Angus Local Development Plan: Main Issues Report Consultation Responses Part 1 Committee Draft January 2015 Contents Part 1 Introduction Page 1 Chapter 2 Page 3 Chapter 3 Page 5 General Page 6 Question 1 Page 8 Question 2 Page 32 Chapter 4 Page 47 General Page 48 Question 3 Page 50 Question 4 Page 61 Question 5 Page 76 Question 6 Page 86 Question 7 Page 95 Chapter 5 Page 107 General Page 108 Question 8 Page 124 Question 9 Page 130 Question 10 Page 134 Question 11 Page 152 Question 12 Page 160 Question 13 Page 171 Chapter 6 Page 179 General Page 180 Question 14 Page 188 Question 15 Page 198 Question 16 Page 200 Question 17 Page 206 Question 18 Page 211 Question 19 Page 216 Chapter 7 Page 219 General Page 220 General Responses Page 225 Part 2 Chapter 8 – Arbroath Page 259 General Page 260 Question 20 Page 266 Question 21 Page 268 Question 22 Page 273 Chapter 9 – Brechin Page 277 General Page 278 Question 23 Page 279 Question 24 Page 281 Question 25 Page 283 Chapter 10 – Carnoustie and Barry Page 285 General Page 286 Question 26 Page 297 Question 27 Page 300 Question 28 Page 304 Chapter 11 – Forfar Page 321 General Page 322 Question 29 Page 326 Question 30 Page 331 Question 31 Page 335 Chapter 12 – Kirriemuir Page 345 General Page 346 Question 32 Page349 Question 33 Page 356 Question 34 Page 362 Chapter 13 – Monifieth Page 373 General Page 374 Question 35 Page 377 Question 36 Page 381 Question 37 Page 383 Chapter 14 – Montrose, Ferryden & Hillside Page 386 General Page 387 Question 38 Page 392 Question 39 Page 394 Question 40 Page 402 Chapter 15 – Edzell Page 406 General Page 407 Question 41 Page 410 Question 42 Page 422 Chapter 16 – Friockheim Page 429 General Page 430 Question 43 Page 432 Question 44 Page 437 Chapter 17 – Letham Page 440 General Page 441 Question 45 Page 443 Question 46 Page 446 Chapter 18 – Newtyle Page 448 General Page 449 Question 47 Page 451 Question 48 Page 458 Introduction Following an initial awareness raising exercise undertaken between 5 November and 23 December 2010, the Angus Local Development Plan Main Issues Report was published for consultation between November 2012 and January 2013. At their meeting on the 5th March 2013, Angus Council Infrastructure Services Committee noted an overview of the range and scale of consultation response to the Main Issues Report, agreed that late responses be taken into account and agreed that all the responses to the Main Issues Report and draft Environmental Report were made publicly available on the Council we site (Report 137/13 refers). A substantial number of responses were received to the Main Issues Report consultation; 186 individual responses giving rise to circa 860 separate comments, rising to 955 when considering late responses accepted by the Council. This statement sets out the Council’s response to all representations received during the Main Issues Report consultation, and those received since the consultation closed. Consideration of the consultation responses has informed the contents of the Proposed Angus Local Development Plan agreed with amendments at the Angus Council meeting on the 11 December 2014 (Report 501/14 refers). Full copies of all responses received are available on the Council’s website: http://archive.angus.gov.uk/ldpmainissuesreport/Responses/default.html This document is split into two parts. Part 1 includes all representations received on Chapters 2 to 7 (questions 1 to 19) of the Main Issues Report and general comments received on the document or its appendices, whilst Part 2 includes all representations received on the settlement specific chapters (questions 20 to 48). For each comment received, the document sets out a unique representation number, the relevant Main Issue, Question number or answer to the question, the Organisation, representee or agent making the representation, and any comment as well as the Council’s response and recommendation. Where similar comments have been submitted, these have been grouped together and a single response has been given to avoid repetition. If there is no response or recommendation immediately following a comment, then this can be found at the end of the grouping of comments. Groups of comments are delineated by a line like this: The document is structured in the same way as the Main Issues Report, and responses are presented in the order of the chapters and questions within that document. Chapter 1 of the Main Issues Report was a Preface, and no questions were posed as part of the Chapter. There were therefore no representations received in relation to this chapter, and this document starts with representations received on Chapter 2 of the Main Issues Report. 