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REPORT TO SCOTTISH MINISTERS ON THE TAYPLAN STRATEGIC DEVELOPMENT PLAN

STRATEGIC DEVELOPMENT PLAN EXAMINATION

carried out under Section 12 of the

Town and Country Planning (Scotland) Act 1997

Reporters: Mike Cunliffe Scott Ferrie Karen Heywood

Date of Report: 13 April 2012

CONTENTS Page No

Examination of Conformity with the Participation Statement 1

Issue

1. Vision and Objectives 2 2. Proposals 1: Map 22 3. Policy 1: Location Priorities – Policy 1A 40 4. Policy 1: Location Priorities – Policy 1b, Text and General 73 5. Shaping Better Quality Places 91 6. Policy 3: Managing TAYplan’s Assets – General and Text 110 7. Managing TAYplan’s Assets – Employment Land 115 8. Policy 3: Managing TAYplan’s Assets – Greenbelts 121 9. Managing TAYplan’s Assets – Finite Resources 136 10. Policy 3: Managing TAYplan’s Assets – Transport 142 11. Policy 3: Managing TAYplan’s Assets – Natural and Historic Assets 147 12. Policy 4: Strategic Development Areas Part A 153 13. Policy 4: Strategic Development Areas – Alternative Sites 171 14. Policy 4: Strategic Development Areas Part B and Supporting Text 183 and General 183 15. Scale and Distribution of Housing 189 16. Policy 5: Housing – Policy 5 Part A Effectiveness of Land 224 17. Policy 5: Housing – Policy 5 Part C Areas Surrounding Dundee and Perth Core Areas 244 18. Policy 5: Housing – Policy 5 Part A Up to 10% Shift between Housing Market Areas 252 19. Policy 5: Housing – Policy 5 Part A Range and Mix of Housing including Affordable 258 20. Policy 6: Energy and Waste/Resource Management Infrastructure - Policy 6a + b, Text and General 269 21. Policy 6: Energy and Waste/Resource Management Infrastructure - Policy 6c 286 22. Policy 7: Town Centres 294 23. Policy 8: Delivering the Strategic Development Plan 303 24. Other Issues 317

TAYPLAN STRATEGIC DEVELOPMENT PLAN

Examination of Conformity with the Participation Statement

1. Section 12(2) of the Town and Country Planning (Scotland) Act 1997 (as amended) states that a person appointed to examine a proposed strategic development plan “is firstly to examine under this section the extent to which the strategic development planning authority’s actings with regard to consultation and the involvement with the public at large as respects the proposed plan have conformed with (or have been beyond the requirements of) the participation statement of the authority which was current when the proposed plan was published under section 10(1)(a).”

2. The proposed TAYplan Strategic Development Plan was published in June 2011. The Development Plan Scheme current at that time was published in March 2011.

3. The participation statement is included at section 13 of the Development Plan Scheme. In that section proposals are set out for:

a. period for representations on the proposed plan b. advertisements c. news releases d. posters/leaflets e. information events f. community councils and elected members g. online h. roving presentations i. other publicity.

4. The Report on Conformity with Participation Statement, published in October 2011, was submitted to Ministers along with the proposed plan. It sets out in a full and comprehensive manner the strategic development planning authority’s actions in regard to the participation proposals (listed above) contained in the Development Plan Scheme.

5. Having considered the evidence, we found that the authority had consulted on the plan and involved the public in the way it said it would in its participation statement, in accordance with section 12(2) of the Act. Being satisfied, we therefore proceeded to examine the proposed strategic development plan.

1 TAYPLAN STRATEGIC DEVELOPMENT PLAN

Issue 1 Vision and Objectives

Development plan Reporter: Page 6: Vision and Objectives reference: Mike Cunliffe Body or person(s) submitting a representation raising the issue (including reference number): Seeking a change

ID Representation Number Person/Organisation Reference 548872 Alyth Community Council PLAN822 Andrew McCafferty for GD Strawson and J 548151 Farquharson PLAN440 443102 Barton Willmore for Scotia Homes PLAN375 545071 Binn Eco Park PLAN138 450103 CTC Right to Ride Network PLAN837 445201 Emac Planning for A & J Stephen Ltd PLAN679 445201 Emac Planning for A & J Stephen Ltd PLAN681 548522 Emac Planning for A & J Stephen Ltd/Bett Homes Ltd PLAN728 548522 Emac Planning for A & J Stephen Ltd/Bett Homes Ltd PLAN729 445204 Emac Planning for Angus Estates Ltd PLAN593 548523 Emac Planning for Bett Homes Ltd PLAN758 548523 Emac Planning for Bett Homes Ltd PLAN759 445203 Emac Planning for James Keiller Estates Ltd PLAN710 445203 Emac Planning for James Keiller Estates Ltd PLAN712 445206 Emac Planning for JG Lang & Son PLAN534 548383 Emac Planning for L Porter PLAN543 548360 Emac Planning for M Batchelor (B) PLAN530 548301 Emac Planning for M Batchelor (K) PLAN517 445205 Emac Planning for Mr R Watson PLAN508 548524 Emac Planning for Stewart Milne Homes PLAN774 548524 Emac Planning for Stewart Milne Homes PLAN775 548524 Emac Planning for Stewart Milne Homes PLAN776 438726 Geddes Consulting for Lynch Homes PLAN629 438726 Geddes Consulting for Lynch Homes PLAN632 438726 Geddes Consulting for Lynch Homes PLAN638 445159 Geddes Consulting for Thomson Homes PLAN883 543112 GS Brown Construction PLAN83 547268 GVA for David Wilson Homes PLAN447 548389 Halliday Fraser Munro for Barratt Homes PLAN579 442882 Homes for Scotland PLAN213 443979 Lynne Palmer PLAN161 406092 Mr Ken Russell PLAN32 337567 Mr Kyffin Roberts PLAN507 548254 Muirhead, Birkhill and Liff Community Council PLAN478 344887 Penny Uprichard PLAN872 548419 Roy de C Chapman PLAN582 453889 Royal Burgh of St. Andrews Community Council PLAN916 548506 Ryden for University of St. Andrews PLAN722 548506 Ryden for University of St. Andrews PLAN723 548506 Ryden for University of St. Andrews PLAN724

2 TAYPLAN STRATEGIC DEVELOPMENT PLAN 548506 Ryden for University of St. Andrews PLAN730 548506 Ryden for University of St. Andrews PLAN732 444087 Scottish Property Federation PLAN240 442871 Smiths Gore for Errol Park Estate PLAN623 442870 Smiths Gore for Mansfield Estates PLAN540 547750 St. Andrews Preservation Trust PLAN304 546491 TMS Planning for Campion Homes PLAN224 345005 TMS Planning for Mr James Thomson PLAN236 345007 TMS Planning for Mr Simon Wilson PLAN396 345006 TMS Planning for Mr Tim Esparon PLAN187 345006 TMS Planning for Mr Tim Esparon PLAN200 346675 TMS Planning for Muir Homes Ltd PLAN353 547863 Wallace Planning Limited for National Grid PLAN351

Support as written

ID Representation Number Person/Organisation Reference 419429 Auchterarder and District Community Council PLAN75 442149 Bidwells for Zurich Assurance Ltd PLAN660 337727 Colliers International for Gleneagles Hotel PLAN50 416017 Colliers International for Persimmon Homes Ltd PLAN37 541486 Colliers International for Taylor Wimpey East Scotland PLAN60 450103 CTC Right to Ride Network PLAN835 450103 CTC Right to Ride Network PLAN836 548948 Hargest Planning Ltd for MacDonald Estates PLAN854 327210 JWK Properties PLAN929 263542 Kingsbarns Community Council PLAN373 444081 Montagu Evans for Montagu Evans PLAN318 548506 Ms Anne Rennie for University of St. Andrews PLAN732 547710 NHS Tayside PLAN295 548506 Ryden for University of St. Andrews PLAN725 548506 Ryden for University of St. Andrews PLAN726 548506 Ryden for University of St. Andrews PLAN727 548506 Ryden for University of St. Andrews PLAN730 548506 Ryden for University of St. Andrews PLAN732 442031 Scottish Environment Protection Agency PLAN169 344848 Scottish Natural Heritage for PLAN413 Scottish Wildlife Trust Angus and Dundee Members 548745 Centre PLAN805 547388 SEStran Regional Transport Partnership PLAN271 Provision of the development plan The Vision and Objectives how the region should be in 2032 and what to which the issue must occur to bring about this change. relates: Planning authority’s summary of the representation(s):

SUMMARY OF REPRESENTATIONS SEEKING A CHANGE

3 TAYPLAN STRATEGIC DEVELOPMENT PLAN (445206); L Porter (548383); M Batchelor (B)(548360); M Batchelor (K)(548301); Mr R Watson (445205) and Stewart Milne Homes (548524) – PLAN774 & PLAN775 (duplicate of PLAN774) ) In order to achieve the vision TAYplan should be more ambitious in terms of its strategy for growth.

Penny Uprichard (344887) considers that there is a lack of economic proposals for funding the Proposed Plan’s ‘visions'.

St. Andrews Preservation Trust (547750) consider that this section of the Proposed Plan does not take account of changes in recent years, including: the significantly changed economic situation; the closure of the Guardbridge Paper Mill (which provides a potential site for the St. Andrews science park or business park); and, the closure of the Leuchars airbase (which offers the chance to review previous decisions not to locate significant new housing in the area because of noise issues, and also allows for the possibility of developing commercial air services).

Wallace Planning Limited for National Grid (547863) seeks adding a new sentence to promote the restoration and regeneration of brownfield sites especially those in need of regeneration e.g. former Gasworks sites. The respondent considers TAYplan should adopt a proactive approach towards promoting viable after-uses for former gas works sites. This approach should be set out in the Strategic Development Plan and be required to be carried forward into the Local Development Plans. Such an approach should recognise that a more sympathetic application of policies is required to ensure the remediation of former gaswork sites.

VISION Ryden for University of St. Andrews (548506) – PLAN 722 seek an amendment to the Vision to read “…live, work, study and visit…”.

SUPPORTING SUSTAINABLE ECONOMIC DEVELOPMENT AND IMPROVING REGIONAL IMAGE AND DISTINCTIVENESS OBJECTIVES

A) Economic Strategy Emac Planning for (Angus Estates Ltd (445204); A & J Stephen Ltd – PLAN681 (445201); A & J Stephen Ltd/Bett Homes Ltd – PLAN729 (548522); Bett Homes Ltd – PLAN759 (548523); James Keiller Estates Ltd – PLAN712 (445203) and Stewart Milne Homes (548524) – PLAN776) request an amendment to the objective starting ‘Strengthen the economic base...’ by inserting ‘business and employment opportunities, including...’ to achieve flexibility over the Plan period in accordance with paragraph 45 of Scottish Planning Policy which requires ‘Authorities should respond to the diverse needs and locational requirements of different sectors and sizes of businesses and take a flexible approach to ensure that changing circumstances can be accommodated and new economic opportunities realised.’

Ryden for University of St. Andrews (548506) – PLAN 723 seeks an amendment to the objective "Strengthen the economic base to support..." to acknowledge the further and high education sector including commercialisation and research. There is no specific mention of the economic benefits of both the further and higher education sectors within the TAYplan area.

Mr Kyffin Roberts (337567) and Royal Burgh of St. Andrews Community Council (453889) seek an amendment to the objective "Strengthen the economic base..." to state that "…commercial spin-offs from the higher education and research sector…" as commercialising higher education is considered to mean running education for profit rather 4 TAYPLAN STRATEGIC DEVELOPMENT PLAN than commercial exploitation of appropriate types of research.

Binn Eco Park (545071) seek an amendment to the objective "Strengthen the economic base..." to refer to the low carbon technology sector in addition to the renewable energy sector, recognising it as a major development opportunity supporting other sectors.

Mr Kyffin Roberts (337567) and Royal Burgh of St. Andrews Community Council (453889) seek an amendment to the objective "Strengthen the critical mass of Dundee..." to remove reference to the word ‘major’ with regard to principal settlements serving as economic drivers, particularly in relation to Tier 3 settlements as Policy 1 seeks a more modest role in the regional economy for these settlements.

Mr Roy de C Chapman (548419) expresses concern that the Proposed Plan looks like a tabletop exercise which appears to be based on the false premise that St Andrews will be "The Economic Driver for the whole of Fife." The future development of tourist facilities in St. Andrews would be welcome, but golf courses in St. Andrews (and in the East Neuk) have reached saturation point and additional courses would have an adverse effect on the landscape without any corresponding gain.

B) Provision of Land for Housing and Employment Scottish Property Federation (444087) consider that the Proposed Plan does not go far enough in encouraging growth and believe that the Strategic Development Plan should plan for a higher growth scenario and set population targets to encourage significant development.

Barton Willmore for Scotia Homes (443102); GVA for David Wilson Homes (547268); Halliday Fraser Munro for Barratt Homes (548389); Homes for Scotland (442882); Smiths Gore for Errol Park Estate (442871); Smiths Gore for Mansfield Estate (442871); Emac Planning for (Angus Estates Ltd (445204); A & J Stephen Ltd – PLAN679 (445201); A & J Stephen Ltd/Bett Homes Ltd – PLAN728 (548522); Bett Homes Ltd – PLAN758 (548523); James Keiller Estates Ltd – PLAN710 (445203); JG Lang & Son (445206); L Porter (548383); M Batchelor (B)(548360); M Batchelor (K)(548301); Mr R Watson (445205) and Stewart Milne Homes (548524) – PLAN774 & PLAN775 (duplicate of PLAN774) ) seek the addition of ‘generous’ in the objective "Plan for an effective supply of land for housing and employment" in order to ensure there is a sufficient housing land supply available in the short and medium term in accordance with Scottish Planning Policy requirements and to drive economic growth. An increase in the quantity and supply of housing land, it is considered, would aid deliverability in the earlier periods of the Plan and allow smaller, more economically viable sites to come forward pending economic recovery and the ability of strategic sites to come forward. Additionally, all those whom Emac Planning represent above, seek the inclusion of a reference to mixed use development in this objective, citing that Paragraph 46 of Scottish Planning Policy identifies that there should be a range and choice of employment sites including opportunities for mixed use development. Halliday Fraser Munro for Barratt Homes (548389) additionally expresses concerns in relation to brownfield sites and promotes a site north east of Monifieth for mixed use development. These issues are addressed in Issue 4 – Policy 1: Location Priorities – Policy 1b, text and general, Issue 13 - Policy 4: Strategic Development Areas – Alternative sites.

Geddes Consulting for Lynch Homes - PLAN629, PLAN632 & PLAN638 (438726) and Geddes Consulting for Thomson Homes (445159) seek an amendment to the objective “Plan for an effective supply...” to ensure a minimum of 5 years housing land supply at all times, and employment, serviced or serviceable within 5 years in order to ensure that the concept of effective land supply is in accord with Scottish Planning Policy and can give 5 TAYPLAN STRATEGIC DEVELOPMENT PLAN appropriate guidance to the emerging Local Development Plans.

Mr Kyffin Roberts (337567) and Royal Burgh of St. Andrews Community Council (453889) seek an amendment to the objective “Plan for an effective supply...” to seek particular reference to affordable housing, considering that this is one of the greatest problems facing many places including St. Andrews.

Ryden for University of St. Andrews (548506) – PLAN 724 seek an amendment to the objective “Plan for an effective supply...” to Plan for an effective supply of land for housing and employment appropriate to local demand, highlighting issues of insufficient provision of staff and student accommodation in St. Andrews and consequent impacts on the University of St. Andrews.

Andrew McCafferty for GD Strawson and J Farquharson (548151) seek an amendment to the objective "Plan for an effective supply…" to plan for a supply of land for housing and employment which is based on meeting needs and demand over the lifetime of the Plan. The response also notes support for a higher, more aspirational range of growth to avoid constraining growth.

Mr Ken Russell (406092) seeks an amendment to the objective "Plan for an effective supply…" by adding ‘and Community Facilities’ to acknowledge the whole variety of developments that contribute to a sustainable community.

Emac Planning for (Angus Estates Ltd (445204); A & J Stephen Ltd – PLAN679 (445201); A & J Stephen Ltd/Bett Homes Ltd – PLAN728 (548522); Bett Homes Ltd – PLAN758 (548523); James Keiller Estates Ltd – PLAN710 (445203); JG Lang & Son (445206); L Porter (548383); M Batchelor (B)(548360); M Batchelor (K)(548301); Mr R Watson (445205); Stewart Milne Homes (548524) – PLAN774 & PLAN775 (duplicate of PLAN774)) consider that the Plan relies too heavily on Strategic Development Areas identified previously under Development Plans approved or adopted in a different economic climate, and that the contribution of the existing Strategic Allocations to the supply of housing land required in Development Plan periods preceding the TAYplan should not therefore just simply be rolled forward. Concern is expressed at the deliverability of some of the Strategic Development Areas. The respondents further consider that the Plan should recognise that some of the supply identified by the Strategic Development Areas actually contributes to the period prior to 2012 and logically therefore their entire allocation should not contribute to the Housing Land Requirement identified in the TAYplan.

C) Deliverability

TMS Planning for (Mr Tim Esparon (345006) – PLAN187 & PLAN200 (duplicate of PLAN187); Campion Homes (546491); Mr James Thompson (345005); Mr Simon Wilson (345007) and Muir Homes Ltd (346675)) consider there should be reference to the "provision of a deliverable development strategy in order to meet the underlying needs of the TAYplan area" added to the diagram. It is imperative that local development plans are required to show deliverability and effectiveness of land allocations.

D) Spatial Strategy

TMS Planning for (Mr Tim Esparon (345006) – PLAN187 & PLAN200 (duplicate of PLAN187); Campion Homes (546491); Mr James Thompson (345005); Mr Simon Wilson (345007) and Muir Homes Ltd (346675)) The objective to "Facilitate appropriate development in rural communities …" should be altered to state "to promote prosperous and sustainable rural communities in order to support local services and amenities, including the 6 TAYPLAN STRATEGIC DEVELOPMENT PLAN provision of additional housing and related development proportionate to local need, available infrastructure and environmental capacity" in line with the requirements of Scottish Planning Policy.

The above further consider a new objective to "facilitate development outwith principle settlements in order to meet identified local needs" should be added.

E) Other

Lynne Palmer (443979) seeks the removal of the letter ‘s’ at the end of ‘town’ when referring to the region’s towns centres.

ENHANCING THE QUALITY OF PLACE THROUGH BETTER DEVELOPMENT OUTCOMES OBJECTIVES

Mr Kyffin Roberts (337567) and Royal Burgh of St. Andrews Community Council (453889) seek an amendment to the objective "Promote and enhance places and landscapes as economic drivers…" to include the word ‘appropriate’ before ‘places and landscapes’ as it is not considered possible to simultaneously safeguard a place and exploit it as an economic driver. The respondents consider that the objective should not apply to places safeguarded under Policy 3 of the Proposed Plan. The respondents also seek an amendment to the objective ‘Continue to protect the important landscape settings …’ to remove the word ‘continue’ as for St. Andrews whilst green belt is proposed in a draft Local Plan this is not yet implemented.

GS Brown Construction (543112) express concern that the green belt concept is an anachronism in planning terms and is too blunt and rigid in its application, and that the proposed Perth green belt will rule out small scale infill type developments within the Perth Core zone.

Ryden for University of St. Andrews (548506) PLAN730 highlight that protection of St. Andrews landscape setting through the use of a green belt must be balanced with the need to ensure there is sufficient housing and employment land supply within St. Andrews to allow its planned and measured expansion, thus securing the economic sustainability of the Town.

ENSURING EFFECTIVE RESOURCE MANAGEMENT AND PROMOTING AN ACCESSIBLE, CONNECTED AND NETWORKED REGION OBJECTIVES

Mr Kyffin Roberts (337567) and Royal Burgh of St. Andrews Community Council (453889) seek an amendment to the objective ‘Promote transport linkages…’ to make reference to bus, rail and cycle path improvements as examples of ‘network improvements’. The respondent considers that such improvements would be consistent with TAYplan's support for reducing carbon emissions. The respondents further seek an amendment to the objective ‘Ensure that new development makes best use of existing networks…’ to add the word ‘protect’ before ‘ecosystems’ for clarity.

Muirhead, Birkhill and Liff Community Council (548254) seeks an amendment to the objective ‘Promote transport linkages…’ to make reference to linking air, bus and rail transport with each other and with the Park and Ride facilities such as Dundee West.

CTC Right to Ride Network (450103) - PLAN837 expresses concern that the objective ‘Enhance the condition and connectivity of the networks of green spaces…’ could be used to force pedal cyclists off the existing roads infrastructure.

7 TAYPLAN STRATEGIC DEVELOPMENT PLAN Ryden for University of St. Andrews (548506) - PLAN732 whilst supporting the objective ‘Support the switch to a low carbon and zero waste economy’ the respondent considers that the plan should consider infrastructure for the creation of a suitable electricity grid to meet community demands to manage renewable energy generation, and consider establishment of more localised waste and resource management facilities.

Alyth Community Council (548872) whilst requesting no specific change, consider that the declaration that the need to fight climate change is central to TAYplan's strategy is strange and that the need to focus on the well-being of all the residents of this area should be central and foremost.

SUMMARY OF REPRESENTATIONS SUPPORTING AS WRITTEN

GENERAL Bidwells for Zurich Assurance Ltd (442149), JWK Properties for J Khazaka (327210), Scottish Environment Protection Agency (442031), Auchterarder and District Community Council (419429), and SEStran Regional Transport Partnership (547388) show general support for the vision and objectives as outlined.

Colliers International for (Persimmon Homes Ltd (416017), Gleneagles Hotel (337727), Kingsbarns Community Council (263542) and Taylor Wimpey East Scotland (541486) show specific support for the objectives as outlined.

VISION

Scottish Wildlife Trust Angus and Dundee Members Centre (548745) specifically supports the underlying vision of the Proposed Plan.

SUPPORTING SUSTAINABLE ECONOMIC DEVELOPMENT AND IMPROVING REGIONAL IMAGE AND DISTINCTIVENESS OBJECTIVES

Ryden for University of St. Andrews (548506) PLAN726/PLAN727/PLAN725, Hargest Planning Ltd (548948), NHS Tayside (547710), Scottish Property Federation (444087) Kingsbarns Community Council (263542) and Montagu Evans (444081) support elements of this objective.

ENHANCING THE QUALITY OF PLACE THROUGH BETTER DEVELOPMENT OUTCOMES

Ryden for University of St. Andrews (548506) PLAN730, CTC Right to Ride Network (450103) PLAN836 and Scottish Natural Heritage (344848) support elements of this objective.

ENSURING EFFECTIVE RESOURCE MANAGEMENT AND PROMOTING AN ACCESSIBLE, CONNECTED AND NETWORKED REGION OBJECTIVES Ryden for University of St. Andrews (548506), CTC Right to Ride Network (450103) PLAN835), Ryden for University of St. Andrews (548506) PLAN732 support elements of this objective.

Modifications sought by those submitting representations:

NOTE TO REPORTER 1: The text in italics in this section has been lifted directly from the each individual/organisation’s representation with minor typographical errors td 8 TAYPLAN STRATEGIC DEVELOPMENT PLAN GENERAL Emac Planning for (Angus Estates Ltd (445204); A & J Stephen Ltd – PLAN679 (445201); A & J Stephen Ltd/Bett Homes Ltd – PLAN728 (548522); Bett Homes Ltd – PLAN758 (548523); James Keiller Estates Ltd – PLAN710 (445203); JG Lang & Son (445206); L Porter (548383); M Batchelor (B)(548360); M Batchelor (K)(548301); Mr R Watson (445205) and Stewart Milne Homes (548524) – PLAN774 & PLAN775 (duplicate of PLAN774)) • The stated vision of the Plan is supported, however, in order to achieve this vision the TAYplan should be more ambitious in terms of its strategy for growth.

Penny Uprichard (344887) • Requests no specific change but considers that there is a lack of economic proposals for funding the Proposed Plan’s ‘visions'.

St. Andrews Preservation Trust (547750) • Requests no specific change but consider that this section of the Proposed Plan does not take account of changes in recent years, including: the significantly changed economic situation; the closure of the Guardbridge Paper Mill; and, the closure of the Leuchars airbase.

Wallace Planning Limited for National Grid (547863) • Insert new sentence to read: “Promote the restoration and regeneration of brownfield sites especially those in need of regeneration eg former Gasworks sites.”

VISION Ryden for University of St. Andrews (548506) – PLAN 722 • The vision should be amended as follows: "By 2032 the TAYplan region will be sustainable, more attractive, competitive and vibrant without creating an unacceptable burden on our planet. The quality of life will make it a place of first choice where more people choose to live, work, study and visit and where businesses choose to invest and create jobs".

SUPPORTING SUSTAINABLE ECONOMIC DEVELOPMENT AND IMPROVING REGIONAL IMAGE AND DISTINCTIVENESS OBJECTIVES

Ryden for University of St. Andrews (548506) – PLAN 723 • Amend Objective (Economic Base) Page 6 to read "Strengthen the economic base to support the renewable energy sector, the further and high education sector including commercialisation and research, the region's ports and food research, forestry, life sciences, digital media and tourism.

Mr Kyffin Roberts (337567) and Royal Burgh of St. Andrews Community Council (453889) • Change "commercialisation of the higher education and research sector" to "commercial spin-offs from the higher education and research sector". 9 TAYPLAN STRATEGIC DEVELOPMENT PLAN Binn Eco Park (545071) • Change Objective that starts...''Strengthen the economic base''...etc by adding after renewable energy ''and low carbon technology'' sector so it reads...'to support the renewable energy and low carbon technology sector, the regions ports etc..''.

Mr Kyffin Roberts (337567) and Royal Burgh of St. Andrews Community Council (453889) • Change "Strengthen the critical mass of Dundee so that with Perth and other principal settlements they serve as major economic drivers supporting a more competitive, strong and stable economy for the region;" to "Strengthen the critical mass of Dundee so that with Perth and other principal settlements they serve as economic drivers supporting a more competitive, strong and stable economy for the region;".

Mr Roy de C Chapman (548419) • Whilst requesting no specific change expresses concern additional golf courses in St Andrews (and in the East Neuk) would have a very adverse effect on the landscape without any corresponding gain.

B) Provision of Land for Housing and Employment

Scottish Property Federation (444087) • The TAYplan's strategy should be more ambitious and plan for a higher population growth.

Geddes Consulting for Lynch Homes - PLAN629, PLAN632 & PLAN638 (438726); Geddes Consulting for Thomson Homes (445159) • Proposed Plan Text: Plan for an effective supply of land for housing and employment. • Proposed Change: Plan for an effective supply of land for housing, ensuring a minimum of 5 years land supply at all times, and employment, serviced or serviceable within 5 years.

Mr Kyffin Roberts (337567) and Royal Burgh of St. Andrews Community Council (453889) • Change "Plan for an effective supply of land for housing and employment;" to "Plan for an effective supply of land for housing, particularly affordable housing, and employment;".

10 TAYPLAN STRATEGIC DEVELOPMENT PLAN Ryden for University of St. Andrews (548506) – PLAN 724 • Amend Objective (Land for Housing and Employment) to "Plan for an effective supply of land for housing and employment appropriate to local demand ".

Andrew McCafferty for GD Strawson and J Farquharson (548151) • Change objective "Plan for an effective supply of land for housing and employment" to read: " Plan for a supply of land for housing and employment which is based on meeting needs and demand over the lifetime of the Plan."

Mr Ken Russell (406092) • Objective 'Plan for an effective supply of land for housing and employment' Add and Community Facilities.

Emac Planning for (Angus Estates Ltd (445204); A & J Stephen Ltd – PLAN679 (445201); A & J Stephen Ltd/Bett Homes Ltd – PLAN728 (548522); Bett Homes Ltd – PLAN758 (548523); James Keiller Estates Ltd – PLAN710 (445203); JG Lang & Son (445206); L Porter (548383); M Batchelor (B)(548360); M Batchelor (K)(548301); Mr R Watson (445205) and Stewart Milne Homes (548524) – PLAN774 & PLAN775 (duplicate of PLAN774)) • Whilst requesting no specific change express concern that the contribution of the existing Strategic Allocations to the supply of housing land required in Development Plan periods preceding the TAYplan should not therefore just simply be rolled forward. • Whilst requesting no specific change to the Vision and Objectives express concern that the Plan should recognise that some of the supply identified by the SDA's actually contributes to the period prior to 2012 and logically therefore their entire allocation should not contribute to the Housing Land Requirement identified in the TAYplan.

C) Deliverability

TMS Planning for (Mr Tim Esparon (345006) – PLAN187 & PLAN200 (duplicate of PLAN187); Campion Homes (546491); Mr James Thompson (345005); Mr Simon Wilson (345007) and Muir Homes Ltd (346675)) • There should also be reference to the "provision of a deliverable development strategy in order to meet the underlying needs of the TayPlan area" added to the diagram.

D) Spatial Strategy

TMS Planning for (Mr Tim Esparon (345006) – PLAN187 & PLAN200 (duplicate of PLAN187); Campion Homes (546491); Mr James Thompson (345005); Mr Simon Wilson (345007) and Muir Homes Ltd (346675)) • The diagram contains the objective to "Facilitate appropriate development in rural communities where job and service needs exist". In line with the requirements of Scottish Planning Policy this should be altered to state "to promote prosperous and sustainable rural communities in order to support local services and amenities, including the provision of additional housing and related development proportionate to local need, available infrastructure and environmental capacity".

E) Other Lynne Palmer (443979) • Page 6 near the top of page, should be "region's town centres" (remove “s” at end of town). 11 TAYPLAN STRATEGIC DEVELOPMENT PLAN TMS Planning for (Mr Tim Esparon (345006) – PLAN187 & PLAN200 (duplicate of PLAN187); Campion Homes (546491); Mr James Thompson (345005); Mr Simon Wilson (345007) and Muir Homes Ltd (346675)) • A new objective to "facilitate development outwith principle settlements in order to meet identified local needs" should be added to the diagram.

ENHANCING THE QUALITY OF PLACE THROUGH BETTER DEVELOPMENT OUTCOMES OBJECTIVES

Mr Kyffin Roberts (337567) and Royal Burgh of St. Andrews Community Council (453889) • Change "Promote and enhance places and landscapes as economic drivers and tourist destinations;" to "Promote and enhance appropriate places and landscapes as economic drivers and tourist destinations." • Change "Continue to protect the important landscape settings and historic cores of St. Andrews and Perth with green belts" to "Protect the important landscape settings and historic cores of St. Andrews and Perth with green belts".

GS Brown Construction (543112) • Whilst requesting no specific change express concern that the green belt concept is an anachronism in planning terms and is too blunt and rigid in its application, and that the proposed Perth green belt will rule out small scale infill type developments within the Perth Core zone.

Ryden for University of St. Andrews (548506) PLAN730 • Whilst requesting no specific change highlight that protection of St. Andrews landscape setting through the use of a green belt must be balanced with the need to ensure there is sufficient housing and employment land supply within St Andrews to allow its planned and measured expansion, thus securing the economic sustainability of the Town.

ENSURING EFFECTIVE RESOURCE MANAGEMENT AND PROMOTING AN ACCESSIBLE, CONNECTED AND NETWORKED REGION OBJECTIVES

Mr Kyffin Roberts (337567) and Royal Burgh of St. Andrews Community Council (453889) • Change "Promote transport linkages, infrastructure improvements and network improvements;" to "Promote transport linkages, infrastructure improvements and rail, bus and cycle path network improvements and extensions;".

Muirhead, Birkhill and Liff Community Council (548254) • In the objective ‘Promote transport linkages…’ include 'In particular the linking of air, bus and rail with each other and with the Park and Ride facilities such as Dundee West'.

Mr Kyffin Roberts (337567) and Royal Burgh of St. Andrews Community Council (453889) • Change "Ensure that new development makes best use of existing networks of infrastructure, movement corridors and ecosystems;" to "Ensure that new development is located to make best use of existing networks of infrastructure and movement corridors and to protect ecosystems;".

12 TAYPLAN STRATEGIC DEVELOPMENT PLAN CTC Right to Ride Network (450103) - PLAN837 • Whilst requesting no specific change express concern that the objective ‘Enhance the condition and connectivity of the networks of green spaces…’ could be used to force pedal cyclists off the existing roads infrastructure.

Ryden for University of St. Andrews (548506) PLAN732 • Whilst supporting the objective ‘Support the switch to a low carbon and zero waste economy’ the respondent considers that the plan should consider infrastructure for the creation of a suitable electricity grid to meet community demands to manage renewable energy generation, and consider establishment of more localised waste and resource management facilities.

Alyth Community Council (548872) • Whilst requesting no specific change, consider that the declaration that the need to fight climate change is central to TAYplan's strategy is strange and that the need to focus on the well-being of all the residents of this area should be central and foremost.

Summary of responses (including reasons) by planning authority:

RESPONSES TO REPRESENTATIONS SEEKING A CHANGE

GENERAL Emac Planning for (Angus Estates Ltd (445204); A & J Stephen Ltd – PLAN679 (445201); A & J Stephen Ltd/Bett Homes Ltd – PLAN728 (548522); Bett Homes Ltd – PLAN758 (548523); James Keiller Estates Ltd – PLAN710 (445203); JG Lang & Son (445206); L Porter (548383); M Batchelor (B)(548360); M Batchelor (K)(548301); Mr R Watson (445205) and Stewart Milne Homes (548524) – PLAN774 & PLAN775 (duplicate of PLAN774)) TAYplan consider the vision to be ambitious. Certainly that is the intention and the message set out in the Foreword. The issue of respondents seeking an increase in the growth of housing land requirement is considered in detail in Schedule 4 (Issue 15: Policy 5: Housing – Policy 5a+b scale and distribution). TAYplan does not consider any change to the Vision and Objectives necessary.

Penny Uprichard (344887) TAYplan considers that there are sufficient economic proposals for funding the Proposed Plan’s ‘visions'. Policies 3 and 4 of the Proposed Plan and their supporting text set out opportunities for economic growth, referring to specific proposals where these are of strategic importance to the region. Policy 8 of the Proposed Plan addresses funding issues, and acknowledges the impact of economic recession. TAYplan does not consider any change to the Vision and Objectives necessary.

St. Andrews Preservation Trust (547750) TAYplan considers that the Proposed Plan adequately takes account of changes in recent years. Changes to the economic situation are reflected throughout the Proposed Plan and TAYplan considers the strategy of the Plan, including the Strategic Development Areas to be deliverable. The closure of the Guardbridge Paper Mill and the possibility (at that stage) of the potential impact of the RAF leaving Leuchars were considered in preparing the Plan. The designation of Leuchars/Guardbridge as a Principal Settlement (Tier 3) and prioritisation of the reuse of previously developed land and buildings in Policy 1 of the Proposed Plan will support bringing Guardbridge Paper Mill back into use, as well as offering potential for the growth of Leuchars/Guardbridge more generally. It is noted that the Ministry of Defence 13 TAYPLAN STRATEGIC DEVELOPMENT PLAN announced in July 2011 that Leuchars will become a base for the Army. TAYplan does not consider any change to the Vision and Objectives necessary.

Wallace Planning Limited for National Grid (547863) TAYplan considers that the Proposed Plan as a whole adequately promotes the restoration and regeneration of brownfield sites. Policy 1: Location Priorities prioritises the reuse of previously developed land and buildings. It is not considered to be appropriate to contain specific reference to former gasworks sites in a Strategic Development Plan, particularly in the Vision and Objectives, although this may be appropriate for inclusion in Local Development Plans. Therefore TAYplan does not consider any change to the Vision and Objectives necessary.

VISION Ryden for University of St. Andrews (548506) – PLAN 722 Whilst it is recognised that the student population in the TAYplan area is significant, the higher and further education establishments are an important part of the economy. It is considered the objective ‘strengthen the economic base to support the renewable energy sector, commercialisation of the higher education and research sector, the region’s ports and for food research, forestry, life science, digital media and tourism’ is adequate. TAYplan’s Topic Paper 1: Vision and Objectives states that: ‘The Vision statement is about what the outcome will look like and gives rise to a series of objectives’ (paragraph 2.1, page 2) (001/SL/Doc46). This is the approach TAYplan have taken in the Proposed Plan and if this was to be changed, there would be a lack of clarity and consistency with the Plan’s objectives and the detail included within the Plan’s Policies. Therefore TAYplan does not consider any change to the Vision and Objectives necessary.

SUPPORTING SUSTAINABLE ECONOMIC DEVELOPMENT AND IMPROVING REGIONAL IMAGE AND DISTINCTIVENESS OBJECTIVES

A) Economic Strategy Emac Planning for (Angus Estates Ltd (445204); A & J Stephen Ltd – PLAN681 (445201); A & J Stephen Ltd/Bett Homes Ltd – PLAN729 (548522); Bett Homes Ltd – PLAN759 (548523); James Keiller Estates Ltd – PLAN712 (445203); Stewart Milne Homes (548524) – PLAN776) and Ryden for University of St. Andrews (548506) – PLAN 723 TAYplan does not consider it necessary for the objectives of the Proposed Plan to go into this level of detail. The wording sought by the respondents is covered within Policies 1 and 3 of the Proposed Plan and their supporting wording. Therefore TAYplan does not consider any change to the Vision and Objectives necessary.

Mr Kyffin Roberts (337567) and Royal Burgh of St. Andrews Community Council (453889) Regarding the wording ‘commercialisation of the higher education and research sector’ TAYplan considers that this wording is clarified by Paragraph 4 on Page 14 of the Proposed Plan. With regard to the wording ‘major economic drivers when referring to Principal Settlements ’TAYplan considers the objective to refer to the Principal Settlements generally, many of which will play an important role in supporting the region’s economy. The objective does not state all other Principal Settlements. Therefore TAYplan does not consider any change to the Vision and Objectives necessary.

Binn Eco Park (545071) TAYplan does not consider it necessary for the objectives of the Proposed Plan to go into this level of detail. Therefore TAYplan does not consider any change to the Vision and Objectives necessary. 14 TAYPLAN STRATEGIC DEVELOPMENT PLAN

Mr Roy de C Chapman (548419) TAYplan disagree with the respondent’s suggestion that the Proposed Plan is a tabletop exercise based on the premise that St. Andrews will be the sole economic driver for the whole of Fife. TAYplan are of the view that there are many economic drivers for Fife, both within and outside the TAYplan area. Proposals for additional golf courses in St. Andrews (and in the East Neuk) will be considered through the Local Development Plan process and planning applications. The Proposed Plan does not identify any specific need for such facilities. Therefore TAYplan does not consider any change to the Vision and Objectives necessary.

B) Provision of Land for Housing and Employment

Scottish Property Federation (444087) TAYplan consider the vision to be ambitious. Certainly that is the intention and the message set out in the Foreword. The issue of respondents seeking an increase in the growth of housing land requirement is considered in detail in Schedule 4 (Issue 15: Policy 5: Housing – Policy 5a+b scale and distribution). TAYplan does not consider any change to the Vision and Objectives necessary.

Barton Willmore for Scotia Homes (443102); GVA for David Wilson Homes (547268); Halliday Fraser Munro for Barratt Homes (548389); Homes for Scotland (442882); Smiths Gore for Errol Park Estate (442871); Smiths Gore for Mansfield Estate (442871); Emac Planning for (Angus Estates Ltd (445204); A & J Stephen Ltd – PLAN679 (445201); A & J Stephen Ltd/Bett Homes Ltd – PLAN728 (548522); Bett Homes Ltd – PLAN758 (548523); James Keiller Estates Ltd – PLAN710 (445203); JG Lang & Son (445206); L Porter (548383); M Batchelor (B)(548360); M Batchelor (K)(548301); Mr R Watson (445205); Stewart Milne Homes (548524) – PLAN774 & PLAN775 (duplicate of PLAN774)); Geddes Consulting for Lynch Homes - PLAN629, PLAN632 & PLAN638 (438726) and Geddes Consulting for Thomson Homes (445159); Royal Burgh of St. Andrews Community Council (453889); Ryden for University of St. Andrews (548506) – PLAN 724; Mr Ken Russell (406092); Mr Kyffin Roberts (337567); Andrew McCafferty for GD Strawson and J Farquharson (548151) Proposed Plan Policy 5 refers to providing an effective and generous supply of land through Local Development Plans. It is not considered necessary to replicate this in the objectives in the same level of detail. Likewise it would be considered to be going into too much detail to refer to mixed use development, community facilities, affordable housing and local demand in this objective, or provide details of what constitutes an effective supply of land, or to refer to meeting needs and demand over the lifetime of the Plan. Issues contained in these responses are considered in detail in another Schedule 4 (Issue 15: Policy 5: Housing – Policy 5a+b scale and distribution). TAYplan does not consider any change to the Vision and Objectives necessary.

15 TAYPLAN STRATEGIC DEVELOPMENT PLAN C) Deliverability

TMS Planning for (Mr Tim Esparon (345006) – PLAN187 & PLAN200 (duplicate of PLAN187); Campion Homes (546491); Mr James Thompson (345005); Mr Simon Wilson (345007) and Muir Homes Ltd (346675)) TAYplan consider that the comments raised with regard to deliverability are adequately covered in the Objectives by reference to an effective supply of land. How the Plan, and indeed how Local Development Plans, are delivered is the role of Action Programmes. TAYplan does not consider any change to the Vision and Objectives necessary.

D) Spatial Strategy

TMS Planning for (Mr Tim Esparon (345006) – PLAN187 & PLAN200 (duplicate of PLAN187); Campion Homes (546491); Mr James Thompson (345005); Mr Simon Wilson (345007) and Muir Homes Ltd (346675)) TAYplan considers the wording proposed by the respondents regarding rural communities to be too detailed to be included as an objective, and considers the existing wording to be appropriate and consistent with Scottish Planning Policy. TAYplan considers that an objective to facilitate development outwith principal settlements is unnecessary and is covered by the objective “Facilitate appropriate development in rural communities…” and Policy 1 of the Proposed Plan. TAYplan does not consider any change to the Vision and Objectives necessary.

E) Other

Lynne Palmer (443979) The minor grammatical change requested by the respondent is not considered to make any difference to the meaning or operation of the Plan. TAYplan does not consider any change to the Vision and Objectives necessary.

ENSURING THE QUALITY OF PLACE THROUGH BETTER DEVELOPMENT OUTCOMES OBJECTIVES

Mr Kyffin Roberts (337567) and Royal Burgh of St. Andrews Community Council (453889)

TAYplan consider that there are appropriate safeguards in the Proposed Plan to protect places and landscapes, particularly Policy 2: Shaping better quality places (F) with regard to design issues and Policy 3: Managing TAYplan’s Asset’s with regard to natural and historic assets and green belt. The use of the word ‘continuing’ in relation to green belt at St. Andrews is considered to be appropriate in view of the fact that green belt has been allocated in the Finalised draft St. Andrews East Fife Local Plan which is anticipated to be approved in advance of the Strategic Development Plan. TAYplan does not consider any change to the Vision and Objectives necessary.

GS Brown Construction (543112)

The Vision and Objectives accord with Scottish Planning Policy (Pages 32-33, Paragraphs 159-164) (001/SL/Doc47) with respect to green belt, and need to be considered alongside Policy 3 of the Proposed Plan. Scottish Planning Policy specifies that the strategic development plan “should establish the need for a green belt, identify its broad area and set the policy for future development within it. Local Development Plans should establish the detailed boundaries of the green belt and identify types of development which are appropriate within the green belt. The issues raised by this respondent are addressed more 16 TAYPLAN STRATEGIC DEVELOPMENT PLAN fully in Issue 8 – Policy 3: Managing TAYplan’s Assets (green belts). TAYplan does not consider any change to the Vision and Objectives necessary.

Ryden for University of St. Andrews (548506) PLAN730

The respondent requests no specific change be made. TAYplan acknowledges that green belts should reflect long term settlement strategy and ensure that settlements are able to accommodate planned growth in accordance with Scottish Planning Policy (Page 33 Paragraph 162) (001/SL/Doc48). TAYplan considers that the Proposed Plan provides the appropriate policies and proposals to achieve this. TAYplan does not consider any change to the Vision and Objectives necessary.

ENSURING EFFECTIVE RESOURCE MANAGEMENT AND PROMOTING AN ACCESSIBLE, CONNECTED AND NETWORKED REGION OBJECTIVES

Mr Kyffin Roberts (337567) and Royal Burgh of St. Andrews Community Council (453889) The suggested inclusion of additional text regarding bus, rail and cycle path improvements is considered too detailed for the Vision and Objectives of a strategic plan. The change requested for clarity regarding ecosystems is considered to be minor and unlikely to affect the implementation of the Plan’s strategy and policies. Therefore TAYplan does not consider any change to the Vision and Objectives necessary.

Muirhead, Birkhill and Liff Community Council (548254) The suggested inclusion of additional text is considered to be implicit in the reference in the objective to ‘Promote transport linkages’ and is considered too detailed for the Vision and Objectives of a strategic plan. TAYplan does not consider any change to the Vision and Objectives necessary.

CTC Right to Ride Network (450103) - PLAN837 The objective referred to highlights that potential uses of green spaces and watercourses may include cycling and walking. It does not suggest that cyclists should use these instead of existing roads infrastructure. The objective ‘Promote transport linkages…’ promotes improvements that bring about a shift towards non-car travel, including cycling. Therefore TAYplan does not consider any change to the Vision and Objectives necessary.

Ryden for University of St. Andrews (548506) PLAN732 The respondent requests no specific change be made. TAYplan considers that the level of detail referred to by the respondent is not appropriate in the Objectives of the Plan. Policy 6: Energy and Waste/Resource Management Infrastructure of the Proposed Plan provides more detail on these matters and the issues are addressed in Schedule 4 Issue 20 Policy 6: Energy and Waste/Resource Management Infrastructure – Policy 6a+b, text and general (inc. whole policy) and Issue 21 Policy 6: Energy and Waste/Resource Management Infrastructure – Policy 6c). TAYplan does not consider any change to the Vision and Objectives necessary.

Alyth Community Council (548872) The declaration referred to (in the Foreword of the Proposed Plan) is considered to be wholly appropriate. Scottish Planning Policy (Page 8, Paragraph 41) (001/SL/Doc49) highlights that the need to tackle climate change is a principal challenge of sustainable economic growth. TAYplan also considers that a wide range of other factors relating to the well-being of the region’s residents are also fundamental to the strategy of the Proposed Plan. These are reflected in the Objectives on Page 6 of the Proposed Plan.

17 TAYPLAN STRATEGIC DEVELOPMENT PLAN RESPONSES TO REPRESENTATIONS SUPPORTING AS WRITTEN

Bidwells for Zurich Assurance Ltd (442149), JWK Properties for J Khazaka (327210), Scottish Environment Protection Agency (442031), Auchterarder and District Community Council (419429), SEStran Regional Transport Partnership (547388), Colliers International for (Persimmon Homes Ltd (416017), Gleneagles Hotel (337727), Kingsbarns Community Council (263542), Taylor Wimpey East Scotland (541486), Scottish Wildlife Trust Angus and Dundee Members Centre (548745), Ryden for University of St. Andrews (548506) PLAN725/PLAN726/PLAN727/PLAN730/PLAN732, Hargest Planning Ltd (548948), NHS Tayside (547710), Scottish Property Federation (444087). Kingsbarns Community Council (263542), Montagu Evans (444081), CTC Right to Ride Network (450103) PLAN835/ PLAN836 and Scottish Natural Heritage (344848)

TAYplan welcomes the support for these issues.

OVERALL

TAYplan considers that all of the issues raised do not warrant any change to the Proposed Strategic Development Plan (June, 2011) and propose that the elements dealt with in this Schedule 4 Summary of Unresolved Issues remain as written and unchanged. The Plan’s vision and objectives should be concise statements, as set out within Circular 1/2009: Development Planning (001/SL/Doc50). Many of the changes being sought by respondents would make the objectives unnecessarily lengthy. The detail sits within the policies.

Reporter’s conclusions:

General 1. I agree with the authority that the plan’s vision and objectives should be concise statements, and that the detail should be contained in the individual policies. Changes to the text should therefore be made only where there are significant needs for correction, clarification or the making good of omissions, or where stated objectives are at odds with national policy.

2. Several representations seek a more ambitious strategy for growth. However, the strategy also has to be realistic and to be compatible with national policies. I consider that the vision and objectives strike a reasonable balance between ambition and realism. Specific aspects such as housing land supply, funding and the re-use of brownfield land are dealt with under the relevant policies in the proposed plan, and I do not consider there is a need to change the vision and objectives in relation to these.

Vision and economic strategy 3. Higher and further education are significant contributors to the regional economy, and ‘study’ is sufficiently different from the activities already specified in the vision to merit inclusion there. Similarly, the contribution of this sector to strengthening the economic base goes beyond the commercialisation of higher education and research, and the relevant objective would be expressed better in the alternative wording suggested by the University of St. Andrews. I do not agree with the authority that this would represent an unnecessary level of detail, or a reduction in clarity and consistency. These changes would require a net addition of only three words on page 6 (one in the vision and two in the objective).

4. Other suggested changes to the ‘Strengthen the economic base’ objective include adding references to business and employment opportunities and to low carbon technology. The

18 TAYPLAN STRATEGIC DEVELOPMENT PLAN general promotion of business and employment opportunities is implicit in a number of other objectives, such as ‘Plan for an effective supply of land for housing and employment’, and ‘Support an advanced, thriving and diverse economy’. The ‘Strengthen the economic base’ objective appears to be concerned with promoting particular sectors of the economy with good growth potential, and this focus would be blurred by turning it into a more general economic objective. On the other hand, adding a reference to low carbon technology would extend the objective into an additional sector which is different from renewable energy, but has significant potential to contribute to the vision of reducing the burden on the planet. The authority’s view is that it is not necessary to go into this level of detail, but the suggested change would be no more detailed than the examples already given in this objective. On balance, I consider that a reference to low carbon technology would be a worthwhile addition.

Provision of land for housing and employment 5. A variety of suggestions have been put forward for changes to the wording of the objective to ‘Plan for an effective supply of land for housing and employment’. These include adding the word ‘generous’ and references to a 5-year supply of land, affordable housing, meeting local needs and demand, mixed use development and community facilities. However, I agree with the authority that elaboration of what constitutes an effective land supply is more appropriately dealt with in the relevant policies elsewhere in the plan, and that there is no need to change this objective. Similarly, comments relating to strategic development areas are best dealt with under Issue 12, and do not justify any change to the objectives.

6. Representations about the objective beginning ‘Strengthen the critical mass of Dundee’ seek the deletion of the word ‘major’ from ‘major economic drivers’. However, I regard the objective as applying to the principal settlements collectively, and I consider that the economic contribution of individual settlements is more appropriately dealt with in Policy 1. There is therefore no need to change this objective.

Deliverability 7. Matters of delivery of the plan are dealt with in Policy 8 and in the Action Programme. The general concept of deliverability is implicit in the diagram on page 6, under the heading ‘what must occur to bring about this change’. I agree with the authority that there is no need to change the vision and objectives in this regard.

Spatial strategy 8. Representations seek a change in the wording of the objective, ‘Facilitate appropriate development in rural communities where job and service needs exist’, to read ‘Promote prosperous and sustainable rural communities in order to support local services and amenities, including the provision of additional housing and related development proportionate to local need, available infrastructure and environmental capacity’. The authority considers the proposed wording to be too detailed to be included as an objective, and maintains that the existing wording is consistent with Scottish Planning Policy (SPP).

9. SPP paragraph 92 sets out the Scottish Government’s broad aim for rural development. By taking a positive approach to new development, planning authorities can help to create the right conditions for rural businesses and communities to flourish. The aim should be to enable development in all rural areas which supports prosperous and sustainable communities whilst protecting and enhancing environmental quality. The policy is developed more fully in paragraphs 93 to 96, including a statement that the requirement for development plans to allocate a generous supply of land to meet housing requirements applies equally to rural and urban areas, and that development plans should support more opportunities for small scale housing development in all rural areas. 19 TAYPLAN STRATEGIC DEVELOPMENT PLAN 10. The existing wording of the objective on page 6 says nothing about housing, and implies that there are some rural communities that do not have job or service needs. I do not consider that it adequately reflects SPP, and recommend that the alternative wording proposed in the representations be adopted, subject to some editing to reduce the overall number of words while preserving the key messages. However, I consider that the amended objective would adequately cover development outside the principal settlements, and I do not support the representations seeking an additional objective for that purpose.

Promoting and enhancing places and landscapes 11. In the objective at the top of the diagram beginning ‘Promote and enhance’, the typographical error ‘towns centres’ should be corrected to ‘town centres’. Representations suggest adding ‘appropriate’ before ‘places and landscapes’, but I do not consider that necessary. It is implicit in a statement of objectives such as that on page 6 that they have to be balanced against one another, and that promotion of places and landscapes as economic drivers and tourist destinations would not be pursued where it undermined other objectives.

Green belts 12. In relation to the green belt objective beginning ‘Continue to protect’, representations suggest removing the word ‘continue’ on the basis that the St. Andrews green belt had not been defined, while others express concern that the green belt should allow sufficient housing and employment land supply to secure the economic sustainability of the town. However, the extent of the St. Andrews green belt and the policies that apply within it have been set out in the finalised local plan, and I consider the retention of the word ‘continue’ is appropriate. Another representation suggests that the green belt concept is an anachronism, but the use of green belts in appropriate circumstances is supported by SPP, and more detailed guidance within TAYplan is set out in Policy 3. There is therefore no need to change the objective.

Networks and transport linkages 13. Representations on the objective beginning ‘Promote transport linkages’ seek to add specific references to rail, bus, cycle paths, air, and park and ride. However, I agree with the authority that such references would add unnecessary detail to the vision and objectives, and I do not support any change to the wording of the objective. Neither do I see any need to change the objective ‘Ensure that new development makes best use of existing networks of infrastructure, movement corridors and ecosystems’. While representations suggest adding ‘to protect’ before ‘ecosystems’, the existing wording is entirely compatible with sustainable use, and there are other objectives which specifically protect biodiversity and natural resources.

14. The objective beginning ‘Enhance the condition and connectivity of the networks of green spaces’ has prompted concern that it could be used to force pedal cyclists off the existing roads infrastructure. While part of the objective is to support cycling and walking, however, it carries no necessary implication that cyclists would be compelled to use off-road routes, where they exist. I do not consider any change is needed in this objective.

Low carbon economy and climate change 15. Representations related to the objective beginning ‘Support the switch to a low carbon and zero waste economy by providing for appropriate infrastructure’ suggest electricity grid improvements and more localised waste management facilities. The appropriate place to consider such matters is under Issues 20 and 21 (Policy 6), and I do not consider there is any need to change the objective. The comment about the relative priority of fighting climate change and focussing on the well-being of residents does not seek any specific change. However, I consider that the stated objectives of TAYplan achieve a reasonable balance between these aims. 20 TAYPLAN STRATEGIC DEVELOPMENT PLAN Reporter’s recommendations:

Modify page 6 of the proposed plan as follows:

In the vision statement at the centre of the page, sixth line, after “work” insert:

“, study”.

Reword the objective beginning “Strengthen the economic base” as follows:

“Strengthen the economic base to support the renewable energy and low carbon technology sectors, the further and higher education sector including commercialisation and research, the region’s ports, food research, forestry, life sciences, digital media and tourism.”

In the objective at the top of the diagram beginning “Promote and enhance places”, fourth line, delete “towns” and insert:

“town”.

Reword the objective, “Facilitate appropriate development in rural communities where job and service needs exist”, to read:

“Promote prosperous and sustainable rural communities that support local services, including the provision of additional housing and related development proportionate to local need, available infrastructure and environmental capacity”.

21 TAYPLAN STRATEGIC DEVELOPMENT PLAN

Issue 2 Proposals 1: Map

Development plan Reporter: Page 7: Proposals 1: Map reference: Mike Cunliffe Body or person(s) submitting a representation raising the issue (including reference number):

Seeking a Change

ID Representation Number Person/Organisation Reference Andrew McCafferty for GD Strawson and J 548151 Farquharson PLAN443 442149 Bidwells for Zurich Assurance Ltd PLAN660 548025 Campaign to Open Blackford Railway-station Again PLAN374 450613 Councillor Michael A Barnacle PLAN811 549276 Dr Eric Thain PLAN912 548525 Dr Peter Symon PLAN896 546838 Kinross-shire Civic Trust PLAN492 444081 Montagu Evans PLAN320 548414 Miss Lynn McGeorge PLAN603 Montgomery Forgan Associates for Headon 349140 Developments Ltd PLAN606 540188 Mr Colin R. McLeod PLAN30 546652 Mr Howard Greenwell PLAN254 337567 Mr Kyffin Roberts PLAN507 545456 Mr Neil Anderson PLAN142 546019 Mr Nigel Mullan PLAN185 545848 Mr Ralph Barker PLAN483 377831 Mrs Judith Harding PLAN499 377831 Mrs Judith Harding PLAN500 542448 Miss Nicola Barrie PLAN73 548737 Mr Willie Rennie MSP PLAN804 546314 Newburgh Train Station Campaign PLAN204 344887 Penny Uprichard PLAN872 344887 Penny Uprichard PLAN877 535502 Rail Freight Group PLAN90 547522 Railfuture Scotland PLAN281 453889 Royal Burgh of St. Andrews Community Council PLAN917 548506 Ryden for University of St. Andrews PLAN737 548506 Ryden for University of St. Andrews PLAN739 443918 Scottish Government PLAN597 443918 Scottish Government PLAN666 547750 St. Andrews Preservation Trust PLAN304 546345 Starlink (St. Andrews Rail Link) Campaign PLAN259 539251 Stewart Milne Homes PLAN311 441235 Tactran Regional Transport Partnership PLAN120 548152 Wilson Adams PLAN433

22 TAYPLAN STRATEGIC DEVELOPMENT PLAN Support as written

ID Representation Number Person/Organisation Reference 419429 Auchterarder & District Community Council PLAN75 543847 Cllr Andrew Arbuckle PLAN97 544553 Cllr Tom Gray PLAN270 337727 Colliers International for Gleneagles Hotel PLAN51 541485 Colliers International for Lawrie and Symington Ltd PLAN347 543455 David Strachan PLAN92 379723 Dunning Community Council PLAN434 547333 Gee Roberts PLAN269 546061 Jane Murray PLAN186 546219 Jim Laughlan PLAN196 546010 Karen Bryce PLAN184 544846 Karl Barrs PLAN130 263542 Kingsbarns Community Council PLAN373 546538 Mary Mitchell PLAN235 Montgomery Forgan Associates for Headon 349140 Developments Ltd PLAN604 547787 Ms Elizabeth Smith MSP PLAN305 548911 Mr John Park MSP PLAN830 547801 Mr Murdo Fraser MSP PLAN307 546436 Mr Roderick Campbell MSP PLAN209 548506 Ryden for University of St. Andrews PLAN732 344939 Scottish Enterprise PLAN422 546005 William Murray PLAN183 Provision of the The Proposals Map shows proposals for how the region will develop development plan over the plan period, including strategic development areas and to which the issue transport projects. relates: Planning authority’s summary of the representation(s):

SUMMARY OF REPRESENTATIONS SEEKING A CHANGE

RAIL PROPOSALS Rail Freight Group (535502) has requested that the Proposed Plan should give rail freight equal weight to sea freight in managing TAYplan’s transport assets. They consider that Tayside will be potentially more vulnerable than most other regions of Scotland as it has no active rail freight facilities e.g. Dundee, one of the largest cities in Britain has no such facilities. Although sea freight alternatives to road haulage are available in Tayside, these are considered unlikely to offer the high-quality domestic logistics and distribution role which rail performs already in Central Scotland and to Aberdeen and Inverness. They propose that land should therefore be identified as strategic rail locations at Montrose station, Dundee West, Perth South and around Blackford station.

