Durievale, Leven Road, Windygates, (Fife Council Site Ref.LDP-WDY001)

Fife Local Development Plan Development Strategy Consultation on behalf of The William Brown Trust February 2014 Clarendon Planning and Development Ltd Exchange Place 2 5 Semple Street Edinburgh EH3 8BL T/F: 0131 306 0115 E: [email protected] W: www.clarendonpd.co.uk

2 Representation to Fife LDP Development Strategy on behalf of The William Brown Trust - February 2014 CONTENTS

4. INTRODUCTION

6. DEVELOPMENT STRATEGY QUESTION 4

10. LANDSCAPE

12. FLOOD RISK

14. ACCESS

16. INDICATIVE DESIGN FRAMEWORK

18. CONCLUSIONS

Representation to Fife LDP Development Strategy on behalf of The William Brown Trust - February 2014 3 Introduction his representation relates to the Fife ending in December 2013. Local Development Plan Development TStrategy Consultation and follows In this context, Windygates is an established previous representations made to both the settlement but outwith a defined Strategic initial ‘Call for Sites’ exercise in 2012 and the Development Area. LDP Main Issues Report in 2013. However, SESplan requires a significant Previous representations outlined the site’s element of the housing requirment to be merits and deliverability in relation to Fife’s met outwith SDA’s in Fife and therefore housing land supply requirement and relative opportunities exist to include suitable sites to the LDP Main Issues Report assessment of within the emerging Local Development Plan competing sites. to contribute to this need.

The current consultation provides the The Development Strategy’s support for Council’s view following the LDP Main Issues Site LDP-WDY-001 (Durievale, Leven Road, Report stage but prior to a Proposed LDP Windygates) as a reasonable alternative being published, which is understood to be in housing site for inclusion within the Summer 2014. Local Development Plan is noted but it is considered that the site merits inclusion as It is understood that this intermediary stage a preferred housing site. has been introduced to provide more detailed information on preferred and alternative sites This submission addresses Consultation and also to address the increase in required Question 4 and the specific points raised housing allocations derived from the South- within the Site Assessment to confirm the East Strategic Development Plan site’s deliverability in the short term and its (SESplan) Supplementary Guidance, a draft of comparative merits in relation to the Council’s which was approved by SESplan committee Site Assessment. in September 2013 with public consultation

4 Representation to Fife LDP Development Strategy on behalf of The William Brown Trust - February 2014 The site’s location on the edge of the Levenmouth urban area and in close proximity to principal routes to Glenrothes and Kirkcaldy (A911 and A915) is demonstrated in Figure 1 with the site boundary depicted in Figure 2.

Fig 1 - Wider Site Location Context Fig 2 - Site Boundary

Representation to Fife LDP Development Strategy on behalf of The William Brown Trust - February 2014 5 Development Strategy Question 4 “Do you agree with the preferred • Burntisland - 40 units (1 site) sites and strategy for the Kirkcaldy/ • Kirkcaldy - 150 units (1 site) Levenmouth area?” • - 400 units (1 site) • Windygates - 120 units (1 site) Part A • Total - 710 units (4 sites) “Does the preferred approach focus development on the right towns in this area? SESplan draft Supplementary Guidance If not, which towns should be chosen?” requires land to be identified for 1,950 units outwith SDA’s in Fife up to 2024. Fife’s Development Strategy identifies preferred housing sites within a number of To meet this requirement, in addition to the settlements within the Kirkcaldy/Levenmouth Kirkcaldy/Levenmouth area, the Development area, with the following indicative housing Strategy identifies preferred sites for 294 units numbers:- within the West Fife Villages and 920 units within the Dunfermline hinterland (excluding • Coaltown of Wemyss - 125 units (1 site) the main town itself). • East Wemyss - 60 units (1 site) • Kirkcaldy - 149 units (2 sites) Overall, this allows for sites with the capacity • Kennoway - 215 units (3 sites) for approximately 1,900 units within ‘preferred • Milton of Balgonie - 25 units (1 site) sites’ to address the SESplan ‘non-SDA’ • Star of Markinch - 20 units (1 site) requirement plus scope for a further 1,300+ • West Wemyss - 54 units (1 site) units within the ‘reasonable alternative’ sites. • Total - 648 units (10 sites) Whilst this is a reasonable allowance to meet strategic requirements, the identified sites will Additionally, further sites are identified be at varying stages of deliverability and it is as ‘reasonable alternatives’, including the considered that sites that can be delivered in following:-

