Planning Statement

Proposed Residential Development, with Associated Infrastructure and Access Blindwells Plot 11,

April 2021

Contents

1. Introduction 1

2. Planning Context 2

3. Proposed Development 7

4. Development Plan Assessment 10

5. Summary and Conclusions 25

Appendix 1: Site Location Plan 26

Kate Donald [email protected] Client Hargreaves Services (Blindwells) Limited Our reference HARE3046

April 2021

1. Introduction

1.1 This Planning Statement has been prepared on behalf of Hargreaves Services (Blindwells) Limited (‘the applicant’) in support of an application to East Lothian Council (‘the Council’) for planning permission for residential development, with associated infrastructure and access, on land referred to as ‘Plot 11’ at Blindwells, East Lothian. A site location plan identifying the land is provided at Appendix 1.

1.2 The purpose of this statement is to provide background details on the proposed development and set out key factors which should be taken into account in the determination of the application. The statement reviews the planning policy context and assesses the proposed development against the development plan.

1.3 This Planning Statement should be read in conjunction with the full suite of submitted drawings and documents which include:

• Architectural Drawings, prepared by EMA Architects;

• Landscape Drawings, prepared by OOBE;

• Drainage and Road Infrastructure Drawings, prepared by Waterman;

• Design and Access Statement, prepared by EMA Architects;

• Landscape Design and Access Statement and Outline Specification, prepared by Oobe;

• Landscape and Habitat Management Plan, prepared by Oobe;

• Pre-Application Consultation Report, prepared by Turley;

• Geo-Environmental Assessment, prepared by Waterman;

• Drainage Strategy and Flood Risk Assessment, prepared by Waterman; and

• Transport Statement, prepared by Tetra Tech.

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2. Planning Context

Planning History

2.1 Plot 11 is situated in the north west of the wider Blindwells site which benefits from planning permission in principle (PPiP) (ref. 20/01030/PM), granted on 18 February 2021 as a result of a Section 42 application to amend conditions on the original permission, for the following development:

“Amend condition 30 of planning permission in principle 14/00768/PPM”

2.2 In May 2018, application 14/00768/PPM was approved on the site at Blindwells for:

“Planning permission in principle for remediation of site and creation of new settlement comprising residential, employment, education and commercial uses with park and ride and rail halt facilities and associated works”

2.3 The application for PPiP was accompanied by a number of supporting documents including, amongst others, an Environmental Statement, Transport Assessment and Retail Assessment, which provided an assessment of the development on the basis of the following principal components:

• Creation of up to 1,600 residential units and ancillary development;

• Creation of access and egress points and road network through the site;

• Creation of a new school campus;

• Creation of employment land;

• Creation of commercial uses;

• Creation of a park and ride facility; and

• Creation of a green network.

2.4 The PPiP is subject to a number of conditions several of which are pertinent to the current application for planning permission for residential development on Plot 11. Condition 3 of 20/01030/PM states “No more than 1600 residential units shall be erected on the site.” The stated reason for this condition is as follows:

“To ensure that there is sufficient education capacity, to restrict the scale of development to that applied for and identified in the applicant's Transport Assessment and to minimise interference with the safety and free flow of traffic on the trunk road.”

2.5 As detailed further in later sections of this Planning Statement, the current planning application does not propose additional homes above the 1,600 units which are approved through the extant PPiP. The use of planning conditions can ensure that the number of homes on the wider site does not exceed the approved 1,600 units, as discussed with the Council.

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2.6 The delivery of no less than 10 hectares of employment land across the masterplan site, as specified by Condition 1k of PPiP 20/01030/PM, is unaffected by the current proposals.

2.7 Condition 1 of PPiP 20/01030/PM requires the submission for approval of matters specified in conditions the “details of the siting, design and external appearance of all the dwellings and other buildings, the means of access to them, the means of any enclosure of the boundaries of the site and of gardens and other subdivisions of the site and the landscaping of the site”.

2.8 These matters should “generally accord” with the indicative masterplan (drawing no. 13055(PL)100 Rev. D), approved first under PPiP 14/00768/PPM and more recently via PPiP 20/01030/PM. Condition 1 specifies a number of requirements that subsequent approval of matters specified in conditions (AMSC) applications are to address (criteria a-p).

Current Application

2.9 The approved indicative masterplan (drawing no. 13055(PL)100 Rev. D) shows retail warehousing and part of the consented large scale foodstore within the current application site boundary for Plot 11. Discussion with Council planning officers established that, because the proposed residential use of Plot 11 did not “generally accord” with the uses shown on the approved indicative masterplan, submission of an AMSC application would not be appropriate and that a separate, standalone application for residential development on Plot 11 would be required.

2.10 The proposed development meets the threshold of a major development as defined by the Town and Country Planning (Hierarchy of Developments) (Scotland) Regulations 2009. A Proposal of Application Notice was submitted in November 2020 (ref. 20/00009/PAN) and pre-application consultation was undertaken by the applicant prior to submission of the planning application. Further details can be found in the Pre- Application Consultation Report.

2.11 The current application is for detailed planning permission therefore it seeks to resolve the detail of the proposed development in the same way that an AMSC application would seek to do. As such, there are several criteria stated in Condition 1 of 20/01030/PM that are relevant to this proposal:

(a) “The provision within the application site of recycling facilities.

(b) Other than in exceptional circumstances where the layout or particular building type does not permit, houses and flats shall be orientated to face the street.

(c) Notwithstanding that shown in the Indicative Master Plan docketed to this planning permission in principle there shall be no integral garages, unless it can be justified as an exceptional design feature, or where the house and garage would not be on a primary street frontage;

(d) The detailed design of the layout shall accord with the principles set out in the Council's Design Standards for New Housing Areas and with Designing Streets;

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(e) The external finishes of the residential units shall be in accordance with a coordinated scheme of materials and colours that shall respect the layout of the development and shall promote render as the predominant finish to the walls of the residential units.

(f) Notwithstanding the details shown in the Indicative Site Master Plan referred to above, there shall be a separation distance of at least 9 metres between facing windows of a proposed new building and the garden boundaries of existing or proposed neighbouring residential properties; and a separation distance of at least 18 metres between directly facing windows of a proposed new building and the windows of existing or proposed neighbouring residential properties.

(g) Parking for the residential, local centre and primary school components of the development hereby approved shall be provided at a rate as set out in the East Lothian Council's "Standards for Development Roads- Part 5 Parking Standards" For the local centre and school this shall include for cycle parking. Private parking spaces in the local centre and other private parking areas shall be a minimum of 2.5 metres by 5 metres and spaces on the public road shall be a minimum of 2.5 metres by 6 metres. Access to private parking areas other than driveways shall be via a reinforced footway crossing and have a minimum width of 5.5 metres over the first ten metres. Private driveways shall be a minimum of 6 metres by 2.5 metres, double driveways shall be 5 metres by 6 metres or 3 metres by 11 metres.

