WEST LOTHIAN PLANNING COMMITTEE

Report by Development Management Manager

1 DESCRIPTION OF THE PROPOSAL

1.1 Conservation area consent for the demolition of unlisted buildings in Bangour Village Conservation Area.

2 DETAILS

Reference no. 0608/LBC/15 Owner of site NHS Lothian

Applicant NHS Lothian Ward & local Broxburn, Uphall and members Winchburgh Tony Boyle Diane Calder Janet Campbell Alex Davidson Case officer Ross Burton Contact details [email protected]

Reason for Referral to West Lothian Planning Committee:

2.1 This is a supporting application to the ‘major’ application for planning permission in principle for the development of the former Bangour Village Hospital (0607/P/15). That application is being considered by the West Lothian Planning Committee and the full council because it is a ‘major’ application which constitutes a departure from the development plan.

2.2 This application, and four listed building consent applications for the demolition of listed buildings on the site are, likewise, being reported to the West Lothian Planning Committee in order that members are aware of the extent of decision making required to determine the application for planning permission in principle and that the associated applications can be determined simultaneously.

2.3 There is no requirement under the Town and Country Planning (Scotland) Act 1997 that in determining applications for conservation consent, that the applicant and those persons who have made representation on the application may appear before and be heard by a committee of the council. Nevertheless, to facilitate the Bangour decision, Standing Orders have been adapted to allow both the West Lothian Planning Committee and the full Council (planning) to determine all Bangour applications.

2.4 A subsequent report will be presented to West Lothian Council and the application for conservation area consent can then be determined.

3 RECOMMENDATION

3.1 It is recommended that West Lothian Planning Committee notes the contents of this report and the terms of all representations that are made by those appearing at the hearing prior to a decision being made on the planning application by West Lothian Council.

4 Location, site history and description of the proposal.

4.1 Appendix (a) is a plan showing the boundary of Bangour Village Conservation Area, and indicates the buildings proposed for demolition. Also attached (appendix b) is a gazetteer of all unlisted buildings on site. The area around Bangour Village Hospital was designated as a conservation area by the council on closure of the hospital in 2004. The conservation area designation aimed at protecting the special character and appearance of the area. Stautory it means that no buildings can be demolished without consent from the council. Additionally, the council’s consent is required for the removal of any trees. The current application does not seek approval for any woodland removal.

4.2 Bangour Village Hospital was opened in 1902; the first buildings constructed were timber, and were intended to be temporary structures, to accommodate patients from Edinburgh while the main buildings on the site were being constructed. These buildings remain, in the north-west sector of the site, and are amongst the unlisted buildings which are proposed for demolition.

4.2 The application site contains a total of 24 unlisted buildings; in addition to the group of buildings in the north-western sector there are five ‘utility’ buildings in the centre of the site – laundry and kitchen buildings – and two therapy buildings. There are four unlisted ward buildings in the north-east corner of the site, close to the important core group of listed buildings but built at a later date. The remainder of the unlisted buildings are scattered through the site; all but two, the former shop and the sports pavilion overlooking the recreation ground, are proposed to be demolished. All of the unlisted buildings are in poor condition.

4.3 The former shop is not proposed for demolition because of its importance to the site. It is located at the centre of the site, at the end of the entrance driveway. It is a single storey building which has modern extensions, but which originally was surrounded by a covered veranda. It is considered that its retention and re-use will add to the character of the new development.

4.4 The pavilion overlooking the recreation ground is a timber building which has been damaged by fire, but enhances the site and is still, it is considered, capable of repair and re-use. Should the recreation ground become part of the new primary school grounds an element of community use is possible.

