SESPLAN JOINT COMMITTEE
6 DECEMBER 2010 ITEM 4
MINUTE of MEETING of the SESplan JOINT COMMITTEE held on 27th September, 2010 at 2.00 p.m. ------
Present: - Councillor J. Beare (Convener), Fife Council Councillor A Martin, Fife Council Councillor J. Lowrie, City of Edinburgh Council Councillor J. Mowat, City of Edinburgh Council Councillor P. McLennan, East Lothian Council Councillor R. Imrie, Midlothian Council Councillor C. Riddell-Carre, Scottish Borders Council Councillor V. Davidson, Scottish Borders Council Councillor R. de Bold, West Lothian Council Councillor M. Day, West Lothian Council
Apologies:- Councillor B. Turner, East Lothian Council Councillor D. Milligan, Midlothian Council
In Attendance:- Mr. J. Bury, City of Edinburgh Council Mr. J. Inman, City of Edinburgh Council Mr. P. Collins, East Lothian Council Mr. I. Glen, East Lothian Council Mr. K. Winter, Fife Council Mr. A. Ferguson, Fife Council Mrs E. Mair, Fife Council Mr. I Johnson, Midlothian Council Ms. J. Long, Midlothian Council Councillor N. Watson, Scottish Borders Council Mr. I. Lindley, Scottish Borders Council Mr. M. Wanless, Scottish Borders Council Mr. S. Field, West Lothian Council Mr. C. McCorriston, West Lothian Council Mr. I. Angus, SESplan Mrs A. Miles, SESplan Mr. L. Harrison, SEStran
1. WELCOME
The Chair welcomed Ian Angus to his first meeting of the Committee following his recent appointment to the post of Strategic Development Plan Manager. Ian gave a brief outline of his previous experience.
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CFP/MISC MINS & WRKNG GRPS/Min SESplan Joint Com 270910 CD
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2. MINUTE
The Minute of Meeting of 26th March, 2010 had been circulated.
Decision
The Committee approved the Minute.
3. PARTICIPATION IN CONSULTATION ON MAIN ISSUES REPORT
There had been circulated a report by the SDP Manager advising of participation in the consultation on the Main Issues Report, summarising the responses to consultation and outlining the process for consideration of the responses. Ian Angus highlighted the key points of the report and advised that the number of responses received had now risen to 218.
Decision
The Committee noted:
(a) the participation in the MIR consultation and the level of response received; and
(b) that a report summarising the responses would be submitted to a future meeting of the Joint Committee for consideration.
4. STRATEGIC DEVELOPMENT PLAN PROJECT PROGRESS UPDATE
There had been circulated a report by the SDP Manager providing an update on the progress of the project, summarising key issues to be addressed in developing the Proposed Plan and proposing a programme, including key milestones, towards the delivery of the Proposed Plan. During discussion concern was raised at slippage in the original timescales leading to an amended timetable being proposed. It was suggested that the SDP Manager and the Clerk should investigate whether the programme could be amended to allow for ratification of the proposed plan by partner authorities following approval of the final proposed plan by the Project Board and prior to approval by the Joint Committee. It was also noted that Scottish Borders Council had concerns in regard to loss of farm land to forestry and that any consultation on this should not be confined to the Forestry Commission and Scottish Natural Heritage.
Decision
The Committee:
(a) noted the progress of the Strategic Development Plan in the period March to September 2010 and proposed work carried out under the work streams outlined in the report; and
(b) approved the timetable but delegated the SDP Manager to make appropriate amendments, in consultation with the Chair and Vice-Chair, as regards the timing of ratification by the Joint Committee and the partner authorities, pending the outcome of further discussions with the Clerk.
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5. OPERATING BUDGET 2009/10 - FINAL (TWELVE MONTH) POSITION
There had been circulated a report by the SDP Manager presenting the SESplan Operating Budget 2009/2010 final position.
Decision
The Committee noted the Operating Budget 2009/2010 Final Outturn position.
6. OPERATING BUDGET 2010/11 - (THREE MONTH) FINANCIAL REPORT
There had been circulated a report by the SDP Manager presenting the SESplan Operating Budget 2010/2011 forecast outturn position based on information available at August 2010.
Decision
The Committee:
(a) noted the Operating Budget 2010/2011 Forecast Outturn position as at August 2010; and
(b) agreed that revised three year budget proposals be submitted for consideration to the December meeting.
7. JOINT COMMITTEE ROTATION, MEETINGS AND INDICATIVE PROGRAMME
There had been circulated a report by the SDP Manager setting out the rotation for the Chair and Vice Chair of the SESplan Joint Committee, together with confirmation of the dates for forthcoming meetings and an indicative programme of papers to be put to the Committee for consideration. Ian Angus advised that, following the earlier approval of the revised timetable, the Members’ Briefing scheduled for 26th October, 2010 would now be postponed until January, 2011.
Decision
The Committee noted the report.
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3
SESPLAN JOINT COMMITTEE 6 DECEMBER 2010
For Decision For Information
ITEM 5 – MAIN ISSUES REPORT CONSULTATION SUMMARY Report by SDP Project Manager
1. INTRODUCTION
1.1 This paper reports on participation in the consultation on the Main Issues Report, outlines the key themes and issues emerging from the responses and notes the way forward on considering the submissions in developing the Proposed Plan. A report which noted the responses received and gave an indication of emerging issues was considered at the SESplan Joint Committee on the 27 September 2010.
2. BACKGROUND
2.1 The consultation period ran between 31st May and 27th August 2010. Responses were invited by email or written submissions to answer the 30 questions contained within the Main Issues Report and on the Monitoring Statement and Interim Environmental Report.
2.2 During the consultation period, 18 exhibitions were held. In addition, Community Councils and other groups were invited to workshops in each Local Authority area and seven such events were held (two workshops in Midlothian). The workshops attracted 127 participants in total. A workshop for private sector representatives was also convened.
2.3 The consultation documents were available to view in libraries and planning receptions throughout the area and on the SESplan website. The documents could also be purchased from the SESplan office. All details of the consultation and how to respond were also presented through a dedicated website.
4 3. RESPONSE TO THE CONSULTATION
3.1 A total of 218 submissions have been received. The majority of responses are from the development industry including landowners, developers and their consultants. East Lothian Council, Fife Council, Midlothian Council, Scottish Borders Council, three neighbouring authorities, twenty-four Community Councils, Scottish Government and all of the Key Agencies, with the exception of the Health Boards, have made submissions. Fifteen responses were received from members of the public.
3.2 The member authorities have reviewed and summarised the submissions which relate primarily to their area. The SESplan Core Team have summarised submissions from Key Agencies and those which are not principally concerned with Strategic Growth Areas. Appendix 1 sets out the main points or themes raised in each submission.
4. THEMES AND ISSUES
4.1 All of the views set out in the submissions will be considered in the preparation of the Proposed Plan. The following paragraphs outline key themes and issues raised in the submissions including the opinions expressed on the options set out in the Main Issues Report.
Overall Vision
4.2 The submissions indicate a significant divergence of views on the Vision in the Main Issues Report. A number of repondents consider that the Vision lacks ambition and is too generic. Some respondents considered that a more long-term view should be promoted while others supported the principle of the Vision but questioned whether it will be achievable. There was some support for a vision which promoted a strategy that will meet housing demand.
5 Housing
4.3 Many landowners, developers, investors and their representatives including Homes for Scotland and the Scottish Property Federation, consider that the preferred scenario of ‘market recovery’ is overly pessimistic and the Plan should set out a more positive approach to recovery and growth. Many of these respondents would prefer to see the alternative approach of ‘High Growth’ progressed through the Proposed Plan as it is more in line with General Registers of Scotland (GRO) projections.
4.4 The Scottish Government outlined concerns that the Proposed Plan may not deliver the generous and effective supply of land required by Scottish Planning Policy (SPP). The Key Agencies including Scottish Water, SEPA and SNH support the preferred ‘market recovery’ scenario. SNH also suggested that a lower growth scenario should be considered in the formulation of the Proposed Plan.
4.5 The development of brownfield land and the preferred approach as set out in the Main Issues Report is largely supported. A large number of respondents considered that the SDP should set a benchmark of 25% for affordable housing but still allow Local Development Plan’s flexibility to set targets according to local circumstances and should not constrain development.
Infrastructure
4.6 The Scottish Government note that the Proposed Plan (and action programme) will need to clarify who has responsibility for delivering specific elements of infrastructure.
4.7 The preferred approach of linking future development to the provision of essential infrastructure is largely supported in the representations, including the Scottish Government. A number of respondents noted that development can fund infrastructure and if growth is to occur development needs to be located where this is achievable.
6 4.8 However, concern was expressed with regards to funding and implementation. It was noted in several responses that a clear strategy for the delivery of essential infrastructure and services is required. Some suggestions include that where significant financial contributions are necessary to facilitate development, local authorities should accept a degree of flexibility in how these are implemented as relying on the private sector to provide essential infrastructure is no longer a viable option.
Transport
4.9 The preferred approach to Transport is supported by the majority of respondents. However, it is considered that:
more detail is required to properly guide developments; new development which is in highly accessible locations and / or makes use of the existing infrastructure should be more strongly supported; access to an improved public transport network is made available and maintained; and a road network which supports business and social connectivity is essential.
4.10 The Scottish Government agree with the proposed policy approach on transport as it is in line with SPP but they consider that further work is needed to identify key transport infrastructure necessary to support development. Any station proposals should only be considered within the context of the Government’s investment hierarchy, set out in the Strategic Transport Projects Review (STPR). In determining station proposals it must be demonstrated that they are able to generate a positive business case. In the absence of such an assessment Transport Scotland would wish to see all references to proposed new stations removed from the emerging plan and either removed from, or their status clarified within Appendix C of the Monitoring Statement.
4.11 SEStran supports the preferred approach as it is in line with the Regional Transport Strategy.
7 Economy
4.12 The preferred approach for economy is generally supported, particularly in terms of proposals at the Edinburgh Waterfront and along the Fife Forth Corridor. Common issues which are raised in the submissions are ensuring:
that the appropriate scale of new development can be delivered to meet economic growth requirements over the plan period; co-ordination between the provision of land for housing and employment; that economic development is focussed in areas where people want to live and is supported by public transport services; and recognition that much of land allocated through the current development plan has not been developed due to marketability and delivery issues.
Environment / Resources
4.13 Overall, most of the preferred approaches set out within these sections of the Main Issues Report are supported with the exception of the Green Belt on which there is a divergence of opinion.
Green Belt
4.14 The majority of the development industry and several landowners support the alternative approach and argued that the Green Belt should not hinder sustainable economic growth and boundaries must adhere to SPP. In this context it is suggested that the extent and shape of the Green Belt may need to be reconsidered, particularly if the ‘High Growth’ scenario was to be pursued through the Proposed Plan.
4.15 The Scottish Government noted that in the preferred approach only the setting of the broad area of the Green Belt is mentioned and the need is not established, which is a requirement of SPP. They also note that the preferred approach does not refer to setting the policy for future development in the Green Belt.
8 Green Network
4.16 The majority of responses broadly support the proposals for the Green Network. However, several note that further clarification is required on issues such as the delivery of the Network.
Climate Change
4.17 The Scottish Government expressed concern that the Main Issues Report does not deal with climate change as a cross-cutting theme and that it does not provide clear strategic spatial direction for key areas such as renewable energy or waste. SEPA have similar concerns on these issues. Those who commented on the preferred approach to renewable energy generally believe that it is appropriate. However, some felt that the principles for climate change and energy need to be more clearly linked to SPP requirements. It has been suggested that the Proposed Plan should include a sustainable development policy and a recognition that there are wider opportunities for energy generation including biomass.
SEA
4.18 SNH, SEPA and Historic Scotland, the ‘Consulting Authorities’ on Strategic Environmental Assessment, commented on the Interim Environmental Report and how to progress this through the Proposed Plan stage. The Consulting Authorities also indicate their commitment to assist SESplan in developing the SEA for the Proposed Plan.
5. GOING FORWARD
5.1 Further work is underway in the reviewing and analysis of the submissions and all submissions will be considered in the development of the Proposed Plan. While all of the submissions will be considered in the preparation of the Proposed Plan, it may not be possible to address all concerns raised by respondents. It is important to note that some of the issues raised through the consultation may not be relevant to the Strategic Development Plan.
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5.2 The SESplan Board, Steering Group and Team will continue to work collaboratively with the key stakeholders including the Key Agencies and representatives from the house building industry and other respondents to clarify the issues and, as far as possible, address these in the preparation of the proposed plan.
5.3 All submissions are available on the SESplan website and hard copies can also be viewed at the SESplan offices and at each individual Member Authority. Respondents have been advised that all submissions are available on the website. A forthcoming SESplan newsletter will be circulated to all respondents and others registered to receive information on SESplan and will include further details on the themes emerging from the consultation. A paper summarising how each issue provided in the submissions has been considered in the preparation of the Proposed Plan will be brought to a future meeting of the Joint Committee.
5.4 A log of ‘Lessons Learned’ in the consultation process will be completed to inform continuing engagement and involvement in SESplan including how the publication of the Proposed Plan will be undertaken. It is expected that the ‘Lessons Learned’ will be reported to the 7 March 2011 Joint Committee.
6. RECOMMENDATION
6.1 It is recommended that the Joint Committee notes:
a) The summaries of the responses to the MIR consultation.
Ian Angus SDP Project Manager Email – [email protected] Tel – 0131 5245158
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Report Drafted By: Annmaree Wood Planner Email – [email protected] Tel – 0131 5245168
APPENDICES Appendix 1 – Summary of Consultation Responses to the Main Issues Report
BACKGROUND PAPERS SESplan Main Issues Report, May 2010 SESplan Monitoring Statement, May 2010 SESplan Interim Environmental Report, May 2010
Policy Implications None Financial Implications None Race Equalities Implications None Gender Equalities Implications None Disability Equalities Implications None
11 Item 5 - Appendix 1
Ref no LPA Respondee Summary of Comments
Strategy proposed will not lead to market growth, instead it will lead to development and jobs stagnation. Negative controls on regional housing systems have much wider direct and indirect impacts on local and regional economies. Essential that SESplan meets housing requirements in full and must follow lead taken by Aberdeen/shire and Moray Structure Plans in order to do so. Fully endorse 'infrastructure MIR-ID076-067 CEC CALA led' approach to future development. In this context, settlement of Currie is a highly sustainable location with local education capacity and capacity within the local drainage network. An appropriate level of growth commensurate with the size of the village could improve local facilities and bring other significant local community benefits such as environmental improvements. Fully endorses five key aims in SDP. Such aims could be incorporated at a local level in the future development at Currie.
A key role of the SDP should be to stimulate economic development opportunities, and recognise the critical role that housing plays in helping achieve this. As well as sustainable locations for new development, sufficient housing choice available at the right price is critical to wider economic success. A much more realistic position needs to be taken, particularly housing land. The MIR does not acknowledge that the majority of existing strategic land allocations are reliant on investment in infrastructure and that this will require significant developer MIR-ID088-079 CEC Cardross Asset Management contributions. A contingency needs to be considered in the SDP strategy allowing for an alternative scenario to be considered. As well as concerns over programming and deliverability, there is also a need to recognise, as the SPP does, that the level of or direction of growth may not simply reflect past trends. In order to achieve the SDP‟s wider vision for West Edinburgh, a review of the greenbelt is likely to be necessary. A more strategic review should be carried out. Principle of promoting West Edinburgh as a key growth location is generally supported. SDP should give greater prominence to West Edinburgh and this should be identified as the principal priority growth area.
Support market recovery scenario but more justification is required. Do not support preferred strategy for all strategic policy areas or the scale MIR-ID100-091 CEC Cockburn Association and direction of growth. Corstorphine Community Difficult to disagree with proposals but implementation at local level would be contentious. Main concerns are traffic volumes, incursions into MIR-ID040-031 CEC Council Green Belt and changing character of the environment. Supportive of principle of growth across SESplan area. Offer no support for decision not to seek additional housing land over the 2008 - 2019 period. This does not accord with the previously identified aspirations of the Scottish Government as set out in SPP. Significant consideration must be given to the clear failure of many development sites to date. Should SESplan continue to rely on heavily constrained sites, there is a risk of diverting investment away from more deliverable locations. Allocations and policies must be flexible and have the MIR-ID116-107 CEC Cramond and Harthill Estates ability to respond to change. Must acknowledge that some of the sites included are not capable of contributing to a minimum 5 year effective land supply. City Region has other viable, deliverable sites which could come forward to meet demand and our clients are keen to progress land at Maybury Road as it is becoming clear that much of the development sites relied upon will not be developed in the timescales envisaged. SESplan must release housing land in the short term and must look to sustainable, deliverable sites to do so.
Support vision but continuing to support existing areas is flawed, as unlikely to come forward. No assessment of new strategic land or existing areas and express concern that no reasonable alternatives brought forward. Support high growth scenario, but a true high growth scenario exceeding GROS should be considered. Low growth scenario not appropriate/ High growth scenarios would not prejudice ability to MIR-ID050-041 CEC Dalmeny Estate bring forward existing sites. Do not consider sustainable approach to identification of land has been applied. Do not support distribution of development set out. Continued need for green belt but need reference to precise form and boundaries at LDP level. Do not support identification of land close to airport. Do not support additional development south east of Edinburgh, instead requirement should be redistributed, focused on Edinburgh. Do not support further housing at Blindwells. University is keen to ensure that emerging Development Plan reflects the aspirations of the institution and its significance in terms of economic activity. Keen to ensure that the SDP provides an appropriate level of support for higher education development. There is an opportunity to introduce more direct references to the economic benefits of the higher and further education sector through development of MIR-ID221-222 CEC Edinburgh Napier University specific policy guidance to provide appropriate encouragement for further development and enhancement of facilities. MIR as drafted does not contain sufficient policy options to provide appropriate encouragement for higher education development, recognising the strategic importance and valuable economic contribution of this sector.
Page 1 of 40 12 Item 5 - Appendix 1
Ref no LPA Respondee Summary of Comments SDP strategy not appropriate and should accommodate a greater degree of flexibility to ensure that sites are removed from the established housing supply if there is no realistic expectation of the site being developed for housing in the plan period. The earlier development of and MIR-ID035-026 CEC F & C Reit Asset Management the identification of additional suitable housing sites within the Strategic Growth Areas will be required in order to ensure that the total housing land requirement is met. Supports vision but need stronger commitment to Green Network. Market recovery supported. However, considers that it is unlikely cost of Grange / Prestonfield MIR-ID239-240 CEC infrastructure could be met. Retail strategy supported but no consideration of possibility of reducing retail outlets in view of changing retail Community Council patterns. SESplan needs to be adaptable in time of economic uncertainty and acknowledge this. The concept of 'local' needs to be taken into account. Need to emphasis importance of decentralising sustainable energy production, support local businesses and recognise importance of mixed MIR-ID104-095 CEC Greener Leith development. Lack of detail on how the plan will promote a modal shift away from car use. Need stronger support of community owned renewable energy facilities. MIR does not discuss options for replacing Cockenzie. The MIR fails to explore alternative scenarios better matched to more modest and realistic outcomes. Priority needs to be given to modernising existing infrastructure in settlements before taxpayers subsidise new MIR-ID075-066 CEC H Toberman developments. New education requirements should be fully secured by developers. Existing SP allocations were bullish yet completions were less than expected. Therefore, allocations were too high. Support redevelopment of Leith docks but support revision of waterfront masterplan especially to increase family housing. Whilst recognising that other strategic town centres in the SESplan area will continue to perform a strategic function and should also be supported accordingly, Edinburgh city centre has not benefited proportionately from the investment that has taken place in other shopping facilities in recent years. SESplan should be clear on the primacy of Edinburgh city centre as the regional centre and supported accordingly through discharging development management functions, to ensure that improvements to its offer will enable it to compete effectively with MIR-ID230-231 CEC Henderson Global Investors other major shopping locations. Paragraph 8.11 should be updated to reflect that outline planning consent was granted in 2009 for redevelopment of the St James Quarter. The text should also be expanded to acknowledge that such proposals offer the principal opportunity to secure development plan objectives, to sustain and enhance the city centre as the regional focus for shopping and related activities. Supports the preferred approach of continuing to support the regeneration and redevelopment of the city centre.
MIR fails to take cognisance of three key factors influencing spatial planning in the near future; Peak Oil, the Scottish Governments „Main Transport Trends‟ and the Climate Change (Scotland) Act 2009. Since the point of economic growth is to stimulate economic activity, a simple analysis of greenfield versus brownfield development demonstrates that brownfield land creates more jobs without any real cost to the economy. Additionally, creating new urban land on the periphery of the city requires more transport costs, causes increased travel patterns, and takes green planting out of the environmental cycle, losing its inherent carbon capture benefits. There is an alternative vision for the MIR-ID073-064 CEC J Grounsell SESplan area which is to support and promote higher density development on existing urban land. Promoting higher densities can increase land values to the point where existing low density development can be redeveloped viably as new housing or other uses, in a more sustainable form, and with minimal infrastructure costs. By restricting rather than furthering land supply, and refashioning the city to higher densities and keeping its compact form it is possible to create a sustainable, attractive, vibrant region which builds on its strengths and fosters economic growth. The proposed development areas around Edinburgh Airport are not more strategically important, nationally, than Edinburgh city itself, and they should be postponed until economic recovery has been proven elsewhere.
Market recovery most realistic but must include flexibility. Must embrace opportunity of more rapid return to growth. Concerned infrastructure constraints will slow housing growth. Include policy to consider sites not identified in housing land supply if supply fails to deliver. Developer contributions must factor in viability. Plan should safeguard Edinburgh City centre, so other development elsewhere does not prejudice it. MIR-ID141-132 CEC John Lewis Partnership Brownfield development should follow SPP approach. No affordable housing benchmark figure or site by site basis only. Greenbelt should allow scope for growth. Important waterfront retail development is limited so it does not compete with city centre. Important Scottish Borders makes contribution to growth.
Page 2 of 40 13 Item 5 - Appendix 1
Ref no LPA Respondee Summary of Comments
Supports „preferred approach‟ but with qualifications. Clear need for Edinburgh City to release more land for residential development especially for family accommodation. Even more urgent if the accepted SESplan housing target is 45,000 houses not 27,000 as currently proposed, in the period to 2032. However, suggested that to locate housing in close proximity to business use as suggested in the MIR would not be appropriate. The most appropriate location would be to separate the residential community from business uses and locate it on MIR-ID117-108 CEC John Swan and Sons Limited land focussed in pods adjacent to the City Bypass and the Union Canal as set out in the Edinburgh Garden District proposals. This area could be removed from the Edinburgh Greenbelt without adversely affecting the purposes of the remaining Greenbelt. There would be merit in this development coming forward in advance of 2019 to meet the 45,000 house target. No doubt the existing Core Development Area in the city at the Edinburgh Waterfront and the South East Wedge continue to struggle to deliver housing. There is an over reliance within CEC to deliver housing product in certain areas, e.g. the Waterfront, that are clearly suffering from marketability problems. Recent housing audits demonstrate a severe slowdown, this arose pre-credit crunch. A significant change in the level of expectations of delivery, numbers and housing type is required to ensure that a housing product does eventually come from such MIR-ID197-188 CEC Mactaggart & Mickel Homes Ltd locations. As compensation, land must be allocated elsewhere to meet shortfalls arising. Allocation of Greenfield land in peripheral locations is welcomed but insufficient numbers identified. Sufficient greenfield land must come forward to meet requirements and provide a range and choice of housing locations. Good to begin with the infrastructure, but constant use of word 'corridor' when identifying areas of development is unfortunate. Suggests to the layman, ribbon development. Accessibility seems based on roads which suggests increased private motor travel, although the emphasis in the document is on trains, trams and other public transport. Much in the document is unexceptional and takes some account of present Marchmont and Sciennes constraints. Lower growth forecast retains sense of a City rather than a conurbation, a concept we feel is vital. But, is the vision actually MIR-ID025-016 CEC Community Council achievable? Diagrams and illustrations not always helpful and sometimes idiosyncratic. Diagrams in chapter 4 are impossible to read as axes are not labeled and designated sites in figure 7 are confusing. Relationship between SDP and LDP needs to be better understood, particularly in relation to brownfield development. It is vital to preserve the sense of a city despite necessary expansion and the preservation of the Green Belt is critical here.
Must include locations that can be made accessible by future transport projects. Endorse the sustainable travel approach of focusing housing growth in areas identified for future economic growth. SESplan area has the environmental capacity to accommodate significantly higher growth. To assume no further allocations to 2019 but not to compensate for growth during that period thereafter is considered unrealistic. It is unsustainable to rely wholly on large scale strategic allocations. Reliance on brownfield development, however, is not an appropriate means MIR-ID203-194 CEC Messrs Paton and Muir by which to meet development targets. Recognition must be given to the fact that much of the land allocated for business through the current Development Plan has not been developed. MIR must better recognise the relationship between housing numbers and jobs creation. SPP is clear on the purposes of green belt and need to allow for settlement expansion. The A8 corridor from Gogar to Ratho is one of the most sustainable locations for new development on the edge of the city.
Vision and spatial strategy objectives generally welcome however the MIR fails to recognise the important role that it has in promoting the investment required in the area in the short to medium term to assist with economic recovery. Housing need and demand have been under estimated, housing supply has been over estimated and there is a reliance on a range of developments which are either constrained or MIR-ID077-068 CEC Miller Homes unviable due to financial constraints on infrastructure provision. Most up to date GROS figures should be used as the basis for setting the housing land requirement, however in line with the SPP requiring a generous supply of housing, we would promote an aspirational level of growth higher than GROS. Concerned that Balerno has been omitted from MIR and consider it merits inclusion in SESplan. Glenpark Estate represents an opportunity for SESplan to consider an alternative location for development in the short to medium term. Housing supply - Regular failure to maintain a minimum 5 year housing land supply in what is now deemed SESplan's jurisdiction. Emerging Plan should positively avoid inheriting the constraints of its predecessor(s) and relate to 'delivery' of a 'generous' supply of housing with a policy framework which promotes rather than hinders development and avoid reiterance of the past supply and demand inflationary influence MIR-ID055-043 CEC Mr P Philip and Mrs E Philip on the market. Balerno - Considered that the site promoted represents a logical area for natural inclusion within the settlement boundary of Balerno offering a sustainable residential opportunity for low rise detached family housing with dedicated affordable provision, mirroring the Scottish Government's key objectives for housing. Proposed site is technically and economically readily deliverable in the short to medium term.
Page 3 of 40 14 Item 5 - Appendix 1
Ref no LPA Respondee Summary of Comments
Housing requirements - Suggested that the emerging plan is based on accurate and up-to-date statistics on population growth and projected households. The foregoing tables are based on the 'market recovery' scenario and ignore backlog which is at odds with Government directive. If the MIR preferred development strategy were adopted by the Plan, such infers no land release before 2019 and does not address the 'generous supply' as articulated by the SPP, notwithstanding the demonstrated non-compliance of the provision of an effective 5 Mr Peter Heatly and Mr Robert MIR-ID054-045 CEC year supply under the current ELSP. Strongly suggested that the release of further Greenfield land beyond the numbers quoted in figure 12 Heatly will be required prior to 2019 if projected housing need and demand is to be met and ensure delivery of the 'vision' purported in the MIR. Balerno - Identified site represents a logical area for natural inclusion within the settlement boundary of Balerno offering a modest development of low rise detached family housing. Proposed site is technically and economically readily deliverable in the short to medium term, offering geographical choice to the family market making use of the sites excellent public transport links to the City Centre and beyond.
