Issue 1 Vision and Objectives LDP2020_MIR_PP4_VI Primary Policies - The Vision Main Issues Report LDP2020_MIR_Q1 Question 1 - Do you agree with the proposed reference: vision and objectives? Body or person(s) submitting a representation raising the issue (including reference number): 000285 RSPB Scotland 000442 Mr And Mrs Mark And Beverly Ellis 000480 Scotia Homes Ltd Emac Planning LLP 000569 SEPA 001027 Scottish Natural Heritage 001035 Homes For Scotland 001524 Scottish Water 001723 Mr Ian Rippon 001815 Force 9 Energy Partners LLP 001816 Joanna Taylor Rafford Consulting 001818 Woodland Trust Scotland 001746 Whitbread Group plc 001862 EDF Energy Planning authority’s summary of the representation(s): Support for Vision Scottish Natural Heritage 001027 SNH welcome the recognition of the important role that the environment plays in Moray and its inclusion in the vision and plan aims/objectives. Scottish Water 001524 Agree in principle with the proposed vision and objectives. Mr And Mrs Mark And Beverly Ellis 000442 Agree with the proposed vision and objectives. Scotia Homes Ltd 000480 Scotia Homes Ltd agrees with the proposed vision and objectives. Homes For Scotland 001035 Homes for Scotland (HFS) supports the overarching vision of the Moray LDP 2020 MIR which promotes Moray as a place in which people want to live, work and invest. The focus on a generous supply of land for housing, the necessary infrastructure to support new development, and importantly the investment to support the level of new development required in Moray are objectives which are fully supported by HFS. HFS member companies play an important role in delivering the vision and the plan aims and objectives are vital to this. By setting strong objectives the tone is clearly set for the rest of the Plan to positively and ambitiously plan for growth in Moray. RSPB Scotland 000285 RSPB broadly welcome the proposed vision and objectives. In particular, the final two bullet points to protect and enhance the natural environment and improve resilience are welcomed. SEPA 000569 SEPA agrees with vision and objectives and welcome specifically the Plan Aims/Objectives of: Apply a placemaking approach to development to create sustainable, welcoming, well connected and distinctive places that are safe, healthy and inclusive, Encourage efficient use of land and promote low carbon and sustainable development, Protect and enhance the built and natural environment, Improve resilience of the natural and build environment to climate change. Arable Land and Brownfield Sites Mr Ian Rippon 001723 Would like to see added to the Vision “Maintain the same area of arable land and woodland”. This is to ensure prudent use of natural resources and to create some tension between the use of the existing productive land, and releasing land for housing. Otherwise it is too easy to release more and more arable land and woodland for building. Queries how new people will be fed if arable land is lost. Development of brownfield sites must be a priority over greenfield sites. Notes Moray doesn’t have a lot of brownfield sites, but what it does have should be fully utilised, before Greenfield sites are eaten into. Health and Wellbeing and A96 dualling Joanna Taylor 001816 While these objectives are laudable wish to see a specific objective about maintaining and enhancing the physical and mental well-being of the population included in the objectives. The value of the plan, and feedback to that plan, is significantly reduced by the uncertainty arising from the lack of clarity on the routing and timing of a dualled A96, which will not be known until later in the year. Many of the detailed suggestions in the plan will need to be reconsidered once the A96 route is known. Additionally there will be other matters that will need planning for once the route is known. It would be helpful to have this acknowledged formally by the Council. Tourism Whitbread Group Plc 001746 The Vision should support growth in the tourist and visitor economy, including expansion of existing hotel facilities. Infrastructure Woodland Trust Scotland 001818 Agree with this vision. Strong policies are needed to guide this vision, particularly regarding the outstanding quality of the environment which requires protection and enhancement. The objectives are good, however, the objective 'Identify and provide for new social and physical infrastructure to support the expanding population whilst safeguarding existing infrastructure' could also touch on the preference to build on existing infrastructure before planning to expand further. In this way precious land and habitats can be saved for other environmental uses, such as woodland expansion. Encouraging building on existing infrastructure is desirable, as it would prevent further undesired and inappropriate development in the wider landscape of Moray, presented in MIR 6. Renewable Energy Force 9 Energy Partners LLP 001815 Vision is welcomed but should recognise the Scottish Government's desire to robustly address climate change and the vision set out in the Scottish Energy Strategy to have a flourishing, competitive local and national energy sector, delivering secure affordable, clean energy for Scotland's households, communities and business. SES specifically states that the Scottish Government will push for UK wide policy support for onshore wind given that this is now amongst the lowest cost forms of power generation of any kind, and is a vital component of the huge industrial opportunity that renewables create for Scotland. The themes and thrust of the Scottish Government's Onshore Wind Policy Statement should also be recognised in the proposed LDP vision. The Statement says that "our energy and climate change goals mean that onshore wind will continue to play a vital role in Scotland's future." Submit that the following should be included in the Plan aims/ objectives; recognise the important opportunities that renewable energy provides recognise the important role of renewable energy, including onshore wind, and energy infrastructure in the right places provide a framework to ensure Moray works to ensure that the energy sector delivers secure affordable and clean energy to its households, community and businesses. Vision should make clear that Moray Council supports sustainable development, suggest “Support economically, environmentally and socially sustainable development” is added to Vision. EDF Energy 001862 The Vision is too simplistic and narrow. No reference within the MIR to the Scottish Energy Strategy (SES) by the Scottish Government . This sets a 2050 ‘vision’ for energy in Scotland. The draft Climate Change Bill is an important consideration to be read alongside the Scottish Climate Change Plan (CCP). These together with the SES and the Onshore Wind Policy Statement (OWPS) contain challenging targets related to renewable energy, electricity and emissions reduction, stretching out to 2050. The only objective that links to energy is the sixth, which seeks to “encourage efficient use of land and promote low carbon and sustainable development”. That seems to relate to decarbonising urban form and more conventional forms of development as opposed to facilitating and encouraging renewable energy generation. There is no mention whatsoever of renewable energy within the vision, aims and objectives. Suggests the Council look at the vision for Dumfries and Galloway LDP2. The Council should not take a view that there are no opportunities for further renewable energy development in Moray because of the findings of its Landscape Capacity Study with regard to wind energy. The Council’s approach that there is no further or only very limited capacity for further wind energy development is wrong, and one that is contrary to the Governments clear policy at the national level. An important objective should be to ensure that Moray supports the continued growth of the renewable energy sector – this can be by way of supporting and encouraging new developments, but also by facilitating the implementation of technological developments that maximise the efficiency and energy yield from existing operational assets. Moray is host to operational renewable energy developments and this is an important consideration to help sustain renewable energy generation and carbon emission targets in the long term. For these reasons we do not agree with the proposed vision and objectives. Officers comments on representations and recommendations: Support for Vision Support for the Vision noted. Arable Land and Brownfield Sites Maintaining the same level of arable land and woodland is not considered to be a realistic objective. The objectives already include “Encourage efficient use of land..” and it is noted that policy DP1 Development Principles requires development to avoid sterilising significant workable reserves of minerals, prime agricultural land or productive forestry. Requiring brownfield sites to be utilised before greenfield sites would unreasonably constrain growth. Recommendation No change to Vision objectives with regard to arable land and brownfield sites as a result of consultation response. Health and Wellbeing and A96 dualling The Vision objectives already note the importance of placemaking to health. The health benefits of good placemaking are discussed further in the justification for policy PP1 Placemaking. The Vision does not need to be amended. The Planning Authority is legally required to adopt a new Local Development Plan every 5 years. Therefore it was not possible to wait for