Local Development Plan - Planning Assessment
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Local Development Plan - Planning Assessment Introduction This statement is in support of the formal comments made to the online planning system for the South Ayrshire Local Development Plan consultation on behalf of Allanvale Land Investments Ltd. This representation seeks the addition of the Burton Farm site as a housing release site in Appendix D of the Proposed Plan. A separate online representation was made seeking a change from greenbelt to a housing allocation for the site. The land to the south of Ayr at Burton Farm can be considered a sustainable extension to the town to provide a well designed and defensible green belt boundary for this part of Ayr. This summary assessment will consider the key planning issues to be addressed in the promotion of this land through the emerging South Ayrshire Local Development Plan (LDP). This supplementary document supports the online comments made to the LDP in response to individual policies in the Plan. This statement will comment on:- • the existing planning policy framework for this site • site considered against the principles of the emerging LDP • landscape implications from this site being developed • housing land supply problems in South Ayrshire • infrastructure and deliverability of this site The subject site is located immediately to the south of Ayr, adjacent to a disused railway line, which is now a footpath. The site presently comprises a number of low grade agricultural fields. The site rises from south to north with its natural topography lending itself to a well contained settlement extension. See the site plan and an indicative Masterplan below. Existing Policy Background The South Ayrshire Local Plan (adopted 2010) allocates the subject site as part of the greenbelt on the southern boundary of Ayr. At present this greenbelt boundary does very little to contribute to a sustainable defensible boundary. The disused rail line, which provides the boundary to the existing developed area, now appears to provide a long distance footpath and connects to the wider network. There is an opportunity to provide an open space feature on this path which can double as a communal park for a new development. The development could then be enclosed within an appropriate landscape setting. We note there has been a similar housing release in the existing local plan at South East Ayr. This significant housing led mixed use release was important given it led to development being allowed on the eastern side of the A77. The A77 was regarded as the defensible greenbelt boundary at this time and it was evident from this proposal that the Council supported such a housing allocation. Although there are clearly differences in this site than Burton Farm it is evident that a physical feature or boundary on a plan does not necessarily mean this can be regarded as a sustainable defensible greenbelt boundary. The site at Burton Farm can provide a longer term greenbelt boundary as shown in the attached plan. The new Scottish Planning Policy document addresses the issue of Development Plan preparation and the requirement to guide the future use of land and the appearance of cities, towns and rural areas. The SPP states that the process of engagement, information gathering, analysis and assessment is all geared towards the submission of the plan to the Scottish Government. In terms of housing the SPP explains that the planning system should contribute to raising the rate of new house building by identifying a generous supply of land for the provision of a range of housing in the right places. We note that South Ayrshire Council has produced a Housing Land Audit, we will consider this below. The SPP also considers housing land and delivery through the Development Plan. It explains that the creation of mixed sustainable communities depends on a generous supply of appropriate and effective sites being available. Allocating a generous supply of land will give the flexibility necessary for the continued delivery of new housing. LDPs should identify the housing land requirements and allocate a range of sites which are effective or capable of becoming effective to meet these requirements up to year 10. LDPs should also provide an indication of possible scale and location of housing land up to year 10. Local Development Plan Policies The Proposed Plan has a section entitled Maintaining and Protecting Land for Housing. This section advises on the housing land requirement for the plan period and beyond, furthermore the plan then advises on the existing housing land allocation and the additional sites proposed for release. This can be summarised as follows:-..... • 10 year plan, 2013 – 2023: requirement for 6108 units + 1221 units (generous supply) = 7329 requirement • Established supply that will become