The amount and phasing of new development is inadequate to achieve the vision. The MIR does not identify a genuine high growth scenario contrary to government policy of a generous supply. The MIR does not address the housing deficit left by the previous SP. Some committed development areas will not be viable in the short/medium term and alternatives will be required. where infrastructure is affordable MIR-ID033-024 CEC Murray Estates development should fund it. Where no feasible alternative funding will be required. SDPs should not set affordable housing benchmark, this is an issue for LDPs. Large abstractions from the green belt at west and South East Edinburgh should be promoted. The Edinburgh Garden District mixed use development provides an opportunity to make a major contribution to SDP requirements.
The idea of increasing sustainable economic growth is welcomed but a greater emphasis needs to be placed on frequent review process. Endorse preferred approach to infrastructure, especially the provision "in partnership and negotiating with Development Industry". Delivery mechanisms need to be explored as part of the preferred approach. Agree with preferred approach where development should be guided MIR-ID115-106 CEC New Ingliston Ltd towards accessible locations. Agree with Preferred Approach to set a broad framework directing LDP Strategies to promote critical points in highly accessible and sustainable locations. Support the development of mixed use development in accessible places as a priority rather than just safeguard land for a single use. Supports green belt land release in West Edinburgh. The presumption against new housing in the city centre raises concerns - there is the option of redeveloping vacant office blocks into housing. Adequate education provision could be maintained by providing family housing. Transport provision should be driven by development and not vice versa. Strongly support the tram. A comprehensive bus and tram system should encourage new city centre New Town and Broughton MIR-ID135-126 CEC housing, particularly affordable housing where car ownership is minimal. The linking of Leith with the city centre will make Leith viable and Community Council attractive centre. Support rebalancing the disproportionate business rate structure of Princes St. Controls should be stricter in terms of the quality of shop fronts and signage. Flood prevention work along the Water of Leith needs to be a priority. Support the committed development subject to the maintenance and enhancement of World Heritage Site. The vision is generally supported, along with it's role in driving LDP's forward to ensure opportunities to encourage investment are not missed MIR-ID165-156 CEC Park Lane Management Ltd through strategies that safeguard land at the expense of investment opportunity and development facilitation. The preferred approach to infrastructure is supported. MIR-ID056-047 CEC RBS Generally supports preferred approach. Wish to play our part in supporting future development and economic growth in the Region.
Disagrees with preferred approach of using reduced GROS figures. Not justified. Proposed programming of no growth until 2019 and limited MIR-ID175-166 CEC Seed & Co growth to 2024 is damaging to the economy. Supports higher growth scenario. Suggests extensions to existing allocations should be examined particularly where development has commenced. Promotes a housing site to east of Almondhill at Kirkliston.
Page 4 of 40 15 Item 5 - Appendix 1
Ref no LPA Respondee Summary of Comments
Spatial strategy supported and welcome identification of South East Edinburgh as a strategic growth point for housing and other uses. This correctly reflects the attributes of the area in respect to existing employment centres and transport infrastructure connections. Already commitment to build upon these attributes through improvements to the public transport network (e.g. Orbital Bus Project) and further strategic economic land provision at the Bioquarter and Shawfair Business Park. The Drum provides an excellent opportunity to accommodate required housing development for approximately 2,500 homes, mostly for families within an attractive landscape framework. Homes provided will assist in meeting substantial shortfall in housing within the City and beyond and will help stem the out-migration of MIR-ID029-020 CEC SEEDco families from the City. Do not support phasing or scale of development preferred by MIR. As evidenced by Lothian Housing Land Audit 2009, there will be a shortfall over the Structure Plan period of 19,000 units to 2015. It would appear as if future supply of housing has been over estimated and future demand under estimated. Approach contradicts Scottish Planning Policy which seeks the provision of a generous supply of housing land. Recommend work is urgently undertaken to re-evaluate the SESplan housing requirement, particularly for the period until 2019. It can be anticipated that this will mean that the South East Edinburgh growth area has to come on stream before 2019 and that its capacity for housing could be significantly greater than 2,650 units.
Spatial strategy remains too reliant on the delivery of major allocations contained within existing development plans. With regard to para 19 of SPP, the current review process presents an opportunity to comprehensively reassess existing policies / strategies and as such, should include a robust review of the effectiveness of the approaches outlined within the 3 current Structure Plans and associated allocations. A significant proportion of the committed housing land supply relates to major allocations such as those within South East Edinburgh, the East Coast Corridor and the West Lothian Corridor. Such sites are inherently fraught with 'deliverability' difficulties (e.g. multiplicity of ownerships, MIR-ID172-163 CEC Stewart Milne Homes up front infrastructural provision, land instability and ground contamination constraints. Current economic climate has exacerbated the 'non- deliverability' of such sites, particularly in the short to medium term. Greater consideration should be given to meeting housing land requirements through the phased extension of existing settlements in a given growth area, thereby reducing up-front servicing costs and supporting local services and facilities. Particularly important to reduce over-reliance on existing major allocations and enable the delivery of sustainable sites. Critical that as a minimum, alternative sites come forward for consideration where it can be demonstrated that such allocations are no longer effective. This is important regardless of which growth scenario is eventually pursued.
Comments submitted in support of identification of South Queensferry as sustainable location for future growth and specifically land to south- west of settlement. Greater consideration given to need to actively encourage investment and stimulate economic growth. Support high growth scenario. Recommend additional housing land allocated to meet demand across all areas and suggest 25% flexibility applied to MIR-ID133-125 CEC Taylor Wimpey housing land requirements to take account of delays in sites coming forward. Support extension of existing settlements as solution to accommodating growth. Need for policy provision at strategic level to allow alternative sites to come forward where demonstrated that existing strategic allocations are no longer effective. Green belt designation of land at South Queensferry should be reassessed.
Welcomed that Waste Management is recognised as a regionally significant activity. SDP offers a forum in which to integrate waste MIR-ID227-228 CEC Zero Waste management priorities with other regional spatial planning policies. Reference to Millerhill site in the text is noted. Supportive of vision, aims and principles however renewable energy should be identified as one of key economic sectors. Role of ports industry and renewable energy sector should be represented alongside other industry related topics. No strong view on growth scenarios. Support approaches to sustainable development, promotion of economic growth areas, retail hierarchy, brownfield land, affordable housing, natural heritage, green network, green belt, forestry, city centre. Supportive of approach to Edinburgh's Waterfront but flexibility should allow MIR-ID058-049 CEC, FC Forth Energy interim uses here and at other proposed major development areas. Believe Fife Forth Corridor offers a wider opportunity than expansion of container freight and should recognise potential for manufacturing and renewable energy support industries at Methil and Burntisland. Considerable potential for economic development at the Port of Rosyth and surroundings as well as at Energy Park at Methil and Burntisland docks. Wider opportunities for energy generation should be recognised and key role of ports noted. Role of large scale biomass in future energy mix of area should be noted. Should not be undue focus on developer contributions to provide infrastructure.
Alternative approach, the higher growth scenario is supported. Sufficient flexibility in policies will be needed to achieve this. High growth MIR-ID133-124 CEC, FC I & H Brown expansions should not undermine committed allocations. Support and promotes additional growth potential at North Dunfermline.
Page 5 of 40 16 Item 5 - Appendix 1
Ref no LPA Respondee Summary of Comments
Support key aims with clarification added on meeting demand both in terms of quality and quantity and in full but vision must be more proactive in delivering land for housing and employment. Fully support priority to continue delivery of infrastructure projects committed through other plans and priority to make best use of existing and proposed infrastructure and support priority to maximise accessibility and sustainable development by directing location of new development to reduce travel although believe preferred approach to this should be extended to include locations that can and will be made accessible. Support approach to sustainable development, brownfield land and green network. Support approach that seeks to focus future housing in areas identified for future economic growth but do not support market MIR-ID202-193 CEC, FC Mrs N Bowlby recovery approach. Relationship between housing numbers and jobs must be netter recognised. Believe more proactive approach is required to housing and economic development than that provided by market recovery. Support high growth scenario as a minimum. Need to ensure more generous supply of land for new housing. Do not believe MIR complies with requirement to meet housing need in area in full. Believe green belt needs to be re-examined to provide fro high growth. Commend approach to develop policy framework for LDP to bring forward land required based on availability of infrastructure and support investigation of delivery mechanisms. Land to south west of South Queensferry proposed as example of how settlement could expand.
Comments relate to landholdings in vicinity of proposed southern landfall of Forth replacement crossing. Supportive of vision subject to main strategic employment locations being well linked to existing and proposed main infrastructure. Support aims of plan. Not supportive of market recovery and believe high growth could be easily accommodated and plan must provide for the household need of area in full. Relationship between jobs and housing needs to be better recognised. Support approaches to sustainable development, linking MIR-ID207-198 CEC, FC Mrs N Bowlby development to provision of infrastructure, guiding development to accessible locations - if it includes those which can and will become accessible and brownfield development. Re-examination of greenbelt required to allow city region to fulfill potential. Opportunity should be given to existing settlements with capacity to expand and meet growth requirements and resolve potential infrastructure issues. Should recognise that South Queensferry and southern bridgehead capable of accommodating significant economic growth.
Foundation of SESplan is infrastructure and transport. Planning must firstly be about people and communities - infrastructure and transport should be subservient elements. Supportive of vision but should be specific to SE Scotland, believe aims may not be achievable. Believe Queensferry and District energy to be key issue which should be equal to priorities of transport and infrastructure. Support approaches to housing land supply, Community Council and accessible locations, brownfield land, natural heritage, green belt, development in countryside, renewables, minerals, agricultural land, MIR-ID065-056 CEC, FC Queensferry Business flooding, Edinburgh City Centre. Supportive of West Edinburgh approach but believe alternative to also be an option. Believe scale of Association regeneration at Waterfront to be misplaced and support alternative approach to Fife Forth and Midlothian Borders corridor, retail. Not supportive of approach to strategic economic growth areas. Transport must be in keeping with scale of development in South East Edinburgh. Coordinated approach required to West Lothian corridor. Infrastructure strategy needs refined to reflect the locality.
Blindwells site is not suitable for the proposed number of houses. Drainage/flooding and access/traffic has not been adequately addressed. East Lothian is being asked to take too many houses to sustain quality of life, with too much emphasis on inappropriate locations. There should be a mixture of locations. The green belt places undue pressure on other areas. Growth should be curtailed until infrastructure has been provided. There are not enough jobs in East Lothian to cope with growth. There is too much emphasis on accessibility to Edinburgh MIR-ID125-116 ELC Anna Berry and on the western part of East Lothian. More planning required as empty industrial premises in East Lothian. Retail should not be focused on Edinburgh city centre due to lack of parking. East Lothian is being singled out for too much energy production and windmills are damaging tourism; more use should be made of tidal power. Agricultural land and water will be important resources in future; flooding control is totally inadequate. Tourism is vital to Edinburgh but trams project has ruined this. Support West Edinburgh approach, limited development supported in South East Edinburgh to check whether this can be sustained.
Page 6 of 40 17 Item 5 - Appendix 1
Ref no LPA Respondee Summary of Comments
Objection in the strongest possible terms to the Market Recovery scenario. As the economy and housing market recovers demand and in- migration will increase. The most logical scenario is for high growth, a more realistic and desirable strategic aim. This is fully backed up by the GROS (2008) figures, which project a 17% increase in population in the period between 2008 to 2033. The high growth scenario should include built in flexibility to cater for any unpredictable changes. Existing committed allocations identified in the development plan would not be comprised by the identification of additional land for housing in the emerging SDP. Regard should be had to additional sites that could be delivered to meet any shortfall whilst planning for growth, via robust justification/demonstration, or that would be suitable for safeguarding as a deliverable option in the later part of the SDP lifespan. The proposed priority locations must be reassessed to take account of a high growth scenario. Broad locations suitable for large scale development, which can be served by highly accessible modes of transport, should be supported and identified in the emerging SDP. The East Coast Corridor requires a greater proportion of additional land to cater for the projected need and demand in this area, given its proximity to Edinburgh and existing transport infrastructure. East Lothian‟s principal towns and surrounding areas i.e. Musselburgh/Wallyford, are highly accessible areas in terms of proximity to major road and rail networks. The MIR-ID122-113 ELC Ashfield Commercial Property identification of a further 3,000 units at Blindwells, is wholly inappropriate and to state that there is additional capacity for 750 units at existing settlements is purely speculative. It would be more appropriate to disperse the additional 3,000 units throughout the East Lothian Corridor, and direct it towards areas which are well serviced by public transportation and where there are proposals to upgrade infrastructure i.e. the Musselburgh/Wallyford area. The loss of greenfield land within the green belt which is of low agricultural value and where development would not adversely impact on the landscape setting and character of the site itself, would not be a departure from sustainable development principles. Furthermore, the development of greenfield sites adjacent to built-up areas can often have a significant positive effect on an urban area i.e. economic, physical and social rejuvenation. Greenfield sites should be favoured when more specific brownfield land deliverability issues, such as the cost of the land remediation, clearly suggest that brownfield land alone cannot deliver housing to the required level, and prime agricultural land should be developed in circumstances where there is a strategic requirement to deliver a specific land use over the plan period. The SDP should provide a sound basis upon which the respective local planning authorities within the region can prepare policies in relation to affordable housing. The emerging SDP must recognise that it would be wholly unacceptable to seek a significant increase in infrastructure contribution levels from private developers as result of this recent cut in Government funding.
GROS projections should be used in the calculation of housing land requirements - they should not be artificially altered without firm justification on planning grounds. The Housing Land Audit requires to be updated and the effectiveness of sites contained therein critically reviewed, with particular reference to the strategic sites identified in the Edinburgh and Lothians Structure Plan. The GROS projections coupled with a 15% flexibility factor should form the basis for the calculation of housing land requirements to take account of uncertainties in the delivery of the existing land supply and to facilitate future completions in line with the Scottish Government‟s previously stated aspirations of developing 35,000 houses in Scotland per annum. Blindwells should not be identified as a potential location for an additional 3000 houses given the deliverability of the current allocation is yet to be proven and is unlikely to be so in advance of the SDP being approved. In the MIR-ID129-120 ELC Bett Homes event of Blindwells failing to deliver it is considered that there are a number of other settlements in East Lothian which are capable of supplementing the housing land supply through the delivery of other sites. The proportion of housing units directed towards the Scottish Borders part of the East Coast Corridor should be reduced and redirected to East Lothian due its proximity to Edinburgh and its superior public transport connections. It is critically important that the SDP sets out clear requirements for the development of new housing in the area through a through assessment of demand, need and the existing housing supply; that there is a choice of locations identified for new housing throughout the area; and that the locations chosen for new development are sustainable in every sense of the word with a particular emphasis on enjoying good access to public transport facilities. Agents client has interests in land to the west of Longniddy for which a plan is supplied. Considers more housing allocations are required, and allocations should be made before 2019. Considers further review on Green Belt boundaries is required and greenbelt releases should be made in accessible locations. There should not be blanket 25% affordable housing MIR-ID136-127 ELC Bett Homes requirement from new housing development in SESplan. Promotes sites in Eskbank, Musselburgh and Haddington that can be delivered in the short term.
Page 7 of 40 18 Item 5 - Appendix 1
Ref no LPA Respondee Summary of Comments
The importance of tourism for the economy should be recognised throughout the plan, and it should have its own section. The plan should recognise the special character of tourism: as a destination, it may not be possible to avoid use of the private car; there may be a need to MIR-ID177-168 ELC Bourne Leisure locate on sites in the countryside or the coast; flooding issues should be balanced with the wider benefits tourism brings and consider the need of some facilities to locate on waterfront or coastal locations, in particular to allow for the improvement or expansion of existing sites.
This response promotes the retention close knit smaller communities, stating that these types of communities bring benefits to health and well being. It is concerned that the vision would make the surrounding areas of Edinburgh into suburbs which are not conducive of these types of communities. It agrees with the aims in principle but that they should have less emphasis on commuting and more work opportunities being available locally. It is supportive of the preferred approach to strategic spatial development. It is generally supportive of the preferred approaches for strategic policy areas, with the exception of economic development, town centres and affordable housing where the alternative approaches are supported. It is supportive of renewables but feels that the draft does not adequately confirm what would be the extent of commitment by developers. Regarding forestry it questions the use of wood as fuel and for export thinks this negates the benefit of trees to the environment and makes more sense for trees to be of scenic value and for sustainable wood being used for building and crafting materials in our country. In relation to the scale and direction of growth it supports the preferred approach for Edinburgh City Centre, Edinburgh Waterfront and West Edinburgh. It supports the alternative approach for the South East Corridor as this would not allow any further expansion into the Greenbelt and the alternative approach for the Fife Forth Corridor, Midlothian Borders Corridor and West Cockenzie and Port Seton MIR-ID234-235 ELC Lothian Corridor for reasons of health and well-being in which smaller communities can work better together and develop. It also supports Community Council the alternative strategy for the East Coast Corridor citing the reason for this in order that East Lothian remains primarily farmland, small villages with emphasis on small businesses and green tourism thus supporting health and well being. Whilst supporting the principle of a new settlement at Blindwells a number of concerns are raised. These include negative impacts upon surrounding communities due to increased traffic on already congested roads during the long construction phase and on completion of the development; cost of setting up and running new emergency service facilities, schools and health care and concern about increased pressure on existing facilities if these were not provided at an early stage in the development; concern about ground conditions including stability, flooding, contamination and gas pipes. Concern is also raised that the size of the proposed settlement is commercially motivated rather than being driven for the specific housing required (affordable housing for those on waiting lists) and about design and conditions of planning consent - feeling of social engineering - high density living with less personal space which leads to mental health problems, more anti-social behaviour and crime. Also raises the questions of how can services and amenities be maintained and staffed in a new settlement when existing communities are threatened with cuts to services. It concludes by asking „is Blindwells the way to go?‟
GROS projections should be used in the calculation of housing land requirements - they should not be artificially altered without firm justification on planning grounds. The Housing Land Audit requires to be updated and the effectiveness of sites contained therein critically reviewed, with particular reference to the strategic sites identified in the Edinburgh and Lothians Structure Plan. The GROS projections coupled with a 15% flexibility factor should form the basis for the calculation of housing land requirements to take account of uncertainties in the delivery of the existing land supply and to facilitate future completions in line with the Scottish Government‟s previously stated aspirations of developing 35,000 houses in Scotland per annum. Opportunities for housing development in addition to those identified in West and South East Edinburgh must be provided to maintain the required effective supply of land. Range of house types must be allowed and less MIR-ID164-155 ELC Cruden Homes reliance of meeting housing requirements from flatted developments. Blindwells should not be identified as a potential location for an additional 3,000 houses given the deliverability of the current allocation is yet to be proven and is unlikely to be so in advance of the SDP being approved. In the event of Blindwells failing to deliver it is considered that there are a number of other settlements in East Lothian which are capable of supplementing the housing land supply through the delivery of other sites, such as in Gullane. The proportion of housing units directed towards the Scottish Borders part of the East Coast Corridor should be reduced and redirected to East Lothian due its proximity to Edinburgh and its superior public transport connections. It is critically important that the SDP sets out clear requirements for the development of new housing in the area through a thorough assessment of demand, need and the existing housing supply; that there is a choice of locations identified for new housing throughout the area; and that the locations chosen for new development are sustainable.
Page 8 of 40 19 Item 5 - Appendix 1
Ref no LPA Respondee Summary of Comments Sufficient housing land should be allocated to allow for fast economic recovery. Integrated public transport is important. Local Authorities MIR-ID144-135 ELC Drum Mhor Caravan Park should set their own affordable housing contribution. In the East Lothian area the alternative approach of dispersing housing allocations is supported.
GROS projections should be used in the calculation of housing land requirements - they should not be artificially altered without firm justification on planning grounds. The Housing Land Audit requires to be updated and the effectiveness of sites contained therein critically reviewed, with particular reference to the strategic sites identified in the Edinburgh and Lothians Structure Plan. The GROS projections coupled with a 15% flexibility factor should form the basis for the calculation of housing land requirements to take account of uncertainties in the delivery of the existing land supply and to facilitate future completions in line with the Scottish Government‟s previously stated aspirations of developing 35,000 houses in Scotland per annum. Blindwells should not be identified as a potential location for an additional 3000 houses given the deliverability of the current allocation is yet to be proven and is unlikely to be so in advance of the SDP being approved. In the MIR-ID130-121 ELC Dunalastair Estates Group event of Blindwells failing to deliver it is considered that there are a number of other settlements in East Lothian which are capable of supplementing the housing land supply through the delivery of other sites. The proportion of housing units directed towards the Scottish Borders part of the East Coast Corridor should be reduced and redirected to East Lothian due its proximity to Edinburgh and its superior public transport connections. It concludes by stating that it is critically important that the SDP sets out clear requirements for the development of new housing in the area through a through assessment of demand, need and the existing housing supply; that there is a choice of locations identified for new housing throughout the area; and that the locations chosen for new development are sustainable. Site is promoted at land between the A1 and A199 to the east of current strategic allocation at Wallyford, notes that potential for this land to be considered is outlined in the ELLP. Also notes that existing allocation has capacity to accommodate at least an additional 200 units.
This response is supportive of the vision and aims of the MIR. It is supportive of the preferred approach to all strategic policy areas and the scale and direction of growth in each of the growth corridors. Several recommendations mainly for clarification and more detail of the MIR preferred strategies are made for the proposed plan. These are summarised in the suggested change for proposed plan cell. Other important general comments are summarised as follows. With regard innovative funding mechanisms ELC would be receptive to innovative funding mechanisms which deliver beneficial development, while being affordable to the public purse, however the onus must be on central government and the private sector to fund the majority of this provision. With regard the preferred approach to guiding development to accessible locations it should not assumed that every site is automatically one which is suitable in all other respects. With regard housing it MIR-ID229-230 ELC East Lothian Council states that market recovery understandable in the short term, but the implication of no strategic housing over the period 2012-2019 does not enable the delivery of additional land for affordable housing during that period. It appreciates that land will be delivered from current Local Plan allocations during this period but this will not meet the existing shortfall. It notes that the SDP HONDA will inform the overall number of houses required to meet housing need and demand. With regard brownfield land it notes that setting a target is likely to be arbitrary and could constrain the ability of particular LDPs to bring forward appropriate development and that this could encourage change of use to potentially more valuable uses. In relation to affordable housing it notes that the alternative approach could lead to distortions in the wider Edinburgh housing market as to where developers might be prepared to invest. The preferred approach allows flexibility to respond to local circumstances.
Page 9 of 40 20 Item 5 - Appendix 1
Ref no LPA Respondee Summary of Comments
This response accepts the vision and states that the key aims encompass the key challenges of the City Region. It supports the preferred market recovery approach believing that high growth would be unrealistic. Care must be taken in using market recovery scenario based on current anticipated and actual public sector cuts and their impact upon private sector performance. With regard to infrastructure it states that alternative mechanisms are worthy of investigation as a lack of or inadequate infrastructure can hinder development and cannot always be funded by the public sector, especially in the current economic climate. In response to transportation it states that often the market will determine development and this must be considered when guiding development. It questions the terminology of figure 10 of allocated, effective, non-effective and safeguarded as this may not accurately reflect the issues surrounding ownership and take-up. It states that the Economic Development, East MIR-ID027-018 ELC strategic economic land around Queen Margaret University has not been included. With regard retail it supports the preferred approach, Lothian Council stating that having Edinburgh city centre with individual authorities setting retail strategies for other centres through the Local Plan will allow local factors to be taken into account. In relation to housing it states that figures should take account of market recovery at best. With regard the environment it emphasises the importance of the protection of natural heritage and environment as the protection of these assets impacts on tourism, the largest single sector of the East Lothian Economy. It supports the preferred approach of broadly maintaining the Green Belt and the broad control of development in the countryside. With regard prime quality agricultural land East Lothian it states that East Lothian is recognised for this and it should be protected to support the local agricultural economy and the food industry. It supports renewable energy stating that this will provide opportunities for local business and the infrastructure.
Broad support for the preferred spatial strategy, aims and overriding objective. MIR strategy will not meet housing demand; significant concerns regarding the low growth scenario. Approach runs counter to Government policies. Should be a greater recognition that the size of the city region will be a key factor in competitiveness. Recognition must be given to the fact that some committed development areas will not be viable in the short to medium term, and alternative options are required. It will be difficult to promote a sustainable settlement strategy in other respects while also protecting prime agricultural land. The amount and phasing of development proposed will be inadequate to achieve the vision. Indeed, there is a possibility that the City will decline if the low growth strategy is implemented. The low growth scenario is contrary to Government policy requiring a generous supply of housing. Development needs to be located where it can fund infrastructure. Support preferred approach to transport, economic development, and retail. The land supply requirement is substantially inadequate, based on a significant overestimate of supply, combined with a significant underestimate of demand. The MIR does not mention or seek to address the shortfall. The assumption appears to be made that supply and demand are currently in equilibrium, which is not the case. In reality, the MIR does not identify a genuine 'high growth' scenario; this is required to meet government policy. Agree that the redevelopment of Elphinstone / Hallhill brownfield land should continue to be emphasised. A substantial increase in overall supply of housing should be the starting point for MIR-ID103-094 ELC Development increasing the supply of affordable housing. SDP should not set benchmark for affordable housing; this is already specified in SPP. Agree that each LDP should set targets based on needs defined in local housing strategies. Agree with preferred approach on natural heritage and green networks. Green belt extent and shape should be reconsidered, in particular the inner boundary surrounding the City. More new development should be located close to the City; West Edinburgh and South East Edinburgh are appropriate locations for major development but the scale envisaged is not sufficient. Agree that protecting agricultural land is important, albeit there should be recognition that other strategic objectives such as the provision of land for housing or economic uses will outweigh this consideration. The MIR preferred development strategy for East Lothian is very limited in scope. Substantially more housing growth should be promoted, some of which should be capable of development as early as possible to meet current housing needs. North Berwick represents an appropriate location for additional housing development in the short term. The site at Ferrygate, represents the next logical phase in the expansion of North Berwick, which combined with existing housing land allocations, will meet demand in the town over the next 20 years or so. The site is capable of being developed in the short term. Dunbar is a suitable location to accommodate further housing development, at sites at Hallhill North and Queens Road South. The homes provided will assist in meeting the substantial shortfall in housing within East Lothian and beyond.
Land at the north-western edge of Whitecraig is suitable for development. It has good transport links so has the advantages of surrounding regional amenities while maintaining the qualities of a rural village. The primary school is in walking distance of the proposed new homes. MIR-ID123-114 ELC Executory of Sir John Hope The site presents an opportunity to create a cohesive northern edge to Whitecraig including the extension of the cycle way and new structured landscaping to enhance the setting of the town. Development would sustain key local facilities (shop, church, pub/restaurant and car garage) and enhance the village through inward investment.