(h) All access roads within the new settlement shall conform to East Lothian Council's "Standards for Development Roads" in relation to roads layout and construction, footways and footpaths, parking layout and number, street lighting and traffic calming measures.

(i) Cycle parking shall be included at a rate of 1 space per flat. The parking shall be in the form of 1 locker per flat or communal provisions in the form of a lockable room or shed.

(l) The provision within the application site of nature based elements such as woodlands, wetlands and SUDS, public open space and boulevard planting.

(m) Vehicle access's to private parking areas (i.e. other than driveways) shall be via a reinforced footway crossing and have a minimum width of 5.5 metres over the first 10 metres to enable adequate two way movement of vehicles;”

2.12 As detailed in this Planning Statement, the Design and Access Statement and the application drawings, the proposed residential development has been designed to comply with these criteria.

Forthcoming Masterplan Amendments

2.13 The proposal to develop land within Plot 11 for residential use, rather than retail use as shown on the approved indicative masterplan, is one of several amendments that the applicant must make to the masterplan in order to reflect changing circumstances since it was prepared to accompany the submission of the application for PPiP in

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September 2014, and subsequently approved in May 2018. Further amendments to the masterplan will be brought forward through separate planning applications.

2.14 The change in circumstances which necessitates the amendments to the indicative masterplan relate to the agreed mechanism for delivery of Blindwells Primary School, improved knowledge of conditions on the site itself and also to wider changes in terms of retailing and employment trends, in East Lothian and nationally.

Redevelopment of Brownfield Site 2.15 The redevelopment of brownfield sites is fundamentally informed by the existing ground conditions and the requirement for any remediation works. Owing to the site’s previous use as an open cast mine, the remediation strategy for the Blindwells site is of primary importance and influences the timescales for delivery of land parcels for development. The remediation strategy has developed as additional data have been gathered about the ground conditions through further detailed investigations.

2.16 Due to the size of the Blindwells site, in addition to the costs and practicalities associated with its remediation, the site is being remediated on a phased basis in a west to east direction. The position of Plot 11 in the north west of the wider site means that it is one of the earlier plots to undergo remediation and, as a result, is one of the earlier plots available for development.

2.17 In addition, the approved indicative masterplan identified future residential development on the area of land to the south of Plot 10, which is located to the south east corner of the wider masterplan site; however, it cannot be confirmed at this stage that this part of the site is suitable for residential development, due to the presence of three mine shafts in this location. Further ground investigation works would be required to ascertain the suitability of this part of the site for residential development. Therefore, the homes which were to be delivered on this part of the site will now be relocated to Plot 11.

Changing Retail Market 2.18 The approved indicative masterplan shows retail uses provided within a large scale foodstore and retail warehousing. This format was reflective of conditions at the time but is no longer considered to be the most appropriate approach to creating the local centre which is required for the new community. This conclusion is supported by 18 months of market testing undertaken by Culverwell, an established retail property agency, instructed by the applicant. Following detailed discussion with a range of potential retail occupiers, including supermarket operators as well as non-food retail warehouse operators, it was concluded that the large scale foodstore and retail warehousing format approved under the existing planning permission in principle is not attractive to the occupier market.

2.19 The primary reason for this conclusion is that the major supermarket brands, who are represented in East Lothian already, do not have a requirement for further floorspace in this area in the short to medium term. Related to this, the non-food operators prefer locations where a supermarket is present, in order to benefit from the footfall that supermarkets generate.

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2.20 Culverwell conclude, based on their assessment of the type of retail demand which exists in the area, that the site would be better able to attract a range of food and non- food retailers, as well as supporting, ancillary uses such as hairdressers, gyms and childcare operators, where the local centre is designed to create smaller commercial properties anchored by mid-size convenience retail.

2.21 This evidence has necessitated a strategic review of the provision of retail space by the applicant, with the conclusion that the most appropriate way to ensure delivery of retailing which meets the needs of the new community and can attract the required range of types and sizes of retail and commercial occupiers will be to deliver this as part of a reconfigured local centre rather than as a large scale foodstore and retail warehousing, which was originally envisaged for delivery on the application site.

2.22 The applicant intends to shift the focus for retail uses towards a reconfigured local centre, where they can be accommodated in smaller scale units alongside other commercial uses, in addition to employment and residential uses, to create a focus for the new community that is both vibrant and viable. It is considered that this traditional ‘high street’ format is more robust in terms of both placemaking and attractiveness to retail occupiers with greater capacity to adapt to any future changes in retail demand. The importance of the adaptability of the local centre and its resilience against changes in demand for retail space has been amplified by the Covid-19 pandemic which has had a significant impact on the retail sector. The applicant is in discussion with the Council’s planning officers to agree the most suitable planning approach to addressing these amendments to the configuration of the local centre, which will be included in a forthcoming planning application.

2.23 While the reconfigured local centre is not located within the application boundary for Plot 11, and therefore does not form part of the application proposals, the change in focus away from a large scale foodstore and retail warehousing does affect the application site, as these uses are no longer proposed for Plot 11.

2.24 The change from retail uses on Plot 11 to residential development does not result in the loss of retail uses on the masterplan site; rather the retail uses will be provided in the reconfigured local centre on the adjacent site and the quantum of development proposed on the masterplan site is not reduced. The proposals represent a change only in the location and format of approved uses on the site.

Summary 2.25 As a result of the ongoing process of phased remediation, Plot 11 is currently undergoing remediation and, once remediation of this plot is completed, this will make it available for development. The development of this land for retail use as currently shown on the approved indicative masterplan is not reflective of current circumstances due to the passage of time since the masterplan was prepared and the changes in the retail market that have occurred in the intervening period. The applicant is seeking to instead develop the land for residential use, as described by the remainder of this Planning Statement.

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3. Proposed Development

3.1 The applicant proposes residential development, with associated infrastructure and access, on land referred to as ‘Plot 11’ at Blindwells, East Lothian.

Housing Number and Mix

3.2 A total of 77 of residential units are proposed across a mix of terraced, semi-detached and detached properties. The proposed development comprises of a mix of 2, 3, and 4 bedroom residential dwellings, predominantly 2 storeys in height, with 2 and a half storey elements, in a range of terraced, semi-detached and detached houses. The proposed housing mix is set out in the table below:

Table 1: Accommodation Schedule

House Type No. of Bedrooms No. of Units Type A 2 24 Type B 2 21 Type C 3 2 Type D 4 3 Type E 4 2 Type F 4 4 Type G 4 1 Type H 3 8 Type J 4 12 Total 77

3.3 30% of the total number of homes will be provided as affordable housing.

Materials

3.4 The proposed materials palette comprises dry dash render, brick detailing, reconstituted stone sills and synthetic slate roof tiles. These materials will be of high quality and appropriate to the existing and emerging built form in the local area.

Boundary Treatments

3.5 A mix of hedge row, brick walls and timber is proposed which will be utilised to enclose gardens and screen cars and drives. With the inclusion of street trees, the provision of boundary treatments adjacent to shared surfaces will also help to reduce forward visibility for motorists and therefore reduce vehicles speeds.

