Garioch Settlements AHMA
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ABERDEENSHIRE LOCAL DEVELOPMENT PLAN FINALISED RESPONSE TO PROPOSED PLAN CONSULTATION GARIOCH – ABERDEEN HOUSING MARKET AREA Issue 74 Settlement - Keithhall Section 6 Proposals maps Garioch (p22) Reporter: Schedule 1 Table 5 (p27) Development plan Schedule 2 Table 5 (p32) reference: Volume 3I Supplementary Guidance, Settlement Statements Garioch 2010 (p29) Body or person(s) submitting a representation raising the issue (including reference number): 444, 496 William Lippe Architects Ltd on behalf of MTM Holdings 849, 852 Knight Frank LLP on behalf of Tor Ecosse Ltd 1175, 1176, 1177, 1179 DPP LLP (Planning Consultants) on behalf of Church of Scotland General Treasurer Provision of the development plan to Land allocations in and around Keithhall which the issue relates: Planning Authority’s summary of the representation(s): H1 Keithhall Support for allocation 1175, 1176, 1177, 1179: Support the allocation of site H1. 1175, 1176: The development of the site represents a logical natural expansion to the established housing area within Keithhall. There are no challenges in terms of the topography and gradient of the site, and it would reflect the pattern of development in the surrounding area. The site has excellent pedestrian and vehicular access with the required upgrading and maintenance also envisaged. 1175, 1176: The site is capable of accommodating development with no adverse visual impact and would not detract from the existing area. The proposed development would be in line with development and design principles within Planning Advice Note 44 ‘Fitting New Housing Development into the Countryside’. Developing the site will result in a sustainable and high quality development. 1175, 1176: The site is both available and deliverable. It is also suitable due to part of the site being allocated as an ‘Area of Future Housing Land’ suitable for five housing units in the current Local Plan. 1176: The proposed development will be designed having regard to the scale, colour, form and density of existing residential developments in the surrounding area, and will incorporate design features which will help create a sense of place and identity while meeting sustainability and energy efficiency demands. Development of the site will help to sustain and support local facilities and the local community. Level of development and density 444, 496, 849, 852: The 15 houses proposed represent over-development and is considered inappropriate, as the density of housing is not in keeping with the existing characteristics of the settlement. A 100% increase within a five year period is not deemed to be small scale. This site is open, exposed and low lying in the west part of the field and goes against guidance provided by Planning Advice Note 72 on how development should fit into or nestle within a landscape, orientation, shelter and screening. Drainage and flooding 444, 496, 849, 852: There is a history of drainage issues related to the existing houses at Keithhall. The Scottish Environmental Protection Agency has identified that there is a potential flood risk associated with the site due to a watercourse running through it. To mitigate this flood risk there is significant cost involved and these resources would be of better use for other community benefits. This and the poor ground conditions of the site render the Page 1 site unsuitable for development. Deliverability 444, 496, 849, 852: The site is constrained due to the landowners being unwilling sellers and there is a large risk it will not come forward for development through the Local Development Plan, due to the landowner not putting forward part of the site when there was a “call for sites”. This was the case with the current Local Plan where the site was allocated for five houses but was never brought forward by the landowner. If the allocated site lies dormant again, the settlement will be unable to maintain the local school roll and bring affordable housing to the area. Designed landscape and ancient monument 849, 852: The site is unsuitable for development as it lies in close proximity to a Historic Landscape and a Scheduled Ancient Monument. Development at this site will therefore require an extremely high standard of design and very careful siting which means that the allocation of 15 units may be too high and may not be feasible. Alternative Site Keithhall 1176, 1177, 1179: Objection to not allocating the site to the North of Keithhall, part of G29 in the Main Issues Report. Keithhall is an appropriate location for accommodating new housing, and it can help meet the Structure Plan requirements in terms of need and predicted population growth. The site is in accordance with Scottish Planning Policy, as it supports small scale housing allocations in rural communities that help ensure their viability is maintained; and due to the land being effective or capable of being effective to meet the housing land requirement, it helps ensure