Page 10 of 40 21 Item 5 - Appendix 1
Ref no LPA Respondee Summary of Comments
Objection in the strongest possible terms to the Market Recovery scenario. As the economy and housing market recovers demand and in- migration will increase. The most logical scenario is for high growth, a more realistic and desirable strategic aim. This is fully backed up by the GROS (2008) figures, which project a 17% increase in population in the period between 2008 to 2033. The high growth scenario should include built in flexibility to cater for any unpredictable changes. Existing committed allocations identified in the development plan would not be comprised by the identification of additional land for housing in the emerging SDP. Regard should be had to additional sites that could be delivered to meet any shortfall whilst planning for growth, via robust justification/demonstration, or that would be suitable for safeguarding as a deliverable option in the later part of the SDP lifespan. The proposed priority locations must be reassessed to take account of a high growth scenario. Broad locations suitable for large scale development, which can be served by highly accessible modes of transport, should be supported and identified in the emerging SDP. The East Coast Corridor requires a greater proportion of additional land to cater for the projected need and demand in this area, given its proximity to Edinburgh and existing transport infrastructure. East Lothian‟s principal towns and surrounding areas i.e. Musselburgh/Wallyford, are highly accessible areas in terms of proximity to major road and rail networks. The MIR-ID092-083 ELC Howard Wallace identification of a further 3,000 units at Blindwells, is wholly inappropriate and to state that there is additional capacity for 750 units at existing settlements is purely speculative. It would be more appropriate to disperse the additional 3,000 units throughout the East Lothian Corridor, and direct it towards areas which are well serviced by public transportation and where there are proposals to upgrade infrastructure i.e. the Musselburgh/Wallyford area. The loss of greenfield land within the green belt which is of low agricultural value and where development would not adversely impact on the landscape setting and character of the site itself, would not be a departure from sustainable development principles. Furthermore, the development of greenfield sites adjacent to built-up areas can often have a significant positive effect on an urban area i.e. economic, physical and social rejuvenation. Greenfield sites should be favoured when more specific brownfield land deliverability issues, such as the cost of the land remediation, clearly suggest that brownfield land alone cannot deliver housing to the required level, and prime agricultural land should be developed in circumstances where there is a strategic requirement to deliver a specific land use over the plan period. The SDP should provide a sound basis upon which the respective local planning authorities within the region can prepare policies in relation to affordable housing. The emerging SDP must recognise that it would be wholly unacceptable to seek a significant increase in infrastructure contribution levels from private developers as result of this recent cut in Government funding.
Page 11 of 40 22 Item 5 - Appendix 1
Ref no LPA Respondee Summary of Comments
The Plan must meet the housing need of the area (all tenures) in full and provide a generous supply of land for residential development in compliance with SPP providing that it is based on sustainable principles. The “market recovery” scenario does not do this or reflect the findings of the HNDA. The “high growth” scenario could be easily accommodated within environmental limits with delivery left to market forces, if certain areas of unmarketable land are de-zoned and compensated for elsewhere. The GRO(S) projections are not “high growth” but more a realistic expectation of growth. Insufficient housing numbers will result in lower population growth and fewer jobs filled. Much of the land currently allocated for business purposes has not been yet developed due to marketability and infrastructure delivery issues. The Plan should encourage a more flexible approach to village development throughout the area based on sustainable development principles, acknowledging the fact that small scale employment in rural areas is significant to the maintenance of viable communities. A supportive planning policy is needed for further appropriate scale development in such areas. Significant upfront works on matters such as schools provision e.g. catchment reviews, should take place at a much earlier stage in the process to provide certainty as to delivery of infrastructure taking account of the considerable lead-in time for design and development. In addition, statutory consultees must commit to infrastructure at MIR-ID196-187 ELC Hudson Homes an earlier stage. Redevelopment of brownfield land is a priority but a range and choice of effective housing land must be identified; in many circumstances, redevelopment of brownfield land is reliant on greenfield releases as enabling development. Upfront infrastructure costs and prevailing market conditions must be taken into account when determining the scale, type and location and timing of delivery of affordable housing; a benchmark target of at least 25% affordable housing is too simplistic; it should be negotiated on a site by site basis. Concern over an “all eggs in one basket” approach in East Lothian with reliance wholly placed at the door of Blindwells to deliver further housing when the original 1,600 residential units have not yet started. a wider ranging approach is required that disperses development to include scope for villages to accommodate growth that supports / enhances and provides local services and community facilities. If the development industry is to directly contribute to necessary infrastructure, significant land release is needed to achieve this. East Lothian‟s main market towns have reached their environmental limit and further growth is adverse to their character and, setting. Many smaller villages are capable of accommodating growth of an appropriate scale commensurate with their size and function. The Core Development Area approach should be relaxed to encourage sustainable growth in these locations. Promotes land to east of Athelstaneford.
All comments are in relation to the current East Lothian Local Plan allocation at Blindwells and possibility of expansion of this allocation in the SDP. The response expresses concern that the road network will be unable to accommodate existing allocation at Blindwells and that the Blindwells Development Framework for the existing allocation does not take into account expansion area of the site. States transport assessment should examine current allocation and possible future allocation. Does not agree (with the Blindwells Development Framework) that traffic should be encouraged to the B6363 to reach Gladsmuir Junction as this route is longer, less sustainable, uses roads of a poorer MIR-ID237-238 ELC Longniddry Community Council standard, crosses under bridge with height restriction, is used by farm traffic and would rely on commuters being willing to take this route. Any proposals to force drivers to take this route would be strongly opposed by existing communities. Concerned about education provision at new settlement - would put pressure on secondary school capacity at Ross High and Preston Lodge High Schools which are nearing capacity with current new housing development in their catchment areas. Strongly opposed to any expansion to the existing allocated new settlement. As an alternative support the development of 4000-5000 houses at East Fortune brownfield site with full education provision (including possible FE college) and small industrial development. This would add traffic to the A1 but not at a current pressure point.
Page 12 of 40 23 Item 5 - Appendix 1
Ref no LPA Respondee Summary of Comments
The vision and aims are generally supported but greater recognition should be given to the current economic climate and, consistent with the broader objectives of NPF2, the need to actively encourage investment and stimulate economic growth. Criticises justification for market recovery scenario on basis of deliverability of existing sites and delays in relation to infrastructure provision. Current allocations should be subject to a robust review rather than simply 'carrying forward' existing allocations. Believes constrained sites have been included in the housing land supply calculations resulting in an over optimistic view of current supply, particularly in the short term. Little/no flexibility is built in. Alternative proposals/strategies must be identified at a strategic level in order to avoid resultant unmet demand where sites are identified as constrained. Application of 25% flexibility to housing land requirements would be an appropriate buffer to take account of delays in sites coming forward and constrained sites. High growth scenario should be confirmed in the Proposed Plan to ensure housing needs are met within each housing market area throughout the plan period, particularly in the short term and to be consistent with SPP. Thus a wider range of sites should be identified in sustainable locations, for example through phased extension of existing settlements. Clarity sought with regard implementation of high growth on basis of (1) at odds with MIR assertion that no additional land allocations will be required until post 2024 MIR-ID171-162 ELC Lord Wemyss Trust (2)unclear how delivery of market recovery scenario would prejudice delivery of existing allocated sites in the short/medium term (3) unrealistic to assume that all medium and longer term strategic allocations are capable of being brought forward more quickly (4) high growth must apply same degree of flexibility as market recovery with the identification of the full shortfall up to 2031. Preferred approach too reliant on timely delivery of existing major allocations, such as Blindwells. Preferred strategy fails to indicate where the additional 3000 units would be located if an expansion of Blindwells is not feasible. Constraints identified could also prejudice delivery of existing allocation at Blindwells. As such greater share of housing allocation should be directed towards settlements such as Haddington - upfront infrastructure costs lower and development would strengthen social and economic base thereby supporting local services. Support should be given to mixed use proposals, including employment generating uses in a town which benefits from direct access to the A1 and has train stations nearby. Land to East of Haddington is a logical extension and highly accessible location - provides opportunity to deliver a high quality, sustainable mixed use development. Site capable of providing phased residential development of up to 500 units with associated business, retail, community and leisure uses, set within comprehensive landscape structure. Unconstrained site, therefore could deliver phased supply in the short term and beyond. Provides site plan on context of Haddington and showing flood envelope, green buffers etc.
Blindwells is not an appropriate location for development due to inadequate transport infrastructure and flooding. Bankton Junction is currently congested at peak times and could not cope with an increase in traffic. The train is not a realistic option for many. There are few MIR-ID-148-139 ELC Lorna White local employment opportunities and units at Macmerry lie vacant. The site is prone to flooding and has been under water when pumps are not operating. Recent housing development have caused flooding in Prestonpans and at St Joseph's School. Development at Blindwells will result in flooding in adjacent areas. The site is riddled with mine workings. The preferred strategy for East Lothian as part of the East Coast Corridor does not provide a strategic requirement for additional economic land up to 2019. To overcome the lack of effective employment land in East Lothian there is limited action the Council can take, land acquired through CPO still needs to be promoted and serviced, requiring investment in up front infrastructure. New land should be allocated to assist in the creation of additional jobs or to assist in an ongoing strategy to free up existing non-effective sites. This allows the re- allocation of some economic sites for other uses and replaces these sites with new effective land. Lothian Park considers this strategy is MIR-ID026-017 ELC Lothian Park II necessary – avoiding sterilisation of potential new sites which could be effective within the next 10 years. The preferred strategy posed by SESplan for East Lothian is unlikely to stimulate economic growth unless a strategic employment requirement is identified for new employment sites located on the East Coast (A1) corridor. Lothian Park considers that a minimum of 10ha of additional greenfield land should be identified as the strategic requirement in the SDP for East Lothian. This would lead to the allocation of new sites in the East Lothian LDP up to 2019 to facilitate future employment creation.
Page 13 of 40 24 Item 5 - Appendix 1
Ref no LPA Respondee Summary of Comments
The Plan must meet the housing need of the area (all tenures) in full and provide a generous supply of land for residential development in compliance with SPP providing that it is based on sustainable principles. The “market recovery” scenario does not do this or reflect the findings of the HNDA. The “high growth” scenario could be easily accommodated within environmental limits with delivery left to market forces, if certain areas of unmarketable land are de-zoned and compensated for elsewhere. The GRO(S) projections are not “high growth” but more a realistic expectation of growth. Insufficient housing numbers will result in lower population growth and fewer jobs filled. Much of the land currently allocated for business purposes has not been yet developed due to marketability and infrastructure delivery issues. The Plan should encourage a more flexible approach to village development throughout the area based on sustainable development principles, acknowledging the fact that small scale employment in rural areas is significant to the maintenance of viable communities. A supportive planning policy is needed for further appropriate scale development in such areas. Significant upfront works on matters such as schools provision e.g. catchment reviews, should take place at a much earlier stage in the process to provide certainty as to delivery of infrastructure taking account of the considerable lead-in time for design and development. In addition, statutory consultees must commit to infrastructure at MIR-ID206-197 ELC Luffness Ltd an earlier stage. Redevelopment of brownfield land is a priority but a range and choice of effective housing land must be identified; in many circumstances, redevelopment of brownfield land is reliant on greenfield releases as enabling development. Upfront infrastructure costs and prevailing market conditions must be taken into account when determining the scale, type and location and timing of delivery of affordable housing; a benchmark target of at least 25% affordable housing is too simplistic; it should be negotiated on a site by site basis. Concern over an “all eggs in one basket” approach in East Lothian with reliance wholly placed at the door of Blindwells to deliver further housing when the original 1,600 residential units have not yet started. a wider ranging approach is required that disperses development to include scope for villages to accommodate growth that supports / enhances and provides local services and community facilities. If the development industry is to directly contribute to necessary infrastructure, significant land release is needed to achieve this. East Lothian‟s main market towns have reached their environmental limit and further growth is adverse to their character and, setting. Many larger villages are capable of accommodating growth of an appropriate scale commensurate with their size and function. The Core Development Area approach should be relaxed to encourage sustainable growth in these locations.
Page 14 of 40 25 Item 5 - Appendix 1
Ref no LPA Respondee Summary of Comments
Market recovery will place economic growth in jeopardy, particularly for the construction industry where the potential for stimulation is diminished. Adopting high growth scenario with local allocations in addition to strategic allocations would recognise the important contribution of the construction industry to the economy and help to meet the identified MIR key aims of growing the economy and meeting housing need and demand. Critical of the MIRs approach of carrying forward existing structure plan allocations without a full and robust assessment of their current effectiveness. Market recovery is not in the interests, social or economic, of the SESplan area or for the wider Scottish economy and is contrary to SPP and NPF2 and aims of MIR. Additional allocations in the short/medium term well beyond the levels indicated within the MIR preferred strategy are clearly required in order to meet legitimate housing needs, including affordable housing. To deliver market recovery scenario of 167,000 houses will require significantly more land to be allocated than would accommodate that number of dwellings. The high growth scenario presented is not high growth, it merely reflects present population growth estimates. Supportive of a high growth scenario that allocates local sites alongside strategic allocations. Numerous settlements within the SDP region that have capacity for small scale development to meet local needs, and that their allocation would be consistent the MIR aim of promoting efficient use of existing infrastructure. Expansion would be of local benefit, particularly to settlements that have experienced little or no development in the past. MIR-ID018-009 ELC Messrs R & A Kennedy Would also reduce the reliance on large scale allocations to deliver the housing demand. Not allocating such sites is at odds with the aims of the MIR. Questions the deliverability of an expansion of current Blindwells allocation on the basis of deliverability and its contribution to the delivery of development in the short/medium term. Whist this site may provide for longer term needs, presently it is not effective. In order to address this effective sites must be brought forward along the A1 corridor in settlements such as Haddington, Tranent and Macmerry. These settlements have the infrastructure and landscape capacity capable of accommodating additional growth in the short term and thus should be the focus of additional allocations to meet identified needs/demand. Land needs to be allocated in LDPs within a context set by the SDP. Wide range of smaller sites in well located and attractive locations require to be allocated through the SDP and LDP process with the SESplan providing a clear context for the future LDPs. Where development is to occur on prime agricultural land it should be fully justified in terms of the need for the development, the availability of alternatives and the overall loss of the resource. There should be a presumption against development on land affected by flooding unless there are overriding reasons to the contrary, albeit such occurrences would appear unlikely to arise except for development which is locationally constrained and which can be protected, without detriment to other property, from the effects of flooding.
Page 15 of 40 26 Item 5 - Appendix 1
Ref no LPA Respondee Summary of Comments
Broad support for the preferred spatial strategy, aims and overriding objective. MIR strategy will not meet housing demand; significant concerns regarding the low growth scenario. Approach runs counter to Government policies. Should be a greater recognition that the size of the city region will be a key factor in competitiveness. Recognition must be given to the fact that some committed development areas will not be viable in the short to medium term, and alternative options are required. It will be difficult to promote a sustainable settlement strategy in other respects while also protecting prime agricultural land. The amount and phasing of development proposed will be inadequate to achieve the vision. Indeed, there is a possibility that the City will decline if the low growth strategy is implemented. The low growth scenario is contrary to Government policy requiring a generous supply of housing. Development needs to be located where it can fund infrastructure. Support preferred approach to transport, economic development, and retail. The land supply requirement is substantially inadequate, based on a significant overestimate of supply, combined with a significant underestimate of demand. The MIR does not mention or seek to address the shortfall. The assumption appears to be made that supply and demand are currently in equilibrium, which is not the case. In reality, the MIR does not identify a genuine 'high growth' scenario; this is required to meet government policy. Agree that the redevelopment of MIR-ID030-021 ELC Miller Homes brownfield land should continue to be emphasised. A substantial increase in overall supply of housing should be the starting point for increasing the supply of affordable housing. SDP should not set benchmark for affordable housing; this is already specified in SPP. Agree that each LDP should set targets based on needs defined in local housing strategies. Agree with preferred approach on natural heritage and green networks. Green belt extent and shape should be reconsidered, in particular the inner boundary surrounding the City. More new development should be located close to the City; West Edinburgh and South East Edinburgh are appropriate locations for major development but the scale envisaged is not sufficient. Agree that protecting agricultural land is important, albeit there should be recognition that other strategic objectives such as the provision of land for housing or economic uses will outweigh this consideration. The MIR preferred development strategy for East Lothian is very limited in scope. Substantially more housing growth should be promoted, some of which should be capable of development as early as possible to meet current housing needs. North Berwick represents an appropriate location for additional housing development in the short term. The site at Ferrygate, represents the next logical phase in the expansion of North Berwick, which combined with existing housing land allocations, will meet demand in the town over the next 20 years or so. The site is capable of being developed in the short term.
Submission promotes 2ha site at Monktonhall Gardens, Old Craighall for residential development. Supports high growth on basis that this MIR-ID031-023 ELC Mr & Mrs Traquir will provide an effective 5 year housing land supply and be consistent with SPP. Supports an alternative approach to greenbelt release that would allow for settlement extensions in sustainable locations. Concerned about Blindwells due to the amount of water that has to be pumped from the site daily, flooding at St Joseph's, and the traffic MIR-ID147-138 ELC Mrs M S Simpson chaos that will result from development at Blindwells and North Berwick.
Concern over impact on East Lothian and North Berwick. Agree with market recovery approach. Concern over developer-led infrastructure provision. Agree development should be located where it can be served by public transport and feel that upgrading of stations and provision of passing loop on Edinburgh Dunbar rail link are a priority. High speed broadband in rural areas would encourage homeworking and reduce travel. Employment land in East Lothian is not sufficient and the increased population will have to travel elsewhere to work. Strategies should seek to provide for industrial units suitable for the self-employed and small enterprises. The approach to retail is questionable as Edinburgh city centre is blighted by road disruption. Higher order retailing at Musselburgh and Kinnaird Park would be accessible to many areas and, coupled with regeneration of local town centres, would provide a more sustainable model. Concern over distribution of housing between East and Midlothian and within East Lothian; a disproportionate burden on East Lothian that has not been justified. A large North Berwick Community MIR-ID238-239 ELC proportion of this is proposed for Blindwells. Agree that brownfield sites should be the focus for new development but insufficient notice has Council been taken of the brownfield site at East Fortune Hospital and Airfield, which has fewer infrastructure problems. If the infrastructure requirements of Blindwells deter developers then pressure would be placed on there established communities to absorb the development in a piecemeal fashion; many settlements are at or near capacity. Development in these locations would detract from quality of life. Support for natural heritage protection and enhancement, green belt, and green network. Concern at impact of householder wind turbines on landscape. Visual impact could be reduced if local authorities played a role in facilitating community projects. A replacement for Torness should be supported in the Plan. Consideration should be given to the use of district heating from Cockenzie at Blindwells. Concerned at impact of off- shore wind farms if sited close to shore. Plan should make reference to the dangers of global warming, rising sea levels and coastal erosion to settlements on the Forth.
Page 16 of 40 27 Item 5 - Appendix 1
Ref no LPA Respondee Summary of Comments
The „Market Recovery‟ scenario will not allow the housebuilding sector to meet demand and need quickly enough over the plan period. A large proportion of the existing supply is made up of large scale allocations such as Blindwells in East Lothian and the South East Wedge in Edinburgh/Midlothian. In the current economic conditions, the very high „up front‟ infrastructure costs of delivering large scale developments such as these can lead to significant delays. This means that these sites remain ineffective in the short to medium term, resulting in a failure to deliver the required housing numbers, particularly during the earlier years of the plan period. The SDP needs to take a bolder approach and plan for a „High Growth‟ scenario, with a focus on allocation of smaller to medium sized sites which are more likely to be effective in the earlier years of the plan period. Agrees with preferred approach to sustainable development. It is important to ensure that the scale of infrastructure contributions required is both proportionate to the scale of development and directly related to the infrastructure requirements generated by that development. Agrees with the preferred approach to transport and welcome the support given to further provision of park and ride facilities. A more sustainable pattern of development will be achieved by providing employment allocations closer to smaller and medium sized settlements, which will provide local employment opportunities and reduce car based journeys. It will be particularly important MIR-ID156-147 ELC Omnivale Ltd in the current economic climate to provide as much flexibility as possible, both in location and uses, to support economic growth. Agrees with the preferred approach to brownfield land. A target for housing completions on brownfield land should not be imposed. Each local authority within the SESplan area should set its own targets for affordable housing based on a local needs assessment within its area. Agrees with preferred approach to natural heritage and green networks. There should be a review of the Green Belt focusing in particular on areas where this envelops existing settlements. Agrees with the preferred approach to development in the countryside. However, care should be taken to ensure that policy does not deny individual local authorities the flexibility to support local development opportunities where appropriate. Agrees with preferred approach to climate change and energy. To add a further 3,000 units out of a total of 3,750 to the current Blindwells allocation will do nothing to speed up delivery of the site. The alternative approach suggests that if the 3000 unit allocation for Blindwells is not implemented, then the 3,000 figure reduces to 750. If there is a need for 3,750 houses in the East Coast Corridor, then sites should be required to be allocated to deliver this requirement. Recommend allocation of smaller to medium sized sites, up to 300 to 350 units, across a wider range of settlements throughout the key transport routes. The Proposal for Tranent Mains will provide for growth in a sustainable manner.
This response expresses concerns with regard funding of new infrastructure to service new housing developments and securing the provision Prestonpans Community MIR-ID020-011 ELC of affordable housing. It notes that Community Council do have major concerns when the SDP reaches LDP level and that the MIR lacks Council enough detail for Prestonpans. The Community Council‟s full view to the proposed vision therefore cannot be made at this stage.
More regard should be taken of the permanent loss of agricultural land. East Lothian seems to have been given an undue share of housing expansion. It is traditionally known as the "garden county" of Scotland because of its fertile soil, but this is being constantly eroded by building. The county's "quality of life" is being ruined by rampant urbanisation. The current surge in general food prices and the Russian ban MIR-ID240-241 ELC R Dowe on grain exports, point towards the obvious danger to food supplies. Farming should be preserved and expanded. Around Tranent alone there are several fertile fields which have lain fallow for many years, presumably in preparation for SESplan. I would question whether the correct priorities are being applied in this case, and I hope that consideration will be given to halting building expansion in East Lothian, and increasing land cultivation. The SDP does not adequately reflect coming challenges of peak oil and climate change impacts. The key aim must be the development of a sustainable and resilient region. More sustainable travel is supported. Investment, including developer contributions, should be sought for improvements to public transport and walking and cycling. Public transport to QMU and the ERI from the east should be improved. Reduction MIR-ID046-037 ELC Sustaining Dunbar in fossil fuel use will require significant changes to the rural economy and this must be enabled. Local generation with CHP is preferred to a centralised power station at Cockenzie which is not compatible with the strategy. Would like policy supporting community renewable energy. Supports planting of new woodland and creation of wildlife corridors.
Page 17 of 40 28 Item 5 - Appendix 1
Ref no LPA Respondee Summary of Comments
Broad support for the preferred spatial strategy, aims and overriding objective. MIR strategy will not meet housing demand. Significant concerns regarding the low growth scenario. Approach runs counter to Government policies. Should be a greater recognition that the size of the city region will be a key factor in competitiveness. Recognition must be given to the fact that some committed development areas will not be viable in the short to medium term, and alternative options are required. It will be difficult to promote a sustainable settlement strategy in other respects while also protecting prime agricultural land. The amount and phasing of development proposed will be inadequate to achieve the vision. Indeed, there is a possibility that the City will decline if the low growth strategy is implemented. The low growth scenario is contrary to Government policy requiring a generous supply of housing. Development needs to be located where it can fund infrastructure. Support preferred approach to transport, economic development, and retail. The land supply requirement is substantially inadequate, based on a significant over estimate of supply, combined with a significant under estimate of demand. The MIR does not mention or seek to address the shortfall. The assumption appears to be made that supply and demand are currently in equilibrium, which is not the case. In reality, the MIR does not identify a genuine 'high growth' scenario, this is required to meet government policy. Agree that the redevelopment of brownfield land should continue to be emphasised. A substantial increase in overall supply of housing should be the starting point for increasing the supply of affordable housing. SDP should not set benchmark for affordable housing, this is already specified in SPP. Agree MIR-ID161-151 ELC Taylor Wimpey that each LDP should set targets based on needs defined in local housing strategies. Agree with preferred approach on natural heritage and green networks. Green belt extent and shape should be reconsidered, in particular the inner boundary surrounding the City. More new development should be located close to the City, West Edinburgh and South East Edinburgh are appropriate locations for major development but the scale envisaged is not sufficient. Agree that protecting agricultural land is important, albeit there should be recognition that other strategic objectives such as the provision of land for housing or economic uses will outweigh this consideration. The MIR preferred development strategy for East Lothian is very limited in scope. Substantially more housing growth should be promoted, some of which should be capable of development as early as possible to meet current housing needs. Given the identified housing shortfalls, additional units at Blindwells should be more than 3,000. Land at Blindwells East should be allocated for development. It would be possible to begin the phasing of the development from the east, as well as the west. Such an approach would remove the reliance on development progressing quickly at Blindwells West. Dunbar is a suitable location to accommodate further housing development, with land at Eweford Farm offering a solution for long term housing growth of 1000 homes, which would assist in meeting the substantial shortfall in housing within East Lothian and beyond. Further growth (in pursuit of the shortfall asserted elsewhere) around the Hopefield (Bonnyrigg) area is justified. Further growth (in pursuit of the shortfall asserted elsewhere) around the Stobs Farm (Gorebridge) area is justified.
Page 18 of 40 29 Item 5 - Appendix 1
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This response supports the vision and aims of the MIR. With regard the spatial strategy it objects to the market recovery preference of not bringing forward any new allocations before 2019 as there is doubt as to the ability of some existing allocated sites to deliver during the 2008- 2019 period. It feels the market recovery approach is too pessimistic and the SDP should take a more positive outlook on the economic future. High growth should be considered with a mechanism to bring forward later allocations in the plan. It supports the approach to sustainable development, infrastructure and transportation. In relation to affordable housing it may be prudent to allow earlier release of market housing (pre 2024) in support of easing the pressure of the affordable sector, especially up to year 10 of SESplan. Supportive of preferred approach to affordable housing, but only if can be delivered 'to scale' with the support of strategic housing land allocations. It is supportive of the overall principle of allocating land across the SESplan area and specifically supports the identification of East Coast Corridor as a key growth area and welcomes the strategy to 'augment' new development areas. It promotes the longer term expansion of Letham Taylor Wimpey / Mactaggart Mains with the allocation of West Mains of Letham, stating that approach is considered sustainable and would fully augment the future MIR-ID109-100 ELC and Mickel Ltd direction, scale and growth of Haddington in a properly planned and phased manner. It also justifies it as it would be an extension of new growth in East Lothian; development of capacity and infrastructure would already be place; established within the existing growth framework and would enable a long-term, but well planned, release of land that meets the SESplan future housing requirements. It promotes the allocation of West Letham in the earlier period of the plan, as to not do so may risk the non delivery of a 5-year housing land supply and restrict the steady delivery (and recovery) of new housing and infrastructure to support it. It does not raise any objection to Blindwells but is concerned that there is a risk it may be delayed and have a knock on effect to severely impact on shortfall and Blindwells status should not be over-inflated through the SESplan preferred strategy of additional allocations of the same site - a solution would be to distribute a wider- spread, additional allocation of housing requirement in other areas, such as Haddington. Alternative approach to East Coast corridor should be considered, but with a level of further allocation of other strategic land to provide the additional housing land requirement. Distribution throughout East Lothian should be reworded to capture 'the principal towns in East Lothian'.