3.6 The homezones will be defined by varied building lines and carriageway widths. Shared surfaces will be incorporated rather than separate footways and nodes will break up

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the road pattern at key locations along the route. Hedges will define the private / public realm and street trees will also provide visual barriers for motorists.

Open Space, Landscaping and Trees

3.7 Dwellings will contain both front and rear gardens to provide functional and private space for the residents. Access to rear gardens will either be via pathways along the side of dwellings or from a rear pathway at the end of their properties. These pathways will also provide a functional route for tasks such as waste collection. A 1.8m high fence will ensure privacy is provided between properties and at the rear of the gardens.

3.8 Throughout the development, ornamental planting will be proposed to introduce colour, texture and interest, particularly in the public streetscape. Hedging will be used to add privacy to the dwellings as well as provide a frame and structure to the plot boundaries.

3.9 Tree planting is proposed to strengthen the identity and character of the spaces within the site and assimilate it within the Blindwells masterplan and complement the placemaking strategy. Species have been selected for their ecological value, as well as visual amenity, seasonal interest and appropriateness to context.

3.10 Woodland and open space is proposed which is orientated on a north / south axis throughout the new development. This allows permeability through the new neighbourhood and provides links between the masterplan features such as Princes Loch to the north and Princes Park to the south. Princes Park acts as a ribbon of landscape through the centre of the Blindwells masterplan site and this will remain a key landscape feature of the site.

3.11 The woodland will also help to define areas of different character within the development creating a sense of place and identity.

Road and Footpath Network

3.12 The site is accessed from two points, at the north and eastern boundaries of the site, which provides vehicular access as well as shared footway/cycleway provision on either side of the streets. These vehicular accesses provide connections to the wider internal street layout that will be delivered throughout the masterplan area which also act as the principal routes for vehicular traffic to the A198. The shared cycle / footpaths will be provided to connect with the existing Core Paths (132 and 270) that run along the eastern boundary of the masterplan site.

3.13 The proposals include a high level of pedestrian permeability, ensuring safe, convenient, and direct pedestrian links are provided throughout the residential area and the Blindwells masterplan. Two active travel routes are provided along the western boundary of the site which provide links to the housing plot to the west and also connections to the north and south to tie into active travel corridors across the masterplan area to provide access to local amenities.

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3.14 The active travel network within the masterplan will be designed to provide ‘Safer Routes to School’ and in line with the guidance contained within Designing Streets.

3.15 The internal layout takes into account Designing Streets guidance by avoiding long, unbroken straight sections of carriageway and providing passive surveillance throughout. Streets will largely comprise of shared surfaces or narrow streets which will assist with reducing vehicle speeds.

3.16 Swept path analysis for refuse vehicles has been undertaken, the details of which are included within the Transport Statement.

Parking

3.17 Cycle parking arrangements will be facilitated within residential curtilages with the addition of on street provision for visitor cycle parking.

3.18 A mixture of in curtilage and on street car parking for residents and visitors is provided throughout the development to Council standards, with appropriate provision made for passive and active electric vehicle charging points. A total of 104 vehicle parking spaces are provided across the site.

Sustainable Urban Drainage System

3.19 Sustainable Urban Drainage System (SuDS) proposals will be developed in line with guidance set out in CIRIA C753 –The SuDS Manual and in compliance with the East Lothian Council, SEPA, and Scottish Water guidance.

3.20 SuDS will be integrated within the landscape strategy; source control treatment will be provided within the development via permeable paving for the parking bays with internal roads drainage to bays along with soft SuDs features such as bio retention, tree pits and filter trenches in areas outwith porous paving, with further pollution mitigation indices being provided within the downstream basins via a filtered low flow channel.

3.21 Surface water runoff from Plot 11 will be attenuated within a Detention Basin which lies to the north of Plot 11 as has been previously agreed within the wider Phase 1 Infrastructure Application (ref. 19/00620/AMM). This will discharge to the realigned Mill Lade. The existing basin will be extended in order to accommodate the flows from Plot 11. The additional basin flows and capacities will be reviewed and signed off under the Scottish Water technical approval process to allow additional flows from Plot 11 to be captured in this SuDS feature.

3.22 Attenuation will ensure that the development should be protected up to the 1 in 200- year (0.5% AEP) rainfall event including a 35% allowance for climate change along with a 10% allowance for urban creep (later unforeseen additions of impermeable areas) in all residential areas. All surface water will be contained below ground in line with current guidance.

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4. Development Plan Assessment

4.1 This section of the Planning Statement identifies the overarching planning policy and guidance applicable to the site which will be used by the Council to assess the proposed development.

4.2 Section 25 of the Town and Country Planning (Scotland) Act 1997 (as amended) requires decisions to be determined in accordance with the development plan, unless material considerations indicate otherwise.

Development Plan

4.3 The development plan for the site comprises:

• South East Scotland Strategic Development Plan (SESPlan) (June 2013); and

• East Lothian Development Plan (LDP) (September 2018).

4.4 Scottish Government states that Supplementary Guidance (SG) can be considered part of the Development Plan. It can provide further information or detail on the policies or proposals that are in the development plan (Circular 6/2013). The SG relevant to the proposals are as follows:

• SESplan Housing Land Supplementary Guidance (2014); and

• Developer Contributions Framework (DCF) Supplementary Guidance.

Material Considerations

4.5 The following are material considerations relevant to the proposal:

• Development Framework for Blindwells New Settlement (June 2010);

• Design Standards for New Housing Areas Supplementary Planning Guidance (May 2020);

• Indicative Regional Spatial Strategy for Edinburgh and South East Scotland City Region;

• National Planning Framework 3; and

• Scottish Planning Policy - finalised amendments: December 2020.

4.6 We note that two petitions for Judicial Review challenging the legal validity and competency of the amendments to SPP and PAN 1/2020 have recently been lodged with the Court of Session and a judgement can be expected in the coming months. While we acknowledge that SPP 2020 remains a material consideration, the amendments must be seen in the context of these being nascent and emerging policy that are subject to legal challenge.

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Development Plan

South East Scotland Strategic Development Plan (SDP) (SESplan) 2013 4.7 SESplan sets out the vision that “by 2032, the Edinburgh City Region is a healthier, more prosperous and sustainable place which continues to be internationally recognised as an outstanding area in which to live, work and do business”. To achieve this vision, SESplan aims to support growth and meet housing need and demand in sustainable locations, integrate land use and sustainable modes of transport, and reduce the need to travel and cut carbon emissions.

4.8 As part of its Spatial Strategy, SESplan identifies thirteen Strategic Development Areas (SDAs), within five sub-regional centres, which are to be the focus for the location of new development. East Lothian is designated an SDA and, as part of the wider East Coast area, is noted to be the focus for key transport routes, primarily the A1 and East Coast Main Line (ECML).

