Submissions on Behalf Of

Submissions On Behalf of:

A & J STEPHEN AND BETT HOMES LTD.

. LAND NORTH OF LIFF HOSPITAL;

. LAND SOUTH OF BIRKHILL

ANGUS LOCAL DEVELOPMENT PLAN

MAIN ISSUES REPORT

Submission on behalf of A&J Stephen Ltd and Bett Homes Ltd (part of the Gladedale Group)

BIRKHILL SOUTH & LIFF HOSPITAL NORTH

James Lochhead MRTPI Development & Planning Consultant

Introduction

A&J Stephen Ltd and Bett Homes Ltd (part of the Gladedale Group) have constructed many houses in Angus and in the Dundee area. Both companies wish to work with Angus Council to deliver their vision of ‘Angus is a place where a first class quality of life can be enjoyed by all’.

However, both companies are also extremely concerned that land to the south of Birkhill and to the north of Liff Hospital has not been considered for development. It is considered that these omissions raise very grave concerns that the spatial strategy of the approved TAYplan will not be delivered.

Consequently, this submission aims to consider Question 1 of the Main Issues Report (MIR) which states:

“Q1 Do you support the preferred options for the LDP spatial strategy and its implications...”

A&J Stephen Ltd and Bett Homes Ltd disagree with the settlement strategy shown in Diagram 3 due to the omission of land to the south of Birkhill and to the north of Liff Hospital.

Strategic Context

Recently approved by Scottish Ministers the TAYplan represents the up to date strategic guidance for Dundee, Angus, Perth and Kinross and north Fife. It is the starting point for any decisions on future land allocations to be made by Angus Council.

Policy 1 of TAYplan seeks to focus the majority of development in the regions principal settlements by identifying a hierarchy of settlements. There are three tiers of settlements. Tier 1 settlements have the potential to accommodate the majority of the region’s additional development such as the Dundee Core.

The Dundee Core is defined as Dundee City, Dundee Western Gateway, Invergowrie, Monifieth, Tayport/Newport/Wormit and Birkhill/Muirhead.

Not only is Birkhill specifically identified as a settlement within the Dundee Core but the land promoted by Stephen/Bett is also within the Dundee Western Gateway, as is Liff Hospital North.

The policy goes on to state that land release will be prioritised based on the sequential approach i.e.

First – land within the principal settlements;

Second – land on the edge of the principal settlements;

Third – where the first and second requirements cannot be met other settlements can be considered for development.

Birkhill should, along with the other settlements that make up the Dundee Core, be the first port of call when considering new land releases. There are few, if any, brownfield sites within the settlement that would be considered financially viable and suitable for housing development. Consequently land on the edge of the settlement must be considered before considering any other location or indeed any of the settlements identified in Tiers 2 and 3.

Angus Local Development Plan

The Angus Main Issues Report (MIR) states at para 3.14 that it will “maintain a development strategy for the edge of Dundee which is consistent with the approach of the emerging Dundee Local Development Plan and the TAYplan’s overall requirement to ensure that land within settlements, and in particular previously developed land and buildings, is prioritised. This means that development sites within the existing boundaries of Monifieth and

Birkhill/Muirhead will be prioritised and that, as suggested for Dundee itself (through Dundee City Council’s Main Issues Report), there ought to be limited greenfield releases in and around the Dundee Core Area.”

The MIR suggests that within Angus part of the Dundee Core Area there are “relatively few opportunities for new development.” Consequently, the MIR directs the majority of new development to Arbroath, Forfar and Montrose and thereafter to Brechin, Carnoustie and Kirriemuir. The MIR argues that because Monifieth has similar characteristics to Carnoustie in terms of services and facilities (schools, health care, shops and services) there may be scope for limited new development in the town.

For the remainder of the land within the Dundee Core Area (i.e. Birkhill) the strategy is to avoid conflicts with the emerging Dundee Local Development Plan by not making any new land allocations in this area.