Page 19 of 40 30 Item 5 - Appendix 1
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SDP will need to embrace sustainable economic growth to ensure the city region remains successful and prosperous, critical elements of this are the provision of a generous supply of housing and the regeneration of existing communities. Spatial development strategy of the MIR is flawed in providing blanket support for identified development areas irrespective of the impact of the recession on the viability of their delivery. By pursing the market recovery scenario it risks building the impacts of recession by reducing land requirements and relying on large potentially constrained allocations, rather than taking the opportunity to reconsider the nature of sites required to deliver housing. Both the preferred strategy and alternative strategies will result in housing shortfalls. Additional housing land above the GROS is therefore required. Wider context for sustainable development must be taken into account, particularly where more rural settlements have not benefitted from economic growth in the past but should in the future. The MIR should promote long term sustainable development strategies for settlements. The MIR needs to be clear that there has been a fundamental change in the development industry over the past three years and that the ability of new development to fund infrastructure has been drastically reduced, particularly where significant upfront funding is required. New models of funding will be needed in future, such as Tax Increment Financing. General approach to accessibility supported but principle should not be used to constrain development in less accessible locations which would otherwise deliver other benefits such as MIR-ID170-161 ELC Taylor Wimpey and AWG economic and social regeneration. NPF2 and SPP both support the importance of housing to the aim of achieving sustainable economic growth. Whilst acknowledging the impact of recession on the housing market, the SPP confirms the need to respond to longer term housing pressures, something the MIR has failed to address. Rather than relying on large potentially constrained allocations and limiting new allocations, the MIR should support the allocation of a range of smaller sites that can be delivered in the short term, particularly in the period to 2019, to help make up for the lack of delivery of large established sites. General support for East Coast Corridor but greater flexibility and commitment to delivery of housing is required. Principle of expansion to Blindwells allocation is not contested, however risk of delay in site implementation. Would be more prudent to have a back up should this site not come forward as planned. If 3750 homes are needed in East Lothian then they should be allocated. This would potentially allow other smaller and established settlements to accommodate growth to aid their regeneration. Ormiston could benefit from a long term sustainable development strategy and is well placed to deliver land for housing in the short, medium and longer term as part of an overall settlement strategy. Ormiston is one of the most deprived villages in East Lothian in terms of common indicators, planned development of a scale and design sympathetic to the established form of the village would help it to share the benefits of long term growth, and help support existing and potentially enhanced community services.
Page 20 of 40 31 Item 5 - Appendix 1
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Greater recognition should be given to the current economic climate, and consistent with the broader objectives of NPF2, the need to actively encourage investment and stimulate economic growth. The 'market recovery‟ scenario may meet demand across the wider SESplan area but this does not necessarily translate to meeting demand at the individual local authority or housing market area level. There will be a deficit in Edinburgh and Fife throughout the Plan period, and to a lesser extent, in East Lothian post 2024. This is contrary to SPP para 74. More land should be identified to meet demand across all geographical areas. The inclusion of constrained sites in the land supply calculations presents an over-optimistic view of current supply, with little or no flexibility built in. Where sites are found to be truly constrained this must be recognised and alternative proposals/strategies identified. A 25% flexibility should be allowed for as a 'buffer' to take account of delays in sites coming forward, and those found to be no longer effective. The „high growth‟ scenario should be confirmed within the Proposed Plan in order to provide for a range and choice of sites, encourage economic growth and ensure that housing needs are met, especially in the short term to 2019. Further clarity is required on implementation of the high growth scenario, which appears to assume no additional housing beyond the market recovery scenario until post 2024, and is at odds with the numbers within the technical note. Existing structure plan MIR-ID186-177 ELC Taylor Wimpey, AWG and SRG allocations would not be sufficient to meet demand and there would be a requirement for an additional 4000 houses for the period 2014-2019 and 41,700 houses for the period 2024-2032. Additional allocations required in response to the high growth scenario must not prejudice the delivery of land within current identified strategic allocations and any strategy to bring sites forward more quickly must ensure cognisance is given to the timely delivery of enhanced infrastructure. Where the high growth scenario is used as a basis for establishing housing land allocations, it is important that the same degree of flexibility is applied as with the market recovery scenario, with the identification of the full shortfall up to 2032. In general terms the proposed concentration of residential development within the identified Strategic Growth Areas, close to key transport routes and employment areas, is supported. Support is given to the retention of the existing allocation at Blindwells, and strong support is given to the proposed extension of Blindwells in order to meet housing needs under the market recovery scenario. If the high growth scenario is pursued an element of the additional allocation could be brought forward more quickly. The principle of the expansion of Blindwells has already been established subject to further technical assessments. The proposed plan should make specific provision for the eastern expansion of Blindwells.
Page 21 of 40 32 Item 5 - Appendix 1
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Extensive submission which includes a Review of the Capacity and Feasibility for the expansion of Longniddry; Sustainable Transport Report and Local Market Review of Longniddry and Blindwells. Supportive of vision and aims, but concerned about delivery of these. Questions whether some existing allocations would meet the key aims and vision, therefore calls for spatial strategy to be reconsidered. Rejects premise that existing allocations in Edinburgh and the Lothians can be delivered on the basis that this is unrealistic in the current market and for the foreseeable future and that the sites are flawed due their complexity and size and the inability to provide key infrastructure to support them. Also questions sustainable credentials of some existing allocations in relation to the now increased importance public transport accessibility, for example Blindwells. Calls for existing allocations to be properly tested against possible settlement expansions, such as Longniddry. Such alternative appropriate sites have to come forward, whether identified in the SDP or at least the option for them to come forward in LDPs. Clear evidence to support market recovery is not set out in MIR or supporting documents. Unrealistic and contrary to SPP for MIR to assume for SESplan that existing allocations will deliver housing demand in the short term. Market recovery is potentially as damaging to the economy as the low overall target. GROS projections already build in impact of the recession. No evidence that economic downturn has reduced latent housing demand. Market recovery is non-aspirational and pessimistic, it fails to recognise potential of the Edinburgh city region, minimum target should be high growth from the outset with interim review. Key advantage of high growth is that it ensures further land can come forward in the short/medium term rather than relying on existing housing allocations. HfS advise that high growth is not high growth it is a „middle scenario‟ and that there could be a higher projection which truly represents aspirations for the region over the medium term. MIR fails to recognise importance of North Berwick Line as part of the MIR strategy to achieve development in sustainable locations. Potential for expansion utilising a rail transport based strategy where new housing at Longniddry could achieve 60% modal split transport patters other than the car. Delivery of MIR strategy flawed unless it focuses on locations on rail links which can deliver sustainable development. No justification for statement that there is little additional capacity for non road-based travel choices in East MIR-ID106-097 ELC Wemyss and March Estate Lothian. There is capacity for major rail-based residential development at Longniddry. East Coast Corridor should be focussed on the East Coast Main Line, not both the rail line and the A1. Not tenable to continue support for development based on using the A1 as the linkage to Edinburgh – such car based traffic is contrary to the principles of sustainability and SPP. Longniddry is more accessible than Blindwells as it has a rail station with good existing services to Edinburgh. Longniddry will be better able to provide a mix of housing tenure and other commercial uses and is a settlement expansion that provides attractiveness in terms of identity, infrastructure, reputation and population. Studies demonstrate linkages between old and new can be achieved and facilities would be within 800m thus overcoming separation of Longniddry expansion by the East Coast Main Line. Potential for enhanced bus provision.
Blindwells is no longer brownfield; has no realistic potential for a new railway station; has fundamental ground condition problems; has no developer involved; is inconsistent with national policy; initial allocation has onerous infrastructure requirements and Homes for Scotland consider the existing site ineffective. Therefore the proposition of testing an expansion area for Blindwells is fundamentally flawed, it is neither an appropriate development site in sustainable development terms nor will it deliver housing. Would be appropriate for alternative strategy as to how the existing allocation and additional 3000 houses can be accommodated. Alternative strategy of considering other locations in East Lothian which will deliver new housing is appropriate and should be adopted in the SDP. Merit in concentrating allocations rather than dispersing them, as larger allocations have potential to spread infrastructure costs. SDP should identify the possibility of expansion of Longniddry as an option for consideration especially if Blindwells fails to deliver its existing allocation. Longniddry could also come forward if the high growth strategy is adopted. SDP strategy should indicate that if Blindwells is the subject of evidence which demonstrates that development has not occurred within the period leading to the issue of a finalised draft of the East Lothian LDP, the LDP should not contain the allocation of land for future expansion at Blindwells.
Page 22 of 40 33 Item 5 - Appendix 1
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The Plan must meet the housing need of the area (all tenures) in full and provide a generous supply of land for residential development in compliance with SPP providing that it is based on sustainable principles. The “market recovery” scenario does not do this or reflect the findings of the HNDA. The “high growth” scenario could be easily accommodated within environmental limits with delivery left to market forces, if certain areas of unmarketable land are de-zoned and compensated for elsewhere. The GRO(S) projections are not “high growth” but more a realistic expectation of growth. Insufficient housing numbers will result in lower population growth and fewer jobs filled. Much of the land currently allocated for business purposes has not been yet developed due to marketability and infrastructure delivery issues. A supportive planning policy is needed for further appropriate scale development in such areas. Significant upfront works on matters such as schools provision e.g. catchment reviews, should take place at a much earlier stage in the process to provide certainty as to delivery of ELC, FC, infrastructure taking account of the considerable lead-in time for design and development. In addition, statutory consultees must commit to MIR-ID044-035 MC, SBC, CALA infrastructure at an earlier stage. Redevelopment of brownfield land is a priority but a range and choice of effective housing land must be WLC identified; in many circumstances, redevelopment of brownfield land is reliant on greenfield releases as enabling development. Upfront infrastructure costs and prevailing market conditions must be taken into account when determining the scale, type and location and timing of delivery of affordable housing; a benchmark target of at least 25% affordable housing is too simplistic; it should be negotiated on a site by site basis. If the development industry is to directly contribute to necessary infrastructure, significant land release is needed to achieve this. Calls for whole ethos of greenbelt to be re-examined, development along principle transport routes must not be constrained by green belt designation, land either side of these routes should be the 'breaks' in the green belt that results in the intervening land designated as green belt wedges. Promotes sites at Hunters Park, Peebles; Whitburn south; Torphicen Road and Druncross Road, Bathgate; Kircaldy south west; Newton, Shawfair; Broomieknowe, Bonnyrigg and increased capacity at existing ELSP allocations at Letham Mains, Haddington and Gilsland, North Berwick.
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Ref no LPA Respondee Summary of Comments
Welcomes the vision and aims but has reservations about meeting housing need. Promoting improved infrastructure and service capacity to meet the needs of new development needs aims, unless a more generous and flexible allocation of housing land is not identified. Objects to market recovery scenario. States it is inconsistent with SPP and based on an overly cautious approach that will exacerbate difficulties many Councils are already facing in maintaining an effective 5 year housing land supply. Considers high growth should be adopted to be consistent with SPP, to address the lack to flexibility of development plan process; because GROS 2008 projections are even higher than 2006 projections; and because several local authorities are already failing to meet 5 year housing land supply requirement and are projected to see some of the biggest rises in household numbers anywhere in Scotland in the 25 year period 2008 - 2033. Setting a target for brownfield land is not appropriate or necessary. Flatted developments which are now in low demand are generally built on brownfield land, this must be balanced against the need to provide effective land to meet demand. Greenfield development where a mix of house types can be provided play a crucial role in meeting the aims of the SDP. Economics of bringing forward housing sites that insist upon a 25% affordable housing provision may make sites unviable and further stifle new development. Encourages the development of smaller, less constrained sites to be brought forward in the short term to meet demand. Crucial SDP realises the constraints to developers of the cost of Persimmon Homes (East) infrastructure for strategic sites and recognises the role smaller sites can play in meeting demand and providing a greater range and choice of MIR-ID047-038 ELC, WLC Scotland sites. Consideration must be given to relationship between development and provision of essential infrastructure in terms of cost and how deliverable each element is. Imperative to ensure that development is directed towards currently accessible locations and not locations which are reliant upon new infrastructure making them accessible, where funding may not be forthcoming. Smaller sites less reliant upon new and expensive infrastructure can also play a crucial role and this should be recognised in the SDP. Objects to preferred greenbelt approach, if there is a demonstrable need for additional housing land then appropriate Green belt sites should be considered. Welcomes preferred approach to South East Corridor, although have reservations over the proposed housing numbers. Consideration needs to be given to the adequacy of infrastructure, particularly the City Bypass and the Sherrifhall Roundabout. Alternative approach involving no further development on Green Belt land is not a realistic option for development requirements. Supports alternative approach to East Coast Corridor, but has reservations about the logic of an additional 3,000 units to Blindwells due to level of funding required for infrastructure. Notes MIR acknowledges existing allocation 1600 units is constrained. Supports preferred approach to Midlothian Borders Corridor. Reservations over the level of new housing proposed in West Lothian. A larger range of new and less constrained sites out with existing CDAs are required pre-2019 to address current shortfalls in the five year effective supply. Support for transport proposals for Fife. The majority of new housing should be directed to the main settlements where major employment growth is proposed.
More housing should be allocated across the city region area and in Fife based on a settlement hierarchy (table included in submission). ASDF support in general the proposed strategy for additional growth in the Fife Forth corridor but feel that a proportion of housing should be distributed to a wider range of settlements in a sustainable manner. Rosyth should be considered for strategic development recognising it as a gateway location with strategic mixed use development potential. Land should be allocated for additional housing development at Thornton Alfred Stewart Property MIR-ID199-190 FC in the region of 250 units, which is appropriate to the scale of the settlement. Land should be allocated for additional housing development at Foundation Crossgates in the region of 150 units, which is appropriate to the scale of the settlement. Land should be allocated for additional housing development at Kingseat in the region of 80 units. Kingseat complies with the preferred strategy for the area. Land should be allocated for additional housing development at Halbeath in the region of 200 - 300 units Halbeath complies with the preferred strategy for the area. Housing allocated in these areas would be deliverable and are easily accessible to local facilities and public transport infrastructure. Supports the Preferred Approach to promote the allocation of an extra 7,000 dwellings, for further growth of existing strategic allocations and the scope for development of new strategic allocations in settlements along the Fife Circle rail line particularly in Glenrothes (East) and Thornton. Support the potential for some allocations to be considered on sustainable local development sites and on sites in smaller MIR-ID016-007 FC Balgonie Estates communities that deliver wider community benefits including social infrastructure and sustainable patterns of growth. There is merit in looking at the capacity of existing smaller settlements such as Milton of Balgonie to accommodate growth where certain criteria are met in terms of access to sustainable forms of transport, environmental quality and design, community and social infrastructure and the potential for regeneration at a more local level.
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Ref no LPA Respondee Summary of Comments Housing land policies should be directed towards making the best use of brownfield land. No strong opinion on either growth scenario, but the plan must allow for economic growth by allocating sufficient housing land. The plan should recognise the ability to realise infrastructure funding and provision in the current climate and should be considering other means of funding infrastructure such as Tax Incremental Finance. It should not be the role of future development to resolve infrastructure deficits in the wider areas they are located. Support the MIR-ID083-074 FC BDW East Scotland provision of economic growth areas, particularly the Edinburgh waterfront and Forth estuary. SESplan must recognise that of all sites identified, not all will be available for immediate development. The plan should encourage interim uses in strategic locations where housing development cannot be delivered immediately. The plan should recognise wider opportunities for energy generation including biomass- fuelled generation. Considerable potential for economic development at the Port of Rosyth and surroundings as well as at Energy Park at Methil and Burntisland docks. The High growth scenario should be adopted to allow more flexibility. Small to medium range sites should be brought forward for housing development as oppose to larger allocations which require substantial infrastructure to deliver them. Economic growth should be spread MIR-ID160-151 FC Broomhall Estates more evenly across the area and promoted in smaller and medium sized settlements. Land for additional housing development should be allocated in the West Villages area including Charlestown and Limekilns. SESplan should recognise the need for regeneration of rural settlements. The comments presented largely relate to population estimates and the provision of sufficient effective housing land to meet identified needs within the SESplan area. Without a full and robust assessment of the effectiveness of “committed” housing sites towards delivery the real level of new allocations required in order to meet the strategy and aims of SESplan cannot be reasonably assessed. Simply accepting that sites allocated within a plan prepared during different economic times and related in many cases to large scale allocations begins the MIR-ID019-010 FC Campion Homes Ltd assessment / evaluation process on a false premise and totally undermines the validity of the outcome. Sufficient and suitable housing land provision and a range of individual community based allocations is the preferred / justified way forward in order to meet local need and to enhance the prospects of delivery and related benefits. Failure to make such provision will result in SESplan failing to achieve its aims, priorities and strategy and would run contrary to established national planning policy.
Housing figures and the majority of the proposals in the document are unrealistic. There is little shortfall of housing in the Fife area given the level of recent house building and the levels proposed in the Fife Structure Plan. Fife should not become a dormitory of Edinburgh. More Charlestown, Limekilns and MIR-ID037-028 FC needs to be done to improve Fife's economy. Development should not take place on prime agricultural land. Transport infrastructure Pattiesmuir Community Council improvements are concentrated in Mid-Fife, West Fife appears to have been ignored. It is unlikely that developers will be able to fund infrastructure. We need more industrial and commercial initiatives and better infrastructure, not just housing development. There is a continuing need to have a policy framework in the SDP which continues to support the development of non renewable resources such as minerals and onshore oil and gas. The SDP should acknowledge unconventional gas exploration like Coal Bed Methane and other MIR-ID017-008 FC Composite Energy similar onshore oil and gas resources as part of a sustainable energy resource. The SDP should identify areas of search and include policies for the extraction of unconventional onshore oil and gas. The preference is that onshore oil and gas is addressed as an energy resource and not a mineral in SESplan. Higher numbers of housing should be provided than set out in both growth scenarios to take account of recent GRO popn figures. The strategy to focus on major strategic allocations set out in existing plan strategies is flawed. Smaller settlement expansions should be MIR-ID153-144 FC Deveron promoted, such as at Roaring Hill in Leslie. The expectation of developers to provide all the necessary infrastructure and affordable housing using current models is flawed. Housing at Edinburgh Waterfront is unlikely to be delivered as programmed and this should be redistributed to smaller settlements for growth. Fife should distribute housing over a wider area to include more smaller settlements.
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Ref no LPA Respondee Summary of Comments
SESplan area already includes attractive, high quality places and should instead seek to build upon this whilst targeting regeneration to areas of need. It should make reference to the drive for creating “distinctive” good quality urban environments. Greater emphasis should be placed on requiring sustainable development. No mention is made of aiming for “decentralised energy production” which is a component of NPF2. Market Recovery scenario seems appropriate. Incorporating more guiding principles for sustainable development to guide LDPs is required. Concentrating more high levels of economic growth in Edinburgh will exacerbate the levels of commuting into the city further, resulting in MIR-ID113-104 FC Fife Council increased congestion on the transport network. This in itself could be a hindrance to economic growth. Stronger emphasis needs to be given to creating more high quality employment opportunities locally in order to reduce the need to travel and to ensure more employment opportunities are available and accessible to all communities. Concern about the findings of the SESplan HNDA relating to the level of affordable housing need and the approach to assessing the market requirement. Additional growth in Fife will be directed through new strategic sites at Dunfermline North, Ore Valley and Glenrothes, Thornton, Markinch. New Local plan sites will also be allocated concentrating on brownfield opportunities in Kirkcaldy and Levenmouth.
Development should not result in the loss of agricultural land. Maximum protection should be afforded to agricultural land and priority should MIR-ID150-141 FC Francis Anthony Spence be given to growing food locally. Growth should be dispersed over a wider area. LDPs should control economic and retail priorities for Fife. Balbeggie near Thornton should be allocated as a strategic mixed use development site. It should be considered for employment MIR-ID224-225 FC Gillespie Investment Group development, housing development, waste recycling facilities and renewables. The site is a large brownfield site in the countryside and should be promoted before greenfield land release. Interested in expanding Kelty around J4 M90. Kelty is a very accessible location that provides all the major requirements for a strategic MIR-ID132-123 FC I & H Brown allocation and links in well with wider strategic goals such as the environmental regeneration of the area. The SDP provides an opportunity to use the existing infrastructure around junction 4 of the M90. MIR-ID124-115 FC JH Aitken Liferent Trust Continued support for the allocation of housing at Kirkcaldy East through the SDP. Kelty should be identified as a location for new development. A mix of uses should be promoted, supported by provision of necessary MIR-ID108-099 FC Kelty Community Council infrastructure. Kelty and its surrounding area should be promoted as a Strategic Outdoor Leisure resource as part of the green network. A masterplan should be commissioned jointly with Fife Council focusing on developing around J4 of the M90. The current infrastructure is inadequate and over pressured by proposed housing development. Current accessible areas are over Kirkcaldy West Community MIR-ID022-013 FC developed. Fife should have greater control on its own economic and retail aspects and these should be led through the proposed LDPs. Council Infrastructure proposals are welcomed as are proposals to reduce the need to travel for employment opportunities. Lochgelly can facilitate additional growth and this should be focussed to the north of the settlement around the rail station. Neither growth MIR-ID139-130 FC Lochgelly Community Council scenario should be pursued. The market should decide where and how much housing is needed. Housing should only be developed in locations where there is available infrastructure. The conclusions of the Lochgelly Charette should be reflected and endorsed in the Strategy. Additional land and housing numbers should be MIR-ID045-036 FC Lochgelly Golf Club allocated to Lochgelly for regeneration purposes. A medium population growth scenario should be proposed instead of either in the MIR. Kelty should be identified along with the other named Fife settlements as a location for future mixed use growth with a balance of new housing, employment and infrastructure provision. Kelty and its surrounding area should be identified as a strategic outdoor leisure resource as part of the green network. The strategic allocation at MIR-ID211-202 FC Lomond Land Lochgelly should be enlarged geographically to allow for a more ambitious and logical development pattern and the housing numbers increased to deliver the aspirations from the Charette. Allowance should be made for additional housing to come forward before 2019 to mitigate the late delivery of existing strategic allocations. Allowance for the potential expansion of the coastal settlements identified in the Structure Plan coastal development zone should be promoted. The "market recovery" approach will impose a constraint on the ability to keep up with demand for housing by reducing scope for flexibility in the allocation of sites. In order for the SDP to ensure deliver of development in the short to medium term within the Fife portion of the plan area, the SLA approach needs to be augmented by measures to compensate for the failure to make progress towards implementation of the MIR-ID066-057 FC LRH Enterprises Newbigging SLA's, particularly in relation to meeting housing needs. Current market conditions dictate a need for flexibility in the allocation of housing sites. The Coastal Development Zone area designated under the Fife Structure Plan should feature as a key priority within the SDP. Burntisland is a sustainable transport locations and should be promoted for additional growth. The proposed Burntisland ferry link to Edinburgh should continue to be promoted.
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Ref no LPA Respondee Summary of Comments
Rail links need to be improved in Fife. Glenrothes and Levenmouth have no direct stations despite being major settlements. The replacement Forth crossing should be multi-modal. Roads must be improved including the links to Kincardine and to Dundee (via the A92). Freight services should be accommodated by rail to reduce HGV traffic on roads and a central distribution depot could be facilitated in central MIR-ID185-176 FC Markinch Community Council Fife. Fife should not be seen as a commuter belt for the cities and must maintain its manufacturing economic base. Glenrothes town centre should have equal status to Kirkcaldy and Dunfermline and be given more prominence and assistance. Smaller local town centres should be acknowledged. Markinch requires more affordable housing and the percentage of this must be tailored to individual area needs. Development should not be encouraged in areas with good landscape quality where it would detract from that quality.
The comments presented largely relate to population estimates and the provision of sufficient effective housing land to meet identified needs within the SESplan area. Without a full and robust assessment of the effectiveness of “committed” housing sites towards delivery the real level of new allocations required in order to meet the strategy and aims of SESplan cannot be reasonably assessed. Simply accepting that sites allocated within a plan prepared during different economic times and related in many cases to large scale allocations begins the MIR-ID024-015 FC Muir Homes Ltd assessment / evaluation process on a false premise and totally undermines the validity of the outcome. Sufficient and suitable housing land provision and a range of individual community based allocations is the preferred / justified way forward in order to meet local need and to enhance the prospects of delivery and related benefits. Failure to make such provision will result in SESplan failing to achieve its aims, priorities and strategy and would run contrary to established national planning policy. Supports the Preferred Approach. More priority should be given to upgrade the A92, particularly at Glenrothes. More emphasis should be given to promoting Glenrothes town centre for strategic development. SESplan must link well with TAYplan to ensure there is no detriment to Fife. There is too much focus on Edinburgh in the Economy section. SESplan should strengthen its statement to ensure that biodiversity and North Glenrothes Community MIR-ID061-052 FC the landscape is protected and enhanced. The tourism section has too much emphasis on Edinburgh. Fife examples of historicity in St Council Andrews, Falkland, Dunfermline and Culross should be referred to. The Lomond Hills National Park should be mentioned along with others in the City Region. “The coast” is totally underplayed in this SESplan. The Fife coast, for example, is an exemplary area of recreation, tourism and natural heritage. North Queensferry Community Concerned that additional growth will place additional burden on existing infrastructure, particularly sewerage. Concern that the MIR has not MIR-ID236-237 FC Council properly identified the locations of the additional housing development. High growth scenario should be promoted with the allocation of more small and medium scale development sites. Land to the north of Dunfermline at Wellwood promoted for development. The scale of developer contributions required should be both proportionate to the scale MIR-ID155-146 FC Omnivale Ltd of development granted planning permission and directly related to the infrastructure requirements generated by that development. A more sustainable pattern of development will be achieved by providing some employment allocations closer to smaller and medium sized settlements, which will provide local employment opportunities and reduce car based journeys.
At a minimum the Higher Growth scenario should be adopted to ensure sufficient housing land is delivered within the plan period. The Plan must conform to national policy as set out in Scottish Planning Policy and provide for the household need of the area at least in full and for all tenures. The general Fife Forth strategy is supported, but growth should not be limited within the settlements mentioned. Coaltown of Balgonie should be considered as a growth location. Tax Incremental Finance, Local / Community Infrastructure Funds and other delivery Persimmon Homes (East) MIR-ID198-189 FC mechanisms to help pump-prime investment and fund infrastructure must be brought forward as a priority as a result. It must also be Scotland recognised that Local Authorities have statutory responsibilities for elements of infrastructure provision e.g. education. Significant upfront works on schools provision e.g. catchment reviews, should take place at a much earlier stage in the Development Plan process to provide certainty to the development industry and local communities as to delivery of such infrastructure taking account of the considerable lead-in time for design and development.
A “high growth” scenario is appropriate, however consideration should be given to a true “high growth” scenario. The priority “to continue the delivery of identified development areas” is flawed. Support the SESplan strategy that additional strategic allocation of housing and MIR-ID074-065 FC Raith Developments Ltd employment land can be made to local development sites. We also support the potential for the development of new strategic allocation in the Fife Firth Corridor, but these should not be restricted to the corridor identified, rather new strategic allocations should be made in the relevant HMA, in sustainable locations and on sites which require minimal infrastructure investment.
