Authority Response to Contributor Comments (28-03-2013)
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Run Date: 28/03/2013 `Authority Response to Contributions by Contributor for FLDP_MAIN 00835 Agnew Mark Comments: 7 Vision The Vision lacks a suitable level of specification against which the overall success of the plan can be readily assessed, and should make reference to 'development targets' such as house completion targets. As the pursuit of a medium growth scenario lacks ambition and will not create the right balance of opportunities to allow the Council area to prosper, the high growth scenario should be pursued. Council response: The Proposed Plan contains very specific housing targets and a monitoring framework. The housing target is an ambitious one given the current low level of housebuilding and uncertain market conditions for the foreseeable future. Main Issue 1: Housing Growth The plan should aim for a higher and more ambitious housing growth level. A key component in the overall recovery of the housing market will be ready access to a sufficient level of unconstrained sites. Pursuing a 'high growth' scenario would not result in the need for major growth areas, and promotion of a wide range of small to medium sites could be successfully integrated into existing communities. Council response: The proposed rate of housing growth has been scaled down slightly to 675 units per annum in the light of revised household projections which would not justify a high growth scenario. The allocated sites, both existing and new, offer sufficient scale and flexibility of supply to meet the housing targets, subject to an upturn in market conditions. Main Issue 2: Sustainable Housing Locations Additional housing required to support the high growth scenario should be split on a proportional basis across the list of settlements detailed in Figure 3.4 of the MIR. Council response: The high growth option is not supported, and would be not be in line with the most recent household projections on which the Proposed Plan is based. Main Issue 3: Housing Need The adoption of a flexible and realistic approach to the provision of affordable housing is key to development viability, and the Council should pay full regard to the Chief Planner's letter of 15 March 2011 when finalising policy. Council response: SG supporting Proposed Plan policy HSG Affordable Housing adopts a flexible approach to provision. Main Issue 4: Infrastructure for Growth Specific reference to the policy tests of Circular 1/2010 should be made in bringing forward policy on developer contributions. Council response: Proposed Plan policy INF2 and related SG concerned with developer contributions highlight need for S75s to comply with the provisions of Circular 3/2012. SHIE/B Shieldhill Potential New Sites The allocation of the site at Hillcrest Farm, Shieldhill (SHIE/B/02) is supported, but it is noted that the boundary shown in previous submission was inaccurate. Council response: The boundary has been amended in line with the original submission. SHIE/B Shieldhill Potential New Sites 242 standard letters submitted expressing support for the allocation of the Hillcrest site (SHIE/B/02). The site would be a modest eastern expansion to Shieldhill, in an area where a precedent for housing has already been established. Shieldhill and Reddingmuirhead would benefit from the housing, there would be no adverse impact on the existing houses, and the local school can cope with the additional children. Council response: The site has been identified as a housing proposal in the Proposed Plan. 00840 Airth Resident Comments: 1 Main Issue 2: Sustainable Housing Locations Airth resident believes housing growth in Airth should be limited to consolidating existing commitments and gap sites, which alone account for 160 units. Airth has significant infrastructure and environmental constraints which make it difficult to support further housing growth. Catchment schools are at capacity, drainage is resitricted and existing traffic and parking problems would be exacerbated by more housing. Further growth will lead to loss of identity and community fragmentation. Council response: The Proposed Plan supports modest growth in Rural North, in line with the MIR. Section 5 of Technical Report 3 provides the rationale for the level of growth considered suitable and the choice of sites in each of the settlement areas. In Rural North the focus of growth remains the existing sites at Airth, augmented by an additional site at the north end of the village, and existing sites at Torwood. The modest growth strategy takes account of environmental and infrastructure constraints across the area, in particular noting that waste water infrastructure improvements are programmed by Scottish Water and capacity pressures at Airth primary school have eased. 