4.5 Some of the remaining unlisted buildings are of interest, but are not of sufficient quality, architecturally or historically, to be worthy of retention. All have suffered from lack of protection and some are in an extremely poor condition. Many have also been adversely affected by additions and alterations. The proposals comprise the demolition of the following buildings:

• Gardeners and porter (Map ref. 2) • Gateway Cottage (3) • Engineer’s Department (5) • Old Laundry (8) • Kitchen and stores (10) • Industrial unit (12) • Domestic Store / Old Post Office (14) • Occupational Therapy (16) • Old Bakery (17) • Physiotherapy / Fire training (23) • Villa 29 (24) • Villa 31 (25) • Neuroscience (28) • Gardeners’ shed (37) • Villa 23 (38) • Villa 24 (39) • Gardeners’ store (40) • Boiler house (41) • X-ray store / school (42) • Villa 25, 26 (43) • Villa 27 (44) • Villa 28 (45)

5 Representations

5.1 Objections have been received from Dechmont Community Council, the Walker Group and a member of the public. The matters raised is summarised as follows:-

Objection comment Planning response

The application for demolition of The two applications are statutorily separate the unlisted buildings should be and this application for conservation area considered along with consent requires to be considered on its own application 0607/P/15 merits, but both applications, and applications for the demolition of some listed buildings on the site, are being reported to the same committee in order that members are aware of the whole picture, and of the proposals for the development of land on which the unlisted buildings stand. As many unlisted buildings as Many of the unlisted buildings are in an possible should be retained, as extremely poor state of repair, and the cost of they constitute an important part retaining and converting them to productive use of the site. would exacerbate the existing heritage deficit, detracting further from the commercial viability of the development of the site, ultimately leading to the possible demolition of listed buildings. Demolition should not be A condition is proposed to be attached which approved without a conservation will require the developer to carry out a area appraisal and acceptable conservation area appraisal. The application is proposals for new buildings to accompanied by a Heritage Statement, which replace the buildings proposed includes an appraisal of the impact which the for demolition. demolitions would have on the conservation area.

The masterplan which has been submitted as part of application 0617/P/15 is considered to give sufficient detail of the proposed development of the site to allow for consideration of this application.

6 Consultations

6.1 The consultation responses received are set out below.

Consultee Comment Historic No objection. The buildings must be recorded to a satisfactory Environment standard before demolition, and any materials which can be Scotland salvaged should be. Specific mention is made of the City of Edinburgh Coats of Arms which survive on some of the timber buildings in the north-west sector of the site.

West of Scotland No objection, subject to the recording of the buildings’ Archaeology features. Service

7 Policy

7.1 The development plan in this case is SESplan and the West Lothian Local Plan 2009 (WLLP), with the emerging Local Development Plan (LDP) as a material consideration. The requirement of the Government’s Scottish Historic Environment Policy (SHEP) is also a material consideration.

Plan Policy Assessment Conform? WLLP HER 1 Preservation and This application is part of a suite of Yes enhancement of the built applications which together seek environment to achieve the retention and re-use of the important listed buildings at Bangour Hospital. Without the demolition of the unlisted buildings on site the proposed development’s viability would be brought into question. HER 2 Protection of The demolition of the unlisted Yes listed buildings buildings will have, in some cases, a positive impact on the settings of some of the listed buildings on the site. HER 19 Character of the The heritage statement which Yes conservation area accompanies the application assesses the impact of the demolitions on the character of the conservation area, taking the view that only three of the unlisted buildings have a positive impact, and that it is proposed to retain the two which are capable of being re- used, the shop and sports pavilion. A condition is proposed requiring the developer to complete a conservation area appraisal within one year of the completion of the development. HER 20 Presumption The proposal must be seen in the Yes against demolition of a context of the application for building in a conservation planning permission in principle, area unless it is fully which seeks permission for the justified in terms of the development of new-build housing need for removal, lack of over parts of the site, in order to any suitable alternative fund the ‘heritage deficit’ - the use and suitability of difference between the cost of replacement development converting the listed buildings on site to productive use and the commercial value of the work. The heritage deficit is substantial and requires the development of significant numbers of new-build houses to fund. If the unlisted buildings were not demolished the proposed redevelopment of the site could not take place. LDP ENV 24 Conservation The buildings proposed for Yes Areas (Demolitions) demolition do not, generally, in their current form, enhance the conservation area. Their removal is justified on the grounds of their condition, the difficulty and cost of adapting them, the enhancement to the conservation area, in visual and economic terms, which will be achieved by their removal, and the fact that their removal is required to allow for the development of the site of the former hospital and the consequent safeguarding of the listed buildings on site. Sottish Conservation Area In deciding whether conservation Yes Historic Consent area consent for the demolition of Environment unlisted buildings in a Policy conservation area should be granted, planning authorities are required to take account of the character or appearance of any part of the conservation area, and of proposals for the future of the site. Demolition can be appropriate if the building is of little townscape value, if its structural condition rules out its retention at reasonable cost, or its form or location make re-use difficult. It can be argued that the above considerations would justify the demolition of most, if not all, of the unlisted buildings on site, on cost alone. The two buildings proposed for retention will be expensive to convert to an alternative use, but their importance to the site is such that their retention is considered to be vital. The remainder of the unlisted buildings are considered to be of lesser importance, so conform to the guidance.