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Ref no LPA Respondee Summary of Comments Large sites such as St Ninians opencast offer the opportunity for a holistic approach to environmental regeneration through tourist / MIR-ID157-148 FC SRG Estates recreational development with associated complementary land uses, crucial in helping to sustain and appropriately diversify the rural economy and associated employment opportunities. Westfield should be specifically allocated and given prominence as a location for economic, renewable energy and waste management MIR-ID166-157 FC SRG Estates development opportunities in the forthcoming SDP. Associated future local level land designations should be based upon conjoined feasibility studies between the local authority and landowner. This should be specifically recognised in the forthcoming SDP. MIR-ID154-145 FC Strawson Holdings Support preferred approach for Fife Forth Corridor and look to have extra land between Lochgelly and the A92, up to 2060. Do not support continued allocation of sites from previous plans. There is too much reliance on delivering constrained sites. High recovery scenario should be used. Provision for equitable provision by developers is acceptable. Release of land before 2019 will be necessary to meet requirements of SPP. Maintaining the greenbelt in its delineation will exacerbate the failure in the land supply. The MIR does not consider whether existing allocations are deliverable and there is over reliance on delivering sites like Blindwells. Land promoted for smaller MIR-ID051-042 FC, MC Banks Developments scale housing development at Whitecraigs, Cardenden, Leven, Windygates and Thornton. The retail hierarchy should recognise Glenrothes & Galashiels below Kirkcaldy, Dunfermline & Livingston. Disagree with setting a benchmark of 25% affordable housing contribution on all sites. oppose additional housing being added to already constrained major strategic sites. Cardenden should be a focus for new housing development in Fife Forth Corridor and could support an additional 1300 houses. A 12 acre site in Rosewell could contribute in the Midlothian Borders Corridor. Would like the SDP to give the flexibility to allow LDPs to allocate sites in smaller settlements rather than focusing on corridors. Considers MIR-ID231-232 MC Andrew Watt that having more people living close to where they work thus making development more sustainable. Considers that development should be located within Edinburgh City and, where rural areas are required, outwith the Green Belt. SESplan should be more ambitious and look beyond the current economic down turn. The MIR does not appear to have the policy framework to help deliver the document's Vision. Would like the SDP to have innovative policies for low density rural housing and policies to MIR-ID062-053 MC Auchendinny Estate promote rural economic growth / development and promote rural housing which can help facilitate development of rural businesses and protect key assets such as listed buildings. Generally supportive of preferred strategy, but seeks flexible approach on developer contributions, affordable housing and ensuring that there MIR-ID169-160 MC BBSRC is sufficient land to deal with sudden upsurges in housing demand. MIR-ID085-076 MC Bellway Homes More housing land required, client's site is effective and offers immediate solution, and current designation is not appropriate. Consider there to be a substantial shortage in the housing land supply in Midlothian, particularly in the short to medium term. Suggest land for housing development at Auchendinny. Highlight that housing development could have a positive and transformational impact on the area. MIR-ID032-023 MC Bett and Miller Homes Propose two alternative growth options for Auchendinny, suggest either would integrate well into the village. Highlight the accessible nature of the settlement and the possibility for a new primary school within the site. Considers that for housing allocations, the high growth scenario is preferable. Seeks flexibility with regard to developer contributions and MIR-ID187-178 MC Buccleuch Property Ltd affordable housing and considers that the opportunity should be taken to review the Green Belt policy and the extent of the Green Belt. Agree with preferred approaches for SE Edinburgh and Midlothian / Borders Corridor. More housing than market recovery desired, further comments about infrastructure and affordable housing amongst other matters. Site at MIR-ID200-192 MC CALA Broomieknowe (Bonnyrigg) can contribute to this. Cousland Village Hall MIR-ID225-226 MC SESplan led identification of areas of search is not local approach and is not supported. Association Market recovery scenario is not supported a higher growth scenario should be taken forward. Comments in relation to, amongst others, MIR-ID048-039 MC Crown Estate developer contributions and rural housing.
Page 28 of 40 39 Item 5 - Appendix 1
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While welcoming that essential infrastructure continues to be funded by developer contributions, it is considered that communities should have more of a say on how its spent. In addition, there is a concern that the growing demand for developer contributions could become an unsustainable burden on construction companies, and the balance of demand from central government, councils and developers needs to be addressed. In terms of location of development, it is considered that the further expansion of Redheugh would be beneficial given it‟s accessible location. Encouragement should be given for local shopping areas to develop. Generally supportive of level of housing development though considers that setting single rate for affordable housing is inappropriate and that more latitude should be left to LDPs in MIR-ID034-025 MC Gorebridge Community Council order to address local needs. Does not accept that only small scale developments should be allowed in the countryside, medium to large scale developments should not be discouraged. Supportive of waste facility at Millerhill. Recognises that Edinburgh City Centre is important but that emphasis here should be on the improvement of the built environment and that development of the city centre should not come at the expense of areas outwith the city. Would not support expansion of SE Edinburgh into Midlothian. Would want Midlothian settlements, particularly Gorebridge to be identified as a „hub‟ in order to provide a greater opportunity for development, given the location adjacent to the Borders Railway. MIR-ID127-118 MC Howgate Community Council Limited natural growth preferred. Very concerned about the speed and volumes of traffic in the Damhead area and passing through to retail and business premises on the boundaries and outside this area. Also concerned about litter. Asserts that additional noise and light pollution will change the present rural atmosphere and affect residents and wildlife. New development in the Straiton corridor and Lothianburn Park and Ride is likely to increase carbon deposits. Suggests there is scope for rejuvenation of currently economically unviable holdings, in line with green belt values and MIR-ID053-044 MC Mark Simpson legislation, including tourism, accommodation, rural workshops, recreation and community uses. Suggests a sympathetic approach may be required from the Council for such development. Improved traffic and environmental measures could make the area more economically productive. States the landscape has not changed much for hundreds of years and that it should be retained if possible. The area could be enhanced with further tree planting, hedgerow restoration and lower speed limits. Damhead can be a buffer between Straiton and the Pentland Hills Regional Park. The Regional Park should not be disturbed or built upon. Welcome more land for economic development, but would like SESplan to consider the allocation of land or the possibility of asset transfer to Mayfield and Easthouses MIR-ID060-051 MC social enterprises. Welcome section on housing but are concerned that allocation of land does not consider the implications for communities, Development Trust in that community facilities and infrastructure must also be developed.
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Midlothian Council continues to be supportive of the preferred development strategy, as identified in the MIR, based upon the „Market Recovery‟ scenario which it considers takes realistic account of the substantial impact that the recession has had on the Scottish economy and the development industry, at least in the short to medium term. It strongly supports the development of committed housing land and strategic allocations, along with the continuing development of urban windfall brownfield opportunities. Midlothian Council notes that the strategic direction of the SDP is largely set by the current structure plans, the Fife and Scottish Borders Structure Plans having been recently approved by Scottish Ministers. Whilst the scale, timing and broad distribution of strategic housing land requirements as set out in the MIR is regarded as generally sound, it is suggested that the Proposed Plan should provide a measure of flexibility to allow local development plans to adjust the phasing of development, if this would help to overcome constraints on delivery, especially in relation to the funding of essential infrastructure. It also requests that, where strategic growth areas straddle two administrative boundaries as is the case in South East Edinburgh and the Midlothian Borders Corridor, there needs to be clarity about the subdivision of land requirements by area and plan period. The MIR‟s support for identifying new employment opportunities in Midlothian is welcomed as essential for achieving sustainable communities of the future. Midlothian Council supports the strategic economic growth areas identified in the MIR and the preferred approach set out in the MIR. However, this Council requests that the Proposed Plan makes specific provision for additional economic land allocations within the Midlothian parts of the two relevant strategic growth areas amounting to 30 - 40 ha. This will build upon successful business locations and help in the provision of local jobs and sustainable communities. The Proposed Plan should make provision for new housing to be accompanied by new employment opportunities in the strategic growth areas as they relate to Midlothian, based upon the transport corridors of the A7 / A68 / Borders Rail and the A701. It should reflect the recognition in the MIR of the need for substantial transport MIR-ID107-098 MC Midlothian Council improvements in Midlothian to improve accessibility and accommodate the scale of growth anticipated without exacerbating current congestion problems. In addition to the re-opening of the Borders Railway and improvements to key junctions on the city bypass, most notably Sheriffhall roundabout, the MIR proposes the development of the Orbital Bus operating on or alongside the city bypass. These and other transportation improvements are seen as key to the promotion of further growth in Midlothian. As set out in the MIR, the Proposed Plan should make provision for appropriate development to be promoted at commercial centres including Straiton Retail Park, subject to the roles of the city centre and strategic town centres not being undermined. Midlothian Council considers that, as an important gateway to Midlothian, there is potential for further retail and commercial / leisure development in the Straiton area, with related improvements to the transport infrastructure.
Finally, the MIR makes reference to the preparation of supplementary guidance in relation to policy topics such as the Green Belt and minerals. Early clarification of the SDP position on these matters is requested to allow a consistent approach to be taken across the SESplan area in the preparation of local development plans. As set out in the MIR, the Proposed Plan should make provision for appropriate development to be promoted at commercial centres including Straiton Retail Park, subject to the roles of the city centre and strategic town centres not being undermined. Midlothian Council considers that, as an important gateway to Midlothian, there is potential for further retail and commercial/ leisure development in the Straiton area, with related improvements to the transport infrastructure. Finally, the MIR makes reference to the preparation of supplementary guidance in relation to policy topics such as the Green Belt and minerals. Early clarification of the SDP position on these matters is requested to allow a consistent approach to be taken across the SESplan area in the preparation of local development plans. Midlothian No 1 Circuit of MIR-ID233-234 MC Provision should be made within existing and vacant buildings for religious use. Land should also be allocated for religious use Jehovah's Witnesses Support for concept of a "Midlothian Gateway". The realignment of the A701 and SESplan offers the opportunity to rationalise development MIR-ID146-137 MC Mr Marshall Milne in this area and diversify the commercial centre to bring much needed civic, services, leisure uses and employment.
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Ref no LPA Respondee Summary of Comments National guidance requires that a 5 year supply of housing land is required. The difficulties of delivering the 27,000 houses over the plan period has been well documented by the development industry, though does not reiterate the arguments. States that there is likely to be a shortfall in supply in the early years of the plan period, which is exacerbated by the proposal to unduly restrict releases until 2019. States that there is already a backlog in the 5 year housing land supply which is exacerbated by the failure of delivery at Shawfair and within the South- MIR-ID182-173 MC Mr. Donald Laird East Wedge. The MIR provides an opportunity to address this. States that while there is support in principle for allocations within the SE Edinburgh area as part of the preferred strategy, the current policy stance which is reliant on existing commitments and Local Plan policies which preclude development are unjustified in relation to land supply and economic imperatives. Promotes site at Cauldcoats Farm, Midlothian as an opportunity in the medium term (35 years), stating that it is the most feasible and viable land within the South East Wedge, which is important given the failure of Shawfair to deliver. Detailed site matters raised in support of this site. MIR-ID093-084 MC Murrayfield Properties Ltd More housing than 'market recovery' required, Tynehead could help meet this. Old Road Securities (ORS) and SESplan should be more ambitious and look beyond the current economic down turn. The MIR does not appear to have the policy MIR-ID152-143 MC Arniston Estate framework to help deliver the document's Vision. Promotes land at Redheugh West. MIR-ID145-136 MC Peel Developments On Q8 supports alternative approach, on other questions where view given supports preferred approach. MIR-ID126-117 MC Pentland Estate Support the vision and aims, and general support for preferred approach Notes that the MIR identifies SE Edinburgh as an area where a further 20 Ha of economic land can be accommodated. Which, in the view of MIR-ID158-149 MC Shawfair Business Park Ltd the respondee describes the site they are promoting, to the north of Sheriffhall Roundabout. Submission goes into some detail about the merits of this site. Full and explicit acknowledgement should be given to Shawfair Masterplan proposals and approved planning application schemes. Supportive of preferred approach of supporting existing allocations and identifying additional housing units in the longer term. A "Shawfair Action Programme" should be devised that deals with fundamental issues of viability, delivery and implementation. Relevant planning MIR-ID086-077 MC Shawfair Developments Ltd authorities should re-appraise Shawfair in the light of the economic downturn, looking at issues such as infrastructure costings, plot-tariffing and other matters critical to viability and deliverability. This should involve fresh dialogue with landowners / developers. Note that there is no funding or timing commitments. Reference to orbital bus route and tramline is also made. These are fundamental to the successful delivery of sustainable development for the wider area. Such constraints / issues should be addressed / delivered via a realistic Action Programme. MIR-ID138-129 MC SPOKES Withdraw support for Borders Rail, more support for cycleways. Considers the Lothianburn area at the A720 / A702 road junction in Midlothian represents a strategic sustainable gateway location to MIR-ID112-103 MC Swanston Farms Ltd Edinburgh and Midlothian that accords with current and proposed economic development planning policies. Taylor Wimpey and Hallam Considers more housing allocations are required, and allocations should be made before 2019. Considers further review on Green Belt MIR-ID105-096 MC Land Management boundaries is required and there should not be blanket 25% affordable housing requirement from new housing development in SESplan.
MIR-ID067-058 MC Tynewater Community Council Generally supports approach, requires strong control over minerals extraction. Generally supportive of preferred strategy, but seeks more explicit support for life science / knowledge-based industry, particularly at Easter MIR-ID188-179 MC University of Edinburgh Bush and Edinburgh Technopole and the Aims and Objectives. Considers there is scope for minor Green Belt alterations in Midlothian to accommodate housing development in Midlothian. Wonders if the MIR-ID089-080 MC Urban Design and Mediation Local Development Plan is the appropriate mechanism for such releases from the Green Belt. Minerals industry should not be allowed to influence the plan disproportionately. The Area of Great Landscape Value should be extended MIR-ID151-142 MC, SBC Quarries Action Group between Dolphinton and West Linton on the A702. No position is stated in terms of support for the MIR.
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The adoption by SESplan of the GRO(S) 2006 projections creates a high housing surplus from the MIR's "Market Recovery" approach in Midlothian. The GRO(S) projections project a low level of household growth incompatible to the current adopted development strategy. Adjustments to the methodology are needed to justify the proposed scale of land releases and the Council's affordable housing policy. Adjustments to the methodology will need to take account of the outcomes from the HNDA and its subsequent correlation. Key conclusions: The MIR for Midlothian does not disclose all of the policy requirements of the SPP, MIR reflects a pessimistic view for Midlothian on housing need and demand, compared to GRO(S), MIR assesses housing need and demand against an optimistic view of the amount of effective housing land available (Audit 2008), given Audit 2009 is now available, Issues relating to the use of different GRO(S) data are not raised in the MIR, None of the outcomes expected in the HNDA process are reported in the MIR, Anticipates the Proposed Plan will justify the levels of land release proposed in the MIR. Any increase in the level of housing growth beyond that presented in the "Market Recovery" approach will have implications for the strategic housing requirement which needs to be modelled. The requirements of SPP have not been met in relation to West Lothian and presents a pessimistic view as opposed to optimistic in terms of housing need and demand. Further land release is MIR-ID094-085 MC, WLC Taylor Wimpey required. SESplan should promote Halbeath in Dunfermline as a strategic development opportunity for 1,400 homes and a primary school to meet the land releases required in the Fife Forth Corridor. New market and affordable homes can be developed within the current local plan period to meet current strategic requirements. Halbeath can meet strategic housing requirements identified in SESplan for the period up to 2019 and 2024. This should be supported in the Proposed Plan based on adopting the High Growth scenario. SESplan should recognise and support the major contribution that a Halbeath proposal will deliver in terms of contributing to infrastructure improvements including provision of part of the route of the Northern Expansion Link Road and the Lyne Burn Bypass. The proposal will provide significant benefits for Dunfermline and will support the SPP requirement for delivering sustainable development. SESplan should acknowledge that the allocation of additional land within the existing SLAs will not add to the delivery of more housing due to the level of home sales which can be sustained in any particular area. The release of new development opportunities as SLAs is therefore an essential component of the Council‟s development strategy to ensure it maintains an effective housing land supply at all times. This is a requirement of SPP. In addition by virtue of its location by the railway, Halbeath will add to the Council's proposed regeneration of communities along the Fife Circle Line in SESplan.
More housing than market recovery desired, Midlothian to take larger share, review of green belt, Walker Group have number of possible MIR-ID213-204 MC, WLC Walker Group sites. Response refers solely to wind farm developments. The respondee states that efficiency should be mentioned in the SDP so as to promote MIR-ID041-032 SBC A Bailey only the best wind farm sites over the "currently proposed indiscriminate approach". Feels SESplan should not interfere with the review of Areas of Great Landscape Value being undertaken by Scottish Borders Council. Broad support for preferred spatial strategy outlined in MIR, and the overriding objective to provide a strategic planning framework for sustainable economic growth over the next 20 years and beyond. This approach amounts to significant progress in respect to the current MIR-ID028-019 SBC Blenheim Portfolio Ltd suite of Structure Plans which are limited in their geography and time horizon. However significant concerns with 'market recovery' scenario, particularly with regards to the housing demand calculations, which are considered inaccurate. Generally supportive of key aims / issues. Concerned about delivery of these due to the credit crunch, especially regarding housing. State MIR-ID244-245 SBC Boyd Farming SESplan should ensure LDPs deliver a wide range of sizes of site. The response promotes the potential for decentralised heat / energy generation to serve communities. Particularly promotes site for a MIR-ID068-059 SBC Charlesfield First Biomass / CHP Plant and a Wood Pellet Plant at Charlesfield. The community council feels that "the MIR is overly focussed on Edinburgh and its requirements. The basic hub and periphery model is deeply flawed and the title Midlothian Borders Corridor is inappropriate. The title itself reveals the prejudice and pre-conception that Clovenfords and District MIR-ID072-063 SBC underpins the Main Issues Report; namely that the Scottish Borders can be dismissed as peripheral. As a result the Main Issues Report is a Community Council profoundly disappointing document for anyone who genuinely cares about the unique character, history, geography, and economic future of the Scottish Borders". Submission is supportive of vision and aims providing housing land allocation issues are resolved. Reject "market recovery" scenario in MIR-ID184-175 SBC David Wilson Homes favour of a "high growth" strategy. In either scenario suggest estimates of housing provision are inadequate.
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General support is given to the overall 'vision' but with recognition of the current economic climate and the need for investment to stimulate economic growth. Disagree with the preferred strategy for housing land allocations preferring a high growth strategy, however there are MIR-ID183-174 SBC Elizabeth Benson's Estate questions as to how this strategy was decided upon and how strategic allocation availability is decided. Submission promotes development to the south of Peebles, where client's estate is located. Submission is broadly supportive of the Midlothian Borders Corridor. Submission refers solely to setting out how the Tweed Valley Forest Park and proposals affecting it can be formalised within the SESplan. As MIR-ID181-172 SBC Forestry Commission Scotland such the proposal calls for SESplan to fully represent tourism and recreation interests. The majority of the questions have not been answered as the base of the proposal is flawed. A consultation was not carried out with the MIR-ID012-003 SBC Kelso Community Council people before SESplan was set up hence the flawed concept of a hub with corridors is not correct. The report should be scrapped and started again with proper consultation. Concern with lack of articulation for economic growth, would like more forward thinking ideas. State "high growth" scenario should be MIR-ID043-034 SBC Kirkland Farm adopted. State infrastructure costs should be spread equally across all users. Housing allocation is inappropriate. Agree with Borders hub. Affordable housing should be 15%. MIR-ID111-102 SBC Lawrie & Symington Submission relates to promotion of Auction Mart site to the West of Peebles with regards to strategic housing land requirement. Considers the 'market recovery' scenario to be inappropriate but broadly supportive of 'high growth scenario'. Promotes client's interests in MIR-ID118-109 SBC Lennel Estate Coldstream, states Coldstream should be recognised as a priority area for regeneration and investment (as in the Structure Plan). Support vision and key aims. Concern with preferred approach to housing figures, which then links into allocations within the Midlothian MIR-ID120-111 SBC Lord Ralph Kerr Borders corridor. Supportive of the vision as it refers to a sustainable and competitive city region but concerns over how vision is to be achieved and focus MIR-ID179-170 SBC M & J Ballantyne purely on residents. Supportive of key aims but concerned growth strategy could undermine them. Strongly disagree with housing land growth strategy. Agree with approach in Midlothian Borders Corridor provided it is under a "high growth" strategy. MIR-ID159-150 SBC Mrs Joyce McLean Submission relates to re-opening of Reston Halt only. Support the vision. Important delivery of economic prosperity within a high quality environment is at the heart of the strategic vision. National MIR-ID140-131 SBC National Grid Properties Grid support the aims of the plan. It is essential that housing demand is met to retain population and investment particularly in peripheral areas. This means the growth strategy should be re-examined. MIR-ID232-233 SBC P J Lewis The plan is undermined by the failure to develop and present the alternatives which exist. It renders the consultation meaningless. Sees a conflict in MIR proposals for growth and proposals for sustainability / environmental protection, particularly in light of finite fossil fuels MIR-ID042-033 SBC Roger Oakes and possibility of further economic problems. Does not agree with Borders Rail project or new Forth Crossing. Agrees with environmental proposals provided policies are rigorously adhered to. Broadly agree with set out approaches. Concerned that the vision is anonymous and lacks a sense of identity for the Borders. Agree with Royal Burgh of Selkirk and MIR-ID101-092 SBC aims but stresses the importance of tourism. Would like to have a Selkirk bypass safeguarded. Do not accept the term "corridor" and do not District Community Council want to promote "dormitory communities". Feel landscape / heritage proposals should be strengthened to include the built environment. Support the vision. Important delivery of economic prosperity within a high quality environment is at the heart of the strategic vision. Our MIR-ID096-087 SBC Rural Renaissance clients support the aims of the plan. It is essential that housing demand is met to retain population and investment particularly in peripheral areas. This means the growth strategy should be re-examined. The response is supportive of the vision, aims and strategic approach. States that local development plans should set targets for redevelopment of brownfield land. Local Authorities should also be allowed to set affordable housing targets. It is stated there should be MIR-ID223-224 SBC Scottish Borders Council clear emphasis on the need to improve accessibility for rural areas, especially in light of the European Spatial Planning Observation Network and its report on Scenarios on the Territorial Future of Europe. Broadly agree with set out approaches. Believe the focus on Edinburgh is misplaced, benefits should spread more widely in the region. MIR-ID097-088 SBC Scottish Borders Party Concerned about the pressures of wind-farm developments and the approach to the conservation of landscape. Feel the Edinburgh green belt approach should be revised (wedge policy).
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Ref no LPA Respondee Summary of Comments Does not agree with the vision, aims, strategy. Also disagree with the majority of approaches to key issues: such as infrastructure, MIR-ID079-070 SBC Scottish Land Holdings transportation, sustainable development, housing, brownfield land, minerals, climate change and energy. Does not agree with housing allocations for Scottish Borders, under the scale and direction of growth. Welcomes many of the proposals set out in the MIR however there is a lack of recognition for the contribution the rural areas of SE Scotland make in terms of achieving national objectives, particularly in relation to sustainable economic growth. The preferred approaches are MIR-ID226-227 SBC SRPBA undoubtedly loaded in favour of the city vision and fail to recognise that the rural area is a living economy which needs to thrive in order to provide the benefits required. There are many more options available in which the rural areas can play a major role to developing and growing the region sustainably. Growth in the Borders should be focused on local needs, local employment and creation of local employment. Confirmation should be given Stow and Fountainhall MIR-ID052-043 SBC as to whether the Midlothian - Borders corridor means the A7 and / or the A68 and where will development may be. Will the proposals be Community Council sustainable and where can plans be viewed. Submission strongly disagrees with the preferred approach (market recovery) for housing land allocations. Aside from this issue the respondent is broadly supportive of the preferred spatial strategy and objective to provide a strategic planning framework for sustainable MIR-ID173-164 SBC Taylor Wimpey and AWG economic growth over the next 20 year period. Supportive of the vision as it refers to a sustainable and competitive city region but concerns over how vision is to be achieved and the focus purely on residents. Supportive of key aims. The Community Council of the Supportive of vision and aims, even if they are Edinburgh-centric. Would prefer a cautious strategic strategy, unclear if they refer to the MIR-ID1214-205 SBC Royal Burgh of Peebles and market recovery scenario. Believe that needs to be further focus on rural / Borders areas regarding sustainable development and District infrastructure contributions. Feel there should also be a focus / mention on community renewable energy schemes. Generally agree with Vision and Aims but believe "area" should replace "city region". Submission focuses on affordable housing and MIR-ID242-243 SBC Tweed Homes implementation. Believe there should be local housing action plans at a local level, may also be need for land releases, CPOs and / or dezoning and reallocation. The preferred approach to minerals is appropriate except in one respect. Para 7.125 refers to a review of demand for minerals at a regional MIR-ID013-004 SESplan CoalPro level. CoalPro considers that in relation to certain strategic minerals, where the geographical distribution of demand may be fundamentally different to that of resources, demand at a national level should be taken into account. Communities Against Airfield MIR-ID095-086 SESplan Concerned that the preferred approach does not allow for regional decisions to be made. Open Cast In summary, the SDP should establish hierarchies of transport, land use, and location for housing, establish principles for energy use and generation, focusing on conservation, set out ways in which full employment could be achieved in sustainable jobs based on for example MIR-ID038-029 SESplan CTC Lothians auditing (of existing bad practice), maintenance, repair, and conservation (of public sector buildings), energy conservation, especially in public sector buildings, recycling, and education of the public in these matters, guide changes in spending, to move from capital to revenue, ensure that new businesses do not compromise the environment (no more water chillers! MIR-ID174-165 SESplan DPP As national policy supports the recognition and protection of pipelines this should be reflected within the Proposed Plan. G. H. Johnston Building Unnecessarily prescriptive and inappropriate density references should be avoided in favour of encouraging developments which are in scale MIR-ID014-005 SESplan Consultants Ltd. with the surrounding development. Glasgow Edinburgh MIR-ID082-073 SESplan The overall approach is appropriate. Collaboration Initiative Considers that the preferred growth scenario contradicts Scottish Government policies. Concern that there is no strategy to meet housing demand. High growth scenario is not credible, suggests should be a 'high', 'medium', 'low'. MIR Growth scenario does not assist for affordable housing. SESplan should be more proactive in bringing forward development land for mainstream housing i.e. an increase in MIR-ID063-054 SESplan Hallam Land Management overall housing supply. SDP's and LDP's should provide an appropriate range and choice of sites. An increase in overall housing should be a starting point for increasing supply of affordable housing. The extent and shape of the greenbelt should be reconsidered, particularly the inner boundary. The SDP should acknowledge that Greenfield sites within the Green Belt can offer an alternative to the development of brownfield land. Consider distances of pipelines in allocating areas for growth. Suitable distances should be maintained between major hazard sites and MIR-ID143-134 SESplan Health and Safety Executive residential developments, buildings, areas of public use , major transport routes and as far as possible recreational areas. Any maps should identify major hazard sites and pipelines.
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Dismayed that a key document for Scotland sets out such a positive vision and then fails to carry that through into the preferred approach. The document is excessively influenced by the current recession rather than set out a positive approach to recovery and growth. The technical bases of the document in particular the use of projections and the HNDA are flawed. The HNDA is also deficient against the terms MIR-ID168-159 SESplan Homes for Scotland of Government guidance and cannot be considered robust and credible in its current form. The uncritical adoption of existing strategies is not acceptable and it is clear there are risks to achieving these. Alternative spatial strategies and land allocations must be considered. The proposed land allocations are deficient by 63,000 units. The MIR has been prepared at arms length from stakeholders. This approach should change if the Government's aim of a more open and inclusive planning system is to be achieved. MIR-ID149-140 SESplan John Wilson Enhance public transport services Support vision but continuing to support existing areas is flawed, as unlikely to come forward. No assessment of new strategic land or existing areas and express concern that no reasonable alternatives brought forward. Support high growth scenario, but a true high growth scenario exceeding GROS should be considered. Low growth scenario not appropriate/ High growth scenarios would not prejudice ability to MIR-ID049-040 SESplan Mortonhall Estate bring forward existing sites. Do not consider sustainable approach to identification of land has been applied. Do not support distribution of development set out. Continued need for green belt but need reference to precise form and boundaries at LDP level. Do not support identification of land close to airport. Do not support additional development south east of Edinburgh, instead requirement should be redistributed, focused on Edinburgh. Do not support further housing at Blindwells.