00892 Alex and Mae Ritchie Comments: 1 MUR/B Muirhouses Potential New Sites Objection is made to the proposed development at Muirhouses (MUR/B/02) on the basis of loss of further greenfield sites, the traffic situation in Muirhouses which will be made worse, and the impact on trees on the east side of Carriden Brae. Page 1 of 117 Run Date: 28/03/2013 `Authority Response to Contributions by Contributor for FLDP_MAIN Council response: The site has not been identified as a housing proposal in the Proposed Plan. Further assessment suggests that there will be substantial impacts on trees and hedgerows which would have an adverse impact on the setting of the village and Carriden Estate. Public consultation has raised concerns about traffic issues on Carriden Brae. 00860 Allison Wilf Comments: 7 Vision The preferred vision is considered to be over-optimistic and based on trends during growth period. Housing requirements are likely to reduce during the Plan period. The focus for housing should be on the regeneration of empty homes and brownfield sites which represents a more sustainable form of development and which would strengthen existing communities. Preference is for the second alternative vision to retain the `status quo'. Council response: The housing target for the Proposed Plan has been scaled back from that in the MIR in the light of revised household projections. There is a strong focus on the redevelopment of brownfield land, although a number of greenfield sites are included to ensure flexibility and choice in the supply. SPP emphasises the need to provide a generous supply of land for housing. Main Issue 1: Housing Growth The preferred option of medium growth is too optimistic and a low growth scenario should be pursued, focusing on regeneration and developing existing identified sites. Most of the housing requirement to 2024 could be met from existing allocations through the `low growth' option. There is a need to define and justify `flexibility allowance', which is any case is considered inappropriate given the optimistic household projections. The flexibility allowance is unquantified and too high, and this together with the absence of windfall and small sites in the housing calculations, means the Plan is at risk of over- supplying housing land to the detriment of regeneration, sustainable housing locations and the consolidation of existing communities. Council response: The proposed rate of housing growth has been scaled down slightly to 675 units per annum in the light of revised household projections. However, in accordance with Scottish Planning Policy, the Council is required to provide a generous supply of housing land, and to build a degree of flexibility into the supply. Some additional sites are required to meet requirements and to provide this flexibility. Main Issue 2: Sustainable Housing Locations, Rural South The option for modest settlement expansion in the Rural South is not supported and a strategy of consolidation should be adopted, relying on existing allocations. There has been no commensurate increase or improvements in infrastructure or services in Shieldhill despite its growth over the last 25-30 years, and there is an issue with the provision of public open space. The 'Low Growth' option is more realistic and should be pursued. Council response: The amount of additional land allocated for housing in the Rural South through the Proposed Plan (over and above existing committed sites) is only 70 units, which is not considered excessive. SHIE/B Shieldhill Potential New Sites Objection is made to the site at Hillcrest, Shieldhill (SHIE/B/02).Pursuing a strategy of consolidation, regeneration and low growth would do away with the need to release site SHIE/B/02. Proposals for housing development have been the subject of refusals of planning consent, and development of the site would erode the countryside/wildlife habitat and lead to settlement coalescence. There are also infrastructure limitations. Council response: The site is identified as a housing proposal in the Proposed Plan, and is conceived as a consolidation of existing development at Hillcrest/Tappernail Farm. Although concerns are noted, the capacity would be restricted to 30 units, and subject to careful site planning to mitigate landscape impact. Capacity exists in the local primary school. The site offers opportunities to improve and manage habitats as a contribution to the local green network. SHIE/B Shieldhill Potential New Sites Objection is made to housing at Belmont Avenue, Shieldhill (SHIE/B/01). Council response: The site is not identified as a housing proposal in the Proposed Plan. It is designated as open space and is subject to the green network Proposal GN16, which seeks to improve the landscape setting of the Lower Braes villages. SHIE/B Shieldhill Potential New Sites Objection is made to housing at Burnhead Farm, Shieldhill (SHIE/B/03). Council response: The site has not been identified as a housing proposal in the Proposed Plan. SHIE/B Shieldhill Potential New Sites Objection is made to housing at Greenwells Farm, Shieldhill (SHIE/B/04) Council response: The site is not identified as a housing proposal in the Proposed Plan. 00991 Anderson J M Comments: 1 POL/B Polmont Potential New Sites Objection is made to the identification of the site at Middlerigg Farm (POL/B/05) as a preferred housing site.