8 Assessment and summary conclusion

8.1 The application site contains 15 listed buildings and 24 unlisted buildings. Two of the unlisted buildings are considered to enhance the conservation area and to be, potentially, re-usable. The development which is proposed under application 0607/P/15 is a mixture of new build housing and the conversion and re-use of all but four of the listed buildings on site; it would not be possible to achieve the numbers of new-build houses required to cross-subsidise the retention of the listed buildings if all of the unlisted buildings were to remain in situ. The listed buildings carry a significant heritage deficit cost for retention and refurbishment; this cost would rise to unsupportable levels if the unlisted buildings were also to be retained. 8.2 The development proposals, which have been arrived at following extensive public consultation, have concentrated on saving the most important buildings on site – all but four of the listed buildings and two of the unlisted buildings. The resulting groupings of listed buildings and new build development will, it is considered, create an attractive development which will respect the style, character and history of this unique site. In order to achieve this, it is accepted that the unlisted buildings proposed for demolition should be removed. 8.3 The proposed development represents an opportunity to save and return to productive use a unique group of listed buildings, in a unique setting. The masterplan demonstrates that the number of dwellings proposed can be accommodated into the landscape without sacrificing the qualities which make it a conservation area. This proposal represents the best opportunity to date of delivering a quality development that preserves the best of the site. 8.4 Any features of note on any of the buildings to be demolished, or any re-usable sandstone, should be used in the redevelopment of the site. Should permission be granted, a condition would be attached to ensure that any features are removed carefully, recorded and stored within the site for re-use.

Chris Norman February 3rd 2016 Development Management Manager

Attachments

Appendix A Unlisted buildings proposed for demolition Appendix B Gazetteer of unlisted buildings

Bangour Masterplan | Heritage Framework| Building GazeƩeer—Unlisted buildings

Character area—Entrance Character area—North west 2 Gardeners and porter 37 Gardeners shed 3 Gateway CoƩage 38 Villa 23 5 Engineer’s Department 39 Villa 24 Character area—Central 40 Gardeners store 6 Shop 41 Boiler 8 Old laundry 42 XͲray store and school 10 Kitchen and stores 43 Villa 25Ͳ26 11 Small laundry 44 Villa 27 12 Industrial unit 45 Villa 28 14 DomesƟc store/Old Post Oĸce 16 OccupaƟonal therapy 17 Old bakery Character area—North east 23 Physiotherapy/Įre training 24 Villa 29 25 Villa31 32 Cricket pavilion

2 Dechmont Community Council

Objection to

BANGOUR VILLAGE HOSPITAL Planning Permission in Principle 0607/P/15 and 0608/LBC/15

October 2015

Prepared By Ian Ferrel Community Councillor Joint Planning Officer DCC PPP/01/10/2015 Issue 2

Objection to PPP 0607/P/15 and 0608/LBC/15

Dechmont Community Council (DCC) have always recognised and supported the need for the development of Bangour Village Hospital to allow this “Jewel in the Crown” of West Lothian to be returned to its former glory. To make this a financial possibility DCC have understood that a number of new houses would be required. One major benefit from this development for Dechmont would be the upgrading of the current Infant School to a full Primary School.