Given that the proposed growth strategy is closely related to the existing rail network , there will be an increase in demand for rail service. This increased service provision may result in the requirement for upgraded rail infrastructure or to upgrade facilities at stations. Accordingly Network Rail supports the MIR requirement that development must be accountable for resultant requirements to railway infrastructure and facilities. A clear strategic context for seeking developer contributions for required infrastructure enhancements or station improvements as a MIR-ID039-030 SESplan Network Rail direct consequence of new development growth should be set out. Network Rail should be excluded from having to make developer contributions. Schemes require Transport Scotland endorsement before Network Rail would consider it. The Proposed Plan should provide strategic guidance for LDP spatial strategies to avoid locating development required to use level crossings. We would request that the Proposed Plan provides a strategic context for LDP‟s to provide a designated notification zone around all operational railway infrastructure within which any development application proposals would be notified to Network Rail. Greater recognition should be given to the importance of the A1 and Berwick-upon-Tweed. Account should also be taken of the Berwickshire MIR-ID210-201 SESplan Northumberland County Council and North Northumberland Coast European Marine Site and the cross border impacts of wind farm proposals. Has a very heavy focus on road infrastructure with public (apart from rail) and sustainable transport (walking and cycling) being much further MIR-ID091-082 SESplan Paths for All down the hierarchy. Supportive of the vision, aims, market recovery scenario, approach to sustainable development, infrastructure, transport, economic growth, MIR-ID131-122 SESplan Perth and Kinross Council housing, green belt, climate change and energy and minerals. Also supportive of the approach to Edinburgh City Centre, West Edinburgh and Fife Forth corridors. Overall, RSPB welcome recognition in the MIR of the importance and value of the area's protected sites and other greenspace networks and MIR-ID098-089 SESplan RSPB Scotland that achieving a sustainable pattern of development is set out as a main priority. However, there are opportunities to go further in tackling climate change and in conserving and enhancing biodiversity. SDP should confirm that economic development includes retail. The SDP should define a hierarchy in accordance with both the current and MIR-ID102-093 SESplan Sainsbury's Supermarkets Ltd potential role and function of each individual centre and identify a clear network of centres. Allocation of land should not prejudice or sterilise the extraction of surface mined coal. Identify strategic surface coal mining areas and give MIR-ID162-153 SESplan Scottish Coal specific policy reference. MIR-ID080-071 SESplan Scottish Enterprise The overall approach to economic development priorities and directions for growth reflects SESplan's earlier inputs and is welcomed.
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Three main concerns moving towards Proposed Plan that need to be addressed. The most significant is around the supply of land for housing. Concerned that on current evidence, the plan may not deliver the generous and effective supply of land that is required. However, Scottish Government (Including issues around the capacity of transport and other infrastructure to deliver the strategy and responding to climate change are two other critical MIR-ID081-072 SESplan Transport Scotland and Historic issues that must be addressed. More generally, appropriate regard must be had to the expectations of development plans of development Scotland) plans as contained within the consolidated SPP. This covers not just the expectations on policy substance but on the form of the document itself. It is worth noting that it is expected that Proposed Plans are shorter than MIR's since lengthy discussion and context about the various options does not need to be set out. The Proposed Plan should focus on SESplan's agreed approach and strategy.
Welcome the commitment to the Central Scotland Green Network. The MIR proposes significant increases in housing allocations and some of these may conflict with environmental aspirations. It is expected that the proposed increases in housing are based on a thorough assessment of sustainability criteria and a robust review of alternative geographical proposals. A third slow growth option should be MIR-ID219-220 SESplan Scottish Natural Heritage considered in addition to market recovery and high growth. If economic recovery takes longer than expected this may be more realistic. Planning for a slow growth scenario could help to avoid an over provision of housing land with its associated problems. It wll be a significant challenge to translate the many positive aspirations of the MIR into such a concise document. MIR-ID084-075 SESplan Scottish Property Federation Vision is broadly acceptable, but this is not carried through to the rest of the document. It is recommended that additional housing land be allocated. The issue of potential shortages in housing land supply are exacerbated by the inclusion of constrained sites within the supply calculations, particularly within the short term. This may involve the identification of new sites, or the re-direction of additional housing growth towards other strategic locations. Within the context of the above, it is strongly suggested that the „High Growth‟ scenario be confirmed within the Proposed Plan. Notwithstanding, further clarity is sought with regard to the implementation of the „High Growth‟ scenario. In general terms, the proposed concentration of residential development within the identified Strategic Growth Areas, close to key transport routes and employment areas, is supported. In the first instance, strong support is given to the MIR-ID218-219 SESplan Scottish Resources Group retention of the existing allocation for a new settlement at Blindwells. In order to meet housing needs over the short-medium term, the MIR preferred strategy is consistent with the provisions of the approved Structure Plan. Strong support is given to the proposed extension of the existing Blindwells allocation in order to meet housing needs under the „Market Growth‟ scenario. Significantly, in the event that the „High Growth‟ scenario is progressed, it is anticipated that an element of this additional allocation could be brought forward more quickly, as required. It is requested that the Proposed Plan make specific provision for the eastern expansion of the existing major allocation at Blindwells.
There is a need for greater emphasis within future documents of the need for developers to provide evidence of their intention to commence development before Scottish Water can access investment funding to provide any strategic capacity that may be required. Early dialogue between Scottish Water and developers will ensure that we are ready to deliver any required investment within the required timescales. Scottish Water will continue to plan for population growth using GRO data and as such investment funds will be aligned with these projections. We support the proposed scenarios for the development of the strategic growth corridors proposed on the basis that this will MIR-ID209-200 SESplan Scottish Water likely require less intervention in water / waste water infrastructure than a more spatially diverse strategy. We are actively engaged with local authorities and developers in order to monitor requirements for investment to enable new development. We remain concerned that there needs to be greater distinction between the various types of infrastructure required under the plan such that difficulties in one area are not viewed across others. For example, difficulties in education provision do not readily compare with the requirement for investment in water / waste water infrastructure given that funds are available to meet water / waste water needs and the solutions involved much less complex than the provision of new schools capacity.
SWT recommend the application of an eco-system based approach to at least the natural heritage aspects of the planning system. The MIR-ID212-203 SESplan Scottish Wildlife Trust green belt should be protected from inappropriate and unsustainable development and any permitted development must only be allowed because of exceptional circumstances.
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SEPA - Welcome the approach to the assessment of the strategic options as well as the assessment of growth areas. Agree with the assessment of the preferred market recovery strategy. It is not clear in the Report that existing flood risk constraints within the Strategic Growth Areas have been identified and we would advise further consideration is given to potential effects on flood risk. SESplan may wish to undertake further detailed assessment in relation to the impacts of the plan on climatic factors. It would be helpful to fully set out the requirements for mitigation and enhancement. SNH - It does not appear to be the case that the SEA process has informed the MIR. The SEA Gateway (Response to MIR-ID235-236 SESplan links between the conclusions of the Interim Environmental Report and aspirations and proposals in the MIR need to be more clearly Interim Environmental Report) explained. Historic Scotland - Structure of the report is clear and welcome that many of the comments returned at scoping and throughout the assessment process have been taken into account. Some areas where the report could have provided a clearer outline of the likely environmental effects for the historic environment. Also difficult at times to see how the findings of the environmental assessment have informed the development of the MIR, particularly in those areas where development is already committed and addtional allocations are proposed.
The aims will contribute to the protection and enhancement of the environment. SEPA welcomes the commitment to sustainable development to help respond to climate change and in particular, the reference to avoiding areas of flood risk, providing a framework for sustainable waste facilities and encouraging renewable energy developments. SEPA support the 'market recovery' scenario and are satisfied that this will have less significant impact on the environment than the 'high growth' scenario. SEPA welcome the commitment to develop a policy framework for LDPs to assist in delivery of essential infrastructure and recommends that, with regards to water management infrastructure, this includes a requirement for LDPs to consider the implications of climate change. The preferred approach to climate change, energy and renewables may have implications for the spatial strategy. SEPA supports the preferred approach to the green network and particularly welcome the inclusion of the blue network which will help achieve the the River Basin Management Plan. SEPA generally support the preferred approach to renewables but recommends that the approach is set in a framework which seeks, as a priority, to reduce energy demand and improve energy efficiency, and seeks to optimise the environmental benefits of energy developments. This could be achieved through a life-cycle approach to assessment and include an assessment of carbon impacts as part of the SEA process for the LDPs. The proposed locational criteria for wind farms is at odds with the government‟s vision of map-based plans. An alternative approach MIR-ID217-218 SESplan SEPA could be for the Proposed Plan to include a map showing strategic areas of search for windfarms. The Key Agencies are preparing guidance to help identify the most sustainable locations for renewable energy developments. Carbon rich soils and peat need to be carefully managed to ensure that they remain as carbon sinks and thereby contribute to the green house gas mitigation targets. SESplan could encourage LDPs to develop a spatial framework which identifies and protects the functionality of carbon rich soils and peat. SEPA supports the preferred approach to identify growth areas which avoid the risk of flooding and which have the capacity or planned upgrades for waste water treatment and water supply. This should be a key consideration in the spatial strategy. SEPA welcomes the development of a Strategic Flood Risk Assessment process to inform the identification of growth areas but the programme for developing this and how it will be used should be clarified. To ensure that future growth areas avoid areas of flood risk, SEPA recommend that this is progressed in time to inform the preparation of the Proposed Plan. SEPA support the preferred approach, welcome the commitment to a planned approach for waste management and the inclusion of a framework for the management of commercial and industrial waste. SEPA will work with SESplan and member authorities to improve information on capacity and forecast demand. SDP could consider showing facilities on Figure B14 of Monitoring Statement on the proposals map.
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Ref no LPA Respondee Summary of Comments
The need for additional strategic waste sites should be addressed in the Proposed Plan, and shown on the strategic map and it may be appropriate to show areas of search indicating preferred locations for other major waste treatment plants. SEPA recommends that the approach in Annex B of the Zero Waste Plan and PAN 63 is followed when showing the preferred approach in the Proposed Plan. Sites identified for employment or industrial uses may be appropriate for waste management facilities. SEPA support the inclusion of a policy framework to direct the delivery of future waste management sites, the exploration of options for energy from waste and the encouragement MIR-ID217-218 SESplan SEPA of recycling in the Proposed Plan. The waste policy framework could be linked to climate change mitigation. SEPA are concerned regarding environmental effects in terms of flood risk, water quality and / or air quality of proposals in West Edinburgh, South East Corridor and the Midlothian Borders Corridor which may be addressed through mitigation measures of require the re-programming of development. In the East Coast Corridor, there may be significant effects in relation to groundwater flooding at Blindwells which may restrict further development in that area and the alternative approach to disperse future growth throughout East Lothian may be more feasible. SEPA will welcome the opportunity to work with SESplan in the development of the Proposed Plan.
MIR-ID114-105 SESplan SEStran SEStran and SESplan to work collaboratively and SEStran to take an active role in producing the development plan. MIR-ID215-216 SESplan Southern Energy PLC Concerned with planning for renewable energy and infrastructure provision for expansion and growth. MIR-ID228-229 SESplan Sport Scotland The current and future needs of sport and physical recreation need to be inextricably linked and considered alongside these policies. The main points raised relate to housing and the relationship between SESplan and adjoining areas. In TAYplan's opinion, the housing MIR-ID137-0128 SESplan TAYplan needs of the SESplan area need to be met within the SESplan area, otherwise there could be implications for adjoining Housing Market Areas such as the Kinross area. The SDP should set out a strategic framework for energy minerals including coal, supporting prior extraction where appropriate to avoid sterilisation of mineral resources through other forms of development. Strategic priorities for development management in relation to mineral proposals, including policies to ensure the effective restoration and after use of mineral sites. In particular, the Coal Authority considers that the following issues should be addressed: an overall strategy for Energy Minerals including coal. This should also recognise the role for other MIR-ID128-119 SESplan The Coal Authority emerging coal related technologies such as coal bed methane, a strategic approach to the safeguarding of surface coal resources within the plan area. For the reasons set out above, the Coal Authority considers that the SDP should incorporate a strategic approach to addressing coal mining legacy issues within the plan area. The SDP should also outline policies to ensure the appropriate restoration and aftercare of mineral developments in order to ensure no future ground stability problems arise. Coal Authority considers that the potential of impact of mineral sterilisation should be built into the relevant policy framework. Our overriding concern is that it doesn‟t help identify and grasp opportunities. Change appears to be seen more as a destabilising force which must be accommodated in order to maintain the status quo. The plan needs to become more proactive and take forward a structured debate on some of the possibilities that the future offers. There is no recognition of the scale and the logistical challenges which will face SESplan; there is negligible exploration of different possibilities and no systemic framework within which the creative discussion is developed MIR-ID243-244 SESplan Vance Allen and Bill Rodger and which will allow interaction of the driving forces to be modelled. The preferred strategy should not adopt a single scenario but rather should explore a variety. Therefore, support a commensurate measure of effort to better understand the implications of a high growth scenario. Dependence on developer contributions is a constraint not only on developments themselves but, by compromising infrastructure provision, it impedes the very economic recovery which will underpin all elements of the plan. It is appropriate to embed the principle of sustainability throughout the plan. More emphasis in the strategy document must be given to the encouragement of new installations for dealing with the vast majority of waste generated from the commercial and industrial waste sectors. It must also be acknowledged that specialised waste management facilities will need to be identified and provided at a strategic level. It should be made abundantly clear that any future SDP waste strategy will address MIR-ID245-246 SESplan Viridor not only municipal / household waste but, also equally apply to the commercial and industrial waste sectors. Clearer guidance reflective of the Zero Waste Plan should be provided in the SDP outlining how commercial and industrial waste streams will be dealt with at both the strategic and LDP level. Seeks allocation of an area of land to the south of Blackridge within the new local development plan for West Lothian. Development MIR-ID031-022 WLC ABW Consultants (Scotland) Ltd aspirations for the site would fit with and compliment the strategic policy objectives of the SDP in relation to sustainable development, infrastructure requirements, transportation, employment land and housing.
Page 38 of 40 49 Item 5 - Appendix 1
Ref no LPA Respondee Summary of Comments Ashdale Land and Property A high growth scenario is supported. Market recovery is unsustainable. More housing land is required and could be accommodated within MIR-ID121-112 WLC Company Ltd. West Lothian in areas such as Broxburn / Uphall. The "high growth" scenario is supported. A flexible approach should be taken to meeting housing supply set out in this scenario. Sustainable MIR-ID189-180 WLC CEMEX Linlithgow greenfield release would support this scenario with development promoted in Linlithgow. Supports the preferred strategy in relation to CDA at Calderwood. A clear strategy for the delivery of essential infrastructure is required which MIR-ID180-171 WLC Davidson and Robertson can then filter through to LDPs. A flexible approach to planning requirements is required. Housing allocations should allow for the higher growth scenario. Land at Forkneuk could contribute to the housing land requirement and MIR-ID119-110 WLC Forkneuk Consortium provides a sustainable development location. Consider re-allocating employment land (which has not delivered for employment uses) to mixed use development to facilitate delivery and MIR-ID176-167 WLC Gladman Developments Ltd allow for economic growth. A generous supply of housing land should be made. The preferred approach for the West Lothian Corridor and the market recovery scenario are appropriate. The Heartlands site as currently Heartlands / Ecosse MIR-ID167-158 WLC allocated in the WLLP, together with an increase in allocations at the site would contribute to meeting the requirements for the West Lothian Regeneration corridor, promote brownfield development and promote sustainable development. The SDP should contain policies relating to Hopetoun Estate to allow the development of small scale rural housing in support of sustainable MIR-ID208-199 WLC Hopetoun Estates development, environmental improvements and local employment opportunities. Such an approach would make a significant contribution to affordable housing. Settlement expansion is promoted at Newton, Threemiletown and Philpstoun. More consideration needs to be given to the quality of development. There is no reference in the MIR to the environmental capacity of the MIR-ID069-060 WLC J Harris Edinburgh & SE Scotland area. Before using the word sustainable in the MIR there is need to measure the current resource demand of the population and what resources are available for us to use. The environmental consequences of our actions need to be taken more seriously.
A higher growth scenario should be adopted. Additional housing land should be brought forward before 2019. Tax increment finance should be adopted to facilitate the delivery of infrastructure. The retail hierarchy should recognise Glenrothes & Galashiels below Kirkcaldy, MIR-ID241-242 WLC K Cadell Dunfermline & Livingston. Disagree with setting a benchmark of 25% affordable housing contribution on all sites and oppose additional housing being added to already constrained major strategic sites. Cardenden should be a focus for new housing development in Fife Forth Corridor and could support an additional 1300 houses. A 12 acre site in Rosewell could contribute in the Midlothian Borders Corridor. MIR-ID178-169 WLC Land Securities Supports the aims and vision for the area and retail development at Livingston. Expansion of Linlithgow should be considered. Remove Linlithgow as an area of development constraint. Modest housing development (900 MIR-ID015-006 WLC Linlithgow Civic Trust units) could be undertaken, controlled as part of an action plan for the town and to accommodate unique infrastructure needs. MIR-ID059-050 WLC Linlithgow Climate Challenge Support preferred scenario based on market recovery provided appropriate environmental safeguards are put in place. Preferred approach to focus future housing growth in those areas identified for future economic growth is endorsed, however housing MIR-ID204-195 WLC LXB Properties numbers should be increased. The market recovery scenario is not supported. The preferred approach can only be a workable solution if the bias that currently exists towards development in the Armadale Area is addressed. Land owners located at the north side of Armadale are being unfairly discriminated against and being denied equal opportunity MIR-ID021-012 WLC Mr Slattery as development in the area is focussed to the south of Armadale. The current proposals should be rejected until these matters are addressed. A high growth scenario is supported. Market recovery is unsustainable. More housing land is required and could be accommodated within MIR-ID163-154 WLC Ogilvie Homes West Lothian. MIR needs to respond to economic recession and climate change. A more pro-active strategy required. Key aims mediocre, uninspiring and not forward thinking. Strategy is too narrowly based around housing. Need a range of proposed scenarios to mimic a more ecological model MIR-ID011-002 WLC Sarah Collings of the future and sustainable development. Suggest using a range of different densities as a starting point. Agree with linking future development to infrastructure and seeking of contributions. Tranpsort hubs must be the main locational factors in development. Preferred approach to Climate change is too weak. Housing allocations should allow for the higher growth scenario. Land at Dunfermline SW (Broomhall) and Calderwood has potential to support additional housing growth above the existing allocations. This would be consistent with the aims and priorities of SESplan and MIR-ID110-101 WLC Stirling Developments positively contribute to the SESplan vision. The sites benefit from good transport links, provision of infrastructure requirements would be more cost efficient and efficiently used in an expanded allocation.
Page 39 of 40 50 Item 5 - Appendix 1
Ref no LPA Respondee Summary of Comments Supports the inclusion of a site at Uphall for development. Development at Uphall would support sustainable development principles. The MIR-ID222-223 WLC Uphall Estates West Lothian corridor should be given greater priority than the south east and east corridors. More housing other than existing strategic allocations should come forward within the first plan period. Seeks the allocation of land at Murieston, Livingston for housing development. Broadly supportive of the preferred spatial strategy and MIR-ID036-027 WLC Wallace Land providing a spatial framework for the next 20 years and beyond. Not supportive of the market recovery scenario. More housing land is required and a high growth scenario put forward beyond the existing "high growth" scenario. The requirements of SPP have not been met in relation to West Lothian and the MIR presents a pessimistic view as opposed to optimistic in terms of housing need and demand. Further land release is required to ensure a 5 year effective supply. New land release could be MIR-ID090-081 WLC Wallace Land accommodated in the current CDAs and at Linlithgow. There is no correlation between the strategic housing requirement and the outcomes of the HoNDA. No particular comments to make on the MIR contents. Happy to support this preferred approach and would expect to advise West Lothian MIR-ID023-014 WLC WoSAS Council on the archaeological aspects of this approach in any emerging Local Development Plan for the area.
Page 40 of 40 51
SESplan Joint Committee Meeting
6 DECEMBER 2010
For Decision For Information
ITEM 6 – STRATEGIC DEVELOPMENT PLAN PROJECT PROGRESS UPDATE Report by SDP Manager
1. INTRODUCTION
1.1 This report provides an update on the progress of the project summarises key issues to be addressed in developing the Proposed Plan and proposes a programme including key milestones towards the delivery of the Proposed Plan.
2. SDP PROJECT PROGRESS SEPTEMBER – DECEMBER 2010
2.1 Since the Joint Committee met in September 2010, significant progress has been made including:
a) Summarising and making available of the responses to the Main Issues Report (MIR), Interim Environmental Report and Monitoring Statement;
b) Engagement with key stakeholders including Key Agencies;
c) Development of aspects of the Proposed Plan under economy, housing and environment workstreams and the appraisal of transport impacts and the Strategic Environmental Appraisal;
d) An audit of project planning processes; and
e) The agreement of the Annual Audit Report and a draft internal audit of governance.
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2.2 A report summarising the key themes in the response to the MIR and the Annual Audit Report will be considered under separate items.
Engagement with key stakeholders including Key Agencies
2.3 Project Board representatives have held further meetings with the Key Agencies Group at a national level and SEStran to establish arrangements for improved collaboration with SESplan. Further Board level meetings with key stakeholders including Transport Scotland, the Scottish Federation of Small Businesses and the Chamber of Commerce are planned.
Proposed Plan Work stream - Economy
2.4 The SESEC Operating Group is developing key inputs to ensure that the Proposed Plan supports the economic growth of the city region. The member authorities have updated their employment land audits and assessments of the expected land requirements including those in key sectors are underway.
Proposed Plan Work Stream - Housing
2.5 The Steering Group have recommended that for the purposes of preparing the proposed plan, estimates of housing need requirements should be based on the Housing Need and Demand Assessment (HNDA) and is completing a re-assessment of the land supply. Subject to the outcome of the re-assessment, the Steering Group and Board will consider whether there is a need to identify any additional land to maintain a generous supply of housing land throughout the plan period, as required by SPP. The Steering Group are developing an approach to considering options should there be a requirement to identify additional housing land.
53 2.6 The HNDA for SESplan was submitted to the Centre for Housing Market Analysis (CHMA) in early 2010. CHMA requested further information to support the HNDA and this has been provided. In a letter dated 27 September 2010, CHMA indicated that ‘HNDA undertaken by SESPlan covers the requirements of the HNDA Guidance’. In response to a request by CHMA, to inform consideration of the HNDA against the guidance and support its assessment as ‘robust and credible’, the Project Board is writing to confirm that it is content with the use of outputs from the HNDA for the purposes of the SDP. The confirmation will assist in CHMA’s consideration of the HNDA against the HNDA guidance.
2.7 The SESplan team are holding monthly liaison meetings with Homes for Scotland to discuss technical aspects of the approach to policy on housing land in the Proposed Plan.
Proposed Plan - Environment
2.8 Forestry Commission Scotland (FCS) and SNH are working with the SESplan team to identify key resources and opportunities in the Central Scotland Green Network to inform the Proposed Plan. FCS and SNH are advising SESplan on relevant content in the plan and any supplementary planning guidance on the network which may be appropriate. FCS, SNH and SESplan are liaising with Scottish Borders Council to coordinate work on the green networks across the Scottish Borders and CSGN areas.
Proposed Plan – Transport
2.9 The SESplan Project Board and Steering Group are liaising with SEStran to complete an appraisal of the transport implications of the development strategy. This will take into consideration any relevant changes from the preferred options in the MIR in the Proposed Plan. Senior representatives of Transport Scotland and the Director of Built Environment and Chief Planner have been invited to attend the Project Board meeting on 10 December to discuss strategic issues and Transport Scotland involvement in the Proposed Plan.
54 Strategic Environmental Assessment
2.10 To address the concerns regarding the Strategic Environmental Assessment raised in the Consulting Authorities response to the Environmental Report, Scottish Government facilitated meetings with SEPA, SNH, Historic Scotland and the SEA Gateway to consider the development of the SEA for the proposed plan. SEPA, SNH and Historic Scotland are collaborating with SESplan in the SEA for the proposed plan.
Project Planning Processes
2.11 The SESplan team and Board are completing an audit of the project planning processes for the SDP. This audit will include a consideration of SESplan’s approach to managing issues and risk. It is planned that a paper outlining our approach to project management including risk management is brought to a future meeting of the Joint Committee.
3. PROGRAMME AND MILESTONES
3.1 As noted at the Joint Committee in September 2010, the Scottish Government has recognised that addressing key issues including housing land, transport and infrastructure as outlined above and others emerging in the responses to the MIR, such as climate change and developing positions on renewables and minerals will require the involvement of a wide range of key stakeholders in the development of the proposed plan.
3.2 The Project Board have reviewed the issues arising around the housing land supply and the process needed to complete a re-appraisal of the land supply and possibly to review allocations and identify additional allocations to ensure that the SDP is consistent with SPP. It recognised that this process must be rigorous and one in which SESplan, the member authorities and other stakeholders have confidence. In turn a rigorous process will help ensure that the SDP is developed as a robust plan which is consistent with SPP and supports sustainable economic growth.
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3.3 The Board and SDP Manager consider that it is impractical to address the issues on the land supply and, if necessary, review housing land allocations within the programme agreed at the meeting of the Joint Committee on 27 September 2010.
3.4 To enable the completion of the process outlined above, it is recommended that the programme, leading to the publication of the Proposed Plan in October 2011, as set out in Appendix 1 is adopted. Scottish Government has accepted informally that SESplan may wish to further review and amend its the programme as set out in Appendix 1
4. RECOMMENDATION
4.1 It is recommended that the Joint Committee:
a) Notes the progress of the SDP in the period September – December 2010 and the proposed work under the work streams outlined above; and
b) Approves the amended timetable for the preparation, approval and publication of the Proposed Plan as set out in Appendix 1 to this report.
Ian Angus SDP Manager Email – [email protected] Tel – 0131 524 5158
APPENDICES Appendix 1: Proposed Amended Timetable to Publish Proposed Plan
56
BACKGROUND PAPERS SESplan Main Issues Report, May 2010 SESplan Monitoring Statement, May 2010 SESplan Interim Environmental Report, May 2010 SESplan Housing Need and Demand Assessment, March 2010 SESplan Development Plan Scheme 2, April 2010
Policy Implications None
Financial Implications None
Race Equalities Implications None
Gender Equalities Implications None
Disability Equalities Implications None
57
Appendix 1 - Strategic Development Plan Progress Update
Proposed Amended Timetable to Publish Proposed Plan October 2011
Meetings/Tasks Date
SESplan Joint Committee 6 December 2010
Project Board 10 December 2010
Project Board 3 February 2010
w/b 7 February 2011 Board / Joint Committee Seminar on Proposed Plan (tbc)
Board / Joint Committee Seminar on Proposed Plan 4 April 2011 (tbc)
Final Proposed Plan to Project Board for sign off 6 May 2011
SESplan Joint Committee Approves Proposed Plan 13 June 2011
Ratification of Proposed Plan by partner authorities June – September 2011
Publication October 2011
58
SESPLAN JOINT COMMITTEE 6 DECEMBER 2010
For Decision For Information
ITEM 7 – OPERATING BUDGET 2010 / 2011 (6 MONTH) FINANCIAL REPORT Report by SDP Project Manager
1. INTRODUCTION
1.1 This report presents the 6 month financial report for the year 2010 / 2011 and covers the period April to September 2010.
1.2 The final out turn position on the 2009 / 2010 Operating Budget was considered at the SESplan Joint Committee on the 27 September 2010 and the 2010 / 2011 Operating Budget was approved at the SESplan Joint Committee held on the 25 January 2010.
2. BACKGROUND
2.1 SESplan Financial Regulations Reporting Requirements specify that detailed monitoring reports are to be submitted to the SESplan Joint Committee at the 6, 9 and 12 month stages of each financial year.