6 Representation to Fife LDP Development Strategy on behalf of The William Brown Trust - February 2014 the short term and are actively being supported Part B by developers should be ranked highest. “Does the preferred approach focus development on the right sites? If not, from Windygates has no preferred housing sites those submitted, which sites should be included within the Development Strategy chosen? and this appears partly due to the proximity of the existing Levenmouth strategic housing The Council’s support of Site LDP-WDY001 allocation (for 1,650 units) on the western - Durievale, Leven Road, Windygates - as a edge of Methil and . However, reasonable alternative housing site (on page given the long term nature and infrastructure 39 of the Development Strategy) is noted but requirements of this site, significantit is considered that sufficient evidence exists completions in the short term are unlikely and for the site to be included as a preferred site other Fife settlements have been supported within the forthcoming Local Development for growth which are in close proximity to Plan. existing, undeveloped major growth areas. When reviewing the Council’s Site Assessment In this respect, it is considered that Windygates, Scoring matrix (within the LDP Main as a reasonably scaled settlement with local Issues Report and summarised within the services including a primary school and good Development Strataegy), it is noted that public transport connections, should have the site is rated positively (+1) for ‘energy’, at least one preferred housing site option to neutral (0) for ‘air pollution & human health’, provide short term completions. ‘settlement’, ‘built heritage’ and ‘biodiversity’ and negatively (-1) for ‘waste’, ‘soils & minerals’ Therefore, the Council’s preferred spatial and ‘landscape’. ‘Water quality & flooding’ is strategy approach for the Kirkcaldy/ rated -2. Levenmouth area in terms of the non- inclusion of Windygates is not supported. Overall, this provides a rating of -4, which compares with the average score of -4.3 for

Representation to Fife LDP Development Strategy on behalf of The William Brown Trust - February 2014 7 ‘reasonable alternative’ sites and -3.3 for settlement along the Kennoway Burn”. ‘preferred sites’. The site was previously the subject of an outline On the basis that ‘waste’ and ‘soil and minerals’ planning application by Barratt (ref.07/02454/ assessment produce a negative assessment COPP) which was refused in 2008 with a for all proposed greenfield sites, the site is subsequent appeal refused in 2009. The main considered to fail the test by virtue of issues factors for refusal at that time were prematurity relating to landscape and, to a greater extent, (with a replacement of the 2004 adopted Local flood risk. Plan being prepared at that time), flood risk and impact on education infrastructure due to This representation focuses on these key the proposed scale (154 units). aspects to support the argument that the site should not be penalised for these The appeal decision letter (ref.PPA/250/807, surmountable factors any more than dated 17th March 2009) provides a detailed competing ‘preferred’ sites within the review of the refusal reasons which is relevant assessment matrix. for determining the site’s suitability at this stage. As the site is the only one considered as a reasonable alternative housing site within Notwithstanding the policy principle / housing Windygates, this supports the view that this land supply situation (which was based on represents the most logical direction of growth a previous Development Plan at that time) for the settlement. which has now altered with a clear need for significant new greenfield housing allocations, As noted within the Site Asssessment, the refererence to flood risk in particular is relevant. previous Local Plan examination highlighted positively that the site is, “well contained It was noted that SEPA had objected to the within the landscape, accessible, close to proposal due to risk of flooding from the the village centre and could round off the Kennoway Burn (along the site’s eastern edge)

8 Representation to Fife LDP Development Strategy on behalf of The William Brown Trust - February 2014 but had conceded that the site may not be of suitable access. The scale of the proposal within the functional flood plain of the Burn can also be reduced from that which was (paragraph 5 of the decision letter, which is promoted via previous representations which attached for reference). The reporter noted that can also address concerns raised within both whilst the possibility of some flooding cannot the Site Assessment and previous Local Plan be ruled out, given that most of the site sits examination. at a higher level than the burn, any flooding would be confined to the site’s eastern edge. The Council’s preferred approach to sites The reporter confirms that in their opinion, for the Kirkcaldy/Levenmouth area in flood risk is not an insurmountable obstacle terms of the non-inclusion of LDP-WDY001 to development (paragraph 6). Durievale, Leven Road, Windygates as a preferred site is not supported. Education capacity remains an issue that will require to be addressed for all new housing sites in the emerging Local Development Plan and is therefore not considered a sufficient reason for exclusion of the site at this stage.