Mr Nigel Mullan (546019); Mr Neil Anderson (545456); Newburgh Train Station Campaign (546314); Wilson Adams (548152); Miss Nicola Barrie (542448); Mr Ralph Barker (545848) and Mr Willie Rennie MSP (548737) seek for greater priority to be given to the re-opening of Newburgh rail station. Newburgh Train Station Campaign (546314) note that since previous studies were undertaken changing circumstances have increased prospects for a station, including increased frequency of trains passing through Newburgh, providing the basis for a service of perhaps 10 stops in each direction. The existing service

23 TAYPLAN STRATEGIC DEVELOPMENT PLAN would allow a station to be viably operated and maintained, improving railway finances. Costs for land purchase and any signalling changes required are estimated to have dropped from previous estimates. Potential carbon dioxide savings are highlighted. Newburgh Train Station Campaign consider that a single new station strategy (i.e. only at Newburgh, rather than Newburgh plus Bridge of Earn/Oudenarde) would be critical to avoid the need for additional capital costs. Mr Neil Anderson (545456); Newburgh Train Station Campaign (546314) and Wilson Adams (548152) state that there is potential to reopen Newburgh station without increasing journey times, including transferring other stops e.g. Ladybank. Mr Neil Anderson (545456); Mr Willie Rennie MSP (548737) and Mr Nigel Mullan (546019) highlight that Newburgh is the largest town in Fife next to a railway line without a rail station. Wilson Adams (548152); Mr Willie Rennie MSP (548737); Miss Nicola Barrie (542448) and Mr Nigel Mullan (546019) highlight local population increases and strong local support for the proposal. Mr Neil Anderson (545456) and Miss Nicola Barrie (542448) highlight that the proposal would have a dramatic economic impact, particularly through tourism as work on the Fife Coastal Path commences. Miss Nicola Barrie (542448) states that there is already existing ground for parking.

Scottish Government (443918) – PLAN597 seek the removal of reference to proposed new rail stations at Bridge of Earn, Newburgh and Wormit. Transport Scotland is responsible for the development of the rail network and has no plans to promote or develop proposals for providing railway stations at Bridge of Earn, Newburgh and/or Wormit. In this regard the Proposed Plan is not co-ordinated with Transport Scotland's investment plans as required by the Planning Circular 1/2009 - Development Planning. These railway station proposals would likely have a negative impact on the national priorities to improve rail journey times from the Central Belt to Inverness and Aberdeen, as identified in the Scottish Government's Strategic Transport Projects Review (2008). Retaining the railway stations in the Proposed Plan risks the planning authority blighting the land and misleading developers and others, as to the possibility of accessing any such station(s) at some point in the future. No evidence has been supplied to Transport Scotland to demonstrate that the points raised in Scottish Planning Policy paragraph 176 have been considered regarding these railway stations, nor evidence to demonstrate that the stations have resulted from appraisal which is robust, based on objective-led analysis and consistent with the approach set out in Scottish Transport Appraisal Guidance. This should include consideration of alternative solutions that may also address the identified problems and opportunities in the locations identified. Transport Scotland has received no evidence that these railway stations have robust business cases prepared in accordance with Scottish Transport Appraisal Guidance and Network Rail's Investment in Stations guidance (May 2011). No evidence has been supplied to explain how the capital cost will be funded or whether there are ongoing revenue subsidy costs of operating the railway stations and any rail services using these locations, and if so, how these will be funded.

Mr Ralph Barker (545848); Mrs Judith Harding (377831); Railfuture Scotland (547522); Starlink (St. Andrews Rail Link) Campaign (546345); Royal Burgh of St. Andrews Community Council (453889); Mr Kyffin Roberts (337567); Mr Howard Greenwell (546652) – PLAN254; St. Andrews Preservation Trust (547750) and Penny Uprichard (344887) – PLAN 877 consider that land should be safeguarded for a rail link/railway and station for St. Andrews. Railfuture Scotland (547522) and Starlink (St. Andrews Rail Link) Campaign (546345) highlight that St. Andrews is an important location for the TAYplan economy, whilst a railway is the most likely way to achieve a modal shift away from car use. Mr Howard Greenwell (546652) suggests that the proposal should allow for electrification of the line. St. Andrews Preservation Trust (547750) notes that there may be conflicts with other proposals identified in the Proposed Plan and the need to mitigate against increased traffic congestion. Mr Kyffin Roberts (337567) highlights the need for appropriate infrastructure to support the scale of proposed development in the town, 24 TAYPLAN STRATEGIC DEVELOPMENT PLAN reducing reliance on the car, the need to reduce carbon emissions, and the psychological barrier of the distance to Leuchars to the use of public transport.

Campaign to Open Blackford Railway-station Again (548025) and Mr Ralph Barker (545848) seek the reopening of Blackford rail station and consider that concentrating on Gleneagles in preference to Blackford contradicts the conclusions of the independent report Blackford Railway Station – Business Case and Market Demand for Station Re-Opening produced by AECOM (April 2010). The proposed station would serve a major development and help negate increased greenhouse gases. The response notes the environmental benefits of electrification of the rail network and states that electrification should include the Dunblane-Blackford-Gleneagles-Perth line.

Kinross-shire Civic Trust (546836) seek the resurrection of the Perth – Kinross – Edinburgh rail link as vital for the future considering sustainability issues, which would have major impacts on settlements along its length.

Mr Ralph Barker (545848) has provided a number of other transport proposals for the TAYplan area, including: • Perth Station Enhancement – protect the present capacity of the station against any adverse development; • There should be a direct rail route between Perth and Edinburgh (long-term policy); • In addition to Newburgh and Blackford railway stations, Abernethy should be reopened; and, • A mention should be made within the Proposed Plan that a more direct deviation may be the best solution for the Usan, Montrose rail double-tracking.

ROAD PROPOSALS Kinross-shire Civic Trust (546836) and Councillor Michael A Barnacle (450613) seek recognition on the Proposals Map of the A977 linking Kinross-shire to the Kincardine Bridge, Glasgow and the South and South West.

Dr Peter Symon (548525) proposes that the Proposals Map and accompanying text to contain a reference to the proposed new bridge over the River Tay north of Perth and its concomitant development opportunities in terms of transport infrastructure, employment land, housing land and energy infrastructure.

Bidwells for Zurich Assurance Ltd (442149) have general support for the vision and objectives but believes that the Proposed A9/A94 and A9/A85 proposals are cost negative and will not contribute to the objective of reducing travel. Greater emphasis should be placed on upgrading public transport, including train services within the Perth Core, and to Pitlochry, Inverness and Edinburgh.

Penny Uprichard (344887) – PLAN 872 notes that there is no sign of the St. Andrews ‘distributor road’.

Mr Colin R. McLeod (540188) seeks deletion of reference to the new bridge over the River Tay linking the A9 and A94 due to a lack of strategic thinking about the impact on traffic flows along roads linking to the new bridge and on communities along these routes. The A94 is not dual carriageway and is not currently suited to large volumes of heavy traffic. The eventual outcome would require a series of new bypasses through Strathmore.

LEUCHARS AIRFIELD St. Andrews Preservation Trust (547750) and Dr Eric Thain (549276) seek the use of the airfield at Leuchars as a commercial airport. Dr Eric Thain (549276) highlights recent 25 TAYPLAN STRATEGIC DEVELOPMENT PLAN investment in aircraft facilities, proximity to Dundee and examples of other ex-military air bases from which commercial airlines have operated.

STRATEGIC DEVELOPMENT AREAS Montgomery Forgan Associates for Headon Developments Ltd (349140) and Ryden for University of St. Andrews (548506) – PLAN 737 seek changes to the description of the St. Andrews West and Science Park Strategic Development Area to ‘St. Andrews West and Science/Research/University Park’.

Royal Burgh of St. Andrews Community Council (453889) and Mr Howard Greenwell (546652) seek the removal of St. Andrews West and Science Park from the Proposals Map. Royal Burgh of St. Andrews Community Council (453889) state that failing this ‘St. Andrews West and Science Park’ should be changed to ‘St. Andrews West’ with consideration given to locating the Science Park at Guardbridge former paper mill. It is also proposed that in the legend ‘The Strategic Development Areas’ be changed to ‘Approximate locations of Strategic Development Areas’.

Ryden for University of St. Andrews (548506) – PLAN 739 seek the inclusion of Guardbridge Energy Centre within the Proposals Map.

Stewart Milne Homes (539251) seek the inclusion of Auchterarder as a strategic growth area on the Proposals Map highlighting delivery issues with identified Strategic Development Areas and the potential for further development at Auchterarder.

Montagu Evans (444081) states that the identification of Strategic Development Areas should not preclude development elsewhere. It is important for effective land to be considered for development on sites that offer the opportunity for sustainable development.

Issues relating to the Strategic Development Areas are addressed in Schedules: 12 – Policy 4: Strategic Development Areas (Policy 4a strategic allocations), 13 – Policy 4: Strategic Development Areas (alternative sites) and 14 – Policy 4: Strategic Development Areas (Policy 4b text and general). Any modifications arising in Policy 4 could have a consequential change to the Proposals Map.

GREENBELT Miss Lynn McGeorge (548414) whilst supporting the approach of protecting the landscape of Perth and Kinross has concerns at the exclusion of areas worth protecting, in particular Luncarty, Redgorton, Stanley and Stormontfield.

Andrew McCafferty for GD Strawson and J Farquharson (548151) considers that the Proposals Map “bubble” inset is insufficiently clear to understand the area/location of green belt around/on the edge of the eastern side of Perth. Should be clarified by relating to a physical feature or settlement.

Penny Uprichard (344887) – PLAN 872 notes that arrows indicating green belt on the Proposals Map are virtually blotted out by the symbol for the St. Andrews West and Science Park Strategic Development Area. Issues relating to the green belt are also addressed in Schedule Issue 8 – Policy 3: Managing TAYplan’s Assets (Greenbelts). Any modifications arising in Policy 3 - Greenbelt could have a consequential change to the Proposals Map.

OTHER – MISCELLANEOUS Tactran Regional Transport Partnership (441235) highlight that the Proposals Map omits identification of a location for the Proposed Dundee West Strategic Park and Ride site, as 26 TAYPLAN STRATEGIC DEVELOPMENT PLAN identified in the Regional Park & Ride Strategy and Strategic Transport Projects Review (2008).

Andrew McCafferty for GD Strawson and J Farquharson (548151) considers that the extent/location of undeveloped coast, particularly on the north side of the River Tay, is so clear as to be indecipherable. It is not understood what is meant by undeveloped coast and its application to the Proposals Map. The respondent requests the symbol be deleted from the diagram.

Scottish Government (443918) - PLAN666 seeks inclusion on page 18 of a reference to the pipeline to transfer CO2 from Longannet in Fife to St. Fergus in Aberdeenshire through carbon capture and storage.

SUMMARY OF REPRESENTATIONS SUPPORTING AS WRITTEN

GENERAL

Auchterarder & District Community Council (419429) Support the Proposals Map in its present form.

Dunning Community Council (379723) Support the improvements to the road and rail infrastructure.

Scottish Enterprise (344939) Support the proposals in terms of strategic sustainable economic development impact.

RAIL PROPOSALS

Cllr Andrew Arbuckle (543847); David Strachan (543455); Karl Barrs (544846); Karen Bryce (546010); Jane Murray (546061); Jim Laughlan (546219); Mr John Park MSP (548911); Mr Murdo Fraser MSP (547801); Mr Ralph Barker (545848); Mr Roderick Campbell MSP (546436) and Ms Elizabeth Smith (547787) Support the proposed new rail station at Newburgh. Reasons given in support of the proposal include: • strong local support for the proposal; • forecast local population increases; • assisting viability of existing services; • increased frequency of trains passing through Newburgh in recent years; • environmental benefits through reducing road traffic; • benefits for commuters; • increased accessibility and social benefits; • economic benefits; • existing station with ground for parking makes proposal more cost effective than other proposals; • Newburgh is the largest town in Fife next to a railway line without a rail station; and, • Other recent station re-openings have proved more successful than expected.

Mr Ralph Barker (545848) Support is given for for railway stations at Wormit and Oudenarde, and for a new railway station at Dundee West / Ninewells Hospital, however Invergowrie station should be retained.

Auchterarder & District Community Council (419429); Cllr Tom Gray (544553); Colliers International for Gleneagles Hotel (337727); Dunning Community Council (379723); Gee Roberts (547333); Mary Mitchell (546538); Mr Ralph Barker (545848) and William 27 TAYPLAN STRATEGIC DEVELOPMENT PLAN Murray (546005) Support the proposed enhancement of Gleneagles station. Reasons given in support of the proposal include: • Existing access issues – access to and from the A9 road is dangerous; • Historic building has fallen into disrepair; • Well used station and more houses planned; • Proposal makes more sense than a new station at Blackford; • Improvements would increase use of the station; • Station serves many surrounding communities; • Proposal can reduce traffic on the A9 and parking congestion at other stations; • Will improve accessibility and connectivity of the area supporting longer term growth; and, • Speedy progress needed to be ready for Ryder Cup in 2014.

STRATEGIC DEVELOPMENT AREAS Montgomery Forgan Associates for Headon Developments Ltd (349140) Support the identification of the Strategic Development Area at St. Andrews West.

Colliers International for Lawrie and Symington Ltd (541485) Support in principle the identification of the strategic development area for Forfar Regional Agricultural Service Centre as a basis for future discussion and examination, recognising the potential opportunity to utilise land and resources in a principal market town of Angus.

Ryden for University of St. Andrews (548506) Support proposals in St. Andrews for a distributor road and for consideration of integrated transport solutions such as bus and rail.

OTHER – MISCELLANEOUS Kingsbarns Community Council (263542) Support undeveloped coast covering East Neuk of Fife in the Proposals Map.

Modifications sought by those submitting representations:

NOTE TO REPORTER: The text in italics in this section has been lifted directly from the each individual/organisation’s representation with minor typographical errors corrected.

RAIL PROPOSALS Rail Freight Group (535502) • Suggest that land at Montrose station, Dundee West (see separate RFG representation on Proposed Action Programme 2011), Perth South and around Blackford station also be specifically identified as potentially strategic locations to support resource management objectives and reduced reliance on road-based freight.

Mr Nigel Mullan (546019), Mr Neil Anderson (545456), Newburgh Train Station Campaign (546314), Wilson Adams (548152), Miss Nicola Barrie (542448), Mr Ralph Barker (545848) and MSP Willie Rennie (548737) • Seek for greater priority to be given to the re-opening of Newburgh rail station through the Proposed Plan and associated Action Programme.

Scottish Government (443918) • Remove reference to proposed new railway stations at Bridge of Earn, Newburgh and Wormit.

Mr Ralph Barker (545848); Mrs Judith Harding (377831), Railfuture Scotland (547522), Starlink (St. Andrews Rail Link) Campaign (546345), Royal Burgh of St. Andrews 28 TAYPLAN STRATEGIC DEVELOPMENT PLAN Community Council (453889), Mr Kyffin Roberts (337567), Mr Howard Greenwell (546652), St. Andrews Preservation Trust (547750) and Penny Uprichard (344887) – PLAN 877 • include a proposed railway station for St. Andrews and a rail link to the main rail line, with a corresponding addition to the legend, and for land to be safeguarded as such.

Mr Howard Greenwell (546652) • The proposal (for a St. Andrews rail link) should allow for electrification of the line.

Campaign to Open Blackford Railway-station Again (548025):- • No specific change to the plan is identified but concern expressed that there are no references in the Proposed Plan to opening Blackford Railway Station within the 2012-2032 plan period.

Mr Ralph Barker (545848) • Mention Blackford Railway station re-opening.

Kinross-shire Civic Trust (546836) • Add a proposal for the Perth - Kinross - Edinburgh rail link.

Mr Ralph Barker (545848) • Perth Station Enhancement – protect the present capacity of the station against any adverse development; • Direct (rail) route between Perth and Edinburgh (Former Glenfarg route) long-term policy; • In addition to Newburgh and Blackford railway stations, Abernethy should be reopened; and, • Proposed Plan should mention that a more direct deviation may be the best solution for the Usan, Montrose rail double-tracking.

ROAD PROPOSALS Kinross-shire Civic Trust (546836) and Councillor Michael A Barnacle (450613) • Add a proposal for recognition on the Proposals Map of the A977 linking Kinross-shire to the Kincardine Bridge, Glasgow and the South and South West.

Dr Peter Symon (548525) • The Proposals Map and accompanying text should contain a reference to the proposed new bridge over the Tay north of Perth and its concomitant development opportunities in terms of transport infrastructure, employment land, housing land and energy infrastructure.

Bidwells for Zurich Assurance Ltd (442149) • Greater emphasis should be placed on upgrading public transport, including train services within the Perth Core. The respondent also expresses concerns that the Proposed A9/A94 and A9/A85 proposals are cost negative and will not contribute to the objective of reducing travel.

Penny Uprichard (344887) – PLAN 872 • Requests no specific change but notes that there is no sign of the St Andrews ‘distributor road’. • Mr Colin R. McLeod (540188) • Delete reference to new bridge over the Tay River (sic) linking A9 & A94. 29 TAYPLAN STRATEGIC DEVELOPMENT PLAN LEUCHARS AIRFIELD St. Andrews Preservation Trust (547750) • Requests no specific change but notes the benefits of developing commercial air services at Leuchars.

Dr Eric Thain (549276) • Revisions to the Strategic Development Plan should include a satisfactory utilisation of the Leuchars air facilities.

STRATEGIC DEVELOPMENT AREAS Montgomery Forgan Associates for Headon Developments Ltd (349140) and Ryden for University of St. Andrews (548506) – PLAN 737 • Change the description of the St. Andrews West and Science Park Strategic Development Area to St Andrews West and Science/Research/University Park.

Royal Burgh of St. Andrews Community Council (453889) and Mr Howard Greenwell (546652) • Remove St. Andrews West and Science Park from the Proposals Map and corresponding legend. Royal Burgh of St. Andrews Community Council (453889) state that failing this Change “St. Andrews West and Science Park’” to “St. Andrews West”.

Royal Burgh of St. Andrews Community Council (453889) • Change “The Strategic Development Areas;” to “Approximate locations of Strategic Development Areas;”.

Ryden for University of St. Andrews (548506) – PLAN 739 • Include Guardbridge Energy Centre within the Proposals1: Map.

Stewart Milne Homes (539251) • Stewart Milne Homes proposes Auchterarder to be included as a strategic growth area and identified as such within the Proposals Map.

Montagu Evans (444081) • Requests no specific change but raises concerns that the identification of Strategic Development Areas should not preclude development elsewhere.

GREENBELT Miss Lynn McGeorge (548414) • Requests no specific change but raises concerns at the exclusion from greenbelt of areas worth protecting, in particular Luncarty, Redgorton, Stanley and Stormontfield.

Andrew McCafferty for GD Strawson and J Farquharson (548151) • The "bubble" inset is insufficiently clear to be able to understand the area/broad location of proposed green belt around/on the edge of the eastern side of Perth. Also, the extent/location of "Undeveloped Coast" particularly on the north side of the Tay is so unclear as to be indecipherable. I request that the broken green line is clarified by, for example, relating it to a physical feature/settlement "on the ground".

Penny Uprichard (344887) – PLAN 872 • Requests no specific change but notes that arrows indicating green belt on the Proposals Map are virtually blotted out by the symbol for the St. Andrews West and Science Park Strategic Development Area. 30 TAYPLAN STRATEGIC DEVELOPMENT PLAN OTHER – MISCELLANEOUS Tactran Regional Transport Partnership (441235):- • The Proposals Map omits identification of a location for the Proposed Dundee West element of the package of Strategic Park and Ride sites around Dundee. It is recommended that this location should be identified.

Andrew McCafferty for GD Strawson and J Farquharson (548151):- • It is not possible to understand what is meant by the term "Undeveloped Coast" and its application to Proposals 1:Map so I request that this symbol is deleted altogether from the diagram.

Scottish Government (443918) – PLAN666 • Include on page 18 a reference to the pipeline to transfer CO2 from Longannet in Fife to St Fergus in Aberdeenshire through carbon capture and storage. If necessary this could be as part of a footnote.

Summary of responses (including reasons) by planning authority:

RESPONSES TO REPRESENTATIONS SEEKING A CHANGE

RAIL PROPOSALS

Rail Freight Group (535502) The issue of giving rail freight equal weight to sea freight is dealt with under Schedule 4 Issue 11 – Policy 3: Managing TAYplan’s Assets: Transport.

Rail Freight Group (535502); Mr Ralph Barker (545848); Mrs Judith Harding (377831); Railfuture Scotland (547522); Starlink (St. Andrews Rail Link) Campaign (546345); Royal Burgh of St. Andrews Community Council (453889); Mr Kyffin Roberts (337567); Mr Howard Greenwell (546652) – PLAN254; St. Andrews Preservation Trust (547750); Penny Uprichard (344887) – PLAN 877; Campaign to Open Blackford Railway-station Again (548025) and Kinross-shire Civic Trust (546836) TAYplan considers that the projects and proposals outlined by the respondents above should not be identified on the Proposals Map. The Proposed Plan recognises that new development will need to be supported by transport infrastructure, and also highlights the benefits of this in terms of contributing to behavioural change and reducing reliance on road based travel.

The projects and proposals for transport infrastructure projects specified within the Proposed Plan (set out in Proposal 1: Map and explained in the Proposed Action Programme) are based on those set out in Scottish Government’s National Planning Framework 2 (2009) (CL/Doc1) and Strategic Transport Projects Review (2008) (CL/Doc53), and the two Regional Transport Strategies which cover the TAYplan region - Sestran (2008) (CL/Doc22) and Tactran (2008) (CL/Doc21).

Policy 3: Managing TAYplan’s assets (Transport) requires Local Development Plans to ensure that appropriate land is safeguarded for future infrastructure provision identified in the Proposals Map, that which is integral to a Strategic Development Plan Area, or which is essential to support a shift from reliance on the car and road-based freight, as well as at the region’s ports and harbours (as appropriate) to support freight and other port related uses.

With regard to projects and proposals requested by the respondents listed above, such schemes or projects that would require the safeguarding of land and/or routes for new or 31 TAYPLAN STRATEGIC DEVELOPMENT PLAN improved infrastructure not covered by the above categories will be determined, as a consequence of this policy, through future iterations of Regional Transport Strategies/Strategic Development Plans. Proposals such as passenger rail facilities for St. Andrews, Blackford and Abernethy, a Perth to Edinburgh rail link via Kinross, and strategic freight rail locations at Montrose station, Dundee West, Perth South and land around Blackford station could be examples of this.

The Tactran Tay Estuary Rail Study (2003) (CL/Doc48 and 57) identifies enhancing Gleneagles Station as a preference to re-opening Blackford Station.

The Proposed Action Programme (October 2011) (Page 15) (CL/Doc37) provides details of rail service enhancements between Aberdeen and the central belt. The 2nd phase of this includes upgrading single track to double track at Usan, including a new bridge over Montrose Basin.

TAYplan does not consider any change to the Proposals Map necessary.

Mr Nigel Mullan (546019); Mr Neil Anderson (545456); Newburgh Train Station Campaign (546314); Wilson Adams (548152); Miss Nicola Barrie (542448); Mr Ralph Barker (545848) and Mr Willie Rennie MSP (548737) The Proposed Plan identifies a new rail station at Newburgh as one of several proposals important to the delivery of the Proposed Plan. Work related to this, and the prioritisation given to the project, is detailed in the updated Proposed Action Programme (October 2011 Page 28, Action 26) (CL/Doc37). This increases the priority given to the re-opening of Newburgh rail station when compared to the Proposed Action Programme (June 2011) to be consistent with other new rail stations proposed. The Plan does not deal with prioritisation but gives support to the scheme therefore no change is proposed. The actions related to proposals for new rail stations is to ‘undertake a transport appraisal for these areas’.

Scottish Government (443918) – PLAN597 The proposed new rail stations that the Scottish Government has asked to be removed from the Proposals Map are all current proposals within existing Structure Plans. A new station at Oudenarde is within the Perth & Kinross Structure Plan (2003) (CL/Doc46) and Newburgh and Wormit within the Fife Structure Plan (May 2009) (CL/Doc39). Both documents are approved by Scottish Ministers. All proposed stations are important to the long term sustainable strategy of TAYplan. Whilst currently not within the Scottish Government’s Strategic Transport Projects Review (2008) (CL/Doc53), these proposals are an important component of TAYplan’s strategy. It is considered appropriate to include these proposals.

The Proposed Action Programme (October 2011) (CL/Doc37) sets out how the proposals will be taken forward, stating that these proposals will involve undertaking a transport appraisal for the areas identified, highlighting the requirement for STAG appraisal. Tactran and SEStran consider that any appraisal of a new rail station at either Newburgh or Oudenarde/Bridge of Earn should not be considered in isolation, but requires to be considered as part of the same appraisal due to their proximity, likely rail network impact and overlapping catchment areas.

TAYplan disagrees that safeguarding land for these proposals risks blighting land. Therefore TAYplan does not consider any change to the Proposals Map necessary.

ROAD PROPOSALS Kinross-shire Civic Trust (546836) and Councillor Michael A Barnacle (450613) There are currently no proposals for strategic improvements to the A977 other than targeted road safety measures. The need for other improvements to this route will be considered through 32 TAYPLAN STRATEGIC DEVELOPMENT PLAN Local Development Plans and/or Regional Transport Strategies. Therefore TAYplan does not consider any change to the Proposals Map necessary.

Dr Peter Symon (548525); Bidwells for Zurich Assurance Ltd (442149) and Mr Colin R. McLeod (540188) The Proposals Map contains a reference to the proposed A9/A94 link and further detail is provided within the Proposed Action Programme (Page 25 Action 20) (CL/Doc37). The Proposed Action Programme October 2011 (Page 25, Action 20) (CL/Doc37) highlights that this proposal is required to enhance accessibility around Perth, facilitate development of West/North West Perth, one of TAYplan’s Strategic Development Areas. The proposal would also increase accessibility and connectivity, whilst improving air quality in Perth town centre (an Air Quality Management Area). A STAG report has been prepared and consulted upon, and a Strategic Environmental Assessment has also been prepared. Therefore TAYplan does not consider any change to the Proposals Map necessary.

Penny Uprichard (344887) – PLAN 872 The St. Andrews ‘distributor road’ is considered to an integral part of the Strategic Development Area, and the route identified through future Masterplanning work. TAYplan consider that is sufficient to show the Strategic Development Area on the Proposals Map without need to show the road proposal separately. Therefore TAYplan does not consider any change to the Proposals Map necessary.

LEUCHARS AIRFIELD St. Andrews Preservation Trust (547750); Dr Eric Thain (549276) The potential use of the airfield at Leuchars as a commercial airport will need to be considered by the Ministry of Defence in relation to the change from an RAF base to an army base. Therefore TAYplan does not consider any change to the Proposals Map necessary.

STRATEGIC DEVELOPMENT AREAS Montgomery Forgan Associates for Headon Developments Ltd (349140) and Ryden for University of St. Andrews (548506) – PLAN 737; Royal Burgh of St. Andrews Community Council (453889); Mr Howard Greenwell (546652) and Stewart Milne Homes (539251) The respondents seek changes or additions to the Strategic Development Areas proposed in Policy 4 of the Proposed Plan. These issues are considered through Schedule 4 Issues: 12 – Policy 4: Strategic Development Areas (Policy 4a strategic allocations), 13 – Policy 4: Strategic Development Areas (alternative sites) and 14 – Policy 4: Strategic Development Areas (Policy 4b text and general). As the Proposals Map reflects Policy 4, any changes to the Strategic Development Areas through Policy 4 may have consequential effects for the Proposals Map. TAYplan does not consider any change to the Proposals Map necessary.

Ryden for University of St. Andrews (548506) – PLAN 739 TAYplan does not consider proposals for Guardbridge Energy Centre to be of scale that requires to be identified on the Proposals Map. Proposals for this site will be considered through the examination of the St. Andrews and East Fife Local Plan.

Royal Burgh of St. Andrews Community Council (453889) TAYplan does not agree with the respondent’s suggestion for ‘The Strategic Development Areas’ be changed to ‘Approximate locations of Strategic Development Areas’ in the legend. The diagram is intended to be indicative whilst assisting the reader in identifying the location of proposals where known. Some of the Strategic Development Areas in specific locations e.g. Dundee Centre and Port, whilst the precise location of others may be not yet finalised. TAYplan does not consider any change to the Proposals Map necessary.

33 TAYPLAN STRATEGIC DEVELOPMENT PLAN Montagu Evans (444081) TAYplan does not consider that the identification of Strategic Development Areas would preclude development elsewhere. Issues relating to development outside the Strategic Development Areas are addressed in Schedule 4 Issue 3 - Policy 3: Policy 1: Locational Priorities – Policy 1 settlement tiers and Schedule 4 Issue 4 - Policy 1: Locational Priorities – Policy 1b, text and general.

GREENBELT Miss Lynn McGeorge (548414); Andrew McCafferty for GD Strawson and J Farquharson (548151) and Penny Uprichard (344887) – PLAN 872 Green belt identified on the Proposals Map for Perth and St. Andrews is intended to be indicative only, as detail on the location of green belt is most appropriately considered at the Local Plan/Local Development Plan level. The inclusion of areas such as Luncarty, Redgorton, Stanley and Stormontfield will be addressed through the identification of green belt in the Perth & Kinross Local Development Plan. It is considered that the Proposals Map provides adequate clarity in view of the above. Issues relating to the greenbelt are also addressed in Schedule Issue 8 – Policy 3: Managing TAYplan’s Assets (Greenbelts). Any modifications arising in Policy 3: Managing TAYplan’s Assets - Greenbelt could have a consequential change to the Proposals Map.

OTHER – MISCELLANEOUS Tactran Regional Transport Partnership (441235) Whilst a square symbol at this area on the Proposals Map could provide more clarity and was an error in publication, it is not considered essential that TAYplan modify the Plan in this regard.

Andrew McCafferty for GD Strawson and J Farquharson (548151) The area of undeveloped coast identified on the Proposals Map is intended to be indicative only, to highlight areas that should be considered at the Local Development Plan level when identifying parts of the coastline that are unsuitable for development (in accordance with Scottish Planning Policy (Page 20, Paragraph 100) (002/SL/Doc40). Policy relating to undeveloped coast is set out in Policy 3: Managing TAYplan’s Assets (Natural and Historic Assets).

Scottish Government (443918) - PLAN666 Whilst the suggestion proposed by the respondent may provide some clarity with regard to National Planning Framework 2, TAYplan do not consider that the land-use implications of this proposal are such that it requires inclusion on the Proposals Map.

RESPONSE TO REPRESENTATIONS SUPPORTING AS WRITTEN Support for the support received in relation to these issues is welcomed by TAYplan.

CONCLUSIONS TAYplan considers that all of the issues raised do not warrant any change to the Proposed Strategic Development Plan (June, 2011) and propose that the elements dealt with in this Schedule 4 Summary of Unresolved Issues remain as written and unchanged. Many of the changes being sought would be a consequence of proposals, such as Strategic Development Areas, being changed in other parts of the Plan.

Reporter’s conclusions:

Rail proposals 1. The Scottish Government seeks the removal of the references to proposed new rail stations at Bridge of Earn/Oudenarde, Newburgh and Wormit. Transport Scotland is

34 TAYPLAN STRATEGIC DEVELOPMENT PLAN responsible for the development of the rail network and has no plans to promote or develop proposals for providing stations at these locations. Planning Circular 1/2009 - Development Planning (CL/Doc29) states in paragraph 18 that strategic development plans should be fully co-ordinated with other important strategies from the earliest stage with key infrastructure providers signed up to the delivery of the emerging proposals. Clearly, those responsible for rail infrastructure are not signed up to new stations at the locations shown on the proposals map.

2. On the other hand, these station proposals are contained in the Perth and Kinross Structure Plan 2003, page 59, and the Fife Structure Plan 2009, where proposal PT1 on page 44 refers to appraisal and assessment of new rail stations at Newburgh and Wormit. These documents have been approved by Scottish Ministers, though the extent of commitment, at least in the Fife case, falls short of firm proposals to build new stations. The TAYplan Proposed Action Programme (October 2011) also adopts a more tentative stance, and pages 27, 28 and 29 say in each case that “a STAG appraisal will consider all options for improving the transport system which could include public transport through improved provision of rail (new station), bus or other, or through improved road schemes”.

3. I consider that indicating these three sites on the proposals map as ‘Proposed new rail stations’ overstates the true position and would suggest a firm intention on the part of those responsible for rail infrastructure. I requested further information from the authority, which has responded that if I consider identifying these new stations as 'proposed' is inaccurate, an alternative could be to state 'proposed (subject to STAG appraisal)'. The authority, however, strongly opposes their removal and argues that such action would not be consistent with other existing approved plans and strategies produced by the Regional Transport Partnerships (Tactran and Sestran) and the respective local authorities. I note also the considerable local support for a station at Newburgh, as evidenced by representations on this issue.

4. Similar objections were put forward by Transport Scotland in relation to the Finalised St. Andrews and East Fife Local Plan 2009 and the Reporters dealing with these issues have recommended adding the following words to the relevant proposals:

‘Transport Scotland has no commitment towards funding the delivery of a station at this location. Transport Scotland's policy is to promote better utilisation of the existing network as a first choice and, as such, welcomes proposals for Park and Choose sites which complement established rail facilities.

The case for a new station will be considered where the needs of local communities, workers or visitors would be sufficient to generate a high level of demand, and feeder rather than inter-urban services would serve the station.’

This wording echoes paragraph 176 of Scottish Planning Policy (SPP). While its inclusion under the proposals map would make the position clear, it would be difficult to fit all of it into the available space. I therefore recommend that only the first sentence (suitably adapted) be included as a footnote, along with the addition to the legend of the words ‘(subject to STAG appraisal)’ as proposed by the authority. I consider that these changes would be sufficient to make the tentative nature of the proposal clear.

5. For the above reasons, I cannot support the representations seeking a greater priority in the plan for the reopening of Newburgh rail station. Whether such a proposal can progress will depend on the outcome of the STAG appraisal which is included in the Action Programme, and on it being successfully demonstrated (in accordance with SPP paragraph 176) that the needs of local communities, workers or visitors would be sufficient to generate 35 TAYPLAN STRATEGIC DEVELOPMENT PLAN a high level of demand, and that feeder rather than inter-urban services would serve the station.

6. As regards the representations seeking the safeguarding of a rail route from Leuchars to St. Andrews, I sought further information from the authority, which has confirmed that there are no proposals for a St. Andrews rail link in the East Area Transport Plan. Local Transport Strategy proposals for St. Andrews include improved public transport between St. Andrews and Leuchars rail station using energy efficient, low-emission vehicles and the existing road network. This will avoid the significant negative environmental impact of constructing a new road or rail corridor that would be required for a dedicated rapid transport link, while continuing to reduce reliance on the use of private cars.

7. I also note that in the examination report on the St. Andrews and East Fife Local Plan, the Reporter concluded that a rail link had been considered but was no longer an option on the grounds of cost and the practicability of identifying a viable and economically justifiable route; that an improved transport link had been provided by a frequent bus service linking St. Andrews to Leuchars station and Dundee; and that in these circumstances it would be pointless for the local plan to safeguard a route for a rail link. I therefore consider that there should be no reference to a St. Andrews rail link on the TAYplan proposals map.

8. With regard to the representations from the Campaign to Open Blackford Railway-station Again, Mr Ralph Barker and Kinross-shire Civic Trust, I agree with the authority that the case for progressing the rail improvements sought has not advanced to the stage where their inclusion on the proposals map would be justified. In the case of Blackford, I note that while higher priority is being given to upgrading the existing Gleneagles station, the proposed Perth and Kinross Local Development Plan has protected a site at Blackford for the long- term potential development of rail passenger and freight facilities. This could, however, take the form of a goods siding rather than a station.

9. The matters raised by the Rail Freight Group are dealt with under Issue 10: Policy 3: Managing TAYplan’s Assets - Transport.

Road Proposals: Cross-Tay Link Road (CTLR) 10. This arises under Issue 2 (Proposals Map), where it is shown as ‘Proposed A9/A94 link (route options)’, but is also relevant to Issue 8 (Green Belts), Issue 10 (Managing Tayplan’s Assets: Transport), Issue 12 (Strategic Development Areas) and Issue 23 (Delivering the SDP). Representations by Zurich Assurance Ltd maintain that the proposals are cost- negative and will not reduce travel, while Colin R McLeod considers that the proposals have not been thought through, particularly in relation to increased long-distance traffic on the A94 and its potential impact on communities. Dr Peter Symon seeks a specific reference to a bridge and the concomitant development opportunities. Lynn McGeorge in her representations under Issue 3 (Locational Priorities) objects to the inclusion of Luncarty, Stanley, Balbeggie and Perth Airport in the Perth Core Area because of their dependence on the CTLR and its perceived impact, while Mark Myles in his representations under Issue 8 (Green Belts) expresses concern about the CTLR’s impact on nature.

11. At my request, the authority has provided additional information on the background to the CTLR proposal including: a. Further information on the economic and environmental case for the CTLR b. An assessment of its effects on traffic patterns, including long-distance traffic on the A94 and its likely impact on communities c. An assessment of its effects on the natural environment d. An explanation of the realism of the funding assumptions e. Copies of relevant documents which were not in the core library. 36 TAYPLAN STRATEGIC DEVELOPMENT PLAN 12. A STAG (Scottish Transport Appraisal Guidance) study was carried out and reported in October 2010. This showed that building a CTLR along the best route corridor, Option C, would achieve a net present value of £53.237 million (at 2002 prices) and return a benefit to cost ratio of 1.925. This means the economic benefits of the proposal would outweigh the costs by a factor of nearly 2, and that this option would provide good value for money. I cannot therefore support the representation by Zurich Assurance Ltd that the proposal is cost-negative.

13. An S-Paramics traffic simulation model was developed by SIAS Ltd for the whole of the Perth Area in 2003, and was updated in 2010, in order that future traffic flows could be modelled taking into account the effects of future development in the Perth area. Such models are currently industry standard for progressing major road schemes. In creating the updated model, an analysis was undertaken to see whether there would be any transfer of traffic between the A90 and the A94. This showed that in the morning peak period (0700 to 0900), an estimated 293 eastbound vehicles approaching Perth on the A9 would transfer from the A90 to the A94 for their onward journey, with 127 westbound vehicles also transferring, a two-way increase of 420 vehicles. This compares with a base two-way flow of 1,550 vehicles on the A94 east of Scone in the same period (Table 8.1 of Shaping Perth’s Transport Future DMRB Stage 1 Assessment Report) and would represent a 27% increase. The corresponding figures for the evening peak period (1600 to 1800) are 393 additional two-way vehicles against a base of 1340, a 29% increase.

14. These are significant increases, although even then the A94 would remain relatively lightly trafficked for a strategic road. Traffic through Scone itself would be reduced slightly (Table 8.8b of the DMRB Stage 1 Report). However, there would be some impact on communities further east on the A94. The extent of this could be diminished if the upgrading of the Perth-Aberdeen route around Dundee were to go ahead. The Dundee Northern Relief Road is listed in Transport Scotland’s Strategic Transport Projects Review 2009, and could take the form either of a bypass to the north of the city, or improvements to the existing Kingsway route. The proposals map shows ‘Proposed A90 upgrade (route options)’ to the north of Dundee. If this reduced journey times on the A90, the relative attractiveness of the CTLR/A94 alternative, and the corresponding traffic volumes, would decrease.

15. The CTLR, together with other proposed measures, would significantly reduce traffic volumes and air pollution in Perth city centre and the Bridgend area. Morning peak period traffic over Queen’s Bridge would reduce by 200 vehicles, and over Smeaton’s Bridge by 870 (two-way flows: Table 8.1 of DMRB Stage 1 Report). Air quality is a major problem in central Perth, with vehicle emissions being a main contributor. While the CTLR would improve environmental quality in the city, its construction would have impacts on the natural environment and cultural heritage along its route. A Strategic Environmental Assessment of the CTLR and related proposals has shown that for the preferred corridor (Option C) there would be minor negative impacts on biodiversity, landscape and soil, and a significant negative impact on cultural heritage. This concerns the area to the north of Scone Palace. Through discussions with Historic Scotland it has been identified that there is no mitigation strategy which would result in the effective removal or avoidance of the impacts to the Garden and Designed Landscape and associated Scheduled Monuments.

16. It is not the role of the TAYplan examination to inquire into the details of the CTLR route and its environmental impacts. Perth and Kinross Council is carrying out a public consultation process about its transport proposals, and the procedures associated with the proposed Local Development Plan will provide further opportunities for public comment. However, I have concluded from the information available to me that sufficient justification exists for the principle of a CTLR for it to be included on the proposals map as ‘Proposed A9/A94 link road (route options)’. In doing so, I have noted the relatively small number of 37 TAYPLAN STRATEGIC DEVELOPMENT PLAN representations opposed to this proposal, and that none has been put forward by the Scottish Government, Transport Scotland, Historic Scotland or Scottish Natural Heritage. I do not consider it necessary for the proposals map to include a specific reference to a bridge or to the concomitant development opportunities.

17. A question mark remains about funding. The estimated construction cost for the CTLR and associated infrastructure is currently £91.5 million. It is clear from initial work that the full requirements cannot be met from within the council’s current capital budget, so in accordance with TAYplan Policy 8 and SPP, the council is preparing further supplementary guidance seeking developer contributions towards essential infrastructure. Current work is based on the assumption that the development industry will be unable to front fund any but the most minor infrastructure requirements, and as a result the council is examining using prudential borrowing powers to assist in the provision of the required infrastructure, while seeking retrospective developer contributions.

18. Circular 1/2009 states that strategic development plans should be concise visionary documents that set clear parameters for subsequent local development plans and inform decisions about strategic infrastructure investment. It is clear to me that the proposed CTLR is an important part of the TAYplan vision and a key strategic infrastructure investment which underpins the settlement strategy for the Perth Core Area. I consider that there is a sufficiently realistic prospect of its construction within the plan period for it to be retained in the proposed plan.

Road proposals: other 19. Representations argue for the inclusion of the A977 on the proposals map. I recognise that this road has strategic significance as the main link from the Kinross area to the Kincardine and Clackmannanshire bridges, and that other roads with comparable roles (such as the A85 and A94) are shown on the proposals map. However, the authority has confirmed that there are currently no proposals to improve the A977 other than localised road safety measures. I therefore do not consider it necessary for the road to be added to the proposals map. As regards the proposed St. Andrews distributor road, I agree with the authority that since this forms an integral part of the St. Andrews West Strategic Development Area, there is no need to show it separately on the proposals map.

Strategic Development Areas (SDAs) 20. Representations about particular SDAs, including suggested additions, are dealt with under Issues 12-14. There are no recommended modifications arising from these issues that would require changes to the proposals map. The University of St. Andrews seeks a reference to the proposed Guardbridge Energy Centre on the proposals map. However, I agree with the authority that this proposal is not of a scale that would warrant inclusion on the map. I also agree with the authority that the suggestion by the Royal Burgh of St. Andrews Community Council to change the legend to ‘Approximate locations’ of SDAs is not justified. Given the scale of the map, the SDA symbol covers an area on the ground several kilometres in diameter and is approximate anyway. There would be no improvement in clarity by changing the legend. With regard to the representation by Montagu Evans, I agree with the authority that the inclusion of SDAs on the proposals map does not preclude development elsewhere, which is provided for by Policy 1: Location Priorities.

Green belts 21. Representations about the extent and clarity of the Perth green belt are considered under Issue 8: Policy 3: Managing TAYplan’s Assets – Greenbelts, where I recommend the replacement of the existing diagram of the Perth green belt on page 13 by a revised diagram showing the proposed extent with greater clarity and naming settlements. There should be consequential changes to the proposals map on page 7 so that it is consistent with the 38 TAYPLAN STRATEGIC DEVELOPMENT PLAN recommended new diagram, but the scale of the map and the inclusion of other information such as road and rail proposals mean that the representation of the green belt there will need to be in a simplified form.

22. As regards the representation from Penny Uprichard, I agree that the green arrows representing the St. Andrews green belt are almost obscured by the SDA symbol. However, given the map scale and the need to include a lot of information, I do not see any ready solution to this. Pages 9 and 13 show the extent of the green belt more clearly.

Other matters 23. The possible use of Leuchars Airfield for civil aviation is a matter for the Ministry of Defence to consider in the light of its future plans for the base, and I agree with the authority that it would not be appropriate to include this on the proposals map.

24. Tactran seeks the addition of a ‘Proposed strategic park and ride’ symbol (red square) to the west of Dundee. The authority concedes that this was omitted in error. Corresponding symbols appear to the east of Dundee and south of the Tay Bridges, and it would be inconsistent to leave out the Dundee West park and ride proposal. I therefore recommend that it be added to the proposals map.

25. Representations seek deletion of the ‘undeveloped coast’ notation. The meaning of ‘undeveloped coast’ and the case for its inclusion in the proposed plan are considered under Issue 3: Policy 1A – Location Priorities. No change is recommended there, and consequently there is no need to change the proposals map.

26. As regards the representation about National Development 10 (carbon dioxide pipeline from Longannet to St. Fergus), the Scottish Government has advised that this should be withdrawn, since the proposal will no longer be implemented.

Reporter’s recommendations:

Modify page 7 of the proposed plan as follows:

On the proposals map, amend the representation of the Perth green belt so that it is consistent with the revised diagram on page 13 recommended under Issue 8.

On the proposals map, on the west side of Dundee insert a red square symbol to represent the proposed Dundee West strategic park and ride.

In the left-hand column under the map, delete the words:

“Proposed new Rail Station”, and insert the following words:

“Proposed new rail station (subject to STAG appraisal)**”.

At the bottom of the page, insert a new footnote as follows:

“**STAG: Scottish Transport Appraisal Guidance. Transport Scotland has no commitment towards funding the delivery of stations at these locations.”

39 TAYPLAN STRATEGIC DEVELOPMENT PLAN

Issue 3 Policy 1: Location Priorities – Policy 1A

Development plan Reporter: Page 9: Policy 1, Part A reference: Mike Cunliffe

Body or person(s) submitting a representation raising the issue (including reference number): Seeking a change ID Person/Organisation Representation Number Reference 548872 Alyth Community Council PLAN821 548151 Andrew McCafferty Associates for GD Strawson PLAN445 and J Farquharson 548151 Andrew McCafferty Associates for GD Strawson PLAN736 and J Farquharson 545593 Auchterhouse Community Council PLAN468 443109 Barton Willmore for Scotia Homes PLAN376 337727 Colliers International for Gleneagles Hotel PLAN52 416017 Colliers International for Persimmon Homes PLAN40 Limited 541486 Colliers International for Taylor Wimpey East PLAN63 Scotland 548117 Dundas Estates & Development Company PLAN430 445201 Emac Planning for A & J Stephen Limited PLAN683 445201 Emac Planning for A & J Stephen Limited PLAN684 445201 Emac Planning for A & J Stephen Limited PLAN685 445201 Emac Planning for A & J Stephen Limited PLAN687 445201 Emac Planning for A & J Stephen Limited PLAN692 548522 Emac Planning for A & J Stephen Limited / Bett PLAN731 Homes Limited 548522 Emac Planning for A & J Stephen Limited / Bett PLAN733 Homes Limited 548522 Emac Planning for A & J Stephen Limited / Bett PLAN735 Homes Limited 445204 Emac Planning for Angus Estates Limited PLAN599 445204 Emac Planning for Angus Estates Limited PLAN601 548523 Emac Planning for Bett Homes Limited PLAN760 548523 Emac Planning for Bett Homes Limited PLAN762 445206 Emac Planning for J G Lang & Son PLAN535 445206 Emac Planning for J G Lang & Son PLAN539 445203 Emac Planning for James Keiller Estates PLAN714 548383 Emac Planning for L Porter PLAN548 548301 Emac Planning for M Batchelor (K) PLAN518 548301 Emac Planning for M Batchelor (K) PLAN527 445207 Emac Planning for Mr W Robertson PLAN571 445205 Emac Planning for Mr R Watson PLAN509 445205 Emac Planning for Mr R Watson PLAN513 548524 Emac Planning for Stewart Milne Homes PLAN777 543112 GS Brown Construction PLAN84 543112 GS Brown Construction PLAN87 547268 GVA Grimley for David Wilson Homes PLAN448 548948 Hargest Planning Limited PLAN855

40 TAYPLAN STRATEGIC DEVELOPMENT PLAN 442882 Homes for Scotland PLAN214 327210 J Khazaka PLAN932 546432 Jim Farquharson PLAN208 443893 Karen Clark for Balmossie Developments Limited PLAN528 and Messrs David Reid Farmers 346689 Karen Clark for Discovery Homes PLAN203 346689 Karen Clark for Discovery Homes PLAN542 443979 Lynne Palmer PLAN153 548414 Miss Lynn McGeorge PLAN607 444081 Montagu Evans PLAN320 444081 Montagu Evans PLAN458 444081 Montagu Evans PLAN460 349140 Montgomery Forgan Associates for Headon PLAN608 Developments Limited 527724 Mr David Dykes PLAN481 546652 Mr Howard Greenwell PLAN255 548055 Mr Ian Fowler PLAN386 548486 Mr Ken Miles PLAN831 337567 Mr Kyffin Roberts PLAN507 548760 Mrs D Jeffrey PLAN810 344874 Mr Stewart McKiddie PLAN645 548250 Ms Joan McEwen Sprunt PLAN476 450286 Muir Group PLAN167 548051 Muir Smith Evans for Muir Homes Limited PLAN388 548051 Muir Smith Evans for Muir Homes Limited PLAN406 547478 Professor Christopher M Steel PLAN280 442290 Rossco Properties PLAN162 453889 Royal Burgh of St. Andrews Community Council PLAN919 330884 Ryden for Bon Accord Land Limited / Stewart PLAN127 Milne Homes 330884 Ryden for Bon Accord Land Limited / Stewart PLAN128 Milne Homes 548506 Ryden for University of St. Andrews PLAN742 548386 Sarah Hunt PLAN545 547388 SEStran Regional Transport Partnership PLAN272 442871 Smiths Gore for Errol Park Estate PLAN628 539251 Stewart Milne Homes PLAN312 539251 Stewart Milne Homes PLAN313 539251 Stewart Milne Homes PLAN314 539251 Stewart Milne Homes PLAN315 539251 Stewart Milne Homes PLAN317 539251 Stewart Milne Homes PLAN319 539251 Stewart Milne Homes PLAN321 539251 Stewart Milne Homes PLAN322 539251 Stewart Milne Homes PLAN345 546153 Strathkinness Community Council PLAN194 346675 TMS Planning for Muir Homes Limited PLAN354 346675 TMS Planning for Muir Homes Limited PLAN355

Support as written ID Person/Organisation Representation Number Reference 376787 Abernethy & District Community Council PLAN118 419429 Auchterarder & District Community Council PLAN76 41 TAYPLAN STRATEGIC DEVELOPMENT PLAN 423150 Braes of the Carse Conservation Group PLAN21 337727 Colliers International for Gleneagles Hotel PLAN53 337727 Colliers International for Gleneagles Hotel PLAN54 416017 Colliers International for Persimmon Homes PLAN38 Limited Colliers International for Persimmon Homes 416017 Limited PLAN39 416017 Colliers International for Persimmon Homes PLAN41 Limited 541886 Colliers International for Taylor Wimpey East PLAN61 Scotland Colliers International for Taylor Wimpey East 541486 Scotland PLAN62 541486 Colliers International for Taylor Wimpey East PLAN64 Scotland 450613 Councillor Michael A Barnacle PLAN812 346407 D G Coutts Associates for Linlathen PLAN284 Developments 548029 DPP LLP for Kinross Estate Company PLAN441 548113 DTZ for Headon Developments PLAN514 379723 Dunning Community Council PLAN435 445201 Emac Planning for A & J Stephen Limited PLAN683 445201 Emac Planning for A & J Stephen Limited PLAN690 548522 Emac Planning for A & J Stephen Limited / Bett PLAN731 Homes Limited 445204 Emac Planning for Angus Estates Limited PLAN599 548523 Emac Planning for Bett Homes Limited PLAN760 548523 Emac Planning for Bett Homes Limited PLAN761 445206 Emac Planning for J G Lang & Son PLAN535 548383 Emac Planning for L Porter PLAN548 548301 Emac Planning for M Batchelor (K) PLAN518 445205 Emac Planning for Mr R Watson PLAN509 548524 Emac Planning for Stewart Milne Homes PLAN777 548948 Hargest Planning Limited PLAN856 445299 Inchture Area Community Council PLAN800 263542 Kingsbarns Community Council PLAN377 546838 Kinross-shire Civic Trust PLAN493 450207 Largo Area Community Council PLAN436 442806 Loch Lomond and The Trossachs National Park PLAN101 Authority 450585 Methven & District Community Council PLAN862 444081 Montagu Evans PLAN456 343111 Montagu Evans LLP for Wallace Land Investment PLAN333 Management 445161 Montgomery Forgan Associates for Morris Leslie PLAN653 Group 442083 Montgomery Forgan Associates for Strategic Land PLAN276 (Scotland) Limited 442083 Montgomery Forgan Associates for Strategic Land PLAN277 (Scotland) Limited 331497 Montgomery Forgan Associates for Taylor PLAN273 Wimpey Montgomery Forgan Associates for Taylor 331497 Wimpey PLAN275 42 TAYPLAN STRATEGIC DEVELOPMENT PLAN 349134 Montgomery Forgan Associates for VGH (VICO PLAN574 Limited/Bett Homes/Headon Developments Limited) 548051 Muir Smith Evans for Muir Homes Limited PLAN691 349010 PPCA Limited for Alfred Stewart Properties PLAN15 Limited 548506 Ryden for University of St. Andrews PLAN746 548335 Savills for John Dewar Lamberkin Trust and PLAN651 Needhill LLP 344939 Scottish Enterprise PLAN423 442031 Scottish Environmental Protection Agency PLAN170 442031 Scottish Environmental Protection Agency PLAN171 344848 Scottish Natural Heritage PLAN414 547388 SEStran Regional Transport Partnership PLAN272 442870 Smiths Gore for Mansfield Estates PLAN544 539251 Stewart Milne Homes PLAN323 441235 Tactran Regional Transport Partnership PLAN94 Provision of the development plan Relates to Policy 1, Part A. to which the issue relates: Planning authority’s summary of the representation(s):

SUMMARY OF REPRESENTATIONS SEEKING A CHANGE

GENERAL Auchterhouse Community Council (545593); Karen Clark (for Balmossie Developments Limited and Messrs David Reid Farmers (443893) and Discovery Homes(346689 - PLAN542)) have indicated that that boundaries shown on the map on Page 9 is too vague. The respondents have therefore requested that the Core Areas should be more clearly defined. Karen Clark for Balmossie Developments Limited and Messrs David Reid Farmers (443893) also consider that the Eastern Villages of Dundee should be included as there is a clear opportunity to improve the sustainability and setting of Balmossie Village.

Colliers International for Gleneagles Hotel (337727) consider that paragraph 7 on Page 8 is misleading and therefore the locations, Pitlochry and St. Andrews should be deleted or should include other locations such as Gleneagles. Alternatively, the respondent suggests that all location names should be removed.

Colliers International for Persimmon Homes Limited (416017) considers that the Policy wording states Tier 2 settlements "have the potential to make a major contribution to the regional economy, but will accommodate a small share of the region's additional development." It is acknowledged that Tier 2 settlements should 'proportionately' accommodate the region's additional development (outwith Dundee and Perth Core Areas). However the respondent considers the town of Kinross can offer more than simply a "small share" given its proximity to a major motorway (M90) and the potential for growth aligned with the SESplan proposed strategy of growth in South Fife at the Forth Bridgehead area. Kinross has the land availability and essential infrastructure capacity to accommodate a proportionate share (a greater balance than currently proposed) to meet the Plan's requirement to provide land release necessary for the plan period. Whilst not objecting to the identification of Kinross as a Tier 2 settlement, the respondent suggests reword of the text to change "small share" to "proportionate share".

43 TAYPLAN STRATEGIC DEVELOPMENT PLAN EMAC Planning (for A & J Stephen Limited (445201 - PLAN683); A & J Stephen Limited (445201 - PLAN684); A & J Stephen Limited/Bett Homes Limited (548522 - PLAN731); A & J Stephen Limited / Bett Homes Limited (548522 - PLAN733); Angus Estates Limited (445204 - PLAN599); Bett Homes Limited (548523 - PLAN760); J G Lang & Son (445206 - PLAN535) and Stewart Milne Homes (548524 - PLAN777)) the respondents consider that non-Strategic Development Area settlements identified in Tier 2 should be removed together with Tier 3 settlements and the settlement priorities left for the more detailed Local Development Plan's to determine.

EMAC Planning (for A & J Stephen Limited (445201 - PLAN687); A & J Stephen Limited/Bett Homes Limited (548522 - PLAN735); Angus Estates Limited (445204 – PLAN601) and Bett Homes Limited (548523 - PLAN762)) consider that TAYplan should not be setting a hierarchy for each of the settlements within the TAYplan area as this is a matter that should be dealt with by the emerging Local Development Plan's and in the context of each housing market area. With the ongoing concern that many of the sites within the existing supply cannot be delivered timeously in the short to medium term then TAYplan should not artificially constrain the ability of the emerging Local Development Plan's to carry out the detailed site appraisal work at the local level.

EMAC Planning for L Porter (548383) consider that on a plan-wide basis a better approach would be for the development hierarchy to be removed from the TAYplan, with the Proposals 1: Map showing only the strategic growth areas, that is, the Core Areas and Strategic Development Areas. All other key service settlements could be identified for growth through the Local Development Plan process.