DCC have used the same criteria below to review any proposal for the site over the last 25 years during which the NHS have been trying to develop this site.

x Impact of number of Houses x Location of Primary School x Impact on Character of development both in Bangour and Dechmont x Traffic impact on surrounding roads x Local infrastructure

DCC fully understand that at this stage of the planning process the fine detail of the proposed development is not required. However it is very obvious that even the basic information to allow a decision to be made even in principle is missing.

Number of Houses

The Planning Statement (August 2015) does not even state the total number of units being proposed. Section 4.4 quoted 800 new dwellings plus an additional undisclosed number from buildings being either converted or demolished. DCC would take from the traffic assessment report NHS are planning for at least an additional 200 units. This would result in the excess of 1000 units.

If you also take into account the development currently under review for the East of Dechmont and also the proposed development by the Walker Group for Burnhouse Farm this could easily result in over 1240+ new houses for Dechmont. This would result in Dechmont being expanded by over 400%. This would have a major impact on the character of Dechmont. A number of people have moved into Dechmont or have relocated within Dechmont due to its village character.

A review of the number of units must take place for the whole area and not just for individual developments in Dechmont. DCC agree with the objection lodged by the Walker Group that the whole character of Bangour would be changed by allowing 1000+ units to be built. The semi-rural character which is the major feature of Bangour would be lost due to the high density of units that would be required to obtain 1000+ houses. The proposed Local Plan only quotes 550 house for this site. In addition the Planning Statement submitted by NHS goes into great detail to state the requirement for an additional 24,000 or so houses is required in West Lothian. Nowhere the statement does not prove the site could handle their proposed 1000+ houses. DCC would also like to see stated in this application the density and type of units proposed along with information on affordable housing.

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DCC PPP/01/10/2015 Issue 2

Location of Primary School

Since the proposal is to shut Dechmont Infant School and relocate it into the new Primary School, the location of the new Primary School must service the new development of Bangour along with the current village of Dechmont including the proposed development to the East of Dechmont.

Also there is a possibility that the existing Dechmont Village Hall may shut since the Education Department may state the new community Primary School can service as the Village Hall for both Dechmont and Bangour saving costs on two halls.

It is therefore extremely important that the location of the Primary School can be located in the middle of the whole area that it is intended to service. This would allow the Primary School to act as a focus point to join the two communities rather than a point of resentment. The most sensible allocation would be the option nearest to Dechmont and the Main Street. A very short pedestrian access could be located through the wooded area on the Main Street which would be directly opposite houses in Dechmont for safety reasons. This position would remove issues with the other proposed sites which would require pupils to walk alongside the busy A89 or for some considerable distance between a wooded area and the burn to houses within Dechmont.

Previously the Education Department suggested locating the Primary School on the Cricket Pitch. DCC feel that this would mean the loss of a significant asset and character of Bangor. Consideration will also be required to ensure the new suds areas within the site are child safe.

Impact on Character of development both in Bangour and Dechmont

As previously discussed the high density of the proposed 1000+ units will have a major impact on the whole character of Bangour. The loss of so many of the listed buildings due to mismanagement by the NHS will also seriously impact on the character. Care must be taken to ensure the replacement units sited on the footprint of listed building are in character with the existing buildings. The Cricket Pitch should be set aside as a recreation area with no building allowed.

The addition of some 1,000sqM for shops/etc. will just add to the already high density housing required to achieve 1000+ units. Care must be taken to ensure the site retains its open spacious feel.

With only 100 units planned per year to be built. This will result in the site being developed over a 10 year period a detailed plan should be required as part of this PPP application to ensure the site is developed in a staged manner without impacting on the residents of the area. How many houses will be built before the new Primary School is open? How many shops will be up and running before the end of the 10 years?