4.9 SESplan acknowledges that the East Coast experiences significant pressure for housing growth and lacks a diverse employment base. This culminates in high levels of commuting as residents seek access to a wider range of employment opportunities, in addition to goods and services.

4.10 In terms of housing, SESplan states in Policy 5 that land for a total of 107,545 new homes is required in the period up to 2024 in the entire SESplan area. Housing Land Supplementary Guidance (November 2014) states that 6,250 new homes must be built within the East Lothian area between years 2009-2019 and 3,800 between 2019-2024, as set out in Table 3.1. Table 3.2 of the Supplementary Guidance contains the SESplan Authority’s assessment of the number of additional housing allocations that would be required in Local Development Plans to meet the assessed requirement. It includes an allocation within the East Lothian SDA of land capable of delivering 3,560 homes.

4.11 Policy 6 requires planning authorities to maintain a five year supply of effective housing land at all times, with the scale of the supply to be derived from the housing requirements for each Local Development Plan identified in the housing land supplementary guidance.

4.12 At paragraph 53 of SESplan, continued commitment is demonstrated to Blindwells as a location for a new settlement through the SESplan period (to 2032) and beyond. SESplan states “the vision is for a settlement of 4,600 dwellings to be comprehensively delivered and designed as a new mixed community”. No more than 1,600 dwellings are anticipated to be delivered before 2032, however additional early completions may be possible subject to satisfactory resolution of infrastructure, master planning, phasing, timing and funding solutions.

4.13 SESplan notes that a review of the development principles of the local plan allocation may be required in order to identify comprehensive solutions to deliver the whole settlement. Housing completions from Blindwells will only be expected to contribute to the SDP Spatial Strategy for the period 2019-2024 at the earliest.

4.14 Policy 8 relating to transportation specifies that Local Development Plans will, inter alia:

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• “Ensure that development likely to generate significant travel demand is directed to locations that support travel by public transport, foot and cycle;

• Ensure that new development minimises the generation of additional car traffic, through the application of mode share targets and car parking standards that relate to public transport accessibility;

• Relate density and type of development to public transport accessibility; and

• Ensure that the design and layout of new development demonstrably promoted non-car modes of travel”.

4.15 Support for a new settlement at Blindwells is continued into SESplan from the Edinburgh and Lothian Structure Plan 2015 (revoked in June 2013 following approval of SESplan). The provision of 1,600 homes, of which 77 are subject of the current application, will contribute substantially to the housing land requirement in the East Lothian SDA.

East Lothian Development Plan (September 2018) 4.16 The East Lothian Development Plan (LDP) was adopted in September 2018 and sets out the Council’s planning strategy and policies to help stimulate, guide and manage future development within East Lothian.

4.17 The following paragraphs identify the key provisions of LDP policy relevant to the proposed development and which should form the basis of the Council’s assessment of the application proposals.

PROP BW1: Blindwells New Settlement 4.18 Land at Blindwells is allocated for a mixed development including circa 1,600 homes, no less than 10 hectares of serviced employment land, a local centre, education and community facilities, infrastructure and associated works.

4.19 The allocation requires a comprehensive masterplan for the entire allocated site which integrates development with the surroundings and conforms to the adopted Development Framework for the site. A masterplan was submitted and approved in respect of the original PPiP (ref. 14/00768/PPM). The LDP notes that proposals which undermine the potential ability to expand Blindwells will not be supported. Any development is subject to the mitigation of any development related impacts, including on a proportionate basis for any cumulative impacts with other proposals including on the transport network, on education and community facilities, and on air quality as appropriate.

4.20 The development of 77 homes on Plot 11 will contribute to the delivery of 1,600 homes which is a key component of the new settlement. As stated previously, the current planning application does not propose additional homes above the 1,600 which are approved through the extant PPiP. The use of planning conditions can ensure that the number of homes on the wider site does not exceed the approved 1,600, as discussed with the Council.

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4.21 The current proposal does not reflect the retail uses currently shown on the approved indicative masterplan for reasons outlined in Chapter 2 of this Planning Statement, instead it seeks the repositioning of housing units from elsewhere in the wider Blindwells site to more appropriately reflect current circumstances in respect of the phased remediation strategy and changes in the retail market.

4.22 The delivery of no less than 10 hectares of employment land across the masterplan site is unaffected by the current proposals.

Policy HOU1: Established Housing Land 4.23 The Council continues to support the principle of appropriate residential development on sites of the established housing land supply as set out in Housing Land Audit 2017.

4.24 In accordance with Policy HOU1, the proposal constitutes appropriate residential development on an allocated housing proposal site (BW1) that forms part of the established housing land supply. It will contribute to the site’s capacity for 1,600 homes as identified in the LDP and stipulated by Condition 3 of the PPiP.

Policy HOU3: Affordable Housing Quota 4.25 The LDP continues the 30% affordable housing quota for Blindwells (site Ref: BW1) as set by the previous local plan.

4.26 To ensure compliance with Policy HOU3, 30% of the 77 homes proposed will be provided as affordable housing.

Policy HOU4: Affordable Housing Tenure Mix 4.27 The Council will seek to ensure that, as part of the provision of affordable housing on any site, provision is made where appropriate for specialist housing, in line with the Council’s Local Housing Strategy and the Supplementary Planning Guidance: Affordable Housing Quota and Tenure Mix.

4.28 The applicant is in discussion with Council's Service Manager for Housing Strategy and Development to agree the most suitable approach to the delivery of affordable housing on the site.

4.29 A Section 75 Agreement is in place for the masterplan PPiP which contains provisions relating to the phased delivery of affordable housing on the wider site; it is the applicant’s intention that affordable housing to be delivered on Plot 11 will satisfy the requirement generated by the wider masterplan development. The applicant will engage with the Council to ensure that the appropriate legal framework is in place to effect this.

PROP ED3: Blindwells Cluster Education Proposals 4.30 PROP ED3 confirms developer contributions will be sought from the developers of the allocated site, including for the provision of campus land, to deliver education provision which will be the subject of legal agreements.

4.31 A Section 75 Agreement is in place for the masterplan PPiP which contains provisions to ensure the delivery of the Blindwells Primary School and secure education contributions. As such, this proposal that will contribute 77 of the 1,600 homes

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approved under the PPiP is not expected to generate a requirement for any additional financial contributions.

PROP CF1: Provision of New Sports Pitches and Changing Accommodation 4.32 PROP CF1 specifies that development proposals for 5 or more homes must make provision for the delivery of new sports pitches and changing accommodation in the relevant contribution zone as set out at Appendix 1 of the LDP and in the Supplementary Guidance: Developer Contributions Framework.

4.33 The new facilities to be provided at Blindwells include:

• Proposal BW1: Blindwells New Settlement – three full size grass pitches and six team changing facility, four tennis courts and a cricket wicket.

4.34 The indicative masterplan approved under application 14/00768/PPM and subsequently 20/01030/PM, shows the position of the new sports pitches that will be provided within the new settlement.