Andrew McCafferty Associates for GD Strawson and J Farquharson (548151 – PLAN736) have indicated that there is no definition of the term "Undeveloped Coastline" in the Plan and the lack of clarity over the extent of area that is proposed to be covered by this designation means that the notation on both Proposals 1: Map and the map on page 9 should be removed. Some parts of the coastline are already protected by statutory and non statutory designations. There are also riparian areas that lie within flood risk areas and these are shown on SEPA's flood risk maps. TAYplan's use of the term "Undeveloped Coastline" is unclear and will lead to confusion in its application and should be deleted from the Plan.

Homes for Scotland (442882); Stewart Milne Homes (539251 - PLAN322) and Montagu Evans (444081 – PLAN320) comment that the two largest settlements (Dundee and Perth) will always form the key areas for economic drive and the largest land releases. However, putting other settlements within the Plan area into a tiering system prevents unnecessarily the natural growth and development of some of the settlements. Therefore the development should be removed. All the major service centres should be allowed to grow and develop in line with market demand and economic prosperity. Local Development Plans should be used to determine the level of growth of settlements, without being unduly restricted by the Strategic Development Plan.

J Khazaka (327210) considers that the statement “There will be no need for any new settlements during the lifetime of this Plan.” Should be removed from the Proposed Plan.

Montagu Evans (444081) although supporting the statement within Policy 1, Part A which states that Local Developments Plans may also provide for some development in settlements that are not principle settlements. It is considered that this policy should also state that the land allocated for development should be land that can be brought forward and developed within the plan period.

Mr Ian Fowler (548055) considers that the Proposed Plan lacks any detailed information on 44 TAYPLAN STRATEGIC DEVELOPMENT PLAN development location or how it will be controlled. In addition, the respondent considers that there seems to be a lot of general comments and promises but no fine detail on how the plan will be implemented to reassure the public.

Muir Group (450286) considers that Tiers 2 and 3 should be omitted and substituted by a statement to the effect that the balance of development should be distributed amongst the region's remaining settlements in accordance with demand/need within each housing market area.

Ryden (for Bon Accord Land Limited/Stewart Milne Homes (330884) and Ryden for Bon Accord Land Limited/Stewart Milne Homes (330884 - PLAN128)) has made the following comments: • Consider that too much emphasis is placed on Dundee and Perth as economic drivers. There are other locations, such as Montrose which have the ability to be an economic driver, which should be reflected in the TAYplan. • The respondent also considers that an explanation or justification for the categorisation of the settlement hierarchy is required. The current classification contradicts itself. • If a tier two settlement makes a major contribution to the regional economy, they should be given the opportunity to accommodate a larger share of new development. The identification of land for development should be made on the merits of each settlement, not where it fits in the hierarchy.

DUNDEE CORE AREA

EMAC Planning for A & J Stephen Limited (445201 - PLAN685) considers that there is market demand for development to the north west of Dundee at Birkhill, i.e. as part of the Dundee Core Area. The respondent recognises and welcomes the identification of ‘Birkhill/Muirhead' as a stated element of the Dundee Core Area and the priority for land release for development within this Tier 1 area, however the deliverability of identified land within the Dundee and South Angus Housing Market Area has been uncertain for a number of years, especially given the history of non-deliverability of the Dundee Western Gateway housing allocations. It is considered that the Western Gateway will continue to face difficulties and may not be delivered in the early phases of the Plan period. As a result, other short and medium term effective housing greenfield releases such as land to the south of Birkhill, require to be made around the City of Dundee to address supply issues.

Karen Clark for Discovery Homes (346689 - PLAN203) although generally supportive of the focus of housing release towards the main settlements, the respondent considers that as demonstrated over recent years, a housing allocation does not guarantee development on site, which is recognised in Scottish Planning Policy. In terms of the Western Gateway, in spite of the best efforts of all parties, the respondent highlights that development has not yet progressed. In light of this very recent experience the respondent considers that it is essential for the continuity of delivery of housing land that there is a range of housing land release. In this way the opportunities to maintain an effective housing land supply will be maximised. It is submitted that a spread of housing land release is required across the main settlements to provide choice, minimise traffic movement, and support strategic economic land release ensuring sustainable access to jobs within all parts of the principle settlements.

Karen Clark for Discovery Homes (346689 - PLAN542) considers that Location Priorities should recognise that, particularly in the Dundee area where the administrative boundaries have been drawn very tightly around the City with no area of "urban fringe" included within the City boundaries, that the Tier 1 catchments makes some recognition of the urban fringe

45 TAYPLAN STRATEGIC DEVELOPMENT PLAN areas, particularly where the redevelopment of brownfield land is proposed.

Mr Stewart McKiddie (344874) considers that Newport and Wormit should be deleted from the Dundee Core Area.

Stewart Milne Homes (539251 - PLAN313); Stewart Milne Homes (539251 - PLAN314); and Stewart Milne Homes (539251 - PLAN315) consider that the villages of Liff, Ballumbie & Duntrune should be included within the Dundee Core Area.

Stewart Milne Homes (539251 - PLAN319 and PLAN321) considers that a wider cross section of land be identified for development within the Dundee City Core Area to ensure there is an adequate supply of unconstrained developable land that can be effective from the early stages of the Plan.

PERTH CORE AREA EMAC Planning for A & J Stephen Limited (445201 - PLAN692) considers that the Perth Core should be amended to cover "an area within approximately 25 minutes travel by local bus from the centre of Perth". This definition is used within the current Perth & Kinross Structure Plan 2003 and has been well understood by officials, elected Members and investors for many years and is a far more strategic assessment of the Perth Core Area. It is clear that relevant and consistent measure should be adopted in the formulation of TAYplan. The plan is a rolling forward of the existing strategic planning context and there is no reason to change this definition.

GS Brown Construction (543112) comment that in relation to the Perth Core Area, the majority of new development is earmarked for the Perth North West expansion scheme and Oudenarde which the respondent considers are jeopardised, in different ways by education and roads infrastructure costs. It is not clear how the plan envisages a solution to these problems.

Jim Farquharson (546432) is concerned about the justification for further development in Perth when flooding is not only a risk but in fact is a reality, even in mid- summer. The respondent further comments that there is no record of flooding in the Carse of Gowrie.

Lynne Palmer (443979) considers that Bridgend should form part of the Perth Core Area. The respondent considers that Bridgend is a congested area in terms of traffic, pollution, housing and land space.

Miss Lynn McGeorge (548414) considers that Luncarty, Stanley, Balbeggie and Perth Airport should not be included within the Perth Core Area.

Mr David Dykes (527724) considers that Scone should not be part of Perth Core Area as this will destroy Scone's identity.

Mrs D Jeffrey (548760) has commented that the developer promoting a new settlement at Craigend, Perthshire (which complies with the national policy of sustainability) has already pledged, not merely to make contributions, but to fund all the infrastructure and the school, thereby relieving the Local Authority and tax payers from this financial burden. The respondent therefore considers that the prospect of building new settlements should not be discounted.

Ms Joan McEwen Sprunt (548250) considers that the Perth Core Area should include the Carse of Gowrie and Guildtown.

46 TAYPLAN STRATEGIC DEVELOPMENT PLAN ST. ANDREWS

Hargest Planning Limited (548948) comment that in the text of Policy 1, Part A it is stated that there will be no additional strategic development in the foreseeable future beyond the St. Andrews Strategic Development Area. St. Andrews is proposed as a Tier 2 settlement - it is clearly the focus of population, employment and services in the North East of Fife. The respondent therefore considers that this statement in relating to St. Andrews within Policy 1 is inappropriate and inconsistent with information and analysis set out in support of the draft Strategic Development Plan. Montgomery Forgan Associates for Headon Developments Limited (349140) are concerned about the vague and ambiguous nature of the statement "Beyond the Strategic Development Area in Policy 4 for St. Andrews there will be no additional strategic development of this scale in the foreseeable future." and request that the terms and purpose/objective of this part of Policy 1 Part A be clarified and confirmed. Until this is done, the respondent does not consider that there is a strategic justification for setting a development ceiling for St. Andrews. Mr Howard Greenwell (546652) has requested an amendment to the text relating to "Beyond the Strategic Development Area in Policy 4 for St. Andrews there will be no additional strategic development of this scale in the foreseeable future" to say "For St. Andrews there will be no additional strategic development in the foreseeable future".

Mr Kyffin Roberts (337567); and Royal Burgh of St. Andrews Community Council (453889 - PLAN919) has requested a number of amendments to Policy 1, Part A, including:- • A change to the wording under Tier 2 Settlements; and, • An amendment to the statement, "Beyond the Strategic Development Area in Policy 4 for St. Andrews…”

Professor Christopher M Steel (547478) considers that the designation of St. Andrews as a "second tier" centre of population should be clarified to mean St. Andrews and its hinterland - specifically including Guardbridge and Leuchars.

Ryden for University of St. Andrews (548506) note that the final paragraph under Policy 1 Location Priorities states that beyond the Strategic Development Area in Policy 4 for St. Andrews there will be no additional strategic development of this scale in the foreseeable future. The respondent is concerned about the ill-defined and ambiguous nature of this statement. While content that an additional Strategic Development Area is unlikely to be allocated in the foreseeable future, it is not clear what comprises "additional strategic development", why such a policy is required and whether it will be used to prevent any additional development of a smaller scale but which has strategic importance in St. Andrews for which there may be a requirement.

Sarah Hunt (548386) considers that there is opportunity to develop at Guardbridge and Leuchars and that St. Andrews should be categorised as a small town.

SEStran (547388) although supportive of the principal settlements, the respondent considers that it is worth including an additional statement in relation to proposed development in St. Andrews.

Strathkinness Community Council (546153) have commented in relation to the future use of the base at RAF Leuchars. The Proposed Plan classifies Leuchars/Guardbridge as a Tier 3 settlement in terms of its development role, however the respondent is concerned about the impact on the communities, especially in relation to housing, schooling, transport and healthcare given the proposed change to RAF Leuchars.

47 TAYPLAN STRATEGIC DEVELOPMENT PLAN OTHER SETTLEMENTS Alyth Community Council (548872) consider that as a Tier 3 Settlement it is disappointing that Alyth appears to be deemed as not requiring development.

Barton Willmore for Scotia Homes (443109) considers that Tier 2 settlements, such as Forfar, have the ability to accommodate sustainable economic growth and thus, contribute to the growth of the TAYplan region as a whole. This is further confirmed through the identification of Forfar as an "Agricultural Service Centre" within the proposed TAYplan. Whilst Forfar is identified as a Tier 2 settlement, this, by its very nature, acts as a barrier to potential future growth beyond that identified in the Proposed Plan. In the case of Forfar, the use of a tiered locational priority system, could potentially have a negative impact on its natural growth and development. In addition, the respondent considers that service centres such as Forfar should be allowed to grow at a rate commensurate to market demand and economic prosperity. The TAYplan should encourage development in these areas and seek to remove any potential restrictive policy wording on development which would compromise the sustainable economic development of the area.

Colliers International for Taylor Wimpey East Scotland (541486) acknowledge that Tier 2 settlements should 'proportionately' accommodate the region's additional development (outwith Dundee and Perth Core Areas). However it is considered the town of Crieff can offer more than simply a "small share" given its historical low growth in preference to Auchterarder (within the Strathearn Housing Market Area). There is a recognised demand (The Perth and Kinross Housing Needs and Demand Assessment) for family homes and signs that the Strathearn area will demand a greater proportion of growth in Perth and Kinross than other housing market areas. Crieff has the land availability and essential infrastructure capacity to accommodate a proportionate share (a greater balance than currently proposed) to meet the Plan's requirement to provide land release necessary for the plan period.

Dundas Estates & Development Company (548117) considers that Dundee and Perth will clearly form the key areas for investment and the development of the region as a whole. However, the growth of other settlements should not be constrained by placement within an artificial tiering system. In particular, the respondent cannot understand why Cupar, one of the principle county towns of Fife, would be placed in a tier behind the likes of Scone, Bridge of Earn and Tayport. Cupar is an established settlement benefiting from road and rail links, commercial services and community facilities. The town serves its own population and the outlying rural population. In order to support and build on the existing social and economic infrastructure, Cupar should be defined as a settlement capable of accommodating a large share of development.

EMAC Planning for J G Lang & Son (445206 - PLAN539) consider that TAYplan should encourage Local Development Plans to provide a generous supply of new housing and mixed use land in North Fife. The available supply is currently being constrained by the reliance on Strategic Allocations to deliver housing in the area. With particular reference to the Cupar Housing, Market Area, there is some concern over the deliverability of Cupar North, particularly within the time period anticipated. A strategy of higher growth over and above that indicated by the General Register Office for Scotland data, would allow the growth of other settlements in the area, including Springfield, where sites are capable of delivering effective housing land in the early periods of the TAYplan.

The respondent considers that it is vital to the sustainability of smaller settlements that some growth is now allowed over the next 20 years, supported by Scottish Planning Policy which states that decisions on the location of new development should amongst other factors promote rural development and regeneration. The commitment in the TAYplan to Local Development Plans providing for some development in settlements not defined as principle 48 TAYPLAN STRATEGIC DEVELOPMENT PLAN settlements is supported. However, the respondent that a more generous supply of land needs to be identified to facilitate the growth required in the early periods of the Plan. Smaller settlements and sites are less likely to be constrained by high development costs and many of the villages in North Fife, including Springfield, would benefit from growth to sustain and enhance village services. It is considered that the moderate expansion of Springfield to the south could accommodate some of the growth requirements of the Cupar Housing Market Area on a site capable of delivering effective housing land within the first 5 years of the Plan.

EMAC Planning for James Keiller Estates (445203) consider that TAYplan should support additional land releases to the north of Dundee along the A90 corridor at Inveraldie. It is suggested that the TAYplan identifies Inveraldie as a Principal Settlement, or alternatively, if the TAYplan removes Tiers 2 (Non-Strategic Development Areas) and Tier 3 settlements from Proposals 1: Map, TAYplan encourages support for the identification of Inveraldie as a Principal Settlement in the Local Development Plan.

EMAC Planning (for M Batchelor (K) (548301) and Mr R Watson (445205 - PLAN509)) although supporting the identification of Dundee and Perth core areas as Tier 1 settlements, together with the identification of Strategic Development Areas within Tier 2, the respondent considers that non-Strategic Development Area settlements identified in Tier 2 should be removed together with Tier 3 settlements (option a). Alternatively, if the identification of other settlements in Tier 2 and 3 remains unchanged, Friockheim and Newbigging should be identified in Tier 3 of the hierarchy (option b). In addition, EMAC Planning for Mr W Robertson (445207) considers that TAYplan should provide either a specific planning policy for Crail Airfield or a general policy on the redevelopment of rural brownfield sites.

Andrew McCafferty Associates for GD Strawson and J Farquharson (548151 - PLAN445) consider that there is an over concentration of future growth at Perth and Dundee and the Plan should include reference to a new settlement at "Horn Grange" to consolidate the scatter of existing development and facilitate provision of social infrastructure such as a new secondary school which could serve the whole of the Carse of Gowrie's existing settlements.

GS Brown Construction (543112 – PLAN87) The plan is too heavily skewed towards development taking place in major settlements, thereby preventing natural growth and development of some of the smaller settlements. The Carse of Gowrie, lying as it does between the principal settlements of Perth and Dundee, should not be the subject of an outright presumption against any development. Flooding is not a problem of sufficient importance to justify such a restriction and the density of population in the corridor is actually a positive factor to be harnessed in encouraging a switch from private to public transport.

GVA Grimley for David Wilson Homes (547268) considers that TAYplan should be encouraging appropriate greenfield land release on effective sites on the periphery of the principal settlements. Although the town of Kinross has some environmental and landscape constraints which should be appropriately managed the respondent also considers that there is opportunity for some limited expansion to the east of the town.

Montagu Evans (444081) considers that there is a disproportionate concentration of development, strategically focused within Dundee and Perth population centres. It is considered that further recognition for residential development should be given to the southern corridor of the TAYplan area, in-particular the Kinross Housing Market Area which provides good transport routes from Glasgow and Edinburgh as well as the cities and towns of Stirling, Dunfermline, Kirkcaldy and Glenrothes.

49 TAYPLAN STRATEGIC DEVELOPMENT PLAN Mr Ken Miles (548486) has requested that Kinross/Milnathort is reallocated to Tier 3 Settlement.

Muir Smith Evans for Muir Homes Limited (548051 - PLAN388) have commented that Auchterarder has previously been recognised as an appropriate location for growth. Auchterarder's location on a very significant transport corridor (bus, train and road) enhances its claim that it is capable of accommodating sustainable development. In this regard, the respondent considers that it is inappropriate for the Proposed Plan to classify Auchterarder as a Tier 3 settlement whist at the same time classifying Crieff as a Tier 2 settlement. Auchterarder as a settlement has more in common with other settlements which are classified as Tier 2. It has very different characteristics to other settlements which are classified as Tier 3 (e.g. Aberfeldy and Anstruther). Muir Smith Evans for Muir Homes Limited (548051 - PLAN406) also commented that the revised additional allocation (400) agreed in February 2009 by Perth & Kinross Council remains relevant and that no evidence has been produced as part of the TAYplan process to explain why this agreed strategic position of only two years ago should now be set aside. The agreed position with Perth & Kinross Council should provide the baseline figure from which to review the full potential of Auchterarder in its contribution to both the Strathearn area as a whole and the A9 Corridor. If allocated as a Tier 3 centre that will not be possible. The respondent is also concerned that significant investment and expenditure in infrastructure has been made in Auchterarder - undertaken by a number of developers, including Muir Homes Limited. This infrastructure has been paid for by the developers and was based on further development areas being released in due course. If development is restricted at Auchterarder, money will have been wasted and infrastructure capacity will remain unused, neither of which can be called sustainable.

Rossco Properties (442290) consider that Auchterarder and surrounding settlements including Dunning should be tier 2, not tier 3.

Smiths Gore for Errol Park Estate (442871 - PLAN628) considers that Errol should also be identified as a Tier 3 settlement.

Stewart Milne Homes (539251 - PLAN312) and Stewart Milne Homes (539251 - PLAN317) considers that the development hierarchy be removed from the Plan with all key service settlements other than Dundee and Perth core areas given equal development opportunities where infrastructure provision or investment allows. If TAYplan seeks to retain the development hierarchy, Stewart Milne Homes proposes that Auchterarder and Carnoustie are categorised as a tier 2 settlement.

Stewart Milne Homes (539251 - PLAN345) consider the following settlements for inclusion as the Region's principle Settlements and Land Allocations for Home Building and in support of Employment Generation at Liff; Carnoustie; Duntrune/Ballumbie; Taybridgehead; Dundee City; Perth West; Auchterarder; Crieff; Burrelton and Blairgowrie; Gauldry; and Strathkinness

TMS Planning (for Muir Homes Limited (346675 - PLAN354) and Muir Homes Limited (346675 - PLAN355)) consider that within the Proposed Plan details of the specific roles of the "principal settlements" and the rational for this status (particularly for the Tier 3 settlements) should be clearly set out.

The rational for rejecting other similarly sized settlements/those with similar characteristics and facilities from this elevated policy status (e.g. not considering these to be principal settlements) should also be clearly set out, towns such as Auchtermuchty. In the absence of appropriate justification, particularly in light of the enhanced policy status, Newburgh should be deleted as a Tier 3 principal settlement. In addition, in light of its 50 TAYPLAN STRATEGIC DEVELOPMENT PLAN gateway location on the main A91, and its present and potential function as a service centre, the town of Auchtermuchty should be identified as a Tier 3 principal settlement. Even if the latter is rejected, TAYplan should identify the important contributions of settlements, such as Auchtermuchty, and the potential for further development in this and similar settlements in order to positively contribute towards meeting the needs of TAYplan.

SUMMARY OF REPRESENTATIONS SUPPORTING AS WRITTEN

GENERAL

Abernethy & District Community Council (376787); Colliers International for Gleneagles Hotel (337727); Colliers International for Persimmon Homes Limited (416017); Colliers International for Taylor Wimpey East Scotland (541486); and Scottish Natural Heritage (344848) support paragraphs 8, 9, 10 and 11 on Page 8. Auchterarder & District Community Council (419429 - PLAN76); Braes of the Carse Conservation Group (423150 - PLAN21); Councillor Michael A Barnacle (450613 - PLAN812); D G Coutts Associates for Linlathen Developments (346407); Kinross-shire Civic Trust (546838); Loch Lomond and The Trossachs National Park Authority (442806 - PLAN101); Methven & District Community Council (450585 - PLAN862); PPCA Limited for Alfred Stewart Properties Limited (349010 - PLAN15); Scottish Enterprise (344939 - PLAN423) and Tactran Regional Transport Partnership (441235 - PLAN94) have all indicated support for Policy 1.

Colliers International for Gleneagles Hotel (337727) have indicated support for text beginning below Tier colour key "Local Development Plans may also provide for some development in settlements that are not defined as principal settlements and in rural areas where this can be accommodated and supported by the settlement, and where it genuinely contributes to the objectives of this Plan, and meets specific local needs or supports regeneration of the local economy".

Colliers International for Persimmon Homes Limited (416017 – PLAN41); Inchture Area Community Council (445299); Montagu Evans LLP for Wallace Land Investment Management (343111); Montgomery Forgan Associates for VGH (VICO Limited/Bett Homes/Headon Developments Limited) (349134) and SEStran Regional Transport Partnership (547388) support the prioritisation for land release within core areas and principal settlements ahead of land elsewhere, whilst Montgomery Forgan Associates for VGH (VICO Limited/Bett Homes/Headon Developments Limited) (349134) also indicate their support for Cupar being identified as a Tier 2 Settlement.

EMAC Planning (for A & J Stephen Limited (445201 - PLAN683); A & J Stephen Limited/Bett Homes Limited (548522 - PLAN731); Angus Estates Limited (445204 - PLAN599); Bett Homes Limited (548523 - PLAN760); J G Lang & Son (445206 - PLAN535); M Batchelor (K) (548301 - PLAN518); Mr R Watson (445205 - PLAN509) and Stewart Milne Homes (548524 - PLAN777)) support the identification of Dundee and Perth Core Areas as Tier 1 Settlements, together with the identification of Strategic Development Areas within Tier 2.

Montagu Evans (444081) support for statement that there is no requirement for any new settlements. Montgomery Forgan Associates for Strategic Land (Scotland) Limited (442083); and Montgomery Forgan Associates for Taylor Wimpey (331497) support for supporting text on Page 8 and Page 9 Policy 1, Parts A & B.

51 TAYPLAN STRATEGIC DEVELOPMENT PLAN Scottish Environmental Protection Agency (442031) supports reference to Strategic Flood Risk Assessment and Habitats Regulations Appraisal.

DUNDEE CORE AREA EMAC Planning (for A & J Stephen Limited (445201 - PLAN690); Bett Homes Limited (548523 - PLAN761)); Stewart Milne Homes (539251 - PLAN323) support the inclusion of Tayport, Newport and Wormit within the Dundee Core Area.

Montgomery Forgan Associates for Strategic Land (Scotland) Limited (442083 - PLAN277) support Policy 1, Part A, including the Dundee Core Area which includes peripheral settlements Muirhead and Birkhill.

Montgomery Forgan Associates for Taylor Wimpey (331497) support Tier 1, including the Dundee Core Area.

Muir Smith Evans for Muir Homes Limited (548051) supports the identification of Muirhead as a potential area for housing development within the Dundee Core Area.

PERTH CORE AREA Montgomery Forgan Associates for Morris Leslie Group (445161) supports the Perth Core Area as a Tier 1 Settlement, in-particular the inclusion of Perth Airport within the Core Area.

Savills for John Dewar Lamberkin Trust and Needhill LLP (548335) support Policy 1, in- particular the focus for development within the Perth Core Area.

Smiths Gore for Mansfield Estates (442870) support Policy 1, including the identification of Scone within the Perth Core Area.

ST. ANDREWS Hargest Planning Limited (548948 - PLAN856) supports St. Andrews being identified as a Tier 2 Settlement.

Ryden for University of St. Andrews (548506) support for Page 8, paragraph 5 and Page 9, paragraph 3.

OTHER SETTLEMENTS Colliers International for Persimmon Homes Limited (416017 - PLAN38) support the identification of Kinross as a principal settlement, whilst Colliers International (for Taylor Wimpey East Scotland (541886 - PLAN61) and Taylor Wimpey East Scotland (541886 - PLAN64)) support the identification of Crieff as a principal settlement.

DPP LLP for Kinross Estate Company (548029) support the inclusion of Kinross / Milnathort as a Tier 2 Settlement and the recognition that this location has the potential to make a major contribution to the regional economy and will accommodate a share of the region’s additional development.

DTZ for Headon Developments (548113) support Policy 1, including the identification of Leuchars / Guardbridge as a Tier 3 Settlement.

Dunning Community Council (379723) note that Auchterarder is Tier 3 Settlement and have indicated that they reserve their right to object to any further development within Auchterarder.

52 TAYPLAN STRATEGIC DEVELOPMENT PLAN Emac Planning for L Porter (548383 - PLAN548) support Arbroath being identified as a Tier 2 Settlement.

Kingsbarns Community Council (263542) support Policy 1, in-particular that the East Neuk of Fife should remain undeveloped beyond its present level.

Largo Area Community Council (450207) supports the prioritisation of Anstruther as the main focus of Tier 3 developments for the East Neuk of Fife.

Modifications sought by those submitting representations:

NOTE TO REPORTER: The text in italics in this section has been lifted directly from each individual/organisation’s representation with minor typographical errors corrected.

GENERAL Auchterhouse Community Council (545593); Karen Clark (for Balmossie Developments Limited and Messrs David Reid Farmers (443893) and Discovery Homes (346689 - PLAN542) • In A. outline map. Please show core areas on a map so that boundaries are clearly defined, e.g. exactly where is the Dundee core northern boundary? These boundaries are far too vague as it is.

Colliers International for Gleneagles Hotel (337727) • No specific change identified, although consider that paragraph 7 on Page 8 is misleading and therefore the locations, Pitlochry and St Andrews should be deleted or should include other locations such as Gleneagles. Alternatively, the respondent suggests that all location names should be removed.

Colliers International for Persimmon Homes Limited (416017) • Wording to Tier 2, change "accommodate small share" to "accommodate a proportionate share".

Emac Planning (for A & J Stephen Limited (445201 - PLAN683); A & J Stephen Limited (445201 - PLAN684); A & J Stephen Limited/Bett Homes Limited (548522 - PLAN731); A & J Stephen Limited/Bett Homes Limited (548522 - PLAN733); Angus Estates Limited (445204 - PLAN599); Bett Homes Limited (548523 - PLAN760); J G Lang & Son (445206 - PLAN535) and Stewart Milne Homes (548524 - PLAN777)) • The identification of Dundee and Perth Core Areas as Tier 1 settlements is supported, together with the identification of Strategic Development Areas within Tier 2. However, non-Strategic Development Area settlements identified in Tier 2 should be removed together with Tier 3 settlements and the settlement priorities left for the more detailed Local Development Plan's to determine.

Emac Planning (for A & J Stephen Limited (445201 - PLAN687); A & J Stephen Limited/Bett Homes Limited (548522 - PLAN735); Angus Estates Limited (445204 – PLAN601) and Bett Homes Limited (548523 - PLAN762) • Propose that the development hierarchy be removed from the Plan with all key service settlements other than Dundee and Perth core areas given equal development opportunities where infrastructure provision or investment allows.

Emac Planning for L Porter (548383) • A better approach would be for the development hierarchy to be removed from the 53 TAYPLAN STRATEGIC DEVELOPMENT PLAN TAYplan, with the Proposals 1: Map showing only the strategic growth areas, that is, the Core Areas and Strategic Development Areas. All other key service settlements could be identified for growth through the Local Development Plan process.

Andrew McCafferty Associates for GD Strawson and J Farquharson (548151 – PLAN736) • There are inconsistencies between Proposals 1: Map and the map on page 9 in respect of the "Undeveloped Coast" notation. The broken line is in a different place on the map on page 9 compared with its position on Proposals 1: Map and two different colours have been used i.e. yellow on Proposals 1: Map and green on the map on page 9. Request that the notation "Undeveloped Coast" be removed from Proposals 1: Map and the map on page 9.

Homes for Scotland (442882 - PLAN214) and Montagu Evans (444081 – PLAN320) • Below Tier 1, all settlements should be included without further division.

J Khazaka (327210) • This statement “There will be no need for any new settlements during the lifetime of this Plan.” should be removed from the Tayplan Proposed Plan.

Montagu Evans (444081) • Supports the statement within Part A which states that Local Developments Plans may also provide for some development in settlements that are not principle settlements. It is considered that this policy should also state that the land allocated for development should be land that can be brought forward and developed within the plan period.

Stewart Milne Homes (539251 - PLAN322) • Stewart Milne Homes proposes the development hierarchy be removed from the plan with all key service settlements other than Dundee and Perth core areas given equal development opportunities where infrastructure provision or investment allows.

Muir Group (450286 - PLAN167) • Tiers 2 and 3 should be omitted and substituted by a statement to the effect that the balance of development should be distributed amongst the region's remaining settlements in accordance with demand/need within each housing market area.

Ryden (for Bon Accord Land Limited/Stewart Milne Homes (330884 - PLAN127); and Bon Accord Land Limited/Stewart Milne Homes (330884 - PLAN128) • In terms of Part A of Policy 1, too much emphasis is placed on Dundee and Perth as economic drivers. There are other locations, such as Montrose which have the ability to be an economic driver. This should be reflected in the Tayplan. • Objection is made to the settlement hierarchy. An explanation or justification for the categorisation of each settlement in each tier should be provided. • The current classification contradicts itself. If a tier two settlement makes a major contribution to the regional economy, they should be given the opportunity to accommodate a larger share of new development. The identification of land for development should be made on the merits of each settlement, not where it fits in the hierarchy.

Mr Ian Fowler (548055 - PLAN386) • No specific change identified although considers that the Proposed Plan lacks any detailed information on development location or how it will be controlled and that there 54 TAYPLAN STRATEGIC DEVELOPMENT PLAN seems to be a lot of general comments and promises but no fine detail on how the plan will be implemented to reassure the public.

DUNDEE CORE AREA Emac Planning for A & J Stephen Limited (445201 - PLAN685) • There is market demand for development to the north west of Dundee at Birkhill, i.e. as part of the Dundee Core Area. We therefore recognise and welcome the identification of ‘Birkhill/Muirhead' as a stated element of the Dundee Core Area and the priority for land release for development within this Tier 1 area.

Karen Clark for Discovery Homes (346689 - PLAN203) • As a result of the effectiveness issues which have occurred in light of the on going difficult economic climate further consideration related to the range, location and spread of housing allocation within the Dundee area.

Karen Clark for Discovery Homes(346689 - PLAN542) • Recognition in the Location Priorities of the pressures on the urban fringe areas.

Mr Stewart McKiddie (344874 - PLAN645) • Newport and Wormit should be deleted from Dundee Core Area.

Stewart Milne Homes (539251 - PLAN313); Stewart Milne Homes (539251 - PLAN314); and Stewart Milne Homes (539251 - PLAN315) • Stewart Milne Homes propose that the villages of Liff, Ballumbie & Duntrune be included within the Dundee Core Area for inclusion within the City's development boundary.

Stewart Milne Homes (539251 - PLAN319 and PLAN321) • Stewart Milne Homes propose that a wider cross section of land be identified for development within the Dundee City Core Area to ensure there is an adequate supply of unconstrained developable land that can be effective from the early stages of the plan.

PERTH CORE AREA Emac Planning for A & J Stephen Limited (445201 - PLAN692) • The Perth Core should be amended to cover "an area within approximately 25 minutes travel by local bus from the centre of Perth". GS Brown Construction (543112 - PLAN84) • In relation to Perth Core Area the majority of new development is earmarked for the Perth North West Expansion Scheme and Oudenarde which, in different ways, are jeopardised by education and roads infrastructure costs. It is not clear how the plan envisages a solution to these problems.

Jim Farquharson (546432 - PLAN208) • No specific change identified, although has raised concerns about the justification for further development in Perth when flooding is not only a risk but in fact is a reality, even in mid- summer and notes that there is no record of flooding in the Carse of Gowrie.

Lynne Palmer (443979 - PLAN153) • Considers that Bridgend should form part of the Perth Core Area. The respondent considers that Bridgend is a congested area in terms of traffic, pollution, housing and land space. 55 TAYPLAN STRATEGIC DEVELOPMENT PLAN Miss Lynn McGeorge (548414 - PLAN607) • Object to Luncarty, Stanley, Balbeggie & Perth Airport being included within Perth Core Area.

Mr David Dykes (527724 - PLAN481) • Implying that Scone is removed from Perth Core Area.

Mrs D Jeffrey (548760 - PLAN810) • No specific change identified, although considers that the prospect of building new settlements should not be discounted.

Ms Joan McEwen Sprunt (548250 - PLAN476) • Perth Core Area should include Carse of Gowrie and Guildtown.

ST. ANDREWS

Hargest Planning Limited (548948) • No specific change identified, although consider that the statement in Policy 1, Part A that there will be no additional strategic development in the foreseeable future beyond the St Andrews Strategic Development Area is inappropriate and inconsistent with information and analysis set out in support of the draft Strategic Development Plan.

Montgomery Forgan Associates for Headon Developments Limited (349140) • No specific change identified, although have indicated concern about the vague and ambiguous nature of the statement "Beyond the Strategic Development Area in Policy 4 for St Andrews there will be no additional strategic development of this scale in the foreseeable future." and request that the terms and purpose/objective of this part of Policy 1 Part A be clarified and confirmed.

Mr Howard Greenwell (546652 - PLAN255) • Reword the text "Beyond the Strategic Development Area in Policy 4 for St. Andrews there will be no additional strategic development of this scale in the foreseeable future" to say "For St. Andrews there will be no additional strategic development in the foreseeable future"

Mr Kyffin Roberts (337567) and Royal Burgh of St. Andrews Community Council (453889 - PLAN919) • Change "Tier 2 settlements have the potential to make a major contribution to the regional economy but will accommodate a smaller share of the region's additional development" to "Tier 2 settlements have the potential to make a major contribution to the regional economy but will accommodate a smaller share of the region's additional development both in absolute terms and relative to their size." • Delete "Beyond the Strategic Development Area in Policy 4 for St. Andrews there will be no additional strategic development of this scale in the foreseeable future" • Change "Beyond the Strategic Development Area in Policy 4 for St. Andrews there will be no additional strategic development of this scale in the foreseeable future" to "Beyond the Strategic Development Area in Policy 4 for St. Andrews there will be no additional strategic development of this scale since to do so would cause irreparable damage to the landscape setting of the town."

Professor Christopher M Steel (547478 - PLAN280) • The designation of St. Andrews as a "second tier" centre of population should be clarified to mean St. Andrews and its hinterland - specifically including Guardbridge 56 TAYPLAN STRATEGIC DEVELOPMENT PLAN and Leuchars. TAYplan evidently incorporates the existing Fife Structure plan which sees St. Andrews as "The economic driver for the whole of Fife". This is a blinkered view unless "greater St Andrews" is envisaged. With the main line rail station at Leuchars, the brownfield site at Guardbridge and the real possibility of commercial development of the former Leuchars air base, it would be foolish in the extreme to neglect the immense potential of this specific part of Fife - much more suited to development (industrial, commercial and housing) than central St Andrews.

Ryden for University of St Andrews (548506) • Amend Policy 1, paragraph 4 as it relates to St Andrews as follows: make clear what is means by "additional strategic development" and clarify on what basis this part of Policy 1 has been included.

Sarah Hunt (548386) • No specific change identified, although considers that there is opportunity to develop at Guardbridge and Leuchars and that St. Andrews should be categorised as a small town.

SEStran Regional Transport Partnership (547388 - PLAN272) • No specific change identified, although consider that it is worth including an additional statement in relation to proposed development in St. Andrews, such as "In developing their Local Plans, the Local Planning Authority should consider the appropriateness of protecting the alignment of the Leuchars to St. Andrews rail line for future use as a transport corridor".

Strathkinness Community Council (546153) • No specific change identified, although have commented in relation to the future use of the base at RAF Leuchars as the Proposed Plan classifies Leuchars / Guardbridge as a Tier 3 settlement in terms of its development role. Concerned about the impact on the communities, especially in relation to housing, schooling, transport and healthcare given the proposed change to RAF Leuchars.

OTHER SETTLEMENTS

Alyth Community Council (548872) • No specific change identified, although concerned that as a Tier 3 settlement Alyth appears to be deemed as not requiring development.

Barton Willmore for Scotia Homes (443109) • Remove reference to "small" share and insert "but will accommodate a share of the region's additional development."

Colliers International (for Persimmon Homes Limited (416017) and Colliers International for Taylor Wimpey East Scotland (541486)) • Wording to Tier 2, change "accommodate small share" to "accommodate a proportionate share".

Dundas Estates & Development Company (548117) • The proposed settlement Tiers should be abandoned below Tier 1 or amended to remove the outlying villages around Perth and Dundee from Tier 1 status. • The status of Cupar should be better reflected within Policy 1.We agree that Cupar has the potential to make a major contribution to the regional economy, but contrary to Policy 1 as currently drafted, we would suggest that Cupar is capable of 57 TAYPLAN STRATEGIC DEVELOPMENT PLAN accommodating a large share of the region's additional development.

Emac Planning for J G Lang & Son (445206 - PLAN539) • It is considered that the TAYplan should adopt a strategy for growth which is sufficiently flexible to enable settlements, such as Springfield, to be considered for growth in the forthcoming Local Development Plan.

Emac Planning for James Keiller Estates(445203) • TAYplan should support additional land releases to the north of Dundee along the A90 corridor at Inveraldie. It is suggested that the TAYplan identifies Inveraldie as a Principal Settlement, or alternatively, if the TAYplan removes Tiers 2 (Non-Strategic Development Areas) and Tier 3 settlements from Proposals 1: Map, TAYplan encourages support for the identification of Inveraldie as a Principal Settlement in the Local Development Plan.

Emac Planning (for M Batchelor (K) (548301); and EMAC Planning for Mr R Watson (445205 - PLAN509)) • The identification of Dundee and Perth core areas as Tier 1 settlements is supported, together with the identification of Strategic Development Areas within Tier 2. However, non-SDA settlements identified in Tier 2 should be removed together with Tier 3 settlements (option a). Alternatively, if the identification of other settlements in Tier 2 and 3 remains unchanged, Friockheim and Newbigging should be identified in Tier 3 of the hierarchy (option b).

EMAC Planning for Mr W Robertson (445207) • Under Category B. insert at the end "...in urban and rural locations. The regeneration of Crail Airfield, as a rural brownfield site will be prioritised for redevelopment."

Andrew McCafferty Associates for GD Strawson and J Farquharson (548151 - PLAN445) • Request the inclusion of a new category in Part A between Tier 1 and Tier 2 and that is a new settlement at Horn Grange.

GS Brown Construction (543112 – PLAN87) • No specific change identified, although concerned that the plan is too heavily skewed towards development taking place in major settlements, thereby preventing natural growth and development of some of the smaller settlements, such as those in the Carse of Gowrie.

GVA Grimley for David Wilson Homes (547268 - PLAN448) • Encouragement should be given on the periphery of the principal settlements for appropriate greenfield land release on effective sites. This is necessary to ensure that housing requirements and growth targets are met in the principal settlements.

Montagu Evans (444081) • There is a disproportionate concentration of development, strategically focused within Dundee and Perth population centres. It is considered that further recognition for residential development should be given to the southern corridor of the TAYplan area.

Mr Ken Miles(548486 - PLAN831) • Reallocate Kinross/Milnathort to Tier 3 developments.

58 TAYPLAN STRATEGIC DEVELOPMENT PLAN Muir Smith Evans (for Muir Homes Limited (548051 - PLAN388; and Muir Homes Limited (548051 - PLAN406)) • The classification of Auchterarder as a Tier 3 settlement is not appropriate. • The classification should be revised to Tier 2.

Rossco Properties (442290 - PLAN162) • Auchterarder and surrounding settlements including Dunning should be tier 2, not tier 3.

Smiths Gore for Errol Park Estate (442871 - PLAN628) • Errol should also be identified on the associated plan as a tier 3 settlement.

Stewart Milne Homes (539251 - PLAN312); Stewart Milne Homes (539251 - PLAN317)

• The development hierarchy be removed from the Plan with all key service settlements other than Dundee and Perth core areas given equal development opportunities where infrastructure provision or investment allows. If TAYplan seeks to retain the development hierarchy, Stewart Milne Homes proposes that Auchterarder and Carnoustie are categorised as a tier 2 settlement.

Stewart Milne Homes (539251 - PLAN345)

• Stewart Milne Homes propose the following settlements for inclusion as the Region's principle Settlements and Land Allocations for Home Building and in support of Employment Generation at Liff; Carnoustie; Duntrune / Ballumbie; Taybridgehead; Dundee City; Perth West; Auchterarder; Crieff; Burrelton and Blairgowrie; Gauldry; and Strathkinness.

TMS Planning (for Muir Homes Limited (346675 - PLAN354); and TMS Planning for Muir Homes Limited (346675 - PLAN355))

• Within the Proposed Plan details of the specific roles of the "principal settlements" and the rational for this status (particularly for the Tier 3 settlements) should be clearly set out - why settlements were selected for this status. The rational for rejecting other similarly sized settlements/those with similar characteristics and facilities from this elevated policy status (e.g. not considering these to be principal settlements) should also be clearly set out, towns such as Auchtermuchty. In the absence of appropriate justification, particularly in light of the enhanced policy status, Newburgh should be deleted as a Tier 3 principal settlement. In addition, in light of its gateway location on the main A91, and its present and potential function as a service centre, the town of Auchtermuchty should be identified as a Tier 3 principal settlement. Even if the latter is rejected, TAYplan should identify the important contributions of settlements, such as Auchtermuchty, and the potential for further development in this and similar settlements in order to positively contribute towards meeting the needs of TAYplan.

Summary of responses (including reasons) by planning authority:

RESPONSES TO REPRESENTATIONS SEEKING A CHANGE

GENERAL Auchterhouse Community Council (545593); Karen Clark (for Balmossie Developments Limited and Messrs David Reid Farmers (443893); and, Discovery Homes (346689 - PLAN542)) Emerging Local Development Plan’s will define settlement 59 TAYPLAN STRATEGIC DEVELOPMENT PLAN boundaries or in the case of Dundee City Council areas for different land uses including recreation and open space. In relation to housing, Policy 1 should be read in conjunction with Policy 5 of the Proposed Plan (Page 17) which focuses the vast majority of Dundee Core Area housing within the Dundee City Council administrative area. The Local Development Plan process will determine which locations within the Core Areas are the most appropriate for which types of land use.

Colliers International for Gleneagles Hotel (337727) There are numerous examples of where national and international golf competitions are held or other areas important to tourism and not all can be listed. As far as golf is concerned the foreword covers Gleneagles, St. Andrews and Carnoustie, recognising their role as international golf competition venues. This section contextualises the point about tourism and golf by referring to two of the Visit Scotland ‘destinations’, clearly there are other areas too. No change is considered necessary.

Colliers International for Persimmon Homes Limited (416017); Emac Planning (for A & J Stephen Limited (445201 - PLAN683); A & J Stephen Limited (445201 - PLAN684); A & J Stephen Limited/Bett Homes Limited (548522 - PLAN731); A & J Stephen Limited/Bett Homes Limited (548522 - PLAN733); Angus Estates Limited (445204 - PLAN599); Bett Homes Limited (548523 - PLAN760); J G Lang & Son (445206 - PLAN535); Stewart Milne Homes (548524 - PLAN777); A & J Stephen Limited (445201 - PLAN687); A & J Stephen Limited/Bett Homes Limited (548522 - PLAN735); Angus Estates Limited (445204 – PLAN601); Bett Homes Limited (548523 - PLAN762); L Porter (548383); Homes for Scotland (442882 - PLAN214)); Montagu Evans (444081 – PLAN320); Stewart Milne Homes (539251 - PLAN322); Muir Group (450286 - PLAN167); Ryden for Bon Accord Land Limited/Stewart Milne Homes (330884 - PLAN127 and PLAN128); Barton Willmore for Scotia Homes (443109); Colliers International (for Persimmon Homes Limited (416017); Taylor Wimpey East Scotland (541486)) and Dundas Estates & Development Company (548117) The above respondents consider that there is either too much emphasis placed on Dundee and Perth and that the settlement categorisation is unjustified, contradictory and should be removed from the Proposed Plan. The settlement hierarchy is designed to focus the majority of the region’s development in principal settlements. These are the largest concentrations of people, jobs, services and facilities. Topic Paper 6: Spatial Strategy (Page 3, Paragraph 3.4) (CL/Doc35) explains that the principal settlements were divided into three tiers to reflect their different scales, roles and functions, now and in the future. Concentrating development in these settlements is seen as the best way to ensure that people, business, jobs, services and facilities are all close together offering increased access and opportunities This is central to meeting the vision and objectives including the need to travel, reduce carbon emissions, reinvest in existing communities and support sustainable economic growth. Dundee and Perth Core Areas are the largest concentrations of people, jobs, services and facilities. They are and will continue to be the major drivers for the regional economy. However, other settlements and localities will also drive the economy individually or collectively. Tier 2 recognises that other smaller principal settlements will also play a major role in the economy but that this is unlikely to be similar in scale to tier 1. The scale of development will also differ as tier 2 settlements accommodate a smaller scale of additional development than tier 1 settlements. Using Montrose Port and St Andrews University as examples, both are within tier 2 settlements and have the potential to increase their economic presence. However, both facilities already exist and the scale of additional development may not necessarily be large because the economic strength will be partly driven by how these existing facilities are used. The subsequent identification of development land is for Local Development Plans based on the merits of that land within the context of the strategy. There may be circumstances where some land is allocated within and some on the edges of a principal settlement but it will be for the Local Development Plan to determine if this is the most appropriate outcome. It would 60 TAYPLAN STRATEGIC DEVELOPMENT PLAN be contradictory to a strategy with these objectives to prioritise development in other locations ahead of development within principal settlements. The tiers are considered the best way to appropriately distinguish between the similarities and differences of the principal settlements and how they would be expected to contribute to delivering the objectives of this Plan.

In relation to the request to modify the Tier 2 description from a ‘small share of development’ to a ‘proportionate share of development’. TAYplan consider that this change would suggest some kind of statistical link between the size of the settlement (e.g. Kinross, Crieff and Auchterarder) and the scale of future development. No such statistical relationship is being made in the Proposed Plan, rather a notional relationship between the broad scale and function of the settlement and how it will perform as part of the strategy. It is for the emerging Local Development Plan’s to determine the appropriate mix of different types of land use and best scale and distribution of these to fulfil the objectives of the TAYplan strategy whilst also considering local circumstances such as development quality, and, environmental and infrastructure capacity. This cannot be done through an arbitrary statistical or ‘proportionate’ relationship based on the present rather than future requirements and issues.

Andrew McCafferty Associates for GD Strawson and J Farquharson (548151 – PLAN736) TAYplan do not consider that the Undeveloped Coast notation should be removed from the Proposed Plan as requested. The notations are indicative only with specific areas/boundaries being established in more detail within the emerging Local Development Plans. Scottish Planning Policy that “Areas which are unsuitable for development will include the isolated coast, which is distant from centres of population and lacks obvious signs of development and is of very significant environmental, cultural and economic value. The special characteristics of the isolated coast should be protected, and there is a presumption against development in these areas” (Scottish Planning Policy, Page 21, Paragraph 102) (CL/Doc2). Policy 1 and associated maps are consistent with Scottish Planning Policy. The Key Agencies, including Scottish Natural Heritage, Scottish Environmental Protection Agency nor the Scottish Government have specified any changes to Policy 1 and have worked in partnership with TAYplan on this.

J Khazaka (327210) TAYplan does not consider that the statement on Page 8 should be deleted as requested by the respondent. The statement refers to there being no need for new settlements during the lifetime of this Plan. The Background Technical Note (Page 123, Paragraph 8.71) (CL/Doc58) explains that that there is likely to be sufficient land to accommodate anticipated development within existing settlements over the first 12 years of the Plan. Given this circumstance, and with no defined need for a new settlement, it is most likely that settlement extensions would best reflect the objectives of the settlement strategy within the Proposed Plan. Any change, in the Policy to suggest new settlements would be acceptable would fundamentally undermine the Plan’s objectives.

Montagu Evans (444081) Policy 1 sets out the spatial strategy and says where development should and should not go. It focuses the majority of the region’s new development within principal settlements. Policy 5 specifies that Local Development Plans should identify a minimum 5 year and work towards a 7 year effective housing land supply by 2015 to support economic growth. TAYplan do not consider that an additional statement is therefore required within Policy 1 of the Proposed Plan as requested by the respondent, as the emerging Local Development Plans will be required to allocate land within each Housing Market Area in order to provide for an effective and generous supply of housing land as required by Scottish Planning Policy (Page 14, Paragraph 70) (CL/Doc2). In addition, if the additional statement was included and be repetitive in other policy areas, a short, concise and visionary Strategic Development Plan would not be possible (Planning Circular 1/2009: Development Planning, Page 4, Paragraph 14) (CL/Doc29). 61 TAYPLAN STRATEGIC DEVELOPMENT PLAN Mr Ian Fowler (548055) The issues raised by the respondent are not of strategic significance. Development locations and the specific locational policy framework will be established by the emerging Local Development Plans. The Proposed Strategic Development Plan does not require to repeat this detail. If it did so, and be repetitive in other policy areas, a short, concise and visionary Strategic Development Plan would not be possible (Planning Circular 1/2009: Development Planning, Page 4, Paragraph 14) (CL/Doc29).

DUNDEE CORE AREA

Emac Planning for A & J Stephen Limited (445201 - PLAN685); Karen Clark (for Discovery Homes (346689 - PLAN203); Discovery Homes(346689 - PLAN542)); Mr Stewart McKiddie (344874 - PLAN645); Stewart Milne Homes (539251 - PLAN313, PLAN314 and PLAN315) and Stewart Milne Homes (539251 - PLAN319 and PLAN321) The settlement hierarchy is designed to focus the majority of the region’s development in principal settlements. Topic Paper 6: Spatial Strategy (CL/Doc35) explains that the principal settlements were divided into three tiers to reflect their different scales, roles and functions, now and in the future. Concentrating development in these settlements is seen as the best way to ensure that people, business, jobs, services and facilities are all close together offering increased access and opportunities (Page 3, Paragraph 3.4) This is central to meeting the vision and objectives including the need to travel, reduce carbon emissions, reinvest in existing communities and support sustainable economic growth. Dundee and Perth Core Areas are the largest concentrations of people, jobs, services and facilities. They are and will continue to be the major drivers for the regional economy.

The arguments put forward by Mr Stewart McKiddie (344874 - PLAN645) and Stewart Milne Homes (539251 - PLAN313, PLAN314 and PLAN315) for the deletion and inclusion of other settlement(s) from the Dundee Core Area do not persuade TAYplan that amendments should be made to the Proposed Plan. This is because the settlements at Liff and Ballumbie/Duntrune are small and consequently do not accommodate the scale of population, jobs, services or facilities of a principal settlement and do not fulfil such a role at present. Although a major planning application has been submitted by Stewart Milne Homes (539251) for residential and golf course development at Ballumbie this currently pending consideration. There is however no policy intention at present to escalate the scale of development at either Liff or Ballumbie/Duntrune so that it could be considered a principal settlement. Within the Dundee Core Area there are a number of major individual strategic sites, including sites within Wormit, Tayport, Newport as well as Dundee Western Gateway. These sites have already been allocated through approved Structure Plans / Local Plans or have planning permission and these strategic sites will affect the implementation of the Strategic Development Plan during its first 12 years and beyond in some cases (Background Technical Note (2010), Pages 111-112, Paragraphs 8.27-8.28 and 8.32) (CL/Doc58). Adding additional settlement(s) within Policy 1 would compromise the principles of the location priorities established in Policies 1 and 3 and would also contradict the Vision and Objectives of the Proposed Strategic Development Plan.

In relation to the effectiveness issues raised by of the Dundee Western Gateway Strategic Development Area, this is considered in more detail within the following Schedule 4:- Issue Number 14: Strategic Development Areas – Alternative Sites.

A number of respondents, including Emac Planning for A & J Stephen Limited (445201 - PLAN685); Karen Clark for Discovery Homes(346689 - PLAN542) and Stewart Milne Homes (539251 - PLAN319) consider that additional land release generally within the Dundee Core, on land at Birkhill and on the urban fringes should be considered further. The identification of development land is for emerging Local Development Plans to consider 62 TAYPLAN STRATEGIC DEVELOPMENT PLAN based on the merits of that land within the context of the strategy. There may be circumstances where some land is allocated within and some on the edges of a principal settlement but it will be for the Local Development Plan to determine if this is the most appropriate outcome.

TAYplan consider that a change to the Dundee Core Area would fundamentally alter the Plan’s locational strategy. No key agencies or the Scottish Government are seeking a change to Policy 1.

PERTH CORE AREA

Emac Planning for A & J Stephen Limited (445201 - PLAN692); GS Brown Construction (543112 - PLAN84); Jim Farquharson (546432 - PLAN208); Lynne Palmer (443979 - PLAN153); Miss Lynn McGeorge (548414 - PLAN607); Mr David Dykes (527724 - PLAN481); Mrs D Jeffrey (548760 - PLAN810); Ms Joan McEwen Sprunt (548250 - PLAN476) The above respondents in some cases are seeking the deletion of settlements from the Perth Core Area and in other cases are promoting that additional settlements should be included within the Perth Core Area.

The settlement hierarchy is designed to focus the majority of the region’s development in principal settlements. Topic Paper 6: Spatial Strategy (CL/Doc35)explains that the principal settlements were divided into three tiers to reflect their different scales, roles and functions, now and in the future. Concentrating development in these settlements is seen as the best way to ensure that people, business, jobs, services and facilities are all close together offering increased access and opportunities (Page 3, Paragraph 3.4) This is central to meeting the vision and objectives including the need to travel, reduce carbon emissions, reinvest in existing communities and support sustainable economic growth. Dundee and Perth Core Areas are the largest concentrations of people, jobs, services and facilities. They are and will continue to be the major drivers for the regional economy.

In terms of the deletion and inclusion of other settlement(s) from the Perth Core Area, TAYplan is not persuaded to amend the Proposed Plan. Settlements identified within the Perth Core Area already contain a number of major individual strategic sites, including sites at Oudenarde and Almond Valley. These sites have already been allocated by approved Structure Plans/Local Plans or have planning permission. These strategic sites will affect the implementation of the Strategic Development Plan during its first 12 years and beyond in some cases (TAYplan Background Technical Note (2010), Pages 111-112, Paragraphs 8.27-8.28 and 8.33) (CL/Doc58).

In terms of the issue raised by Lynne Palmer (443979) regarding the omission of Bridgend, it should be noted that Bridgend is already part of Perth along with other neighbourhoods and is therefore already included within the definition of Perth Core Area. No change is therefore proposed. The inclusion of the Carse of Gowrie suggested by Jim Farquharson (546432) and Ms Joan McEwen Sprunt (548250) and Guildtown also suggested by Ms Joan McEwen Sprunt (548250) within the Perth Core Area are also not considered appropriate as the settlements are small and consequently do not accommodate the scale of population, jobs, services or facilities of a principal settlement and do not fulfil such a role at present. There is also no policy intention at present to escalate the scale of development at the Carse of Gowrie and Guildtown so that it could be considered a principal settlement.

It should also be noted that within the Background Technical Note to the Main Issues Report (April 2010) (CL/Doc58), TAYplan considered a Spatial Strategy which would have focused development along the region’s main transport corridors. This would have included land at the Carse of Gowrie. Such a spatial strategy was considered unreasonable and unrealistic 63 TAYPLAN STRATEGIC DEVELOPMENT PLAN given the reliance on travel to access jobs, services and facilities which would be inconsistent with Scottish Planning Policy (Background Technical Note (2010), Pages 118- 119, Paragraphs 8.52-8.55) (CL/Doc58). The majority of Main Issues Report respondents preferred the strategy of concentrating growth in Core Areas (Topic Paper 6: Spatial Strategy, Page 4) (CL/Doc35).

In relation to comments regarding flooding (Jim Farquharson (546432)) and potential infrastructure constraints with the proposed Strategic Development Areas (GS Brown Construction (543112 - PLAN84 and PLAN87)) TAYplan previously carried out an exercise to understand the key environmental and infrastructure issues presented by the strategic sites. The assessments aimed to understand what infrastructure support exists and what improvements may be needed. (Background Technical Note (2010), Pages 113, Paragraphs 8.35 and Pages 125-134, Annexe A) (CL/Doc58). In addition, the Background Technical Note (2010) (Page 121, Paragraph 8.65) indicates that “the Strategic Environmental Assessment concludes that substantial parts of the Carse of Gowrie are already at medium to high flood risk which could increase with sea level rise. Although Perth City Centre and some sites along the Tay and Almond experience high flood risk there are already some defences and the critical mass of development and economic interest to make further defence measures comparatively viable. Locating a greater share of development in the Carse of Gowrie, would place more households in locations of increasing flood risk with less likelihood of protection from defences.” TAYplan considers that these matters can be addressed and mitigated satisfactorily through the emerging Perth & Kinross Local Development Plan or through the planning application process. Neither Scottish Environmental Protection Agency, Scottish Natural Heritage, nor the Scottish Government have raised any issues regarding flooding or other potential infrastructure constraints and have sought no changes to Policy 1.

TAYplan consider that a change to the Perth Core Area would fundamentally alter the Plan’s locational strategy. No key agencies or the Scottish Government are seeking a change to Policy 1.

ST. ANDREWS Hargest Planning Limited (548948); Montgomery Forgan Associates for Headon Developments Limited (349140); Mr Howard Greenwell (546652):- Mr Kyffin Roberts (337567); Royal Burgh of St. Andrews Community Council (453889 - PLAN919) and Ryden for University of St. Andrews (548506) TAYplan does not consider that any modification or additional information is required in relation to Policy 1, Part A as it relates to St. Andrews. The recently approved Fife Structure Plan (2009) (CL/Doc39) has already carried out an exercise to identify and consider the implications of strategic sites, including St. Andrews (Background Technical Note (2010), Page 112, Paragraph 8.31) (CL/Doc58). The paragraph within Policy 1 regarding St. Andrews is included in order to protect the setting of the town and the views in and out of its historic core. Smaller scale development within the town’s boundary will be for the emerging Local Development Plan to consider (Topic Paper 6: Spatial Strategy, Page 7, Paragraph 5.13) (CL/Doc35). This approach is also compatible with Policy 3 (Greenbelts).