The loss of the Dechmont Infant School and the possible closure of the Village Hall will have an impact on a major part of Dechmont. West Lothian Council Education department need to discuss what plans they will have for these buildings.

Dechmont for the past 40 years has only seen limited development with only about 15 or so houses being built. If all three developments are allowed to take place. The village will effectively increase by over 400%. This will completely change the whole character of Dechmont. From a small village of around 300 houses with some 750 people (based on 2.5 people per house) to a large village of 1540+ houses with over 3,850 people an increase of some 3,100 people.

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DCC PPP/01/10/2015 Issue 2

There will be some residents of Dechmont who must feel the development of Bangour and the saving of the two “A” List buildings is not worth the impact it will have on their surroundings.

A Woodland Trust should be set up to manage the woods around Bangour. This should be a requirement of this PPP approval before any development is undertaken and not left to be set up until after the site is developed, when a large number of trees could have been removed.

Little consideration would appear to have been given for other uses of the site other than housing.

The application for demolition of unlisted buildings in Bangour 0608/LBC/15 should not be considered separately but should be considered as part of application 0607/P/15 due to the impact on the whole site.

Traffic impact on surrounding roads

A separate report has been produced by DCC to cover Traffic Impact due to the large number of errors within the NHS Traffic Assessment. DCC believe the conclusion in the NHS Traffic Assessment of no significant impact is wrong.

The report by DCC proves there will be a significant impact on the surrounding area due to the increased traffic from Bangour.

Dechmont already has issues with the current traffic and major changes will be required even to accommodate any small additional increase let alone the major additional traffic from 1000+ units.

Local Infrastructure

Schools

The Planning Statement does not appear to have a section on Education Assessment. Major issues already exist with education capacity with the Roman Catholic Primary /Secondary School for the area.

1000NHS 120East Dechmont 120Walker Total Primary 0.3156 316 38 38 392 RC Primary 0.0927 92 12 12 116 Secondary 0.1706 170 21 21 212 RC Secondary 0.0597 60 8 8 76

Both the RC Primary and RC Secondary are close or over their capacity at present in 2015

These figures above only take into account the possible development within the Dechmont area. With major developments planned within the catchment areas for Broxburn and Livingston these figures will only make the situation more critical.

Just looking at the additional buses required would mean possibly 3 buses going to St Nicholas, 5 buses going to Broxburn and 3 buses going to St Margaret's. A total of around 11 buses to take the pupils from Dechmont to their schools.

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DCC PPP/01/10/2015 Issue 2

GPs

At present the Strathbrock Health Center GP’s are not able to cope with the current pressure due to the extra houses built over the last few years in the area. The added extra 3,000 people will only add to this problem.

One GP surgery has introduced a phone call back from the doctor to try to cope instead of appointments.

Dentists

Appointment waiting times are constantly growing due to workload.

Sewage

NHS Flood Risk Plan even states the Newbridge Sewage Treatment Works has less than 10 housing units available spare capacity. Interestingly NHS gloss over this point and state it would be covered in the design stage of the development later.

Surely NHS have to prove the infrastructure can cope with this PPP application or at least plans will be in place to deal with the additional pressure before West Lothian Council can make a decision.

Conclusions

x Too many houses for the area to cope with. x Significant loss of character to Bangour with over density. x NHS Traffic assessment major problems. Total wrong conclusion. x Major impact on Dechmont being expanded by over 400% x Developments in Dechmont need to be considered as part of this development at Bangour. x Only one sensible site for new Primary School. x Insufficient reports supplied to allow a decision to be made by West Lothian Council.

In light of the proposed new flight path from Edinburgh Airport consideration should also be given if this development should be allowed given it will be within the new TUTUR route. The Government states the number of people which are affected by noise from living underneath a flight path should be reduced. This development would only add to the number not reduce it.

DCC reserves the right to make further comment on applications 068/LBC/15 and 060/P/15 as and when further detailed information is provided.

