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

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Durievale, Leven Road, Windygates, Fife (Fife Council Site Ref.LDP-WDY001) Durievale, Leven Road, Windygates, Fife (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 Scotland 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?” • Markinch - 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 Buckhaven. 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.
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