Mr Kyffin Roberts (337567); Royal Burgh of St. Andrews Community Council (453889 - PLAN919) Professor Christopher M Steel (547478); Sarah Hunt (548386) and SEStran (547388) Tier 2 Settlements accommodate some of the TAYplan area new development but at a much smaller scale than the Tier 1 settlements. They are differentiated from Tier 3 because their present roles as service centres, particularly retail and their potential economic significance are important in regional terms, for example the tourism and research potential of St Andrews. The strategy of the Proposed Plan allows for some development in these areas to support their present roles, recognising that their continued use and improvements 64 TAYPLAN STRATEGIC DEVELOPMENT PLAN will contribute significantly to the regional economy. However, beyond the strategic sites outlined in Policy 4 of the Proposed Plan (Page 15) Tier 2 settlements accommodate a smaller share of the new development of the TAYplan area and would be unlikely to accommodate additional strategic scale development. Beyond existing proposals in and around St. Andrews, development pressures would be directed away from St. Andrews (Background Technical Note (2010), Page 115, Paragraphs 8.39) (CL/Doc58). Leuchars/Guardbridge were included as Tier 3 Settlements within the Proposed Plan given the anticipated regeneration of the former paper mill in Guardbridge which will concentrate a scale and function of development in the settlements which reflects the intended role of Tier 3 Settlements. In addition, their position on the national rail network better describes the role of Leuchars/Guardbridge in the future (Topic Paper 6: Spatial Strategy, Page 7, Paragraph 5.10) (CL/Doc35). There is no requirement to merge St. Andrews with Leuchars/Guardbridge.

The comments by Strathkinness Community Council (546153) relate to the recent announcement by the Secretary of State for Defence, the Rt Hon Dr Liam Fox MP (CL/Doc64) to the House of Commons that RAF Leuchars would close as an RAF station and would later be taken over by the British Army as a base for two battalion/regiment sized units and a head quarters for a new multi-role brigade. Although the number of personnel anticipated would represent an increase of about 150 plus dependents. Given the proposed, modest increase in personnel anticipated, TAYplan does not consider that a change is required from Leuchars/Guardbridge as a Tier 3 Settlement within the Proposed Plan.

SEStran (547388) TAYplan does not consider that an additional statement is required in relation to protecting the alignment of the Leuchars to St. Andrews rail line as requested by the respondent. This issue is considered further under Schedule 4 Issue Number 2: Proposals 1 Map.

OTHER SETTLEMENTS

Alyth Community Council (548872) TAYplan does not agree with the respondents view regarding development within Alyth. As a Tier 3 Settlement Alyth is considered to have the potential to play an important but modest role in the regional economy and will accommodate a small share of the region’s additional development which is more about sustaining them. Ultimately, the emerging Perth & Kinross Local Development Plan will determine the scope, scale and location of future land allocations within the town.

Emac Planning (for J G Lang & Son (445206 - PLAN539); James Keiller Estates (445203); M Batchelor (K) (548301); Mr W Robertson (445207); and Mr R Watson (445205 - PLAN509)); Andrew McCafferty Associates for GD Strawson and J Farquharson (548151 - PLAN445); Montagu Evans (444081); Smiths Gore for Errol Park Estate (442871 - PLAN628); Stewart Milne Homes (539251 - PLAN345); TMS Planning (for Muir Homes Limited (346675 - PLAN354) and TMS Planning for Muir Homes Limited (346675 - PLAN355)):- The above respondents all consider that additional settlements, across the TAYplan should be included as principal settlements within Policy 1, although it should be noted that a number of settlements listed by Stewart Milne Homes (539251 - PLAN345) are already included as principle settlements. Notwithstanding this, the arguments put forward by the respondents for the inclusion of other settlement(s) do not persuade TAYplan that amendments should be made to the Proposed Plan. This is because the settlements are small and consequently do not accommodate the scale of population, jobs, services or facilities of a principal settlement and do not fulfil such a role at present. There is also no policy intention at present to escalate the scale of development within these settlements so that they could be considered a principal settlement. Topic Paper 6: Spatial Strategy (CL/Doc35) explains that the principal settlements were divided into three tiers to 65 TAYPLAN STRATEGIC DEVELOPMENT PLAN reflect their different scales, roles and functions, now and in the future. Concentrating development in these settlements is seen as the best way to ensure that people, business, jobs, services and facilities are all close together offering increased access and opportunities (Page 3, Paragraph 3.4). Adding additional settlement(s) within Policy 1 would compromise the principles of the location priorities established in Policies 1 and 3 and would also contradict the Vision and Objectives of the Proposed Strategic Development Plan.

In relation to the points made by TMS Planning (for Muir Homes Limited (346675 - PLAN354) and Muir Homes Limited (346675 - PLAN355) regarding the Proposed Plan providing rationale for the status of principal settlements, this background information is provided in the Background Technical Note (2010) (Pages 114-116, Paragraphs 8.37-8.43) (CL/Doc58). The Proposed Plan does not require to repeat this detail. If it did so, and be repetitive in other policy areas, a short, concise and visionary Strategic Development Plan would not be possible (Planning Circular 1/2009: Development Planning, Page 4, Paragraph 14) (CL/Doc29).

Dundas Estates & Development Company (548117); Mr Ken Miles (548486 - PLAN831); Muir Smith Evans (for Muir Homes Limited (548051 - PLAN388); Muir Homes Limited (548051 - PLAN406)) and Rossco Properties (442290 - PLAN162) The above respondents consider that a number of the principal settlements identified within Policy 1 should be re-categorised into a different tier. The Proposed Plan has identified a series of the region’s principal settlements as the focus for additional development. These settlements are already the largest concentrations of population, jobs, services and facilities. They are also most able to accommodate additional growth. The settlements are divided into three tiers which distinguish between the scale of growth to be accommodated, these reflect the varying scales of size and significance of these principal settlements. This approach does not preclude development elsewhere but ensures that the majority is in locations which will reflect the vision and objectives.

All settlements are deemed to be in the correct tier and the evidence provided does not persuade TAYplan that the Proposed Plan should be amended. In some instances it may be that the development suggested may take place irrespective of which tier the settlement appears in but the critical factors is that the tiers distinguish between the relative differences between the types of settlements whilst realising that all are principal settlements as the main providers of services etc.

Tier 3 settlements provide range of jobs, services and facilities for themselves and their surroundings. Their role in the Plan will be to continue to do this and ensure that they continue to be the hub for activity in their area, accepting that as settlements they are generally smaller in scale than those identified in tier 2 and will play a less substantial role in the regional economy than those in tier 2.

GVA Grimley for David Wilson Homes (547268) Policy 1, Part B specifically deals with the issue of development priorities. The respondent considers that development on the periphery of principal settlements should be encouraged, however the Proposed Plan clearly specifies that following land within principal settlements, land on the edge of principal settlements would then be under consideration. Emerging Local Development Plans will allocate appropriate land taking into account the development priorities established within the Strategic Development Plan. TAYplan does not consider that this detail needs to be repeated within Policy 1, Part A. If it did so, and be repetitive in other policy areas, a short, concise and visionary Strategic Development Plan would not be possible (Planning Circular 1/2009: Development Planning, Page 4, Paragraph 14) (CL/Doc29).

66 TAYPLAN STRATEGIC DEVELOPMENT PLAN RESPONSES TO REPRESENTATIONS SUPPORTING AS WRITTEN

TAYplan welcomes the support for these issues.

CONCLUSION

Policy 1 accords fully with Scottish Planning Policy (Page 7, Paragraph 38) in respect of the location of new development and Circular 1/2009: Development Planning (Page 4, Paragraphs 13-14) regarding the requirement for Strategic Development Plan’s to contain a spatial strategy for future development. 55% of respondents at the Main Issues stage supported the preferred strategy, whilst 14% preferred the alternative strategy. 49% of respondents agreed with the settlements identified as the region’s principal settlements (Main Issues Report (2010), Pages 40-48) and (Topic Paper 6: Spatial Strategy, Page 4). TAYplan considers that the issues raised do not warrant any change to the Proposed Strategic Development Plan (June, 2011) and propose that the elements dealt with in this Schedule 4 Summary of Unresolved Issues remain as written and unchanged. No Key Agencies, including the Scottish Government have sought any changes to Policy 1. TAYplan consider that any modifications to Policy 1 could have fundamental implications on delivering the vision and objectives of the Proposed Plan.

Reporter’s conclusions:

General

1. I agree with the authority that setting the detailed boundaries of principal settlements should be a matter for local development plans rather than the strategic development plan. The text specifies the settlements which are to be included, and provides sufficient precision for strategic planning purposes. As regards the mention of Pitlochry and St. Andrews in the supporting text on page 8 relating to tourism, these are given only as examples and the omission of references to other locations fulfilling similar functions, such as Gleneagles (or Crieff or Carnoustie, for that matter), does not imply that these are less significant. I note that Gleneagles is mentioned in the foreword on page 3, and do not consider that any change is necessary.

2. Several representations argue that the policy places too much emphasis on Dundee and Perth, or that there should be no differentiation between tiers of settlements outside these areas and that the nature and extent of development in those settlements should be left to local development plans to determine. In terms of population, economy, infrastructure and services, Dundee and Perth are by a large margin the major settlements of the region. It is central to the TAYplan strategy that they are supported in maintaining and building upon their present roles. A more dispersed pattern of development would not make the best use of existing infrastructure and would be less sustainable in terms of increased travel demands. The emphasis on accommodating additional development in Dundee and Perth is therefore justified.

3. The strategy also provides a significant, though smaller, role for the other principal settlements, and does not exclude appropriate development in smaller, non-principal settlements. The value of dividing principal settlements (other than Dundee and Perth) into two tiers is less immediately obvious, however. The basis for doing so appears to be grounded in a mixture of existing size, function and development potential. There is some explanation of this in Topic Paper 6: Spatial Strategy and in the Main Issues Report, where paragraph 9.9 explains that Tier 2 settlements are differentiated from Tier 3 because their present roles as service centres, particularly retail, and their potential economic significance

67 TAYPLAN STRATEGIC DEVELOPMENT PLAN are important in regional terms. No systematic analysis has, however, been presented to justify the categorisation. The retail functions of Blairgowrie, Crieff and Kinross are placed in the lowest tier under Policy 7: Town Centres, yet these settlements are accorded Tier 2 status in Policy 1, presumably on the basis of development potential.

4. The lack of explicit justification for assigning a settlement to Tier 2 or Tier 3 presents problems in dealing with representations challenging categorisation, for example those which argue that Kinross/Milnathort should be in Tier 3 rather than Tier 2. On the basis of the retail offer, I would agree with that view. On the other hand, the draft Local Development Plan identifies sites for 442 additional houses and 28 hectares of employment land, so it could be argued that development potential outweighs the existing service provision in justifying a Tier 2 placing. For the sake of consistency, I would have to look at all similar marginal cases. However, it is not clear that the outcome would make any significant difference in terms of the application of Policy 1. Principal settlements (of all tiers) are to receive priority in the release of land for development, but both Tier 2 and Tier 3 settlements will accommodate only a small share of the region’s additional development. It does not appear to me to make much practical difference whether a settlement is assigned to Tier 2 or Tier 3.

5. There are three possible responses to that situation. One is to live with a degree of arbitrariness and accept the existing categorisation. Another is to remove the distinction between Tier 2 and Tier 3, as suggested in some representations, so that apart from Dundee and Perth the named settlements are all classed as just ‘other principal settlements’. A third would be to seek to introduce a greater degree of differentiation. While representations suggest changing the Tier 2 description from ‘a small share of development’ to ‘a proportionate share’, I agree with the authority that this would suggest some kind of statistical link for which there is no real basis. I note, however, that Topic Paper 6, paragraph 7.6 suggests that Tier 2 should accommodate a ‘smaller’ share of development (that is, smaller than for Tier 1) and Tier 3 a ‘small’ share, whereas the proposed plan uses ‘small’ in both cases. I conclude that the simplest solution is to accept the existing categorisation, though I recommend changing the wording of the Tier 2 description to accord with Topic Paper 6, which clearly envisaged a distinction from Tier 3.

6. Some representations go further and suggest that outside the Dundee and Perth core areas, there should be no distinction between principal settlements and other settlements, and that the roles and development potential of all settlements (other than the identification of Strategic Development Areas) should be left to local development plans. That would, however, completely undermine Policy 1 and would call into question the value of a regional settlement strategy. The policy of concentrating development in principal settlements is integral to realising the vision and objectives of TAYplan, and I consider that it should be retained.

Undeveloped coast

7. Representations argue that both the meaning and the extent of ‘undeveloped coast’ as shown on page 9 and on the proposals map (page 7) are unclear, and that this feature should be removed from the plan. The notation of ‘undeveloped coast’ on pages 7 and 9 needs to be read in conjunction with Policy 3: Managing TAYplan’s Assets on page 13. This requires local development plans to identify and safeguard parts of the undeveloped coastline that are unsuitable for development and set out policies for their management, identifying areas at risk from flooding and sea level rise and developing policies to manage retreat and realignment, as appropriate. The authority considers that ‘undeveloped coast’ comprises all of the coastline outside developed areas (predominantly settlements). It includes, but is not restricted to, ‘isolated coast’ as defined in SPP paragraph 102, which is distant from centres of population, lacks obvious signs of development, is of 68 TAYPLAN STRATEGIC DEVELOPMENT PLAN very significant environmental, cultural and economic value, and whose special characteristics should be protected by a presumption against development in these areas.

8. In identifying ‘undeveloped coast’ for further scrutiny in local development plans, TAYplan is consistent with SPP paragraph 100, which requires development plans to identify coastal areas likely to be suitable for development, areas subject to significant constraints and areas which are considered unsuitable for development. Indication on the map as ‘undeveloped coast’ does not necessarily mean that there should be no development there: that is a matter for local development plans, which will examine how far the coast should be considered to extend inland, what coastal areas are suitable for development, and what policies should apply there. The indications on the diagram on page 9 simply show the broad extent of the areas for further examination, and should be retained. The proposals map on page 7 appears to be consistent with the page 9 diagram, within the limitations of having to fit a lot of information into a small space.

New settlements

9. Representations call for deletion of the statement on page 8 that there will be no need for any new settlements during the lifetime of the plan, and propose that the plan should promote new settlements at Craigend to the west of Perth and at Horn Grange between Perth and Dundee. The authority’s position is that there is sufficient land in and adjacent to existing principal settlements to meet the predicted need for housing and related development during the first 12 years of the plan, so that there is no need for any new settlements. Creating new settlements would undermine the policy of concentrating development in existing settlements, and would require new infrastructure and facilities rather than making best use of what already exists. There is an overlap with the issues concerning Policy 4: Strategic Development Areas and Policy 5: Housing. Paragraphs 84 and 85 of Scottish Planning Policy together state that the majority of housing land requirements will be met within or adjacent to existing settlements, unless new settlements can be justified against a number of criteria. I do not consider that these criteria are met in the TAYplan region.

Timing and detail of development

10. Montagu Evans seeks an addition to the policy to state that land allocated for development should be capable of being brought forward and developed within the plan period. The authority points out that Policy 5 specifies that local development plans should identify a minimum 5 year effective land supply and work towards a 7 year supply by 2015. The effectiveness of housing land is fully examined under Issue 16. I do not consider that there is any need to change Policy 1 as suggested. Mr Ian Fowler seeks more detailed information on the location and control of development, and seeks assurances about retaining present village boundaries. These are, however, matters more appropriate for local development plans than for the strategic development plan.

Dundee Core Area

11. Representations propose the addition of settlements (Liff and Ballumbie/Duntrune) to the Dundee Core Area, or the deletion of settlements currently included (Tayport, Newport and Wormit). The authority argues that Liff and Ballumbie/Duntrune are small settlements where the scale of future development would not be sufficient for them to be considered principal settlements. Although Ballumbie/Duntrune lies outside the Dundee City boundary, it appears to me to be an extension of the city’s built-up area rather than a separate settlement in its own right, and I consider that significant further development could take place there (on the edge of a principal settlement) without breaching Policy 1 as it is 69 TAYPLAN STRATEGIC DEVELOPMENT PLAN currently written. The extent and nature of such development is a matter for local development plans, but it would not result in a new principal settlement. While Liff is separated from the city by countryside, it is a small village with few services and I agree with the authority that any development there is unlikely to result in a principal settlement.

12. Given their proximity to the city and good transport links, Tayport, Newport and Wormit are integral components of the Dundee Core Area and have a role to play in accommodating development needs. I note that they contain strategic sites already recognised in the finalised local plan, or with planning permission. I therefore do not support any changes to the list of settlements comprising the Dundee Core Area.

Perth Core Area

13. The suggestion that the Perth Core Area should be redefined as the area within 25 minutes travel by local bus from the centre of Perth would result in a degree of uncertainty as to what areas and settlements were included or excluded. Although this definition is used in the Perth and Kinross Structure Plan 2003, and covers broadly the same area as Policy 1 of TAYplan, I consider the more definitive approach adopted by the latter to be preferable and consistent with other settlements in the region. Bridgend is part of Perth and does not need to be specified separately. Guildtown (population 300, with very limited services) is too small to be considered a principal settlement.

14. Representations suggest adding the Carse of Gowrie and point out that most of it is less susceptible to flooding than Perth City Centre. The Carse is a large area stretching most of the way from Perth to Dundee, and its inclusion in the Perth Core Area would fundamentally alter the balance of the settlement strategy. Even the largest settlements in the Carse (Errol, population 1,300; St. Madoes/Glencarse, 1,000; and Inchture, 1,200) do not have the size or the range of facilities to be considered as principal settlements. While much of the Carse away from the Tay Estuary is not prone to flooding, encouraging major development there would require provision of new infrastructure and would result in increased travel. Although parts of Perth City Centre are prone to flooding, its population and economic importance have justified flood protection measures there and are likely to justify further enhancement of these. I do not consider that there is justification for adding the Carse of Gowrie to the Perth Core Area.

15. Other representations suggest removing Luncarty, Stanley, Balbeggie and Perth Airport from the core area, on the grounds that these could not be developed without the construction of the Cross Tay Link Road which would have significant environmental impacts. I have considered the case for the road under Issue 2: Proposals Map. If it were not built, the development potential of these settlements would be severely constrained. Nevertheless, they would continue to function as parts of the Perth Core Area and I consider they should be retained within it. The removal of Scone has also been suggested, on the grounds that development there would destroy its identity. Given its population of 4,900 and its proximity to Perth, however, it would not be reasonable to exclude Scone from the core area. Policy 3: Managing TAYplan’s Assets refers to using the Perth green belt to sustain the identity of Scone. It will be for the local development plan to establish what development in Scone can be carried out while preserving its identity. I therefore do not support any of the suggested deletions of settlements.

St. Andrews

16. Representations query the meaning of, and need for, the statement that ‘Beyond the Strategic Development Area in Policy 4 for St. Andrews there will be no additional strategic development of this scale in the foreseeable future’. It is suggested that this statement be 70 TAYPLAN STRATEGIC DEVELOPMENT PLAN omitted, or reworded by omitting ‘of this scale’ or adding a reference to preserving the landscape setting of the town. I sought further information from the authority on the reasons for inclusion of this policy statement.

17. The authority states that the text continues the long term strategy of the Fife Structure Plan of protecting the town from further large scale expansion. The need for this statement is to provide certainty, particularly to the local community, that in the foreseeable future there will be no strategic development of the scale of the proposed Strategic Development Area, which comprises residential development in the order of 1,090 homes, 10 hectares of employment land and 10 hectares of science park.

St. Andrews has international status due to its prominence as the home of golf and its historical importance, and its character needs to be protected from over development. Its setting also needs to be protected, hence the identification of a green belt that manages the scale of the town and protects its rural setting and key views into the historic centre. Due to the unique character of St. Andrews both in a Scottish and TAYplan context, the authority considers that this policy wording is required to direct future strategic scale development to other settlements. It does not, however, preclude smaller scale development that accords with development plan policy, whether it is of local or strategic importance.

18. While I accept the need to preserve the historic character and setting of St. Andrews, there are other policies in TAYplan which serve that end. Under Policy 3: Managing TAYplan’s Assets, St. Andrews is one of only two settlements to be accorded a green belt, whose functions include preserving its setting, views and special character including its historic core. Policy 2: Shaping better quality places, Part F promotes understanding, incorporating and enhancing natural and historic assets. The Finalised St. Andrews and East Fife Local Plan considers the scale and extent of development that would be appropriate for the town while preserving its character and setting. The strategic development plan, which covers the period up to 2032, identifies no additional strategic development of this scale in St. Andrews. The period up to 2032 is the foreseeable future, so the plan already does what the authority says the local community wants it to do and there is no need to state this explicitly. Even taking account of the unique status of St. Andrews, I do not accept that the statement in Policy 1 is necessary or that it provides additional clarity about further development in the town. The words ‘of this scale’ leave the door open to large-scale development slightly smaller than that envisaged in the Strategic Development Area, while the removal of those words would suggest a ban on development which has strategic importance but is small in scale, a concern expressed by the University of St. Andrews. I consider that the best course would be to omit the statement altogether.

19. Representations draw attention to the significance of Guardbridge and Leuchars as areas of growth that complement St. Andrews. Leuchars/Guardbridge is recognised as a Tier 3 settlement on the diagram on page 9. It is, however, physically separated from St. Andrews by the proposed green belt. I consider that St. Andrews is correctly categorised in Tier 2, given its size, economic importance and range of services.

Other settlements

20. Representations propose that the list of principal settlements should be extended to include Springfield, Inveraldie, Friockheim, Newbigging, Auchtermuchty and Errol. Most of these are small villages with limited service functions and limited development potential, as recognised in local plans. Auchtermuchty, with a population of 2,068 and capacity for some new development, is perhaps a marginal case. Newburgh, which is included as a Tier 3 settlement, has only 2,213 people, though it appears to me to have rather more shops than Auchtermuchty and the finalised local plan indicates a larger housing development capacity. 71 TAYPLAN STRATEGIC DEVELOPMENT PLAN Ultimately, a line has to be drawn somewhere and I consider the authority’s exclusion of Auchtermuchty is reasonable. The other settlements mentioned above are all too small, and would remain so with any realistic level of development, to be classed as principal settlements. Policy 1 provides for some development in settlements that are not defined as principal settlements. It is a matter of degree, and they are not significantly disadvantaged in comparison with listed Tier 3 settlements.

21. It has been suggested that Kinross/Milnathort should be relegated from Tier 2 to Tier 3 and that Auchterarder should be promoted from Tier 3 to Tier 2. As explained in paragraphs 4 and 5 above, there appears to me to be no systematic basis for the plan’s categorisation of settlements into Tiers 2 and 3, but I do not consider the distinction between them especially important. I do not therefore propose any changes of this nature. It has also been suggested that Cupar has the potential to make a major contribution to the regional economy and that this should be reflected in Policy 1. Cupar is a Tier 2 settlement, and the description on page 9 already recognises that such settlements have the potential to make a major economic contribution. The scope of strategic development in Cupar is set out in Policy 4: Strategic Development Areas. Even with the major expansion proposed, however, Cupar would not become a Tier 1 settlement, and I do not consider any related change to Policy 1 is needed.

Reporter’s recommendations:

Modify page 9 of the proposed plan as follows:

In the description of Tier 2, second line, delete “small” and insert:

“smaller”.

Delete the words:

“Beyond the Strategic Development Area in Policy 4 for St. Andrews there will be no additional strategic development of this scale in the foreseeable future”.

On the settlement map, amend the representation of the Perth green belt so that it is consistent with the revised diagram on page 13 recommended under Issue 8.

72 TAYPLAN STRATEGIC DEVELOPMENT PLAN

Issue 4 Policy 1: Location Priorities – Policy 1b, text and general

Page 8: Managing TAYplan’s Assets Supporting Development plan Reporter: Text reference: Mike Cunliffe Page 9: Policy 1, Part B Body or person(s) submitting a representation raising the issue (including reference number):

Seeking a change ID Person/Organisation Representation Number Reference 548872 Alyth Community Council PLAN823 548151 Andrew McCafferty Associates for GD Strawson and J PLAN446 Farquharson 548151 Andrew McCafferty Associates for GD Strawson and J Farquharson PLAN745 548151 Andrew McCafferty Associates for GD Strawson and J Farquharson PLAN747 443109 Barton Willmore for Scotia Homes PLAN378 442149 Bidwells for Zurich Assurance Limited PLAN663 445206 Emac Planning for J G Lang & Son PLAN535 445203 Emac Planning for James Keiller Estates PLAN714 548383 Emac Planning for L Porter PLAN548 548360 Emac Planning for M Batchelor (B) PLAN531 548301 Emac Planning for M Batchelor (K) PLAN518 438726 Geddes Consulting for Lynch Homes PLAN646 445159 Geddes Consulting for Thomson Homes Limited PLAN884 445159 Geddes Consulting for Thomson Homes Limited PLAN885 543112 GS Brown Construction PLAN85 543112 GS Brown Construction PLAN89 548389 Halliday Fraser Munro for Barratt Homes PLAN581 442882 Homes for Scotland PLAN215 346689 Karen Clark for Discovery Homes PLAN542 237724 Lomond Land PLAN407 443979 Lynne Palmer PLAN153 343111 Montagu Evans LLP for Wallace Land Investment Management PLAN331 442083 Montgomery Forgan Associates for Strategic Land (Scotland) Limited PLAN278 548055 Mr Ian Fowler PLAN387 548486 Mr Ken Miles PLAN832 548760 Mrs D Jeffrey PLAN808 548760 Mrs D Jeffrey PLAN809 344887 Penny Uprichard PLAN874 453889 Royal Burgh of St. Andrews Community Council PLAN918 442871 Smiths Gore for Errol Park Estate PLAN631 442870 Smiths Gore for Mansfield Estates PLAN545 442870 Smiths Gore for Mansfield Estates PLAN546 442870 Smiths Gore for Mansfield Estates PLAN547 330884 Ryden for Bon Accord Land Limited/Stewart Milne Homes PLAN127 539326 Spittalfield and District Community Council PLAN95

73 TAYPLAN STRATEGIC DEVELOPMENT PLAN 331662 SportScotland PLAN143 547750 St. Andrews Preservation Trust PLAN842 546491 TMS Planning for Campion Homes PLAN225 546491 TMS Planning for Campion Homes PLAN226 546491 TMS Planning for Campion Homes PLAN227 345005 TMS Planning for Mr James Thomson PLAN237 345005 TMS Planning for Mr James Thomson PLAN238 345005 TMS Planning for Mr James Thomson PLAN239 345007 TMS Planning for Mr Simon Wilson PLAN397 345007 TMS Planning for Mr Simon Wilson PLAN398 345006 TMS Planning for Mr Tim Esparon PLAN188 345006 TMS Planning for Mr Tim Esparon PLAN192 345006 TMS Planning for Mr Tim Esparon PLAN193 345006 TMS Planning for Mr Tim Esparon PLAN201 345006 TMS Planning for Mr Tim Esparon PLAN202 346675 TMS Planning for Muir Homes Limited PLAN357 346675 TMS Planning for Muir Homes Limited PLAN358

Support as written ID Person/Organisation Representation Number Reference 444081 Montagu Evans PLAN457 344848 Scottish Natural Heritage PLAN415 Provision of the This Schedule 4 relates to general points raised on Page 8 development plan (Supporting Text) and points raised in relation to Policy 1, Part B on to which the issue Page 9. relates: Planning authority’s summary of the representation(s):

SUMMARY OF REPRESENTATIONS SEEKING A CHANGE Alyth Community Council (548872) consider that the Proposed Strategic Development Plan focuses on the larger urban areas and neglects the rural area including small towns like Alyth.

Andrew McCafferty Associates for GD Strawson and J Farquharson (548151 – PLAN446) consider that the reference in Part B to prioritising land release should be deleted from the Plan.

Andrew McCafferty Associates for GD Strawson and J Farquharson (548151 - PLAN745) consider that It is not possible to prevent the implementation of extant planning consents for housing. Priority can be given to identifying brownfield sites which are suitable for development but there is no workable mechanism to prevent or delay other sites which are suitable for development being granted planning permission or implemented.

Andrew McCafferty Associates for GD Strawson and J Farquharson (548151 - PLAN747) consider that a new or consolidated settlement offers a number of benefits including the potential of providing social infrastructure such as educational and community facilities in an area of deficiency. It is unwise to be so categorical about ruling out a potential form of development which could provide a source of land supply if the preferred alternatives in the Plan fail to deliver sufficient supply or do not deliver units at all. The respondent therefore considers that the option of a new or consolidated settlement should be kept in the Plan to meet needs in the latter period of the Plan.

74 TAYPLAN STRATEGIC DEVELOPMENT PLAN Barton Willmore for Scotia Homes (443109); Homes for Scotland (442882); Smiths Gore (for Errol Park Estate (442871) and Mansfield Estates (442870 – PLAN546 and PLAN547)) have requested an amendment to the wording of Policy 1, Part B, in order to ensure the reuse of previously developed land and buildings, where financially viable to do so.

Bidwells for Zurich Assurance Limited (442149) consider that whilst the capacity of growth accommodation will ultimately be decided in the Local Development Plans, the respondent believes that within Policy 1, TAYplan ought to make clear and emphasise the importance of development effectiveness in contributing to he housing land supply to 2032. Therefore in Section B of Policy 1, the respondent believes that the word "effective" should be inserted within 1 and 2 of the table.

Emac Planning (for J G Lang & Son ( 445206); James Keiller Estates (445203); L Porter (548383); M Batchelor (B) (548360); M Batchelor (K) (54830)); Geddes Consulting (for Lynch Homes (438726); Thomson Homes Limited (445159 – PLAN884) and Thomson Homes Limited (445159 – PLAN885)) consider that an additional statement should be inserted under Part B, to include a reference to the identification of land release through the Local Development Plan process. Geddes Consulting (for Lynch Homes (438726); and Thomson Homes Limited (445159)) also considers a reference should be included that where the effective land supply is not sufficient, additional land should be proposed through a mechanism in Local Development Plans.

GS Brown Construction (543112 – PLAN85 and PLAN89) have indicated that the Perth area does not have significant areas of brownfield land and that which exists is blighted by high costs for reuse. In addition, the respondent considers that the commitment in Policy B to prioritise land release for development within principal settlements is too simplistic – judgements on a site by site basis are necessary to establish whether they are effective or non effective.

Halliday Fraser Munro for Barratt Homes (548389) have commented that although the Proposed Plan identifies that land within principle settlements should be a priority for land release within the current economic climate this may not be achievable. There is inevitably very little Greenfield land within such locations. Brownfield sites invariably require significant investment and also are less likely to provide family housing which is required to meet the Plan's aspirations for a mix of housing types. Such sites are also more likely to produce flatted developments for which restrictive bank lending criteria make it difficult for households to secure a mortgage. Consequently, these types of development have been the most heavily affected by the economic downturn and are unlikely to make a significant contribution to the housing land supply in the short to medium term. There is a danger that an over- reliance on such an in-flexible policy could lead to failure for Local Development Plans to allocate and deliver Strategic Development Plan requirements. TAYplan as a strategic document is charged to take a long-term view. It should realistically be planning for economic recovery.

Karen Clark for Discovery Homes (346689) The respondent considers that Location Priorities should recognise that, particularly in the Dundee area where the administrative boundaries have been drawn very tightly around the City with no area of "urban fringe" included within the City boundaries, that the Tier 1 catchments makes some recognition of the urban fringe areas, particularly where the redevelopment of brownfield land is proposed. Further, the boundaries of the various tiers are unclear; a more detailed plan is required to ensure clarity on the tier catchment areas.

75 TAYPLAN STRATEGIC DEVELOPMENT PLAN Lomond Land (237724) have indicated that the need to allow development to support rural communities and sustain rural economies where they genuinely offer opportunity for self- sustaining settlement expansion should be given stand alone policy support by TAYplan. This should be separated from the sequential test approach of Policy 1. The test of acceptability of development to support rural communities should be based on criteria which assess the developments contribution to sustaining the settlements where it is proposed, not the availability of land in the other principal settlements as proposed by the sequential Policy 1.

The strategy to focus development almost exclusively on principal settlements at the expense of all other settlements and areas is overly restrictive and contrary to national policy. Policy 1 identifies the principal settlements. Clause B of Policy 1 identifies what is described as a sequential approach to locating development and only having gone through this criteria can development which offers the opportunity for self-sustaining settlement expansion of other settlements be considered.

It is highly likely that the effect of this will be that the, ‘self-sustaining development needs of other settlements', will not be met because they will always be considered subservient to the land availability of the principal settlements. This effect, possibly unintended, but nevertheless the likely outcome, will be contrary to Scottish Planning Policy.

The TAYplan Topic Paper 6: Spatial Strategy at para. 5.12 acknowledge that “an outright ban would deprive communities of vital small scale development or changes of use which provide housing, employment or services and facilities." In the same paragraph it fails to recognise that such small scale community based development can also contribute to reducing travel demand by the co-location of people and services in the same way that a general strategic concentration on the Principle Settlements can.

Lynne Palmer (443979) notes that Policy 1, Part B mentions "prioritising land release" and "reuse of previously developed land", however there is no mention of demolition to release land. The respondent therefore considers that buildings that are single storey and next to buildings of 3/4 stories especially flats, should be removed to allow more housing to be built. The word demolition should therefore be included.

Montagu Evans LLP for Wallace Land Investment Management (343111) Consider that, where there is an established need locally, the development of land at or near the settlement edge or indeed locations which are or can be made sustainable should be considered favourably subject to detailed policies of the individual local development plans.

Montgomery Forgan Associates for Strategic Land (Scotland) Limited (442083) consider that TAYplan should specifically state that both greenfield and brownfield land will be required to secure the identified levels of completion and to offer choice as required by Scottish Planning Policy.

Mr Ian Fowler (548055) has requested that a comment is included within the Proposed Strategic Development Plan that present village boundaries will be recognised and not exceeded by additional developments, coalescence between settlements will not be allowed and the integrity and independence of small villages will be guaranteed.

Mr Ken Miles (548486) considers that Policy 1, Part B, third point in table should be deleted as the statement is a means to allow development in otherwise inappropriate locations.

Mrs D Jeffrey (548760 - PLAN808 and PLAN809) considers that new settlements would be more desirable than large extensions to existing villages. 76 TAYPLAN STRATEGIC DEVELOPMENT PLAN

Penny Uprichard (344887) considers that the statement:- ‘Where there is insufficient land or where the nature/scale of land use required to deliver the Plan cannot be accommodated within or on the edge of principal settlements and this offer the genuine possibility for self- sustaining settlements the expansion of other settlements should be considered' refers specifically to St. Andrews.

Royal Burgh of St. Andrews Community Council (453889) has requested modifications to paragraphs two and seven of the supporting text on Page 8.

Ryden for Bon Accord Land Limited/Stewart Milne Homes (330884) consider that Policy 1, Part B is not clear on where the hierarchy of principal, settlements fits. Land within principal settlements should not be given priority as it can be developed through Local Development Plans. Greater emphasis should be given to land on the edge of principal settlements regardless of their tier.

Smiths Gore for Mansfield Estates (442870 - PLAN545) have requested a modification to the text of Policy 1, Part B in relation to looking more at local needs.

Spittalfield and District Community Council (539326); TMS Planning (for Campion Homes (5464910 - PLAN225); Mr James Thomson (345005 - PLAN237); Mr Simon Wilson (345007 - PLAN397); Mr Tim Esparon (345006 - PLAN188) and Muir Homes Limited (346675 - PLAN357)) have all requested a modification to Page 8, Paragraph 11.

SportScotland (331662) have indicated that it is not clear from this section of the Plan what the approach to development in the countryside (completely outwith a settlement) is. Page 9 of the Proposed Plan states that development in rural areas where it can be accommodated and supported by the settlement, may be acceptable. It is not clear what this means - is the policy referring to development within rural settlements or is it referring to countryside areas outwith settlements? Policy clarity is needed in this area.

St. Andrews Preservation Trust (547750) have requested a change to paragraph nine on Page 8 as they do not see the logic of the statement in the St. Andrews context. The Fife Structure Plan acknowledged the "national and international importance" of the landscape setting of St. Andrews but nevertheless proposed massive building, expanding the built area, by at least 30% in sensitive landscape areas providing views to and from the historic core (and the landscape setting of the town). There seems to have been no re-appraisal of this in the TAYplan.

TMS Planning (for Campion Homes (5464910 - PLAN226 and PLAN227); Mr James Thomson (345005 - PLAN238 and PLAN239); Mr Simon Wilson (345007 - PLAN398); Mr Tim Esparon (345006 - PLAN192, PLAN193 and PLAN202) and Muir Homes Limited (346675 - PLAN358)) have all requested a modification to Policy 1, Part B3 to provide clarity in respect of self-sustaining settlements (Policy B3).

TMS Planning for Mr Tim Esparon (345006 - PLAN201) has requested additional text for the last paragraph on Page 8, specifically looking at local needs to help sustain local communities.

SUMMARY OF REPRESENTATIONS SUPPORTING AS WRITTEN Montagu Evans (444081) have indicated that they note that TAYplan balances the importance of sustaining rural economies with the need to protect the countryside, by allowing some development in small settlements which are not principal settlements and that 77 TAYPLAN STRATEGIC DEVELOPMENT PLAN implementation of this will be set out in the Local Development Plans. This approach is supported.

Scottish Natural Heritage (344848) supports Policy 1, Part B.

Modifications sought by those submitting representations:

NOTE TO REPORTER: The text in italics in this section has been lifted directly from each individual/organisation’s representation with minor typographical errors corrected.

Alyth Community Council (548872) • No specific change identified, although have concerned that it appears apparent that we in the rural areas and small towns like Alyth need expect any priority in the next 20 years. This is a plan which focuses on the larger urban areas and neglects the rest of this area.

Andrew McCafferty Associates for GD Strawson and J Farquharson (548151 – PLAN446) • The reference in Part B to prioritising land release should be deleted from the Plan.

Andrew McCafferty Associates for GD Strawson and J Farquharson (548151 - PLAN745) • The third paragraph down in the right hand column on page 8 referring to prioritising land release should be deleted.

Andrew McCafferty Associates for GD Strawson and J Farquharson (548151 - PLAN747) • Deletion of the following sentence at the end of the fifth paragraph in the right hand column on page 8: "There will be no need for any new settlements during the lifetime of this Plan."

Barton Willmore for Scotia Homes (443109); Homes for Scotland (442882); Smiths Gore (for Errol Park Estate (442871) and Mansfield Estates (442870 – PLAN547)) • Reword as follows:- 'Prioritise within each category, as appropriate, the reuse of previously developed land and buildings, where financially viable to do so.'

Bidwells for Zurich Assurance Limited (442149) • …believe that there should be a greater emphasis on the effectiveness of development land and this should be re-inforced throughout pages 8 and 9 but in particular in Policy 1, Part B.

Emac Planning (for J G Lang & Son ( 445206); James Keiller Estates (445203); L Porter (548383); M Batchelor (B) (548360); M Batchelor (K) (548301)) • Under B, after "prioritise land release for development within principal settlements" insert "which will be identified through the Local Development Plan process".

Geddes Consulting (for Lynch Homes (438726); Thomson Homes Limited (445159 – PLAN884) and Thomson Homes Limited (445159 – PLAN885)) • Proposed Change: B. prioritise land release for development within principal settlements ahead of other land; and, prioritise within each category, as appropriate, the reuse of previously developed land and buildings (particularly listed buildings). Local Development Plans should allocate land for development to achieve the requirement set out in Policy 4 78 TAYPLAN STRATEGIC DEVELOPMENT PLAN and Policy 5. Where the effective land supply is not sufficient to meet the requirements set out in Policy 4 and Policy 5, additional land should be released through a proposed mechanism in the Local Development Plans.

GS Brown Construction (543112 – PLAN85 and PLAN89) • Although no specific change has been identified, it is considered that the plan is too heavily skewed towards development taking place in major settlements, thereby preventing natural growth and development of some of the smaller settlements. • The Carse of Gowrie, lying as it does between the principal settlements of Perth and Dundee, should not be the subject of an outright presumption against ANY development. Flooding is not a problem of sufficient importance to justify such a restriction and the density of population in the corridor is actually a positive factor to be harnessed in encouraging a switch from private to public transport. • The commitment in Policy B to prioritise land release for development within principal settlements is too simplistic – judgements on a site by site basis are necessary to establish whether they are effective or non effective.

Halliday Fraser Munro for Barratt Homes (548389) • Change; ‘Prioritise land release for development within principal settlements'... to the core areas.

Karen Clark for Discovery Homes (346689) • Recognition in the Location Priorities of the pressures on the urban fringe areas. • Provision of a Plan at a larger scale to provide clarity on the Tier catchment areas.

Lomond Land (237724) • The need to allow development to support rural communities and sustain rural economies where they genuinely offer opportunity for self-sustaining settlement expansion should be given stand alone policy support by Tayplan. This should be separated from the sequential test approach of Policy 1. The test of acceptability of development to support rural communities should be based on criteria which assess the developments contribution to sustaining the settlements where it is proposed, not the availability of land in the other principal settlements as proposed by the sequential Policy 1.

Lynne Palmer (443979) • Policy 1B. Include demolition of buildings to release land.

Montagu Evans LLP for Wallace Land Investment Management (343111) • Reflecting submissions to the Main Issues Report, in supporting economic development opportunities that may present themselves across the plan area, as advocated earlier in this submission, the plan should not discourage growth by adding additional restrictions to potentially effective greenfield sites.

Montgomery Forgan Associates for Strategic Land (Scotland) Limited (442083) • TAYplan should specifically state that both greenfield and brownfield land will be required to secure the identified levels of completion and to offer choice as required by Scottish Planning Policy.

Mr Ian Fowler (548055) • Page 8 states- "this plan balances the importance of sustaining rural economies with the need to protect the countryside, by allowing dome development in small settlements which are not principle settlements. Implementation of this plan will be set 79 TAYPLAN STRATEGIC DEVELOPMENT PLAN out in Local Developments Plan." Could you include a comment that present village boundaries will be recognised and not exceeded by additional developments, coalescence between settlements will not be allowed and the integrity and independence of small villages will be guaranteed.

Mr Ken Miles (548486) • Policy 1 B3 should be deleted as the statement is a means to allow development in otherwise inappropriate locations.

Mrs D Jeffrey (548760 –PLAN808 and PLAN809) • No specific change identified, although considers that new settlements would be more desirable than large extensions to existing villages.

Penny Uprichard (344887) • No specific change identified, however considers that the statement:- ‘Where there is insufficient land or where the nature/scale of land use required to deliver the Plan cannot be accommodated within or on the edge of principal settlements and this offer the genuine possibility for self-sustaining settlements the expansion of other settlements should be considered' refers specifically to St. Andrews.

Royal Burgh of St. Andrews Community Council (453889) • Page 8, Location Priorities, Paragraph 2. Change "They also have significant land capacity to accommodate future development." Too many of them also have significant land capacity to accommodate future development." • Page 8, Location Priorities, Paragraph 7. Change "or attending major events, such as international golfing competitions e.g. St. Andrews" to "or as bases for attending major events, such as international golfing competitions e.g. St. Andrews."

Ryden for Bon Accord Land Limited/Stewart Milne Homes (330884) • No specific change identified, although consider that Policy 1, Part B is not clear on where the hierarchy of principal, settlements fits. Land within principal settlements should not be given priority as it can be developed through Local Development Plans. Greater emphasis should be given to land on the edge of principal settlements regardless of their tier.

Smiths Gore for Mansfield Estates (442870 - PLAN546 and PLAN547)) • Page 9 Policy Location Priorities, Proposal B, Change to “Prioritise land release for development within principal settlements ahead of other land; and prioritise within each category, as appropriate, the reuse of previously developed land and buildings.”

Spittalfield and District Community Council (539326) • by allowing some development in small settlements which are not principal settlements, in small proportion to their size.

SportScotland (331662) • No specific change identified and is seeking clarification on what the approach to development in the countryside (completely outwith a settlement) is. Page 9 states that development in rural areas where it can be accommodated and supported by the settlement, may be acceptable. It is not clear what this means - is the policy referring to development within rural settlements or is it referring to countryside areas outwith settlements? Policy clarity is needed in this area.

80 TAYPLAN STRATEGIC DEVELOPMENT PLAN St. Andrews Preservation Trust (547750) has requested a change to paragraph nine on Page 8, although no specific change has been identified.

TMS Planning (for Campion Homes (5464910 - PLAN225); Mr James Thomson (345005 - PLAN237); Mr Simon Wilson (345007 - PLAN397); Mr Tim Esparon (345006 - PLAN188) and Muir Homes Limited (346675 - PLAN357)) • Page 8 last paragraph "The plan balances...... Local development plans". This paragraph needs to state that (added at the end) "There is a requirement to look at local needs and to deliver development to help sustain communities and the services/facilities that serve them. It is a requirement of this plan that local development plans specially address local needs as an integral part of the development strategy".

TMS Planning (for Campion Homes (5464910 - PLAN226 and PLAN227); Mr James Thomson (345005 - PLAN238 and PLAN239); Mr Simon Wilson (345007 - PLAN398); Mr Tim Esparon (345006 - PLAN192, PLAN193, PLAN201 and PLAN202) and Muir Homes Limited (346675 - PLAN358)) • Part B within the table with priorities 1-3, section 3 is unclear and requires to be clarified. The words "and this offers the genuine opportunity for self-sustaining settlements" should be deleted. Added to the end of the section 3 should be the term "Such expansion should be guided by the Vision and Objectives of the Plan and the individual needs and capacity of the settlement and should be demonstrated through the local development plan process".

Summary of responses (including reasons) by planning authority:

RESPONSES TO REPRESENTATIONS SEEKING A CHANGE

Alyth Community Council (548872) The Proposed Plan has identified a series of the region’s principal settlements as the focus for additional development. These settlements are already the largest concentrations of population, jobs, services and facilities. They are also most able to accommodate additional growth. The settlements are divided into three tiers which distinguish between the scale of growth to be accommodated, these reflect the varying scales of size and significance of these principal settlements. This approach does not preclude development elsewhere but ensures that the majority is in locations which will reflect the vision and objectives. TAYplan therefore does not agree with the respondents. No change is required.

Barton Willmore for Scotia Homes (443109); Homes for Scotland (442882); Smiths Gore (for Errol Park Estate (442871) and Mansfield Estates (442870 – PLAN546 and PLAN547)) Policy 1, Part B is consistent with Scottish Planning Policy (Page 16, Paragraph 80) which requires planning authorities to promote the efficient use of land and buildings, directing development towards sites within existing settlements where possible to make effective use of existing infrastructure and service capacity and to reduce energy consumption. Redevelopment of urban and rural brownfield sites is preferred to development on greenfield sites. In addition, Scottish Planning Policy indicates that when identifying locations for housing, planning authorities and developers should consider the reuse of previously developed land before development on greenfield sites and should take account of a number factors, including the potential contribution to the strategy and policies of the development plan, accessibility, availability of infrastructure, including waste management, education and community facilities, whether development can be achieved within the required time frame, the provision of choice across the housing market area, design, quality and density of development, and the individual and cumulative effects of the proposed 81 TAYPLAN STRATEGIC DEVELOPMENT PLAN development. There is no specific reference within Scottish Planning Policy regarding financial viability. No change is therefore required within the Proposed Plan.

Bidwells for Zurich Assurance Limited (442149); Emac Planning (for J G Lang & Son (445206); James Keiller Estates (445203); L Porter (548383); M Batchelor (B) (548360); M Batchelor (K) (548301)); Geddes Consulting (for Lynch Homes (438726); Thomson Homes Limited (445159 – PLAN884) and Thomson Homes Limited (445159 – PLAN885)) Policy 1 sets out the spatial strategy and says where development should and should not go. It focuses the majority of the region’s new development within principal settlements. Policy 5 specifies that Local Development Plans should identify a minimum 5 year and work towards a 7 year effective housing land supply by 2015 to support economic growth. TAYplan do not consider that an additional statement is therefore required within Policy 1 of the Proposed Plan as requested by the respondent, as the emerging Local Development Plans will be required to allocate land within each Housing Market Area in order to provide for an effective and generous supply of housing land as required by Scottish Planning Policy (Page 14, Paragraph 70) (CL/Doc2). In addition, if the additional statement was included and be repetitive in other policy areas, a short, concise and visionary Strategic Development Plan would not be possible (Planning Circular 1/2009: Development Planning, Page 4, Paragraph 14) (CL/Doc29). In relation to the comment by Geddes Consulting (for Lynch Homes (438726) and Thomson Homes Limited (445159)) regarding the request for additional land to be proposed by Local Development Plans where the effective supply is not sufficient, TAYplan considers that Policy 5 (Page 17) provides flexibility for Local Development Plans to allocate a larger supply of land in order to assist the delivery of build rates. In addition, Local Development Plans can utilise as a potential source of supply to meet shortfalls in planned provision the initial assessment of sites carried out by each authority in their 2009 Urban Capacity Studies (Background Technical Note, Page 20, Paragraph 3.35) (CL/Doc58). This approach is consistent with Scottish Planning Policy (Page 16, Paragraph 81) (CL/Doc2).

Andrew McCafferty Associates for GD Strawson and J Farquharson (548151 – PLAN446) The Proposed Plan has identified a series of the region’s principal settlements as the focus for additional development. These settlements are already the largest concentrations of population, jobs, services and facilities. They are also most able to accommodate additional growth. Topic Paper 6: Spatial Strategy (CL/Doc35) explains that the principal settlements were divided into three tiers to reflect their different scales, roles and functions, now and in the future. Concentrating development in these settlements is seen as the best way to ensure that people, business, jobs, services and facilities are all close together offering increased access and opportunities (Page 3, Paragraph 3.4). Prioritising land release within principal settlements ahead of land elsewhere is integral to ensuring that the majority of growth is concentrated there. This is central to meeting the vision and objectives including the need to travel, reduce carbon emissions, reinvest in existing communities and support sustainable economic growth.

It should also be noted that within the Background Technical Note to the Main Issues Report (April 2010) (CL/Doc58), TAYplan considered a Spatial Strategy which would have focused development along the region’s main transport corridors. This would have included land at the Carse of Gowrie. Such a spatial strategy was considered unreasonable and unrealistic given the reliance on travel to access jobs, services and facilities which would be inconsistent with Scottish Planning Policy (Background Technical Note (2010), Pages 118- 119, Paragraphs 8.52-8.55). The majority of Main Issues Report respondents preferred the strategy of concentrating growth in Core Areas (Topic Paper 6: Spatial Strategy, Page 4) (CL/Doc35).

Andrew McCafferty Associates for GD Strawson and J Farquharson (548151 - 82 TAYPLAN STRATEGIC DEVELOPMENT PLAN PLAN745); GS Brown Construction (543112 – PLAN85 and PLAN89); Halliday Fraser Munro for Barratt Homes (548389); Lynne Palmer (443979); Montagu Evans LLP for Wallace Land Investment Management (343111); Montgomery Forgan Associates for Strategic Land (Scotland) Limited (442083) and Ryden for Bon Accord Land Limited / Stewart Milne Homes (330884) TAYplan consider that Policy 1, Part B is clear, concise and sufficiently flexible to deliver development in accordance with Scottish Planning Policy (Page 16, Paragraph 77) (CL/Doc2). Prioritising land release within principal settlements ahead of land elsewhere is integral to ensuring that the majority of growth is concentrated there. This is central to meeting the vision and objectives including the need to travel, reduce carbon emissions, reinvest in existing communities and support sustainable economic growth. The Proposed Plan clearly specifies that following land within principal settlements, land on the edge of principal settlements would then be under consideration. Emerging Local Development Plans will allocate appropriate land taking into account the development priorities established within the Strategic Development Plan. In relation to comments by Lynne Palmer (443979), although demolition of buildings may be the source of some future development land planning permission (with the exception of protected buildings and areas) is not required for demolition, therefore no change is proposed.

Andrew McCafferty Associates for GD Strawson and J Farquharson (548151 - PLAN747); Mrs D Jeffrey (548760 –PLAN808 and PLAN809) Although noting the views of the respondent in relation to new settlements, TAYplan does not consider that new settlements are required within the Proposed Plan period. The Background Technical Note (Page 123, Paragraph 8.71) (CL/Doc58) explains that that there is likely to be sufficient land to accommodate anticipated development within existing settlements over the first 12 years of the Plan. Given this circumstance, and with no defined need for a new settlement, it is most likely that settlement extensions would best reflect the objectives of the settlement strategy within the Proposed Plan.

Scottish Planning Policy (Page 17, Paragraphs 84-85) (CL/Doc2) is also clear that a new settlement may be appropriate if it is justified by the scale and nature of the housing land requirement, and there are physical, environmental or infrastructural constraints to the further growth of existing settlements, it is part of a strategy for promoting rural development and regeneration, it could assist in reducing development pressure on other greenfield land, it can be readily serviced by public transport, it will not have a significant adverse effect on any natural or built heritage interest safeguarded by a national or international designation, and it will not result in other significant environmental disbenefits, for example promoting development in areas of high flood risk. TAYplan also does not consider that there is justification for a new settlement within the region based upon the above criteria. Any change, in the Policy to suggest new settlements would be acceptable would fundamentally undermine the Plan’s objectives.

GS Brown Construction (543112) In relation to modifications sought by the respondent in relation to the Carse of Gowrie, this matter is considered in more detail within Issue 3: Location Priorities – Settlements.

Karen Clark for Discovery Homes (346689) considers that further recognition should be given to land on the urban fringes. TAYplan consider that the identification of development land is for emerging Local Development Plans to consider based on the merits of that land within the context of the strategy. There may be circumstances where some land is allocated within and some on the edges of a principal settlement but it will be for the Local Development Plan to determine if this is the most appropriate outcome.

Lomond Land (237724) The Proposed Plan has identified a series of the region’s principal settlements as the focus for additional development. These settlements are already the 83 TAYPLAN STRATEGIC DEVELOPMENT PLAN largest concentrations of population, jobs, services and facilities. They are also most able to accommodate additional growth. Topic Paper 6: Spatial Strategy (CL/Doc35) explains that the principal settlements were divided into three tiers to reflect their different scales, roles and functions, now and in the future. Concentrating development in these settlements is seen as the best way to ensure that people, business, jobs, services and facilities are all close together offering increased access and opportunities (Page 3, Paragraph 3.4). Prioritising land release within principal settlements ahead of land elsewhere is integral to ensuring that the majority of growth is concentrated there. This is central to meeting the vision and objectives including the need to travel, reduce carbon emissions, reinvest in existing communities and support sustainable economic growth. Policy 1, Part B is consistent with Scottish Planning Policy (Page 16, Paragraph 80) (CL/Doc2) which requires planning authorities to promote the efficient use of land and buildings, directing development towards sites within existing settlements where possible to make effective use of existing infrastructure and service capacity and to reduce energy consumption.

Notwithstanding this, Policy 1: Location Priorities, Part A (Page 13) provides opportunity for Local Development Plans to provide for some development outwith principal settlements where this can be accommodated and supported by the settlement and where it contributes to the objectives of the Strategic Development Plan whilst also meeting local needs or supporting the regeneration of the local economy.

TAYplan consider that Policy 1 is clear, concise and sufficiently flexible to deliver development in the most appropriate locations in accordance with Scottish Planning Policy (Page 16, Paragraph 77).

Penny Uprichard (344887) TAYplan does not agree with the respondent’s comments regarding Policy 1, Part B, priority 3 and the reference to St. Andrews. Policy 1, Part A identifies St. Andrews as a Tier 2 principle settlement. Tier 2 Settlements accommodate some of the TAYplan area new development but at a much smaller scale than the Tier 1 settlements. They are differentiated from Tier 3 because their present roles as service centres, particularly retail and their potential economic significance are important in regional terms, for example the tourism and research potential of St Andrews. The economic importance of St. Andrews was recently acknowledged within the recent Penny Uprichard v The Scottish Ministers and Fife Council Court of Session decision, in which the judge states “The effect of our quashing those parts of the Plan that relate to St Andrews West would be that it would cease to be a strategic land allocation. That would undermine the settlement strategy of the Plan. It would disrupt the local plan process. It would frustrate the policy decision that St Andrews must make its contribution to the economic regeneration of Fife. In this way the wider economic strategy would be undermined and, in my opinion, would become unworkable. I think that there would also be a vacuum in the development plan because there would no longer be a coherent planning framework for development control in St Andrews West.” (Penny Uprichard v The Scottish Ministers and Fife Council Court of Session decision)

The strategy of the Proposed Plan allows for some development in these areas to support their present roles, recognising that their continued use and improvements will contribute significantly to the regional economy. However, beyond the strategic sites outlined in Policy 4 of the Proposed Plan (Page 15) Tier 2 settlements accommodate a smaller share of the new development of the TAYplan area and would be unlikely to accommodate additional strategic scale development. Beyond existing proposals in and around St. Andrews, development pressures would be directed away from St Andrews (Background Technical Note (2010), Page 115, Paragraphs 8.39) (CL/Doc58).

Land Release priority 3 in Policy 1, Part B is the final consideration that should be made 84 TAYPLAN STRATEGIC DEVELOPMENT PLAN when all other land sources for development within identified principle settlements have been exhausted.

Mr Ian Fowler (548055) TAYplan considers that the level of detail in Policy 1 is appropriate for a strategic planning policy document and does not require to prevent coalescence to all settlements within the TAYplan region. Scottish Planning Policy states that “other policies or designations, such as countryside policies, provide an appropriate context for decision making” (Scottish Planning Policy, Page 32, Paragraph 160) (CL/Doc28). Therefore it is considered that the prevention of coalescence of other settlements is an issue which will be considered in more detail within emerging Local Development Plan policy and/or during the planning application process.

Mr Ken Miles (548486) TAYplan does not agree with the respondents comments in relation to Policy 1, Part B, priority 3. Land Release priority 3 in Policy 1, Part B is the final consideration that should be made when all other land sources for development within identified principle settlements have been exhausted.

Royal Burgh of St. Andrews Community Council (453889) Policy 1 and its supporting text on Page 8 is clear and concise as required by Planning Circular 1/2009: Development Planning (Page 4, Paragraph 14) (CL/Doc29)and sufficiently flexible to deliver development in accordance with Scottish Planning Policy (Page 16, Paragraph 77) (CL/Doc2). Prioritising land release within principal settlements or adjacent to them ahead of land elsewhere is integral to ensuring that the majority of growth is concentrated there. This is central to meeting the vision and objectives including the need to travel, reduce carbon emissions, reinvest in existing communities and support sustainable economic growth. Emerging Local Development Plans will allocate appropriate land taking into account the development priorities established within the Strategic Development Plan.