2.2 This report is the 6 month report for the financial year 2010 / 2011.
3. FORECAST 2010 / 2011 6 MONTH FINANCIAL POSITION
3.1 Appendix 1 presents the forecast out turn position for 2010 / 2011 which is reporting an underspend of £65,000.
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3.2 Within the ‘Fixed Costs’ element of the budget, it is forecast that there will be an underspend on staffing of £7,000. The fixed costs reported within Appendix 1 does include an allowance for the recruitment of a temporary graduate planner from January 2011 to the end of March 2011, and the process of recruitment has been initiated.
3.3 There is a forecast overspend of £7,000 on team accommodation, administration and IT. The forecast is however based on 2009 / 2010 Quarter 4 information which contains costs relating to one off items such as server upgrades and the maintenance of the video conference facility. It is also important to note that the lease of the SESplan offices expires in May 2011 and negotiations on the lease are underway through SEStran. The Project Board are considering the issues around the accommodation of the SESplan team and update will be brought to a future meeting of the Joint Committee.
3.4 Within the ‘Variable Costs’, an underspend of £35,000 is forecast. Under the elements of Public engagement / Facilitation and Printing, the spend to date on the Main Issues Report Consultation has been calculated as £40,000 against a total budget of £45,000. Under the 2010 / 2011 Consultancies, the forecast spend is £50,000 against a budget of £80,000, providing for a forecast underspend of £30,000.
3.5 The forecast underspend relates to the remaining balance of the Scottish Government Start Up Grant and is proposed to be carried forward to 2011 / 2012, allowing member contributions to remain at £40,000 per authority. The underspend will be set aside as a contingency against the Examination.
3.6 A further update will be provided in the 9 Month report to be presented to SESplan Joint Committee in March 2011.
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4. RECOMMENDATION
4.1 It is recommended that the Joint Committee,
a) Agree that any surplus funding be carried forward to 2011 / 2012.
Ian Angus SDP Project Manager Email – [email protected] Tel – 0131 5245158
Report Drafted By: Alice Miles Lead Officer Email – [email protected] Tel – 0131 5245167
APPENDICES Appendix 1: Operating Budget 2010 / 2011 (6 Month) Financial Report
Policy Implications None Financial Implications None Race Equalities Implications None Gender Equalities Implications None Disability Equalities Implications None
61
Appendix 1 - Operating Budget 2010 / 2011 (6 Month) Financial Report
2010/11 2010/11 2010/11 Cost per Budget1 Forecast2 Variance council pa FIXED COSTS Team salaries + oncosts (based on team of 3) 148,000 141,000 -7,000 23,500
Team Accommodation, admin & IT 45,000 52,000 7,000 8,667
Audit Fee 3,750 3,750 0 625
Consumables, travel, training, misc 6,750 12,000 5,250 2,000
TOTAL Fixed Costs 203,500 208,750 5,250 34,792
VARIABLE COSTS 2010/11 Consultancies 80,000 50,000 -30,000 8,333 Regional Retail Assessment - Catchment only - 00 0 0 shared with CEC Econ Dev Housing Need and Demand Assessment 0 0 0 0
Employment Forecasts 0 0 0 0
SEA of Main Issues Report 0 0 0 0 Climate Change & SDPs study (Joint bid with other 00 0 0 SDPAs for ESRC funding) Public engagement/Facilitation 20,000 14,000 -6,000 2,333
Printing - leaflets, MIR, supp docs 25,000 26,000 1,000 4,333
Add: 10% contingency 15,000 10,000 -5,000 1,667
TOTAL Variable Costs 140,000 100,000 -40,000 16,667 TOTAL COSTS 343,500 308,750 -34,750 51,458
FUNDED BY Balance Carried Forward From 09/10 110,398 133,302 22,904 22,217 Partner Contributions 240,000 240,000 0 40,000 Sale of Plans 0 500 500 83 Interest On Revenue Balances 2,000 500 -1,500 83 TOTAL INCOME 352,398 374,302 21,904 62,384
Balance Carried Forward to 2010/11 -8,898 -65,552 -56,654 -10,925
1 As approved by SESplan Joint Committee on the 25 January 2010 2 Forecast Out Turn Position for 2010 / 2011 62
SESPLAN JOINT COMMITTEE 6 DECEMBER 2010
For Decision For Information
ITEM 8 – OPERATING BUDGET 2011 / 2012 Report by SDP Project Manager
1. INTRODUCTION
1.1 This report presents for approval a proposed SESplan Operating Budget and invites member council contributions for financial year 2011 / 2012.
1.2 The final out turn position on the 2009 / 2010 Operating Budget was considered at the SESplan Joint Committee on the 27 September 2010 and the 2010 / 2011 Operating Budget was approved at the SESplan Joint Committee held on the 25 January 2010.
2. BACKGROUND
2.1 The constitution establishes the principle that joint costs of SESplan will be shared equally by the six member councils, in line with Scottish Government guidance.
2.2 The SESplan Scheme of Delegation states that powers delegated must be carried out within the financial parameters set out by the separate minute of agreement on finance (‘the financial rules’). These financial rules, proposed that each member council should pay its full annual contribution to Fife Council, on behalf of SESplan, by the end of April in each financial year.
63 3. PROPOSED 2011 / 2012 OPERATING BUDGET
3.1 The proposed Operating Budget for 2011 / 2012, covering the period 1 April 2011 – 31 March 2012 is set out within Appendix 1. The proposed Budget identifies fixed costs relating to staffing and accommodation together with variable costs relating to spend on items such as commissioning research studies or advice from consultants.
3.2 The fixed costs estimate is £230,300. Around 77% of this is staff costs associated with the Core Team including 3 permanent members of staff and a temporary graduate planner.
3.3 As discussed under Item 7, the appointment of a temporary graduate planner is underway. The temporary member of staff will be recruited on a six month basis (1 January 2011 – 30 June 2011). Three months costs of this additional post will be met through the 2010 / 2011 Operating Budget with the remaining three months accounted for within the fixed costs of the proposed 2011 / 2012 Operating Budget. The proposed 2011 / 2012 Operating Budget also allows for a further six month temporary appointment should it be required. This has not yet been approved, providing an opportunity for savings in the year of this post is not required.
3.4 The proposed Operating Budget for 2011 / 2012 estimates that Team Accommodation, Administration and IT costs will remain as in 2010-11 with the exception of an allowance for the costs associated with the temporary appointment noted above. It is also important to note however that the lease of the SESplan offices expires in May 2011 and negotiations on the lease are underway through SEStran. The Project Board are considering the issues around the accommodation of the SESplan team and an update will be brought to a future meeting of the Joint Committee.
3.5 Variable costs have been estimated at £68,400, with a 10% contingency added to provide a margin of flexibility. The total variable costs are therefore estimated at £76,000 and include an allowance for the publication and printing of the Proposed Plan. An allowance has also been provided for the publication and printing of a Modified Plan. It is not yet known whether a Modified Plan will be required; therefore there may be further opportunity for savings to be made.
64
3.6 Combined fixed and variable costs are estimated at £306,300. These are the best estimates based on our current project knowledge and expenditure incurred in 2010 / 2011.
4. MEMBER COUNCILS’ NET LIABILITY
4.1 Each member authority is liable for one sixth of the annual operating budget. The overall 2011 / 2012 Operating Budget is estimated at £306,300, equating to £51,050 per member. However, when offset against the forecast 2010 / 2011 underspend, this gives a figure of £40,000 contribution per authority. The budget proposes the application of the balance of the Scottish Government Start Up Grant and provides for a minimum carry forward of £252 to 2012 / 2013.
4.2 It is important to note that where savings are made in 2010 / 2011 and 2011 / 2012 these will be set aside as a contingency against the Examination (scheduled for 2012), the costs for which are not yet known.
4.3 The financial rules state that members’ contributions be in place by the end of April each year – within one month of the start of the financial year. It is therefore requested that the £40,000 be paid to Fife Council on or before the 30 April 2011.
4.4 It is requested that all member councils take steps now in their current budget setting rounds to ensure that contributions will be in place by the start of the next financial year.
5. FINANCIAL IMPLICATIONS
5.1 SESplan needs £306,300 to fund its work, equating to £51,050 per member authority. This is reduced to £40,000 per member authority when offset against the forecast 2010 / 2011 underspend. This needs to be reflected in each authority’s forward budget setting.
5.2 Regular reports on budget performance will continue to be presented to the Joint Committee by the SDP Manager at the 6, 9 and 12 month stages of each financial year.
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6. RECOMMENDATION
6.1 It is recommended that the Joint Committee,
a) Approves the proposed SESplan 2011 / 2012 Operating Budget as set out in Appendix 1. b) Agrees to set member council contributions for 2011 / 2012 at £40,000 per member authority, payable to Fife Council by the 30 April 2011. c) Instructs officers to invite the member councils to ratify recommendations a) and b) and to make their required contributions by the due date. d) Notes that regular reports on budget performance at the 6, 9 and 12 month stages of each financial year will be presented to Committee by the SDP Manager.
Ian Angus SDP Project Manager Email – [email protected] Tel – 0131 5245158
Report Drafted By: Alice Miles Lead Officer Email – [email protected] Tel – 0131 5245167
APPENDICES Appendix 1: Operating Budget 2011 / 2012
Policy Implications None Financial Implications None Race Equalities Implications None Gender Equalities Implications None Disability Equalities Implications None
66 Appendix 1: Operating Budget 2011 / 2012 2010 / 2011 2010 / 2011 6 OPERATING MONTH COST PER BUDGET FINANCIAL 2011 / 2012 MEMBER (Approved at REPORT (Being BUDGET AUTHORITY Joint Committee considered 2011 / 2012 25 Jan 2010) Under Item 7)
FIXED COSTS
Team Salaries and Oncosts 148,000 141,000 158,000 26,333
Team Accommodation, Admin and IT 45,000 52,000 55,500 9,250
Audit Fee 3,750 3,750 3,800 633
Consumables, Travel, Training, Misc 6,750 12,000 13,000 2,167
Total Fixed Costs 203,500 208,750 230,300 38,383
VARIABLE COSTS
2010 / 2011 Consultancies 80,000 50,000 0 0 Main Issues Report - Public 20,000 14,00000 Engagement / Facilitation Main Issues Report - Printing 25,000 26,000 0 0 2011 / 2012 Consultancies (includes for 00 68,400 11,400 proposed plan consultation / printing) Add: 10% contingency 15,000 10,000 7,600 1,267
Total Variable Costs 140,000 100,000 76,000 12,667
TOTAL COSTS 343,500 308,750 306,300 51,050
INCOME Balance Carried Forward 110,398 133,302 65,552 10,925
Partner Contributions 240,000 240,000 240,000 40,000
Sales of Plans 0 500 500 83
Interest On Revenue Balances 2,000 500 500 83
TOTAL INCOME 352,398 374,302 306,552
SURPLUS / DEFICIT 8,898 65,552 252
67
SESPLAN JOINT COMMITTEE 6 DECEMBER 2010
For Decision For Information
ITEM 9 – ANNUAL AUDIT 2009 / 2010 Report by SDP Project Manager
1. INTRODUCTION
1.1 This report introduces the Annual Audit 2009 / 2010 prepared by Scott-Moncrieff together with a Draft Governance Systems Review prepared by Fife Council Audit Services.
2. ANNUAL AUDIT REPORT
2.1 The Annual Audit Report which was completed by Scott-Moncrieff is provided as Appendix 1. The Annual Audit has been discussed and agreed with the SESplan Treasurer and SDP Manager and was submitted to Audit Scotland on the 29 October 2010.
2.2 The main elements of the Annual Audit were to, Audit the financial statements, including a review of the Statement on the System of Internal Financial Control, Review corporate governance arrangements, and Review internal financial controls and financial systems.
2.3 The Annual Audit concluded that the organisation’s governance arrangements are in general satisfactory.
2.4 The Action Plan (See Page 11 of Appendix 1) sets out an agreed action to address a recommendation that arrangements are put in place to regularly review and update a risk register. The Audit Report also notes areas for improvement in SESplan governance systems as identified in the Draft Governance Systems Review undertaken by Fife Council.
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2.5 It is proposed that a review of project management including risk management is undertaken and reported to the SESplan Project Board in December. A process for an annual review of risk management by SESplan elected members will be recommended to the March 2011 meeting of the Joint Committee.
3. SESPLAN GOVERNANCE SYSTEMS REVIEW
3.1 The Draft Governance Systems Review undertaken by Fife Council provides, A review of the set-up and governance arrangements, including financial rules, and A high level overview of other systems.
3.2 The Audit undertaken forms part of the Strategic Audit Plan for Fife Council Audit Services Division, acting as Internal Auditor to SESplan. Scott-Moncrieff, External Auditor has advised that it wants to place reliance on this review as part of its 2009 / 2010 Audit.
3.3 The Draft Action Plan (See Page 11 - 12 of Appendix 2) sets out five recommendations for action as follows, SESplan should develop a system for following up points arising at Joint Committee meetings, ensuring they are reported back, particularly where items are approved for ratification at each of the member authorities. SESplan should review its governance arrangements. SESplan should agree formal arrangements for obtaining and funding administrative support. SESplan should develop appropriate arrangements for assessing, obtaining and monitoring Best Value. SESplan should develop a publications policy.
3.4 The SESplan team is working with Fife Council Audit Services to finalise the Action Plan which will address the recommendations.
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3.5 As detailed in paragraph 2.4 above it is proposed that a review of the project management and governance arrangements is undertaken and reported to the SESplan Project Board in December. A process for an annual review of risk management by SESplan elected members will be recommended to the March 2011 meeting of the Joint Committee.
4. RECOMMENDATION
4.1 It is recommended that the Joint Committee,
a) Notes the Annual Audit 2009 / 2010. b) Notes the Draft Governance Systems Review 2009 / 2010.
Ian Angus SDP Project Manager Email – [email protected] Tel – 0131 5245158
Report Drafted By: Alice Miles Lead Officer Email – [email protected] Tel – 0131 5245167
APPENDICES Appendix 1: Annual Audit Report 2009 / 2010 Appendix 2: Draft Governance Systems Review 2009 / 2010
Policy Implications None Financial Implications None Race Equalities Implications None Gender Equalities Implications None Disability Equalities Implications None
70 Edinburgh and South East Scotland Strategic Development Planning Authority (SESplan) Annual Report on the Audit to SESplan and the Controller of Audit 2009/10
October 2010
71
Edinburgh and South East Scotland Strategic Development Planning Authority (SESPlan) Annual Report on the Audit to SESplan and the Controller of Audit 2009/10
Executive summary ...... 1
Introduction ...... 2
Financial statements...... 3
Governance...... 7
Appendix 1: Action Plan ...... 10
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Executive summary
Financial statements
We are pleased to report that our independent auditors’ report contains an unqualified audit opinion on the financial statements for the year ended 31 March 2010. We also certify that the accounts have been properly prepared in accordance with relevant legislation, applicable accounting standards and other reporting requirements.
SESplan reported a surplus for the year of £10,268 (2008/09: £118,848). The general fund balance brought forward of £118,848 at 1 April 2009 increased to a cumulative net surplus balance of £129,116 at 31 March 2010. 2009/10 was the first full year of operation and expenditure related mainly to staffing and accommodation. This was funded by Scottish Government grant funding and contributions from the constituent authorities.
Governance
Fife Council’s Audit and Risk Management Services provide an internal audit function to SESplan. During 2009/10, they carried out a review of SESplan’s governance arrangements. The review identified a number of areas of improvement for SESplan to address and an action plan has been developed to take forward these. We have placed reliance, where appropriate, on Audit and Risk Management Services work during the year.
We have reviewed SESplan’s corporate governance arrangements in relation to its systems of internal financial control and standards of conduct including the prevention and detection of fraud and corruption. Our review confirmed that the organisation’s governance arrangements are, in general, satisfactory.
Conclusion
This report concludes our audit of SESplan for 2009/10. We have performed our audit in accordance with the Code of Audit Practice published by Audit Scotland, International Standards on Auditing (UK and Ireland) and Ethical Standards.
This report has been discussed and agreed with the SESplan Treasurer. We would like to thank all management and staff for their co-operation and assistance during our audit.
Scott-Moncrieff October 2010
SESplan Scott-Moncrieff Annual Report on the Audit to SESplan and the Controller of Audit Page 1 October 2010 73
Introduction
1 This report summarises the findings from our 2009/10 audit of the Edinburgh and South East Scotland Strategic Development Authority (SESplan).
2 The main elements of our audit work in 2009/10 have been: • Audit of the financial statements, including a review of the Statement on the System of Internal Financial Control • Review of corporate governance arrangements • Review of internal financial controls and financial systems
3 The key findings arising from our work are summarised in this annual report.
4 Our findings are drawn together within two sections: • Financial Statements: summarises the key outcomes from our 2009/10 audit of SESplan’s financial statements • Governance: covers a summary of SESplan’s corporate governance arrangements
5 This report is addressed to SESplan and the Controller of Audit and will be published on Audit Scotland’s website, www.audit-scotland.gov.uk.
SESplan Scott-Moncrieff Annual Report on the Audit to SESplan and the Controller of Audit Page 2 October 2010 74
Financial statements
Introduction
6 Financial statements are a key way by which SESplan accounts for the stewardship of the resources made available it. In this section we summarise the key outcomes from our 2009/10 audit of SESplan’s financial statements.
Our Responsibilities
7 We audit the financial statements and give an opinion on:
• whether they give a true and fair view, in accordance with relevant legal and regulatory requirements and the Code of Practice on Local Authority Accounting in the United Kingdom 2009 – A Statement of Recommended Practice (the SORP), of the financial position of the organisation and of its income and expenditure for the year then ended; and • whether they have been properly prepared in accordance with the Local Government (Scotland) Act 1973.
8 We also review the Statement on the System of Internal Financial Control by considering the adequacy of the process put in place by the Treasurer to obtain assurances on systems of internal control. We assess whether disclosures in the statement are consistent with our knowledge of SESplan.
Independence
9 International Standard on Auditing 260 – Communication of Audit Matters with those Charged with Governance – requires us to communicate on a timely basis all facts and matters that may have a bearing on our independence.
10 We provided no additional services to SESplan during the year and can confirm that we have complied with the Auditing Practices Board Ethical Standard 1 – Integrity, Objectivity and Independence. In our professional judgement the audit process has been independent and our objectivity has not been compromised.
Legality
11 We have planned and performed our audit recognising that non-compliance with statute or regulations may materially effect the financial statements. Our audit procedures included the following:
• Reviewing minutes of relevant meetings • Enquiring of senior management and the organisation’s solicitors the position in relation to litigation, claims and assessments
SESplan Scott-Moncrieff Annual Report on the Audit to SESplan and the Controller of Audit Page 3 October 2010 75
• Performing detailed testing of transactions and balances
12 We are pleased to report that we did not identify any instances of concern with regard to the legality of transactions or events.
Responsibility for the Statement of Accounts
13 It is the responsibility of the SESplan and the Treasurer to prepare the financial statements in accordance with the proper practices set out in the CIPFA/LASAAC Code of Practice on Local Authority Accounting in the United Kingdom (the SORP). This means:
• Acting within the law and ensuring the regularity of transactions • Maintaining proper accounting records • Preparing financial statements which give a true and fair view of the financial position of the organisation and its expenditure and income for the period ended 31 March 2010.
Overall conclusion
14 Our audit report is included on pages 14 and 15 of the annual accounts and is addressed to members of SESplan and the Accounts Commission for Scotland. The report was issued on 29 September 2010 and is unqualified. We also certify that the accounts have been prepared properly in accordance with relevant legislation, applicable accounting standards and other reporting requirements.
15 SESplan is required under Regulation 4 of the Local Authority Accounts (Scotland) Regulations 1985 to submit a copy of an abstract of their accounts to the Controller of Audit by 30 June. We are pleased to confirm that SESplan’s unaudited financial statements were submitted to the Controller of Audit by the deadline of 30 June.
Format of the Accounts
16 In accordance with the designation orders and associated statutory guidance, SESplan meets the definition of a joint committee under section 106 of the Local Government (Scotland) Act 1973. Section 106 extends to the accounts and audit provision of the 1973 Act to joint committees. SESplan is therefore required to produce separate accounts which comply with the SORP.
17 The SORP specifies the principles and practices of accounting required to prepare a statement of accounts which give a true and fair view of the financial position and transactions of an organisation.
18 As part of our 2009/10 audit we considered the arrangements SESplan had in place to ensure compliance with the requirements of the SORP. Overall we concluded that SESplan has complied with the requirements of the SORP.
SESplan Scott-Moncrieff Annual Report on the Audit to SESplan and the Controller of Audit Page 4 October 2010 76
Audit Adjustments
19 We identified no major errors or weaknesses during our audit. The financial statements were updated for the potential adjustments identified during our audit work. The net effect on the financial statements is as follows:
Table 1: Impact of audit adjustments £ Surplus for the year per the draft accounts 23,686 Unrecognised expenditure (13,418) Adjusted surplus per the audited accounts 10,268
20 The adjustment relates to a quarterly invoice from City of Edinburgh Council which had not been accrued for in the financial statements.
Internal Audit
21 Effective co-ordination between internal audit and external audit is essential in order to minimise duplication of effort and maximise the benefits of audit. Fife Council’s Audit and Risk Management Services provides internal audit function to SESplan. As required by the Code of Audit Practice, we have established appropriate working arrangements with Fife Council’s internal audit function.
22 In accordance with the Code of Audit Practice and International Standard on Auditing 610 – Considering the work of internal audit, “the external auditor should perform an assessment of the internal audit function when internal auditing is relevant to the external auditor’s risk assessment”. Overall we concluded that reliance could be placed on the work of internal audit. To avoid duplication of effort and to ensure an efficient audit process, we have made use of internal audit work where appropriate.
Accounting and internal control systems
23 During our audit we reviewed the key financial systems in place within the organisation. Overall we found the systems of internal financial control reviewed to be of a good standard with controls operating at an adequate or effective level.
Statement on the System of Internal Financial Control
24 SESplan has published a statement on the system of internal financial control within the 2009/10 statement of accounts. The statement provides an overview of the key elements of the organisation’s governance arrangements and systems of internal financial control.
25 As part of our audit work we are required to review the information disclosed in the statement and assess whether SESplan’s opinion on the effectiveness of its internal financial controls is consistent with our understanding of the internal financial control framework.
SESplan Scott-Moncrieff Annual Report on the Audit to SESplan and the Controller of Audit Page 5 October 2010 77
26 During our audit we identified a number of changes required to be made to the statement to ensure it reflected the actual arrangements in place. The statement of internal financial control as presented in the annual accounts submitted to the Controller of Audit on 30 June 2010 reported the following arrangements which were not applicable or in place at SESplan:
• The Treasurers review of the effectiveness of the system of internal financial control will be informed by the certification of grant claims • The Partnership Director’s assurance certificate on internal controls
27 The statement was updated accordingly and we are satisfied with the disclosures made in the revised statement reflect the actual arrangements in place at SESplan. The revised statement is consistent with our knowledge and understanding of the internal financial control framework operating at SESplan.
Financial Position
28 SESplan reported a surplus for the year of £10,268 (2008/09: £118,848). The general fund balance brought forward of £118,848 at 1 April 2009 increased to a cumulative net surplus balance of £129,116 at 31 March 2010. 2009/10 was the first full year of operation and expenditure related mainly to staffing and accommodation. This was funded by Scottish Government grant funding and contributions from the constituent authorities.
Looking Forward
29 In 2008 the CIPFA/LASAAC local authority SORP board confirmed that from 2010/11 all local authority accounts will be prepared in accordance with International Financial Reporting Standards (IFRS). This change will bring local government bodies into line with other UK public sector bodies. It is essential that SESplan starts the transition period in 2009/10. A comparative balance sheet as at 1 April 2009 will be required.
SESplan Scott-Moncrieff Annual Report on the Audit to SESplan and the Controller of Audit Page 6 October 2010 78
Governance
30 Governance is about direction and control of organisations. It is concerned with structures and processes for decision making and accountability. Good governance can be defined as “the way a local authority operates is based on sound decision-making and effective processes are in place to support these decisions”.
31 This section sets out the main findings from our review of SESplan’s corporate governance arrangements.
Governance Arrangements
32 The Designation Order which formally constituted the Edinburgh and South East Scotland Strategic Development Planning Authority (SESplan) came into force on 25 June 2008. In June 2008 the SESplan joint committee was formally established. The Joint Committee comprises twelve councillors, two from each of the six constituent authorities:
• Fife Council • City of Edinburgh • East Lothian Council • Midlothian Council • Scottish Borders Council • West Lothian Council
33 As a group, these councils have a statutory duty to work together to prepare, and keep under review, a strategic development plan for the Edinburgh city region.
34 During 2009/10, Fife Council’s internal audit service carried out a review of SESplan’s governance arrangements. The review identified a number of areas of improvement for SESplan to address (table 2). We have placed reliance, where appropriate, on this work during the year.
Table 2: Areas for improvement identified by internal audit • SESplan has no system for following up points arising at Joint Committee meetings to ensure that they are reported back and results included in the minutes. This is particularly important where ratification is required from Member Authorities. • The objectives, obligations and responsibilities of SESplan and the Member Authorities, and the performance management and reporting requirements for administrative and financial support are not clearly set out in the governance documents. • SESplan’s governance arrangements have not been reviewed to assess how it does and wishes to perform its business, and how this is and should be set out in its official documents • SESplan has not considered either arrangements for assessing, obtaining or monitoring Best Value or the assumption in the statutory guidance that, apart from start up costs, only a redistribution of existing council resources is required.
SESplan Scott-Moncrieff Annual Report on the Audit to SESplan and the Controller of Audit Page 7 October 2010 79
Table 2: Areas for improvement identified by internal audit • SESplan does not adequately monitor that member authorities fulfil their roles in providing administrative support and complying with SESplan’s Financial Regulations • SESplan should develop a publications policy and procedures to ensure it meets its duties for accountability for public money. Source: Fife Council’s internal audit report (draft), SESplan governance review
35 The draft report also notes that SESplan has not formally agreed arrangements for obtaining and funding its administrative support (financial, HR and legal services) through service level agreements, including a scheme for monitoring and reporting the provision and costs. We also highlighted this in our 2008/09 annual audit report to SESplan and the Controller of Audit.
36 Fife Council’s internal audit report includes an action plan with recommendations to address these points. We would encourage SESplan to address these as a matter of priority.
Risk management
37 An important feature of a robust system of internal control is a developed and integrated approach to risk management. Effective risk management will deliver an appropriate balance between risk and control, more effective decision making, better use of limited resources and greater innovation.
38 SESplan has developed a risk register which provides a record of the key risks facing the organisation. During our review however we noted that the the register is not regularly reviewed and updated. Action plan point 1
Prevention and detection of fraud and irregularity
39 The integrity of public funds is at all times a matter of concern. As external auditors we are required to consider the arrangements made by management for the prevention and detection of fraud and irregularities. Our responsibilities in this area are addressed in a number of ways:
• Our systems based audit approach to the major accounting systems is planned so as to provide a reasonable expectation of detecting material misstatements resulting from fraud or error • We focus on specific areas of high risk for potential fraud and irregularity and review the control arrangements in place in these areas • We review the Audit Scotland Technical Bulletins with regard to fraud reports and ensure that the authority has adequate arrangements in place to stop similar frauds occurring • We examine the key governance documents issued by the organisation to ensure that they deal adequately with fraud and corruption and provide a framework for exercising strong internal control
SESplan Scott-Moncrieff Annual Report on the Audit to SESplan and the Controller of Audit Page 8 October 2010 80
40 We have performed a review of the arrangements for the prevention and detection of fraud, irregularity and corruption in place at SESplan. Our review concluded that the arrangements are satisfactory to prevent and detect fraud and other irregularities.
