Representation to East Lothian Council, Local Development Plan, Main Issues Report Historic Lothian Protection & Development Ltd – Land at East Fortune Hospital The Site The site comprises the former East Fortune Hospital located within the settlement of East Fortune, East Lothian. The site is 17.2 hectares in size and is long, linear and largely flat. The site is bounded to the north by the B1377. It is contained by the farmland associated with East Fortune airfield to the south and west. East Fortune Steading abuts the site to the north west and the eastern boundary of the site is contained by existing housing. The site previously formed part of the East Fortune airfield when it was constructed as a base for fighter planes and airships in 1915 during World War I. It was then developed to house East Fortune Hospital in 1922 until it closed in 1997. Since then the since has been vacant. The site contains 7 B listed buildings. These all formed part of the original airship station. The remainder of the buildings formed part of East Fortune Hospital and are not listed but are within the curtilage of the listed buildings. All of the buildings within the site are now in an advanced state of disrepair and dereliction and are known to contain asbestos which will require removal. Due to their continued vacancy, the site attracts anti-social and criminal behaviour and is a local eyesore. East Fortune airfield to the south is a Scheduled Ancient Monument. The site contains large areas of woodland and planting and some individual mature trees, all of which are covered by a Tree Preservation Order. While the site’s location is rural, it is not isolated. There are a range of services and leisure and tourism uses in the vicinity of the site, making it an active part of East Lothian. These include the National Museum of Flight, East of Scotland Microlights, the Melville Motor Club which uses sections of the former runway for race track events, and the East Fortune Market which takes place every Sunday. Brand Leisure runs a caravan site to site’s immediate north at East Fortune Farm and the Flag Heritage Centre at Athelstaneford also attracts visitors to the area. The site is circa 2 miles from shops and services at East Linton and circa 2 miles from Drem which has a train station. It is 2 miles from Athelstaneford and the Primary School which serves East Fortune. Haddington and North Berwick are local employment centres in addition to Edinburgh which is accessible by rail from Drem. Policy Context for Site The site is currently covered by policy ENV12: Former East Fortune Hospital in the Adopted East Lothian Local Plan. This policy is highlighted as “Requiring Minor Review” in the Main Issues Report (Appendix 6) and Question 26 seeks views on this. 1 The terms of ENV12 are as follows: “The Council supports the use of the former East Fortune Hospital for employment, leisure or tourism uses. All proposals should safeguard and secure the long-term maintenance of the Listed Buildings and their setting. A housing use will only be acceptable as enabling development to secure this and is further conditional upon: 1. satisfactory provision for the retention and long term maintenance of the 7 Listed Buildings; and 2. any housing being limited in number and size of units to that agreed with the Council on the basis of what is judged the minimum necessary by independent assessment to secure (1) above; and 3. availability of infrastructure, including education capacity” Planning History The site was subject to a series of planning applications throughout the 1990’s, none of which were granted planning consent. The most recent planning application was lodged by Historic Lothian Protection & Development in 2005 (ref 05/00357/OUT). This applied for outline planning consent for the development of 56 homes, 6 of which were to be affordable. The application proposed the retention of the listed buildings and a number of the unoccupied buildings on site. These, the application stated, would be subject to a subsequent planning application for their conversion at a later stage. The application was recommended for approval by East Lothian Council’s planning officers. The Officer commented in his report that: • At no time since 1998 has anyone sought of the Council planning permission for any employment, leisure or tourism use of the site. • The Council’s Policy & Projects Manager advises that there has been no interest in the site for any such uses. • Therefore, it would not be unreasonable to consider a residential development provided it can meet the remaining three conditions of policy ENV12. However it was refused at Committee on 6th October 2009 on the following grounds 1: a) That the enabling development would not meet the requirement of Policy ENV12 in that was not associated with a proposal for the site which envisages employment, leisure or tourism uses whilst safeguarding and securing long term maintenance of the listed buildings. 1 See Minute of Planning Committee 6 th October 2009 (Appendix A) 2 b) That a satisfactory enabling housing development would not be achievable in accordance with Part 5 of Policy DC1 by virtue of its proximity to a large area of dereliction with no immediate prospect of use of remedial action, with resultant implications for the amenity and security of residents. The Planning Committee Convenor commented at the time that further housing could be approved for the site if it was part of a multi-faceted application which included a masterplan for the site. The lack of interest in the site for uses other than residential, and the failure of an application to gain planning consent at Committee despite satisfying local authority officers, and the continued slide of the site into dereliction are all indicators that the terms of policy ENV12 require updating in order to facilitate development on the site. MIR Response to Site Circular 6/2013 requires planning authorities to monitor the impact of policies and proposals of the existing plan. A Monitoring Statement should take account of these impacts and form an evidence base of the plan (para 61). This informs the Main Issues Report which identifies where key change have occurred since the last plan. Question 26 of the East Lothian MIR confirms that the Monitoring Statement indicates where and how it is intended to promote for the LDP a “minor review “ of existing local plan policies and the introduction of new policies, inviting comments on these. In relation to Policy ENV12: East Fortune Hospital, the Monitoring Statement states: “No planning applications for redevelopment of the site have been received for the site during the Local Plan period so the policy has not been applied. A site submission promoting the site for development has been received in the call for sites for the MIR.” The Statement goes on: “This policy remains relevant. The East Fortune site continues to require a planning policy to guide its future development including that of its recently reaffirmed listed buildings. Review to ensure the policy remains clear and reaffirms the need to ensure a long term future for the listed buildings.” It is concluded that the policy should therefore be reviewed and amended. Historic Lothian Protection & Development Ltd agrees with this approach. The failure of the site to be developed indicates that the policy is not providing developers with sufficient clarity or certainty regarding development at this location. Other local authorities such as Midlothian Council have taken far more positive approach to promoting enabling development to secure listed buildings (e.g. the allocation of land at Roslynlee Hospital, Penicuik for 120-300 homes). 3 It is also disappointing that East Lothian Council has failed to establish that policy ENV12 has indeed been applied in the Local Plan period. While the last application for the site was received in 2005, it was determined in 2009, with Policy ENV12 being a determining issue. Moreover, there are significant lessons to be learnt from the Committee’s deliberations of that planning application and its implications for policy ENV12. Proposed Policy The following are the grounds for revising policy ENV12: a) Lack of demand for employment/tourism/leisure uses at this location b) The need for a holistic solution with additional housing. c) Clarity is required regarding the future use of the listed buildings. d) The need to recognise additional costs associated with the redevelopment of the site. It is proposed that ENV12 should be modified as follows: “As a means to support the protection and bringing back into use listed buildings on the site, residential development is supported at the former East Fortune Hospital. The listed structures are not suitable for residential use, however residential development will be acceptable on the remainder of the site to support their ongoing retention, reuse and maintenance. The site can accommodate 50-200 homes. A masterplan will be required to establish an appropriate scale of development and how development will relate to the remaining structures and the landscape setting of the site. Employment, leisure and tourism uses will also be supported within the site. Development is further conditional upon: 1. Satisfactory provision for the retention and long term maintenance of the 7 Listed Buildings; and 2. The ability of the development to secure the demolition / conversion of remaining buildings on site / removal of asbestos / introduction of alternatives uses if proposed /appropriate planning obligations; and 3. Availability of infrastructure, including education capacity.” 4 Justification a) Lack of demand for employment/tourism/leisure use An Employment Land and Property Market Review for the East Fortune Hospital site was undertaken by Ryden in 2014 2.