a minimum five years effective land supply is maintained. The development of the northern part of G29 represents a logical natural expansion to the established housing area within Keithhall. There are no challenges in terms of the topography and gradient of the site and it would reflect the pattern of development in the surrounding area. The site is accessible to public transport and has excellent pedestrian and vehicular access with the required upgrading and maintenance also envisaged. Development of the site will help to sustain and support local facilities and the local community. Modifications sought by those submitting representations: H1 Keithhall 444, 496: The allocation for H1 Keithhall should be reduced to 5 houses with the remaining 10 from the allocation being relocated to Kinmuck H1. 849, 852: Site H1 should be removed and replaced with Tor Ecosse’s deliverable sites at Kinmuck, which will help maintain the setting of Keithhall as well as deliver new housing and associated community benefits to Kinmuck. Alternative Site Keithhall 1176, 1177, 1179: Include the remaining part of site G29 as shown in the Main Issues Report, which lies to the north of the settlement, for up to 10 houses with scope to be developed throughout the full period of the Proposed Plan. Summary of responses (including reasons) by Planning Authority: Overview Keithhall lies to the east of Inverurie within the Aberdeen Housing Market Area and in the “local growth and diversification area” identified within the Structure Plan. Keithhall primary school has a falling roll and is forecast to be operating at 84% in 2016. Focusing a larger allocation at Keithhall, as opposed to Kinmuck, allows pupils to walk to school. Paragraph 94 of Scottish Planning Policy states that development plans should support more opportunities for small scale housing development in rural areas including extensions to existing clusters and groups. Therefore, the allocation at Keithhall is consistent with Scottish Planning Policy. Page 2 Site H1 Support for allocation The support for development of site H1 is noted. Level of development and density The level of development proposed takes into account existing service and infrastructure capacities, deliverability and local needs. The site proposed is a compact site with existing development to the north and west and is well related to the core of the existing settlement and close to the primary school. No further allocations are made in phase 2, limiting impact on the character of the settlement while still providing a viable site. Once the sites at Kinmuck and Keithhall are developed there is unlikely to be capacity for substantially more housing and new allocations are likely to be restricted. There is no historic established density within the village, and whilst the density proposed may not be similar to the housing development to the north it would not be out of keeping. The density would equate to approximately 17 houses per hectare when taking into account the 40% open space requirement. This is well below the density of 30 houses per hectare expected within SG Housing1: Housing land allocations 2007-2016 and is more reflective of the rural location. Drainage and flooding There appear to be no significant issues with ground conditions that could not be addressed at the detailed planning stages. Scottish Environment Protection Agency have identified that there is a small watercourse within the site that may be a flood risk. Given the size of the site and the open space requirements there is scope for mitigation and inclusion of a buffer strip along the watercourse edge. Appropriate text has been added to the supplementary guidance in respect of requirement for a flood risk assessment. Deliverability The bid submitted covered a larger area and also included a site to the north of Keithhall. Therefore, the entire H1 falls within the bid submitted by the landowner. The landowner has indicated an intention to bring the site forward and has confirmed deliverability. Designed landscape and ancient monument The site is not within the Keith Hall designed landscape and this designation ends on the opposite side of the road to the site. The impact on the designed landscape is mitigated by existing development within the designed landscape opposite the site H1. Historic Scotland advised at the main issues stage that some low key development could be absorbed without significant impact on the garden and designed landscape. Alternative site - Northern part of G29 This site was fully debated following consultation on the Main Issues Report and following widespread community engagement the Council’s conclusion was to exclude it, as in addition to the H1 site it would lead to over-development, and this site lies within the Keith Hall Garden and Designed Landscape. Conclusion None of the modifications sought are supported. The development strategy and land allocations in Keithhall are appropriate and sufficient to meet the needs of the settlement strategy.