Performance
41 The Joint Committee has developed a Development Plan Scheme (DPS) which outlines how the organisation will prepare and maintain the strategic development plan. The DPS includes a timetable for the creation of the strategic development plan. Progress on the implementation of the DPS is monitored by the Joint Committee. The DPS is reviewed and updated on an annual basis. Table 3 shows the progress to date against the timetable.
Table 3: Progress against timetable (including in the DPS) Stage Implementation date Completed SESplan created June 2008 ✔ Approval of Edinburgh and South East November 2008 ✔ Scotland SDP Boundary Publication of Development Plan March 2009 ✔ Scheme Number 1 Preparation of Main Issues Report and January 2009 – December supporting documents, commissioning ✘ 2009 (now March) and receiving background studies. Publication of Main Issues Report (MIR) Dec 2009 May 2010 ✘ and Environmental Report (ER) Source: SESplan DPS1 and DPS2
42 The preparation and subsequent publication of the Main Issues Report and Environmental Report was delayed due as the background information required to prepare the report not being formally published until May 2010. SESplan do not envisage that this will delay the overall project. It is the intention that the final strategic development plan will be submitted to Scottish Ministers in line with the original forecast of March 2012.
SESplan Scott-Moncrieff Annual Report on the Audit to SESplan and the Controller of Audit Page 9 October 2010 81
Appendix 1: Action Plan
Our action plan details the key weaknesses and opportunities for improvement that we have identified during this review. To assist SESplan in assessing the significance of the issue raised and prioritising the action required to address it, the recommendation has been rated.
It should be noted that the weaknesses identified in this report are only those that have come to our attention during the course of our normal audit work. The audit cannot be expected to detect all errors, weaknesses or opportunities for improvements in management arrangements that may exist.
Our grading structure helps management assess the significance of the issues raised and prioritise the action required to address them. The grading structure is as follows:
Grade 5 Very high risk exposure - Major concerns requiring Joint Committee attention.
Grade 4 High risk exposure - Material observations requiring management attention.
Grade 3 Moderate risk exposure - Significant observations requiring management attention.
Grade 2 Limited risk exposure - Minor observations requiring management attention
Grade 1 Efficiency / housekeeping point.
SESplan Scott-Moncrieff Annual Report on the Audit to SESplan and the Controller of Audit Page 10 October 2010 82
Action Para Action Plan Point Recommendation and Management comments Responsible Agreed Plan Ref Rating Officer Completion Ref Date 1 38 Risk management We recommend that Establish a process of regular Ian Angus 31 March Whilst SESplan has established a risk SESplan put in place review of the risk register by 2011 register to record all potential risks to the arrangements to regularly the Project Board and annual organisation, the register is not subject to review and update its risk review by the Joint regular review by management. A risk register. Committee agreed by the register is an important tool in ensuring that Priority 3 Joint Committee. risks have been identified and managed by the organisation.
SESplan Scott-Moncrieff Annual Report on the Audit to SESplan and the Controller of Audit Page 11 October 2010 83
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84
Audit Report Issued
Audit Services
Draft for Discussion Only
SESplan
The Strategic Development Planning Authority for Edinburgh and South East Scotland
Governance Systems Review
Management’s Responsibility for Internal Control Management is responsible for internal control and provides an annual statement on the system of internal financial control within its statement of accounts. Management, having undertaken an assessment of the risks involved and/or having been advised of areas of risk by internal audit, external audit, or another inspection body, is responsible for putting appropriate internal controls in place. If proper internal controls are not in place, Management must accept responsibility for the increased risk of fraud and error.
85
CONTENTS
Executive Summary ...... 1
1. Introduction ...... 3
2. Arrangements between SESplan and Member Authorities ...... 4
3. SESplan’s Constitution and Management Arrangements ...... 5
4. Administrative Support Arrangements ...... 6
5. Action Plan...... 11
86 SESplan Date printed 15/11/2010 Draft for Discussion Only
Executive Summary
This audit reviews the set-up and governance arrangements, including financial rules and a high level overview of other systems, of SESplan, the Strategic Development Planning Authority (SDPA) for Edinburgh and South East Scotland. This audit forms part of the Strategic Audit Plan of Fife Council Audit Services Division, acting as Internal Auditor to SESplan. Scott-Moncrieff, External Auditor, has advised that it wants to place reliance on this review as part of its 2009/10 audit.
Good Practice Points SESplan has a constitution accepted by the Member Authorities, consistent with its assessment of its duties and objectives, including delegations from Member Authorities for performing the role of Strategic Development Planning Authority (SDPA) for Edinburgh and South East Scotland. The objectives, obligations and responsibilities of SESplan and the Member Authorities, and the performance management and reporting requirements for the professional responsibilities are clearly set out in the Joint Committee (JC) Constitution, JC Minutes, and the Scheme of Delegation. SESplan has appropriate policies and protocols for maintaining its Constitution and professional role as the SDPA for the Edinburgh City Region. SESplan has appropriate arrangements for planning, providing and monitoring that it meets its professional obligations (e.g. public consultations, area boundaries, Main Issues Report, Strategic Environmental Assessment, Strategic Development Plan (SDP)). SESplan has appropriate mechanisms for reporting on its professional role to Member Authorities, sponsors and the public. SESplan has its own cost centre codes within Fife Council’s financial ledger, and all SESplan transactions are recorded and accounted for separately from those of Fife Council. Member Authorities are invoiced for their equal share of the costs. Salaries and wages, including legitimate expenses, are properly processed and paid.
Areas for Improvement SESplan has no system for following up points arising at Joint Committee meetings to ensure that they are reported back and the results included in the minutes. This is particularly important where ratification is required from Member Authorities. The objectives, obligations and responsibilities of SESplan and the Member Authorities, and the performance management and reporting requirements for administrative and financial support, are not clearly set out in the governance documents. SESplan’s governance arrangements have not been reviewed to assess how it does and wishes to perform its business, and how this is and should be set out in its official documents. Despite being recommended in the 2009 External Auditor’s Report (dated September 2009), review of the Financial Rules has not progressed. However, all invoices after that date that we tested were properly authorised. Despite being recommended in the 2009 External Auditor’s Report, SESplan has not formally agreed arrangements for obtaining and funding its administrative support (financial, HR, legal services, etc) e.g. through Service Level Agreements, including a scheme for monitoring and reporting their provision and costs. SESplan has not considered either arrangements for assessing, obtaining or monitoring Best Value or the assumption in the Statutory Guidance (Clause 25) that, apart from start-up costs, only a redistribution of existing Council resources is required. SESplan does not adequately monitor that Member Authorities fulfil their roles in providing administrative support and complying with SESplan’s Financial Regulations. Although appropriate mechanisms are available for reporting on its accountability for public money, these have not been used consistently.
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Audit Opinion
In our opinion, the system of controls under review for the set-up, governance and financial arrangements of SESplan merits a Grade 4. We consider that the materiality of the area that has been audited warrants a Grade 4, accordingly we assess the overall risk as High. See Appendix for an explanation of the terminology.
Distribution
Convener, SESplan Joint Committee SESplan Strategic Development Plan Manager SESplan Treasurer External Auditor
Stewart A. S. Good Geoff McDonald Audit Team Leader Audit & Risk Management Services Manager Fife Council, Finance & Procurement 08451 555555 Ext 446079 [email protected]
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1. Introduction
1.1 This audit reviews the set-up and governance arrangements, including financial rules and a high level overview of other systems, of SESplan, the Strategic Development Planning Authority (SDPA) for Edinburgh and South East Scotland. 1.2 This audit forms part of the Strategic Audit Plan of Fife Council Audit Services Division, acting as Internal Auditor to SESplan. Scott-Moncrieff, External Auditor, has advised that it wants to place reliance on this review as part of its 2009/10 audit. 1.3 SESplan is one of four SDPAs designated by Scottish Ministers on 25 June 2008, comprising a partnership of the following planning authorities - City of Edinburgh, East Lothian, Fife, Midlothian, Scottish Borders and West Lothian Councils. 1.4 Each group of authorities has a statutory duty under section 4 of the Planning etc. (Scotland) Act 2006 to work together and prepare and keep under review a Strategic Development Plan (SDP) for its area. The key role of SESplan is to do so for the Edinburgh City Region, which involves engaging and collaborating with key stakeholders and the wider community. The legislation is supported by Statutory Guidance (Scottish Government Planning Circular 2, 2008). SDPs replace the duty to prepare Structure Plans and, apart from start-up costs, are anticipated to require a redistribution of resources rather than significant additional spending. 1.5 SESplan is governed by a Joint Committee (JC) representing the constituent Member Authorities, who each appoint two Councillors to it, a Project Board comprising the relevant Director or Head of Service from each Member Authority and a dedicated Project Team, including a Strategic Development Plan (SDP) Manager, to provide the professional work. 1.6 SESplan has developed a website, providing minutes and papers for all its Joint Committee meetings, including details of the statutory background, Constitution, Financial Rules, etc. The website provides a public gateway to SESplan and its work. 1.7 The objectives of this audit are to confirm that: a) there is a clear Agreement in place between the Member Local Authorities creating SESplan, identifying its statutory duties and agreeing its objectives, and its performance management and reporting requirements, including delegations to SESplan; b) SESplan’s Constitution, protocols and management arrangements meet the objectives for its creation, including providing, monitoring and reporting its professional functions; c) SESplan has clear arrangements, including agreements with Member Authorities, for providing, monitoring and reporting financial and other administrative support and obtaining best value. 1.8 The scope of the audit covered: a) accessing the SESplan website and discussions with appropriate officers and/or members of SESplan and Fife Council; b) reviewing relevant governance, financial, administrative and operational documentation; c) identifying and evaluating the internal controls for ensuring that processes are in place for achieving key SESplan objectives; d) reporting on findings and making recommendations where appropriate.
1.9 We discussed the findings in this report and its factual accuracy with Ian Angus, Strategic Development Plan Manager and Alice Miles, Lead Officer. 1.10 We acknowledge the assistance and co-operation of all staff contacted during this audit.
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2. Arrangements between SESplan and Member Authorities Control Objective 2.1 There is a clear Agreement in place between the Member Local Authorities creating SESplan, identifying its statutory duties and agreeing its objectives, and its performance management and reporting requirements, including delegations to SESplan. Risk 2.2 Failure to fulfil the statutory requirements for producing and maintaining an SDP for the Edinburgh City Region. Testing 2.3 Reviewed the SESplan website and relevant governance, financial and administrative documentation, including Joint Committee minutes and reports. Interviewed appropriate officers of SESplan and Fife Council. Control OK Comment Rec There is a formal Agreement, X The Constitution of the Joint Committee 1 signed / ratified by all the Member is accepted by its Members as being the Authorities, creating an SDPA, as Agreement. However, there is no system designated by Scottish Ministers on for ensuring that points forward from JC 25 June 2008. meetings are followed up and reported and the Minutes do not formally confirm its ratification by the Member Authorities. SESplan carried out a formal - assessment of its duties, objectives and supporting arrangements, including delegations from Member Authorities, performance management and reporting requirements. The Agreement (or its supporting SESplan’s objectives, obligations and - documents) clearly sets out the responsibilities are set out, split between objectives, obligations and the Constitution, Joint Committee responsibilities of SESplan and the Minutes and the Scheme of Delegation. Member Authorities, including authority delegated to SESplan and However, although the professional leading roles and what they entail, planning responsibilities are clear, those and is consistent with the formal for administrative support are not (see assessment. Section 4). The Agreement (or its supporting X Performance management and reporting 2 documents) clearly sets out the requirements are clear for professional performance management and responsibilities. However, those for reporting requirements for SESplan financial reporting and administrative and the Member Authorities, is support are not (see Section 4) and there consistent with the formal are several inconsistencies between the assessment and is kept under Constitution and actual practice. SESplan review. was unable to demonstrate how it reviews its governance arrangements.
The roles of the JC Convener, Project Board and SDP Manager are not shown in full, but are, respectively, to chair meetings, manage the SDP Manager and manage the business. The Statutory Guidance states that the
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Control OK Comment Rec Chair ‘will have a key role in managing the business of the Joint Committee and ensuring decisions are made’ (Clause 12) and refers to the support of officials and an SDP Manager (Clauses 9, 16 and 18). SESplan has clear evidence that it JC papers (November 2008) confirm that 1 has received the agreed delegations the Scheme of Delegation was ratified by from all the Member Authorities. all Member Authorities, but SESplan was unable to demonstrate this.
3. SESplan’s Constitution and Management Arrangements Control Objective 3.1 SESplan’s Constitution, protocols and management arrangements meet the objectives for its creation, including providing, monitoring and reporting its professional functions. Risk 3.2 Failure to fulfil the statutory requirements for producing and maintaining an SDP for the Edinburgh City Region. Testing 3.3 Examined SESplan’s Constitution and Scheme of Delegation, including Joint Committee minutes and reports, for evidence of its management arrangements. 3.4 Reviewed SESplan’s Development Plan Scheme (DPS) and timetable, Main Issues Report, Strategic Environmental Assessment etc., including Joint Committee minutes and reports, for evidence of its planning and monitoring arrangements. 3.5 Reviewed the SESplan website for evidence of a reporting framework. Control OK Comment Rec SESplan’s Constitution provides - the appropriate Objects and Powers to undertake its designated role as the SDPA for the South East Region of Scotland (Edinburgh City Region). SESplan has appropriate policies - and protocols for maintaining its Constitution and professional role as the SDPA for the Edinburgh City Region. SESplan has appropriate - arrangements for planning, providing and monitoring that it meets its professional obligations (e.g. public consultations, area boundaries, Main Issues Report, Strategic Environmental Assessment, SDP). SESplan has appropriate - mechanisms for reporting on its professional role to Member Authorities, sponsors and the public.
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4. Administrative Support Arrangements Control Objective 4.1 SESplan has clear arrangements, including agreements with Member Authorities, for providing, monitoring and reporting financial and other administrative support and obtaining best value. Risk 4.2 Failure to fulfil the statutory requirements for producing and maintaining an SDP for the Edinburgh City Region. Testing 4.3 Reviewed SESplan’s website for evidence of formal arrangements for obtaining appropriate administrative support and best value, and for regular monitoring and financial reporting. 4.4 Reviewed SESplan’s Financial Rules for completeness, consistency and clarity, and assessed whether SESplan and Member Authorities are complying with them. Selected a sample of 22 transactions for financial year 2009/10 and checked these for appropriateness, and evidence of approval by the SDP Manager prior to processing. Control OK Comment Rec SESplan has appropriate formal X JC approved allocations of support roles 1, arrangements for obtaining and to Fife and East Lothian Councils and 2, 3 funding administrative support SEStran in August 2008, subject to (financial, HR, legal services, etc). ratification, but SESplan was unable to demonstrate if or when Member Authorities did so.
Despite being recommended in the 2009 External Audit Report, and shown as ‘agreed’ on the Audit Scotland website, Service Level Agreements with Member Authorities for providing, and charging for, administrative support were decided against by the Project Board on 23 October 2009 and have not progressed. SESplan has appropriate X SESplan was unable to demonstrate that it 4 arrangements for assessing, has considered either arrangements for obtaining and monitoring Best assessing, obtaining or monitoring Best Value. Value or the assumption in the Statutory Guidance (Clause 25) that, apart from start-up costs, only a redistribution of existing Council resources is required. SESplan has Financial Regulations X The Fife Council SESplan Project Board 1, clearly setting out the obligations member presented draft Financial Rules to 2, 3 and responsibilities of SESplan and, JC, which JC approved in January 2009, where appropriate, Member subject to ratification, but SESplan was Authorities. unable to demonstrate if or when Member Authorities did so. The Financial Rules show: Fife Council, as Lead Authority, to adopt the role of partnership banker and employing authority; the Treasurer to be an identified employee of Fife Council; certain financial responsibilities of the SDP Manager;
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Control OK Comment Rec transactions to be conducted in accordance with Fife Council’s regulations, schemes and procedures.
SESplan’s Constitution does not mention the role of Treasurer (e.g. whether it is to monitor and/or provide financial services). SESplan was unable to demonstrate an official, named appointment. However, JC accepts Treasurer’s reports in the name of Fife Council’s Executive Director, Finance & Resources and his Statement of Responsibilities in the annual accounts.
SESplan’s Constitution does not define the administrative role of the SDP Manager, whose job description requires a planning qualification and project management experience without any explicit mention of financial or administrative matters.
The Financial Rules do not define the budgeting, costing and accounting requirements for administrative support provided by Member Authorities, nor arrangements for the prevention and detection of fraud and irregularity, nor contemplate sales income, eg from the sale of plans.
Despite being recommended in the 2009 External Auditor’s Report, review of the Financial Rules has not progressed.
When we drew it to the attention of the VAT Accountant, the VAT position of SESplan was regularised with HMRC. Operating budgets for the next X The Financial Rules require the Operating 1, financial year are proposed by the Budget to be approved by JC and ratified 2, 3 SDP Manager, approved by the by Member Councils by the end of SESplan Joint Committee and December and that budgets must be ratified by the Member Authorities agreed by the Project Board. by the end of December. January JC meetings in 2009 and 2010 recommended the 2009/10 and 2010/11 budgets for ratification, but SESplan was unable to demonstrate if or when they were ratified by Member Authorities. The SDP Manager, in conjunction X Financial monitoring reports are not 1, with the Treasurer, submits detailed regularly submitted to Committee, as 2, 3 financial monitoring reports to the required by the Financial Rules.
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Control OK Comment Rec SESplan Joint Committee at the 6, The JC Constitution (Clause 9.1) requires 9 and 12 month stages of each that it shall meet not less than 4 times per financial year. The reports year – but it only met 3 times in 2009. compare actual expenditure to date Financial monitoring reports are and projected / final outturn distributed to the Project Board but only expenditure with the budget to JC members for JC meetings. They are position. presented by the SDP Manager, although prepared through a Fife Council Accountant. Neither the Treasurer nor the Accountant attends JC meetings.
Despite the JC January meeting noting the need for Period 6, 9 and 12 reports in future, no report was presented to the March meeting and the June meeting was cancelled, although papers were distributed. A meeting was held in September and another scheduled for December 2010. SESplan monitors that Member SESplan was unable to demonstrate how 1, Authorities fulfil their roles in it monitors the adequacy of its support 2, 3 providing administrative support services. The findings listed in this report and comply with SESplan’s indicate that monitoring is not adequate. Financial Regulations, as follows: there is a SESplan financial SESplan has its own cost centre codes ledger for recording and within Fife Council’s financial ledger, accounting for its transactions and all SESplan transactions are separately from those of Member recorded and accounted for separately Authorities; from those of Fife Council. Member Authorities are invoiced 2009/10 and 2010/11 invoices were for their equal share of the costs; submitted and paid in August 2009 and June /August 2010 respectively, instead of April, as agreed by JC members at the January meetings in 2009 and 2010. Member Authorities invoice X The Financial Rules do not clearly SESplan for services provided; define the treatment of costs for support services from Member Authorities, SESplan has not asked for invoices or reports on the services they supply, and none have been provided. Some fees from SEStran were not allocated correctly due to an oversight when a new Accountant started in February 2010. salaries and wages, including legitimate travel, hospitality and other expenses incurred in the course of duty, are properly processed and paid; SESplan ensures that all The Action Plan in the 2009 External expenditure incurred is valid and Audit Report (dated September 2009) approved before a transaction is states that procedures for this would be processed. confirmed in writing. SESplan was
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Control OK Comment Rec unable to provide these. However, all invoices after that date that we tested were properly authorised. SESplan has appropriate X Although appropriate mechanisms are 5 mechanisms for reporting on its available for reporting on its accountability for public money to accountability for public money, these Member Authorities, sponsors and have not been used consistently. the public. The 2009/10 unaudited accounts were published on SESplan’s website in July 2010, but the 2008/09 accounts were only published in August 2010.
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5. Action Plan
RECOMMENDATIONS ACTION PLAN Rec Recommendation Grading Agreed Proposed Action/Explanation * Responsible Officer Timescale No (Y/N) 1 SESplan should develop a system for following up Substantial Y A system has now been put in place, and SDP Manager December points arising at Joint Committee meetings, ensuring Member Authorities have been asked to 2010 that they are reported back, the results included in the provide confirmation of ratification where minutes and supporting evidence is held. This is there are gaps in SESplan records. In particularly important where ratification is required future, all items that require ratification from Member Authorities, and should include ensuring will be reported back to JC, minuted and that this has been obtained wherever it has already been supporting evidence retained as a record. required, including where shown in this report.
2 SESplan should review its governance arrangements, Substantial Y A review of the Constitution and other SDP Manager March 2011 assessing how it does and wishes to perform its governance arrangements was initiated for business, and how this is and should be set out in its discussion at the 22 October Project Board. official documents, including its Constitution, Scheme Once the review is complete, revised of Delegation and Financial Rules, and produce a arrangements will be ratified by the revised and consistent scheme of administration, Member Authorities. including taking account of the inconsistencies identified in this report. A schedule of papers for all 2010 Committees was put to JC on 27 September 2010, including reporting on items that require ratification.
Four meetings are being scheduled for 2011, centred on when financial reports are required to be put to JC. Dates for 2011 JC are being convened by Midlothian and a schedule of papers will be put to the next JC meeting on 6 December 2010.
* Give full details of the action to be taken to implement the recommendation or a full explanation of the reasons for non-implementation. 1434 Issued Draft 061010 Page 11 96 SESplan Date printed 15/11/2010 Draft for Discussion Only
RECOMMENDATIONS ACTION PLAN Rec Recommendation Grading Agreed Proposed Action/Explanation * Responsible Officer Timescale No (Y/N) 3 SESplan should agree formal arrangements for Substantial Y There are ongoing discussions about shared SDP Manager March 2011 obtaining and funding its administrative support services, particularly against a background (financial, HR, legal services, etc) e.g. through Service of budget cuts, but this has not yet been Level Agreements, including a scheme for monitoring defined. It has been agreed that member and reporting their provision and costs. authorities do not recharge for (ad hoc?) support services.
However, a review is ongoing and a three year ‘business plan’, including a discussion of support services, but not Service Level Agreements, is being put to the Project Board on 22 October 2010. 4 SESplan should develop appropriate arrangements for Substantial Y In addition to the three year ‘business plan’ SDP Manager March 2011 assessing, obtaining and monitoring Best Value, and (see above), the Operating Budget for assessing whether its work requires resources additional 2011/12 will be reported to the Project to those previously spent by Member Authorities. Board on 5 November and JC on 6 December 2010.
Consideration of Best Value and use of resources will be more explicitly discussed and noted in relevant Minutes, which will be available as part of the evidence supporting the annual Statement on Internal Control. 5 SESplan should develop a publications policy and Substantial Y A review is ongoing, centred on content SDP Manager March 2011 procedures to ensure that it meets its duties for and timetabling for the SESplan website. accountability for public money.
* Give full details of the action to be taken to implement the recommendation or a full explanation of the reasons for non-implementation. 1434 Issued Draft 061010 Page 12 97
SESPLAN JOINT COMMITTEE 6 DECEMBER 2010
For Decision For Information
ITEM 10 – SESPLAN JOINT COMMITTEE ROTATION, MEETINGS AND INDICATIVE PROGRAMME Report by SDP Project Manager
1. INTRODUCTION
1.1 This Report sets out the rotation for the chair and vice chair of the SESplan Joint Committee, together with confirmation of the dates for forthcoming meetings and an indicative programme of papers to be put to the Committee for consideration.
1.2 This Report provides an update to the paper considered by the Joint Committee on the 27 September 2010 following confirmation of dates for meetings in 2011.
2. SESPLAN JOINT COMMITTEE
2.1 The rotation of the chair and vice chair of the SESplan Joint Committee as set out within the SESplan Constitution is to be on an annual basis starting on the 1 January each year. The current chair is Fife Council with Midlothian Council acting as vice chair.
2.2 The dates for future rotation are set out in Appendix 1. From the 1 January 2011 Midlothian Council will take the chair of the Joint Committee with East Lothian Council acting as vice chair.
2.3 The dates for forthcoming meetings are set out in Appendix 1. If the amended timetable for the preparation of the proposed plan recommended under Item 6 is approved, the member briefing will be held in April rather than January 2011. This meeting will consist of a seminar on the outline of the proposed plan.
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2.4 As set out within the SESplan Constitution, the SESplan Joint Committee is to meet four times a year. It is proposed that these meetings are held in March, June, September and December every year to facilitate quarterly reporting on progress including quarterly financial reporting.
3. RECOMMENDATION
3.1 It is recommended that the Joint Committee,
a) Notes the rotation of the chair and vice chair of the Joint Committee, the dates for forthcoming meetings and the indicative papers to be put forward for consideration.
Ian Angus SDP Project Manager Email – [email protected] Tel – 0131 5245158
Report Drafted By: Alice Miles Lead Officer Email – [email protected] Tel – 0131 5245167
APPENDICES Appendix 1: SESplan Joint Committee Rotation, Meetings and Papers 2011
Policy Implications None Financial Implications None Race Equalities Implications None Gender Equalities Implications None Disability Equalities Implications None
99 Appendix 1 - SESplan Joint Committee Rotation, Meetings and Papers 2011
ROTATION
Year Chair Vice Chair
1 January 2008 – 31 December 2008 Edinburgh Scottish Borders
1 January 2009 – 31 December 2009 Scottish Borders Fife
1 January 2010 – 31 December 2010 Fife Midlothian
1 January 2011 – 31 December 2011 Midlothian East Lothian
1 January 2012 – 31 December 2012 East Lothian West Lothian
1 January 2013 – 31 December 2013 West Lothian Edinburgh
100 MEETING DATES Date for Draft Dates for Final Pre-Agenda Date for Issue of Date of Meeting Agenda / Reports Reports to be Meeting Agenda to be Emailed Emailed
6 December 2010 19 November 2010 24 November 2010 26 November 2010 29 November 2010
w/b 3 February 2011 No formal committee to be held. Member Briefing on the Proposed Plan.
7 March 2011 14 February 2011 21 February 2011 23 February 2011 28 February 2011
4 April 2011 No formal committee to be held. Member Briefing on the Proposed Plan.
13 June 2011 23 May 2011 30 May 2011 1 June 2011 6 June 2011
12 September 2011 22 August 2011 29 August 2011 31 August 2011 5 September 2011
5 December 2011 14 November 2011 21 November 2011 23 November 2011 28 November 2011
101 PAPERS
Date of Meeting Paper Item For
Summary of Submissions on Main Issues Report Information / Discussion Strategic Development Plan Project Progress Report Information / Decision 6 December 2010 Operating Budget 2010 / 2011 – 6 Month Financial Report Decision Operating Budget 2011 / 2012 Decision Annual Audit Information Strategic Development Plan Project Progress Report Information / Decision Feedback on Ratification of Items at 6 Dec Cee Information 7 March 2011 Development Plan Scheme 3 Decision Operating Budget 2010 / 2011 – 9 Month Financial Report Decision Governance Review Information / Decision Strategic Development Plan Project Progress Report Information / Decision 13 June 2011 Proposed Plan Decision Operating Budget 2010 / 2011 – 12 Month Financial Report Decision Strategic Development Plan Project Progress Update Information / Decision 12 September 2011 Operating Budget 2011 / 2012 – 3 Month Financial Report Decision Strategic Development Plan Project Progress Report Information / Decision Proposed Plan – Submission to Ministers Decision Development Plan Scheme 4 Decision 5 December 2011 Operating Budget 2011 / 2012 – 6 Month Financial Report Decision Annual Audit 2010 / 2011 Information Operating Budget 2012 / 2013 Decision
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