct development to suitable locations, not to prevent development from happening.

Paragraph 162 states:

Green belt boundaries identified in local development plans should reflect the long term settlement strategy and ensure that settlements are able to accommodate planned growth... Boundaries should also take into account the need for development in smaller settlements within the green belt, and where appropriate leave room for expansion.

The approach is also reflected in paragraphs 49 and 50 of the draft SPP.

Clearly, the Green Belt should not be used as a tool to prevent development. Analysis of the effective housing land supply as confirmed by HLA 2013 confirms that the Preferred Development Strategy will not maintain a 5 year effective housing land supply at all times as required by SPP and TAYplan.

The housing land situation is now critical. Analysis of the Proposed Development Strategy confirms that it will not maintain a continuous 5 year effective housing land supply at all times.

Accordingly, the Proposed Plan must allocate additional land to meet the housing land requirement in full.

Strathkinness is a sustainable location, and there are no infrastructure capacity constraints that inhibit the scale of development proposed for Sunnyside, Strathkinness.

The Council’s Site Assessment of the gives a score of -3. This is in line with the average score for Preferred Sites which is -3.3. This Assessment confirms that there are no infrastructure capacity concerns that would preclude development. The proposed development would provide much needed affordable housing and employment land. In addition to the significant contribution to the effective land supply, it is considered that the release of the land from the Green Belt is justified. The revised site assessment which now takes in the tourism project revises the score from -3 to +2.

The overall concept needs to secure its allocation in the LDP to initiate the development process. Thereafter, market research will be carried out to finalise the interest in the proposed business opportunities.

Once demand and requirements have been satisfied, Planning Permission will be sought to confirm design specification and final costs. Subject to final agreement with a house builder, the enabling development will be confirmed, allowing the funding package to be structured and put in place.

It is anticipated that this programme will take at least 3 years to finalise after the LDP is adopted. This lengthy but necessary approach is necessary because the site is currently in the Green Belt.

Conclusion There is currently a deficit in tourism provision in this part of Fife outwith the visitor destination of St. Andrews. It is also understood that there are concerns with the availability of the employment land supply in the St Andrews Area. This Preferred Strategy needs to be compliant with the Council’s aim to support sustainable economic growth in rural areas.

The Council’s Preferred Development Strategy needs to have greater regard to accommodate leisure proposals in its LDP to accord with the policy requirement of Scottish Government as set out in SPP, NPF and VisitScotland’s Tourism Development Framework for Scotland.

The housing land requirement for St Andrews and North East Fife HMA is 3,024 homes from 2012 to 2024. This period is in accord with TAYplan Policy 5. Analysis of Housing Land Audit 2013 confirms that the effective supply for this period is 2,012 homes. Therefore the housing land shortfall, taking account of windfall allowance, is 792 homes.

The Council promotes a strategy that focuses attention on delivery of the St Andrews West SDA. The preferred strategy for the wider area is to provide opportunities for additional small and medium scale development that complements this existing allocation

Thomson Homes does not object to the principle of supporting the SDA.

However, the scale of housing shortfall is much greater than that anticipated by the Council and Proposed Plan will have to allocate land for 792 homes in St Andrews and East Fife HMA.

The development strategy for the St Andrews Area will not succeed unless the Proposed Plan identifies additional settlements for the release of further housing land. This provides the justification for the allocation of this project using housing in an enabling role. This is in accord with VisitScotland’s Tourism Development Framework for Scotland.

Thomson Homes is promoting the allocation of a unique leisure opportunity that would require enabling development of up to 114 homes, including 34 affordable homes (30%), at Sunnyside, Strathkinness.

The site is confirmed to meet the tests of effectiveness set out in PAN 2/2010 and is deliverable in the long term and would contribute much needed affordable homes in Strathkinness in accord with the SHIP.

Using the evidence set out in the SEA Site Assessment and the Preferred Development Strategy Site Assessment, a revised Site Assessment score is presented to the Council of +2. This takes into account the information presented in the Development Framework Report.