East Lothian Council, Local Development Plan – Main Issues Report, 2014

Representation to Main Issues Report on Behalf of Messrs Moffat Regarding Innerwick East and Innerwick West, Innerwick, , EH42 1SB

INNERWICK EAST AND INNERWICK WEST

23rd January 2015

Prepared by Mark T McGleish BA (Hons) PgDip UPA MRTPI

INTRODUCTION

This representation is in response to the Main Issues Report (MIR) for the proposed East Lothian Local Development Plan. It is made on behalf of Messrs Moffat, owners of the sites referred to within the MIR as Innerwick East (ref: PM/DR/HSG104) and Innerwick West (ref: PM/DR/HSG091). Innerwick East is approximately 0.9Ha/2.22 acres in size. Innerwick West is approximately 0.8Ha/1.98 acres in size.

Innerwick East (ref: PM/DR/HSG104) is identified within the MIR as a preferred new housing opportunity with an indicative capacity of 18 units. Innerwick West (ref: PM/DR/HSG091) is identified within the MIR as a reasonable alternative development site with an indicative capacity of 16 units. These matters are explored further below.

Messrs Moffat are working to deliver an effective and sustainable low density mixed tenure residential development on both sites. The location of the sites which are separated from one another by the C122 public roadway is shown on the map below.

Innerwick East/West

Innerwick East/West Location Plan

GENERAL SITE DESCRIPTION

Both sites are to be considered for residential development. The indicative site boundaries are shown in red on the satellite image below. The sites are separated from one another by the public roadway (C122). The blue line indicates some of the landowner’s additional ownership.

The reference co-ordinates/identifiers to the approximate site centre point (public road separating the sites) are:

OS X (Eastings) 372017 OS Y (Northings) 674133 Nearest Post Code EH42 1SB Lat (WGS84) N55:57:34 (55.959394) Long (WGS84) W2:26:59 (-2.449773) Lat,Long 55.959394,-2.449773 Nat Grid NT720741 / NT7201774133 mX -272707 mY 7514900 Mapcode GBR ND9Y.Y68

Immediately Adjacent Land Owned by Messrs Moffat (Blue) Innerwick West

Innerwick East

Innerwick East/West Indicative Site Boundaries and Immediate Surroundings

Both sites (Innerwick West and East) are currently within agricultural use (arable). They are separated from one another by the public road (C122) heading from Innerwick village northwards towards the A1 trunk road. To the south the sites are bounded by single storey houses which form the northern boundary of the village at

present. To the eastern side of Innerwick East lies Innerwick Primary School and agricultural land. To western side of Innerwick West lies agricultural land. To the north of both sites lies agricultural land. The coastline is situated some distance to the north, at its closest point it is approximately 2.5km to the north east of the subject sites.

There are no waterways within or immediately abutting the site and the SEPA Indicative River & Coastal Flood Map has been consulted which indicates that the sites are not at risk from flooding of any kind.

The sites comprise of class 3.1 prime agricultural land. There is however no record of significant or carbon rich soils within the sites. The sites possess relatively flat topography.

Both sites are relatively discrete from a landscape and visual perspective, partly due to the favourable topography allowing them to sit naturally on the edge of the settlement with little impact. The existing Innerwick village, much of which is a conservation area, gives both of the sites a backdrop of built form when viewed from the north. An appropriately designed residential development should have no significant prejudicial landscape or visual impact when viewed from either the existing village to the south or from the north via the coastal fringe or closer inland. Impact on receptors should therefore be low.

Given that the sites contain no landscaping features along their exposed boundaries it is considered appropriate to introduce native planting e.g. trees and hedgerows to provide an edge and this could also be of assistance to the Council’s green network aspirations.

The sites are well served by regular bus services every hour to and Berwick upon Tweed. Bus stops are circa 300m and 400m walking distance from the sites. The sites are within easy walking distance of Innerwick Primary School. is the nearest town providing a plethora of local services and is less than an 8km commute. A mid-week mobile post service visits Innerwick to provide postage, banking and vehicle licensing services. There are excellent road connections to Edinburgh and further afield via the nearby A1, which lies some 900m to the north of the sites.

PLANNING STATUS/CONTEXT

Statutory Development Plan:

The statutory development plan for Innerwick East/West comprises the Strategic Development Plan for Edinburgh and South East (SDP) and the East

Lothian Local Plan 2008 (ELLP2008). The SDP sets out the strategic planning requirements for inter alia East Lothian. The ELLP2008 was prepared under a previous strategic plan, the Edinburgh and the Lothians Structure Plan 2015, which is now revoked. The ELLP2008 needs to be replaced by a new Local Development Plan (LDP) for East Lothian and must conform to the SDP. The MIR forms part of the LDP preparation process.