In relation to tourism, TAYplan considers that the modification requested by the respondent is already stated within paragraph 7 on Page 8. There is no requirement to repeat the phrase requested as the text is already clear and concise in accordance with Planning Circular 1/2009: Development Planning.

Smiths Gore for Mansfield Estates (442870); TMS Planning (for Campion Homes (5464910 - PLAN225); ); Mr James Thomson (345005 - PLAN237); Mr Simon Wilson (345007 - PLAN397); Mr Tim Esparon (345006 - PLAN188) and Muir Homes Limited (346675 - PLAN357)) In relation to the comments made on local needs, TAYplan considers that the meeting of local needs, particularly outside of principal settlements along with other considerations is appropriately dealt with in Policy 1, Part A. The supporting text final paragraph on page 8 explains that the various balances between different considerations and how these are applied in different localities will be for Local Development Plans. This is considered sufficient to explain how local needs can be met and no change is proposed.

Smiths Gore for Mansfield Estates (442870) has also requested a modification to Policy 1, Part B in relation to the deletion of the reference to listed buildings. Policy 1, Part B is consistent with Scottish Planning Policy (Page 16, Paragraph 80) (CL/Doc2)which requires planning authorities to promote the efficient use of land and buildings, directing development towards sites within existing settlements where possible to make effective use of existing infrastructure and service capacity and to reduce energy consumption. The reference to listed buildings reflects the strategic importance of these assets in defining the TAYplan region, therefore the reuse of listed buildings is preferential than being left vacant.

Spittalfield and District Community Council (539326) It is considered that there is no requirement to modify the supporting text on Page 8 of the Proposed Plan as requested by 85 TAYPLAN STRATEGIC DEVELOPMENT PLAN the respondent. Policy 1 is clear and concise in relation to development outwith principal settlements. Part A provides opportunity for Local Development Plans to provide for some development outwith principal settlements where this can be accommodated and supported by the settlement and where it contributes to the objectives of the Strategic Development Plan whilst also meeting local needs or supporting the regeneration of the local economy. This part of Policy 1 read in conjunction with Part B, which prioritises the development hierarchy sets out clearly the spatial strategy for implementation by the emerging Local Development Plans. TAYplan therefore consider that a modification, as specified by the respondent for the supporting text, would result in duplication within other parts of the Proposed Strategic Development Plan and would not result in a short, concise and visionary Strategic Development Plan (Planning Circular 1/2009: Development Planning, Page 4, Paragraph 14) (CL/Doc29).

SportScotland (331662) Topic Paper 6: Spatial Strategy (Page 7, Paragraph 5.12) (CL/Doc35) states that the “Proposed Plan must be clear what arrangements are expected for development outside of principle settlements.” The approach adopted by the Proposed Plan seeks to balance the need to support the rural economy with protecting the countryside by ensuring that only development which directly contributes to meet local needs and support the economy is allowed. Policy 1 refers to both development within smaller rural settlements (not identified as principal settlements) as well as more remote countryside areas. Ultimately, emerging Local Development Plans will allocate appropriate land taking into account the development priorities established within this Strategic Development Plan and where it meets the vision and objectives of the Plan, including the need to travel, reduce carbon emissions, reinvest in existing communities and support sustainable economic growth.

St. Andrews Preservation Trust (547750) The Proposed Plan has identified a series of the region’s principal settlements as the focus for additional development. These settlements are already the largest concentrations of population, jobs, services and facilities. They are also most able to accommodate additional growth. Topic Paper 6: Spatial Strategy (CL/Doc35) explains that the principal settlements were divided into three tiers to reflect their different scales, roles and functions, now and in the future. Concentrating development in these settlements is seen as the best way to ensure that people, business, jobs, services and facilities are all close together offering increased access and opportunities (Page 3, Paragraph 3.4). Prioritising land release within principal settlements ahead of land elsewhere is integral to ensuring that the majority of growth is concentrated there. This is central to meeting the vision and objectives including the need to travel, reduce carbon emissions, reinvest in existing communities and support sustainable economic growth. Policy 1, Part B and the supporting text on Page 8 is consistent with Scottish Planning Policy (Page 16, Paragraph 80) (CL/Doc2)which requires planning authorities to promote the efficient use of land and buildings, directing development towards sites within existing settlements where possible to make effective use of existing infrastructure and service capacity and to reduce energy consumption.

In terms of the respondent’s comments in relation to St. Andrews, the recently approved Fife Structure Plan (2009) (CL/Doc39)has already carried out an exercise to identify and consider the implications of strategic sites, including St. Andrews (Background Technical Note (2010), Page 112, Paragraph 8.31) (CL/Doc58). The paragraph within Policy 1 regarding St. Andrews is included in order to protect the setting of the town and the views in and out of its historic core. Smaller scale development within the town’s boundary will be for the Local Development Plan to consider (Topic Paper 6: Spatial Strategy, Page 7, Paragraph 5.13) (CL/Doc35). This approach is also compatible with Policy 3 (Greenbelts). TMS Planning (for Campion Homes (5464910 - PLAN226 and PLAN227); Mr James Thomson (345005 - PLAN238 and PLAN239); Mr Simon Wilson (345007 - PLAN398); 86 TAYPLAN STRATEGIC DEVELOPMENT PLAN Mr Tim Esparon (345006 - PLAN192, PLAN193, PLAN201 and PLAN202); and Muir Homes Limited (346675 - PLAN358)) Land Release priority 3 in Policy 1, Part B is the final consideration that should be made when all other land sources for development within identified principle settlements have been exhausted. Emerging Local Development Plans will allocate appropriate land taking into account the development priorities established within the Strategic Development Plan.

In relation to the comments made on local needs, TAYplan considers that the meeting of local needs, particularly outside of principal settlements along with other considerations is appropriately dealt with in Policy 1, Part A. The supporting text final paragraph on page 8 explains that the various balances between different considerations and how these are applied in different localities will be for Local Development Plans. This is considered sufficient to explain how local needs can be met and no change is therefore proposed.

RESPONSE TO REPRESENTATIONS SUPPORTING AS WRITTEN TAYplan welcomes the support for these issues.

CONCLUSION Policy 1 is consistent with Scottish Planning Policy. 55% of respondents at the Main Issues stage supported the preferred strategy, whilst 14% preferred the alternative strategy. 49% of respondents agreed with the settlements identified as the region’s principal settlements (Main Issues Report (2010), Pages 40-48) and (Topic Paper 6: Spatial Strategy, Page 4). TAYplan considers that the issues raised do not warrant any change to the Proposed Strategic Development Plan (June, 2011) and propose that the elements dealt with in this Schedule 4 Summary of Unresolved Issues remain as written and unchanged. No Key Agencies, including the Scottish Government have sought any changes to Policy 1. TAYplan consider that any modifications to Policy 1 could have fundamental implications on delivering the vision and objectives of the Proposed Plan.

Reporter’s conclusions:

General 1. I have dealt with the general principles of TAYplan’s settlement strategy under Issue 3, and concluded that they should be supported. Representations that seek to remove or dilute the priority given to development within, or on the edge of, principal settlements would undermine that strategy. The policy does not, however, exclude appropriate development in other locations. It does not, for example, impose an outright presumption against any development in the Carse of Gowrie, as argued by one representation. I consider that the general thrust of Policy 1 Part B should be retained, but I go on to look at specific aspects raised in representations.

Brownfield sites 2. Representations seek the addition of ‘where it is financially viable to do so’ to the statement on prioritising the reuse of previously developed land and buildings, and seek recognition that both greenfield and brownfield land will be required to meet development needs. However, I agree with the authority that Scottish Planning Policy (SPP) paragraph 80 states that redevelopment of urban and rural brownfield sites is preferred to development on greenfield sites, and does not qualify that preference with a test of financial viability. The factors listed in the SPP to be taken into account include whether development can be achieved within the required time frame, and that could rule out some brownfield sites in need of extensive remedial work or new infrastructure. Some representations point out that there is a relatively limited supply of brownfield land in the TAYplan region, so it is unlikely that all development needs could be met without recourse to greenfield land. However, I do

87 TAYPLAN STRATEGIC DEVELOPMENT PLAN not consider that there is any need to change the policy by introducing mention of financial viability or greenfield sites.

3. Another suggestion is to remove the words ‘(particularly listed buildings)’. SPP paragraph 111 states that planning authorities should support the best viable use of historic assets that is compatible with the fabric, setting and character of the historic environment. The aim should be to find a new economic use that is viable over the long term with minimum impact on the special architectural and historic interest of the building or area. It is therefore appropriate to give particular emphasis to the reuse of listed buildings wherever possible. That does not rule out sensitive new development alongside, or as part of, listed building conversion where that is necessary to produce a viable scheme. I consider that the reference to listed buildings should remain. As regards the suggested addition of a reference to demolition of buildings to release land, there is nothing in the policy which precludes the demolition of unlisted buildings and I do not see any need to add such a reference.

Sequential approach 4. Representations on behalf of Barratt Homes seek to change ‘prioritise land release for development within principal settlements’ to ‘prioritise land release for development within the core areas’. Other representations seek clarification of how the hierarchy of principal settlements fits into the sequential approach for development priority. These raise the question of whether all principal settlements are, or should be, equal in terms of the sequential approach, or whether the approach is to be applied tier by tier, for example by giving greater priority to development on the edge of Dundee than to development within Carnoustie.

5. In response to my request for clarification, the authority has confirmed its intention that the sequential approach should give equal status to all principal settlements. It is not intended to promote sites on the edge of settlements in general ahead of land within them; but neither does it exclude these. Which specific sites are allocated for different land uses is a matter for local development plans. The authority has suggested alternative wording which could overcome any potential ambiguity. This would replace the existing statement with:

‘B. prioritise land release for all principal settlements using the sequential approach in this Policy; and, prioritise within each category, as appropriate, the reuse of previously developed land and buildings (particularly listed buildings).’

Alongside this alternative wording the title ‘sequential approach’ would be inserted above the diagram to the right. The existing text ‘land release within principal settlements ahead of other land’ could be considered repetitive of the sequential categories in the diagram and the supporting text on page 8, right-hand column. The alternative wording would explain more clearly that the sequential categories apply equally to all principal settlements without detracting from the original emphasis of the policy and without introducing greater complexity. It would reinforce the generic references to ‘principal settlements’ as a collective within the supporting text.

6. I consider that the proposed alternative wording would bring greater clarity and avoid any ambiguity inherent in the present policy statement, and I recommend that it be adopted. In doing so, I endorse the policy of giving equal weight to all principal settlements and I do not support the suggestion that the core areas (Dundee and Perth) should be given greater weight than other settlements in applying the sequential approach. The policy does not discriminate against edge-of-settlement development in the core areas where this is justified to meet demand.

88 TAYPLAN STRATEGIC DEVELOPMENT PLAN Effectiveness 7. Representations on behalf of Zurich Assurance Limited seek addition of the word ‘effective’ before ‘land’ in boxes 1 and 2 of the sequential diagram. This would emphasise resource efficiency by concentrating development on sites that do not require significant new infrastructure investment. The authority, however, points out that Policy 5 requires local development plans to identify a minimum 5 year effective land supply, and work towards a 7 year supply. The application of that policy will therefore ensure that sites which are already effective will be given priority over those requiring new infrastructure investment, and I do not consider that any reference to effectiveness needs to be added to Policy 1.

Small settlements and rural development 8. Box 3 of the sequential approach diagram needs to be read with the paragraph in Policy 1A beginning ‘Local Development Plans may also provide’. Together, they provide the policy for development in non-principal settlements and rural areas. Representations have queried the meaning of ‘self-sustaining settlements’ in box 3. It is unlikely that small settlements could become self-sustaining, in the sense of providing for all their residents’ needs. In response to my request for clarification, the authority points out that the expression is intended to ensure that development in locations outside principal settlements contributes to creating places which have the appropriate infrastructure and range of local services and facilities to contribute to the objectives set out on page 6. This supports the place shaping agenda set out in the vision and, in more detail, in Policy 2. It is needed to ensure that the development needs of rural communities and small settlements, which are not defined in Policy 1 Part A, can be met.

9. The authority has suggested alternative wording for box 3 as follows:

'3. Where there is insufficient land or where the nature/scale of land use required to deliver the Plan cannot be accommodated within or on the edge of principal settlements and this offers the genuine opportunity to fulfil the locational and place shaping elements of this Plan the expansion of other settlements should be considered’.

This, however, would introduce a potential new ambiguity about the meaning of ‘locational’. In my view it is meant to refer to Part A of Policy 1, and in particular the paragraph beginning ‘Local Development Plans may also provide’, while place shaping is principally the subject of Policy 2. I consider that box 3 would be clearer if it referred directly to Policy 1 Part A and to Policy 2, and that the words, ‘this offers the genuine opportunity to fulfil the locational and place shaping elements of this Plan’ should be replaced by ‘where it is consistent with Part A of this policy and with Policy 2,’.

10. Representations seek a stand-alone policy for rural communities which is based on the contribution of development to sustaining the settlements where it is proposed, and is not dependent on the availability of land in principal settlements. Such an approach is inherent in Part A of Policy 1, which refers to meeting specific local needs, but is arguably undermined by box 3 of the sequential approach which requires land within or on the edge of principal settlements to be considered first. However, in my view box 3 (with the recommended amendments) is compatible with the rest of the policy. Some of the development required to deliver the plan will be development to meet the needs of small settlements, which by definition could not be located in principal settlements. For example, if all the retail and community facility needs of a village were to be met in a nearby town rather than in the village itself, there would be increased need for travel resulting in increased carbon emissions and disadvantage to rural residents, which would be incompatible with the plan. Such development is of a nature which cannot be accommodated within or on the edge of a principal settlement, and would therefore satisfy the test in box 3. I do not therefore consider there is a need for a separate stand-alone policy. 89 TAYPLAN STRATEGIC DEVELOPMENT PLAN

11. SportScotland seeks clarification of the policy for development in rural areas outside any settlement. The sequential approach in Part B of Policy 1 is clearly concerned only with settlements, but development in rural areas outside settlements is covered in Part A. The placing of the words there, ‘where this can be accommodated and supported by the settlement’, however, raises doubt as to whether any development in the countryside outside settlements is envisaged. This difficulty could be overcome by moving the words ‘and in rural areas’ to place them after ‘supported by the settlement’, and I recommend that Part A of Policy 1 be reworded accordingly.

12. Spittalfield and District Community Council seeks to amend the last paragraph on page 8 by adding at the end of the first sentence after ‘by allowing some development in small settlements which are not principal settlements’ the words, ‘in small proportion to their size’. Mr Ian Fowler seeks addition of a comment that present village boundaries will be recognised and coalescence will not be allowed. However, Part A of Policy 1 requires development in such settlements to meet specific local needs or support the regeneration of the local economy. Large-scale expansion is unlikely to be compatible with this requirement. In any event, the scale and nature of development in such settlements and the effect on settlement boundaries are matters for local development plans. I therefore do not consider there is any need to change the text on page 8.

Reporter’s recommendations:

Modify page 9 of the proposed plan as follows:

In Part A, replace the paragraph beginning “Local Development Plans may also provide” with the following:

“Local Development Plans may also provide for some development in settlements that are not defined as principal settlements where this can be accommodated and supported by the settlement, and in rural areas, if such development genuinely contributes to the objectives of this Plan and meets specific local needs or supports regeneration of the local economy.”

In Part B, replace the paragraph on the left of the page with the following:

“B. prioritise land release for all principal settlements using the sequential approach in this Policy; and prioritise within each category, as appropriate, the reuse of previously developed land and buildings (particularly listed buildings).”

Above the diagram at the bottom right of the page, insert:

“Sequential Approach”.

Replace the text in box 3 of the diagram with the following:

“3. Where there is insufficient land or where the nature/scale of land use required to deliver the Plan cannot be accommodated within or on the edge of principal settlements, and where it is consistent with Part A of this policy and with Policy 2, the expansion of other settlements should be considered.”

90 TAYPLAN STRATEGIC DEVELOPMENT PLAN

Issue 5 Shaping Better Quality Places

Reporter: Page 10: Shaping Better Quality Places Development plan Mike Cunliffe (and Supporting Text reference: Scott Ferrie Page 11: Policy 2 Shaping Better Quality Places where stated) Body or person(s) submitting a representation raising the issue (including reference number):

Seeking a change ID Representation Number Person/Organisation Reference 443109 Barton Willmore for Scotia Homes PLAN380 450103 CTC Right to Ride Network PLAN838 450103 CTC Right to Ride Network PLAN839 548525 Dr Peter Symon PLAN897 548117 Dundas Estates and Development Co PLAN432 445201 Emac Planning for A & J Stephen PLAN695 548522 Emac Planning for A & J Stephen Ltd/Bett Homes Ltd PLAN738 445204 Emac Planning for Angus Estates PLAN602 548523 Emac Planning for Bett Homes Ltd PLAN763 445206 Emac Planning for J G Lang & Son PLAN536 445203 Emac Planning for James Keiller Estates Ltd PLAN715 548383 Emac Planning for L Porter PLAN564 548301 Emac Planning for M Batchelor (K) PLAN519 445205 Emac Planning for Mr R Watson PLAN510 548524 Emac Planning for Stewart Milne Homes PLAN779 329236 Forth Ports PLC PLAN682 548389 Halliday Fraser Munro for Barratt Homes PLAN584 442882 Homes for Scotland PLAN216 Jones Lang La Salle for Scottish and Southern Energy 441086 PLAN907 and its Group Companies 443979 Lynne Palmer PLAN160 443979 Lynne Palmer PLAN161 443979 Lynne Palmer PLAN292 406092 Mr Ken Russell PLAN33 547710 NHS Tayside PLAN298 344887 Penny Uprichard PLAN875 545597 Prof Charles McKean PLAN148 442290 Rossco Properties PLAN162 453889 Royal Burgh of St. Andrews Community Council PLAN920 344848 Scottish Natural Heritage PLAN408 444087 Scottish Property Federation PLAN246 442870 Smiths Gore for Mansfield Estates PLAN550 442870 Smiths Gore for Mansfield Estates PLAN551 539251 Stewart Milne Homes PLAN324

Support as written ID Representation Number Person/Organisation Reference 349314 Architecture and Design Scotland PLAN905 419429 Auchterarder and District Community Council PLAN81

91 TAYPLAN STRATEGIC DEVELOPMENT PLAN 443109 Barton Willmore for Scotia Homes PLAN379 442149 Bidwells for Zurich Assurance Ltd PLAN664 423150 Braes of the Carse Conservation Group PLAN22 335193 Broughty Ferry Community Council PLAN3 416017 Colliers International for Persimmon Homes Ltd PLAN42 541486 Colliers International for Taylor Wimpey East Scotland PLAN65 450613 Councillor Michael A Barnacle PLAN813 547239 Forestry Commission Scotland PLAN268 445299 Inchture Area Community Council PLAN801 263542 Kingsbarns Community Council PLAN384 263542 Kingsbarns Community Council PLAN377 Loch Lomond and The Trossachs National Park 442806 PLAN102 Authority 450585 Methven and District Community Council PLAN863 Montgomery Forgan Associates for Morris Leslie 445161 PLAN655 Group 547710 NHS Tayside PLAN297 349010 PPCA Ltd for Alfred Stewart Properties Ltd PLAN16 Ryden for Bon Accord Land Limited/ Stewart Milne 330884 PLAN128 Homes Savills for John Dewar Lamberkin Trust and Needhill 548335 PLAN651 LLP 344939 Scottish Enterprise PLAN424 442031 Scottish Environmental Protection Agency PLAN173 442031 Scottish Environmental Protection Agency PLAN174 442031 Scottish Environmental Protection Agency PLAN175 442031 Scottish Environmental Protection Agency PLAN176 442031 Scottish Environmental Protection Agency PLAN172 344848 Scottish Natural Heritage PLAN417 344848 Scottish Natural Heritage PLAN416 337414 Scottish Water PLAN131 548745 Scottish Wildlife Trust Angus and Dundee Members PLAN806 441235 Tactran Regional Transport Partnership PLAN121 Provision of the development plan To set a framework for better quality places to provide for improved to which the issue resilience through greater adaptability. relates: Planning authority’s summary of the representation(s):

SUMMARY OF REPRESENTATIONS SEEKING A CHANGE

RESILIENCE (Policy 2 Part A) a) Flooding and the Undeveloped Coast Whilst there is a common understanding that there should be an overall presumption against development in areas of flood risk and coastal erosion, Dr Peter Symon (548525) seeks more detail on such flood-prone areas and Jones Lang LaSalle for Scottish and Southern Energy and its Group Companies (441086) seek greater detail in recognising that an exception may be made for essential infrastructure on areas vulnerable to coastal erosion, flood risk and on the undeveloped coast. Jones Lang LaSalle for Scottish and Southern Energy and its Group Companies (441086) consider that there may be some circumstances where locational decisions are required to support, for example, the development of the offshore marine renewables industry.

92 TAYPLAN STRATEGIC DEVELOPMENT PLAN Lynne Palmer (443979) and the Royal Burgh of St. Andrews Community Council (453889) seek small changes to the wording and grammar of sections 2ai) and 2aii) to include greater consideration of green networks and to enhance the clarity of these sections and remove ambiguity or variance from national policy.

TAYplan also note that whilst some respondents support the policy, they have identified some specific areas that seek a change: Scottish Water (337414) suggest that in addition to SUDs, flood routing is used to mitigate flooding, the Forestry Commission Scotland (547239) suggest relating SUDs and green networks to improve and expand our environment for the enjoyment of all, and the Scottish Environmental Protection Agency (442031) suggest that avoidance of flooding and flood risk from all sources, not just coastal and fluvial should be considered in future revisions of the Plan. b) Green Infrastructure

The Royal Burgh of St. Andrews Community Council (453889) seek a change to the expression ‘green infrastructure’ to ensure clarity of the meaning behind the term.

COMMUNITY INFRASTRUCTURE (Policy 2 Part B) a) Community Facilities

Mr Ken Russell (406092) seeks a change to Policy 2 (Part B) to provide recognition of use class 10 and 11 facilities at a strategic scale to provide clear guidance for Local Development Plans. b) New Development

Whilst Bon Accord Land Limited/Stewart Milne Homes (330884) support pages 10 and 11 in general, they have identified a specific area that they seek a change. They consider that encouragement should be given, where capacity, to new development outwith cities.

TRANSPORT INTEGRATION (Policy 2 Part C) Smiths Gore for Mansfield Estates (442870) PLAN550 and CTC Right to Ride Network (450103) both seek a change to the wording of Policy 2 (Part C). Smiths Gore for Mansfield Estates (442870) seek to ensure that there is more mention of supporting rural and remote areas, providing realistic sustainable transport objectives for these areas as per information provided in Scottish Planning Policy (2010). CTC Right to Ride Network (450103) PLAN838 seek to provide clarity on the section as a whole by small changes to wording and on providing specific emphasis on reducing the need to travel by car, and developing the approach to sustainable transport by providing additional reference to cycling.

WASTE MANAGEMENT (Policy 2 Part D) Lynne Palmer (443979) PLAN160 seeks a change to Policy 2 (Part D) to provide greater clarity around finding solutions to recycling which are not currently be possible.

RESOURCE EFFICIENCY AND LOW/ZERO CARBON GENERATION (Policy 2 Part E) a) Resource Efficiency and Low/Zero Carbon Generation

Homes for Scotland (442882), Scottish Property Federation (444087), Stewart Milne Homes (539251), Smiths Gore for Mansfield Estates (442870) PLAN551, Emac 93 TAYPLAN STRATEGIC DEVELOPMENT PLAN Planning (for L Porter (548383), James Keiller Estates Ltd (445203), J G Lang & Son (445206), Mr R Watson (445205), M Batchelor (K) (548301), A & J Stephen (445201), Bett Homes Ltd (548523), A & J Stephen Ltd/Bett Homes Ltd (548522), Angus Estates (445204), Stewart Milne Homes (548524)), Barton Willmore for Scotia Homes (443109) and Dundas Estates and Development Co (548117) are concerned about the reference to exceeding Scottish Government low carbon targets and wish to seek a change to the wording in Policy 2 (Part E).

Smiths Gore for Mansfield Estates (442870), Homes for Scotland (442882), Stewart Milne Homes (539251), Dundas Estates and Development Co (548117) and Emac Planning (for L Porter (548383), James Keiller Estates Ltd (445203), J G Lang & Son (445206), Mr R Watson (445205), M Batchelor (K) (548301)) seek a change to provide greater flexibility to respond to continuing changes in Scottish Government policy.

Smiths Gore for Mansfield Estates (442870), Homes for Scotland (442882), Barton Wilmore for Scotia Homes (443109), Dundas Estates and Development Co (548117), and Emac Planning (for L Porter (548383), James Keiller Estates Ltd (445203), J G Lang & Son (445206), Mr R Watson (445205), M Batchelor (K) (548301)) seek a change to provide greater consideration of more effective building design, materials and construction methods rather than low and zero carbon generating technologies as more viable in the present and foreseeable future economic climate.

The Scottish Property Federation (444087) consider 15% reductions to be achievable, but have concern about the final 5% reduction and view this as a threat to the viability of development and question why such an issue should be an issue for TAYplan, given what the Scottish Property Federation (444087) consider to be misguiding requirements of Scottish Planning Policy and Planning Advice Note 84. Emac Planning (for L Porter (548383), James Keiller Estates Ltd (445203), J G Lang & Son (445206), Mr R Watson (445205), M Batchelor (K) (548301)) and Emac Planning (for A & J Stephen (445201), A & J Stephen Ltd/ Bett Homes Ltd (548522), Bett Homes Ltd (548523), Angus Estates (445204), Stewart Milne Homes (548524)) agree with the above point in balancing the level of current low carbon targets against the viability of development in this economic climate.

Stewart Milne Homes (539251) seek a replacement of text in Policy 2 (Part E) to focus on a generic statement which ensures consideration of the fabric of the development site, rather than focusing on shortsighted low and zero carbon technologies. Stewart Milne Homes (539251) view this as the most appropriate, cost effective and long-term solution to meet or exceed Scottish Government targets. b) Large Scale Renewable Technologies

Forth Ports PLC (329236) seek a change to replace the implicit reference to renewable energy throughout pages 10, 11 and specifically in Policy 2 (Part E) to be made explicit to provide greater flexibility for encourage development of renewable technologies on a larger scale and the integration of these with smaller developments to meet the Scottish Government’s 2020 targets for renewable electricity generation and heat.

ARRANGEMENT, LAYOUT, DESIGN, DENSITY AND MIX OF DEVELOPMENT (Policy 2 Part F) a) Green Infrastructure

Scottish Natural Heritage (344848) seek a change to amend Policy 2 (Part F) to ensure that the design of development includes the provision of additional green infrastructure, to 94 TAYPLAN STRATEGIC DEVELOPMENT PLAN ensure respect for existing features and assets and to link with other policies in the Proposed Strategic Development Plan which make reference to green infrastructure. b) Scottish Government Policy

CTC Right to Ride Network (450103) PLAN839 seeks a change to Policy 2 (Part F) to provide greater consideration of other Scottish Government policy documents which are considered relevant, in addition to Designing Places and Designing Streets, already mentioned. They also seeks clarity on the meanings of phrases in the policy which state, integrating networks and utilising existing green spaces.

SUPPORTING TEXT, POLICY AND GENERAL a) Place Quality

Dr Peter Symon (548525) seeks a change to provide explicit reference to the orientation and aspect of dwellings.

Penny Uprichard (344887) welcomes the aspirations of Policy 2, but expresses concern that if the Plan is approved, it is unlikely the aspirations will lead to a new culture in delivering the aims.

Prof Charles McKean (545597) expresses concern about recent poor new-build standards and suggests that understanding the historic grain should not be a substitute for achieving quality. Lynne Palmer (443979) PLAN161 also expresses concern about place quality in general, with specific reference to Bridgend in Perth and how current standards in Bridgend need to be carefully thought through, to develop a better quality of life, before any further development in brought to the area through the Local Development Plan process. b) Graphics

Halliday Fraser Munro for Barratt Homes (548389) seek a change to remove the graphics from page 10 completely as suggest that these are not relevant to a strategic planning document, are not clear, nor are significant to the overall strategy of TAYplan and instead suggest that these should be covered in supplementary planning guidance or within the emerging Local Development Plans.

NHS Tayside (547710) seeks changes to the scale/principle/outcome diagram on page 10 to provide greater clarity and detail. NHS Tayside (547710) considers that this diagram should reflect, more closely, the local planning needs to involve local people. Lynne Palmer (443979) PLAN292 seeks clarification on the reference to ‘frontage developments’ in the Inverness City Vision diagram.

The Royal Burgh of St. Andrews Community Council (453889) seek changes to the wording accompanying the diagrams in Policy 2 (Part F) for greater clarity and relevance at a strategic scale.

Halliday Fraser Munro for Barratt Homes (548389) seek a change to remove the graphics from Policy 2 (Part F) completely as suggest that these are not relevant to a strategic planning document, are not clear, nor are significant to the overall strategy of TAYplan and instead suggest that these should be covered in supplementary planning guidance or within the emerging Local Development Plans.

95 TAYPLAN STRATEGIC DEVELOPMENT PLAN c) Economic Viability Rossco Properties (442290) seeks a change to take full account of economic and viability issues of development proposals.

SUMMARY OF REPRESENTATIONS SUPPORTING AS WRITTEN

RESILIENCE (Policy 2 Part A) Scottish Water (337414) and the Scottish Environmental Protection Agency (442031) PLAN173 both support Policy 2 (Part A), with the Scottish Environmental Protection Agency (442031) PLAN173 showing particular support to the emphasis on climate change, reference to the importance of reducing surface runoff through sustainable urban drainage systems and reference to the strategic importance of carbon rich soils.

The Forestry Commission Scotland (547239) are generally supportive of the whole plan.

COMMUNITY INFRASTRUCTURE (Policy 2 Part B) Colliers International (for Persimmon Homes Ltd (416017) and Taylor Wimpey East Scotland (541486)) both support Policy 2 (Part B), drawing particular attention to the fact that infrastructure should enhance not just the physical land use but also the social and environmental infrastructure.

TRANSPORT INTEGRATION (Policy 2 Part C) The Scottish Environmental Protection Agency (442031) PLAN174 and Montgomery Forgan Associates for the Morris Leslie Group (445161) both support Policy 2 (Part C). The Scottish Environmental Protection Agency (442031) PLAN174 show particular support for the mention of infrastructure improvements, especially in Air Quality Management Areas. Montgomery Forgan Associates for Morris Leslie Group (445161) supports the aspiration of developing and integrating sustainable transport and land uses.

WASTE MANAGEMENT (Policy 2 Part D) The Scottish Environmental Protection Agency (442031) PLAN175 support Policy 2 (Part D) and the incorporation of waste solutions.

RESOURCE EFFICIENCY AND LOW/ZERO CARBON GENERATION (Policy 2 Part E) The Scottish Environmental Protection Agency (442031) PLAN176 support Policy 2 (Part E) and the requirements for local plans and masterplans to require high resource efficiency in development, including low carbon energy technologies, suggesting that heat recovery mapping could further develop opportunities for heat recovery.

ARRANGEMENT, LAYOUT, DESIGN, DENSITY AND MIX OF DEVELOPMENT (Policy 2 Part F) Broughty Ferry Community Council (335193) and Kingsbarns Community Council (263542) PLAN384/377 both support Policy 2 (Part F). Broughty Ferry Community Council (335193) state the importance of protecting built assets and the use of traditional materials to provide a sense of place and regional character. Kingsbarns Community Council (263542) PLAN384/377 believe that this part of the policy is particularly important in a Conservation village like Kingsbarns and to protect its unique landscape and small townscape qualities which attract tourists to visit.

SUPPORTING TEXT, POLICY AND GENERAL PPCA Ltd for Alfred Stewart Properties Ltd (349010), Loch Lomond and The Trossachs National Park Authority (442806), Scottish Enterprise (344848), Scottish Natural Heritage (344848) PLAN417, Inchture Area Community Council (445299), 96 TAYPLAN STRATEGIC DEVELOPMENT PLAN Scottish Wildlife Trust Angus and Dundee Members (548745), Councillor Michael A Barnacle (450613), Methven and District Community Council (450585) and Architecture and Design Scotland (349314) all support the whole of policy 2. PPCA Ltd for Alfred Stewart Properties Ltd (349010) specifically support the infrastructure led approach, Scottish Enterprise (344848)support the attractiveness of locations for economic development and Scottish Natural Heritage (344848) PLAN417 support quality of place and the emphasis on protecting and enhancing habitats, landscapes and networks of green space. Inchture Area Community Council (445299)shows particular support for Part A i), the Scottish Wildlife Trust Angus and Dundee Members (548745) particularly supporting the recognition of climate change and Councillor Michael A Barnacle (450613) the overall aims of this policy. Architecture and Design Scotland (349314) particularly support the briefing, structure and delivery and stewardship emphasis of the policy.

Tactran Regional Transport Partnership (441235), Auchterarder and District Community Council (419429), Ryden for Bon Accord Land Limited/ Stewart Milne Homes (330884), Braes of the Carse Conservation Group (423150), Bidwells for Zurich Assurance Ltd (442149) and Savills for John Dewar Lamberkin Trust and Needhill LLP (548335) support pages 10 and 11 of the Proposed Plan in general. The Braes of the Carse Conservation Group (423150) show particular support for the presumption against development in areas vulnerable to flood risk and rising sea level and Bidwells for Zurich Assurance Ltd (442149) is pleased that the quality of place within TAYplan is central to the vision and objectives of the Plan as this contributes to a better quality of life and makes the region more attractive. Savills for John Dewar Lamberkin Trust and Needhill LLP (548335) show support specifically for Policy 2.

The Scottish Environmental Protection Agency (442031) PLAN172, NHS Tayside (547710), Scottish Natural Heritage (344848) PLAN416 and Barton Willmore for Scotia Homes (443109) all support the supporting text on page 10 of the Proposed Plan. The Scottish Environmental Protection Agency (442031) PLAN172 specifically support the emphasis on local authorities using the Scottish Environmental Protection Agency’s (442031) PLAN172 map based advice on pressures affecting the water environment. NHS Tayside (547710) support the promotion of active travel through the design of the environment. Scottish Natural Heritage (344848) PLAN416 support paragraphs 1-7 of the supporting text and the diagrams. Barton Willmore for Scotia Homes (443109) specifically supports the sentence ‘good quality development properly considers how location, design and layout can reduce the need to consume resources, maximise the contribution of sustainable economic and support a better quality of life’.

Modifications sought by those submitting representations:

NOTE TO REPORTER: The text in italics in this section has been lifted directly from the each

individual/organisation’s representation with minor typographical errors corrected.

RESILIENCE (Part A) a) Flooding and the Undeveloped Coast

Dr Peter Symon (548525) • ‘discussion of presumption against development in areas at risk of flooding (p 11) should be accompanied by a list of such flood-prone areas and a map showing their locations (including inter alia any in the lower Earn valley, the Almond valley and the Tay valley north of Perth).’

97 TAYPLAN STRATEGIC DEVELOPMENT PLAN Jones Lang LaSalle for Scottish and Southern Energy and its Group Companies (441086) • ‘recommended that, with respect to the presumption against development in areas vulnerable to coastal erosion or flood risk, this is clarified with recognising that an exception may be made for essential infrastructure.’ • ‘recommend that Policy 2 is amended to allow for essential infrastructure to be located on the majority of coastal locations, subject to appropriate justifications and assessment of environmental impact.’

Forestry Commission Scotland (547239) • ‘under policy 2 para A, would like to see under (ii) something relating to SUDS and green networks.’

Lynne Palmer (443979) • ‘page 11 at Ai 3rd sentence down, remove semi-colon after "measures". Should be a comma.’

Royal Burgh of St. Andrews Community Council (453889) • Page 11, Policy 2Ai: ‘Change "a presumption against development in areas vulnerable to coastal erosion, flood risk and rising sea levels; including the undeveloped coast." to "a presumption against development in areas vulnerable to coastal erosion, flood risk or rising sea levels; or situated on the undeveloped coast." • Page 11, Policy 2Ai: ‘Delete "To ensure flood risk is not exacerbated, mitigation and management measures; such as those envisaged by Scottish Planning Policy, should be promoted;" ’

Scottish Water (337414) • Section ii): ‘in addition to the use of SUDS, flood routing should also be considered as a method of dealing with flooding as this will require less land and will help to route flood water away from housing.’

Scottish Environmental Protection Agency (442031) • ‘consideration be given to placing greater emphasis in future revisions of the Plan on avoidance of flooding and flood risk from all sources, not just coastal and fluvial.’ b) Green Infrastructure Royal Burgh of St. Andrews Community Council (453889) • Page 11, Policy 2Aiv: ‘Change "Identifying, retaining and enhancing existing green infrastructure and spaces" to "Identifying, retaining and enhancing existing open spaces." ’

COMMUNITY INFRASTRUCTURE (Part B) a) Community Facilities Mr Ken Russell (406092) • Part B: ‘integrate new development with existing community infrastructure and work with other delivery bodies to integrate, concentrate and co-locate additional new infrastructure ADD and community facilities to optimise its coverage and capability.’ b) New Development Bon Accord Land Limited/Stewart Milne Homes (330884) • Part B: ‘Encouragement should be given to the provision of new homes in suitable, sustainable locations in settlements outwith the major cities which have the capacity to accept new development.’ 98 TAYPLAN STRATEGIC DEVELOPMENT PLAN TRANSPORT INTEGRATION (Part C)

Smiths Gore for Mansfield Estates (442870) PLAN550 • Proposal C: ‘Add "ensure that rural areas are also supported and be realistic about the likely availability of alternative to access by car in rural and remote rural areas." ’

CTC Right to Ride Network (450103) PLAN838 • ‘To reduce the need to travel. We would be obliged if the words "especially by car" were to be added. Ref. Scottish Planning Policy, February 2010, para 165, 3rd line "this means a shift from car based travel...". Para 167, 4th last line, "reducing reliance on the car", Para 169, "Hierarchy of Priorities" i.e.:-walking, cycling, public transport, then car and other motorised modes. 4th line "to achieve a walkable". We would be obliged if this was altered to "achieve a walking and cycling environment.....Ref. above mentioned SPP reference.’ • ‘5th line, "land uses with green space". Would changing the word "with" to "also" be appropriate. I.e.: - what has previously been suggested, "the improved usage of existing established networks, before the introduction of highly expensive new infrastructure.’

WASTE MANAGEMENT (Part D)

Lynne Palmer (443979) PLAN160 • ‘Policy 2D insert after the word "solutions", including recycling.’

RESOURCE EFFICIENCY AND LOW/ZERO CARBON GENERATION (Part E) a) Resource Efficiency and Low/Zero Carbon Generation Homes for Scotland (442882) and Smiths Gore for Mansfield Estates (442870) PLAN551 • ‘Ensure that high resource efficiency and low/zero carbon energy generation technologies are incorporated within development to reduce carbon emissions and energy consumption...’ should be changed to ‘ Ensure that new developments are created with the full recognition of the need to reduce carbon emissions and energy consumption to meet or exceed Scottish Government’s standards. This may be through improved building techniques; low and zero carbon energy generation technologies; or other mechanisms proposed by the Scottish Government.’

Emac Planning for (L Porter (548383), James Keiller Estates Ltd (445203), J G Lang & Son (445206), M Batchelor (K) (548301) and Mr R Watson (445205)) • ‘Delete sentence or replace ‘Ensure that new developments are built to standards that create low energy buildings and development. This may be achieved through improved building techniques and/or low and zero carbon energy generation technologies, in order to seek to meet Scottish Government standards". The requirement to "exceed" Government Targets should be removed.’

Emac Planning for (A & J Stephen (445201), A & J Stephen Ltd/Bett Homes Ltd (548522), Bett Homes Ltd (548523), Angus Estates (445204) and Stewart Milne Homes (548524)) • ‘Delete sentence and insert ‘Ensure that new developments are built to standards that create low energy buildings and development. This may be through improved building techniques and/or low and zero carbon energy generation technologies.' • ‘The requirement to "exceed" Government Targets should be removed.’

99 TAYPLAN STRATEGIC DEVELOPMENT PLAN Barton Willmore for Scotia Homes (443109) • ‘Reword as follows: "ensure that high resource efficiency and low/zero carbon energy generation technologies are incorporated within development, where appropriate and practical, to reduce carbon emissions and energy consumption to meet or exceed Scottish Governments standards." ’

Scottish Property Federation (444087) • ‘The plan should recognise that reductions of 15% and more can be achieved by construction methods, including better insulation, different wall materials, and general air tightness. However, requiring development to achieve the final 5% to reach zero carbon is extremely costly and will threaten the viability of development.’

Stewart Milne Homes (539251) • ‘Section E. from Policy 2 be removed and replaced with a generic "fabric first" or resource efficient approach to carbon saving measures through development to meet or exceed Government targets.’

Dundas Estates and Development Co (548117) • ‘The commentary at 'E' should be expanded to include for all technical building improvements rather than simply low/zero carbon generation technologies.’ b) Large Scale Renewable Technologies Forth Ports PLC (329236) • ‘The need to consider the generation of renewable energy is implicit in the text in pages 10 and 11, but should be made explicit.’ • Part E: ‘should promote renewable energy technologies to service development in its widest sense, rather than just as a small scale part of an individual development.’

ARRANGEMENT, LAYOUT, DESIGN, DENSITY AND MIX OF DEVELOPMENT (Part F) a) Green Infrastructure Scottish Natural Heritage (344848) • ‘The introductory sentence of 'F' should be amended to include "..assets, the multiple roles of infrastructure and networks and local design context and provision of additional green infrastructure to deliver these roles, and meet the requirements of Scottish Government’s Designing Places and Designing Streets." ’ b) Scottish Government Policy CTC Right to Ride Network (450103) PLAN839 • Add: ‘Transport Scotland, Disability Discrimination Act, Good practice Guide for Roads.’

SUPPORTING TEXT, POLICY AND GENERAL a) Place Quality

Dr Peter Symon (548525) • ‘discussion of good quality (housing) development (p.10) should include explicit reference to orientation and aspect of dwellings.’

Penny Uprichard (344887) and Lynne Palmer (443979) PLAN161 • None stated.

100 TAYPLAN STRATEGIC DEVELOPMENT PLAN Prof Charles McKean (545597) • Policy 2F: ‘after 'context ' add 'raise procurement patterns and quality standards to at least those recommended by Architecture and Design Scotland' and meet.... ’ b) Graphics

Halliday Fraser Munro for Barratt Homes (548389) • Page 10: ‘Remove graphics.’

NHS Tayside (547710) • ‘Diagram - 'Region: Settlement: Neighbourhood'. Emphasis should reflect that local planning needs to involve local people.’

Lynne Palmer (443979) PLAN292 • None stated.

Royal Burgh of St. Andrews Community Council (453889) • Page 11, Policy 2F: ‘Change "Making it easy, safe and desirable to walk and cycle within and between neighbourhoods utilising existing green space and water networks" to "Making it easy, safe and desirable to walk and cycle within and between neighbourhoods utilising existing green space and paths alongside water networks". ’ • Page 11, Policy 2F: ‘Change "This approach will help determine the size, shape and form of development and how it can respond to adaptation to help achieve future- proofing our new communities and facilities" to "This approach will help determine the size, shape and form of development and make communities and facilities more sustainable". ’

Halliday Fraser Munro for Barratt Homes (548389) • Page 11, F: ‘Remove graphics.’ c) Economic Viability

Rossco Properties (442290) • ‘Policy 2 needs to take full account of economic and viability issues of development proposals.’

Summary of responses (including reasons) by planning authority:

RESPONSE TO REPRESENTATIONS SEEKING A CHANGE

RESILIENCE (Policy 2 Part A) a) Flooding and the Undeveloped Coast

Dr Peter Symon (548525) and Jones Lang LaSalle for Scottish and Southern Energy and its Group Companies (441086) Policy 2 (Part A) cannot consider all types of development proposals that may come forward but the policy framework does broadly cover the key strategic aspects of climate change resilience and flood risk (CL/Doc65). Paragraph 5.16 (page 12) of TAYplan Topic Paper 3: Resources and Climate Change (June 2011) (006/SL/Doc47) states: ‘…define broad areas where Scottish Planning Policy (2010) (CL/Doc2) requirements apply but it could be for Local Development Plans to determine which areas are at risk from flooding and sea level rise and to develop policies to manage retreat an realignment’. 101 TAYPLAN STRATEGIC DEVELOPMENT PLAN The location of onshore infrastructure for marine renewables will be assessed against a broad range of development plan and national policy.

The Scottish Environmental Protection Agency (442031) support the approach taken in Policy 2 (Part A).

Lynne Palmer (443979) and Royal Burgh of St. Andrews Community Council (453889) This policy is clear and coherent and accords with Scottish Planning Policy (2010) (paragraphs 43, 98, 102 and 103 (pages 8, 20 and 21) (006/SL/Doc44). The policy has been prepared in close consultation with the Key Agencies, many of whom have noted their support to change the policy is unnecessary and would raise issues of inconsistency across the Plan.

Scottish Water (337414), Forestry Commission Scotland (547239) and Scottish Environmental Protection Agency (442031) The policy covers these issues and further detail will be provided through Local Development Plan policies. The policy is consistent with Scottish Planning Policy (2010) (CL/Doc2). Some of the respondents have not been clear on what they wish the policy to be changed to. b) Green Infrastructure Royal Burgh of St. Andrews Community Council (453889) Paragraph 5.19 in TAYplan Topic Paper 3: Resources and Climate Change (June 2011) (CL/Doc32) provides clarity on the definition of the term ‘green infrastructure’ used in the Strategic Development Plan. This term is considered appropriate for use in this policy, is widely used, and therefore it is not considered that a change will be required.

COMMUNITY INFRASTRUCTURE (Policy 2 Part B) a) Community Facilities Mr Ken Russell (406092) Community infrastructure includes all types of community facilities. The emphasis of the Plan on quality of place and this part of Policy is about the provision of community facilities. TAYplan proposes to make no change. There is not a need to be specific on the use classes. Using the term ‘facilities’, is more understandable to people. b) New Development Bon Accord Land Limited/ Stewart Milne Homes (330884) TAYplan’s strategy does not prevent new development outwith cities. TAYplan is minded to retain the current wording in Policy 2, Part B which relates to all new development and fits in with the context of Policy 1: Location Priorities (Schedule 4: Issue 3 - Policy 1: Locational Priorities).

TRANSPORT INTEGRATION (Policy 2 Part C) Smiths Gore for Mansfield Estates (442870) PLAN550 and CTC Right to Ride Network (450103) PLAN838 TAYplan consider that Policy 2 (Part C) adequately covers TAYplan’s rural and urban area with adequate reference to cycling and modal shift. To introduce such a change to this policy would result in unnecessary detail.

WASTE MANAGEMENT (Policy 2 Part D)

Lynne Palmer (443979) PLAN160 The policy is flexible to include new technologies as they advance over the next 20 years.

102 TAYPLAN STRATEGIC DEVELOPMENT PLAN RESOURCE EFFICIENCY AND LOW/ZERO CARBON GENERATION (Policy 2 Part E) a) Resource Efficiency and Low/Zero Carbon Generation Homes for Scotland (442882), Scottish Property Federation (444087), Stewart Milne Homes (539251), Smiths Gore for Mansfield Estates (442870) PLAN551, Emac Planning (for L Porter (548383), James Keiller Estates Ltd (445203), J G Lang & Son (445206), M Batchelor (K) (548301) and Mr R Watson (445205)), Emac Planning (for A & J Stephen (445201), A & J Stephen Ltd/Bett Homes Ltd (548522), Bett Homes Ltd (548523), Angus Estates (445204) and Stewart Milne Homes (548524)), Barton Willmore for Scotia Homes (443109) and Dundas Estates and Development Co (548117) The Proposed Plan has a strong emphasis on helping achieve relevant targets in the Climate Change Act. This is required within the Planning etc (Scotland) Act (CL/Doc17). The policy requires ‘to meet’ as a minimum. Some developers may well wish ‘to exceed’ and the policy accommodates this.

The policy is flexible to at least align with building control regulations. Paragraph 182 of Scottish Planning Policy (2010) (006/SL/Doc45) specifically states that ‘The current target is for 50% of Scotland’s electricity to be generated from renewable sources by 2020 and 11% of heat demand to be met from renewable sources. These targets are not a cap.’ This statement reinforces the flexibility required in this policy, particularly given the 20 year lifespan of the Strategic Development Plan.

The phrase ‘Scottish Government’s standards’ as a benchmark and not stating a specific percentage is used in Policy 2 (Part E) as these standards may change within the Strategic Development Plan’s lifespan.

TAYplan does not consider it necessary to outline how such targets could be achieved due to the vast number of possible solutions. The Strategic Development Plan must consider these standards as these are a legitimate and important component and consideration for any development of firstly reducing resource demand and secondly switching its source to low/zero carbon. Failure to consider this element of place quality would represent a major deficit in any policy framework, particularly one which aims to support the delivery of targets to reduce carbon emissions in the Climate Change (Scotland) Act 2009 (CL/Doc13) through a variety of measures.

TAYplan considers that the policy seeks to align with national standards in considering the current economic climate. Such changes to this policy would run contrary to Planning Authorities being required/encouraged by the Scottish Government to assist in meeting Climate Change targets. The Scottish Environmental Protection Agency (442031) supports this section of Policy 2 (Part E). b) Large Scale Renewable Technologies Forth Ports PLC (329236) The policy is encouraging an increase in such technology across the TAYplan area. The policy is focused on all scales of development, such a change is not considered necessary.

ARRANGEMENT, LAYOUT, DESIGN, DENSITY AND MIX OF DEVELOPMENT (Policy 2 Part F) a) Green Infrastructure Scottish Natural Heritage (344848) The wording accompanying the ‘Integrate Networks’ part of the policy uses the word ‘enhance’ which refers both to the scale and quality of green infrastructure. Additionally, 103 TAYPLAN STRATEGIC DEVELOPMENT PLAN Policy 2 (Part Aiv) also states ‘enhance existing green infrastructure’. b) Scottish Government Policy

CTC Right to Ride Network (450103) PLAN839 The policy takes account of all relevant legislation and statutory policy and listing further is not conducive of the production of a concise, strategically focused and land-use policy document. This modification would prevent the Proposed Plan from being a short, concise and visionary Strategic Development Plan (Planning Circular 1/2009: Development Planning, Page 4, Paragraph 14) (006/SL/Doc42).

SUPPORTING TEXT, POLICY AND GENERAL a) Place Quality

Dr Peter Symon (548525) Consideration of the orientation and aspect of dwellings is included within the reference to ‘design and layout’ in the 4th paragraph of page 10’s supporting text.

Penny Uprichard (344887) The Proposed Action Programme (October 2011) (006/SL/Doc46) specifically states the action: ‘Delivering sustainable communities through leadership’ (page 41) which is the approach that will be carried forward by TAYplan in delivering the aims of the Strategic Development Plan. Local Development Plans require through legislation (Circular 1/2009) (CL/Doc29) to be consistent with the Strategic Development Plan. Prof Charles McKean (545597) and Lynne Palmer (443979) PLAN161 The focus of place quality is to improve the overall quality across the TAYplan area. The specifics of the Bridgend area of Perth is a Local Development Plan issue. b) Graphics

Halliday Fraser Munro for Barratt Homes (548389), NHS Tayside (547710), Lynne Palmer (443979) PLAN292, Royal Burgh of St. Andrews Community Council (453889) and Halliday Fraser Munro for Barratt Homes (548389) The graphics are important in illustrating the desired approach, key principles, objectives and strategy of TAYplan to shaping better quality places. TAYplan Topic paper 4: Place Shaping (June 2011) (CL/Doc33) provides further detail on how the diagrams provide a basis for TAYplan’s constituent authorities to implement this policy. They provide further detail on how these principles could and should be developed at a local authority, settlement and site specific scale and therefore no changes are commended by TAYplan. The footnote on page 10 specifically refers to Strategic Development Frameworks role in consulting local communities.

The reference to Tornagrain is for illustrative purposes only. Where the diagrams are based is irrelevant. The fundamental point of this Architecture and Design Scotland national diagram being included is to assist in explaining what a Strategic Development Framework is to make such a change would have a major impact on the style of the Plan, a style widely welcomed in moving to a new style of Strategic Development Plans.

In supporting the whole of Policy 2, Architecture and Design Scotland (349314) stated in their response that ‘This Plan recognises that different measures to deliver quality, being applied at different scales, in the different spatial contexts of TAYplan, contribute individually and collectively to the delivery of this Plan’s vision’. TAYplan Topic Paper 4: Place Shaping (June 2011) (Page 13, paragraph 5.14) (006/SL/Doc48) states that the Plan should: ‘set out 104 TAYPLAN STRATEGIC DEVELOPMENT PLAN requirements to ensure that the arrangement, layout, design, density and mix of development and its connections are the result of understanding, incorporating and enhancing present natural and historic assets, the multiple roles of infrastructure and networks and local design context, and meet the requirements of Scottish Government’s Designing Places (2008) and Designing Streets (2010)’ (CL/Doc 26 and 27). This is encapsulated through these diagrams.

The diagrams provide a basis for TAYplan’s constituent authorities to implement this policy. They provide further detail on how these principles could and should be developed at a local authority, settlement and site specific scale. No changes have been sought to the graphics by the Scottish Government or any key agency. These graphics have been developed with the key agencies. It does represent a new style of policy. It is innovative, clear, concise and consistent with Scottish Government Policy. To change these graphics would have a major impact on the style of the Plan, and how it has used graphics rather than all text, to express key statements/processes. This point is an example of how a Strategic Development Plan differs from old style Structure Plans and has a clear focus on setting out how places should change. c) Economic Viability Rossco Properties (442290) A Strategic Development Framework would take account of an economic and viability framework. This, in part, is recognised in the supporting text of Policy 2.

RESPONSE TO REPRESENTATIONS IN SUPPORTING AS WRITTEN TAYplan welcomes the support for these issues.

CONCLUSION

TAYplan considers that all of the issues raised do not warrant any change to the Proposed Strategic Development Plan (June, 2011) and propose that the elements dealt with in this Schedule 4 Summary of Unresolved Issues remain as written and unchanged. Some of the changes being sought by respondents are considered at odds with the emphasis being place by the Scottish Government on a move to more concise, visionary Strategic Plans, utilising graphics to illustrate points and aid interpretation. These graphics are the output of close partnership working with a number of Key Agencies.

Quality of place is central to the Proposed Plan vision. To change this Policy could have fundamental implications for delivering the Scottish Government’s objective of improving the quality of our places.

Reporter’s conclusions:

Resilience 1. Representations seek greater detail in Part A i. of the policy by listing flood-prone areas and showing them on a map, and by setting out exceptions for essential infrastructure and for other types of development where location in vulnerable areas cannot be avoided. More detail on flood risk is available on the maps published by the Scottish Environment Protection Agency (SEPA), and I do not consider that this level of detail is appropriate for inclusion in a strategic plan of this nature. Flood risk has, however, been taken into account in shaping the plan. The authority, working with SEPA, has produced a Strategic Flood Risk Assessment which has informed both the locational elements and the general policies of the proposed plan. Policy 2A is consistent with guidance in the Scottish Planning Policy (SPP) where the Risk Framework (paragraph 204), while indicating a general presumption against

105 TAYPLAN STRATEGIC DEVELOPMENT PLAN new development in areas of medium to high flood risk, recognises that exceptions may arise if a location is essential for operational reasons, including transport or some utilities infrastructure, and an alternative lower risk location is not achievable. The detailed consideration of where such development is appropriate is a matter for local development plans.

2. Suggested changes to Part A ii. include the addition of references to flood routing and to the inclusion of sustainable drainage systems in green networks (as proposed by the Forestry Commission in its representations nominally relating to Policy 3, Issue 11, but actually concerned with Policy 2 Part A ii). The policy, however, does not preclude either of these. Flood routing is a means of dealing with, rather than reducing, surface runoff; while green networks are covered in Parts A iv. and F of the policy. Whether any particular green network should include sustainable drainage systems is a matter for the local development plan. A suggested change to Part A iv. is to replace ‘green infrastructure and spaces’ with ‘open spaces’, in the interests of clarity. However, I regard the meaning of the existing wording as being clear enough. I do not therefore consider there is a need to change Part A of Policy 2.

Community infrastructure 3. Representations suggest adding in Part B a reference to ‘community facilities’ after ‘new infrastructure’, on the grounds that development in use classes 10 and 11 contributes to sustainable communities and should be recognised. However, I consider the term ‘community infrastructure’ is wide enough to include such development. A further suggestion is to add wording to encourage the provision of new homes in suitable, sustainable locations in settlements outwith the major cities. The location of new housing is, however, dealt with elsewhere in TAYplan, including Policy 1 which recognises the role of settlements other than Dundee and Perth in accommodating development. I do not therefore consider there is a need to change Part B.

Transport integration 4. Representations on behalf of Mansfield Estates seek the addition to Part C of references to support for rural areas and to realism about the likely availability of alternatives to car access, and point out the relevant guidance in SPP. Rural development is, however, covered in Policy 1, while there is nothing in Section C of Policy 2 which appears to me to assume an unrealistic reliance on rural public transport. The CTC Right to Ride Network seeks changes to the text to emphasise the need to reduce car travel and to promote a walking and cycling environment. Again, SPP (paragraphs 165, 167 and 169) is cited in support. However, I consider that the existing text promotes walking and cycling in sufficient detail for a strategic plan, and is compatible with the SPP guidance. I therefore do not see any need to change Part C.

Waste management 5. Lynne Palmer suggests inserting in Part D after the word ‘solutions’, ‘including recycling’, and points out that not all councils provide services for recycling all household materials. However, the existing wording covers the full range of waste management solutions and allows flexibility to include new technologies, and I do not consider there is any need to make this section more specific.

Resource efficiency and low/zero carbon generation 6. A number of representations seek changes to the wording of Part E. The main points are: • It is not always practical or appropriate to incorporate low/zero carbon energy generation technology, particularly in smaller developments • Better gains in energy efficiency and carbon reduction can be obtained by focusing on

106 TAYPLAN STRATEGIC DEVELOPMENT PLAN orientation, design, materials and construction • The policy should include renewable or low-carbon energy production on a larger scale, which is more efficient and provides better value for money than micro- generation in individual developments • While meeting the Scottish Government’s standards is accepted, seeking to exceed them is likely to be costly and the value of this is questioned.