Ian Ferrel

Joint Planning Officer

Dechmont Community Council

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Bangour Objection 0608/LBC/15 | Conservation Area Consent for the demolition of unlisted buildings in Bangour Village Conservation Area Firstly, we would remind the Planning Authority that they have a duty to pay special attention to the desirability of preserving or enhancing the character and appearance of the area when exercising their powers under the planning legislation. PAN71 states; For significant applications within conservation areas, local authorities should encourage applicants to submit design statements based on conservation area appraisals. The application documents do not contain any such appraisal and furthermore the Planning Statement makes reference to a Heritage Statement yet to be submitted. Further comment on this application should therefore be permitted as and when this information is made available. As stated in Scottish Historic Environment Policy 2011, where demolition is to be followed by re-development of the site, consent to demolish should in general be given only where there are acceptable proposals for the new building. In this case, the consideration of the application to demolish 22 unlisted buildings within the CA should not be considered separately from proposals for new building. Unfortunately, the corresponding application, 0607/P/15, is for permission in principle and a planning application for the demolition of selected listed buildings has yet to be lodged. We therefore reserve the right to make further comment on this and the corresponding applications in respect of proposals at Bangour Village Hospital, Dechmont. 0607/P/15 | Planning permission in principle for a residential and mixed use development (with Environmental Impact Assessment) at former Bangour Village Hospital The application is for permission in principle although the figure of approximately 800 houses (at a density of approximately 12-15 per acre) is quoted throughout the supporting documents. This is considerably in excess of the figures permitted in the adopted Local Plan (500 houses) or the recently published proposed Local Development Plan (550). The development of circa 800 houses would therefore be contrary to the adopted and emerging development plans. The Design Statement identifies circa 70 acres gross of development land for housing which would be netted down by approximately 10% leaving a nett developable acreage of 63 acres which is only capable of delivering approximately 630 houses at an average density of 10/ac or 25/ha. The development of housing at densities higher than this would be incompatible with the semi rural character of the site and would be likely to have an impact upon the setting of those listed buildings which are retained. Walker Group consider that the site cannot accommodate more than 600 houses without compromising density policies and impacting upon the setting and character of the site. The Design Statement and Environmental Statements both make reference to a Planning Statement, however, there is no Planning Statement document available on the Council’s web site and for this reason we reserve the right to submit further comments as and when this document is made available. In the absence of any supporting planning argument to justify a departure from the adopted and emerging development plans the Walker Group questions the granting of a permission in principle which seeks consent for up to 800 units. The application contains no detailed assessment of education requirements or how the development of the site will be carried out having regard to existing education capacity, current school rolls and other development opportunities such as Burnhouse Farm (120 units) identified in the proposed LDP. However, it is noted that the Transport Assessment assumes a twin-tracked primary school with estimated capacity of circa 420 pupils. A new school of circa 420 capacity would be capable of accommodating 1500 houses at the current child product rate of 0.28 for non denominational schools. A single stream NDPS of 220 capacity would support a total of 785 houses. The Walker Group consider that this application cannot be determined independent from the consideration of the Burnhouse Farm site or in the absence of a detailed education proposal including the scale and capacity of the proposed primary school illustrated for development within the Bangour site. The development of the Burnhouse Farm site at circa 120 units, as supported in the LDP, along with the development of the Bangour Hospital site at circa 600-630, would together support the development of a new non-denominational primary school. For the reasons set out above, the Walker Group reserves the right to make further comment on applications 0608/LBC/15 and 0607/P/15 as and when further detailed information is provided.