Within the ELLP2008 the land that comprises Innerwick East/West is highlighted as lying within policy area DC1. Policy DC1 contains criteria that apply to the principle of development within all of East Lothian's countryside and undeveloped coast. Policy DC1 dictates that...”Development, including changes of use, will be acceptable in principle within the countryside and undeveloped coast where it is directly related to agriculture, horticulture, forestry and countryside recreation. Other business use will also be acceptable where it is of an appropriate scale and character for its proposed location in the countryside, it can be suitably serviced and accessed and there are no significant traffic or other environmental impacts “.

The SDP identifies a number of Strategic Development Areas (SDAs) which local development plans must prioritise as locations to accommodate the SDPs strategic housing and employment growth. East Lothian has one SDA. It runs along the A1 and East Coast railway line from to Dunbar. The subject sites lie within the SDA.

Main Issues Report (MIR):

Within the MIR there are two main spatial development strategies put forward, one of ‘compact growth’ which is the preferred option and one of ‘dispersed growth’ which is the alternative option. With compact growth, the focus of the search for new housing land is on... “the main settlements within the west of the SDA, closest to the origin of demand adjacent to the city, and then consider those main settlements further east. Land may also be identified at settlements outwith the SDA if required.” With the dispersed growth option the Council would promote a continuation of the current ‘dispersed’ spatial strategy. In doing so it would seek to... “share and spread additional development across East Lothian by focusing on the main settlements within the SDA. However, land may also be identified at settlements outwith the SDA if required.”

Within the MIR, the preferred strategy supports the delivery of existing strategic housing land allocations along with the other smaller scale housing commitments that form part of the established housing land supply. This land is supplemented with additional sites. In doing this the MIR concentrates on analysing sites in ‘clusters’, sharing the likely enabling and supporting infrastructure requirements where known

at this stage, together with estimates of reasonable lead-in and delivery timescales involved for each.

The subject sites are contained within the ‘Dunbar Cluster’. The MIR indicates that... “Dunbar/Belhaven, , and Innerwick are those settlements that are within the East Lothian Strategic Development Area (SDA). As they are outwith the western part of the SDA these settlements are not preferred as the focus for identifying additional strategic development land at this stage. However, they could contribute to this as they are within the SDA. Yet Innerwick is a small settlement by comparison and any development there must reflect this as well as the character of the settlement and local area.”

The MIR shows Innerwick East (ref: PM/DR/HSG104) as identified as a preferred new housing opportunity with an indicative capacity of 18 units. Further, Innerwick West (ref: PM/DR/HSG091) is identified within the MIR as a reasonable alternative development site with an indicative capacity of 16 units.

It is highlighted that development of Innerwick East could be supported, subject to availability of education capacity. It is understood that capacity exists at present. Further that access may be achievable from the C125 with extension of the 30mph speed limit southwards. It recognises that the site has good accessibility to the Innerwick Primary School. Further, that a suitable design to integrate any development with the settlement and immediate locale would be required along with a masterplan for development.

It is further highlighted that land at Innerwick West may be a reasonable alternative development site, subject to education capacity and access issues being confirmed. Further, that a suitable design to integrate this site as part of the settlement and local area would also be required.

Designations:

The following designations were checked using the Scottish Natural Heritage database, and none were found to be within or immediately adjacent the Innerwick East/West site boundary:

1. Sites of Special Scientific Interest 2. Special Areas of Conservation 3. Special Protection Areas 4. Ramsar 5. National Scenic Areas 6. National Nature Reserves 7. Local Nature Reserves

8. National Parks 9. Country Parks 10. Regional Parks

The following designations were checked using the Historic Scotland database, and none were found to be within the Innerwick East/West site boundary:

1. Listed Buildings 2. Scheduled Monuments 3. Canmore (archaeological and architectural heritage records) 4. Gardens & Designed Landscapes

INNERWICK EAST AND WEST – DEVELOPMENT ASPIRATION

Innerwick East and Innerwick West are both offered as effective housing sites that can contribute to the short term housing land supply within East Lothian.

Messrs Moffat the owner’s of Innerwick East are supportive of its continued identification as a preferred housing site and consider it capable of accommodating 18 homes, with a mix of private and affordable dwellings.

Messrs Moffat also offer Innerwick West as an effective housing site and consider it capable of accommodating 16 homes, with a mix of private and affordable dwellings.

If 25% of the site’s capacity is identified as affordable housing, the delivery of the affordable housing units involved could be in conjunction with an RSL. Initial discussions have taken place with both a developer and RSL interest in this respect. However, the option for the Council to consider other forms of affordable provision as set out in the Scottish Planning Policy is available and is supported by the site owners. In this respect more diverse ways of providing affordable homes in addition to the now traditional publicly funded RSL development of ‘quota land’ must be sought, in order to deliver sufficient units within necessary timescales overall throughout East Lothian.