PROP HSC2: Health Care Facilities Proposals 4.35 PROP HSC2 advises that NHS Lothian has identified proposals within East Lothian as part of its modernisation agenda and the delivery of these is supported by the Council. At Blindwells this includes a further new GP practice and a new facility will be required to serve the current allocation and developer contributions (land and capital) for this will be required from that development.

4.36 A Section 75 Agreement is in place for the masterplan PPiP which contains provisions to ensure delivery of healthcare provision. As such, this proposal that will contribute 77 of the 1,600 homes approved under the PPiP is not expected to generate a requirement for any additional financial contributions.

Policy OS3: Minimum Open Space Standard for New General Needs Housing Development 4.37 For developments of 20 and more dwellings the minimum requirement for on-site provision of open space is 60m2 per dwelling. This should consist of provision of formal and informal open space as well as space for equipped play areas in accordance with Policy OS4. Natural green space provision should also be accommodated to provide suitable recreational opportunities close to home, and where possible will link these areas to wider networks including core paths and recreational routes.

4.38 The policy also requires that open space be provided in accordance with the approved masterplan where a development forms part of an area for which there is a masterplan approved by the Council; as is the case with Blindwells.

4.39 Areas of open space are within close proximity of the application site, including the Town Park, adjacent to Princes Loch, and Princes Park, both of which provide open spaces within a landscaped setting. The houses at Plot 11 are separated from neighbouring housing to the west by a landscaped corridor providing further amenity space and routes through to these open spaces. Provision of these open spaces accords with the approved indicative masterplan, as required by Policy OS3.

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Policy OS4: Play Space Provision in new General Needs Housing Development 4.40 Development of 50 and more dwellings must provide play space. For developments of 50-159 dwellings a play area suitable for children aged 0–8 will be required. Where a development forms part of an area for which there is a masterplan approved by the Council, play space must be provided in accordance with the masterplan.

4.41 Play areas must: be easy and safe to reach on foot; be well overlooked by surrounding dwellings; be equipped and laid out to a design as agreed with the Council; be provided by the developer; and have arrangements in place for maintenance to the satisfaction of the Council.

4.42 In accordance with Policy OS4, areas of play space will be delivered in line with that shown on the approved indicative masterplan. These spaces have been carefully positioned within the site to maximise access from the housing plots.

Policy T1: Development Location and Accessibility 4.43 New developments should be located on sites that are conveniently and safely accessible on foot and by cycle, by public transport as well as by private vehicle, including adequate car parking provision in accordance with the Council’s standards. The submission of Travel Plans may also be required in support of certain proposals.

4.44 The suitability of the site for development from an accessibility perspective has been established through the PPiP. Further details of the site’s accessibility by public transport is provided in the Transport Statement submitted with this application.

4.45 The Council's "Standards for Development Roads- Part 5 Parking Standards" specifies the parking standard for general housing as 1 private space plus 0.5 communal space for dwellings with up to five rooms, and 2 private spaces plus 0.25 communal space for dwellings with six or more rooms. The Transport Statement confirms that a mixture of in curtilage and on street car parking for residents and visitors is provided throughout the development to the Council’s standards.

Policy T2: General Transport Impact 4.46 New development must have no significant adverse impact on: road safety; the convenience, safety and attractiveness of walking and cycling in the surrounding area; public transport operations in the surrounding area, both existing and planned, including convenience of access to these and their travel times; the capacity of the surrounding road network to deal with traffic unrelated to the proposed development; and residential amenity as a consequence of an increase in motorised traffic.

4.47 Any mitigation required as a result of the impact of development on the transport network will be provided by the developer and secured by the Council by planning condition and / or legal agreement where appropriate.

4.48 As confirmed by the Transport Statement, the Transport Assessment that accompanied the PPiP application included a comprehensive analysis of vehicle trip generation, distribution and traffic impact. The proposal for 77 homes does not add additional housing over and above the maximum 1,600 permitted by the PPiP, as such, there will be no additional vehicle trips above the level that was included in the traffic modelling exercise associated with the PPiP. The Transport Statement concludes that no

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assessment of the traffic impact of the proposal is required, both on the internal network of streets within the masterplan area, or external local and strategic road network.

Policy T30: Road Safety and 20mph Limits 4.49 Policy T30 notes that the Council shall develop a road safety plan to further invest in road safety and further introduce 20mph speed limits and zones in residential areas.

4.50 A Speed Limit Strategy for the site has been approved in respect of Condition 25 of the PPiP. This document confirms that residential roads within the site would all be subject to 10mph speed limits, to be implemented as zones. The layout of the proposed development has been designed to mitigate vehicle speeds; the internal streets will largely comprise of shared surfaces or narrow streets which will act to keep vehicle speeds down.

Policy DCN2: Provision for Broadband Connectivity in New Development 4.51 Development proposals of 5 or more homes shall, as part of the development, make provision for deliverable opportunities for digital infrastructure to the proposed new homes or business premises as relevant, particularly provision for ducting and fibre or wiring for broadband connectivity.

4.52 The applicant is in discussion with digital infrastructure service providers to facilitate provision of this infrastructure, in accordance with the requirements of Policy DCN2.

Policy W3: Waste Separation and Collection 4.53 Policy W3 requires all new development to include appropriate provision for waste separation and collection to meet the requirements of the Waste (Scotland) Regulations and address the waste hierarchy.

4.54 Each property will include appropriate provision for storage of domestic kerbside collection bins and boxes as well as recycling facilities in line with the Council’s waste collection service. Swept path analysis has been undertaken to ensure there is sufficient space for servicing by collection vehicles.

Policy NH10: Sustainable Drainage Systems 4.55 All development proposals must demonstrate that appropriate provision for Sustainable Drainage Systems (SuDS) has been made at the time of submitting a planning application. Sufficient space for proposed SuDS provision, including the level and type of treatment appropriate to the scheme of proposed development, must be safeguarded in site layouts. Provision must also be made for appropriate long-term maintenance arrangements to the satisfaction of the Council.

4.56 A drainage assessment may also be required to show the impact of a 1 in 200-year rainstorm event. SuDS schemes should be designed with an allowance for climate change.

4.57 Proposals must also demonstrate through a design-led approach how SuDS proposals are appropriate to place and designed to promote wider benefits such as placemaking, green networks and biodiversity enhancement.

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4.58 The Plot 11 Drainage Strategy and Flood Risk Assessment confirms that the surface water runoff from the development will discharge via permeable paving and soft SuDS features to an offsite basin, as previously agreed with the Council, then on to the realigned Mill Lade. Source control treatment will be provided within the plot, with a further level of treatment being provided within the downstream basin. Attenuation will ensure that the development should be protected up to the 1 in 200-year (0.5% AEP) rainfall event including a 30% allowance for climate change.

Policy NH11: Flood Risk 4.59 Development that would be at unacceptable risk of flooding will not be permitted. New development within areas of medium to high risk of coastal or watercourse flooding (with greater than 0.5% annual probability of flooding) should generally be avoided. All relevant development proposals will be assessed based on the probability of a flood affecting the site and the nature and vulnerability of the proposed use.