Discussion

For Angus Council to dismiss out of hand any new development an opportunity at Birkhill or Liff Hospital North is contrary to the strategic advice of the TAYplan. If this strategy continues within the Proposed Plan, A&J Stephen Ltd and Bett Homes Ltd firmly believe that there are very strong grounds for making an objection on the grounds of non-conformity with the TAYplan. Furthermore land at Monifieth has now been identified for development on the east side of the city. This is the exact opposite of the whole concept of promoting development to the west of the city which has been established planning policy for almost 20 years.

It is of note that Policy 5 of the TAYplan states that there is a “presumption against land releases in areas surrounding the Dundee and Perth Core Areas, including the Carse of Gowrie, where it would prejudice the delivery of the Strategic Development Areas or regeneration within the Core Areas or conflict with other parts of the Plan.” Birkhill South and Liff Hospital North are both within the Dundee Western Gateway Strategic Development Area and Birkhill is a named settlement in its own right. Angus Council have misdirected themselves and failed to understand the strategic guidance provided by TAYplan.

It is quite simply unacceptable to prepare options that are “consistent with the approach of the emerging Dundee LDP” (para 3.14). It is the TAYplan that the Angus LDP must be consistent with, not the Dundee LDP. This is a fundamental error of the current spatial strategy put forward by Angus Council.

New housing should be directed to locations with an acknowledged demand for housing. The chosen settlement strategy is fundamentally flawed by not including development opportunities to the south of Birkhill and to the north of Liff Hospital in accordance with the established and approved guidance contained within TAYplan. By directing growth to the more tertiary settlements that are presently, and will undoubtedly in the future, remain unmarketable with sales rates that are notoriously slow will not in any way meet the aspiration and vision of the Council.

Birkhill South and Liff Hospital North are located on the periphery of Dundee and therefore directly benefits from influences of the Dundee Housing Market. Such sites should be identified for housing to meet the housing demand where there is a known and proven requirement for housing. If the alternative housing growth strategy is to allocate housing in locations where there is limited or historically slow housing demand then the robustness of the new LDP comes into question along with the ability to meet the housing requirements of the TAYplan.

One of the main aims of the Scottish Government is to encourage housing growth in the right locations and to ensure the new Development Plans endorse viable and responsive housing growth strategies. The options presented in the MIR fail in this regard.

The options presented in the MIR for the South Angus Housing Market Area are extremely limited. It is proposed (at this stage) that only 5 new housing sites are added to the existing supply – one in Carnoustie, one in Monifieth and three relatively small sites in Newtyle. Guidance contained in TAYplan is that the Angus LDP should be aiming to ensure viable and effective housing sites are made available to allow 80 houses per annum to be constructed. Restricting the supply of new sites to only three settlements is very unlikely to meet the TAYplan requirements or indeed the Government’s desire to see a ‘generous’ supply of housing land. This reinforces the need for further additional land to be allocated at Birkhill South and Liff Hospital North. Furthermore, the justification for allocating three sites at Newtyle, 8 miles from Dundee, yet ignoring the role of Birkhill and Liff Hospital must be severely questioned.

Proposed Sites

Birkhill South represents a logical extension to the village. Numerous facilities already exist on the south side of the settlement and the proposed development would consolidate and enhance these assets. The site is well contained and offers an obvious opportunity for approximately 360 houses on some 14 hectares. Visually the site is also well contained on its eastern and western boundaries by mature woodland and to the south by rising ground. The northern boundary is characterised by the residential southern edge of the village.

Liff Hospital North, like Birkhill South is located within the Strategic Development Area known as the Dundee Western Gateway and represents an ideal opportunity to consolidate and enhance the redevelopment of the former hospital and adjoining development sites that have already been identified. The northern boundary of the site respects the Reporter’s recommendation into the Dundee Local Plan in the early 1990’s.

Both sites are in control of recognised house builders with a proven track record of delivering high quality residential developments and both sites should be included in the forthcoming Proposed Development Plan for Angus. Site plans are included in this submission.