Messrs Moffat wish to utilise a thorough masterplanning exercise and pre-application consultation process involving the Council and other key stakeholders in order to ensure that development proposals are robust and deliverable. This will include a thorough assessment of access issues, landscape and visual impact and how the site can support the Council’s green network aspirations, in particular via the use of native tree and hedgerow planting along exposed boundaries.

EFFECTIVENESS FOR HOUSING DEVELOPMENT

The owners of the sites at Innerwick support a full review being undertaken by the Council into the effectiveness of all existing housing allocations contained within the Housing Land Supply Audit. Where sites currently contained with the housing land supply audit are failing to exhibit effectiveness for development or the likelihood of it within necessary timescales, the inclusion within the housing land supply of additional proven effective housing sites should occur to meet properly assessed housing land requirements. In this respect Innerwick East and Innerwick West should be considered to help meet this need.

Planning Advice Note (PAN) 2/2010: Affordable Housing and Housing Land Audits, provides clear guidance on the assessment of effectiveness. Given the information known at present, both Innerwick East and Innerwick West pass the effectiveness assessment as exhibited below.

The PAN states that “to assess a site or a portion of a site as being effective, it must be demonstrated that within the five-year period beyond the date of the audit the site can be developed for housing (i.e. residential units can be completed and available for occupation), and will be free of constraints on the following basis”:

Ownership test: the site is in the ownership or control of a party which can be expected to develop it or to release it for development. Where a site is in the ownership of a local authority or other public body, it should be included only where it is part of a programme of land disposal.

The sites are privately owned by Messrs Moffat, who are working to see their land developed for housing as quickly as possible. There are no ownership constraints and there is developer interest in the sites.

Physical test: the site, or relevant part of it, is free from constraints related to slope, aspect, flood risk, ground stability or vehicular access which would preclude its development. Where there is a solid commitment to removing the constraints in time to allow development in the period under consideration, or the market is strong enough to fund the remedial work required, the site should be included in the effective land supply.

The sites are free of physical constraints. There is no need for ground works or retention that could be prejudicial to their economic viability as housing sites. The land offers space to accommodate SUDs drainage.

Access could be taken from C122. The owners control the entire site frontage to the adopted highway at that location and additional land fronting the carriageway

heading north. There are no surface watercourses within the sites that could influence development. Further, development can occur without causing ecological, environmental or flooding concerns. SEPA’s indicative flood risk mapping has been consulted and the sites are not shown to be at risk from flooding. We are not aware of any previous mining activity on or under the landholdings.

Contamination test: previous use has not resulted in contamination of the site or, if it has, commitments have been made which would allow it to be developed to provide marketable housing.

Both Innerwick East and Innerwick West have an agricultural past, being used for grazing and cropping. There has been no mining, landfill or contaminative uses to the owner’s knowledge and the sites should be completely unconstrained in this respect.

Deficit funding test: any public funding required to make residential development economically viable is committed by the public bodies concerned.

No public funding is required, the sites are considered currently economically viable in their own right.

Marketability test: the site, or a relevant part of it, can be developed in the period under consideration.

The sites are marketable for house building. There has already been developer interest in both Innerwick East and Innerwick West, with regards to both private and affordable tenures.

Infrastructure test: the site is either free of infrastructure constraints, or any required infrastructure can be provided realistically by the developer or another party to allow development.

There are no known infrastructure constraints considered likely to inhibit development of the sites.

Land use test: housing is the sole preferred use of the land in planning terms, or if housing is one of a range of possible uses other factors such as ownership and marketability point to housing being a realistic option.

The redevelopment of Innerwick East and Innerwick West for housing is supported by the owners Messrs Moffat and there has been developer interest in both sites. This combined with the Council’s identification thus far of the sites as possible housing opportunities adds to their effectiveness.

The subject sites at Innerwick East and Innerwick West are effective. They suffer none of the obvious constraints outlined in PAN 2/2010, and should be actively considered for allocation and programming in the short term.

MAIN ISSUES REPORT – SUPPLY OF HOUSING LAND

It is appreciated that it is difficult for any Council to assess housing site effectiveness with complete accuracy. Messrs Moffat encourage and support the Council in undertaking a fair and robust assessment of site effectiveness at allocation stage and also in the use of the annual housing land audit mechanism to gauge and adjust effective supply on an ongoing basis. In that regard it is the opinion of Messrs Moffat that a sufficient generosity requirement should be built in to cover underperformance of the supply.

CONCLUSION

We trust that the above points are considered valuable at this early stage in the preparation of the East Lothian Local Development Plan. The landowners look forward to promoting Innerwick East and West pro-actively in conjunction with the Council and other key stakeholders.

In that respect the owners support the Council’s identification of Innerwick East as a preferred housing site. Innerwick East is an effective site that can contribute in the short term to the areas land supply. Innerwick West mirrors this. The owners also offer Innerwick West to make a contribution to the effective housing land supply within East Lothian.