1 2 Chapter 2 3 Chapter: 2 Introduction Main Issue: Question: 0 Answer: Representation: 780/001 Organisation: Nathro Wind Farm Ltd Agents: Jones Lang LaSalle Comment: Support the Main Issues identified in paragraph 2.2 of 'Renewable Energy Generation' and 'Reducing Green House Gas Emissions.' These are consistent with the UK and Scottish Governments carbon reduction and renewable energy generation targets, to which Angus Council requires to contribute. Response: Support noted. Recommendation: No change as a result of this submission. Angus Councils policy response to these issues will be addressed in the Proposed ALDP Proposed Plan. 4 Chapter 3 5 Chapter 3 - General Representation: 762/001 Organisation: MBM Planning & Development Consultants Ltd Representee: Mr Mark Myles Comment: MBM Planning note that the monitoring work undertaken in the preparation of the MIR has shown that population decline in the more remote rural areas of Angus has generally reduced and in many cases has reversed over the past decade or so. Whilst MBM Planning acknowledge that the strategy will require support to be given to developing sites within existing villages to help support these rural service centres, the council’s housing in the countryside strategy and policy is equally important in helping to sustain and grow the rural population and economy. The current adopted development plan policy allows for greater opportunities for housing in the countryside within the remote rural areas (identified as Category 2 Rural Settlement Units) but that policy is now considered to be dated and no longer justified. Paragraph 3.23 of the MIR notes that ‘with population recovering in these areas and with changes to service provision being more obviously influenced by changes in society rather than by local development…’ we would therefore support the alternative option which is to remove the current two tier approach to countryside housing and treat all parts of them Angus countryside in an equal fashion. Even the argument that is put forward in the MIR (paragraph 3.23) for maintaining the current approach of providing greater opportunities in the remote areas which states that ‘given that household size is likely to decline in the future, so that a greater number of new homes would be required to maintain a stable population’ actually provides another reason as to why there should be no two tier approach and that the new homes that are required, can be accommodated across all of the rural areas. The single policy approach for housing in the countryside is also fully endorsed by Scottish Planning Policy (paragraphs 92-96) which state that ‘Development plans should support more opportunities for small scale housing development in ALL rural areas, including new clusters and groups, extensions to existing clusters and groups, replacement housing, plots on which to build individually designed houses, holiday homes and new build or conversion housing which is linked to rural businesses or would support the formation of new businesses by providing funding. Opportunities to replace rundown housing and steadings, and to provide limited new housing along with converted rehabilitated buildings, should be supported where the new development is designed to fit in the landscape setting and will result a cohesive grouping. Response: Comment noted. This representation supports a single tier countryside housing policy approach across the Local Development Plan area. Recommendation: No change. The policy approach to countryside housing development will be incorporated into the Proposed ALDP and related Supplementary Guidance. This representation will be taken into consideration in developing the proposed plan. Representation: 797/002 Organisation: Fife Council Representee: David Wardrope 6 Comment: 2nd sentence: This would depend on the scale of new housing. A modest number may have no effect at all on services and facilities whilst more substantial numbers would. Response: Comment noted. The scale and location of new housing promoted through the Proposed ALDP will take account of a range of site specific factors, including the availability and capacity of local services and facilities. Recommendation: No change Representation: 797/001 Organisation: Fife Council Representee: David Wardrope Comment: Suggest that the term “the strategy will be to avoid conflicts with….” be changed to “the strategy will be to complement…”, if used in later documents. Representation: 899/001 Organisation: Aberdeenshire Council Representee: Piers Blaxter Comment: The change in emphasis in rural policy towards concentration of development in service centres may result in displacement to Aberdeenshire settlements. This is not perceived as being a serious issue. Response: Comment noted. Recommendation: No change to the Proposed ALDP Spatial Strategy as a result of this representation 7 Chapter 3 – Question 1 Do you support the preferred options for the LDP spatial strategy and its implementation, as shown in Tables 1, 2 and 3? Please explain your answer and give details of any alternative option that you think is better. Main Issue: Question: 1 Answer: Yes Representation: 762/003 Organisation: MBM Planning & Development Consultants Ltd Representee: Mr Mark Myles Comment: Support the reasonable alternative approach set out in Table 2 : The strategy for rural Angus : housing in the countryside (page 13) of the MIR.