It is therefore considered that the reason for refusal in 2008/09 was primarily policy principle-based and given the distinct change in policy, the site can overcome other issues and be considered a viable site at this time.

As detailed hereafter, it is considered that landscape and flood risk factors can be addressed satisfactorily, along with provision

Representation to Fife LDP Development Strategy on behalf of The William Brown Trust - February 2014 9 Landscape The Site Assessment notes that, whilst the site containment of the Kennoway Burn woodland is “reasonably well contained”, development and existing residential properties to west/ of the site would extend Windygates eastwards north. and change the sense of arrival from the south- east. In particular, the ‘gateway’ position of the Figure 4 depicts the view from the A916 Leven site and visually prominent steep slopes rising Road, just after the roundabout entrance to from the bridge facing roundabout are a factor. Windygates as noted in the Site Assessment. The bowling club is in the foreground with the However, the assessment does note site’s upper level partially visible to the rear. that “sensitive development could be acceptable”. Notwithstanding the site’s defined boundaries, it is considered that mitigation Firstly, it is noted that 4 out of the 10 preferred of development impact on views to the site sites within the Kirkcaldy/Levenmouth area from the eastern entrance can be provided are rated negatively for landscape impact, through appropriate and sensitive site demonstrating that greenfield sites by their design. nature require an element of design mitigation. This is addressed within the indicative As denoted by Figure 2 (page 5) it is contended design framework and seeks to provide a that the site is very well contained in terms of more integrated site layout than that which natural and built boundaries. The land falls formed previous proposals for the site. It from north to south and it is accepted that the should also be noted that the previous upper parts of the site are more sensitive in proposal was not refused on any landscape terms of overall character and setting. impact grounds.

Figure 3 shows the rise in level across the site from the Leven Road / bowling club side in the right of the photo. This image shows the visual

10 Representation to Fife LDP Development Strategy on behalf of The William Brown Trust - February 2014 Fig 3 (above) - View eastwards across site to Kennoway Burn Fig 4 - View northwards over site from south-east approach

Representation to Fife LDP Development Strategy on behalf of The William Brown Trust - February 2014 11 Flood Risk The Council’s Site Assessment rates the site representation to demonstrate how the site negatively under ‘water quality and flooding’, could be designed and developed by pulling noting that a new Flood Risk Assessment back proposed housing and gardens from is required which incorporates the culvert this boundary. beneath Leven Road. Figure 6 shows the eastern site boundary, which As noted on pages 8-9 above, the previous is the area at risk of potential fluvial flooding planning appeal decision letter reviewed the but which can potentially accommodate SUDS flood risk impact on the site and concluded and landscape features to mitigate risk and that the risk was not insurmountable and that provide a transition between the development given site levels, the risk would be associated area and rural boundary. with the site’s eastern edge only. Overall, in line with the opinion of the In this respect, a Flood Risk Assessment was planning appeal reporter and the SEPA undertaken at the time of the previous planning flood risk map, it is considered that application (2007/08) and it is intended that a mitigation measures are capable of revised version will be undertaken to support addressing any flood risk and the site any future application to address the concerns should be rated neutral for this element of noted above. the site assessment.

SEPA’s indicative flood map (Figure 5 with site marked by red-line boundary), reinforces this opinion that the extent of flood risk focuses on the Kennoway Burn rather than the wider site.

The previous planning proposal included built development up to the site’s eastern boundary and it is the intention of this

12 Representation to Fife LDP Development Strategy on behalf of The William Brown Trust - February 2014 Fig 5 (above) - SEPA Flood Risk Map - site Fig 6 (below) - View of site’s eastern edge to Kennoway Burn

Representation to Fife LDP Development Strategy on behalf of The William Brown Trust - February 2014 13 Access Whilst not rated a negative factor, we would Dependant upon the scale of development, a wish to clarify scope for achievable access into secondary access may be achievable via the the site. A916 Kennoway Road on the north-western site edge. The principal access can be taken from the A916 Leven Road, to the immediate west of the Proposed access points are indicated on Figure bowling club. An element of the land fronting 8. the site is within Council ownership but Figure 7 demontrates an achievable roundabout A Transport Assessment will be undertaken as access across adopted highway. pat of any future application to confirm the access strategy and associated requirements.