7. The authority responds that the policy is flexible to accommodate future changes in Scottish Government targets, and does not consider it necessary to outline how such targets could be achieved due to the vast number of possible solutions. However, SPP paragraph 39 specifically refers to a need to encourage energy efficiency through the orientation and design of buildings and choice of materials, as well as the use of low and zero carbon generating technologies. Such measures have the potential to make a major contribution to reducing energy needs, and I consider they are sufficiently important to warrant specific mention in this section. The result would be to place greater emphasis on energy-efficient design and materials, while retaining a reference to low/zero carbon energy generation technologies.

8. The authority suggests that some developers may wish to exceed the Scottish Government’s standards. While I accept that, the inclusion of the words ‘or exceed’ in the policy could be taken as an invitation to local development plans to impose higher than national standards, and this could adversely affect the economics of development in parts of the TAYplan region. I consider that the choice of whether to go beyond national standards in any particular development should be left to developers, and the words ‘or exceed’ should be removed from Part E.

9. While I accept that large-scale electricity generation from renewable sources will usually be more efficient than small-scale, there is a role for micro-generation and I support its inclusion in the policy. The proposed plan includes provision elsewhere for larger generation schemes, particularly in Policy 6.

Arrangement, layout, design, density and mix of development

10. Scottish Natural Heritage (SNH) seeks the addition in the introductory paragraph of Part F after ‘local design context’ of the words, ‘and provision of additional green infrastructure to deliver these roles’. SNH suggests this would be consistent with the statement in support of Policy 8 (fourth paragraph on page 22) that quality is built into design by the provision of green spaces, and that this is a requirement of other policies in the plan. However, while Policy 2 requires design to incorporate and enhance present assets, it does not refer to the creation of new green infrastructure.

11. The authority’s response is that the word ‘enhance’, which is also used in the ‘Integrate Networks’ part of the policy and in Part A iv, refers both to the scale and quality of green infrastructure. However, in my view it does not obviously extend to the creation of new green infrastructure where none at present exists. I consider this a significant omission from the policy, and recommend additional wording to take account of SNH’s point. Given the complex grammatical structure of the paragraph, however, it would be clearer if the additional words were placed at the end (‘, and provide additional green infrastructure where necessary’).

12. The CTC Right to Ride Network seeks the addition at the end of the introductory paragraph of Part F of references to the requirements of Transport Scotland, the Disability Discrimination Act and the Good Practice Guide for Roads. However, I agree with the

107 TAYPLAN STRATEGIC DEVELOPMENT PLAN authority that extending the list of requirements to be complied with is not necessary and would not be consistent with the concise, strategic nature of the plan.

13. The Royal Burgh of St. Andrews Community Council seeks changes to the text under the headings ‘Integrate Networks’ and ‘Work with the grain of the place’. In the former, the proposed change is to add ‘paths alongside’ before ‘water networks’. In the latter, it would recast the words after ‘form of development’, on the grounds that the meaning of the existing text is unclear. I appreciate that it would be the paths rather than the channels that would accommodate walking and cycling along water networks, though a similar point could be made in relation to green space (where cycling on paths would generally be preferable to cycling on grass). I think the meaning of the existing text is clear enough. Similarly, while the latter part of the ‘Work with the grain of the place’ section does not appear to me to be a model of clarity, the general drift of its meaning is discernible. I do not therefore consider that any amendment to these sections is needed.

Supporting text, policy and general

14. Dr Peter Symon seeks specific reference to orientation and aspect of dwellings in the paragraph on page 10 about good quality development. However, I consider that these are covered by the existing text which refers to location, design and layout. I have recognised the particular contribution of orientation to energy saving in my proposed modification of Part E of Policy 2

Reporter for paragraph 15 only: Scott Ferrie

15. Professor Charles McKean seeks the insertion of additional text in Policy 2 Part F, which would require procurement patterns and policy standards to be raised to at least those recommended by Architecture and Design Scotland. I am satisfied that Part F (which already references Designing Places and Designing Streets), read in the context of Policy 2 as a whole, appropriately and adequately reflects the Scottish Government ambition of providing for quality places.

16. Representations seek various changes to the graphics on pages 10 and 11, including their complete removal from both pages on the grounds that they provide detailed design guidance not relevant to strategic planning and bear no specific relationship to the overall strategy of the TAYplan area. The authority defends their inclusion as being important in illustrating the desired approach and key principles, and points to the support of Architecture and Design Scotland for Policy 2 as a whole. While I agree that the graphics are not specifically related to places within the TAYplan area, I consider that they are helpful in illustrating general principles, as well as providing colour and visual interest. I therefore support their retention.

17. NHS Tayside comments, in relation to the diagram in the centre of page 10, that the emphasis should reflect that local planning needs to involve local people. However, no specific changes are suggested, and the process of preparing local development plans already provides extensive opportunities for the involvement of local people.

18. As regards representations that Policy 2 needs to take full account of economic and viability issues of development proposals, the authority responds that this is recognised in the supporting text, and that strategic development frameworks would take account of economic viability. I do not consider that there is any need to change the policy or supporting text.

108 TAYPLAN STRATEGIC DEVELOPMENT PLAN Reporter’s recommendations:

Modify page 11 of the proposed plan as follows:

Replace the existing Part E with the following:

“E. ensure that high resource efficiency is incorporated within development through the orientation and design of buildings, the choice of materials and the use of low and zero carbon energy generating technologies to reduce carbon emissions and energy consumption to meet the Scottish Government’s standards.”

At the end of the introductory paragraph of Part F, after “Designing Streets” add the following text:

“, and provide additional green infrastructure where necessary”.

109 TAYPLAN STRATEGIC DEVELOPMENT PLAN

Issue 6 Policy 3: Managing TAYplan’s Assets – General & Text

Page 12: Managing TAYplan’s Assets Development plan Reporter: Supporting Text reference: Karen Heywood Page 13: Policy 3 (Whole Policy) Body or person(s) submitting a representation raising the issue (including reference number):

Seeking a change ID Person/Organisation Representation Number Reference 548169 DPP LLP for Shell UK Limited PLAN444 445201 Emac Planning for A & J Stephen Limited PLAN698 548522 Emac Planning for A & J Stephen Limited/Bett PLAN743 Homes Limited 445204 Emac Planning for Angus Estates Limited PLAN612 548523 Emac Planning for Bett Homes Limited PLAN766 445206 Emac Planning for J G Lang & Son PLAN537 445203 Emac Planning for James Keiller Estates Limited PLAN716 548383 Emac Planning for L Porter PLAN566 548301 Emac Planning for M Batchelor (K) PLAN520 548301 Emac Planning for M Batchelor (K) PLAN521 445205 Emac Planning for Mr R Watson PLAN511 548524 Emac Planning for Stewart Milne Homes PLAN782 329236 Forth Ports PLC PLAN678 539251 Stewart Milne Homes PLAN325

Support as written ID Person/Organisation Representation Number Reference 419429 Auchterarder & District Community Council PLAN82 337727 Colliers International for Gleneagles Hotel PLAN55 445299 Inchture Area Community Council PLAN802 442806 Loch Lomond and The Trossachs National Park PLAN103 Authority 547710 NHS Tayside PLAN299 344939 Scottish Enterprise PLAN425 Scottish Wildlife Trust Angus & Dundee Members 548745 Centre PLAN807 Scottish Wildlife Trust Angus & Dundee Members 548745 Centre PLAN805 441235 Tactran Regional Transport Partnership PLAN122 Provision of the development plan Relates to general points raised on Page 12 (Supporting Text) and to which the issue Page 13 (Policy 3). relates: Planning authority’s summary of the representation(s):

SUMMARY OF REPRESENTATIONS SEEKING A CHANGE Emac Planning (for A & J Stephen Limited (445201); A & J Stephen Limited/Bett Homes Limited (548522); Angus Estates Limited (445204); Bett Homes Limited 110 TAYPLAN STRATEGIC DEVELOPMENT PLAN (548523); James Keiller Estates Limited (445203); L Porter (548383); M Batchelor (K) (548301 – PLAN520); M Batchelor (K) (548301 – PLAN521); Mr R Watson (445205); J G Lang & Son (445206); Stewart Milne Homes (548524)) and Stewart Milne Homes (539251)

Six of the above respondents Emac Planning (for James Keiller Estates Limited (445203); M Batchelor (K) (548301 – PLAN520); M Batchelor (K) (548301 – PLAN521); Mr R Watson (445205) and J G Lang & Son (445206)) have requested a modification to the second sentence of the second paragraph on Page 12 because it is felt the Action Programme does not identify how the Strategic Development Plan Authority will ensure deliverability of development infrastructure. The identification of this together with a lead role being taken by the Strategic Development Plan Authority is essential to the effective delivery of infrastructure within the Plan period, through public and private partnership where appropriate.

Five of the above respondents Emac Planning (for A & J Stephen Limited (445201); A & J Stephen Limited/Bett Homes Limited (548522); Angus Estates Limited (445204); Bett Homes Limited (548523) and Stewart Milne Homes (548524)) have requested a modification to the final sentence of the fourth paragraph on Page 12 because it is felt the Action Programme does not identify how the Strategic Development Plan Authority intends to deliver development infrastructure. This is vital to ensure that development is delivered within the plan period and that a programme is in place which can be implemented and monitored. The insertion of the suggested sentence would reflect the importance of the Strategic Development Plan Authority’s position in being able to co-ordinate deliverability in- association with the private sector where appropriate.

Forth Ports PLC (329236) have requested a modification to paragraph three on Page 12 as they consider that ports are occupied by cargo handling and manufacturing/industrial operations. The term port-related could therefore be interpreted in a restrictive manner, and it is important to promote economic growth opportunities in industry/manufacturing within Ports.

The respondent has also requested a modification to paragraph seven on Page 12 to note that managed realignment and habitat creation should be considered in the context of the overall economic development of the region, to minimise conflict between important species and habitats and economic growth areas. The respondent considers that there is potential to increase risk to economic development if habitat creation is encouraged in proximity to core development areas.

DPP LLP for Shell UK Limited (548169) have requested the inclusion of an appropriate strategic policy which recognises the importance of the existing oil and gas pipelines which run through the TAYplan area and that all new development is in accordance with the Health and Safety Executive’s Planning Advice for Developments near Hazardous Installations (PADHI) Guidelines.

SUMMARY OF REPRESENTATIONS SUPPORTING AS WRITTEN Auchterarder & District Community Council (419429); Loch Lomond and The Trossachs National Park Authority (442806); Scottish Wildlife Trust Angus & Dundee Members Centre (548745 - PLAN805); and Tactran (441235) have all expressed support for Policy 3 with Colliers International for Gleneagles Hotel (337727); NHS Tayside (547710) and Scottish Enterprise (344939) expressing support for sustainable economic growth/development.

111 TAYPLAN STRATEGIC DEVELOPMENT PLAN Inchture Area Community Council (445299) and Scottish Wildlife Trust Angus & Dundee Members Centre (548745) have indicated their support for the intention of TAYplan to respect regional distinctiveness and scenic value, maintain the integrity of NATURA 2000 sites and to safeguard habitats, sensitive green spaces and wetlands.

Modifications sought by those submitting representations:

NOTE TO REPORTER: The text in italics in this section has been lifted directly from each individual/organisation’s representation with minor typographical errors corrected.

Emac Planning (for A & J Stephen Limited (445201); A & J Stephen Limited/Bett Homes Limited (548522); Angus Estates Limited (445204) and Bett Homes Limited (548523)) • Page 12 states "It also requires the public and private sectors to work jointly to deliver infrastructure". It is considered that this sentence should be replaced by: "The SDPA will lead and co-ordinate the delivery of an infrastructure programme, through the proposed Action Programme and will encourage private and public partnership where appropriate."

Emac Planning (for J G Lang & Son (445206); James Keiller Estates Limited (445203); L Porter (548383); M Batchelor (K) (548301 – PLAN520); M Batchelor (K) (548301 – PLAN521); Mr R Watson (445205) and Stewart Milne Homes (548524)) • Page 12 states that "It also requires the public and private sectors to work jointly to deliver infrastructure". It is considered that this sentence should be replaced by: "The SDA will encourage private and public partnership where appropriate to deliver infrastructure. The SDA will take a proactive approach and through the Action Programme lead and co-ordinate the delivery of an infrastructure programme."

Forth Ports PLC (329236) • Paragraph 3 on page 12 should be amended, to add industrial as well as port-related uses. • Paragraph 7 on page 12 should be altered to note that managed realignment and habitat creation should be considered in the context of the overall economic development of the region, to minimise conflict between important species and habitats and economic growth areas.

DPP LLP for Shell UK Limited (548169) • Need for Appropriate Pipeline Policy Inclusion of an appropriate strategic policy which recognises the importance of the existing oil and gas pipelines which run through the TAYPlan area and that all new development is in accordance with the HSE PADHI Guidelines.

Summary of responses (including reasons) by planning authority:

RESPONSES TO REPRESENTATIONS SEEKING A CHANGE

Emac Planning (for A & J Stephen Limited (445201); A & J Stephen Limited / Bett Homes Limited (548522); Angus Estates Limited (445204); Bett Homes Limited (548523); J G Lang & Son (445206); James Keiller Estates Limited (445203); L Porter (548383); M Batchelor (K) (548301 – PLAN520); M Batchelor (K) (548301 – PLAN521); Mr R Watson (445205); Stewart Milne Homes (548524)) and Stewart Milne Homes (539251) This is an issue relevant to the Action Programme rather than the Proposed itself. The Action Programme (CL/Doc37) is there to detail how the Strategic Development Plan 112 TAYPLAN STRATEGIC DEVELOPMENT PLAN will be implemented. Such a change to the Strategic Development Plan text could restrict how the Action Programme is taken forward. Details of a delivery mechanism could be added to the Action Programme it is monitored and updated, and when such information is available. It is considered that the information provided in the deliverability/timing and lead partners/person responsible columns provide the information available to encourage joint working relationships at this stage in the Plan process.

This issue is dealt with in more detail in Schedule 4 titled: Issue number 7: Policy 8: Delivering the Strategic Development Plan.

Forth Ports PLC (329236) It is considered that there is no requirement to modify the Proposed Plan to include the term ‘industrial’ as well as port-related uses. TAYplan considers that Dundee and Montrose Ports are different in terms of their scale and function and therefore a wider ‘industrial’ use would be inappropriate. TAYplan’s Topic Paper 2 ‘Growth Strategy’ (Page 19, Paragraph 7.16) (CL/Doc31) confirms the flexibility which currently exists and which may apply to other harbours if appropriate. This includes the aim to support freight, economic growth – specifically of the offshore renewable energy industry – and tourism.

In relation to the comment provided that the Proposed Plan should be modified in respect of the managed realignment and habitat creation etc., Policy 3 and the supporting text on Page 12 is consistent with national legislation on habitats (e.g. Nature Conservation (Scotland) Act 2004) (CL/Doc12). Given the ports are adjacent to Natura 2000 sites, it is considered such a change to the Proposed Plan could be inconsistent with national policy.

Although there is no specific reference to habitat creation within the Proposed Plan, Scottish Planning Policy (Page 26, Paragraph 126) (CL/Doc2) indicates that ‘Planning authorities should take a broader approach to landscape and natural heritage than just conserving designated or protected sites and species, taking into account the ecosystems and natural processes in their area. A strategic approach to natural heritage in which wildlife sites and corridors, landscape features, watercourses, and areas of open space are linked together in integrated habitat networks can make an important contribution to the maintenance and enhancement of biodiversity and to allowing ecosystems and natural processes to adapt and respond to changes in the climate. Planning authorities should seek to prevent further fragmentation or isolation of habitats and identify opportunities to restore links which have been broken. Where possible, planning authorities should seek benefits for species and habitats from new development including the restoration of degraded habitats.’

The issue of habitat creation is a matter of detail for Local Development Plans or through further supplementary planning guidance to determine (including masterplans and/or development briefs) prior to implementing specific development proposals. In addition, habitat creation may also come through mitigation for planning applications. The text is consistent with Scottish Planning Policy (CL/Doc2). and other legislative requirements. Such a change to the text would be inconsistent. Neither Scottish Government nor Scottish Natural Heritage have sought changes to this text.

DPP LLP for Shell UK Limited (548169) It is considered that there is no requirement to modify the Proposed Plan to include a strategic policy which recognises the importance of the existing oil and gas pipelines which run through the TAYplan area. The Proposed Plan is compliant with Scottish Planning Policy (CL/Doc2) and the Strategic Development Areas have been assessed against such infrastructure. It is a requirement for Local Development Plan to take account of major hazardous installations and the Proposed Plan does not require to repeat this. If it did so, and be repetitive in other policy areas, a short, concise and visionary Strategic Development Plan would not be possible (Planning Circular 1/2009: 113 TAYPLAN STRATEGIC DEVELOPMENT PLAN Development Planning, Page 4, Paragraph 14) (CL/Doc29). In addition, Policy 6: Energy and Waste Resource Management, Part C (Page 19) considers the effects of oil and gas pipeline exclusion zones. Issue 24 deals with this in more detail.

RESPONSE TO REPRESENTATIONS SUPPORTING AS WRITTEN

TAYplan welcomes the support for these issues.

CONCLUSION

This Policy is consistent with Scottish Planning Policy. TAYplan considers that the issues raised does not warrant any change to the Proposed Strategic Development Plan (June, 2011) and propose that the elements dealt with in this Schedule 4 Summary of Unresolved Issues remain as written and unchanged.

Reporter’s conclusions:

1. In relation to the representations made by Emac Planning and others, I agree with the authority that this issue is relevant to the Action Programme rather than the proposed strategic development plan.

2. As for Forth Ports’ concerns, I agree that general manufacturing uses which do not require to use port facilities are often found at ports. However, I also consider that ports are valuable facilities and it is important that they remain available to those uses which would benefit from them. Retaining the term “port-related uses” in the supporting text on page 12 need not necessarily prevent more general industrial uses from locating at ports through the development management process, if planning authorities decided they were otherwise acceptable. (See also Issue 10).

3. In addition, I agree with the authority that, as the ports are adjacent to Natura sites, the change suggested to paragraph 7 on page 12 could be inconsistent with national policy. Furthermore, habitat creation is a detailed matter for the local development plan.

4. With reference to the concerns expressed by Shell, I note that, despite any explicit reference to oil and gas pipelines in the supporting text to Policy 6: Energy and Waste/Resource Management Infrastructure, oil and gas pipelines are an example of energy infrastructure. Part C of Policy 6 states that local development plans and development proposals should ensure that all areas of search, allocated sites, routes and decisions for energy and waste/resource management infrastructure have been justified on the basis of a number of considerations. One of these considerations is the specific land take requirements associated with the infrastructure technology and associated statutory exclusion zones. I consider, therefore, that these concerns are a matter for the local development plan and the development management process.

Reporter’s recommendations:

No modifications.

114 TAYPLAN STRATEGIC DEVELOPMENT PLAN

Issue 7 Managing TAYplan’s Assets – Employment Land

Page 12: Managing TAYplan’s Assets Development plan Reporter: Supporting Text reference: Karen Heywood Page 13: Policy 3 Employment Land Body or person(s) submitting a representation raising the issue (including reference number):

Seeking a change

ID Person/Organisation Representation Number Reference 445201 Emac Planning for A & J Stephen Limited PLAN696 445201 Emac Planning for A & J Stephen Limited PLAN697 548522 Emac Planning for A & J Stephen Limited / Bett PLAN740 Homes Limited 548522 Emac Planning for A & J Stephen Limited / Bett PLAN741 Homes Limited 445204 Emac Planning for Angus Estates Limited PLAN605 445204 Emac Planning for Angus Estates Limited PLAN609 548523 Emac Planning for Bett Homes Limited PLAN764 548523 Emac Planning for Bett Homes Limited PLAN765 445203 Emac Planning for James Keiller Estates Limited PLAN717 548524 Emac Planning for Stewart Milne Homes PLAN780 548524 Emac Planning for Stewart Milne Homes PLAN781 343111 Montagu Evans LLP for Wallace Land Investment PLAN330 Management 453889 Royal Burgh of St. Andrews Community Council PLAN921 444087 Scottish Property Federation PLAN248

Support as written

ID Person/Organisation Representation Number Reference 337727 Colliers International for Gleneagles Hotel PLAN56 Savills for John Dewar Lamberkin Trust and Needhill 547927 LLP PLAN651 Provision of the development plan Employment Land – this Schedule 4 relates to the three bullet points to which the issue under the Employment Land section of Policy 3. relates: Planning authority’s summary of the representation(s):

SUMMARY OF REPRESENTATIONS SEEKING A CHANGE

Royal Burgh of St. Andrews Community Council (453889) has requested two separate modifications to the text within Policy 3. Firstly, the respondent is seeking a modification to the first bullet point as it is considered that the ‘five years supply’ of employment land appears to be undefined and does not appear to have a basis within Scottish Planning Policy. The respondent also considers that the quantities of land designated for employment purposes should not be grossly disproportionate to historical demand.

115 TAYPLAN STRATEGIC DEVELOPMENT PLAN Secondly, the respondent is seeking a modification to the second bullet point to avoid housing land being wasted by being allocated as a Class 4 Use and subsequently lying undeveloped.

Scottish Property Federation (444087) agrees with the proposals to support economic growth in the region and the identification and safeguarding of a five year supply of employment land. Notwithstanding this, the respondent as well as Emac Planning (for A & J Stephen Limited (445201 – PLAN696), A & J Stephen Limited/Bett Homes Limited (548522 – PLAN740), Angus Estates Limited (445204 – PLAN605), Bett Homes Limited (548523 – PLAN764), James Keiller Estates Limited (445203 – PLAN717) and Stewart Milne Homes (548524 – PLAN780)) have suggested that a seven year supply of employment land should be identified within the cities as it is considered that a healthier supply of employment land, particularly within the cities will facilitate the requirement in Scottish Planning Policy that the five year supply should be serviced and marketable. In addition, allocations should be identified by a site selection process with appropriate criteria added to aid the transparency of the process, whilst unrealistic allocations should be avoided. Allocations should only be made in areas where the market wants to invest.

Emac Planning (for A & J Stephen Limited (445201 – PLAN697), A & J Stephen Limited/Bett Homes Limited (548522 – PLAN741), Angus Estates Limited (445204 – PLAN609), Bett Homes Limited (548523 – PLAN765), James Keiller Estates Limited (445203 – PLAN717) and Stewart Milne Homes (548524 – PLAN781)) have requested that an additional, fourth, bullet point is included under the employment land section of Policy 3. It is considered that new employment land is required across the region, not just within principal settlements to ensure sustainable mixed-use communities and to further support economic diversification. The respondents also consider that Local Development Plans are in the best position to allocate employment land in areas of need and where there is a demonstrable market-led interest.

Montagu Evans LLP for Wallace Land Investment Management (343111) note that Scottish Planning Policy states that Strategic Development Plans should identify an appropriate range of business locations, including mixed developments, business parks, science parks, medium and large industrial sites and high amenity business locations. It is therefore considered that the importance of maintaining support for sites such as ‘T in the Park’ should be highlighted in the Proposed Strategic Development Plan as these sites provide an opportunity to improve and expand economic development locally. This is particularly relevant given Kinross is identified as a Tier 2 Settlement where an element of growth is expected across the TAYplan area and given the location of Junction 6 of the M90 which could contribute significantly to economic development opportunity for a variety of uses.

SUMMARY OF REPRESENTATIONS SUPPORTING AS WRITTEN

Colliers International for Gleneagles Hotel (337727) support the third bullet point under the Employment Land section of Policy 3, in particular the respondent is encouraged to note TAYplan’s emphasis on employment land also relates to tourism as well as industrial land uses.

Savills for John Dewar Lamberkin Trust and Needhill LLP (547927) note that there is a shortage of prestige business land in the Perth area, however the respondent supports Policy 3 as it recognises the need for at least five years supply of employment land whilst safeguarding Class 4 office type uses within principal settlements.

116 TAYPLAN STRATEGIC DEVELOPMENT PLAN Modifications sought by those submitting representations:

NOTE TO REPORTER: The text in italics in this section has been lifted directly from each

individual/organisation’s representation with minor typographical errors corrected.

Emac Planning (for A & J Stephen Limited (445201 – PLAN696); A & J Stephen Limited/Bett Homes Limited (548522 – PLAN740); Angus Estates Limited (445204 – PLAN605); Bett Homes Limited (548523 – PLAN764); James Keiller Estates Limited (445203); Stewart Milne Homes (548524 – PLAN780)); and Scottish Property Federation (444087) • On Employment Land, bullet 1, insert after "principal settlements" and “at least 7 years supply of employment land within the cities of Dundee and Perth".

Emac Planning (for A & J Stephen Limited (45201 – PLAN697); A & J Stephen Limited/Bett Homes Limited (548522 – PLAN741); Angus Estates Limited (445204 – PLAN609); Bett Homes Limited (548523 – PLAN765); James Keiller Estates Limited (445203); and Stewart Milne Homes (548524 – PLAN781)) • On Employment Land insert fourth bullet to state: "Identifying employment land outwith the principal settlements, as an integral approach, to achieving sustainable mixed use communities."

Montagu Evans LLP for Wallace Land Investment Management (343111) • Reflecting our earlier submissions to the Main Issues Report, the distinctions of the various centres across the area are noted. Each centre plays an important role in providing a range of services, which should be acknowledged within the plan. Economic development, and its sustained promotion is critical within the TAYplan area to maintain and support equitable growth. Our client owns land at Kinross including that which hosts, in part, 'T in the Park'. The festival is a significant attractor, supporting the local and wider TAYplan economy. The importance of tourism, culture and major events, such as 'T in the Park', is acknowledged in the plan and recognised within it as being one of a number of key sectors of the Scottish economy with the potential to grow disproportionately.

Royal Burgh of St. Andrews Community Council (453889) • Page 13, Policy 3, Employment Land Change "identifying and safeguarding at least 5 years supply of employment land within principal settlements" to "identifying and safeguarding an appropriate supply of employment land in the light of historical demand within principal settlements". • Page 13, Policy 3, Employment Land Change "safeguarding areas identified for class 4 office type uses in principal settlements" to "safeguarding areas identified for class 4 office type uses in principal settlements proportionate to historic demand".

Summary of responses (including reasons) by planning authority:

RESPONSES TO REPRESENTATIONS SEEKING A CHANGE

Emac Planning (for A & J Stephen Limited (445201 – PLAN696); A & J Stephen Limited/Bett Homes Limited (548522 – PLAN740); Angus Estates Limited (445204 – PLAN605); Bett Homes Limited (548523 – PLAN764); Stewart Milne Homes (548524 – PLAN780)); Royal Burgh of St. Andrews Community Council (453889) and Scottish Property Federation (444087) It is considered that there is no requirement to modify bullet point one as requested by the respondents. Policy 3 – Employment Land states that ‘at least 117 TAYPLAN STRATEGIC DEVELOPMENT PLAN 5 years supply of employment land’ should be identified and safeguarded which is consistent with the requirements set out in Scottish Planning Policy (Page 9, Paragraph 46) (CL/Doc2).. In addition to the compatibility with Scottish Planning Policy (CL/Doc2)., TAYplan consider that Policy 3 has enough in-built flexibility for individual Local Authorities through their Local Development Plans to identify and safeguard a longer supply of employment land if required.

Topic Paper 2: Growth Strategy (June 2011) (Page 12, Paragraph 5.18) (CL/Doc31). indicates that The Strategic Development Plan could have set out employment land figures to Local Authority level; however work has not been done to justify this and it has not been tested through the Main Issues Report (2010) (CL/Doc38). Employment land dynamics also differ strongly from housing land for example and within the four local authorities the supply of employment land is also variable. The purpose of Policy 3 (Employment Land) is to ensure consistency. An Employment Land Audit was undertaken at the Main Issues Stage (Monitoring Statement, Page 70, Paragraph 6.6) which meets the requirements set out in Scottish Planning Policy (Page 9, Paragraph 46) (CL/Doc2).

Emac Planning (for A & J Stephen Limited (45201 – PLAN697); A & J Stephen Limited/Bett Homes Limited (548522 – PLAN741); Angus Estates Limited (445204 – PLAN609); Bett Homes Limited (548523 – PLAN765) and Stewart Milne Homes (548524 – PLAN781)) It is considered that there is no requirement to add an additional bullet point as requested by the respondents. Although Policy 3 does not specifically mention the identification of employment land outwith the principal settlement, Policy 1: Location Priorities, Part A (Page 13) provides opportunity for Local Development Plans to provide employment uses outwith principal settlements where this can be accommodated and supported by the settlement and where it contributes to the objectives of the Strategic Development Plan whilst also meeting local needs or supporting the regeneration of the local economy. This modification would result in duplication within policies of the Proposed Strategic Development Plan and therefore a short, concise and visionary Strategic Development Plan would not be possible (Planning Circular 1/2009: Development Planning, Page 4, Paragraph 14) (CL/Doc29).

Montagu Evans LLP for Wallace Land Investment Management (343111) Although the importance of major tourism events such as ‘T in the Park’ is noted and recognised as playing a significant role in enhancing the economy of the area, the specific reference to major events is not considered to be of strategic significance and therefore does not warrant a modification of the Proposed Plan. Whilst ‘T in the Park’ is a permanent use of the land, many major events are often temporary uses of land and as such a change in the strategic employment land policy is neither necessary nor appropriate. The Main Issues Report (2010) (Page 26) (CL/Doc38) identified major sporting and cultural events such as ‘T in the Park’ continuing to be major draws for visitors around the globe, however no particular reference was required within the Proposed Strategic Development Plan.

Royal Burgh of St. Andrews Community Council (453889) The potential loss of employment land was considered to be a key issue which was discussed in the Main Issues Report (2010) (Page 27, Paragraph 5.8) (CL/Doc38). The Main Issues Report indicated that the cumulative loss of employment land to alternative land uses, particularly in rural parts of the region, could affect the provision of business premises and jobs.

Subsequently, TAYplan’s Topic Paper 2 ‘Growth Strategy’ (June 2011) (Page 11, Paragraph 5.20) (CL/Doc31)continues this further and states that safeguarding land including existing employment sites is important given the risk that alternative land uses on these or adjacent sites prevent or limit how businesses can use the land. This can, in some circumstances, deprive an area of a range of employment land for a variety of users, including the loss of Class 4 office type uses. Similarly some sites, particularly within principal settlements where 118 TAYPLAN STRATEGIC DEVELOPMENT PLAN there is a greater mix of land-uses could be lost directly to redevelopment for alternative uses. Although the Topic Paper indicates that the impacts of this later circumstance could be significant in rural communities as it could stifle future enterprise by depriving emerging businesses of premises, requiring them instead to acquire land, planning consent and then construct premises the same could also apply to principal settlements.

In addition, Scottish Planning Policy (Page 10, Paragraph 47) (CL/Doc2)also highlights that ‘development plans should support small business development and growth and promote opportunities for low impact industrial, business and service uses which can co-exist with housing and other sensitive uses without eroding amenity. The Proposed Plan provides a range and choice of marketable strategic employment land sites, in accordance with Scottish Planning Policy TAYplan consider that the safeguarding of areas identified for Class 4 office type uses in Policy 3 adequately supports business growth and development as required in Scottish Planning Policy (Page 9, Paragraph 46) (CL/Doc2). Accepting the proposed changes would undermine one of the Proposed Plan’s key objectives of “supporting” sustainable economic development (Proposed Strategic Development Plan, Page 6).

RESPONSE TO REPRESENTATIONS SUPPORTING AS WRITTEN

TAYplan welcomes the support for these issues.

CONCLUSION

Reporter’s conclusions:

1. Scottish Planning Policy states that planning authorities should ensure that there is a range and choice of marketable sites and locations for businesses allocated in development plans to meet anticipated requirements. Marketable land should meet business requirements and be serviceable within 5 years, amongst other things. This is not the same as saying there should be a 5 year supply of employment land, as is required by Policy 3.

2. Nevertheless, TAYplan Topic Paper 2: Growth Strategy requires local development plans to ensure that there should be at least a 5 year supply of employment land within the principal settlements. I consider this is a reasonable amount of employment land which should meet all foreseeable needs. Requiring local development plans to ensure “at least” a 5 year supply means that planning authorities will be able to provide more than the minimum amount if local circumstances merit it.

3. In relation to employment land outwith principal settlements, Policy 1 Part A states that local development plans may also provide for some development in settlements that are not principal settlements and in rural areas. Such development should be supported by the settlement, contribute to the objectives of TAYplan, meet specific local needs or support regeneration of the local economy. There is no need to repeat this in Policy 3.

4. I agree with the authority that the requirement for local development plans to safeguard areas identified for class 4 office type uses in principal settlements is consistent with Scottish Planning Policy. However, Scottish Planning Policy also points out that obsolete commercial and industrial property can act as a constraint on the economic growth of towns and cities.

119 TAYPLAN STRATEGIC DEVELOPMENT PLAN The policy states that authorities should adopt a proactive approach to encouraging the reuse of buildings and previously developed land in these circumstances. The addition suggested to Policy 3 is not necessary, as planning authorities will be well aware of the requirements of Scottish Planning Policy.

5. In relation to the suggestion that support for the T in the Park site should be highlighted in the plan, I consider that this issue is more appropriately dealt with in the local development plan.

Reporter’s recommendations:

No modifications.

120 TAYPLAN STRATEGIC DEVELOPMENT PLAN

Issue 8 Policy 3: Managing TAYplan’s Assets – Greenbelts

Reporter: Page 12: Managing TAYplan’s Assets Development plan Mike Cunliffe (and Supporting Text reference: Scott Ferrie where Page 13: Policy 3 Greenbelts stated) Body or person(s) submitting a representation raising the issue (including reference number):

Seeking a change

ID Person/Organisation Representation Number Reference 548889 Alaric Hopgood PLAN826 Andrew McCafferty for GD Strawson and J 548151 Farquharson PLAN449 Andrew McCafferty for GD Strawson and J 548151 Farquharson PLAN445 442149 Bidwells for Zurich Assurance Limited PLAN668 450613 Councillor Michael A Barnacle PLAN814 445201 Emac Planning for A & J Stephen Limited PLAN700 542815 Flora Selwyn PLAN78 445159 Geddes Consulting for Thomson Homes Limited PLAN886 543112 GS Brown Construction PLAN89 548948 Hargest Planning Limited PLAN857 442882 Homes for Scotland PLAN217 546838 Kinross-shire Civic Trust PLAN494 450207 Largo Area Community Council PLAN437 548414 Miss Lynn McGeorge PLAN610 548414 Miss Lynn McGeorge PLAN603 544315 Miss Marianne Baird PLAN113 548386 Miss Sarah Hunt PLAN545 545660 Mr Colin McAllister PLAN150 546652 Mr Howard Greenwell PLAN256 548413 Mr John Hendrie PLAN575 443846 Mr K C Fraser PLAN560 548486 Mr Ken Miles PLAN833 328142 Mr Mark Myles PLAN395 543388 Mrs Anne Tynte-Irvine PLAN93 545391 Mrs Jennifer Byrne PLAN139 348875 Mrs Jennifer Hopgood PLAN793 377831 Mrs Judith Harding PLAN499 377831 Mrs Judith Harding PLAN500 541352 Mrs Wendy Baylis PLAN556 344887 Penny Uprichard PLAN876 548708 Philip Anthony Hardie PLAN797 538105 PPCA Limited for Edinmore Properties Limited PLAN19 545597 Professor Charles McKean PLAN148 545572 Professor Karla Pollmann PLAN147 453889 Royal Burgh of St. Andrews Community Council PLAN921 442870 Smiths Gore for Mansfield Estates PLAN552

121 TAYPLAN STRATEGIC DEVELOPMENT PLAN 442870 Smiths Gore for Mansfield Estates PLAN541 547750 St. Andrews Preservation Trust PLAN849

Support as written ID Person/Organisation Representation Number Reference 450585 Methven & District Community Council PLAN866 Montgomery Forgan Associates for Headon 349140 Developments Limited PLAN611 Montgomery Forgan Associates for Morris Leslie 445161 Group PLAN657 527724 Mr David Dykes PLAN479 546153 Strathkinness Community Council PLAN189 Provision of the development plan Greenbelts – this Schedule 4 relates to the two bullet points under the to which the issue Greenbelts section of Policy 3. relates: Planning authority’s summary of the representation(s):

SUMMARY OF REPRESENTATIONS SEEKING A CHANGE

GENERAL

Geddes Consulting for Thomson Homes Limited (445159) have indicated that Policy 3 - green belts needs to accord with Scottish Planning Policy. The respondent indicates that the green belts around Perth and St. Andrews should provide clarity and certainty on where development will and will not take place. As required by Scottish Planning Policy, the Proposed Plan must set the principles for defining the green belt boundaries at Perth and St. Andrews to accommodate the future strategic requirement at settlements. These boundaries must be clearly identifiable using strong visual or physical landscape features and not be tightly drawn against the urban edge. The current green belt inner boundaries do not comply with this policy requirement and therefore intervention is necessary by the Strategic Development Plan Authority.

Mr John Hendrie (548413) has commented that the Proposed Plan alludes to preventing coalescence in respect of Perth and St. Andrews and has requested that this should refer to all other communities within the Plan.

Andrew McCafferty for GD Strawson and J Farquharson (548151 - PLAN449 and PLAN445) consider that the green belt boundaries are impossible to understand and also consider that the diagram illustrating "Perth Core Area" is unacceptable and cannot be understood.

Royal Burgh of St. Andrews Community Council (453889) are seeking two modifications to the green belt text within Policy 3. • Firstly, the respondent requests that ‘at both’ is replaced with ‘encircling’ at bullet point one in the interests of accuracy as it is not possible to continue to designate green belt boundaries that have not hitherto been designated. • Secondly, the respondent requests an additional modification at bullet point one by replacing the word ‘infrastructure’ with ‘proposals shown’ and delete ‘and Strategic Development Areas in Policy 4’ as Strategic Development Areas are shown on the Proposals Map and so do not require separate mention.

122 TAYPLAN STRATEGIC DEVELOPMENT PLAN PERTH PPCA Limited for Edinmore Properties Limited (538105) does not agree with the proposed green belt around Perth and considers it unnecessary, excessive and untenable and prevents sustainable growth with alternatives available through Scottish Planning Policy. In addition, the respondent has indicated that reasons for designation given in the Strategic Development Plan must comply with purposes set out in Scottish Planning Policy and that land must be tested against the purposes of green belt set out in Scottish Planning Policy before it is designated as such.

Emac Planning for A & J Stephen Limited (445201); Homes for Scotland (442882); and Smiths Gore for Mansfield Estates (442870 - PLAN552 and PLAN541) has requested a modification to bullet point two for the green belt text within Policy 3 in order to avoid misinterpretation of the policy, specifically to ensure the continued separation of Perth and Scone.

Homes for Scotland (442882) has also requested modifications to bullet point two for the green belt text within Policy 3, including: • The green belt consultation exercise was last undertaken in 2004. Given that the precise boundaries of the green belt will have a constraining effect on long term development potential, it is of considerable concern that the boundaries proposed are based on consultation last undertaken in 2004. There is no reference to any subsequent studies to assess the robustness of the green belt boundaries which would be provided. Green belt boundaries – which are intended to provide guidance over a 20 year period, should not be defined on the basis of studies which are out of date, or based on the premise of limiting development. The boundaries should make allowance for some development, and allow for opportunities that would be suitable adjacent to the green belt.

The requirements of Scottish Planning Policy should be followed when defining the inner and outer limits of the proposed Perth green belt.

Mr Mark Myles (328142) considers that the proposed extent of the Perth green belt is too vague and should be more clearly stated and shown with greater conviction on the diagrams within the Proposed Plan to include the area between Berthapark and Luncarty/Redgorton so as to properly guide the emerging Perth and Kinross Local Development Plan when it comes to defining the green belt boundaries.

Miss Lynn McGeorge (548414 - PLAN610 and PLAN603) although supportive of the approach proposed to protect and enhance the landscape qualities of Perth and Kinross, the respondent considers that many areas surrounding Perth, including Luncarty/Redgorton/Stanley/Stormontfield appear to have been excluded as being areas of beauty and worth protecting.

Smiths Gore for Mansfield Estates (442870 - PLAN552 and PLAN541) objects to the proposal for a green belt around Perth. The respondent firstly considers that it is not particularly necessary to provide a green belt as growth around Perth could be managed carefully through the Strategic Development Plan and Local Development Plan process, and there is unlikely to be any major unplanned growth. Should a green belt be required by the Strategic Development Plan, there is a need to draw generous, appropriate and defensible boundaries around the villages in this area which allow for a suitable level of expansion.

Secondly, the respondent also states that Policy 3 specifically mentions Scone and the requirement to use "Perth green belt to sustain the identity of Scone". Whilst the respondent

123 TAYPLAN STRATEGIC DEVELOPMENT PLAN is supportive of the retention of the separate identity of Scone, it is considered that this should not be undertaken at the expense of providing the town with the necessary room to expand to meet its own needs. The green belt boundary should therefore be held back from the existing edge of the settlement to allow room for expansion. There is sufficient separation at present from the adjacent settlement to the south to sustain the identity of Scone with a small extension to the south side of Scone as per the respondent’s submission to the Perth and Kinross Main Issues Report (October 2010 – February 2011).

GS Brown Construction (543112) consider that the green belt concept is an anachronism in planning terms and is too blunt and rigid in its application. The respondent indicated that they are particularly familiar with the proposed Perth green belt and consider that its imposition will rule out small scale infill type developments within the Perth Core zone.

Bidwells for Zurich Assurance Limited (442149) notes that a new green belt is proposed within the Perth Core Area. Whilst a green belt would help preserve the landscape setting of Perth and the identity of Scone, a balance needs to be struck between those needs and that of the needs to accommodate and facilitate economic development and growth within the core area. Bearing in mind the long term nature of green belts, the respondent considers that a series of green wedges around Perth would be a more appropriate means of achieving those aims whilst facilitating economic development and growth in this key component of the TAYplan region. Whilst the final boundaries of a greenbelt will not be drawn through TAYplan but through a Local Development Plan, the respondent finally considers that these principles should be made clear within TAYplan.

Councillor Michael A Barnacle (450613) considers that the Perth green belt boundary should be drawn more tightly towards the outer ring road and the A9 west and north. In addition, the respondent considers that Kinross-shire should be included along with Perth and St. Andrews as an area of landscape and heritage importance.

ST. ANDREWS

Mrs Judith Harding (377831 –PLAN499); Mrs Judith Harding (377831 – PLAN500); Miss Marianne Baird (544315); Mrs Jennifer Byrne (545391); Largo Area Community Council (450207); Mrs Wendy Baylis (541352); Mr K C Fraser (443846); Mrs Jennifer Hopgood (348875); Alaric Hopgood (548889); Philip Anthony Hardie (548708); Penny Uprichard (344887); and Mrs Anne Tynte-Irvine (5433880)

All of the above respondents have commented that the green belt around St. Andrews has not yet been designated or fixed. The respondents therefore consider that the green belt should be set for St. Andrews before housing is allocated within the proposed western extension of the town. In addition, three of the above respondents have provided additional comments, including: Mrs Judith Harding (377831 – PLAN500) considers that there is no protection for landscape value (a tourist asset) which can be destroyed by allowing windfarms near settlements or places of outstanding beauty. Largo Area Community Council (450207) consider that TAYplan should make a more robust commitment to landscape protection given the importance of tourism to the rural economy. Mrs Jennifer Hopgood (348875) considers that the proposed green belt boundary does not protect the setting of St. Andrews to the west or the "views and special character...".

The following respondents have made separate representations on the proposed St. Andrews Greenbelt:

Mr Colin McAllister (545660); Mr Howard Greenwel (546652); St. Andrews Preservation Trust (547750), Flora Selwyn (542815); and Miss Sarah Hunt (548386) have indicated 124 TAYPLAN STRATEGIC DEVELOPMENT PLAN that they do not consider that golf courses or tourist facilities are acceptable forms of development within the St. Andrews green belt and therefore these exceptions should be reviewed.

Professor Karla Pollmann (545572) has commented that the St. Andrews green belt should be retained and development should stop eating into and destroying it.

Professor Charles McKean (545597) has requested a modification to the first bullet point after St. Andrews as a critical part of the identity and setting of St. Andrews lies in its sharp edge with the countryside and its distant views. The respondent considers that this has been gravely eroded in the last 30 years, in the approaches from south, east and west; and that the Proposed Plan should be used to prevent any further blurring of its identity.

Hargest Planning Limited (548948) supports the principle of a green belt around St. Andrews as well as its principal role in protecting the landscape setting of the town and views into and out of its historic core. However, the respondent considers that the description of the green belt should be amended to reflect the potential for long term growth to the west of the current Strategic Development Area, particularly within the Craigtoun area of west St. Andrews, on the grounds that, the development of this area will not adversely affect either the landscape setting of the town or views into or out of the historic core.

KINROSS

Two respondents (Mr Ken Miles (548486) and Kinross-shire Civic Trust (546838) have commented on the omission of Kinross within Policy 3 and have highlighted the important landscape setting and important heritage of the town. It should also be noted that Councillor Michael A Barnacle has made a similar comment which is summarised above. Mr Ken Miles (548486) also considers that Kinross should be afforded a green belt designation to protect its setting.

Kinross-shire Civic Trust (546838) considers that Kinross-shire should be identified in the Strategic Development Plan as an area of Landscape and Heritage Interest as much of Kinross-shire is covered by the Area of Great Landscape Value Policy in the current Kinross Area Local Plan. The respondent also comments that Kinross-shire has a number of Sites of Special Scientific Interest, has the Loch Leven Special Protection Area (National Nature Reserve), Sites of Local Conservation Interest, Conservation Areas and Scheduled Monuments. Perth & Kinross Council have also intimated that it will consider replacing the Area of Great Landscape Value with a special landscape value policy in the new Local Development Plan. SUMMARY OF REPRESENTATIONS SUPPORTING AS WRITTEN

GENERAL

Methven & District Community Council (450585) although indicating strong support for the green belt policies, it is considered that core villages such as Almondbank and Methven should be incorporated into bullet point two as Methven & District Community Council covers villages near, but not in Perth, therefore the green belt must secure the landscape and leisure opportunities for local people and visitors and prevent urban sprawl.

PERTH

Mr David Dykes (527724) and Montgomery Forgan Associates for Morris Leslie Group (445161) support the Perth green belt in order to sustain the historic identity of Scone. 125 TAYPLAN STRATEGIC DEVELOPMENT PLAN ST ANDREWS Strathkinness Community Council (546153) has indicated their support to limiting the types of land uses within the St. Andrews green belt to protect the setting and historic core of the town.

Montgomery Forgan Associates for Headon Developments Limited (349140) supports the objective of protecting the important landscape settings and historic core of St. Andrews through the designation of a green belt. This position has underpinned the work undertaken so far by Headon Developments which recognises recognises that the correct balance can be struck between securing the town's landscape setting and historic core and the need to ensure there is sufficient housing and employment land supply within St. Andrews to allow for its planned and measured expansion, thus securing the economic sustainability of the town.

Modifications sought by those submitting representations:

GENERAL Geddes Consulting for Thomson Homes Limited (445159) • existing green belt boundaries around Perth and St. Andrews should be amended to meet the strategic requirements for growth, reflect the long term settlement strategy and ensure that settlements are able to accommodate planned growth, meeting the objectives of Scottish Planning Policy without the inner boundary being drawn too tightly against the urban edge.

Mr John Hendrie (548413) • The Plan alludes to preventing coalescence in respect of Perth and St. Andrews. Can it please refer to all other communities within the Plan?

Andrew McCafferty for GD Strawson and J Farquharson (548151 – PLAN449) • The diagram illustrating "Perth Core Area" is unacceptable and cannot be understood. It should be deleted and replaced with a clearer version which shows recognisable features/settlements on the ground.

Andrew McCafferty for GD Strawson and J Farquharson (548151 – PLAN445) • Request that the way that the proposed green belt around the eastern side of Perth is shown on the plan on page 9 is clarified preferably by showing a relationship to a recognisable feature/settlement on the ground.

Royal Burgh of St. Andrews Community Council (453889) • Change "continuing to designate green belt boundaries at both St. Andrews and Perth" to "designate green belt boundaries encircling both St. Andrews and Perth". • Change "to manage long term planned growth including infrastructure in this Plan's Proposals Map and Strategic Development Areas in Policy 4" to "to manage long term planned growth including proposals shown in this Plan's Proposals Map."

PERTH PPCA Limited for Edinmore Properties Limited (538105) • Object to the blanket approach to proposed Green Belt designation around Perth City.

EMAC Planning for A & J Stephen Limited (445201) • Amend the second bullet to read: "using Perth green belt to ensure the continued separation of Perth and Scone to sustain the identity of Scone and provide sufficient land for planned development around key villages and settlements". 126 TAYPLAN STRATEGIC DEVELOPMENT PLAN Homes for Scotland (442882) • Amend the second bullet point to: ‘using Perth green belt to sustain the identities of Perth and Scone, and providing sufficient land for planned development around key villages and settlements, subject to a full review of the existing greenbelt’

Smiths Gore for Mansfield Estates (442870 – PLAN552) • Remove the "Proposed Green Belt" requirement or change the text in Policy 3, as suggested by Homes for Scotland to; " using Perth green belt to sustain the identities of Perth and Scone, and providing sufficient land for planned development around key villages and settlements, subject to a full review of the existing greenbelt'.

Smiths Gore for Mansfield Estates (442870 – PLAN541) • Page 7 Proposals Map. Remove the "Proposed Green Belt" requirement or change the text in Policy 3 , as suggested by Homes for Scotland to "using Perth green belt to sustain the identities of Perth and Scone, and providing sufficient land for planned development around key villages and settlements, subject to a full review of the existing greenbelt'.

Mr Mark Myles (328142) • Policy 3 highlights that the identity of Scone is to be protected. The Proposed Plan should state that other rural settlements within the Perth Core Area are as equally important e.g. Redgorton, Luncarty, Almondbank and that their identities should also be protected. As such I consider that the proposed extent of the green belt should be more clearly stated and shown with greater conviction on the diagrams within the proposed plan to include the area between Berthapark and Luncarty/Redgorton so as to properly guide the emerging Perth & Kinross Local Development Plan when it comes to defining the green belt boundaries.

Miss Lynn McGeorge (548414 – PLAN603 and PLAN610) • No specific change identified, considers that many areas surrounding Perth, including Luncarty/Redgorton/Stanley/Stormontfield appear to have been excluded as being areas of beauty and worth protecting.

GS Brown Construction (543112) • No specific change identified, although concerned that the greenbelt concept is an anachronism in planning terms and is too blunt and rigid in its application. Familiar with the proposed Perth Green Belt and consider that its imposition will rule out small scale infill type developments within the Perth Core zone.

Bidwells for Zurich Assurance Limited (442149) • A series of green wedges would be a more effective means of achieving the stated goals.

Councillor Michael A Barnacle (450613) • No specific change identified, although considers that the Perth green belt boundary should be drawn more tightly towards the outer ring road and the A9 west and north. In addition, Kinross-shire should be included along with Perth and St. Andrews as an area of landscape and heritage importance.

ST. ANDREWS

Mrs Judith Harding (377831 –PLAN499 and PLAN500); Miss Marianne Baird (544315); Mrs Jennifer Byrne (545391); Largo Area Community Council (450207); Mrs Wendy 127 TAYPLAN STRATEGIC DEVELOPMENT PLAN Baylis (541352); Mr K C Fraser (443846); Mrs Jennifer Hopgood (348875); Alaric Hopgood (548889); Philip Anthony Hardie (548708); Penny Uprichard (344887) and Mrs Anne Tynte-Irvine (5433880) • No specific change identified, although all consider that the green belt should be set for St. Andrews before housing is allocated within the proposed western extension of the town.

Mr Colin McAllister (545660); Mr Howard Greenwell (546652); St. Andrews Preservation Trust (547750); Flora Selwyn (542815) and Miss Sarah Hunt (548386) • Have all indicated that they do not consider that golf courses or tourist facilities are acceptable forms of development within the St. Andrews green belt.

Professor Karla Pollmann (545572) • Keep the green belt of St. Andrews and stop eating into it and destroying it.

Professor Charles McKean (545597) • Policy 3: ...continuing to designate green belt boundaries at St Andrews...add ' to encircle the town prior to the identification of housing land '

Hargest Planning Limited (548948) • No specific change identified, although consider that the description of the green belt should be amended to reflect the potential for long term growth to the west of the current Strategic Development Area, particularly within the Craigtoun area of west St. Andrews, on the grounds that, the development of this area will not adversely affect either the landscape setting of the town or views into or out of the historic core.

KINROSS

Mr Ken Miles (548486) • Considers that Kinross should be afforded a green belt designation.

Kinross-shire Civic Trust (546838) • No specific change identified, although considers that Kinross-shire should be identified in the Strategic Development Plan as an area of Landscape and Heritage Interest as much of Kinross-shire is covered by the Area of Great Landscape Value Policy in the current Kinross Area Local Plan.

Summary of responses (including reasons) by planning authority:

RESPONSES TO REPRESENTATIONS SEEKING A CHANGE

GENERAL

Geddes Consulting for Thomson Homes Limited (445159; and, Andrew McCafferty for GD Strawson and J Farquharson (548151 – PLAN449 and PLAN445) Policy 3 (Greenbelts) accords with Scottish Planning Policy (Pages 32-33, Paragraphs 159-164) (CL/Doc2). Scottish Planning Policy is clear on the role Strategic Development Plans have in establishing the principle of a greenbelt. In this regard, Scottish Planning Policy specifies that the Strategic Development Plan “should establish the need for a green belt, identify its broad area and set the policy for future development within it. Local Development Plans should establish the detailed boundaries of the green belt and identify types of development which are appropriate within the green belt.” (Page 33, Paragraph 161). This is what the Proposed Plan does. The Scottish Government nor any other Key Agency have raised concern, nor 128 TAYPLAN STRATEGIC DEVELOPMENT PLAN sought any changes to Policy 3 (Greenbelts) or associated maps. TAYplan does not consider that a modification to Policy 3 is necessary.

Mr John Hendrie (548413) TAYplan considers that the level of detail in Policy 3 (Greenbelts) and the supporting text (Page 12) is appropriate for a strategic planning policy document and does not require to prevent coalescence to all settlements within the TAYplan region. Topic Paper 3: Resources and Climate Change (Page 11, Paragraph 5.13) (CL/Doc32)specifies that Perth and St. Andrews have designated green belts in order to preserve their historic settings, views and special character. Scottish Planning Policy also states that “most settlements do not have or need green belts because other policies or designations, such as countryside policies, provide an appropriate context for decision making” (Scottish Planning Policy, Page 32, Paragraph 160) (CL/Doc2).Therefore, the prevention of coalescence of other settlements is an issue which will be considered in more detail within Local Development Plan policy and/or during the planning application process.

Royal Burgh of St. Andrews Community Council (453889) The principal for green belts at Perth and St. Andrews was established in their respective Structure Plans, although the detailed boundaries will be set out in the emerging Perth & Kinross and St. Andrews and East Fife Local Development Plans (Background Technical Note (April 2010), Page 8, Paragraph 2.23) (CL/Doc58). Scottish Planning Policy is clear on the role Strategic Development Plans have in establishing the principle of a green belt. In this regard, Scottish Planning Policy specifies that the Strategic Development Plan “should establish the need for a green belt, identify its broad area and set the policy for future development within it (Scottish Planning Policy, Page 33, Paragraph 161) (CL/Doc2). The specific changes sought to the text would not provide consistency across the Plan.

The St. Andrews green belt was designated in the approved Fife Structure Plan (2009) (CL/Doc39) with the boundaries being defined through the Local Development Plan – currently at examination stage. Through the Local Development Plan process there has been considerable consultation on this alongside the proposed Strategic Development Area. To make any changes to this, at this late stage in a process of designating and defining the boundary, would undermine the current wording of Policy 3 and could have implications for other policies of the Proposed Plan.

1. The High Court decision by Lord Justice Clerk, Lord Brodie and Lord McEwan on September 7th 2011 (CL/Doc76)dismissed the legal challenge to the Fife Structure Plan 2009 stating that:

“The effect of our quashing those parts of the Plan that relate to St Andrews West would be that it would cease to be a strategic land allocation. That would undermine the settlement strategy of the Plan. It would disrupt the local plan process. It would frustrate the policy decision that St Andrews must make its contribution to the economic regeneration of Fife. In this way the wider economic strategy would be undermined and, in my opinion, would become unworkable. I think that there would also be a vacuum in the development plan because there would no longer be a coherent planning framework for development control in St Andrews West.”

PERTH

PPCA Limited for Edinmore Properties Limited (538105); Mr Mark Myles (328142); Miss Lynn McGeorge (548414 – PLAN603 and PLAN610); GS Brown Construction (543112); Bidwells for Zurich Assurance Limited (442149); and Councillor Michael A Barnacle (450613) Policy 3 (Greenbelts) accords with Scottish Planning Policy (Pages 32-33, Paragraphs 159-164) (CL/Doc2). Scottish Planning Policy is clear on the role Strategic 129 TAYPLAN STRATEGIC DEVELOPMENT PLAN Development Plans have in establishing the principle of a greenbelt. In this regard, Scottish Planning Policy specifies that the Strategic Development Plan “should establish the need for a green belt, identify its broad area and set the policy for future development within it. Local Development Plans should establish the detailed boundaries of the green belt and identify types of development which are appropriate within the green belt.” (Page 33, Paragraph 161).

The principal for a green belts at Perth was established in the approved Perth Structure Plan (2003) (CL/Doc46), although the detailed boundaries will be set out in the emerging Perth & Kinross Local Development Plan (Background Technical Note (April 2010), Page 8, Paragraph 2.23) (CL/Doc58).

In relation, to the Perth green belt, Policy 3 does not suggest a blanket ban on development. The green belt will protect the historic core and setting of Perth as well as accommodating infrastructure and planned development, whilst preventing the sprawl of the city into the countryside. Consequently, and whilst read in conjunction with Policy 1: Location Priorities; this forms an important element of ensuring that growth is focussed firstly within the Perth Core Area and particularly that the largest concentrations are at the Perth West/North West Strategic Development Area as defined in Policy 4 (Page 15). This approach is therefore an integral element of the Spatial Strategy of the Proposed Plan and is consistent with Scottish Planning Policy (Pages 32-33, Paragraph 160) (CL/Doc2), whilst also forming a continuation of the approach set out in the Perth and Kinross Structure Plan (2003) (CL/Doc46). A failure to implement the green belt in this way would make the planned and coordinated growth of Perth City at the heart of the Perth Core Area impossible. Only by putting in place a green belt and by drawing its boundaries to take account of planned growth can the decision making framework be capable of supporting sustainable growth, consistent with Scottish Planning Policy (Page 32, Paragraph 159) (CL/Doc2), whilst allowing the Perth & Kinross Local Development Plan to define the specific boundaries to assist in the delivery of the Spatial Strategy of the Strategic Development Plan.

