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Main Issues Report Will “Meet Housing Requirements in Appropriate Marketable Locations”

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Appendix 1 MIR Consultation Question Summaries MIR Consultation Question Summaries 51 Issue: MIR question: Aims & Objectives Question 1 Total number of responses on issue 201 Support aims and objectives 129 Do not support aims and objectives 64 Scottish Government, key agencies, and adjoining authorities Scottish Government believes the LDP should make explicit reference to enhancement of Green networks and reference to green networks could be added in to the Objective. “To ensure that the area’s significant international, national and local cultural and natural heritage assets including green networks are protected and conserved, and where appropriate enhanced, including biodiversity, flora and fauna as well as soil, water and air quality.” Welcome that one of the proposed Objectives/ Outcomes is to recognise the important role that town centres and other mixed use areas have in providing services locally. Scottish Water: supports the aims and objectives of the LDP and is committed to ensuring that adequate infrastructure is available to enable development in line with its responsibilities. Internal Consultees: ELC Countryside: Radical industrial developments are proposed which will affect quality of life dramatically. The two ideas for accommodating new house building will not serve the needs of the whole county well. Small housing developments throughout the county particularly providing affordable housing in areas such as Gullane and North Berwick need to go hand in hand with dramatic improvement on the whole counties' accessibility and in particular bus services. Ensure that the area’s significant international, national and local cultural and natural heritage assets are protected and conserved, and where appropriate enhanced, including biodiversity, flora and fauna as well as soil, water and air quality - importance of green networks as dictated by NPF3. National interest groups Royal Society of Protection of Birds (RSPB) commend the aims of sustainable development, including sustainable travel and the aim to minimise greenhouse-gas emissions. Commend the aim and objective to protect and enhance the area’s high quality environment. The report’s recognition of East Lothian’s coastline importance for its wildlife, notably birds is welcomed. The aspiration to improve rail transport, particularly new stations at East Linton and Blindwells is also welcomed. Homes for Scotland: supports the clear plan objective of increasing housing supply, and the recognition given to needing to ensure sites are allocated in marketable locations. This is vital if the plan is to be successfully implemented, shows a proper understanding of the needs of the house- building industry and provides a strong context for emerging policies on housing supply. Network Rail: The rail network within the MIR boundary has clearly been a key consideration in preparing the document’s vision and spatial strategy. This reflects the aspirations of Scottish Planning Policy which places a strong emphasis on sustainable locations for new development, with good access to public transport a key constituent. Network Rail are supportive of this approach provided that due consideration is given to the impacts that new development may have on the existing rail network. Network Rail supports strategies which to promote integrated and sustainable 52 development. It is similarly keen to promote safeguarding and improving the existing and railway network in tandem with new development, and that appropriate contributions are required to effect improvements. National Trust For Scotland: We strongly agree that the development of previously developed land must be the priority. We welcome the minimisation of flood risk and focus on climate change resilience, this must be reflected in only proposing housing sites which are not on floodplains. Scottish Wildlife Trust: We consider that the Aims are about promoting development but do not reflect the need to protect the natural environment. The aim does mention ‘in a sustainable way’ but this needs to be further defined. Similarly the Objective to ‘promote sustainable development ’ outlines measures to promote climate change and limit travel which are all part of sustainable development but there is no clear recognition of the need to protect our natural resources. Landowners, developers and agents APT Planning & Development on behalf of Cruden homes and Cala Management Ltd supports the general aims and objectives of the MIR. APT planning and development on behalf of W.J. Simpson and Son are pleased to support the MIR document in identifying the field at Castlemains Place as a preferred site for future residential development. Inch Cape Offshore Limited (ICOL) generally welcomes the vision, aims, objectives and outcomes of the MIR, set out in Section 4. In the Section under ‘Promote Sustainable Development’ (para.4.3), it is noted that the MIR identifies the need to ‘provide for appropriate renewable energy generation opportunities’. Walker Group (Scotland) Ltd supports the clear plan objective of increasing housing supply, and the recognition given to needing to ensure sites are allocated in marketable locations. Bourne Leisure welcomes the objective of ‘encouraging the diversification of the rural economy by supporting appropriate economic development and tourism’. Viridor fully supports the Aims, Objectives of the MIR. Whithall Lodges support the Vision Aims Objectives and Outcomes in the LDP. Gladman Developments Ltd supports the aims and objectives for the LDP and believes they are clear and set out that East Lothian will provide for the city region and meet housing requirements in appropriate marketable locations. It is key marketable locations are chosen to ensure the housing supply is effective. Additional factors to be considered which would ensure an effective housing supply include: a generosity factor; range of sites by size and location; and small effective in the short term sites. PPCA Ltd on behalf of Wallace Land Investments supports the statement that the Main Issues Report will “meet housing requirements in appropriate marketable locations”. However, the strategy adopted will not deliver this as it does not properly and fully consider all marketable locations. By focusing development in an artificially small western sector of the Council area, and in the face of fundamental and strategic infrastructure constraints as confirmed within the document itself, the Council has not produced a deliverable Main Issues Report that is complaint with the Strategic 53 Development Plan. George F White LLP on behalf of Mr M Steven & Mr D Lockie is in general agreement with the aims and objectives of the MIR. 1.2 In particular an agreement that greenfield land will have to be used in an efficient way to meet the scale of strategic development requirements. Clarification about what an ‘effective use of greenfield land’ is required, regarding the standards which will be applied to meet this criterion. GL Hearn on behalf of the Co-operative Group support the stated aim that the strategy and policies of the East Lothian LDP will contribute to the Edinburgh City Region being a ‘healthier, more prosperous and sustainable place’. Scott Hobbs on behalf of In-site Property Solutions supports the overall preferred strategy of the MIR, with some reservation for which more information is provided in the detailed response to each relevant question. In-Site supports the overall Aims, Objectives and Outcomes proposed in the MIR including the intention to promote sustainable development and to help grow the economy and increase housing supply. Scott Hobs on behalf of Ashfield Land believes SPP seeks to “support economically, environmentally and socially sustainable places”. The protection and enhancement of natural heritage, including green infrastructure, landscape and the wider environment is a further key policy principle. In relation to development plans, the SPP states at paragraph 30 that the spatial strategy of an LDP should be “both sustainable and deliverable, providing confidence to stakeholders that the outcomes can be achieved”. The objectives and outcomes of the MIR should be amended to ensure that they closely reflect the presumption in favour of sustainable development as outlined in SPP and the focus for new development being on sustainable, deliverable locations. Scott Hobbs on behalf of SP Energy Networks believes there are significant plans for offshore wind to the east of the Firths of Forth and Tay. We want developers to work together to minimise the number and impacts of these developments by combining infrastructure where possible. Whilst we have safeguarded Cockenzie as a site for future thermal generation, it may present significant opportunities for renewable energy-related investment. We expect developers, East Lothian Council and the key agencies, including Scottish Enterprise to work together to ensure that best use is made of the existing land and infrastructure in this area. Scott Hobbs on behalf of Queen Margaret University believes the constraints of the local road network, most notably centred on the Old Craighall junction on the A1, are recognised in the MIR. QMU considers this to be a critical issue constraining the future economic development prospects of East Lothian and in particular the delivery of the long-established employment land allocation adjacent to the University at Craighall. Geddes Consulting on behalf of Hamilton & Kinneil Estates, Lothian Park Ltd, Wallace Land Gladys Dales Drylaw Trust and
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