4.60 Flood Risk Assessments will normally be required for proposals within the medium to high risk category of flood risk. They may also be required in the low to medium category in certain circumstances, for example at the upper end of the probability range or for essential infrastructure and the most vulnerable uses.

4.61 The Plot 11 Drainage Strategy and Flood Risk Assessment confirms that Plot 11 is not considered to be at risk from flooding.

Policy CH5: Battlefields 4.62 The site is located within the boundary of the ‘Battle Of ’ Inventory of Historic Battlefields site. Policy CH5 specifies that development within a site listed in the Inventory of Historic Battlefields will not be permitted where it would have a significant adverse effect on the key features of the battlefield, including its key landscape characteristics and special qualities, unless it can be demonstrated that the overall integrity and character of the battlefield area will not be compromised. Where new development is supported, appropriate mitigation must be provided to conserve or enhance the key features of the battlefield, including through siting, scale, design and landscape treatment and, where relevant, contribute to the understanding of the battle and historic assets.

4.63 In accordance with Policy CH5, the development proposed as part of this application will not have a significant adverse effect on key features of the battlefield. The principle of development with the boundaries of the ‘Battle Of Prestonpans’ Inventory of Historic Battlefields site has been established through PPiP 20/01030/PM.

Policy DP1: Landscape Character 4.64 All new development, with the exception of changes of use and alterations and extensions to existing buildings, must:

1. Be well integrated into its surroundings by responding to and respecting landform, and by retaining and where appropriate enhancing existing natural and physical features at the site, including water bodies, that make a significant contribution to the character and appearance of the area and incorporate these into the development design in a positive way;

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2. Include appropriate landscaping and multifunctional green infrastructure and open spaces that enhance, provides structure to and unifies the development and assists its integration with the surroundings and extends the wider green network where appropriate.

4.65 The proposed landscaping is critical to establishing a successful new settlement at Blindwells. The strategy for the new neighbourhood considered the urban edge, green network, connectivity, increased biodiversity and the creation of development pockets within an appropriate framework to inform development phases.

4.66 The landscape strategy for the site has been developed in conjunction with Oobe and seeks to assimilate the plot within the wider masterplan and allows permeability through the new neighbourhood and access to features such as Princes Loch and Princes Park.

4.67 Woodland and open space orientated on a north / south axis throughout the new development is proposed. The woodland will help to define areas of different character within the development creating a sense of place and identity and also creates opportunities to enhance the biodiversity.

Policy DP2: Design 4.68 Policy DP2 requires the design of all new development, with the exception of changes of use and alterations and extensions to existing buildings, must:

1. Be appropriate to its location in terms of its positioning, size, form, massing, proportion and scale and use of a limited palate of materials and colours that complement its surroundings; 2. By its siting, density and design create a coherent structure of streets, public spaces and buildings that respect and complement the site’s context, and create a sense of identity within the development; 3. Position and orientate buildings to articulate, overlook, properly enclose and provide active frontages to public spaces or, where this is not possible, have appropriate high quality architectural or landscape treatment to create a sense of welcome, safety and security; 4. Provide a well-connected network of paths and roads within the site that are direct and will connect with existing networks, including green networks, in the wider area ensuring access for all in the community, favouring, where appropriate, active travel and public transport then cars as forms of movement; 5. Clearly distinguish public space from private space using appropriate boundary treatments; 6. Ensure privacy and amenity, with particular regard to levels of sunlight, daylight and overlooking, including for the occupants of neighbouring properties; 7. Retain physical or natural features that are important to the amenity of the area or provide adequate replacements where appropriate; 8. Be able to be suitably serviced and accessed with no significant traffic or other environmental impacts.

4.69 The design proposes high quality materials which are appropriate for the massing and scale of the surrounding residential developments. The buildings respect traditional

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qualities of form and proportion but will combine with contemporary detailing to reflect the 21st century construction techniques.

4.70 Key frontages have been identified in important locations and elevations throughout the new neighbourhood. Key frontages will address important areas of public realm such as the central open space and the north south connections.

4.71 Buildings have been located to overlook key spaces such as primary routes, open space and play areas, providing active frontage and natural surveillance. They will also act as landmarks within housing streets so that the new area is easily navigated and recognisable. This will ensure that the individual areas are unique and help to create a sense of character and identity throughout the new neighbourhood.

4.72 The proposals include a high level of pedestrian permeability, ensuring safe, convenient, and direct pedestrian links are provided throughout the proposed development and the wider Blindwells masterplan site. Two active travel routes are provided at the western boundary of the site which provide links to the housing plot to the west and also connections to the north and south to tie into active travel corridors across the masterplan area to provide access to local amenities. Pedestrian permeability has been maximised through the street hierarchy which prioritises pedestrian and cycle movement to make a more attractive area to meet, congregate and play. Elements such as street trees, courtyards, varied surfaces and informal parking will reduce vehicle speeds and increase safety.

4.73 A mix of hedge row, brick walls and timber which will be utilised to enclose gardens and screen cars and drives. Hedges will define the private / public realm and street trees will also provide visual barriers for motorists.

4.74 The dwellings have suitable separation distances to ensure high levels of privacy. Fencing, 1.8m in height, will ensure privacy is provided between properties and at the rear of the gardens.

4.75 Swept path analysis for refuse vehicles has been undertaken to ensure the site can be suitable serviced and accessed.

Policy DP3: Housing Density 4.76 Policy DP3 expects new housing sites to achieve a minimum average density of 30 dwellings per hectare (net) using a full range of housing types and sizes. Where appropriate this density may be increased to respect and respond to the particular circumstances of its location, in particular the accessibility of the site to public transport and other relevant services, and the need to encourage and support the provision of local facilities necessary to high quality urban living.

4.77 Based on the area of the housing plot which extends to 1.85 hectares, the development achieves a density of 42 dwellings per hectare.

Policy DP4: Major Development Sites 4.78 All housing and employment proposals of a major development type as defined by the provisions of The Town and Country Planning (Hierarchy of Developments) (Scotland)

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Regulations 2009, require the submission of a masterplan for the entire allocated site and an accompanying supporting statement.

4.79 An indicative masterplan was submitted and approved in respect of the original PPiP (ref. 14/00768/PPM). The current application proposes an alternative use for Plot 11 than shown on the approved indicative masterplan submitted under 14/00768/PPM, however it does not alter the principles of development for the site established by the approved masterplan. Full details of how the development assimilates with the parameters of the approved masterplan is set out in the accompanying Design and Access Statement.

Policy DP8: Design Standards for New Housing Areas 4.80 Policy DP8 requires the principles of the Council’s supplementary planning guidance Design Standards for New Housing Areas to be incorporated into the design and layout of all new relevant developments. All Home Zone / shared surface street designs must also be consistent with this document.