Fig 7 - Potential principal access from Leven Road

14 Representation to Fife LDP Development Strategy on behalf of The William Brown Trust - February 2014 Potential Secondary Access

Proposed Principal Access

Fig 8 - Proposed Access Points

Representation to Fife LDP Development Strategy on behalf of The William Brown Trust - February 2014 15 Indicative Design Framework To illustrate the potential design solution to C - Greenspace (landscaped SUDS zone) address the aforementioned factors, Figure along Kennoway Burn on site’s eastern edge, 9 provides an indicative design framework incorporating SUDS wetland scheme and which sets out the key principles. providing mitigation of any potential flood risk whilst also providing transition from urban to This takes into account the key issues deriving rural edge from the Council’s Site Assessment, being landscape integration and flood risk. D - Greenspace (formal) on level ground opposite Leven Road entrance The framework is based upon a contextual approach, taking into account existing site E - Greenspace (informal) on steeper land on levels, woodland and adjacent uses to enable north-east of site, linked by footpaths through integration between proposed development site (dotted line) areas, greenspace and the rural edge. F - Woodland, including retention of existing In particular, the following elements are trees and new planting along contours on addressed:- ridgeline to mitigate impact on views from south-east entrance to town and link open A - Principal access from Leven Road, west spaces of bowling club, across adopted highway, serving southern part of site as Phase 1, with G - Development blocks of small to medium dashed-line denoting main residential street scale allowing for higher density terraced through site, in line with site contours housing on southern part of site and detached units on northern part of site, frontage to B - Potential secondary access from streets (including Leven Road entrance), access Kennoway Road, serving northern part of site lanes off main street and scope for c.80-90 as Phase 2 units (reduction on previous proposals)

16 Representation to Fife LDP Development Strategy on behalf of The William Brown Trust - February 2014 Plan 3 - Transport Network B E

F G D C

A

Fig 9 - Indicative Design Framework

Representation to Fife LDP Development Strategy on behalf of The William Brown Trust - February 2014 17 Plan 3 - Transport Network Conclusions his submission to the Fife Local has good transport links. Development Plan Development TStrategy provides a response to the Leven Road, as the only site assessed as a Council’s Site Assessment and Consultation ‘reasonable alternative’ within the town forms Question 4 in particular, following previous the most logical direction for urban extension. representations to the ‘Call for Sites’ in 2012 and Main Issues Report in 2013. The site’s negative assessment for landscape impact can be countered through a sensitive Whilst noting Fife Council’s inclusion of land at design to mitigate views from the south- Durievale, Leven Road, Windygates (Ref.LDP- eastern approach into the town. The site is WDY001) as a ‘reasonable alternative’ housing rated similar to 40% of preferred sites within site, it is considered that the site should the Kirkcaldy/Levenmouth area. be included as a preferred housing site for inclusion within the Local Development Plan. The site’s negative assessment for flood risk This is based upon the following factors: is countered by the outcome of previous planning promotion (the site’s eastern edge Fife Council require to identify land with deemed the only potentially affected area), potential for delivering 1,950 housing units as supported by the SEPA flood map. This outwith Strategic Development Areas to risk can be mitigated through design, as 2024 - Windygates has no preferred housing outlined, and if rated fairly in the Council’s Site sites to contribute to this requirement and Assessment, i.e. a 0 or -1 as opposed to -2, the this is objected to on the grounds of, a) lack site’s overall rating should compare directly of current major housebuilder in town and with ‘preferred’ sites. associated market opportunity versus more ‘saturated’ settlements, b) question over The indicative design framework illustrates deliverability of major sites in area such as how a reduced capacity of c.80-90 units Levenmouth, and, c) the settlement is served can be sensitively accommodated on the site, by local services including primary school and capable of delivery in the short term.

18 Representation to Fife LDP Development Strategy on behalf of The William Brown Trust - February 2014 Clarendon Planning and Development Ltd

Exchange Place 2 5 Semple Street Edinburgh EH3 8BL 0131 306 0115 [email protected] www.clarendonpd.co.uk

On behalf of The William Brown Trust & Barratt David Wilson Homes (BDW)

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