The Scottish Government nor any other Key Agency have raised concern, nor sought any changes to Policy 3 (Greenbelts) or associated maps. TAYplan does not consider that a modification to Policy 3 is necessary.

Emac Planning for A & J Stephen Limited (445201); Homes for Scotland (442882); and Smiths Gore for Mansfield Estates (442870 – PLAN552 and PLAN541) TAYplan do not consider it necessary to modify the second bullet point of Policy 3 (Greenbelts) Proposed Plan relating to Perth. The designation of a green belt around Perth aims to protect its historic core and setting, whilst accommodating infrastructure and planned development. The emerging Perth & Kinross Local Development Plan will define the specific boundaries of the greenbelt. In conjunction with bullet point one, Policy 3 (Greenbelts) is clear and concise and accords with Scottish Planning Policy (Pages 32-33, Paragraphs 159-164) (CL/Doc2). Although the respondents are only requesting relatively minor modifications to the wording of the second bullet point of Policy 3 (Greenbelts), the changes requested are considered to be repetitive with other parts of Policy 3 (Greenbelts), therefore any change to the Proposed Plan would mean that a short, concise and visionary Strategic Development Plan would not be implicated (Planning Circular 1/2009: Development Planning, Page 4, Paragraph 14) (CL/Doc29). Such changes are not considered necessary.

ST. ANDREWS

Mrs Judith Harding (377831 –PLAN499 and PLAN500); Miss Marianne Baird (544315); Mrs Jennifer Byrne (545391); Largo Area Community Council (450207); Mrs Wendy Baylis (541352); Mr K C Fraser (443846); Mrs Jennifer Hopgood (348875); Alaric 130 TAYPLAN STRATEGIC DEVELOPMENT PLAN Hopgood (548889); Philip Anthony Hardie (548708); Penny Uprichard (344887); Mrs Anne Tynte-Irvine (5433880); Hargest Planning Limited (548948); Professor Karla Pollmann (545572) and Professor Charles McKean (545597) Policy 3 (Greenbelts) accords with Scottish Planning Policy (Pages 32-33, Paragraphs 159-164) (CL/Doc2). Scottish Planning Policy is clear on the role Strategic Development Plans have in establishing the principle of a greenbelt. In this regard, Scottish Planning Policy specifies that the strategic development plan “should establish the need for a green belt, identify its broad area and set the policy for future development within it. Local Development Plans should establish the detailed boundaries of the green belt and identify types of development which are appropriate within the green belt.” (Page 33, Paragraph 161).

The Finalised St. Andrews & East Fife Local Plan (2009) (Pages 98 and 141) (CL/Doc40)sets the proposed green belt boundaries for St. Andrews but is clear that the inner boundary of the green belt may be adjusted via the Masterplanning process for the St. Andrews West proposal. A green belt for St. Andrews has been a proposal of the St. Andrews & East Fife Local Plan since March 2005, when the Consultative Draft St. Andrews & East Fife Local Plan was published. The green belt proposal carried through (in an amended form) to the St. Andrews & East Fife Local Plan - Finalised Draft of August 2006 and is now included (with further amendment) as proposal LW4 24 in the Finalised St. Andrews & East Fife Local Plan (2009). The size of the green belt has increased, in response to representations made and the comments of various Committees, at each stage of the Local Plan process. In addition, in drawing the green belt boundaries for St. Andrews, Fife Council have taken into consideration various landscape studies.

It should be noted that the Finalised St. Andrews & East Fife Local Plan (2009) (CL/Doc40)is currently under Examination by Scottish Ministers. The St. Andrews green belt proposal (LW4 24, Policy E17) will be considered as part of this examination, however it is the view of Fife Council that appropriate boundaries have been set for the proposed St. Andrews green belt. Scottish Planning Policy (Page 33, Paragraph 162) (CL/Doc2) states that inner boundaries should not be drawn too tightly around the urban edge, but where appropriate should create an area suitable for planned development between the existing settlement edge and green belt boundary.

2. The High Court decision by Lord Justice Clerk, Lord Brodie and Lord McEwan on September 7th 2011 (CL/Doc76)dismissed the legal challenge to the Fife Structure Plan 2009 stating that:

Mr Colin McAllister (545660); Mr Howard Greenwell (546652); St. Andrews Preservation Trust (547750); Flora Selwyn (542815) and Miss Sarah Hunt (548386)TAYplan does not consider that the issues raised are of strategic significance. The Proposed Plan does not identify types of development which are appropriate within the St. 131 TAYPLAN STRATEGIC DEVELOPMENT PLAN Andrews green belt. This is matter is addressed by Policy E17 in the Finalised St. Andrews & East Fife Local Plan (2009) (CL/Doc40) (Page 141) which is consistent with the approach sought in Scottish Planning Policy (Page 33, Paragraph 161) (CL/Doc2). It should be noted that that the Finalised St. Andrews & East Fife Local Plan (2009) currently under Examination by Scottish Ministers which will consider the St. Andrews Greenbelt issue.

KINROSS

Mr Ken Miles (548486) and Kinross-shire Civic Trust (546838) Scottish Planning Policy states that “most settlements do not have or need green belts because other policies or designations, such as countryside policies, provide an appropriate context for decision making” (Scottish Planning Policy, Page 32, Paragraph 160) (CL/Doc2). TAYplan therefore considers that there is no strategic requirement for a greenbelt at Kinross as the policy framework for countryside development adjacent to main settlements will be established by the emerging Perth & Kinross Local Development Plan.

Kinross-shire Civic Trust (546838) TAYplan does not consider that the issue raised is of strategic significance. Policy 3 (Natural and Historic Assets) is clear and concise on the importance of safeguarding sensitive landscapes. The policy framework for particular important landscapes, such as Kinross-shire is likely to established by the emerging Perth & Kinross Local Development Plan.

RESPONSE TO REPRESENTATIONS SUPPORTING AS WRITTEN TAYplan welcomes the support for these issues.

CONCLUSION

TAYplan considers that the issues raised do not warrant any change to the Proposed Strategic Development Plan (June, 2011) and propose that the elements dealt with in this Schedule 4 Summary of Unresolved Issues remain as written and unchanged. Scottish Natural Heritage, Scottish Government nor any other Key Agency have sought any changes to Policy 3 (Greenbelts) or associated maps.

The Proposed Strategic Development Plan takes forward the green belt principles established in approved Structure Plans. Any change to Policy 3 (Greenbelts) would undermine the Development Plan process of establishing green belt boundaries which is being taken forward through Local Plans / Local Development Plans. TAYplan consider that Policy 3 (Greenbelts) is consistent with Scottish Planning Policy, Page 32-33, Paragraphs 159-164) and therefore does not consider that any modifications are necessary.

Reporter’s conclusions:

General 1. Representations argue that this part of Policy 3 does not provide sufficient clarity and certainty about the boundaries of the Perth and St. Andrews green belts and about where development will be allowed, and that existing green belt boundaries do not conform to Scottish Planning Policy (SPP). However, it is not the function of strategic development plans to set green belt boundaries. SPP paragraph 161 states that the strategic development plan should establish the need for a green belt, identify its broad area and set the policy for future development within it. Local development plans should establish the detailed boundaries of the green belt and identify types of development which are appropriate within the green belt. I consider that this section of TAYplan correctly fulfils the requirements set out in the SPP, and that it would not be appropriate for it to prescribe in

132 TAYPLAN STRATEGIC DEVELOPMENT PLAN greater detail the boundaries which should be set by local development plans. I do, however, have sympathy with the view that the Perth green belt diagram is confusing, and I will go on to consider that under the ‘Perth’ heading.

2. Mr John Hendrie seeks a policy to prevent the coalescence of other settlements in addition to those covered by the green belts. However, it would not be appropriate to designate green belts for all settlements, as is made clear by SPP paragraph 160. It will be for local development plans to consider whether policies are needed to maintain the separation of other settlements.

3. The Royal Burgh of St. Andrews Community Council seeks amendments to the text to delete ‘continuing to’, replace ‘at both’ with ‘encircling both’ and ‘infrastructure’ with ‘proposals shown’, and by deleting the reference to Strategic Development Areas. It argues that ‘continuing to designate’ is inappropriate where a green belt boundary has not yet been designated. However, the Finalised St. Andrews and East Fife Local Plan now designates a green belt boundary for St. Andrews. Also, such a boundary could not completely encircle the town because the sea lies to the east. The references to infrastructure shown on the proposals map and to Strategic Development Areas appear to me to be correct, and I see no need to change them.

Perth 4. Several representations raise concerns about the extent and clarity of the Perth green belt as shown on page 13, and of the settlements within the Perth Core Area. While it is for local development plans to establish the detailed boundaries of the green belt and identify types of development which are appropriate within it, the SPP (paragraph 161) requires the strategic development plan to identify its broad area.

5. The diagram on page 13, like the versions of it incorporated in the maps on pages 7 and 9, is confusing and difficult to understand. The green dotted lines weave in and out in a convoluted way, have unexplained bulges to the east and west of Perth, and leave open a gap to the north of the city which suggests a development corridor as far as Stanley. The diagram contains fewer ‘blobs’ than there are settlements listed in Policy 1A, and does not name the settlements. While this diagram has its origins in the 2003 Perth and Kinross Structure Plan, it may not provide a satisfactory basis for detailed green belt proposals in the emerging local development plan.

6. At my request, the authority has produced a revised diagram which more clearly identifies the extent of the green belt, confirming that it is meant to encircle both Perth and Scone and naming the related settlements. I consider that this provides much greater clarity, and I recommend that it be substituted for the existing diagram, with consequential changes on pages 7 and 9. Comments from some of those who made earlier representations on this issue, while welcoming the new diagram as an improvement, seek greater precision in showing the boundaries of existing settlements in relation to the green belt. However, I consider that such a degree of detail is not appropriate to a strategic development plan, and should be left to the emerging local development plan. Whether the settlement at the centre of the new diagram should be labelled ‘Perth’ is a matter for the authority. I do not think its identity is open to any doubt. Similarly, it is for the authority to adopt a page layout and diagram scale that ensure the settlement names remain legible in the printed plan.

7. Some representations challenge the need for a green belt or suggest changes to the text. The principle of a Perth green belt is carried forward from the existing structure plan, while a detailed review of its boundaries and of the policies that should apply within it is a matter for the emerging local development plan. I consider that Policy 3 sets out an appropriate level of justification and policy guidance for a strategic development plan. The overall purposes of 133 TAYPLAN STRATEGIC DEVELOPMENT PLAN the green belt are set out in the first bullet point, while the second bullet point aims specifically to sustain the identity of Scone and to provide sufficient land for planned development around key villages and settlements. There is no reason to conclude that the policy would rule out small-scale infill development in settlements within the Perth Core Area. I consider that there is no need to change the existing text as it applies to Perth.

St. Andrews 8. Representations consider that the green belt should be set before housing is allocated within the proposed western extension of the town. The setting of green belt boundaries is a matter for the St. Andrews and East Fife Local Plan, and has been considered in the examination of that plan. Other representations argue that golf courses and tourist facilities should not be regarded as acceptable forms of development in the St. Andrews green belt. Again, this is a matter for the local plan, provided the broad objectives set out in the first bullet point of this part of Policy 3 are followed. I do not consider that any changes in TAYplan are required in relation to the St. Andrews green belt.

Reporter for paragraph 9 only: Scott Ferrie

9. Professor Charles McKean seeks the amendment of Policy 3 to ensure the designation of a green belt boundary for St. Andrews prior to the identification of housing land. The Finalised St. Andrews and East Fife Local Plan now designates a green belt boundary for St. Andrews, in tandem with the allocation of land for residential development. It seems to me therefore, that modifying the proposed plan as sought would be inappropriate and, indeed, ineffectual.

Kinross 10. Mr Ken Miles considers that Kinross should be afforded a green belt designation to protect its setting. However, the SPP (paragraph 160) states that most settlements do not need green belts. There are other ways in which the setting of Kinross can be protected, through appropriate policies in the local development plan. Kinross-shire Civic Trust and Councillor Michael Barnacle consider that Kinross-shire should be identified in TAYplan as an area of landscape and heritage interest. However, there are several other parts of the region that could make a similar claim, and the part of Policy 3 dealing with Natural and Historic Assets makes provision for safeguarding landscapes and heritage assets wherever they are situated. I do not consider that there is a need to include specific mention of Kinross in the part of Policy 3 dealing with green belts.

Reporter’s recommendations:

Modify page 13 of the proposed plan as follows:

Under the heading “Perth Core Area”, delete the existing diagram and replace it with Appendix 1 to the authority’s letter of 27 February 2012 headed “Further Information Response: Issue 8: Policy 3: Greenbelts”.

Modify pages 7 and 9 of the proposed plan so that the representation of the Perth Core Area and green belt is consistent with the revised diagram on page 13.

134

TAYPLAN STRATEGIC DEVELOPMENT PLAN

Issue 9 Managing TAYplan’s Assets – Finite Resources

Provide the references for where the issue arises in the development plan. Development plan Reporter: Page 12: Managing TAYplan’s Assets reference: Karen Heywood Supporting Text Page 13: Policy 3 Finite Resources Body or person(s) submitting a representation raising the issue (including reference number):

Seeking a change

ID Person/Organisation Representation Number Reference 169659 Coal Authority PLAN164 169659 Coal Authority PLAN166 450613 Councillor Michael A Barnacle PLAN814 548286 Emac Planning for Skene Group Limited PLAN506 547768 G.M. Gall PLAN563 547768 G.M. Gall PLAN303 263542 Kingsbarns Community Council PLAN389 546838 Kinross-shire Civic Trust PLAN494 450207 Largo Area Community Council PLAN436 330871 Mineral Products Association (Scotland) PLAN583 548055 Mr Ian Fowler PLAN391 548413 Mr John Hendrie PLAN575 548408 Mrs Marion Lang PLAN570 Royal Burgh of St. Andrews Community 453889 Council PLAN921

Provision of the development plan Natural and Historic Assets – this Schedule 4 relates to the two bullet to which the issue points under the Finite Resources section of Policy 3. relates: Planning authority’s summary of the representation(s):

SUMMARY OF REPRESENTATIONS SEEKING A CHANGE

MINERALS

Coal Authority (169659 - PLAN164) although supporting the commitment to safeguarding minerals of economic importance, the respondent considers that more clarity is required within the Proposed Strategic Development Plan on what minerals are of economic importance. In particular, coal resources should be included within the parameters of minerals of economic importance given the levels of current, historic and future extraction within Fife. The Coal Authority (169659 - PLAN166) has also commented that Areas of Search for future coal extraction should have been considered within the Strategic Development Plan process. The respondent has highlighted the East Dunbartonshire Local Development Plan Examination where the Reporter concluded that areas of search are a matter for the new Strategic Development Plans to consider.

136 TAYPLAN STRATEGIC DEVELOPMENT PLAN Emac Planning for Skene Group Limited (548286) supports the commitment to safeguarding mineral deposits, however in addition to the Mineral Products Association (Scotland) (330871) the respondent considers that the Policy text is amended to directly reflect national policy as contained in Scottish Planning Policy (SPP), paragraph 227. The current policy does not acknowledge that 10 years extraction should be available ‘at all times in all market areas’ which is also supported by SPP.

Emac Planning for Skene Group Limited (548286) also considers that their proposed second sentence would provide certainty that within this city region planning context there is a commitment to working and liaising across local authority boundaries.

PRIME AGRICULTURAL LAND

Councillor Michael A Barnacle (450613), Mrs Marion Lang (548408), G.M. Gall (547768 – PLAN303 & PLAN563); Kingsbarns Community Council (263542) and Largo Area Community Council (450207) have all commented that TAYplan should protect agricultural land from further development in order to produce more food. In addition, Mr John Hendrie (548413) has commented that the Proposed Strategic Development Plan makes no specific reference to preventing building outside village boundaries and protecting prime agricultural land which bound them.

Mr Ian Fowler (548055) and Royal Burgh of St. Andrews Community Council (453889) consider that there is an emphasis on the advantages of development on prime agricultural land if it is seen as being advantageous. As a result, the respondents have both requested a modification to the wording of Policy 3 – Finite Resources.

Kinross-shire Civic Trust (546838) indicates that TAYplan must identify the need to retain prime agricultural land in terms of self sufficiency and an ability to provide food. The respondent has also indicated that a map which displays all the areas of prime agricultural land should accompany the Proposed Strategic Development Plan.

Modifications sought by those submitting representations:

NOTE TO REPORTER: The text in italics in this section has been lifted directly from each individual/organisation’s representation with minor typographical errors corrected.

MINERALS

Coal Authority (169659 – PLAN164) • Policy 3, Managing TAYplan's Assets Clarity is required in the Strategic Development Plan on what minerals are of economic importance, The Coal Authority would wish to see coal resources included within the parameters of a mineral of economic importance given the levels of historical, current and likely future extraction within Fife.

Coal Authority (169659 – PLAN166) • Policy 3, Managing Tayplan's Assets (Omission) - The Coal Authority objects to the omission of the consideration of Areas of Search for future coal extraction within the Strategic Development Plan process.

Emac Planning for Skene Group Limited (548286) • Under finite resources the commitment to safeguarding mineral deposits is supported.

137 TAYPLAN STRATEGIC DEVELOPMENT PLAN Emac Planning for Skene Group Limited (548286); Mineral Products Association (Scotland) (330871) • However, it is suggested that the Policy is amended from Local Development Plans requiring to” safeguard minerals deposits of economic importance and land for a minimum of 10 years supply of aggregates" to: "ensure a landbank of permitted reserves for construction aggregates of a minimum 10 years extraction is available at all times in all market areas. The Local Development Plan Authorities will work together to ensure an adequate supply of minerals can be provided".

PRIME AGRICULTURAL LAND

Royal Burgh of St. Andrews Community Council (453889) • Page 13, Policy 3, Finite Resources. Change "protect prime agricultural land, new and existing forestry areas, and carbon rich soils (where identified) where the advantages of development do not outweigh the loss of productive land." to "protect prime agricultural land, new and existing forestry areas, and carbon rich soils (where identified).".

G.M. Gall (547768 – PLAN 303); Councillor Michael A Barnacle (450613); Mr Ian Fowler (548055); Mrs Marion Lang (548408) and Largo Area Community Council (450207) • No specific change identified, although consider that that TAYplan should protect agricultural land from further development in order to produce more food.

G.M. Gall (547768 – PLAN563) • No specific change identified, although concerned about the increasing urbanisation of our country. No doubt this is to some extent forced by population pressure; without doubt Scotland, like the rest of the world is overpopulated by humans.

Mr John Hendrie (548413) • No specific change identified, although Proposed Strategic Development Plan makes no specific reference to preventing building outside village boundaries and protecting prime agricultural land which bound them.

Kinross-shire Civic Trust (546838) • No specific change identified, although comments are provided in terms of • Agricultural Land • Area of Great Landscape Value

Summary of responses (including reasons) by planning authority:

RESPONSES TO REPRESENTATIONS SEEKING A CHANGE

MINERALS

Coal Authority (169659 - PLAN164); Coal Authority (169659 - PLAN166); EMAC Planning for Skene Group Limited (548286) and Mineral Products Association (Scotland) (330871) It is considered that there is no requirement to include areas of search or to define specific important mineral reserves within the Proposed Plan. Scottish Planning Policy (Page 47, Paragraph 226) (CL/Doc2) states that during development plan preparation (not specifically Strategic Development Plans) ‘Planning Authorities should liaise with operators and neighbouring planning authorities and use verifiable sources of information to identify appropriate search areas. These search areas, or where appropriate specific sites, should be identified and safeguarded in development plans and the criteria to be satisfied by 138 TAYPLAN STRATEGIC DEVELOPMENT PLAN development proposals set out. The same safeguarding principles should apply to land allocated for development which is underlain by minerals and where prior extraction of the mineral would be beneficial.’ TAYplan consider that across the area, Local Plans already set out areas of search with detailed policies. It is considered that Local Development Plan’s are more appropriate for the TAYplan area in setting out areas of search and providing a policy framework to asses individual planning applications. Local Plans and emerging Local Development Plans are also best placed to determine which specific areas ought to be protected, based on their minerals potential and afford an appropriate safeguard. The Proposed Plan does not require to repeat this. Indeed, the non-inclusion of minerals search areas was also raised within the Main Issues Report (April 2010) (Page 29, Paragraph 6.5) (CL/Doc38) and considered that it was not a cross-boundary or strategic issue. If it did so, and be repetitive in other policy areas, a short, concise and visionary Strategic Development Plan would not be possible (Planning Circular 1/2009: Development Planning, Page 4, Paragraph 14) (CL/Doc29).

In terms of ensuring that a landbank of permitted reserves for construction aggregates of a minimum 10 years extraction is available at all times in all market areas, TAYplan again considers that Local Plans across the area already set out detailed policies on the extraction of minerals and are again more appropriate for establishing and maintaining an appropriate landbank as set out in Scottish Planning Policy. Policy 3 is compliant with Scottish Planning Policy (Page 47, Paragraph 227) (CL/Doc2).

Topic Paper 3: Resources and Climate Change (Pages 10 and 11, Paragraph 5.12) (CL/Doc32) indicates that the Proposed Plan could determine that minerals extraction is not a strategic issue, as suggested by the Main Issues Report (April 2010) (Page 29, Paragraph 6.5) (CL/Doc38). However, it was considered that this was unlikely to properly reflect the importance of responsible asset management including the impact that development could have on economically important minerals and helping to ensure there is a supply of minerals, particularly aggregates, for the construction industry. Therefore, the Proposed Strategic Development Plan could have required Local Development Plans to safeguard economically important minerals in contributing to the requirement to have a 10 year supply of aggregates in Scottish Planning Policy. The Proposed Plan could also have gone further by setting out policies for taking decisions on individual applications for minerals extraction. However, in the case of the latter, no such approach has been considered at Main Issues Report stage, given that as stated above Local Plans across the TAYplan area already set out areas of search with detailed policies; and, Scottish Planning Policy is already very clear on strategic level requirements for minerals. Such a change to the Proposed Strategic Development Plan would be very significant. No change has been proposed from any of the key agencies, specifically Scottish Government, Scottish Natural Heritage or Scottish Environmental Protection Agency.

Responding specifically to The Coal Authority (169659 - PLAN166) reference to the East Dunbartonshire Local Development Plan Reporters Findings, it is considered that the two development plans are not comparable. Whilst The Coal Authority refer to Fife coal deposits, these are located outwith the TAYplan area in mid and west Fife predominantly. East Dunbartonshire and other parts of the Glasgow and Clyde Valley Strategic Development Plan Area have significantly more coal reserves than that located within the TAYplan area.

PRIME AGRICULTURAL LAND Kinross-shire Civic Trust (546838); Councillor Michael A Barnacle (450613); Largo Area Community Council (450207) Mr Ian Fowler (548055); Mrs Marion Lang (548408); G.M. Gall (547768 – PLAN 303); G.M. Gall (547768 – PLAN563); Mr John Hendrie (548413) and Royal Burgh of St. Andrews Community Council (453889) Policy 3 (Finite Resources) accords with Scottish Planning Policy (Page 20, Paragraph 97) (CL/Doc2). Topic 139 TAYPLAN STRATEGIC DEVELOPMENT PLAN Paper 3: Resources and Climate Change (Pages 10, Paragraph 5.11) (CL/Doc32) acknowledges that the TAYplan region contains a lot of prime agricultural land (93,872 ha or 12% of the TAYplan area) (Environmental Report (2009), Appendix D, Agricultural Land and Development Pressure 2009 Map) (CL/Doc41)and as a result in order for development to take place, particularly where settlements have limited brownfield sites, then some greenfield land of prime agricultural quality will need to be considered on the edge of settlements. Policy 3 considers supporting food and resource security as one consideration in the prioritisation of land release.

Policy 3 as it relates to prime agricultural land should therefore also be read in conjunction with Policy 1, Part B which prioritises land release for development within principal settlements. Therefore the loss of suitable prime agricultural land will only be permitted in circumstances where there are no available sites within a principal settlement and where the proposed development is of sufficient benefit to outweigh the loss of prime agricultural land.

In terms of the comments relating to Scottish Planning Policy, the Proposed Plan conforms to Scottish Planning Policy. Policy 1: Location Priorities, Part B provides the sequential approach to Local Development Plan’s in allocating sites. The Proposed Strategic Development does not identify the specific boundaries for the Strategic Development Areas (Policy 4). The boundaries will be set by future Local Development Plans or have already been established through previous development plans or through the planning application process. In addition, Local Development Plans can also consider the capacity of principal settlements to accommodate additional growth beyond the identified Strategic Development Areas, therefore TAYplan considers it in-appropriate to identify areas of prime agricultural land which may be lost as a result of the settlement strategy when defined boundaries have previously or will be established by constituent Local Development Plans in due course.

The above also applies to development on the edge of rural settlements, not defined as principle settlements. Policy 1: Location Priorities, Part A (Page 13) provides opportunity for Local Development Plans to provide for some development outwith principal settlements where this can be accommodated and supported by the settlement and where it contributes to the objectives of the Strategic Development Plan whilst also meeting local needs or supporting the regeneration of the local economy.

In summary, no change has been proposed by Scottish Government or any of its key agencies.

CONCLUSION

This Policy is consistent with Scottish Planning Policy. The policy framework provided is considered appropriate for this Strategic Plan given the nature of the TAYplan area. The four Constituent Councils have detailed policies in place on minerals. TAYplan considers that the issues raised in relation to minerals and prime agricultural land does not warrant any change to the Proposed Strategic Development Plan (June, 2011) and propose that the elements dealt with in this Schedule 4 Summary of Unresolved Issues remain as written and unchanged.

Reporter’s conclusions:

Minerals

1. In relation to minerals areas of search, I am aware that the circumstances in East Dunbartonshire are different to those in the TAYplan area. In East Dunbartonshire the

140 TAYPLAN STRATEGIC DEVELOPMENT PLAN approved Glasgow and Clyde Valley Structure Plan identifies mineral search areas and it was not necessary for the local plan to repeat these. The local plan examination concluded that this was a matter for the strategic development plan, as this would eventually replace the structure plan.

2. As the authority explains above, the four constituent planning authorities all have detailed minerals policies and minerals areas of search. I agree that it is more appropriate for these matters to continue to be covered in replacement local development plans.

3. I reach a similar conclusion in relation to what constitutes minerals of economic importance.

4. With reference to construction aggregates, I consider Policy 3 should be amended to include the full text of the relevant section of Scottish Planning Policy for clarity.

Prime agricultural land

5. Scottish Planning Policy states that development on prime agricultural land should not be permitted unless it is an essential component of the settlement strategy or is necessary to meet an established need, for example for major infrastructure development, where no other suitable site is available.

6. I consider that TAYplan has to be read as a whole, since the policies interlink, as the authority explains above. I also consider that, in relation to prime agricultural land, Policy 3, when read with Policy 1, accords with the section of Scottish Planning Policy referred to in the previous paragraph. Consequently, I do not consider that the part of Policy 3 referring to prime agricultural land needs to be modified.

Reporter’s recommendations:

Modify TAYplan as follows: on page 13 in the first bullet point of the Finite Resources section of Policy 3:

(i) add “construction” before “aggregates”; and

(ii) after “aggregates” add: “at all times in all market areas”.

141 TAYPLAN STRATEGIC DEVELOPMENT PLAN

Issue 10 Policy 3: Managing TAYplan’s Assets – Transport

Page 12: Managing TAYplan’s Assets Development plan Reporter: Supporting Text reference: Karen Heywood Page 13: Policy 3 Transport Body or person(s) submitting a representation raising the issue (including reference number):

Seeking a change

ID Person/Organisation Representation Number Reference 335193 Broughty Ferry Community Council PLAN5 548525 Dr Peter Symon PLAN898 329236 Forth Ports PLC PLAN686 329236 Forth Ports PLC PLAN713 443979 Lynne Palmer PLAN161 347686 Network Rail PLAN283 535502 Rail Freight Group PLAN90 453889 Royal Burgh of St. Andrews Community Council PLAN921

Support as written ID Person/Organisation Representation Number Reference 329236 Forth Ports PLC PLAN713 545848 Mr Ralph Barker PLAN483 548142 Seagreen Wind Energy Limited PLAN522

Provision of the development plan Transport – this Schedule 4 relates to the two bullet points under the to which the issue Transport section of Policy 3. relates: Planning authority’s summary of the representation(s):

SUMMARY OF REPRESENTATIONS SEEKING A CHANGE

SEEKING A CHANGE (PORTS – BULLET POINT ONE) Lynne Palmer (443979) consider that Perth Harbour is an important economic asset and should therefore have a reference within the Proposed Strategic Development Plan. In addition.

Forth Ports PLC (329236 – PLAN686) consider that bullet point under the Transport section of Policy 3 should be amended to include industrial and port-related uses as ports are occupied by cargo handling activities and also manufacturing uses. In addition, the Proposed Strategic Development Plan should also include the renewable energy and the low carbon economy as these are growth sectors for the region.

Forth Ports PLC (329236 – PLAN713) have also provided additional comments in relation to ports, including: • The Proposed Strategic Development Plan needs to broaden its terminology to ensure that it encompasses the range of manufacturing and industrial uses that should be encouraged within the Port of Dundee, as ‘port-related’ use alone could be 142 TAYPLAN STRATEGIC DEVELOPMENT PLAN interpreted restrictively. • It is important to recognise the Port as the location for importing resources that are not available in the immediate geographical area.

Dr Peter Symon (548525) considers that the Proposed Strategic Development Plan should include a reference regarding the possibility of investigating an expansion of port facilities and infrastructure where necessary to permit modern freight facility development in order to capture a greater share of freight trade associated with containerisation. This can also be achieved by increasing the scale of shipping and transport, however it may also require a rethink of the port strategy to include the possibility of expanding beyond existing port boundaries.

SEEKING A CHANGE (INFRASTRUCTURE PROVISION – BULLET POINT TWO) Broughty Ferry Community Council (335193) have requested a modification to the second bullet point within the Transport section of Policy 3, as it is considered that land should be reserved (via local plans) to provide sidings to enable local trains to move aside for express and freight trains.

Royal Burgh of St. Andrews Community Council (453889) has requested a modification to the second bullet point within the Transport section of Policy 3, as it is considered the current wording is in-effective because it will be rarely possible to establish that infrastructure provision is essential for a modal shift.

Rail Freight Group (535502) have requested that the Proposed Strategic Development Plan should give rail freight equal weight to sea freight in managing TAYplan’s transport assets. It is considered that Tayside will be potentially more vulnerable than most other regions of Scotland as it has no active rail freight facilities e.g. Dundee is one of the largest cities in Britain with no such facilities. Although sea freight alternatives to road haulage are available in Tayside, these are unlikely to offer the high-quality domestic logistics and distribution role which rail performs already in Central Scotland and to Aberdeen and Inverness. Land should therefore be identified as strategic rail locations at Montrose station, Dundee West, Perth South and around Blackford station.

SEEKING A CHANGE (GENERAL COMMENTS) Network Rail (347686) have requested that the Proposed Strategic Development Plan should provide strategic guidance for Local Development Plan’s to require development proposals to consider any impact on the use of level crossings and where required to require appropriate mitigation. The respondent has indicated that Network Rail may have to reduce train line speed should their be increased usage of level crossings by vehicular and pedestrian movements, which would conflict with government and TAYplan objectives of improving rail services within the area.

SUMMARY OF REPRESENTATIONS SUPPORTING AS WRITTEN

Mr Ralph Barker (545848) has indicated support for Dundee, Montrose and Perth Harbour’s including road and rail links.

Seagreen Wind Energy Limited (548142) has indicated support for bullet point one under the Transport section of Policy 3.

Forth Ports PLC (329236 – PLAN713) support the Proposed Strategic Development Plan’s approach to emphasising the importance of the Port of Dundee and the renewable energy industry as a key growth sector.

143 TAYPLAN STRATEGIC DEVELOPMENT PLAN Modifications sought by those submitting representations:

NOTE TO REPORTER: The text in italics in this section has been lifted directly from each individual/organisation’s representation with minor typographical errors corrected.

SEEKING A CHANGE (PORTS – BULLET POINT ONE) Lynne Palmer (443979) • No specific change identified, although consider that Perth Harbour should have a reference within the Proposed Strategic Development Plan.

Forth Ports PLC (329236 – PLAN686) • Transport bullet point 1 should be amended to include industrial and port-related uses, and to support...should also include the renewable energy industry and the low carbon economy.

Forth Ports PLC (329236 – PLAN713) • The Proposed Strategic Development Plan needs to broaden its terminology to ensure that it encompasses the range of manufacturing and industrial uses that should be encouraged within the Port of Dundee, as ‘port-related’ use alone could be interpreted restrictively. • It is important to recognise the Port as the location for importing resources that are not available in the immediate geographical area.

Dr Peter Symon (548525) • "Managing TAYplan's Assets" (p.12) and "Strategic Development Areas" (p.14) should include a reference to the possibility of investigating an expansion of port facilities and infrastructure where necessary to permit modern freight facility development in order to capture a greater share of freight trade associated with containerisation.

SEEKING A CHANGE (INFRASTRUCTURE PROVISION – BULLET POINT TWO) Broughty Ferry Community Council (335193) • Second bullet point. In-particular the consideration that land should be reserved (via local plans) to provide sidings to enable local trains to move aside for express and freight trains.

Royal Burgh of St. Andrews Community Council (453889) • Page 13, Policy 3, Transport.

Change "which is essential to support a shift from reliance on the car and road-based freight and support resource management objectives" to "which is desirable for supporting a shift from reliance on the car and road-based freight or for supporting resource management objectives".

Rail Freight Group (535502) • Rail Freight Group urges Tayplan to give rail freight equal weight to sea freight in managing TAYplan's transport assets - specifically in the page 13 references to safeguarding land at ports and other locations. We suggest that land at Montrose station, Dundee West (see separate RFG representation on Proposed Action Programme 2011), Perth South and around Blackford station also be specifically identified as potentially strategic locations to support resource management objectives and reduced reliance on road-based freight.

144 TAYPLAN STRATEGIC DEVELOPMENT PLAN SEEKING A CHANGE (GENERAL COMMENTS)

Network Rail (347686) • Network Rail Infrastructure Limited request that the SDP provides strategic guidance for LDPs to require development proposals to consider any impact on the use of level crossings and where required to require appropriate mitigation.

Summary of responses (including reasons) by planning authority:

RESPONSES TO REPRESENTATIONS SEEKING A CHANGE

Lynne Palmer (443979) Although Policy 3 (Transport) does not include a direct reference to Perth Harbour, the policy text does refer to “other harbours” which would include Perth.

Forth Ports PLC (329236 – PLAN686); Forth Ports PLC (329236 – PLAN713); and Dr Peter Symon (548525) It is considered that there is no requirement to modify the Proposed Strategic Plan to include the term ‘industrial’ as well as port-related uses as requested by Forth Ports PLC (329236 – PLAN686). TAYplan considers that Dundee and Montrose Ports are different in terms of their scale and function and therefore a wider ‘industrial’ use would be inappropriate. TAYplan’s Topic Paper 2 ‘Growth Strategy’ (Page 19, Paragraph 7.16) (CL/Doc31) confirms the flexibility which currently exists and which may apply to other harbours if appropriate. This includes the aim to support freight, economic growth – specifically of the offshore renewable energy industry – and tourism.

In terms of comments provided by Dr Peter Symon (548525) TAYplan considers that bullet point two of Policy 3 (Transport) is sufficiently clear and flexible to allow future infrastructure provision of ports. This could also include the expansion of port facilities if required. This is a matter for future Local Development Plans to consider in more detail, therefore there is no requirement to modify the Proposed Plan as requested.

Broughty Ferry Community Council (335193) and Network Rail (347686) TAYplan do not consider the requirement to provide sidings to enable local trains to move aside for express and freight trains or to provide strategic guidance for Local Development Plan’s to require development proposals to consider any impact on the use of level crossings as strategic land-use planning issues or cross boundary issues. The Plan does however more generally set out within the Policy to safeguard land for future infrastructure provision through Local Development Plans. The changes sought by Network Rail (347686) in relation to level crossings is a detailed matter which will be considered further during the preparation of Local Development Plans. The Scottish Government nor Transport Scotland have raised any concern, nor sought any changes, therefore TAYplan does not consider that a modification to Policy 3 is necessary.

Royal Burgh of St. Andrews Community Council (453889) TAYplan considers that Policy 3 (Transport) clearly states that land should be safeguarded which is essential to support a shift from reliance on the car, which meets the requirements of Scottish Planning Policy. It is considered that although the respondent has requested only a minor modification, any change would undermine the current wording of Policy 3 and could have implications for other policies of the Proposed Plan.

Rail Freight Group (535502)- TAYplan considers that bullet point two of Policy 3 (Transport) is sufficiently clear and flexible to allow future infrastructure provision of other modal shifts away from car and road based freight. This could also include rail freight. The Scottish Government nor Transport Scotland have raised any concern, therefore TAYplan does not

145 TAYPLAN STRATEGIC DEVELOPMENT PLAN consider that a modification to Policy 3 is necessary.

In relation to the suggestion by the Rail Freight Group (535502) that land should be identified at a number of locations throughout the TAYplan region for rail freight use, Schedule 4: Issue Number 2: Proposals Map 1 deals with this matter in more detail.

RESPONSE TO REPRESENTATIONS SUPPORTING AS WRITTEN TAYplan welcomes the support for these issues.

CONCLUSION TAYplan considers that the issues raised does not warrant any change to the Proposed Strategic Development Plan (June, 2011) and propose that the elements dealt with in this Schedule 4 Summary of Unresolved Issues remain as written and unchanged. Scottish Government nor any of the Regional Transport Partnership’s has sought any changes to Policy 3 (Transport). The Policy is consistent with Scottish Planning Policy.

Reporter’s conclusions:

Ports 1. In relation to Forth Ports’ concerns, I agree that general manufacturing uses which do not require to use port facilities are often found at ports. However, I also consider that it is important that valuable and scarce port facilities should remain available to those uses which would benefit from them. Retaining the term “port related uses” in the first bullet point of the Transport section of Policy 3 on page 13 need not necessarily prevent more general industrial uses from locating at ports through the development management process, if planning authorities decided they were otherwise acceptable.

2. I consider that the use of ports for renewable energy is already supported by the phrase “ to support freight, economic growth…”. Furthermore, I note that the supporting text on page 12 states that it is important to support the growth of emerging sectors of the economy, such as the off-shore renewable energy sector through the protection of the region’s ports for port related uses. (See also Issue 6).

3. The first Transport bullet point refers to Dundee and Montrose and “other harbours, as appropriate”. I agree with the authority that this would include Perth. In addition, I also agree that the text in the bullet point is sufficient as it stands and would allow future expansion of the ports, if necessary.

Infrastructure provision 4. I agree with the authority that provision of land for railway sidings, rail freight facilities and impact on level crossings are not strategic issues. In any event, I note that there is general provision within Policy 3 for safeguarding land for future infrastructure provision.

5. I do not agree with the representation stating that it will very rarely be possible to establish that infrastructure provision is essential to support modal shift. For example, it would be possible to justify provision of infrastructure at a port for freight handling facilities and that this could replace the need for road-based freight.

Reporter’s recommendations:

No modifications.

146 TAYPLAN STRATEGIC DEVELOPMENT PLAN Policy 3: Managing TAYplan’s Assets – Natural & Historic Issue 11 Assets Page 12: Managing TAYplan’s Assets Development plan Reporter: Supporting Text reference: Karen Heywood Page 13: Policy 3 Natural and Historic Assets Body or person(s) submitting a representation raising the issue (including reference number):

Seeking a change

ID Person/Organisation Representation Number Reference 335193 Broughty Ferry Community Council PLAN4 547239 Forestry Commission Scotland PLAN268 331257 Mountaineering Council of Scotland PLAN851 331257 Mountaineering Council of Scotland PLAN852 328962 Mr Graham Lang PLAN565 548408 Mrs Marion Lang PLAN570 538523 Perth and Kinross Heritage Trust PLAN20 545597 Professor Charles McKean PLAN148 331662 SportScotland PLAN144 547750 St. Andrews Preservation Trust PLAN849

Support as written

ID Person/Organisation Representation Number Reference 423150 Braes of the Carse Conservation Group PLAN23 450585 Methven and District Community Council PLAN865 442031 Scottish Environmental Protection Agency PLAN177 344848 Scottish Natural Heritage PLAN418 344848 Scottish Natural Heritage PLAN420

Provision of the Natural and Historic Assets – this Schedule 4 relates to the three development plan bullet points under the Natural and Historic Assets section of Policy to which the issue 3. relates: Planning authority’s summary of the representation(s):

SUMMARY OF REPRESENTATIONS SEEKING A CHANGE

Broughty Ferry Community Council (335193) consider that high quality bathing waters are economically and aesthetically important, whilst also being important in terms of public health. On this basis, the respondent seek that the quality of the bathing waters in the Tay Estuary and nearby should be mentioned in Policy 3, particularly given the combination of increased development and the impact of climate change which may have negative impacts on the bathing water quality at Broughty Ferry beach and St. Andrews east sands.

Forestry Commission Scotland (547239) are generally supportive of the Proposed Development Plan as it addresses a number of forestry related matters, however the respondent would like to see something relating specifically to SUDS and green networks.

147 TAYPLAN STRATEGIC DEVELOPMENT PLAN SUDS have been seen as stand alone features in the past, but there is an option to include them as part of the green network. The respondent further considers that green networks should not be seen as an option, but more an opportunity to improve and expand our environment for the enjoyment of all.

Mountaineering Council of Scotland (331257 – PLAN851) whilst welcoming the recognition that the landscape asset is important and should not be adversely affected, the respondent seeks a statement within Policy 3 that the identification of environmentally sensitive areas and important natural and historic assets will be progressed as a matter of urgency. In addition, Mountaineering Council of Scotland (331257 – PLAN852) have also indicated that Policy 3 should map valuable landscape assets to ensure a defensible energy infrastructure plan. Mrs Marion Lang (548408) has commented that there is little recognition of the importance of landscape to tourism within the Proposed Strategic Development Plan.

Mr Graham Lang (328962) considers that there are few references to the value of landscape within the Proposed Strategic Development Plan. The respondent is also concerned about the current flood of proposals for windfarms which it is considered is endangering large areas of countryside.

Perth and Kinross Heritage Trust (538523) seek an additional paragraph in Policy 3 stating a commitment to protecting all archaeological and historic sites, whilst indicating that as well as stating the protection of all designated sites, this should also include a commitment to protecting all unscheduled archaeological and historic sites which are identified in Local Authorities Sites and Monuments Record or Historic Environment Record.

Professor Charles McKean (545597) has requested a modification to the second bullet point as the current list is a value-free list implying that everything has an equal impact on everybody. If we lessen the identity of Fife burghs – which has happened in Cupar, St. Andrews, and even the coastal burghs – this is done at our tourist peril.

SportScotland (331662) has requested that an additional site of importance for sport and recreation should be added to this current list of sites within the second bullet as it is considered that the TAYplan area has a range of important sites for outdoor sport and recreation including hills, rivers, beaches, mountain bike trails, coastal footpaths and whitewater rivers. These areas should be protected from development whilst opportunities to access them should also be provided from new development.

St. Andrews Preservation Trust (547750) have commented that TAYplan needs to play its part in preventing global warming effects which would reduce the need to introduce the mitigation measures specified within the Natural and Historic Assets section of Policy 3.

SUMMARY OF REPRESENTATIONS SUPPORTING AS WRITTEN

Scottish Natural Heritage (344848 – PLAN418) support paragraphs 2 and 7 on Page 12, in-particular the references regarding the need to address climate change and the associated emphasis on building-in mitigation and adaptation to climate change.

Scottish Natural Heritage (344848 – PLAN420), Braes of the Carse Conservation Group (423150), Methven and District Community Council (450585) and Scottish Environmental Protection Agency (442031) support the three bullet points under the Natural and Historic Assets section of Policy 3, particularly the references regarding the protection and enhancement of designated sites, habitats, landscapes and networks of green space and safeguarding the undeveloped coastline.

148 TAYPLAN STRATEGIC DEVELOPMENT PLAN Modifications sought by those submitting representations:

NOTE TO REPORTER: The text in italics in this section has been lifted directly from each individual/organisation’s representation with minor typographical errors corrected.

Broughty Ferry Community Council (335193) • An important TAYplan asset, and which is not mentioned, is the quality of the bathing waters in the Tay Estuary and nearby. This issue should be mentioned and given a higher profile.

Forestry Commission Scotland (547239) • Would like to see aspects of green networks etc expanded upon. Useful to include something stating that 'The principles of the Central Scotland Green Network' will be adopted for Tayplan.

Mountaineering Council of Scotland (331257 – PLAN851) • No specific change identified, although considers that a statement should be included within Policy 3 that the identification of environmentally sensitive areas and important natural and historic assets will be progressed as a matter of urgency.

Mountaineering Council of Scotland (331257 – PLAN852) • No specific change identified, although indicate that Policy 3 should map valuable landscape assets to ensure a defensible energy infrastructure plan.

Mrs Marion Lang (548408) • No specific change identified, although is concerned that there is little recognition of the importance of landscape to tourism within the Proposed Strategic Development Plan.

Mr Graham Lang (328962) • Policy 4 - there are few references to the value of landscape. The current flood of proposals for windfarms is endangering large areas of countryside.

Perth and Kinross Heritage Trust (538523) • In the section: Policy 3 - Managing TAYplan's Assets. Under the heading Natural and Historic Assets, there is no mention of the historic environment. This section should include a paragraph stating a commitment to protecting all archaeological and historical sites. As well as stating the protection of all designated sites this should also include a stated commitment to protecting all unscheduled archaeological and historical sites as identified in the relevant local authorities Sites and Monuments Record or Historic Environment Record.

Professor Charles McKean (545597) • add, bullet-point two under 'understanding and respecting': Add after 'landscapes' the words 'so crucial to the identity of place and the tourist experience of it'.

SportScotland (331662) • SportScotland wishes to see sites of importance for sport and recreation in the outdoors added to the list of sites in the second bullet point.

St Andrews Preservation Trust (547750) • Have indicated that TAYplan needs to play its part in preventing global warming effects which would reduce the need to introduce the mitigation measures specified within the Natural and Historic Assets section of Policy 3. 149 TAYPLAN STRATEGIC DEVELOPMENT PLAN Summary of responses (including reasons) by planning authority:

RESPONSES TO REPRESENTATIONS SEEKING A CHANGE

Broughty Ferry Community Council (335193) Although the comments in relation to bathing water quality are noted, particularly in relation to beaches at Broughty Ferry and St. Andrews, TAYplan do not consider that a specific reference is required in Policy 3 (Natural and Historic Assets). The issue of water quality and population and health was assessed within the Strategic Environmental Assessment (Pages 54-56 and Pages 67-70) (CL/Doc41). The purpose of Strategic Environmental Assessment is to ensure that aspects of the environment, such as plants and animals, water quality, historic features, and human health are considered whilst a plan is being prepared in order for it to be modified to avoid or limit harmful environmental effects whilst promoting or increasing positive environmental effects. The Strategic Environmental Assessment also promotes transparency in the development of plans through the involvement of key stakeholders. The key consultation authorities, Historic Scotland, Scottish Environmental Protection Agency and Scottish Natural Heritage have already considered and endorsed TAYplan’s Environmental Report (April 2010) without further modification. The latter two key agencies are supporting Policy 3 as it stands.

Forestry Commission Scotland (547239) The level of detail provided in Policy 3 is appropriate for a strategic planning policy document. Further detail on Sustainable Urban Drainage Systems in-particular is an issue which will be considered within Local Development Plans or during the planning application process. The Proposed Action Programme (CL/Doc37) identifies the preparation of a greenspace strategy (Page 33). The scope of this does not require to be detailed in the Proposed Plan. This will be taken forward in partnership with the key agencies, including the Forestry Commission in preparation for the second Strategic Development Plan.

Mountaineering Council of Scotland (331257 – PLAN851); Mountaineering Council of Scotland (331257 – PLAN 852); Mrs Marion Lang (548408);Mr Graham Lang (328962; and) and Professor Charles McKean (545597) TAYplan considers that the level of detail in Policy 3 is appropriate for a strategic planning policy document. Policy 3, bullet point two, specifies landscapes as an important consideration in the assessment of development suitability. Further detail on landscapes is an issue which will be considered within Local Development Plans or during the planning application process.

SportScotland (331662) TAYplan acknowledge the importance of access to sites for outdoor sport and recreation, however the inclusion of a specific reference to such sites is not required. Policy 2: Shaping Better Quality Places (Proposed Plan, Page 11, Part F) brings out further information on access in general and more specifically on integrating networks. There is no need to replicate this information within Policy 3.

St. Andrews Preservation Trust (547750 Topic Paper 3: Resources and Climate Change (June 2011) (Page 11, Paragraph 5.15) (CL/Doc32)considers that applying a blanket ban on development in order to safeguard natural and historic assets would be impractical given the important role these assets play in place shaping and the region’s social, economic and environmental future. Policy 3 therefore safeguards natural and historic assets and development will only be permitted where it would not adversely impact upon but preferably enhance these assets. This recognises that some development can be appropriate and bring advantages that improve the quality of such sensitive areas (Topic Paper 3: Resources and Climate Change (June 2011) (Page 18, Paragraph 7.13) (CL/Doc32).

In relation to ‘global warming’, the Proposed Plan’s Vision seeks to switch to a low carbon

150 TAYPLAN STRATEGIC DEVELOPMENT PLAN and zero waste economy by providing for appropriate infrastructure and improvements in the resilience to climate change and other potential risks. In addition, the Proposed Plan’s Vision also seeks to promote a shift towards non-car travel, support cycling and walking, ensuring new development makes best use of existing networks and infrastructure whilst design-in at the outset to achieve high resource efficiency standards. TAYplan is clearly committed to ensuring global warming effects are reduced within the Proposed Plan as specified in Scottish Planning Policy (Pages 8-9, Paragraphs 41-44) (CL/Doc2) and Climate Change (Scotland) Act 2009(CL/Doc13). TAYplan disagrees with the comments provided by the respondent and considers that no further detail is required.

RESPONSE TO REPRESENTATIONS SUPPORTING AS WRITTEN

TAYplan welcomes the support for these issues.

CONCLUSION

TAYplan considers that the issues raised does not warrant any change to the Proposed Strategic Development Plan (June, 2011) and propose that the elements dealt with in this Schedule 4 Summary of Unresolved Issues remain as written and unchanged. Policy 3 (Natural and Historic Assets) has been developed working in partnership with the key agencies. Of these Key Agencies, only Forestry Commission Scotland (547239) are seeking a minor change to the policy, whilst others are explicitly supporting it. The Policy is consistent with Scottish Planning Policy. Therefore, a change to Policy 3 could undermine this approach which has ensured the exact policy wording is in agreement with the Key Agencies.

Reporter’s conclusions:

1. With reference to bathing water quality, the Scottish Environment Protection Agency, which is the key agency concerned with implementation of the European Commission Bathing Water Directive, has not expressed any concerns about Policy 3. Consequently, I do not consider that it needs to be amended.

2. I consider that the terms of the Natural and Historic Assets section of Policy 3 are sufficient to ensure that local development plans take landscapes into account in setting the policy context for development.

3. I agree with the authority that it is not necessary to refer to sites for outdoor recreation in Policy 3. The Natural and Historic Assets section of the policy requires local development plans to safeguard such natural assets, which will also safeguard their use for recreational purposes. In addition, Policy 2 part A requires green infrastructure and spaces to be identified, retained and enhanced. Part F of Policy 2 ensures that development incorporates and enhances natural and historic assets.

4. One of TAYplan’s objectives is to “Support the switch to a low carbon and zero waste economy by providing for appropriate infrastructure and improvements in our resilience to climate change and other potential risks”. However, it is unrealistic to consider that this will be achieved with no development. Consequently, Policy 3, and, in particular, the Natural and Historic Assets section of the policy, is necessary to ensure these assets are safeguarded.

5. Perth and Kinross Heritage Trust alleges that Policy 3 does not mention the historic environment. However, the second bullet point of the Natural and Historic Assets section

151 TAYPLAN STRATEGIC DEVELOPMENT PLAN mentions parks, townscapes, archaeology, historic buildings and monuments. The definition of such assets at the bottom of the page refers to ancient monuments, archaeological sites and landscape, historic buildings, townscapes, parks, gardens and other designed landscape and other features, which includes but is not restricted to designated buildings or areas.

Note: The representation made by Forestry Commission Scotland (PLAN268) refers to a change to Policy 2 Part A (ii) and concerns SUDS and green networks. This has been dealt with under Issue 5, which deals with representations about Policy 2.

Reporter’s recommendations:

No modifications.

152 TAYPLAN STRATEGIC DEVELOPMENT PLAN

Issue 12 Policy 4 Strategic Development Areas Part A

Development plan Reporter: Page 15: Policy 4 Part A reference: Scott Ferrie Body or person(s) submitting a representation raising the issue (including reference number):

Seeking a change

ID Representation Number Person/Organisation Reference 548889 Alaric Hopgood PLAN825 & 827 442149 Bidwells for Zurich Assurance Ltd PLAN669 545660 Colin McAllister PLAN149 337727 Colliers International for Gleneagles Hotel PLAN57 541485 Colliers International for Lawrie & Symington Ltd PLAN349 450613 Councillor Michael A Barnacle PLAN815 513279 D Graham Wynd PLAN505 527724 David Dykes PLAN474 346407 DG Coutts for Linlathen Developments PLAN284, 286 & 289 548390 DG Coutts for Margaret Swanney PLAN562 548169 DPP LLP for Shell UK Ltd PLAN442 548364 Dr Mary Campbell-Brown PLAN549 548525 Dr Peter Symon PLAN899 445206 Emac Planning for JG Lang PLAN539 542815 Flora Selwyn PLAN79 & 80 329236 Forth Ports PLC PLAN688, 693 & 713 328962 Graham Lang PLAN565 543112 GS Brown Construction PLAN89 547268 GVA Grimley Ltd for David Wilson Homes PLAN450 548159 GVA Grimley Ltd for Land Securities PLAN465 377771 Henry Paul PLAN475 546652 Howard Greenwell PLAN258 547693 Irene Duncan PLAN294 545391 Mrs Jennifer Byrne PLAN140 348875 Mrs Jennifer Hopgood PLAN600, 792 & 794 377831 Mrs Judith Harding PLAN 501, 502 & 504 346689 Karen Clark Planning for Discovery Homes PLAN203 544315 Miss Marianne Baird PLAN112 & 293 548408 Marion Lang PLAN567 & 570 450585 Methven & District Community Council PLAN868 349140 Montgomery Forgan Associates for Headon PLAN615 & 618 Developments Ltd 349134 Montgomery Forgan Associates for VGH PLAN577 (VICO Ltd/Bett Homes/Headon Developments) 443846 Mr KC Fraser PLAN561 543388 Mrs Anne Tynte-Irvine PLAN93

153 TAYPLAN STRATEGIC DEVELOPMENT PLAN 344887 Penelope Uprichard PLAN878 548708 Philip Anthony Hardie PLAN798 545597 Professor Charles McKean PLAN148 442290 Rossco Properties PLAN162 & 163 548419 Roy de C Chapman PLAN585 453889 Royal Burgh of St. Andrews Community Council PLAN922 330884 Rydens for Bon Accord Land Ltd/Stewart Milne Homes PLAN127 548506 Rydens for University of St. Andrews PLAN748 & 751 548386 Miss Sarah Hunt PLAN545 547750 St. Andrews Preservation Trust PLAN304 & 843 539251 Stewart Milne Homes PLAN326 546153 Strathkiness Community Council PLAN190 541352 Mrs Wendy Bayliss PLAN559

Support as Written

ID Representation Number Person/Organisation Reference 419429 Auchterarder & District Community Council PLAN100 443109 Barton Willmore for Scotia Homes PLAN381 548499 Chris Addison-Scott PLAN689 541485 Colliers International for Lawrie & Symington Ltd PLAN346 & 348 548948 Hargest Planning Ltd for Macdonald Estates PLC PLAN858 443912 Montagu Evans for Inverarity Farms Ltd PLAN360 349134 Montgomery Forgan Associates for VGH (VICO Ltd/Bett PLAN576 Homes/Headon Developments) 547933 Savills for Pilkington Trust PLAN620 344939 Scottish Enterprise PLAN426 442031 Scottish Environmental Protection Agency PLAN178 & 179 344848 Scottish Natural Heritage PLAN421 441235 Tactran Regional Transport Partnership PLAN123

Provision of the development plan The identification of strategic development areas and allocation of land to which the issue uses for each site. relates: Planning authority’s summary of the representation(s):

SUMMARY OF REPRESENTATIONS SEEKING A CHANGE

CUPAR NORTH STRATEGIC DEVELOPMENT AREA

Stewart Milne Homes (539251) and Mrs Wendy Bayliss (541352) Neither are supportive of the proposed Strategic Development Area at Cupar North for 1,400 homes, 10 hectares of employment land and bulky goods retail. Stewart Milne Homes (539251) considers that for the first 5 years of the Proposed Plan the infrastructure costs to deliver the site are too high, while Mrs Wendy Bayliss (541352) considers that development at the location will spoil the landscape setting.

Montgomery Forgan Associates for VGH (VICO Ltd/Bett Homes/Headon Developments) (349134) considers the figure of 1,400 homes for the site to be too low and that a higher figure is required to justify the requirement for key infrastructure improvements.

154 TAYPLAN STRATEGIC DEVELOPMENT PLAN Emac Planning for JG Lang & Son (445206) expresses concern regarding the Cupar North Strategic Development Area especially within the anticipated time period. A more generous supply of sites is required for other settlements within North East Fife e.g. Springfield to meet the demand.

DUNDEE’S STRATEGIC DEVELOPMENT AREAS

DG Coutts for Linlathen Developments (346407); DG Coutts for Margaret Swanney (548390) and Karen Clark Planning for Discovery Homes (346689) Questions the selection of Dundee Western Gateway as a Strategic Development Area for Dundee as site is still constrained and has not been developed for past 18 years. It still has a Section 75 Legal Agreement to sign some 6 years after the Local Authority were minded to approve a planning application. As a result the developers can also hold the Local Authority to ransom and prevent other sites coming forward as a result. Karen Clark Planning for Discovery Homes (346689) believes that release of land for housing at east Dundee will not impact on the Strategic Development Area at Western Gateway as it will provide choice, minimise traffic movement and will ensure sustainable access to employment.