4.81 The homezone streets and lanes will have a different character where the pedestrian and cyclist is prioritised over vehicular traffic. The homezones will be defined by varied building lines and carriageway widths. Shared surfaces will be incorporated rather than separate footways and nodes will break up the road pattern at key locations along the route. Full details of how the development complies with this policy is set out in the accompanying Design and Access Statement.

Policy DEL1: Infrastructure and Facilities Provision 4.82 Policy DEL1 states that new development will only be permitted where the developer makes appropriate provision for infrastructure and community facilities required as a consequence of their development in accordance with Scottish Government Circular 3/2012 or any revision. Developer contributions will be required from all new development proposals of 5 or more dwellings, including affordable homes.

4.83 A Section 75 Agreement is in place for the masterplan PPiP which contains provisions to ensure that infrastructure will be delivered appropriately. As such, this proposal that will contribute 77 of the 1,600 homes approved under the PPiP is not expected to generate a requirement for any additional financial contributions.

Material Considerations

Blindwells Development Framework (2010) 4.84 The Council produced supplementary planning guidance for the Blindwells development site in 2010 in the form of a Development Framework. This document builds on existing local plan policy and outlines specific requirements and deliverables which must accompany development that takes place in the years ahead throughout the different implementation phases of the proposal.

4.85 Policy DP9 of the LDP requires proposals for the development of sites that are subject to a development framework that has been adopted by the Council to conform to the relevant framework or brief.

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4.86 The Development Framework identifies that the site is allocated for a new settlement and sets out those criteria against which any planning application will be assessed. The Design and Access Statement provides detail on how the proposed development complies with the design code set out in the Development Framework document.

Design Standards for New Housing Areas Supplementary Planning Guidance (May 2020) 4.87 The Design Standards for New Housing Areas Supplementary Planning Guidance seeks to raise awareness of the unique characteristics and attributes of East Lothian, how these can be used positively to create new places both small scale and large, and the technical aspects of design that are required to deliver great new places.

4.88 The proposed development seeks to build on the key design principles established by the PPiP and as stated in the Design and Access Statement, “to create a sense of place and identity which will be instantly recognisable as Blindwells”. Further details on how this is achieved by the proposed development is provided in the Design and Access Statement.

Indicative Regional Spatial Strategy for Edinburgh and South East Scotland City Region 4.89 The Planning (Scotland) Act 2019 was enacted in July 2019 which removes the statutory requirement to prepare a Strategic Development Plan and replaces it with duty on local authorities to prepare a Regional Spatial Strategy (‘RSS’).

4.90 The RSS will not form part of the statutory Development Plan which will now comprise the National Planning Framework and the Local Development Plan. The most current SESplan Strategic Development Plan (2013) will remain in force until the approval of National Planning Framework 4 which is anticipated in late 2021.

4.91 A draft indicative RSS covering the Edinburgh and South East Scotland City Region areas has been submitted to Scottish Government to feed into preparation work for NPF4. The iRSS recognises Blindwells as a strategic site, a key element of housing delivery that will deliver new communities in key locations across region. As one of the seven strategic housing sites in the region, the Blindwells Development Area can enable significant new employment and economic development opportunities, including a new regional town centre. There is significant potential to enable this long term development opportunity in a sustainable, inclusive, healthy and low carbon way.

4.92 As the draft RSS following Scottish Government comments is not due until late 2021 it is not considered it will be sufficiently progressed to inform the planning application, although its continued support for delivery of the Blindwells new settlement is noted.

National Planning Framework 3 4.93 National Planning Framework 3 (NPF3) sets out the vision of how Scotland should develop over the next 20 to 30 years. NPF3 outlines the Scottish Government’s central purpose of focussing government and public services on creating a more successful country, with opportunities for all to flourish, through increasing sustainable economic growth. Through implementation of the spatial strategy set out in NPF3 there will be ‘opportunities for growth and regeneration, investment in the low carbon economy, environmental enhancement and improved connections across the country’.

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4.94 NFP3 notes a need in Edinburgh and the south east for a planned approach to ensure development requirements are met, and a greater and more concerted effort to deliver a generous supply of housing land.

4.95 The Scottish Government makes note of the large quantity of previously used and derelict land across Scotland, and aims to bring this back into productive use. Although much of Scotland’s previously disturbed land is located to the west of the country, Blindwells will make a significant contribution to the government’s aim with through restoration of a large scale brownfield site.

4.96 Transport accounts for a significant proportion of Scotland’s greenhouse gas emissions. The Scottish Government has set an ambitious target of at least an 80% reduction in greenhouse gases by 2050. The Blindwells development can contribute to this by reducing the need to travel by car, providing key services locally and promoting other modes such as cycling, walking, public transport, and the provision of park and ride facilities to aid connectivity within the wider local area. In addition, a mixed use compact settlement with effective walking and cycle networks will significantly help to reduce mobility rates in the area and contribute to increased sustainable growth in East Lothian. The relationship between land use and transport must be highly integrated to achieve this goal. The use of new technologies is also important in the drive to reduce carbon emissions, with the option to work from home and communications technology helping reduce energy consumption.

4.97 In terms of green infrastructure, NPF3 outlines a requirement for an integrated approach and a ‘greening’ of the urban environment, which will result in improvements to quality of life, enhanced environmental performance and climate resilience. Well- designed and walkable streets will benefit pedestrians and cyclists, contributing to improved health and well-being.

4.98 Overall the Blindwells development is likely to contribute to the goals in the NPF3 for themes such as housing, sustainability, placemaking, sustainability economic growth, built environment, vacant land and greening the environment.

Scottish Planning Policy 4.99 The introductory section of Scottish Planning Policy (SPP) outlines the purpose of planning and what it aims to achieve – in essence it is the Scottish Government’s main policy statement on land use planning and its purpose.

4.100 The purpose of SPP is “to set out national planning policies which reflect Scottish Ministers’ priorities for operation of the planning system and for the development and use of land”. SPP includes core values that should underpin the planning system at Paragraph 4 which are:

• Focus on outcomes, maximising benefits and balancing competing interests;

• Play a key role in facilitating sustainable economic growth, particularly the creation of new jobs and the strengthening of economic capacity and resilience within communities;

• Be plan-led, with plans being up-to-date and relevant;

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• Make decisions in a timely, transparent and fair way to provide a supportive business environment and engender public confidence in the system;

• Be inclusive, engaging all interests as early and effectively as possible;

• Be proportionate, only imposing conditions and obligations where necessary; and

• Uphold the law and enforce the terms of decisions made.

4.101 SPP encourages the planning system to “take a positive approach to enabling high- quality development and making efficient use of land to deliver long-term benefits for the public while protecting and enhancing natural and cultural resources”.

4.102 Sustainability is highlighted as a principle policy of SPP and directs the planning system to facilitate economically, socially and environmentally sustainable places by enabling development that balances the cost and benefits of a proposal over the longer term.