Additional objections: In response to the Planning Statement we would challenge the suggestion that the site can accommodate 800 residential units. The net developable area of 70 acres includes land required for key frontages and open space. The MasterPlan Plot Boundaries contained within the Design Statement (pg103) is closer to a net developable area which would be closer to 63 acres (a 10% reduction to achieve a true net developable area). At 63 acres the site cannot achieve 800 units at an appropriate density. This is a semi-rural location within a Conservation Area containing Listed Buildings. Densities of 12-15/acre, as suggested, as not appropriate in this location. At a standard residential density of 10/ac the site can accommodate circa 630 units. The Planning Statement claims that density is not a matter for the PiP, however we would argue that to make an unsubstantiated claim that the site is capable of accommodating 800 houses makes density an issue for this PiP. WG maintain that, having regard to advice in SHEP 2011, which states; “where demolition is to be followed by re-development of the site, consent to demolish should in general be given only where there are acceptable proposals for the new building”, it is inappropriate to consider this application in principle without a Listed Building application for the demolition of the listed buildings. Furthemore, as and when the Council come to consider the application for the demolition of the Listed Buildings it will be inappropriate to consider this without detailed proposals for new development. The PiP does not contain the requisite details to allow consideration of the demolition of the listed buildings. The SHEP 2011 is quite clear at para 3.34, that “It is not possible to seek or be given outline listed building consent”. The proposal is not in conformity with the West Lothian Local Plan. Furthermore, we argue that notwithstanding the acknowledged housing land shortfall and the requirement for additional housing to meet the shortfall, the over development of the Bangour Village Hospital should not be supported simply to achieve this. Indeed, SESPlan states in respect of West Lothian at para 93; “new allocations could be directed towards existing committed developments if it can be demonstrated that they can contribute towards the housing requirement within the specified time periods.” Contrary to SHEP 2011 guidance the applicants have not made a case, within the documents available on the web site prior to the period of comments expiring, that the demolition of listed buildings, which are identified, albeit are not part of this PiP, are justified as “not economically viable and that it has been marketed at a price reflecting its location and condition to potential restoring purchasers for a reasonable period”. As determination of this PiP presumes the demolition of listed buildings, the PiP cannot be supported or justified as complying with Scottish Government policy. The Planning Statement has been overtaken by events in that the West Lothian Local Development Plan was approved for consultation by the Council Executive on 15 September 2015 and will be the subject of statutory consultation within a few weeks. Notwithstanding the applicants Agents making a case for increased capacity in response to the MIR, The proposed LDP represents the Council's settled view as to what the final adopted content of the plan should be. The LDP will form part of the development plan once approved however, until then it will be a material consideration in planning decisions. In this respect, the proposal for circa 800 houses is contrary to the proposed LDP which allocates the site for 550. It is argued by the applicants that increasing the capacity of the site to 800 will contribute towards the housing land shortfall, however we would point out that the site is currently constrained and non-effective for reasons of Physical/Infrastructure/Marketability/No consent, within the current Housing Land Audit therefore the development of the site at 500 or 550 will result in a contribution towards the shortfall. The Planning Statement relies on a Heritage Statement as justification for the demolition of most of the unlisted buildings within the CA, however we have not been able to inspect said Heritage Statement within the period for comments. For this reason, we reserve the right to make further comment as and when additional material is lodged in respect of this application. The Planning Statement does not address the education matters.

Graeme A Patrick

Strategic Land Director

Walker Group (Scotland) Ltd

Westerwood House

Royston Road

Deans Industrial Estate

LIVINGSTON

West Lothian

EH54 8AH

Comments for Planning Application LIVE/0608/LBC/15

Application Summary Application Number: LIVE/0608/LBC/15 Address: Land at former Bangour Village Hospital, Dechmont Proposal: Conservation Area Consent for the demolition of unlisted buildings in Bangour Village Conservation Area (grid ref. 303063 670901) Case Officer: Ross Burton

Customer Details Name: Mr Scott Deuchars Address: 2 Limefield Road Polbeth

Comment Details Commenter Type: Other Stance: Customer objects to the Planning Application Comment Reasons: Comment:I remember driving through Bangour village on my way to the old hospital as a child and still enjoy a walk with my dog through the now abandoned village. I'm all for developing the site but feel that it would be a great shame to lose many of these buildings just because it is easier and cheaper to demolish them instead of redeveloping them. Just because the buildings are not listed does not stop them from being impressive part of the landscape of the buildings and would prefer as many of the existing buildings to be saved as part of the new development.