effective to 2023: 5277 units • Housing shortfall required to be met through LDP: 1872 units The LDP explains that the Council will regularly review the housing land requirements and if there is not enough land available they will potentially release suitable Greenfield sites. In our view this will have to take place as part of this LDP review. The above figures present an over optimistic view of the likely established supply to come forward in the period to 2023. This part of the LDP is also misleading in that it does not outline the effective 5 year supply for South Ayrshire, rather it relies on the 5277 units coming out of the established supply prior to 2023. In our view this highlights a concern that there will not be an effective land supply in South Ayrshire when the plan is adopted. As considered above in the SPP the Council, through the LDP, should allow for a generous supply of housing land of land which is effective. We will review below some of the main sites in this established supply which are unlikely to provide anything near the number of units required to meet the housing land requirement in South Ayrshire. South Ayrshire Housing Land Audit (approved 2010) We will not analyse every site in the audit, rather we will focus on the main providers of sites in South Ayrshire, over 20 units, and the main settlement(s), Ayr, Prestwick and Troon. The majority of existing allocations are in these locations and will have the most influence on the land supply. SA0231, South Harbour Street, in the established supply since 1985 Post 2017 – 37 units SA0490A, West Sanquar Road, in the established supply since 2001 Post 2017 – 100 units SA0490B, West Sanquar Road, in the established supply since 2001 Post 2017 – 80 units SA0525, McCall Avenue, in the established supply since 2002 Post 2017 – 86 units SA0527, Seafield Hospital, in the established supply since 2002 Post 2017 – 30 units SA0546, SE Ayr, in the established supply since 2002 2010 – 2017 – 550 units , Post 2017 – 2150 units SA0579, Greenan, in the established supply since 2007 Post 2017 – 250 units SA0581, Ayr Race Course, in the established supply since 2007 2010 – 2017 – 150 units , Post 2017 – 250 units SA0602, Craigie Campus, in the established supply since 2008 2010 – 2017 – 60 units , Post 2017 – 190 units SA603, Somerset Park, in the established supply since 2008 2010 – 2017 – 50 units , Post 2017 – 105 units SA0524, NE Troon, in the established supply since 2002 2010 – 2017 – 275 units , Post 2017 – 325 units The total Post 2017 supply to come forward, based on these sites alone, is 3603 units. Included in this amount is 2150 units to be built in the SE Ayr site post 2017. Furthermore, the sites highlighted in blue above are programmed as supplying 1085 units prior to 2017. To date none of these sites have produced any units and whilst we do not doubt there will be a level of supply from some of these locations it will not be anywhere near the expected amounts shown in the LDP considered above. Summary The Burton Farm site is a logical extension to the south of Ayr and can provide a more sustainable boundary to this part of the town. The proposal can work within the existing topography to provide an enclosed and sheltered development with appropriate landscaping. The Proposed Plan explains there is a housing shortfall and accordingly proposes new allocations in the Draft Plan. As part of the housing requirement for South Ayrshire there is too much reliance on the delivery of units from the established land supply in the Council area. The LDP as it stands does not accord with the SPP and is not clear in identifying a 5 year effective supply of housing land. There is a requirement to allocate additional land for housing due to this shortfall and the issues with timing over the delivery of various other sites in the local authority area. In this regard our client’s site should be allocated as a housing allocation and promoted for residential development in this LDP. SOUTH AYRSHIRE COUNCIL – MAIN ISSUES REPORT PROPOSED HOUSING DEVELOPMENT – BURTON FARM, AYR CONTENTS 1. INTRODUCTION 2. SITE ANALYSIS AND CONTEXT 3. PLANNING POLICY AND LAND SUPPLY 4. LANDSCAPE SETTING 5. DESIGN PROPOSALS AND ACCESS 6. SUMMARY SOUTH AYRSHIRE COUNCIL – MAIN ISSUES REPORT PROPOSED HOUSING DEVELOPMENT – BURTON FARM, AYR 1. INTRODUCTION 1.1 – This document has been prepared as a response to the South Ayrshire Council Local Development Plan Main Issues Report. The Council have sought representations and comments on the Main Issues Report to be submitted by 31st January 2018. 1.2 – The site is located in the South West boundary of the town of Ayr and extends to some 30 hectares. It is adjacent to the established Burton Estate and the new build development at Greenan by Mactaggart & Mickel. 1.3 - The site comprises of agricultural land and generally slopes from South to North.