4.103 Paragraph 29 of SPP 2020 sets out 13 sustainability principles. These principles remain unchanged from the previous version of SPP. Paragraph 33 of SPP (as amended) confirms that whether a proposed development is sustainable development should be assessed according to the principles set out in paragraph 29. It is clear from the amended wording that the assessment of sustainability is separate from development plan considerations. The principles include the following:

• Giving due weight to net economic benefit;

• Responding to economic issues, challenges and opportunities, as outlined in local economic strategies;

• Supporting good design and the six qualities of successful places;

• Supporting town centre and regeneration priorities;

• Making efficient use of existing capacities of land, buildings and infrastructure including supporting town centre and regeneration priorities;

• Supporting delivery of accessible housing, business, retailing and leisure development;

• Supporting delivery of infrastructure

• Supporting climate change mitigation and adaptation including taking account of flood risk;

• Improving health and well-being by offering opportunities for social interaction and physical activity, including sport and recreation;

• Having regard to the principles for sustainable land use set out in the Land Use Strategy;

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• Protecting, enhancing and promoting access to cultural heritage, including the historic environment;

• Protecting, enhancing and promoting access to natural heritage, including green infrastructure, landscape and the wider environment;

• Reducing waste, facilitating its management and promoting resource recovery;

• Avoiding over-development, protecting the amenity of new and existing development and considering the implications of development for water, air and soil quality.

4.104 Placemaking is a further principle policy outlined by SPP. Development should be directed to the right place through the implementation of spatial strategies that encourage sustainable patterns of development appropriate to the area. SPP advocates optimising the use of existing resource capabilities through coordination of housing development and infrastructure investment.

4.105 SPP includes a number of policy subjects, the following of which can be viewed as being relevant for the Blindwells development.

Enabling Delivery of New Homes 4.106 The Blindwells new settlement will make a significant contribution to housing provision in the East Lothian area. The Blindwells development also achieves the preference that the government sets out for the re-use or re-development of brownfield land in directing development to the most appropriate location, consideration must be given to “the re-use or re-development of brownfield land before new development takes place on greenfield sites” (Paragraph 40).

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5. Summary and Conclusions

5.1 This Planning Statement has assessed the proposal for residential development, with associated infrastructure and access, on land referred to as ‘Plot 11’ at Blindwells, East Lothian.

5.2 Plot 11 is situated in the north west of the wider Blindwells site, which benefits from planning permission in principle (PPiP) for remediation of the site and creation of new settlement comprising residential, employment, education and commercial uses.

5.3 The indicative masterplan, approved under the PPiP, shows development of land at Plot 11 for retail use; however, this is not reflective of current circumstances due to the passage of time since the masterplan was prepared and the changes in the retail market that have occurred in the intervening period. The applicant is seeking to instead develop the land for residential use, for the reasons set out in Section 2 of this statement.

5.4 A total of 77 new homes are proposed as part of this application for planning permission, of which 30% will be provided as affordable housing. As noted above, these new homes are not proposed in addition to the 1,600 which are approved through the extant PPiP, rather these homes contribute towards the number currently approved. As noted at Section 2 above, the suitability of land to the south of Plot 10 for residential development cannot be confirmed at this stage, as such, homes originally envisaged in this part of the site will now be provided on Plot 11. Therefore, the 1,600 homes approved will not be exceeded through approval of this application for planning permission. Planning conditions can be used to ensure that this is achieved.

5.5 The proposals have been designed in accordance with the Blindwells Development Framework (2010) and with the approved Blindwells PPiP masterplan, as set out in the accompanying Design and Access Statement. The principle of residential development on Plot 11 is consistent with the aims of East Lothian Local Development Plan policy in relation to deliver a sustainable new settlement at Blindwells.

5.6 As demonstrated by this Planning Statement and other documentation submitted in support of this application, the proposal will deliver a high quality, accessible and sustainable residential development, in accordance with the relevant policies outlined in the development plan; therefore, it is respectfully requested that East Lothian Council approve the application accordingly.

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Appendix 1: Site Location Plan

The Haven Lay-by THIS DRAWING IS COPYRIGHT ©. 3677 GP ORDNANCE SURVEY CROWN COPYRIGHT ©, ALL RIGHTS RESERVED. LICENCE NUMBER 100020449.

DO NOT SCALE FROM THIS DRAWING, USE FIGURED DIMENSIONS ONLY. ALL DIMENSIONS TO Track BM 29.07m BE CHECKED ON SITE BEFORE WORK COMMENCES, DISCREPANCIES TO BE REPORTED TO EMA. MP 11 VARIATIONS AND MODIFICATIONS TO INFORMATION SHOWN ON THIS DRAWING SHALL NOT

Track 6568 BE CARRIED OUT WITHOUT PRIOR PERMISSION OF EMA ARCHITECTS, WHO ACCEPT NO LIABILITY FOR ALTERATIONS MADE TO THIS DRAWING BY ANY OTHER PARTY. 0072 THIS DRAWING IS TO BE READ IN CONJUNCTION WITH ALL RELEVANT ARCHITECTURAL, STRUCTURAL, SERVICES DRAWINGS AND SPECIFICATIONS.

The West Seton House IT IS THE RESPONSIBILITY OF THE CONTRACTOR TO ENSURE THAT ALL MATERIALS USED Stables DURING CONSTRUCTION CARRY A CE MARKING.

Seton West Mains

Tordene REV DESCRIPTION DRAWN CHKD. DATE

Garage

Battle of Prestonpans Track 21st September 1745

5500

MP 0.75 APPLICATION BOUNDARY Track

Track LAND IN CONTROL OF THE A 198 SL APPLICANT A 198

FB

SL BM 32.84m Track

B 1361

MP .5 Mineral Railway

SL

A 198 Track Path

Meadow House

Path

Drain

El Sub Sta

Sinks

Drain Drain

A 198

5800

St Joseph's School

A 198

Drain 1

6

St Joseph's Cottages Track ema

Golf Range architects masterplanners

BANKTON JUNCTION 42 CHARLOTTE SQUARE EDINBURGH EH2 4HQ

Lay-by A 1 E [email protected] T 0131 247 1450 W WWW.EMA-ARCHITECTS.CO.UK

A 1

Drain

Drain Drain BLINDWELLS, EAST LOTHIAN

Lay-by Lay-by HARGREAVES SERIVES (BLINDWELLS) LTD

Drain

A 1

LOCATION PLAN PLOT 11

56.1m Tranent Mains A 1 Cemetery

Track

BM 65.89m

Tranent Cemetery SCALE / SIZE DATE / DRAWN PROJ. TYPE SHEET No. / No. SHEETS Track

WB Tanks 1:2500 / A1 16.12.20 /JF 1 / 1 Tranent Mains DRAWING REFERENCE

18 21018(PL)001_A

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4 ISSUE PURPOSE WORK STAGE 28

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FILE CLASSIFICATION FILE REFERENCE 7

Turley Office 26 Dublin Street Edinburgh EH3 6NN

T 0131 297 0229