Stewart Milne Homes
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Submissions On Behalf of: STEWART MILNE HOMES . GENERAL ISSUES, QUESTIONS 1-18; . LAND AT CLAYHOLES, CARNOUSTIE; . LAND AT WESTHAVEN, CARNOUSTIE; . LAND NORTH OF WOODSIDE ROAD, LIFF; . LAND SOUTH OF WOODSIDE ROAD, LIFF; . BALLUMBIE GOLF & RESIDENTIAL DEVELOPMENT; . VILLAGE H, BALLUMBIE; . VILLAGE V, BALLUMBIE Angus Main Issues Report - November 2012 Response on Behalf of Stewart Milne Homes December 2012 Angus Main Issues Report November 12 – Stewart Milne Homes Response Jan 13 Spatial Strategy Q1. Do you support the preferred options for the LDP spatial strategy and its implementation, as shown in Tables 1, 2, and 3? Please explain your answer and give details of any alternative option that you think is better. Q2. Would you support the implementation of a “Development Charge” system in Angus, so that public sector finances would be used to front-fund the development of infrastructure that is required to service new development, with costs being recouped once new homes/business premises are sold? Please explain your answer. Q1. Response The overall approach of the spatial strategy is supported with the view that development in the main be directed towards the larger settlements within the Angus Area. Stewart Milne Homes have land interests in both Montrose and Carnoustie, and welcome Angus Council’s strategy of continuing to focus the majority of development within the larger settlements. It is of some concern however, that there seems to be a lack of new sites being supported through the MIR for Montrose in particular. The large areas of land being looked at for new employment use does not compare to the amount of land identified for housing within the settlement. Part of the strategy for Montrose is to encourage new economic development to the area through the Port of Montrose and this strategy needs to be coupled with a strong housing allocation to support the release of further land for employment. A separate representation has been prepared for Ferryden, Montrose and has been submitted to the Council for consideration. Similarly, representations has been prepared and submitted for our land interests at Carnoustie. Stewart Milne Homes however, do not agree with the strategy set out for rural South Angus. Rural South Angus has a key part to play in the distribution of development through the Dundee City Region Strategy and at present, both Dundee City Council and now Angus Council seem to be taking the approach that little or at least, very limited housing and employment opportunities would be coming forward through the South Angus settlements outside that of Monifieth. Settlements within the rural South Angus Housing Market Area and settlements that fall within close proximity to the Dundee City boundary such as Liff and Village H at Ballumbie are not seeing the level of development that would seem appropriate to help support existing communities and to realistically support a developing City Region. Table 1 sets out that Angus Council seek to identify small scale development in Edzell, Frockheim, Letham and Newtyle. Stewart Milne Homes would not support this approach and do not consider that development so far removed from existing infrastructure can be supported through the sustainable policies set out by TAYplan. There seems no logical justification to seek to bring these particular smaller settlements forward for development, when settlements within the rural south Angus HMA Angus Main Issues Report November 12 – Stewart Milne Homes Response Jan 13 have been essentially overlooked, settlements which are closer to transport corridors, to the City and need investment in infrastructure which the Council will struggle to deliver without further development. Table 2 sets out that Angus Council’s preferred option would be to maintain their current approach of providing greater opportunity for new countryside housing in the remote rural areas. Stewart Milne Homes would support that approach, but there has to be a sound reason for bringing forward developable pockets within rural settlements. Land on the boundary of the Dundee City that falls within the South Angus Housing Market Area has been largely overlooked within the MIR with indication that land release on the outskirts of the City could prejudice development within the City of Dundee. Parts of South Angus fall within the Dundee Core Area and are set out within TAYplan as helping deliver strategic housing and employment land to feed the City Region. The village of Liff by way of an example has a significant part to play in delivering sensitively managed pockets of development of land to provide necessary infrastructure required to provide for schools, road upgrades and maintain communities. Sensitively phased development will enable smaller communities that lie on the boundary of Dundee City to become more self-sufficient and sustainable in their own right. The individual settlement analysis does identify that some small scale development will be considered within the rural settlements and based on a landscape capacity to absorb new development. Whilst Stewart Milne Homes welcomes the fact that Angus Council will look to other smaller settlements for development, there requires to be greater analysis undertaken to establish which settlements would benefit greatest from development. Separate development bids have been prepared for land interests within the settlement of Liff and other settlements within administrative area to be considered, have been submitted to Angus Council for further site specific consideration. Q2. Response Understanding of development economics and the expectations on the development industry to continue to provide significant infrastructure continues to be the biggest challenge facing the house building industry. The removal of lending facilities for upfront infrastructure has severely reduced the ability of developers to unlock large, strategic sites. Support from local and national government is needed, in the way of loans, or grants, to facilitate the delivery of significant infrastructure projects. Stewart Milne Homes recognise that contributions on a fair and measured scale are essential to bring forward development however, cannot in the majority of instances be front funded. There is still evidence of a considerable lack of understanding of development finance and delivery at local government level also, in the numbers of housing units allocated required to fund significant levels of infrastructure. Housing allocations are made through the housing land audits carried out by Local Authorities but more often than not the number of houses identified as “need” within an area cannot justifiably finance the level of infrastructure required. Angus Main Issues Report November 12 – Stewart Milne Homes Response Jan 13 Stewart Milne Homes support the principle of a development charge system in terms of creating certainty for developers and landowners and with the potential from moving away from lengthy and costly Section 75 agreement negotiations. Any development charge system would have to ensure the stakeholders that contributions met the tests of Circular 1/2010 and that a transparent and fully justifiable breakdown of costs were in place ensuring that a standard development charge does not prohibit or restrict release of development land through the planning system. The management of funding will be the biggest challenge, but should not be insurmountable as there are many processes already in place for gathering of Developer Contributions which can be tracked to individual planning consents rather than lost unacceptably in wide the wider Council accounting procedures. Any proposals to bring in such mechanisms would require detailed consultation and should be brought through the Proposed Plan so they can be fully scrutinised at examination. Main Issue 1: Housing Land Q3. Do you agree that new housing development on unallocated small and “windfall” sites should be considered as additional to new housing on allocated sites? Please explain your answer. Q4. Do you agree that Angus LDP should not allocate land just to compensate for the possible failure of some sites to deliver new homes on expected timescales? Please explain your answer. Q5. Do you agree that the housing land supply of the Angus LDP should be released in two phases during the 10-year plan period? Please explain your answer. Q3. Response Stewart Milne Homes would agree that housing development on small unallocated sites known as “windfall”, should continue to be “in addition” to allocated housing within the proposed Local Development Plan. Windfall development historically has augmented the housing land supply in smaller numbers and allowed settlement growth in certain areas that would not have otherwise come forward due to financial restrictions on larger releases. It would therefore be in the interest of Angus Council to maintain their current approach and allow windfall to come forward unrestricted. It ensures flexibility in the provision of housing land supply. The Council set out within the MIR in their alternative option for housing land supply, that they would estimate future completions on windfall sites to reduce planned housing land allowances, which have been established on the basis of the TAYplan requirements. Stewart Milne Homes does not support this concept and would strongly suggest that this approach is not taken. The level of housing output in completions across the Angus HMA has seen significant decline over the years since 2008. In some cases, the only housing