Forth Ports PLC (329236) believes that the proposed Dundee Centre & Port Strategic Development Area should allow for mixed use development, including employment land, manufacturing and port related uses. The term port related uses may be regarded as somewhat restrictive and should encompass manufacturing and industrial uses as well.

GVA Grimley for Land Securities (548159) considers that Dundee Waterfront is the most important Strategic Development Area within the city region and the Plan should say more to recognise the importance of the Waterfront regeneration proposal to achieving a successful and well integrated city centre and adding to the regions economy.

FORFAR STRATEGIC DEVELOPMENT AREA

Colliers International for Lawrie & Symington Ltd (541485) A development framework for the proposed Forfar Regional Agricultural Service Centre is required prior to any development and this should involve input from the Council, agencies and local businesses.

PERTH’S STRATEGIC DEVELOPMENT AREAS

Bidwell’s for Zurich Assurance Ltd (442149); Councillor Michael A Barnacle (450613); David Dykes (527724); GS Brown Construction (543112); GVA Grimley Ltd for David Wilson Homes (547268); Methven & District Community Council (450585) and Rossco Properties (442290) All have issues regarding the proposed Strategic Development Areas at West/North West Perth. Bidwell’s for Zurich Assurance Ltd (442149) consider the Strategic Development Area to be excessive in terms of housing numbers and the required A9/A85 junction improvements are overly reliant on funding coming from developers of the Strategic Development Areas. Councillor Michael A Barnacle (450613) is opposed to the Perth West site while GS Brown Construction (543112), GVA Grimley Ltd for David Wilson Homes (547268) and Rossco Properties (442290) questions the deliverability of the sites due to infrastructure and funding constraints especially education and transport. David Dykes (5277240) thinks there should be more definite detail on the housing numbers as there is for the Oudenarde Strategic Development Area. Methven & District Community Council (450585) considers that the Perth West/North West Strategic Development Area should not include the floodable terraces of the River Almond. DPP LLP for Shell UK Ltd (548169); Dr Peter Symon (548525) and GS Brown Construction (543112) express concerns regarding the Oudenarde Strategic Development Area. DPP LLP for Shell UK Ltd (548169) considers the level of development proposed at Oudenarde SDA is now too high 155 TAYPLAN STRATEGIC DEVELOPMENT PLAN and it should accord with approved masterplan for the site and should be in accordance with Health & Safety Executive's PADHI guidelines as a Shell UK gas pipe line runs through the site. Dr Peter Symon (548525) considers that the Oudenarde Strategic Development Area should be excluded as it is located on a floodplain. GS Brown Construction (543112) questions the deliverability of the site due to infrastructure constraints especially education and transport.

ST. ANDREWS STRATEGIC DEVELOPMENT AREA

Miss Marianne Baird (544315); Mr KC Fraser (443846); Mrs Anne Tynte-Irvine (543388); Penelope Uprichard (344887); Professor Charles McKean (545597); Roy de C Chapman (548419); Royal Burgh of St. Andrews Community Council (453889); Miss Sarah Hunt (548386); St. Andrews Preservation Trust (547750); Strathkiness Community Council (546153); Mrs Wendy Bayliss (541352); Alaric Hopgood (548889); Colin McAllister (545660); D Graham Wynd (513279); Dr Mary Campbell Brown (548364); Flora Selwyn (542815); Henry Paul (377771); Howard Greenwell (546652); Irene Duncan (547693); Mrs Jennifer Byrne (5453910); Mrs Jennifer Hopgood (348875) and Mrs Judith Harding (377831) All object to the inclusion of the St. Andrews Strategic Development Area in the Proposed Plan for the following number of reasons: A. It is considered that it will have an adverse impact on the proposed greenbelt for the town and it does not take account of the Tyldesley & Grant Landscape and Green Belt Assessment carried out on behalf of Fife Council. B. There are a number of brownfield sites within the town that could accommodate some of the development before any greenfield land is developed. C. The proposed housing number of 1,090 homes is based on outdated and flawed population figures stemming from the 2002 Fife Structure Plan. D. There has never been any justification of the need for the number of dwellings proposed especially within the current economic climate. E. It will have an adverse impact on the landscape and potential tourism. F. No impact study carried out on impact of proposed housing on the town or tourism. G. It will have an adverse impact on the towns setting and the surrounding countryside. H. The proposed housing numbers are too high as town has reached saturation point. I. Its viability is impacted by a lack of funding for infrastructure. J. It will place a strain on the road infrastructure especially through Strathkiness. K. It should not be included until an up to date assessment of current economic conditions, the situation at Leuchars Air base and St. Andrews purchase of the former paper mill at Guardbridge is carried out. L. It will harm the reputation of St. Andrews. M. There is no landscape assessment of the site and TAYplan is insensitive to the uniqueness of St. Andrews. N. Sites from the Fife Structure Plan should not be included until a reassessment of the General Register of Scotland’s (GROS) figures is carried out. O. Site is unrealistic and surplus to requirements as a representative town survey in 2010/2011 showed that there were 11% of the town’s dwellings vacant and there is available land at the old hospital site and surrounding area. P. It will destroy the historic setting of the town. Q. It is contradictory to the Climate Change (Scotland) 2009 Act as over 800 pupils will have to travel in from Tay Bridge settlements. R. It will not help St. Andrews reputation as the home of golf. S. No alternative sites have been considered. T. No need for Science Park development as University now on former paper mill at Guardbridge. U. There has been no ecological justification of the Strategic Development Area.

156 TAYPLAN STRATEGIC DEVELOPMENT PLAN Montgomery Forgan Associates for Headon Developments Ltd (349140) and Rydens for University of St. Andrews (548506) Both consider the term Science Park to be too restrictive and it should be Science/Research/University Park. The housing number of 1,090 dwellings should be the minimum number of dwellings and advocates a higher number so as to be consistent with other Strategic Development Areas e.g. Perth West/North West.

Philip Anthony Hardie (548708) and Alaric Hopgood (548889) Both do not agree that St. Andrews acts as an economic driver for Fife. Philip Anthony Hardie (349140) considers that the proposed housing numbers will not result in a rebirth of Fifes economy and if St. Andrews does expand a bypass will be required. Alaric Hopgood (548889) considers that St. Andrews is not supported by appropriately planned infrastructure.

Colliers International for Gleneagles Hotel (337727) Does not agree with focussing emphasis of St. Andrews international importance for golf in the region. There is no mention of Carnoustie or Gleneagles who have respectively hosted the British Open and will be hosting the Ryder Cup in 2014.

GENERAL DG Coutts for Linlathen Developments (346407); Graham Lang (328962) and Marion Lang (548408) Have issues with all the proposed Strategic Development Areas. DG Coutts for Linlathen Developments (346407) is supportive of Dundee and Perth as the main areas of growth but considers the proposed Strategic Development Area's to be poorly thought out and rely on sites with a history of failure.

Rossco Properties (442290) Considers that the emphasis on Strategic Development Area's is incorrect. More account should be taken of other locations with potential to expand e.g. Dunning.

Rydens for Bon Accord Land Ltd/Stewart Milne Homes (330884) Considers that more Strategic Development Areas should be identified on the edge of settlements other than Perth or Dundee.

SUMMARY OF REPRESENTATIONS SUPPORTING AS WRITTEN

Chris Addison-Scott (548499) and Montgomery Forgan Associates for VGH (VICO Ltd/Bett Homes/Headon Developments) (349134) Both are supportive of the Cupar North Strategic Development Area. Chris Addison-Scott (548499) believes that the provision of a relief road (funded mainly by developer contributions) will help reduce congestion and associated issues within Cupar itself and Montgomery Forgan Associates for VGH (349134) believes it will allow other proposals for the area to advance with support from TAYplan.

Montagu Evans for Inverarity Farms Ltd (443912) supports the proposed Dundee Western Gateway Strategic Development Area especially at South Gray which has an extant planning consent for the development of 230 dwellings.

Colliers International for Lawrie & Symington Ltd (541485) and Barton Willmore for Scotia Homes (443109) Both support the recognition of Forfar being identified as a 'Regional Agricultural Service Centre.'

Savills for Pilkington Trust (547933) supports the proposed Strategic Development Area at West/North West Perth especially at Almond Valley as it is an effective site which can contribute to sustainable economic growth.

157 TAYPLAN STRATEGIC DEVELOPMENT PLAN Hargest Planning Ltd for Macdonald Estates PLC (548948) supports the St. Andrews Strategic Development Area as the principle has been identified in the approved Fife Structure Plan (2009) and is identified in the St. Andrews Local Plan.

Auchterarder & District Community Council (419429); Scottish Enterprise (344939); Scottish Environmental Protection Agency (442031); Scottish Natural Heritage (344848) and Tactran Regional Transport Partnership (441235); All supportive of the policy and supporting text. Scottish Enterprise (344939) states that it accords with their priorities. Scottish Environmental Protection Agency (442031) adds that all Strategic Development Areas will require flood risk assessments.

Modifications sought by those submitting representations:

CUPAR NORTH STRATEGIC DEVELOPMENT AREA Emac Planning for JG Lang & Son (445206) requests that a more generous housing supply is required for other settlements within NE Fife e.g. Springfield because of questions over the deliverability of Cupar North during the Plan period.

Montgomery Forgan Associates for VGH (VICO Ltd/Bett Homes/Headon Developments) (349134) requests that the Cupar North housing figure of 1,400 homes should be reworded to 1,400+ so that additional units can be supported to justify the requirement for key infrastructure improvements.

DUNDEE’S STRATEGIC DEVELOPMENT AREAS DG Coutts for Linlathen Developments (346407); DG Coutts for Margaret Swanney (548390) and Karen Clark Planning for Discovery Homes (346689) requests that alternative Strategic Development Area's with more realistic development prospects be identified for the Plan especially at East Dundee.

Forth Ports PLC (329236) requests that the proposed Dundee Centre & Port Strategic Development Area should be amended to allow for mixed use development, including employment land, manufacturing and port related uses. The term port related uses is regarded as somewhat restrictive and should encompass industrial uses as well.

FORFAR STRATEGIC DEVELOPMENT AREA

Colliers International for Lawrie & Symington Ltd (541485) requests that a development framework for the proposed Forfar Regional Agricultural Service Centre is completed prior to any development.

PERTH’S STRATEGIC DEVELOPMENT AREAS Bidwell’s for Zurich Assurance Ltd (442149) request that half of the housing numbers earmarked for West/North West Perth Strategic Development Areas should be reallocated to other areas within the Perth Core Area.

David Dykes (527724) requests that there is more detail on the housing numbers for the West/North West Perth Strategic Development Areas as there is for the Oudenarde Strategic Development Area.

DPP LLP for Shell UK Ltd (548169) requests that the level of development proposed at Oudenarde Strategic Development Area is reconsidered as it is now too high and may not accord with Health & Safety Executive's PADHI guidelines as a Shell UK gas pipe line runs through the site.

158 TAYPLAN STRATEGIC DEVELOPMENT PLAN ST. ANDREWS STRATEGIC DEVELOPMENT AREA

Miss Marianne Baird (544315); Mr KC Fraser (443846); Mrs Anne Tynte-Irvine (543388); Penelope Uprichard (344887); Roy de C Chapman (548419); Royal Burgh of St. Andrews Community Council (453889); Miss Sarah Hunt (548386); St. Andrews Preservation Trust (547750); Strathkiness Community Council (546153); Alaric Hopgood (548889); Colin McAllister (545660); D Graham Wynd (513279); Dr Mary Campbell Brown (548364); Flora Selwyn (542815); Henry Paul (377771); Howard Greenwell (546652); Irene Duncan (547693); Mrs Jennifer Byrne (5453910); Mrs Jennifer Hopgood (348875); Mrs Judith Harding (377831); Professor Charles McKean (545597) and Mrs Wendy Bayliss (541352) All request that the St. Andrews Strategic Development Area is deleted as a site for development from the Proposed Plan. Professor Charles McKean (545597) requests that the St. Andrews Strategic Development Area is removed from the Proposed Plan or postponed until after a landscape assessment is carried out or the green belt is implemented. Mrs Wendy Bayliss (541352) requests that the St. Andrews Strategic Development Area is removed from the Proposed Plan until there is an up to date assessment of current economic conditions, the situation of RAF Leuchars and St. Andrews University purchase of the former paper mill at Guardbridge.

Rydens for University of St. Andrews (548506) request that the proposed Science Park as part of the St. Andrews Strategic Development Area is reworded to include Science/Research/University Park to more accurately reflect the range of activities likely to take place.

Rydens for University of St. Andrews (548506) request that the proposed 1,090 homes as part of the St. Andrews Strategic Development Area is revised to say 1,090+ homes so that it will be consistent with the approved Fife Structure Plan.

Alaric Hopgood (548889) and D Graham Wynd (513279) requests that St. Andrews is not designated as the economic driver for Fife.

Mrs Jennifer Hopgood (348875) requests that the housing land requirement for St. Andrews is reviewed prior to any strategic allocation.

GENERAL

Rossco Properties (442290) requests that more account should be taken of other locations with potential to expand e.g. Dunning.

Rydens for Bon Accord Land Ltd/Stewart Milne Homes (330884) requests that further Strategic Development Areas should be identified on the edge of settlements other than Perth or Dundee.

Summary of responses (including reasons) by planning authority:

RESPONSES TO REPRESENTATIONS SEEKING A CHANGE

CUPAR NORTH STRATEGIC DEVELOPMENT AREA

Issue raised by EMAC Planning for JG Lang & Son (445206) Settlements such as Springfield in north east Fife are too small to accommodate Strategic Development Areas as they do not have the capacity or existing infrastructure to accommodate large scale development and would in effect lead to the creation of a new settlement. The Finalised St.

159 TAYPLAN STRATEGIC DEVELOPMENT PLAN Andrews & East Fife Local Plan 2009 (CL/Doc40), which is currently undergoing examination, has allocated sites within small villages such as Springfield that are appropriate to the size and nature of the settlement. On this basis there is no need for TAYplan to consider additional sites for any smaller settlements within the TAYplan region and this is a role for the Local Development Plans.

Issue raised by Montgomery Forgan Associates for VGH (VICO Ltd/Bett Homes/Headon Developments) (349134) The Strategic Development Area of Cupar North is an allocated site in the approved Fife Structure Plan 2009 (CL/Doc39), that has gone through a series of assessments before any housing figures were arrived at. The figure of 1,400 homes is seen as an appropriate level of development whilst helping fund the new Relief Road. It will provide certainty and confidence to the local community that no more than 1,400 homes will be developed over the next 20 years. The Strategic Development Area is also allocated in the Finalised St. Andrews and East Fife Local Plan 2009 (CL/Doc40), which is currently undergoing examination and will on adoption form part of the Development Plan.

DUNDEE’S STRATEGIC DEVELOPMENT AREAS

Issue raised by DG Coutts for Linlathen Developments (346407); DG Coutts for Margaret Swanney (548390) and Karen Clark Planning for Discovery Homes (346689) An assessment of strategic sites was undertaken as part of TAYplans Background Technical Note 2010 (pages 119-127) (012/SL/Doc8) to help understand whether they would impact on important environmental designations and any possible infrastructure implications. The sites assessed were a combination of those already allocated in approved Structure Plans or have planning permission or were submitted by developers during the TAYplan Awareness Raising Initial Consultation in August/September 2009. Some of the sites submitted were considered to be too small and not strategic in significance and were therefore not assessed. These could still be assessed as part of the Local Development Plan Process if submitted to the respective Local Authority. The following sites/areas within the Dundee Core Area were assessed. • Ashdownie/Ashludie Farms, Monifieth • Carlogie, Carnoustie • Berryhill Farm, Dundee; • Linlathen, Arbroath Road, Dundee; • Dundee Western Gateway; and • East Dundee Port Rail Freight Facility, Dundee

From these assessments it was considered that Linlathen and Dundee Western Gateway should be brought forward as Strategic Development Areas and East Dundee Port Rail Freight Facility could form part of the existing Dundee and Port Strategic Development Area. Berryhill Farm was found to require significant transport and education infrastructure improvements. It was also not considered as a suitable strategic site because it is located in the countryside with no services. Therefore it is not considered to be an effective or sustainable site. Development at such a location is also considered that it will have an adverse impact on the surrounding landscape. There are known infrastructure issues especially drainage surrounding the sites promoted in Monifieth and Carnoustie leading to issues over their effectiveness during the Strategic Plan period. The TAYplan Topic Paper 2 – Growth Strategy (paragraph 5.24) (012/SL/Doc9) considered that the site at Carnoustie, although large in scale, will only play a significant role locally and if developed would not singularly affect the delivery of the Strategic Development Plan.

Seeking growth in locations outside of Dundee city are considered likely to fuel a growth in road based commuting. This is not consistent with the objectives of the Proposed Plan and is

160 TAYPLAN STRATEGIC DEVELOPMENT PLAN contrary to Policy 1 and has the potential to adversely impact on Policy 3. Policy 5 Part C of the Proposed Plan also helps clarify the presumption against housing land releases in the areas surrounding Dundee. It is not a blanket restriction on housing development and it places the onus on developers/land owners to demonstrate that housing proposals would not prejudice the delivery of Strategic Development Areas or regeneration within the core areas or conflict with other parts of the Strategic Development Plan. However, given the parameters of Policy 1 Part A, of the Proposed Plan the scale of any development in such locations should be small. The non inclusion of the above sites and others within the Dundee Core Area does not represent their deletion or importance and should remain part of the Local Development Plan process.

In addition to this if sites/areas have not been put forward as potential Strategic Development Areas during the Awareness Raising Initial Consultation in August/September 2009 and the Main Issues Report Consultation in 2010, then it is considered that the Proposed Plan stage of the planning process is too late for landowners/agents to be submitting sites for consideration.

Issue raised by Forth Ports PLC (329236) Table 1 of Policy 4 already allows that Dundee Centre & Port Strategic Development Area can comprise of a mixed use development, including business, commercial, leisure, retail residential and port related. The allocation does not specifically restrict the Port area to just port related uses and the supporting text on page 14 (paragraph 5) specifically mentions industrial uses such as offshore renewables for Dundee Port.

FORFAR STRATEGIC DEVELOPMENT AREA

Issue raised by Colliers International for Lawrie & Symington Ltd (541485) Footnote *** on page 15 of the Proposed Plan states that the Forfar Regional Agricultural Service Centre will not require a Development Framework because of the nature of its allocation. There is no specific site or general area earmarked within Forfar. It is the entire settlement that is designated as a Strategic Development Area because of Forfar’s position as a hub to the agricultural industry and the important role it has on the TAYplan economy. As a Regional Agricultural Service Centre it is envisaged that it will support and range of activities and development (existing and new) across the Forfar area. The TAYplan Topic Paper 2 – Growth Strategy (paragraph 7.13) (012/SL/Doc10) confirms that it will be for the Local Development Plan to determine whether a site(s) is required to contribute to this role.

PERTH’S STRATEGIC DEVELOPMENT AREAS

Issue raised by Bidwell’s for Zurich Assurance Ltd (442149) If half of the housing numbers earmarked for West/North West Perth Strategic Development Areas were reallocated to other Strategic Development Areas within the Perth Core Area it would fundamentally undermine both the strategy of growing Perth to the west/north west and concentrating a significant proportion of growth to assist in creating a sustainable expansion and new infrastructure. The housing numbers indicated for Perth West/North West are the approximate numbers required to help ensure the development of the sites will be economically viable and help justify the expected infrastructure requirements including the A9/A85 junction improvements and the proposed new bridge over the River Tay north of Perth. Increasing the housing numbers at the other Perth Strategic Development Areas or other sites within the Perth Core Area would place too much of a load on the sites and surrounding areas in terms of the increased infrastructure requirements and its capacity to accommodate a large increase of housing numbers.

Issue raised by David Dykes (527724) No more detail on the housing numbers for the 161 TAYPLAN STRATEGIC DEVELOPMENT PLAN West/North West Perth Strategic Development Areas is required at this point of the planning process. The indicative numbers of 4,000+ homes for the West/North West Perth Strategic Development Area is considered acceptable until a Strategic Development Framework is produced by Perth & Kinross Council and their Local Development Plan. The Development Framework will provide clear design and scale parameters which will include greater detail on suggested housing numbers and therefore provide greater clarity to potential developers and the public.

Issue raised by DPP LLP for Shell UK Ltd (548169) The land area of the Oudenarde Strategic Development Area is the same size as before. It is just that the development density for housing has been increased from 1,000 units to 1,400 units. An area of land to the south east of the Strategic Development Area is constrained in terms of Health and Safety legislation because of the Shell gas pipeline which runs through it. The Shell pipeline is situated immediately to the east of part of the Strategic Development Area which has a Planning Permission in Principle (08/00610/OUT) (012/SL/Doc11) (subject to a Section 75 Legal Agreement) since March 2009 for employment use. At the time of the planning application Shell Exploration and Production stated they had no objections to the proposal. Condition 18 of the decision notice states that prior to any submission of a detailed application the developer is required to consult with the pipeline operator to ensure that any proposals put forward do not prejudice the safety or integrity of the facility.

ST. ANDREWS STRATEGIC DEVELOPMENT AREA Issue raised by Miss Marianne Baird (544315); Mr KC Fraser (443846); Mrs Anne Tynte- Irvine (543388); Penelope Uprichard (344887); Roy de C Chapman (548419); Royal Burgh of St. Andrews Community Council (453889); Miss Sarah Hunt (548386); St. Andrews Preservation Trust (547750); Strathkiness Community Council (546153); Alaric Hopgood (548889); Colin McAllister (545660); D Graham Wynd (513279); Dr Mary Campbell Brown (548364); Flora Selwyn (542815); Henry Paul (377771); Howard Greenwell (546652); Irene Duncan (547693); Mrs Jennifer Byrne (5453910); Mrs Jennifer Hopgood (348875); Mrs Judith Harding (377831); Professor Charles McKean (545597) and Mrs Wendy Bayliss (541352) National Planning Framework 2 (CL/Doc1) recognises that St. Andrews is an asset to both the national and local economy because of its university and as a tourist destination. TAYplan follows national planning policy with its strategy of focusing that majority of new development in the main towns and cites. For St. Andrews there is a recognised shortage of affordable houses within the town.

The St. Andrews Strategic Development Area is already allocated in the approved Fife Structure Plan 2009 (CL/Doc39) and the Finalised St. Andrews and East Fife Local Plan 2009 (CL/Doc40) which is currently undergoing examination. Because TAYplan will supersede the Fife Structure Plan once adopted it is important that the majority of the existing Strategic Development Areas are included the first TAYplan Strategic Development Plan to ensure continuity and consistency. According to Circular 1/2009 (paragraph 45) (012/SL/Doc12), the Scottish Government considers that it would be good practice to draw from existing Plans within the first generation of Strategic Development Planning Authority. Paragraph 78 of Circular 1/2009 (012/8SL/Doc13) also says that reporters should generally not recommend modifications to parts of plans that have been examined in previous examinations or rolled forward from previous plans, unless circumstances have clearly changed. It is also important to note that the establishment of a Strategic Development Planning Authority and production of the first TAYplan Strategic Development Plan does not mean everything from a land use perspective or land allocation starts from a clean slate. In addition, because there are no significant changes to the Strategic Development Area from the Fife Structure Plan, it is considered that there is no need or requirement to warrant a landscape reassessment being carried out or wait until the green belt has been implemented. 162 TAYPLAN STRATEGIC DEVELOPMENT PLAN 3. The High Court decision by Lord Justice Clerk, Lord Brodie and Lord McEwan on September 7th 2011 (CL/Doc76) dismissed a legal challenge to the Fife Structure Plan 2009 stating that:

The issue of impact on landscape setting and protection/enhancement of key views is an important element of the yet to be produced masterplan for St. Andrews West Strategic Development Area. An independent, assessment of key views from the west of the town to the historic core was carried out to inform the Strategic Development Framework process. This work will help inform the production of the masterplan for the site which will require formal public consultation.

In terms of the future of RAF Leuchars this issue has been dealt with by another Schedule 4 (Issue 13 Policy 4 Strategic Development Areas Alternative Sites). On July 18th 2011, the Secretary of State for Defence, the Rt Hon Dr Liam Fox MP (CL/Doc64) announced to the House of Commons that that RAF Leuchars will close as an RAF station and transfer to the British Army to base two units of and the headquarters for one of the five new multi-role brigades. The gap between the RAF leaving and the Army arriving will affect housing demand in the area. Departing RAF personnel selling properties may well do so prior to the arrival of Army personnel who may otherwise have purchased them. The St. Andrews West and Science Park Strategic Development Area could provide one source of off-base housing within the locality.

It is also important to note that St. Andrews University has confirmed its purchase of the former paper mill at Guardbridge with the intention to develop an Energy Centre with the heat and power piped to St. Andrews Town. The remainder of the site will be developed for related uses such as accommodating spin off companies involved in energy research, community and commercial activities. This development should not compromise the aspirations of the Science Park element of the St. Andrews Strategic Development Area. It is therefore important that the Science park remains part of the Strategic Development Area.

Issue raised by Rydens for University of St. Andrews (548506) There is no need to reword Science Park as part of the St. Andrews Strategic Development Area to include Science/Research/University Park as the term Science Park is flexible enough to not restrict other University related uses such as research facilities/offices. All should fall under the same use class order 4 (Business) (CL/Doc77) which allows such uses as offices (other than that specified under Class 2), research and development of products or processes and light industry.

Issue raised by Rydens for University of St. Andrews (548506) Firstly, the Fife Structure Plan 2009 (CL/Doc39) will be replaced by the Strategic Development Plan once it is approved and secondly, it is an incorrect statement that the Fife Structure Plan says 1,090+ homes for St. Andrews Strategic Development Area. The Structure Plan originally allocated 1,000 homes to form part of the Strategic Development Area with an additional 90 assigned through the St. Andrews and East Fife Local Plan (CL/Doc40) from the 270 unit strategic allocation to the St. Andrews and North East Fife Housing Market Area. As a consequence 163 TAYPLAN STRATEGIC DEVELOPMENT PLAN there is no requirement to modify the 1,090 homes as part of the St. Andrews Strategic Development Area to say 1,090+ homes. This is considered the maximum level of housing required for the location and help fund required infrastructure. It also gives confidence to the community that no more than 1,090 will be developed in the allocated area.

Issue raised by Alaric Hopgood (548889) and D Graham Wynd (513279) St. Andrews is the largest settlement within north east Fife in terms of population size, provision of services and status. Because the largest settlements within a region generally act as the economic driver, St. Andrews because of its size and facilities is the principal town in north east Fife. Its international reputation for its university and as the home of golf along with the 600,000+ visitors it receives annually is not only an economic driver for north east Fife but for the whole of Fife and also the Dundee City Region.

Issue raised by Mrs Jennifer Hopgood (348875) The housing land requirement figures for St. Andrews Strategic Development Area come from the Approved Fife Structure Plan 2009 (CL/Doc39) and this went through a series of robust assessments before arriving at the approved figure of 1,000 homes for the Strategic Development Area. An additional 90 units were assigned from a 270 unit strategic allocation to the St. Andrews and North East Fife Housing Market Area resulting in 1,090 homes being allocated for the Strategic Development Area. The TAYplan Strategic Development Plan, once approved, will replace the existing Fife Structure Plan 2009 (CL/Doc39) and will use the existing approved Structure Plan figures as their base. The scale of the housing land release at St. Andrews West indicates that 1,090 houses are required. This is because there is a development strategy to expand St. Andrews to realise the potential of tourism and the University as an economic driver for Fife. As part of this strategy, land for 1,090 houses has already been identified alongside land identified for academic requirements, science park and employment. The development strategy recognises that this housing development, in addition to meeting housing needs, is a key element of the expansion of this area of St. Andrews, as it will enable the proposed improvement to the University's facilities through the provision of shared infrastructure. Other sites in St. Andrews (including brownfield sites) which come forward for housing, whilst contributing to the housing land supply in the St. Andrews and NE Fife Housing Market Area, will not reduce the requirement for 1,090 houses to be provided as part of the St. Andrews West Strategic Land Allocation. Such sites have been taken into account in identifying the scale of St. Andrews West Strategic Development Area. This has been covered in more detail in another Schedule 4 (Issue 015 Scale and Distribution of Housing.) Any change to the St. Andrews Strategic Development Area would undermine the existing allocation that has been approved at Structure Plan level and more recently at Local Plan level, which is currently undergoing examination. There are no new material considerations relating to the St. Andrews Strategic Development Area and it remains important to the overall strategy.

GENERAL Issue raised by Rossco Properties (442290) Requests that more account should be taken of other locations with potential to expand e.g. Dunning. Settlements such as Dunning are too small to accommodate Strategic Development Areas as they do not have the capacity or infrastructure to accommodate large scale development and would in effect lead to the creation of a new settlement. The Perth & Kinross Local Development Plan which has produced its Main Issues Report 2010 (CL/Doc62) has identified some potential sites within smaller settlements such as Dunning that are considered more appropriate to the size and nature of the settlement. On this basis there is no need for TAYplan to consider additional sites for any smaller settlements within the TAYplan region and this is a role for the Local Development Plans.

Issue raised by Rydens for Bon Accord Land Ltd/Stewart Milne Homes (330884) Most settlements that do not appear in Policy 1 (Location Priorities) of the Proposed Plan are 164 TAYPLAN STRATEGIC DEVELOPMENT PLAN considered too small to accommodate Strategic Development Areas as they do not have the capacity or infrastructure to accommodate large scale development and could in effect lead to the creation of a new settlement. On this basis there is no need for TAYplan to consider additional sites for any smaller settlements within the TAYplan region and this is a role for the Local Development Plans.

RESPONSE TO REPRESENTATIONS SUPPORTING AS WRITTEN

TAYplan notes and welcomes the support for these issues.

CONCLUSION

Any changes or alterations to any of the Strategic Development Areas could fundamentally undermine the existing allocations in each authority as most have been approved at Structure Plan and Local Plan level. All the Strategic Development Areas were approved because they were considered effective sites. Scottish Government considers it good practice to draw from existing Structure Plans with the first generation of Strategic Development Plans and that the reporters generally does not recommend modifications to parts of plans that have been examined in previous examinations or rolled forward from previous plans, unless circumstances have clearly changed. In addition, the establishment of a Strategic Development Planning Authority and production of the first TAYplan Strategic Development Plan does not mean the land allocation process starts from a clean slate.

Because there are no significant changes to the Strategic Development Area from the Fife Structure Plan (CL/Doc39), it is considered that there is no need or requirement to warrant a landscape reassessment being carried out or wait until the green belt has been implemented. TAYplan considers the issues raised do not warrant any change to the Proposed Strategic Development Plan (June, 2011) and propose that the elements dealt with in this Schedule 4 Summary of Unresolved Issues remain as written and unchanged.

Reporter’s conclusions:

General

1. I deal with those matters grouped under the ‘General’ heading first, as issues concerning the principle of strategic development areas are considered there.

2. As is noted within the proposed plan, Scottish Planning Policy requires development plans to identify where strategic development within the plan area ought to take place. Policy 1: Location Priorities sets out a hierarchy of settlements within the plan area and, for a number of stated reasons, directs that new development be provided for in accordance with that hierarchy. I am satisfied generally that the range and distribution of proposed strategic development areas identified in Policy 4A respects the locational priorities established earlier in the proposed plan.

3. There is no clear evidence before me that the proposed strategic development areas either have long-standing histories of failure or are otherwise unlikely to become at least partly effective during the plan period. I will consider the latter in more detail as it relates in particular to the Dundee Western Gateway later. I must also take account of paragraph 78 of Circular 1/2009 – Development Planning, which states amongst other things that parts of the plan which have been rolled forward from previous plans should not be modified unless circumstances have clearly changed. I will consider that matter also in more detail, where appropriate, later.

165 TAYPLAN STRATEGIC DEVELOPMENT PLAN 4. The identification of strategic development areas in or adjacent to smaller settlements, such as Dunning or Auchterarder, would not be consistent with the wider locational priorities of the proposed plan, and would be likely to lead to significant infrastructural and sustainability issues. I agree with the authority however, that it will be for local development plans to identify development opportunities for such settlements, commensurate with the locational priorities of the proposed plan and the ability of those settlements to successfully accommodate such development.

Cupar North Strategic Development Area

5. The proposed Cupar North Strategic Development Area (SDA) is identified as the ‘Cupar North Strategic Land Allocation’ in the approved Fife Structure Plan (2009) and in the finalised St. Andrews and East Fife Local Plan. The latter has undergone examination very recently and the appointed Reporters have not recommended any substantive change to that proposal. I have not been made aware of any clear change in circumstances affecting the proposed SDA and therefore, bearing in mind the terms of paragraph 78 of Circular 1/2009 referred to above, I consider it appropriate that the allocation be rolled forward into the proposed plan.

6. The proposed capacity of 1,400 homes is also consistent with the finalised local plan. Whilst I agree with some representations that the infrastructural requirements for this strategic development area are significant, there is no compelling evidence that they are out of scale to the development proposed, and the authority indicates that it considers the overall proposal to be achievable. I find therefore, that the capacity of the site also stands to be rolled forward into the proposed plan.

7. Having said that, it is not my experience that site capacities established in development plans, and particularly in strategic plans, can realistically be viewed as an irrevocable limitation on the capacity of the site. The eventual capacity of any site can only be established at a much more detailed stage, later in the planning process, and will depend on the precise nature of the development, the site and its surroundings and a range of infrastructural and other issues. The same must apply to consideration of the nature and cost of any infrastructure necessary to mitigate the effects of the development, which is almost certain to change over the plan period, and the precise scale of development required to fund that infrastructure. I consider it appropriate therefore, that that the heading in Table 1 of Policy 4A be amended to read “Type and indicative scale of development”.

8. As I concluded above generally, it will be for local development plans to allocate land for residential development in smaller settlements (such as Springfield), commensurate with the locational priorities of this plan, the capacity of the settlement to absorb such development and within the build rate established in the proposed plan for the respective housing market area.

Dundee Strategic Development Areas

9. I invited the authority to comment on the contention, made in a number of representations, that the Dundee Western Gateway Strategic Development Area is characterised by a history of delivery failure and remains constrained. In particular, I invited the authority to comment on the likely effectiveness of the SDA, together with an outline of the development planning and development management history of the site and any progress made on the ground.

10. In its written response, the authority confirmed that it considers the SDA to be effective; and that Dundee City Council remains committed to its development and continues to assist 166 TAYPLAN STRATEGIC DEVELOPMENT PLAN in the delivery of necessary infrastructure. The SDA is identified in the approved Dundee and Angus Structure Plan (2001) and the adopted Dundee Local Plan Review (2005). Planning permissions for Villages 1 and 2 appear to be dependent on the conclusion of planning obligations which have been pending for some considerable time. Nonetheless, the authority advises that the obligation for Village 2 has now been advanced to a detailed level, and that most of the main elements pertinent to Village 1 are also covered in that obligation. More substantive progress has been made in the case of Village 3, with development on the ground well underway.

11. The authority has provided evidence of important progress being made in the form of the necessary and significant improvement of Dykes of Gray Road by the city council. Modelling work is also stated to be underway on necessary improvements to the Swallow Roundabout, which the city council now intends to undertake in advance of development, the cost of which is intended to be recovered through the planning obligation(s).

12. I am satisfied on the available evidence that the authority undertook a comprehensive assessment of candidate Dundee strategic development areas during preparation of the proposed plan. I am on the whole satisfied, based on the evidence outlined above, that the Dundee Western Gateway SDA is likely to become effective during the lifetime of the proposed plan. It follows that the proposal is appropriate and sufficient and that, in accordance with paragraph 78 of Circular 1/2009, I need not consider other sites or approaches. Other smaller development sites do however, stand to be assessed for inclusion in the local development plan, within the locational priorities of this plan and within the build rate established for the Dundee City housing market area.

13. Policy 4 sets out the type and scale of development proposed for each of the SDAs. For the Dundee Centre and Port SDA, those are stated to be mixed uses, including [my emphasis] business, commercial, leisure, retail, residential and port-related uses. I am satisfied that the prefacing of the uses by “including”, read together with the wide-ranging nature of those uses, leaves appropriate scope for the exact nature of development to be permitted there to be established in the local development plan and through the development management process.

14. Paragraph 14 of Circular 1/2009 states Scottish Ministers’ expectations of strategic development plans to be “concise visionary documents”. In that context I do not consider it necessary or appropriate to include further text on the importance of this SDA and its linkages to the city centre.

Forfar Strategic Development Area

15. The authority explains that the proposed Forfar Regional Agricultural Service Centre SDA is not site or area specific; the whole settlement is designated for its role as an agricultural sector service hub. Topic Paper 2 – Growth Strategy confirms that it will be for the local development plan to determine whether a site-based approach is required to contribute to this role. In these circumstances I agree that a strategic development framework would be inappropriate and that footnote * on page 15 of the proposed plan satisfactorily expresses the position.

Perth Strategic Development Areas

16. The proposed West/North West Perth SDA is located within the Perth Core Area, identified as a Tier 1 settlement in Policy 1: Location Priorities of the proposed plan. Tier 1 settlements are stated to have potential to accommodate the majority of the region’s development over the plan period. The identification of this proposed SDA for 4,000+ homes 167 TAYPLAN STRATEGIC DEVELOPMENT PLAN and 50 hectares of employment land is, in principle, consistent with the locational priorities of the plan.

17. In its response to my further information request on Issue 12, the authority explains that developing Perth in this direction is necessary to accommodate the level of housing required to be provided to meet needs and demand; that such a scale of development can be accommodated within the environmental capacity of the area; and that potential alternative expansion areas are affected by topographical and infrastructural constraints. I am satisfied that there is no clear evidence before me to indicate that the proposed SDA is either insufficient or inappropriate.

18. I agree with the authority that any significant reallocation of housing numbers away from this SDA to elsewhere within the Perth Core Area could compromise the overall locational strategy of the proposed plan and undermine the viability of the SDA as far as the provision of necessary infrastructure is concerned. In any event, there is no clear evidence before me that such a reallocation could be accommodated within the environmental and infrastructural capacity of alternative development locations.

19. I also find the description of the proposed SDA to be adequately expressed. It will be for the local development plan to identify specific sites and their respective capacities in accordance with the requirements of Policy 4 of the proposed plan. It can come as no surprise that a development of the scale proposed here will require significant infrastructural investment to be brought forward. The proposed Action Programme, which is before me but is not subject to this examination, sets out key elements for the delivery of this proposal and is stated by the authority to have the support of the key agencies. It will also be for the local development plan to identify the range of necessary infrastructure in more detail and to establish a mechanism for its delivery. As matters stand there is no detailed evidence before me which would lead me to conclude that the necessary infrastructure could not be supported by the scale of development proposed. In this regard I also draw attention to my findings at paragraph 7 above.

20. The authority’s response to my further information request contains comprehensive information on the River Almond and its flood plain. It advises that such areas (at risk of a 1:200 flood event) do not comprise a significant part of the land likely to be allocated in furtherance of the proposed SDA, and that there is considered to be adequate developable capacity remaining to provide for the scale of development set out in Policy 4A. I have no evidence to dispute that conclusion.

21. A number of representations contend that the capacity of the proposed Oudenarde SDA is likely to be restricted due to flood risk and the presence of a gas pipeline running through the site. The authority advises (in its response to matters raised in Issue 13) that the Scottish Environment Protection Agency has not indicated that there is any significant flood risk at Oudenarde that could cause them to object to its development. I also note that the Strategic Flood Risk Assessment, produced in consultation with SEPA, states that the site can be designed to avoid development in flood risk areas and that, with careful siting and the use of SuDs, there will not be a significant risk from flooding or an increase in flooding elsewhere. In regard to the gas pipeline, the authority indicates that the area of the allocation remains the same as before, but that the proposed density has been increased. The proposed Perth and Kinross Local Development plan has now been published for consultation and indicates, in regard to Oudenarde, that “there will be no increased house numbers within the pipeline consultation zone which covers the eastern part of the site”. I am satisfied overall that there is no evidence that the proposed development capacity cannot be satisfactorily delivered, subject to the detailed guidance of the proposed local development plan and to appropriate consideration at the development management stage. 168 TAYPLAN STRATEGIC DEVELOPMENT PLAN 22. There is no clear evidence before me to lead me to conclude that the necessary infrastructural improvements could not be supported by the scale of development proposed. In this regard I also draw attention to my findings at paragraph 7 above.

St. Andrews Strategic Development Area

23. As noted under the ‘General’ heading above, paragraph 78 of Circular 1/2009 – Development Planning states amongst other things that the person appointed to examine the plan should generally not recommend modifications to parts of the plan that have been examined in previous examinations or rolled forward from previous plans unless circumstances have clearly changed. Paragraph 45 of the circular, referring to the main issues report, states that content being retained from the existing plan should be “identified but with limited discussion”. I would not go so far as to say (as does the authority in its response to representations) that paragraph 45 signifies an indication from the Scottish Government that it would be good practice to draw from existing plans within the first generation of strategic development plans. Indeed, an e-mail from the Scottish Government Built Environment Directorate, attached as appendix 2 to the authority’s response to my further information request, confirms that it would be appropriate to take forward those strategic allocations considered to be effective and still required, but that the authority is not obliged to roll forward the strategies of the previous plan. I agree with that interpretation.

24. The proposed St. Andrews West and Science Park SDA is identified as the ‘St. Andrews West Strategic Land Allocation’ in the relatively recently approved Fife Structure Plan (2009) and in the finalised St. Andrews and East Fife Local Plan. The latter has undergone examination very recently and the appointed Reporters have not recommended any change to the principle of that proposal. The issue of the impact of the proposal on the landscape setting of the town was specifically considered as part of that examination, as were many of the other impacts included in representations to this plan.

25. I agree with the authority that the impact of developments regarding the future use of RAF Leuchars and Guardbridge is unlikely to significantly affect the plan’s strategy. In these circumstances I do not consider that this element of the proposed plan ought to be delayed.

26. I conclude that there is no clear change in circumstances affecting the proposed strategic development area and therefore, bearing in mind the terms of paragraph 78 of Circular 1/2009 referred to above, consider it appropriate that the strategic allocation be rolled forward into the proposed plan.

27. I agree with the authority that there is no need to alter the name of the SDA within the plan as the term ‘science park’ is sufficiently flexible to include university/research developments, which should in any case fall within the same use class. The eventual name, for identification and marketing purposes, of whatever development takes place on site would in any event be a matter for others and would clearly not be dependent on labelling within the plan.

28. The allocation of 1,090 homes is entirely consistent with, and was specifically considered during the examination of, the finalised St. Andrews and East Fife Local Plan. There is no evidence before me to indicate that it would be inappropriate to roll that forward into the plan. I draw attention however, to my findings at paragraph 7 above.

29. The reference, in the ninth paragraph of page 14, to the international reputation of St. Andrews as the home of golf is made in the context of explanatory text in support of the allocation of the SDA. There is no logic, and no merit in the context of a concise plan, of expanding that text to include reference to other golf destinations within the plan area. 169 TAYPLAN STRATEGIC DEVELOPMENT PLAN Reporter’s recommendations:

Modify the proposed plan as follows:

In Policy 4A Table 1, delete the second table heading reading “Type and scale of development” and replace with the following text:

“Type and indicative scale of development”

170 TAYPLAN STRATEGIC DEVELOPMENT PLAN

Issue 13 Policy 4 Strategic Development Areas - Alternative Sites

Development plan Reporter: Pages 14 & 15: Policy 4 and Supporting Text reference: Scott Ferrie Body or person(s) submitting a representation raising the issue (including reference number):

Seeking a change

ID Representation Number Person/Organisation Reference

548889 Alaric Hopgood PLAN827 548151 Andrew McCafferty Associates for GD Strawson & J PLAN443 & 453 Farquharson 545660 Colin McAllister PLAN149 513279 D Graham Wynd PLAN505 346407 DG Coutts for Linlathen Developments PLAN285 548525 Dr Peter Symon PLAN899 548522 Emac Planning for A&J Stephen Ltd./Bett Homes PLAN734 445204 Emac Planning for Angus Estates Ltd. PLAN650 548360 Emac Planning for M Batchelor PLAN533 & 531 548524 Emac Planning for Stewart Milne Homes PLAN778 542815 Flora Selwyn PLAN79 547768 GM Gall PLAN302 543112 GS Brown Construction PLAN89 548389 Halliday Fraser Munro for Barratt Homes PLAN586 546652 Howard Greenwell PLAN257 547693 Irene Duncan PLAN294 546532 Jim Farquharson PLAN796 377831 Mrs Judith Harding PLAN501 327210 JWK Properties PLAN931 443893 Karen Clark Planning for Balmossie Developments Ltd & PLAN529 Messrs David Reid Farmers 544315 Miss Marianne Baird PLAN293 548760 Mrs D Jeffrey PLAN810 442290 Rossco Properties PLAN163 548419 Roy de C Chapman PLAN585 453889 Royal Burgh of St. Andrews Community Council PLAN922 548386 Miss Sarah Hunt PLAN545 444087 Scottish Property Federation PLAN240 & 250 442871 Smiths Gore for Errol Park Estate PLAN634 & 643 328791 St. Andrews Green Belt Forum PLAN356 547750 St. Andrews Preservation Trust PLAN304 & 843 539251 Stewart Milne Homes PLAN316 & 326 547863 PLAN352 Wallace Planning Ltd for National Grid Provision of the development plan The identification of strategic development areas and allocation of land to which the uses for each site. issue relates:

171 TAYPLAN STRATEGIC DEVELOPMENT PLAN Planning authority’s summary of the representation(s):

SUMMARY OF REPRESENTATIONS SEEKING A CHANGE

ALTERNATIVE STRATEGIC DEVELOPMENT AREA– GUARDBRIDGE Alaric Hopgood (548889); Colin McAllister (545660); D Graham Wynd (513279); Flora Selwyn (542815); Howard Greenwell (546652); Irene Duncan (547693); Mrs Judith Harding (377831), Miss Marianne Baird (544315); Roy de C Chapman (548419); Miss Sarah Hunt (548386); St. Andrews Greenbelt Forum (328791) and St. Andrews Preservation Trust (547750) All have expressed their opposition to the St. Andrews Strategic Development Area and have suggested an alternative site of the former paper mill at Guardbridge for a variety of reasons. Alaric Hopgood (548889) and D Graham Wynd (513279) considers that no consideration has been given to the former paper mill at Guardbridge as an alternative site. Colin McAllister (545660), Flora Selwyn (542815), Howard Greenwell (546652), Irene Duncan (547693) and Miss Sarah Hunt (548386) states that the former paper mill is a large brownfield site and is not a greenfield site within the St. Andrews green belt. Judith Harding (377831), Miss Marianne Baird (544315), Roy de C Chapman (548419) St. Andrews Greenbelt Forum (328791) and St. Andrews Preservation Trust (547750) consider that the proposed science park element of the St. Andrews Strategic Development Area should be built at the site of the former paper mill in Guardbridge.

ALTERNATIVE STRATEGIC DEVELOPMENT AREAS– CARSE OF GOWRIE Andrew McCafferty Associates for GD Strawson & J Farquharson (548151); GS Brown Construction (543112); Jim Farquharson (546432) and Smiths Gore for Errol Park Estate (442871) All promote alternative locations within the Carse of Gowrie to be considered as Strategic Development Areas. Andrew McCafferty Associates for GD Strawson & J Farquharson (548151) promotes the development of a new settlement at Horn grange because of the over concentration of site at Perth and Dundee. Proposal is for 3,500 dwelling and 35 hectares of employment land. GS Brown Construction (543112) consider that the Carse of Gowrie is a suitable location for significant development as flooding is not a significant problem to warrant its exclusion. Jim Farquharson (546532) considers that the Carse of Gowrie should be promoted as a development area and as an economic generator for Perth. He considers that there are no flooding issues unlike Perth. Smiths Gore for Errol Park Estate (442871) recommends that Table 1 on page 15 should include a 25ha site at Drums of Ardgaith near Errol for employment uses including a service station. Because of its strategic location between Perth & Dundee on the A90 and also served by a nearby railway line the site should be considered suitable to be a strategic business location.

ALTERNATIVE STRATEGIC DEVELOPMENT AREAS – DUNDEE DG Coutts for Linlathen Developments(346407); EMAC Planning for (A&J Stephen Ltd/Bett Homes (548522); Angus Estates Ltd (445204); M Batchelor (548360); Stewart Milne Homes (548524)); Halliday Fraser Munro for Barratt Homes (548389); Karen Clark Planning for Balmossie Developments Ltd & Messrs David Reid Farmers (443893); Scottish Property Federation (444087) and Stewart Milne Homes (539251)All promote alternative locations or sites on the edge of or surrounding Dundee City to be considered as Strategic Development Areas. DG Coutts for Linlathen Developments (346407) considers that all Strategic Development Areas need to be free from constraints and indicates that there are unconstrained sites at east and north Dundee and in the surrounding settlements. Emac Planning for A&J Stephen Ltd/Bett Homes (548522) suggests that there are effective sites at north west Dundee especially Birkhill as it unlikely that the Dundee Western Gateway Strategic Development Area will come forward in the

172 TAYPLAN STRATEGIC DEVELOPMENT PLAN early part of the Plan. Emac Planning for Angus Estates Ltd (445204) promotes Carnoustie as an alternative location for large scale development. Emac Planning for M Batchelor (548360) Promotes greenfield sites at north and north east Dundee including at Ballumbie North in Angus as it has a clear association with Dundee, and is a proven market area. Emac Planning for Stewart Milne Homes (539251) promotes additional land release at north east Ballumbie/Duntrune as an alternative to the Western Gateway Strategic Development Area. Halliday Fraser Munro for Barratt Homes (548389) promote Monifieth North as a Strategic Development Area for mixed use including retail as it is in a highly sustainable location and can provide much needed housing land for Monifieth. There have been very few housing allocations in recent development plans yet the sites that have been allocated none have been developed. Karen Clark Planning for Balmossie Developments Ltd & Messrs David Reid Farmers (443893) questions the effectiveness of some sites allocated and the impact of non/delayed delivery will have on housing supply. Other allocations should be considered especially at east Dundee which is a sustainable location. Scottish Property Federation (444087) promotes further strategic sites in north and east Dundee as proposed sites such as Dundee Western Gateway and Oudenarde could remain constrained and therefore cannot guarantee any stimulus to economic growth. Stewart Milne Homes (539251) supports land release at eastern end of Dundee City as an alternative area for housing development.

ALTERNATIVE STRATEGIC DEVELOPMENT SITE – OTHER SITES

Alaric Hopgood (548889); Dr Peter Symon (548525); GM Gall (547768); JWK Properties (327210); Mrs D Jefferey (548760); Rossco Properties (442290); Stewart Milne Homes (539251) and Wallace Planning Ltd for National Grid (547863) All promote sites/locations within the TAYplan area to be considered as Strategic Development Areas. Alaric Hopgood (548889) promotes RAF Leuchars as an alternative site to St. Andrews Strategic Development Area. Dr Peter Symon (548525) recommends that the Oudenarde Strategic Development Area is replaced by a site in Kinross as it is in a more sustainable location that does not flood. GM Gall (547768) recommends Kinloch Rannoch as area where further development should be considered as it has a rail station and surrounding land is of lower production potential than that surrounding Dundee and St. Andrews. JWK Properties (327210) and Mrs D Jeffrey (548760) both promote Craigend (near Methven) as a new village instead of some of the West/North West Perth Sites which are constrained and have funding issues. The site is considered sustainable and developer has pledged to fund all infrastructure requirements including a new school. If the site is discounted the opportunity will be lost by the Local Authority. Rossco Properties (442290) considers that an additional/alternative area for future employment development in Perth is land east of Friarton Bridge. Stewart Milne Homes (539251) consider that Auchterarder should be identified as a Strategic Development Area. Wallace Planning Ltd for National Grid (547863) Recommends that "Dundee Centre and Port Strategic Development Area" should include "Dock Street". The gas holder site is promoted as location for future retail development as is supported by the current Local Plan.

Modifications sought by those submitting representations:

NOTE TO REPORTER: The text in italics in this section has been lifted directly from each individual/organisation’s representation with minor typographical errors corrected.

ALTERNATIVE STRATEGIC DEVELOPMENT AREAS– GUARDBRIDGE Alaric Hopgood (548889); Colin McAllister (545660); D Graham Wynd (513279); Flora Selwyn (542815); Howard Greenwell (546652); Irene Duncan (547693); Mrs Judith

173 TAYPLAN STRATEGIC DEVELOPMENT PLAN Harding (377831), Miss Marianne Baird (544315); Roy de C Chapman (548419); Miss Sarah Hunt (548386); St. Andrews Greenbelt Forum (328791) and St. Andrews Preservation Trust (547750) All request that the former paper mill at Guardbridge is considered as an alternative location to the St. Andrews Strategic Development Area and in particular as the location for the proposed Science Park element of the Strategic Development Area.

ALTERNATIVE STRATEGIC DEVELOPMENT AREAS– CARSE OF GOWRIE

Andrew McCafferty Associates for GD Strawson & J Farquharson (548151); GS Brown Construction (543112); Jim Farquharson (546432) and Smiths Gore for Errol Park Estate (442871): All request that the Carse of Gowrie area is considered for large scale strategic development and in particular at the following locations. • Andrew McCafferty Associates for GD Strawson & J Farquharson (548151) promote Horn Grange, Errol for 3,500 homes and 35 hectares of employment land. • Smiths Gore for Errol Park Estate (442871) promotes land at Drums of Ardgaith (near Errol) for 25 hectares of employment land including a service station.

ALTERNATIVE STRATEGIC DEVELOPMENT AREAS – DUNDEE

DG Coutts for Linlathen Developments(346407); EMAC Planning for A&J Stephen Ltd/Bett Homes (548522); Emac Planning for (Angus Estates Ltd (445204); M Batchelor (548360);Stewart Milne Homes (548524)); Halliday Fraser Munro for Barratt Homes (548389); Karen Clark Planning for Balmossie Developments Ltd & Messrs David Reid Farmers (443893); Scottish Property Federation (444087) and Stewart Milne Homes (539251) All request that certain areas/locations surrounding or near to Dundee are considered to be alternative Strategic Development Areas for future large scale development.

ALTERNATIVE STRATEGIC DEVELOPMENT SITE – OTHER SITES

Alaric Hopgood (54889) requests that RAF Leuchars is considered as an alternative site to St. Andrews Strategic Development Area.

Dr Peter Symon (548525) requests that the Oudenarde Strategic Development Area is replaced by a site in Kinross as it is in a more sustainable location that does not flood.

GM Gall (547768) requests that Kinloch Rannoch is considered as an alternative Strategic Development Area to Dundee and St. Andrews.

JWK Properties (327210) and Mrs D Jeffrey (548760) request that Craigend (near Methven) is considered as a suitable location for a new village instead of some of the West/North West Perth sites.

Rossco Properties (442290) requests that consideration is given to land east of Friarton Bridge in Perth as an additional/alternative area for future employment development.

Stewart Milne Homes (539251) requests that Auchterarder should be identified as a Strategic Development Area and shown in Table 1 on page 15 of the Proposed Plan.

Wallace Planning Ltd for National Grid (547863) requests that "Dundee Centre and Port Strategic Development Area" includes "Dock Street" which includes the gas holder site.

174 TAYPLAN STRATEGIC DEVELOPMENT PLAN Summary of responses (including reasons) by planning authority:

RESPONSES TO REPRESENTATIONS SEEKING CHANGE

An assessment of strategic sites was undertaken as part of TAYplans Background Technical Note 2010 (pages 119-127) (013/SL/Doc9) to help understand whether they would impact on important environmental designations and any possible infrastructure implications. The sites assessed were a combination of those already allocated in approved Structure Plans or have planning permission or were submitted by developers during the TAYplan Awareness Raising Initial Consultation in August/September 2009. Some of the sites submitted were considered to be too small and not strategic in significance and were therefore not assessed. These could be assessed as part of the Local Development Plan Process if submitted to the respective Local Authority.

Circular 1/2009 (paragraph 45) (013/SL/Doc10), the Scottish Government considers it good practice to draw from existing Plans within the first generation of Strategic Development Plans. Paragraph 78 of Circular 1/2009 (013/SL/Doc11) also says that reporters should generally not recommend modifications to parts of plans that have been examined in previous examinations or rolled forward from previous plans, unless circumstances have clearly changed.

In addition, the Proposed Plan stage of the production of a Strategic Development Plan is not the stage for the introduction of alternative sites that have not been considered through the Main Issues Report stage.

ALTERNATIVE STRATEGIC DEVELOPMENT AREAS– GUARDBRIDGE

Issue raised by Alaric Hopgood (548889); Colin McAllister (545660); D Graham Wynd (513279); Flora Selwyn (542815); Howard Greenwell (546652); Irene Duncan (547693); Mrs Judith Harding (377831), Miss Marianne Baird (544315); Roy de C Chapman (548419); Miss Sarah Hunt (548386); St. Andrews Greenbelt Forum (328791) and St. Andrews Preservation Trust (547750) It is considered that the former paper mill at Guardbridge is not of a scale or site size (9.6 hectares) that would be considered to be a potential Strategic Development Area in its own right. The Approved Fife Structure Plan (2009) (CL/Doc39) does not identify it as a Strategic Development Area and considers that smaller scale developments will be identified in through its Local Plans and future Local Development Plans. TAYplan Topic Paper 6 – Spatial Strategy (paragraph 5.10) (013/SL/Doc12) specifically mentions the potential for development at Guardbridge, in particular the regeneration of the former paper mill, but will, be of a scale and function of development which reflects the role of a tier 3 settlement.

Scottish Environment Protection Agency also advised that the development of the former paper mill site could be contrary to Scottish Government guidance as it lies within the 200 year coastal flood envelope and should be the subject of a Flood Risk Assessment. This may mean that not all of the 9.6 hectares would be developable.

It is also important to note that St. Andrews University has confirmed in their representation (PLAN732) to the Proposed Plan that it has purchased the former paper mill with the intention to develop an Energy Centre with the heat and power piped to St. Andrews. The remainder of the site could be developed for related uses such as accommodating spin off companies involved in energy research, community and commercial activities. This is in addition to the Science Park element of the St Andrews. Strategic Development Area.

175 TAYPLAN STRATEGIC DEVELOPMENT PLAN In addition the area indicated for the University Science Park as part of the St. Andrews Strategic Development Area will be close to the A91, existing facilities and activities on land in the control of the University. It would therefore seem sensible to locate the proposed Science Park in a location close to existing University facilities. Fife Structure Plan 2009 (page 18) (013/SL/Doc13) is also clear that a large proportion of the required housing for St. Andrews should be located to the west of the town and in particular the Strategic Land Allocation. The Finalised St. Andrews and East Fife Local Plan 2009 also promotes (page 87) (013/SL/Doc14